WORLD

RESOURCES
INSTITUTE

CCS GUIDELINES

Guidelines for
Carbon Dioxide Capture, Transport, and Storage

Authors and Editors

Sarah M. Forbes, World Resources Institute
Preeti Verma, World Resources Institute
Thomas E. Curry, M.J. Bradley and Associates LLC
Dr. S. Julio Friedmann, Lawrence Livermore National Laboratory
Sarah M. Wade, AJW, Inc.

CCS GUIDELINES

Contributing Stakeholders
Jorg Aarnes, DNV Energy

Jennifer Johnson, Great Plains Institute

Scott Anderson, Environmental Defense Fund

Joy Kadnar, U.S. Department of Transportation

Peta Ashworth, CSIRO

Robert Kane, U.S. Department of Energy Office of Fossil Energy

Jeff Bielicki, Harvard University

Anhar Karimjee, U.S. Environmental Protection Agency (observer)

Larry Boggs, General Electric

Tom Kerr, International Energy Agency

Judith Bradbury, Pacific Northwest National Laboratory

Asteghik Khajetoorians, BP America, Inc.

Jay Braitsch, U.S. Department of Energy Office of Fossil Energy

Dan E. Kieke, Chevron Energy Technology Company

Grant Bromhal, National Energy Technology Laboratory

Bruce Kobelski, U.S. Environmental Protection Agency (observer)

Frank Burke, on behalf of the National Mining Association

Peter Lidiak, American Petroleum Institute

Keith Burnard, AEA Energy and Environment UK

John Litynski, National Energy Technology Laboratory

David Coleman, Shell Exploration and Production Co.

Cliff Lowe, Chevron

David Conover, National Commission on Energy Policy

Sasha Mackler, National Commission on Energy Policy

Michael Cox, Hydrogen Energy International LLC

Philip Martson, Martson Law

Steven Crookshank, American Petroleum Institute

Marty McBroom, American Electric Power

David Curtiss, American Association of Petroleum Geologists

Sean McCoy, Carnegie Mellon University

Heleen de Coninck, Energy Research Centre of the Netherlands

Steve Melzer, Melzer Consulting

Jan Wilco Dijkstra, Energy Research Center of the Netherlands

Jim Meyers, Contek Solutions LLC

Michael Donlan, Industrial Economics, Incorporated

Kenneth Michie, Anadarko Petroleum Corporation

Andrew Duguid, Schlumberger Carbon Services

Rachel Miller, BP America, Inc.

Richard Esposito, Southern Company Services, Inc.

Bruce Nestleroth, Battelle

Robert Finley, Illinois State Geological Survey

Robin Newmark, Lawrence Livermore National Laboratory

Elizabeth Fleming, Shell Exploration & Production Americas

Karen Obenshain, Edison Electric Institute

Sarah Glenn, Shell Oil Company

Babatunde Oyenekan, Chevron Energy Technology Company

Tim Grant, National Energy Technology Laboratory

Rajesh J. Pawar, Los Alamos National Laboratory

Sallie Greenberg, Illinois State Geological Survey

Naomi Pena, Pew Center on Global Climate Change

Lee Gresham, Carnegie Mellon University

George Peridas, Natural Resources Defense Council

Tom Grieb, Tetra Tech

Edward Rubin, Carnegie Mellon University

Heleen Groenenberg, Energy Research Centre of the Netherlands

David Schmalzer, Argonne National Laboratory (retired)

Neeraj Gupta, Battelle

Gregory Schnaar, AAAS Fellow, U.S. Environmental Protection Agency (observer)

George Guthrie, Los Alamos National Laboratory

Simon Shackley, independent researcher

Megan Guy, Goldman Sachs

Gary Spitznogle, American Electric Power

David Haines, Shell Exploration & Production Americas

Terry Surles, WESTCARB

Richard Halvey, Western Governors Association

Kate Swayne, Marsh, Inc.

Ken Havens, Kinder Morgan

Ron Sweatman, Halliburton

Ian Hayhow, Natural Resources Canada

Matt Toner, Hydrogen Energy International LLC

Ken Hendricks, Anadarko Petroleum Corporation

Chiara Trabucchi, Industrial Economics, Incorporated

Howard Herzog, Massachusetts Institute of Technology

Karen Utt, Xcel Energy

Gardiner Hill, BP Alternative Energy

John Venezia, ICF International

Raja Jadhav, Chevron Energy Technology Company

Robert Van Voorhees, Bryan Cave LLP

Mike Hirl, Kinder Morgan

Kurt Waltzer, Clean Air Task Force

Ken Hnottavange-Telleen, Schlumberger Carbon Services

Ann Weeks, Clean Air Task Force

Sue Hovorka, University of Texas at Austin

Elizabeth Wilson, University of Minnesota

Scott Imbus, Chevron Energy Technology Company

Andy Wolfsberg, Los Alamos National Laboratory

Nick Irving, Southern Company

Michael Wolosin, Pew Center on Global Climate Change

Matthew Jaruzel, Peabody Energy

Iain Wright, BP Alternative Energy

Melanie Jensen, Plains CO2 Reduction Partnership

CCS GUIDELINES

WRI

CCS Guidelines
Guidelines for Carbon Dioxide Capture, Transport, and Storage
Cite as:
World Resources Institute (WRI). CCS Guidelines:
Guidelines for Carbon Dioxide Capture, Transport, and Storage.
Washington, DC: WRI.
Published by
World Resources Institute
10 G Street, NE
Suite 800
Washington, DC 20002
2008 World Resources Institute

CCS GUIDELINES

Each World Resources Institute report presents a timely, scholarly

treatment of a subject of public concern. WRI takes responsibility for
choosing the study topics and guaranteeing its authors and
researchers freedom of inquiry. It also solicits and responds to the
guidance of advisory panels and expert reviewers. Unless otherwise
stated, however, all the interpretation and findings set forth in WRI
publications are those of the authors. You can purchase publications
online through the World Resources Institute Online Bookstore at
http://www.wristore.com/.

The full report is available online at www.wri.org. Materials may be

reproduced with the written permission of the World Resources Institute.
ISBN 978-1-56973-701-9

The CCS Guiding Principles

1. Protect human health
and safety.

2. Protect ecosystems.

3. Protect underground
sources of drinking
water and other
natural resources.

4. Ensure market
confidence in emission
reductions through
regulatory clarity and
proper GHG accounting.

5. Facilitate cost-effective,
timely deployment.

Guidelines for
Carbon Dioxide Capture, Transport, and Storage

CCS GUIDELINES

ACKNOWLEDGMENTS
This publication is the collective product of a carbon dioxide capture
and storage (CCS) stakeholder process convened by the World
Resources Institute (WRI) between February 2006 and September
2008. The unique perspectives and expertise that each participant
brought to the process were invaluable to ensuring the development
of a robust and broadly accepted set of technical guidelines for CCS.
This publication would not have been produced without the
leadership of WRI Climate and Energy Program Director Jonathan
Pershing and the authors and editors who demonstrated outstanding
commitment and diligence throughout the process. WRI would like to
thank BP and the Pew Charitable Trust for their financial support, as
well as all those stakeholders who generously provided in-kind
contributions of their time and expertise.

We are thankful for the early leadership and management of this

initiative by former WRI staff members Jeffrey Logan and John
Venezia. We would also like to thank the WRI peer reviewers
(Elizabeth Cook, Joseph Foti, Stephen Russell, and Neelam Singh) and
the external peer reviewers (John Coequyt, Ben Hengst, Jeffrey Logan,
Gregory Schnaar, and Gabriella Von Goerne) for their thoughtful review
of the document prior to publication and Greg Fuhs and Seth Ort for
their careful copy edit. This work and the stakeholder process also
benefited substantially from the strategic insights and reviews of WRI
staff members Janet Ranganathan and Debbie Boger.

DISCLAIMER
This document, designed to provide guidance to CCS project
developers, regulators, and policymakers, has been developed
through a diverse multi-stakeholder consultative process involving
representatives from business, nongovernmental organizations,
government, academia, and other backgrounds. While WRI encourages the use of the information in this document, its application
and the preparation and publication of reports based on it are the
full responsibility of its users. Neither WRI nor the individuals who
contributed to the Guidelines assume responsibility for any
consequences or damages resulting directly or indirectly from their
use and application.

TABLE OF CONTENTS
EXECUTIVE SUMMARY
GUIDELINES

8
12

Part 1

Introduction

19

Part 2

Capture

23

2.1 INTRODUCTION

23

2.2 TECHNOLOGY OVERVIEW

2.2.1 Capture from Power Plants
2.2.1.1 Post-Combustion Capture
2.2.1.2 Pre-Combustion Capture
2.2.1.3 Oxy-Fuel Combustion
2.2.2 Capture from Industrial Sources
2.2.3 Capture Economics
2.2.4 Managing Carbon Dioxide and Co-Constituents

24
25
27
28
28
29
31
32

Capture Guideline 1: Recommended Guidelines for CO2 Capture

35

2.3 NON-CO 2 ENVIRONMENTAL IMPACTS

2.3.1 Air Emissions
2.3.1.1 New Source Performance Standards and New Source Review
2.3.2 Water Use
2.3.3 Solid Waste

35
37
38
39
40

Capture Guideline 2: Recommended Guidelines for Ancillary Environmental Impacts from CO2

40

Part 3

41

Transport

41
42
42

3.2 PIPELINE DESIGN AND OPERATIONS

3.2.1 Pipeline CO2 Composition
3.2.2 Pipeline Operating Temperature and Pressure
3.2.3 Pipeline Design

43
43
44
45

Transport Guideline 1: Recommended Guidelines for Pipeline Design and Operation

47

CCS GUIDELINES

3.1 INTRODUCTION
3.1.1 Developing CO2 Pipeline Infrastructure for CCS
3.1.2 CO2 Pipeline Operating Experience

CCS GUIDELINES
6

3.3 PIPELINE SAFETY AND INTEGRITY

3.3.1 Pipeline Safety Regulations
3.3.2 Comparative Safety of CO2 Pipelines
3.3.3 Environmental Health and Safety
3.3.4 Addressing Potential Public and Environmental Concerns

47
47
47
47
48

Transport Guideline 2: Recommended Guidelines for Pipeline Safety and Integrity

48

3.4 CO 2 PIPELINE SITING REGULATION

3.4.1 Siting of CO2 Pipelines

49
49

Transport Guideline 3: Recommended Guidelines for Siting CO2 Pipelines

50

3.5 PIPELINE ACCESS AND TARIFF REGULATION

51

Transport Guideline 4: Recommended Guidelines for Pipeline Access and Tariff Regulation

52

Part 4

53

Storage

4.1 INTRODUCTION
4.1.1 Terminology
4.1.2 Organization of the Storage Guidelines
4.1.3 Carbon Storage Performance Expectations
4.1.4 Implications of Potential Deployment Pathways
4.1.4.1 CO2 Sources
4.1.4.2 CO2 Transport
4.1.4.3 Reservoir Types and Project Sizes
4.1.5 Identification of Storage Issues Addressed in the Guidelines
4.1.5.1 Specific Stages of a Storage Project
4.1.5.2 Cross-Cutting Issues

53
53
54
54
55
56
56
56
56
56
57

4.2 INTEGRATION WITHIN AND AMONG CCS PROJECTS

4.2.1 Integration Within a CCS Project
4.2.1.1 Timeline for a Theoretical Project
4.2.2 Integration Among Storage Projects: Basin-Scale Management

60
60
61
62

4.3 DETAILED DISCUSSION OF STEPS INVOLVED IN IMPLEMENTING A STORAGE PROJECT

4.3.1 Cross-Cutting Issues
4.3.1.1 Measurement, Monitoring, and Verification
 Key Monitoring Parameters
 Developing a Project-Specific Monitoring Plan

64
64
64
65
67

Storage Guideline 1: Recommended Guidelines for MMV

70

4.3.1.2 Risk Assessment

 Hazard Identification
 Evaluation of Receptor Impacts
 Risk Management
 Mitigation or Remediation Planning

72
72
74
76
76

Storage Guideline 2: Recommended Guidelines for Risk Assessment

4.3.1.3 Financial Responsibility
Storage Guideline 3: Recommended Guidelines for Financial Responsibility
4.3.1.4 Property Rights and Ownership
Storage Guideline 4: Recommended Guidelines for Property Rights and Ownership
4.3.2 Project Stage Issues
4.3.2.1 Site Characterization and Selection
 The Goal of Site Characterization
 A Conceptual Approach to Site Characterization and Selection
 Key Factors in Reservoir Suitability
 Site Characterization as an Operational Concern
 Injection Scale
 Emerging Tools for Screening Sites
 Site Characterization and SelectionSummary
Storage Guideline 5: Recommended Guidelines for Site Selection and Characterization
4.3.2.2 Operations
 Operational Planning and Management
 Timing and Staging
 Site Preparation and Well Construction
 Injection Guidelines
Storage Guideline 6: Recommended Guidelines for Injection Operations
4.3.2.3 Managing the End of a Storage Project: Site Closure and Post-Closure
 Site Closure
Storage Guideline 7: Recommended Guidelines for Site Closure


Post-Closure

78
78
80
80
82
83
83
83
84
85
89
89
89
90
91
92
92
93
94
95
97
98
98
103
104

Storage Guideline 8: Recommended Guidelines for Post-Closure

104

Part 5

105

Supplementary Information

106
120
121
122
127
132
143
143
144

CCS GUIDELINES

Glossary and Acronyms

Appendix A: Early WRI CCS Stakeholder Meetings
Appendix B: Guidelines for Policymakers
Appendix C: Guidelines for Regulators
Appendix D: Guidelines for Project Developers and Operators
Bibliography
List of Figures
List of Tables
Photo Credits

EXECUTIVE SUMMARY
The Carbon Dioxide Capture and Storage (CCS) Guidelines effort
was initiated to develop a set of preliminary guidelines and
recommendations for the deployment of CCS technologies in the
United States, to ensure that CCS projects are conducted safely and
effectively. As such, the CCS Guidelines are written for those who
may be involved in decisions on a proposed project: the developers,
regulators, financiers, insurers, project operators, and policymakers.
These Guidelines are intended to guide full-scale demonstration of
and build public confidence in CCS technologies by informing how
projects should be conducted.
Worldwide increases in energy demand coupled with a continued
reliance on fossil fuel resources have contributed to a significant
increase in atmospheric levels of carbon dioxide (CO2). This increase
shows no signs of slowing. According to the International Energy
Agencys (IEAs) World Energy Outlook 2007, the projected growth
in energy demand will translate into a 57 percent rise in energyrelated CO2 emissions by 2030 (IEA 2007). Others argue especially
in the recent high energy price environmentthat global energy
demand will be much lower than the IEA forecast.
Scenarios for stabilizing climate-forcing emissions suggest
atmospheric CO2 stabilization can only be accomplished through the
development and deployment of a robust portfolio of solutions,
including significant increases in energy efficiency and conservation
in the industrial, building, and transport sectors; increased reliance
on renewable energy and potentially additional nuclear energy
sources; and deployment of CCS. Slowing and stopping emissions
growth from the energy sector will require transformational
changes in the way the world generates and uses energy.

CCS GUIDELINES

CCS is a broad term that encompasses a number of technologies

that can be used to capture CO2 from point sources, such as power
plants and other industrial facilities; compress it; transport it mainly
by pipeline to suitable locations; and inject it into deep subsurface
geological formations for indefinite isolation from the atmosphere.
CCS is a critical option in the portfolio of solutions available to
combat climate change, because it allows for significant reductions
in CO2 emissions from fossil-based systems, enabling it to be used
as a bridge to a sustainable energy future.

In technology development there is a period referred to as the

valley of death, where a technology has been proven in the laboratory and on a small scale, but has yet to become commercially
viable. CCS technology has progressed quickly from being a concept
to a key part in proposed climate change mitigation plans. This
progression is partly the result of early successes in pilot capture
demonstrations and field validation tests, where small volumes of
CO2 have been injected for research purposes. It is also due in large
part to the experience that has been gained injecting CO2 for
enhanced oil recovery over the past three and a half decades. There
are skeptics who believe that CCS remains infeasible, with
continued interest driven by the lack of any other viable solution
that would allow the continued use of coal. To achieve the potential
benefits of CCS and prove that safe and permanent storage can be
realized, it is important to continue large-scale demonstration and
deployment of this technology.
Although the CCS industry is still in its formative stages, in developing the CCS Guidelines participants were able to draw from a
wealth of information, analogous regulatory experience, and
industrial best practices. As the knowledge and understanding of
the suite of CCS technologies grow, these Guidelines will be revised to reflect emerging best practices. The potential for further
development is most evident where the CCS Guidelines identify
areas for additional research and, hence, suggest that extra care
be taken during the early deployment phase.
This effort has progressed in the context of a swiftly changing
regulatory landscape of CCS-specific regulations emerging at the
U.S. federal and state levels. The CCS Guidelines complement these
efforts by focusing a group of experts on specific issues in order to
examine, describe, and explain best practices for the implementation
of specific projects. In addition, the Guidelines introduce some larger
policy issues that go beyond the regulatory frameworks proposed by
federal and state governments. Appendices B, C, and D categorize
the Guidelines according to the intended implementing audiences:
Appendix B presents information intended for Congress, Appendix C
presents information intended for regulators, and Appendix D
presents information intended for operators.

A key finding of the stakeholder process is that

even though additional research is needed in some areas,
there is adequate technical understanding to safely conduct
large-scale demonstration projects.

projects: fossil energy, electric utility, insurance and service

providers. These experts represent a variety of disciplines, including
engineering, finance, economics, law, and social science. To have
the technical discussions needed to arrive at a robust set of
guidelines, all stakeholders agreed to focus the discussions and
guidelines on how and not whether to implement a CCS project.
These Guidelines are written in the U.S. context, since the
stakeholder process involved primarily U.S. experts. WRI is in the
process of conducting additional work to customize the Guidelines
for other key countries, taking into account their specific local
conditions and context.

The Process
The purpose of the CCS Guidelines is not to make a case for or
against CCS, but rather to develop practical considerations for
demonstrating and deploying CCS technologies. The starting point
for the CCS Guidelines stakeholder discussions was that CCS will
most likely be needed to achieve the magnitude of CO2 emissions
reduction required to stabilize and reduce atmospheric concentrations of greenhouse gases (GHGs).
These Guidelines represent current understanding of how to
implement CCS technologies. Discussions of the Guidelines were
predicated on the following principles:
1. Protect human health and safety.
2. Protect ecosystems.
3. Protect underground sources of drinking water and other natural
resources.
4. Ensure market confidence in emission reductions through
regulatory clarity and proper GHG accounting.
5. Facilitate cost-effective, timely deployment.

Since this projects inception, rapid expansion of and interest in CCS

technologies have accelerated movement toward the development of regulations and policies to support CCS. As such, the
organizational and individual composition of the contributing
stakeholders has changed over time. The stakeholders listed in this
document contributed by attending workshops on the draft
Guidelines between December 2007 and July 2008, and/or
providing written comments. Other key stakeholders contributed
early on in shaping the Guidelines. A detailed description of the
CCS stakeholder process is provided in Part 1 and Appendix A of
these Guidelines.

Limitations of the Guidelines

These Guidelines address most of the technical issues involved
in the design, implementation, and decommissioning of CCS.
However, it is important to note that there are other important
issues involved in successful scale-up of CCS that were beyond the
scope and expertise of the WRI-convened stakeholder process.
These issues include:
 Procedures for engaging local communities in the design and
implementation of CCS,
 Guidelines on the compensation of property owners regarding
pipeline right-of-way and pore space ownership,

CCS GUIDELINES

To develop the CCS Guidelines, the World Resources Institute (WRI)

convened a diverse group of over 80 stakeholders, including
representatives from academia, business, government, and
environmental nongovernmental organizations (NGOs). Business
participants included those most likely to be involved in CCS

These Guidelines reflect the collective agreement of the contributing

stakeholders, who offered strategic insights, provided extensive
comments on multiple iterations of draft guidelines and technical
guidance, and participated in workshops. The authors and editors
strived to incorporate these sometimes diverse views. In so doing,
they weighed conflicting comments to develop guidelines that best
reflect the views of the group as a whole, and acknowledged
diverging opinions among stakeholders. Although these Guidelines
reflect the collective input of the contributing stakeholders,
individual stakeholders were not asked to endorse them. The
identification of the individual stakeholders should not be interpreted
as, and does not constitute, an endorsement of these Guidelines by
any of the listed stakeholders.

CCS GUIDELINES

10

Application of public right-to-know information disclosure and

third-party verification of operator-submitted information, and
How to address any upstream impacts associated with the
increased use of coal per unit of energy generated as a result
of the energy penalty associated with the use of CCS.

While the Guidelines include references to resources for these

issues, they are not intended to provide a comprehensive treatment
of these issues. Throughout the Guidelines, areas are highlighted
where more research is needed, and the Guidelines can be revised
to reflect emerging best practices as at-scale experience is gained.
Also, many of the policy recommendations (such as the framework
for post-closure stewardship) explore the need for additional
legislation, but without going into detail. Going forward, WRI will
seek opportunities to address these and other issues by convening
appropriate stakeholders and by drawing from experience gained
through other relevant initiatives. Finally, although this first edition
of the Guidelines frames the important policy issues surrounding
GHG accounting, liability, financial incentives, and long-term
stewardship associated with CCS projects, the stakeholders
acknowledge that more discussionand in some cases experience
is needed to propose more robust Guidelines for these important areas.

Who Should Read This Document

These Guidelines present recommendations and best practices for
those involved in the development and implementation of CCS
projects. The document also provides a comprehensive introductory

reference for those new to CCS who seek to understand how to

responsibly conduct projects. A potential operator, financier, insurer,
or regulator can use these Guidelines as a benchmark in evaluating
potential project plans and as a reference on the current technical
understanding of best practices for CCS, and a policymaker can use
them to establish regulatory and investment frameworks that
enable successful and responsible CCS deployments. It is important
to note that these Guidelines are not intended to replace or provide
the detailed technical knowledge that would be required to select
the location for or to design and operate a CCS project. In fact, one
of the findings derived from this process is that each CCS project
will be unique, and a team of qualified experts will be needed to
design and operate each project.

Organization of the Guidelines

The Guidelines are divided into three primary parts: Capture,
Transport, and Storage. Nevertheless, decisions made regarding
the specific configuration of the capture system affect the project
through the final phases of post-closure storage. Similarly, upfront planning regarding the capacity of the storage reservoir in
comparison to the projected CO2 emissions is essential. A CCS
project requires thoughtful integration to ensure that materials are
fit-for-purpose and that the comprehensive impacts of the project
are evaluated both throughout the project chain and through the
expected project life cycle.

These CCS Guidelines were developed by a diverse group

of stakeholders, including over 80 contributers
from academia, business, government,
and environmental nongovernmental organizations (NGOs).
CAPTURE
While entities have commercially deployed CO2 capture technologies
on industrial processes for various purposes, including the production
of streams of CO2 for use in enhanced oil recovery (EOR) and for sale
as a food-grade product, capture technologies have not been
demonstrated on commercial-scale power plants. Demonstration and
potential widespread deployment of capture technologies will require
owners and operators of power plants to learn new processes and
adopt additional safety protocols, but these methods, guidelines, and
regulations are in use in other industries. The current state of CO2
capture technologies and the potential environmental impacts of the
technologies are summarized. The Guidelines also include an analysis
of the existing U.S. regulatory structure for carbon capture and
highlight considerations for deployment.

Next Steps
As CCS technology progresses around the world, an emergent
standard of conduct will evolve for both regulation of CCS as well as
industrial best practices. The CCS Guidelines are intended to inform
those considering CCS policies and regulations in the United
States and those who manage the various aspects of CCS demonstration and full-scale projects. The Guidelines can be revised as
understanding of the technology grows. Additionally, WRI will
leverage this work to develop Guidelines for an international
audience, including work with local stakeholders to develop Guidelines that can be implemented in other countries, such as China.

TRANSPORT
Today, there are well over 3,000 miles of CO2 pipelines in operation
in the United States. This operational experience provides a basis for
the development of a CO2 pipeline infrastructure for CCS. The
Guidelines build on this experience, and are intended to inform
pipeline infrastructure development for widespread deployment of
CCS. The transport element of the CCS Guidelines describes existing
standards for CO2 pipeline design, operational, and regulatory
practices, and identifies potential issues associated with more
geographically diverse transportation of CO2 for the purpose of
geologic storage.

CCS GUIDELINES

STORAGE
The storage plan for an individual site ultimately must reflect the
heterogeneity in local geological conditions, be informed by
knowledge gained during project operations, and be based on
site-specific data. The Guidelines reflect the current understanding
of operational guidelines for permanent underground storage.
Proper site characterization and operation are critical to successful
geologic storage efforts. Also integral to safe and effective geologic
storage is developing a sound measurement, monitoring, and
verification (MMV) plan, conducting a comprehensive risk analysis,
and establishing a plan for the CCS project that includes
considerations for long-term site stewardship.

11

GUIDELINES
Each of the following guidelines has been excerpted
from this document. Please refer to the full text of the
document for an in-depth review of information pertinent
to each guideline.

Capture Guidelines

CCS GUIDELINES

Capture Guideline 1: Recommended Guidelines for CO2 Capture

(Section 2.2, page 35)
a. Demonstrations of all capture approaches (pre-combustion,
post-combustion and oxy-fuel combustion) are urgently needed
on commercial-scale power plants to prove the technologies.
b. There should be recognition of the potential challenges in
achieving the theoretical maximum capture potential before
the technologies are proven at scale. This may necessitate
flexibility in establishing appropriate capture rates for early
commercial-scale projects with the amount of CO2 captured at
a facility dependent on both technology performance and the
specific goals of the project.
c. Standards for the levels of co-constituents have been proposed
by some regulators and legislators; however, there is potential
risk that this could create disincentives for reducing sources of
anthropogenic CO2 if the standard is set too stringently. Ultimately,
the emphasis should be on employing materials, procedures, and
processes that are fit-for-purpose and assessing the environmental impacts of any co-constituents, along with the benefits of
CO2 emissions reduction, as part of a comprehensive CCS risk
assessment. Facility operators, regulators, and other stakeholders
should pay particular attention to potential impacts of
co-constituents in the transport and storage aspects of the project.

12

Capture Guideline 2: Recommended Guidelines for Ancillary

Environmental Impacts from CO2 Capture (Section 2.3, page 40)
a. When constructing a new facility or retrofitting an existing
facility in the United States, operators must comply with
requirements under the Clean Air Act and the Clean Water Act,
as appropriate.
b. Options for minimizing local and regional environmental impacts
associated with air emissions, use of water, and solid waste
generation should be evaluated when considering technologies
for capture.
c. Use of capture technologies could result in hazardous or
industrial waste streams. Operators must follow guidelines and
regulations for the handling and disposal of industrial or
hazardous wastes.
d. Operators should investigate the use of combustion wastes as
beneficial byproducts.

e. Currently, the U.S. Environmental Protection Agency (EPA) is

considering regulation of coal combustion wastes that are sent
to landfills or surface impoundments, or used as fill in surface
or underground mines. Potential impacts of the volume and
concentrations of hazardous materials in the waste stream from
facilities with CO2 capture should be evaluated in this context.

Transport Guidelines
Transport Guideline 1: Recommended Guidelines for Pipeline
Design and Operation (Section 3.2, page 47)
a. CO2 pipeline design specifications should be fit-for-purpose and
consistent with the projected concentrations of co-constituents,
particularly water, hydrogen sulfide (H2S), oxygen, hydrocarbons,
and mercury.
b. Existing industry experience and regulations for pipeline design
and operation should be applied to future CCS projects.

Transport Guideline 2: Recommended Guidelines for Pipeline

Safety and Integrity (Section 3.3, page 48)
a. Operators should follow the existing Occupational Safety and
Health Administration (OSHA) standards for safe handling of CO2.
b. Plants operating small in-plant pipelines should consider
adopting Office of Pipeline Safety (OPS) regulations as a
minimum for best practice.
c. Pipelines located in vulnerable areas (populated, ecologically
sensitive, or seismically active areas) require extra due diligence
by operators to ensure safe pipeline operations. Options for
increasing due diligence include decreased spacing of mainline
valves, greater depths of burial, and increased frequency of
pipeline integrity assessments and monitoring for leaks.
d. If the pipeline is designed to handle H2S, operators should
adopt appropriate protection for handling and exposure.

Transport Guideline 3: Recommended Guidelines for Siting CO2

Pipelines (Section 3.4, page 50)
a. Considering the extent of CO2 pipeline needs for largescale CCS, a more efficient means of regulating the siting of
interstate CO2 pipelines should be considered at the federal
level, based on consultation with states, industry, and other
stakeholders.
b. As a broader CO2 pipeline infrastructure develops, regulators
should consider allowing CO2 pipeline developers to take
advantage of current state condemnation statutes and regulations
that will facilitate right-of-way acquisition negotiations.

The CCS Guidelines are intended to inform

those considering CCS policies and regulations
in the United States and those who manage
the various aspects of full-scale CCS demonstrations.
Transport Guideline 4: Recommended Guidelines for Pipeline
Access and Tariff Regulation (Section 3.5, page 52)
a. The federal government should consult with industry and states
to evaluate a model for setting rates and access for interstate
CO2 pipelines. Such action would facilitate the growth of an
interstate CO2 pipeline network.

Storage Guidelines
Storage Guideline 1: Recommended Guidelines for Measurement
Monitoring, and Verification (MMV) (Section 4.3.1.1, page 70)
a. MMV requirements should not prescribe methods or tools;
rather, they should focus on the key information an operator is
required to collect for each injection well and the overall
project, including injected volume; flow rate or injection
pressure; composition of injectate; spatial distribution of the
CO2 plume; reservoir pressure; well integrity; determination of
any measurable leakage; and appropriate data (including
formation fluid chemistry) from the monitoring zone, confining
zone, and underground sources of drinking water (USDWs).

b. Operators should have the flexibility to choose the specific

monitoring techniques and protocols that will be deployed at
each storage site, as long as the methods selected provide data
at resolutions that will meet the stated monitoring requirements.
c. MMV plans, although submitted as part of the site permitting
process, should be reviewed and updated as needed throughout
a project as significant new site-specific operational data
become available.
d. The monitoring area should be based initially on knowledge of the
regional and site geology, overall site specific risk assessment, and
subsurface flow simulations. This area should be modified as
warranted, based on data obtained during operations. It should
include the project footprint (the CO2 plume and area of
significantly elevated pressure, or injected and displaced fluids).
Groundwater quality monitoring should be performed on a
site-specific basis based on injection zone to USDW disposition.
e. MMV activities should continue after injection ceases as
necessary to demonstrate non-endangerment, as described in
the post-closure section (see Storage Guideline 7d).

CCS GUIDELINES
13

CCS GUIDELINES

Based on this process and the robust set of Guidelines

presented herein, we believe there is sufficient evidence that
CCS projects can be carried out safely and effectively to
warrant quickly moving to full-scale demonstrations.

14

Storage Guideline 2: Recommended Guidelines for Risk

Assessment (Section 4.3.1.2, page 78)
a. For all storage projects, a risk assessment should be required,
along with the development and implementation of a risk
management and risk communication plan. At a minimum, risk
assessments should examine the potential for leakage of
injected or displaced fluids via wells, faults, fractures, and
seismic events, and the fluids potential impacts on the integrity
of the confining zone and endangerment to human health and
the environment.
b. Risk assessments should address the potential for leakage
during operations as well as over the long term.
c. Risk assessments should help identify priority locations and
approaches for enhanced MMV activities.
d. Risk assessments should provide the basis for mitigation/
remediation plans for response to unexpected events; such
plans should be developed and submitted to the regulator in
support of the proposed MMV plan.
e. Risk assessments should inform operational decisions, including
setting an appropriate injection pressure that will not compromise
the integrity of the confining zone.
f. Periodic updates to the risk assessment should be conducted
throughout the project life cycle based on updated MMV data and
revised models and simulations, as well as knowledge gained
from ongoing research and operation of other storage sites.
g. Risk assessments should encompass the potential for leakage
of injected or displaced fluids via wells, faults, fractures, and
seismic events, with a focus on potential impacts to the
integrity of the confining zone and endangerment to human
health and the environment.
h. Risk assessments should include site-specific information, such
as the terrain, potential receptors, proximity of USDWs, faults,
and the potential for unidentified borehole locations within the
project footprint.
i. Risk assessments should include non-spatial elements or
non-geologic factors (such as population, land use, or critical
habitat) that should be considered in evaluating a specific site.

Storage Guideline 3: Recommended Guidelines for Financial

Responsibility (Section 4.3.1.3, page 80)
a. Based on site-specific risk assessment, project operators/
owners should provide an expected value of the estimated
costs of site closure (including well plugging and abandonment,
MMV, and foreseeable mitigation (remediation) action) as part
of their permit application. These cost estimates should be
updated as needed prior to undertaking site closure.
b. Project operators/owners should demonstrate financial assurance
for all of the activities required for site closure.
c. Policies should be developed for adequately funding the postclosure activities that become the responsibility of an entity
assuming responsibility for long-term stewardship, as described
in the Post-Closure section.
d. Because of the public good benefits of early storage projects
and the potential difficulty of attracting investment, policymakers should carefully evaluate options for the design and
application of a risk management framework for such projects.
This framework should appropriately balance relevant policy
considerations, including the need for financial assurances,
without imposing excessive barriers to the design and deployment of CCS technology.
Storage Guideline 4: Recommended Guidelines for Property
Rights and Ownership (Section 4.3.1.4, page 82)
a. Potential operators should demonstrate control of legal rights
to use the site surface and/or subsurface to conduct injection,
storage, and monitoring over the expected lifetime of the project
within the area of the CO2 plume and (where appropriate)
the entire project footprint. Regulators will also need access
for inspection.
b. Continued investigation into technical, regulatory, and legal
issues in determining pore space ownership for CCS is
warranted at the state and federal levels. Additional legislation
to provide a clear and reasonably actionable pathway for CCS
demonstration and deployment may be necessary.
c. MMV activities may require land access beyond the projected
CO2 plume; therefore, land access and any other property
interest for these activities should be obtained.

d. Operators should avoid potential areas of subsurface migration

that might lead to claims of trespass and develop contingencies
and mitigation strategies to avoid such actions.
Storage Guideline 5: Recommended Guidelines for Site
Selection and Characterization (Section 4.3.2.1, page 91)
a. General Guidelines for Site Characterization and Selection
1. Potential storage reservoirs should be ranked using a set
of criteria developed to minimize leakage risks. Future work
is needed to clarify such ranking criteria.
2. Low-risk sites should be prioritized for early projects.
3. As required by regulation, storage reservoirs should not be
freshwater aquifers or potential underground sources of
drinking water.
4. Confining zones must be present that possess characteristics
sufficient to prevent the injected or displaced fluids from
migrating to drinking water sources or the surface.
5. Site-specific data should be collected and used to develop
a subsurface reservoir model to predict/simulate the
injection over the lifetime of the storage project and the
associated project footprint. These simulations should
make predictions that can be verified by history-matching
within a relatively short period of time after initial CO2
injection or upon completion of the first round of wells. The
reservoir model and simulations should be updated
periodically as warranted and agreed with regulators.
6. Saline formations and mature oil and gas fields should be
considered for initial projects. Other formations, such as
coal seams, may prove viable for subsequent activity with
additional research.
b. Guidelines for Determining Functionality of Confining Zones
1. Confining zones must be present and must prevent the
injected or displaced fluids from migrating to drinking water
sources as well as to economic resources (e.g., mineral
resources) or the surface.
2. Operators should identify and map the continuity of the
target formation and confining zones for the project
footprint, and confirm the integrity of the confining zones
with appropriate tools. Natural and drilling or operationally
induced fractures (or the likely occurrence thereof) should
be identified.

3. Operators should identify and map auxiliary or secondary

confining zones overlying the primary and secondary target
formations, where appropriate.
4. Operators should identify and locate all wells with penetrations of the confining zone within the project footprint.
A survey of these wells to assess their likely performance and integrity based on completion records and visual
surveys should be conducted. These data should be made
publicly available.
5. Operators should identify and map all potentially significant
transmissive faults, especially those that transect the
confining zone within the project footprint.
6. Operators should collect in-situ stress information from site
wells and other sources to assess likely fault performance,
including stress tensor orientation and magnitude.
c. Guidelines for Determining Injectivity
1. If sufficient data do not already exist, operators should
obtain data to estimate injectivity over the projected project
footprint. This may be accomplished with a sustained test
injection or production of site well(s). These wells (which
could serve for injection, monitoring, or characterization)
should have the spatial distribution to provide reasonable
preliminary estimates over the projected project footprint.
2. Water injection tests should be allowed in determining
site injectivity.
3. Operators should obtain and organize porosity and permeability measurements from core samples collected at the
site. These data should be made publicly available.
d. Guidelines for Determining Capacity
1. Operators should estimate or obtain estimates of the
projected capacity for storing CO2 with site-specific data
(CO2 density at projected reservoir pressure and temperature)
for the project footprint. This should include all target
formations of interest, including primary and secondary
targets. Capacity calculations should include estimates of
the net vertical volume effectively utilized or available for
storage and an estimate of likely pore volume fraction to be
used (utilization factor).
2. Operators should collect and analyze target formation
pore fluids to determine the projected rate and amount of
CCS GUIDELINES

Throughout the Guidelines,

areas are highlighted where more research is needed,
and the Guidelines can be revised to reflect
emerging best practices as at-scale experience is gained.

15

CO2 stored in a dissolved phase. These data should be

made publicly available as necessary for permitting and
compliance purposes.
3. Operators should obtain estimates of phase-relative permeability (CO2 and brine) and the amount of residual phase
trapping. One possible approach is to use core samples with
sufficient spatial density to confirm the existence of the
trapping mechanisms throughout the site and to allow their
simulation prior to site development. Estimates should be
updated with site-specific monitoring and modeling results.
These data should be made publicly available as necessary
for permitting and compliance purposes.

CCS GUIDELINES

Storage Guideline 6: Recommended Guidelines for Injection

Operations (Section 4.3.2.2, page 97)
a. A field development plan should be generated early on in the
permitting phase.
b. Operators should develop transparent operational plans and
implementation schedules with sufficient flexibility to use
operational data and new information resulting from MMV
activities to adapt to unexpected subsurface environments.
c. Operational plans should be based on site characterization
information and risk assessment; they should include
contingency mitigation/remediation strategies.
d. Storage operators should plan for compressor and well
operations contingencies with a combination of contractual
agreements relating to upstream management of CO2, backup
equipment, storage space, and, if necessary, permits that allow
venting under certain conditions.
e. Wells and facilities should be fit-for-purpose, complying with
existing federal and state regulations for design and construction.
f. The reservoir and risk models should be recalibrated (or
history-matched) periodically, based on operational data and
re-run flow simulations. Immediate updates should be made if
significant differences in the expected and discovered geology
are found.
g. The casing cement in the well should extend from the injection
zone to at least an area above the confining zone.
h. Well integrity, including cement location and performance,
should be tested after construction is complete, and routinely
while the well is operational, as required by regulation.

16

i. Water injection tests should be allowed at all prospective CCS sites.

j. Injection pressures and rates should be determined by well
tests and geomechanical studies, taking into account both
formation fracture pressure and formation parting pressure.
Rules should not establish generally applicable quantitative
limits on injection pressure and rates; rather, site-specific
limitations should be established as necessary in permits.
k. Operators should adhere to established workplace CO2 safety
standards.
l. Operators should implement corrosion management approaches,
such as regularly checking facilities, wells and meters for
substantial corrosion. Corrosion detected should be inhibited
immediately, or damaged facility components should be replaced.
Dehydration of the injectate should be required to prevent
corrosion, unless appropriate metallurgy is installed.
m. Operational data should be collected and analyzed throughout a
projects operation and integrated into the reservoir model and
simulations. The data collected should be used to history-match
the project performance to the simulation predictions.
Storage Guideline 7: Recommended Guidelines for Site Closure
(Section 4.3.2.3, page 103)
a. Continued monitoring during the closure period should be
conducted in a portion of the wells in order to demonstrate
non-endangerment, as described below.
b. For all other wells, early research and experience suggest that
conventional materials and procedures for plugging and
abandonment of wells may be sufficient to ensure project
integrity, unless site-specific conditions warrant special
materials or procedures. A final assessment should include a
final cement bond log across the primary sealing interval of all
operational wells within the injection footprint prior to plugging,
as well as standard mechanical integrity and pressure testing.
c. Operators should assemble a comprehensive set of data
describing the location, condition, plugging, and abandonment
procedures and any integrity testing results for every well that
will be potentially affected by the storage project.
d. Satisfactory completion of post-injection monitoring requires a
demonstration with a high degree of confidence that the
storage project does not endanger human health or the
environment. This includes demonstrating all of the following:

One of the findings derived from this process

is that each CCS project will be unique,
and a team of qualified experts will be needed
to design and operate a site.

or associated mitigation or remediation arising out of the

conduct of post-closure MMV.
f. If one does not already exist in a jurisdiction, a publicly
accessible registry should be created for well plugging and
abandonment data.
g. As a condition of completing site closure, operators should
provide data on plugged and abandoned wells potentially
affected by their project to the appropriate well plugging and
abandonment registry. This would include the location and
description of all known wells in the storage project footprint,
and the drilling, completion, plugging, and integrity testing
records for all operational wells.
h. The site-specific risk assessment should be updated based on
operational data and observations during closure.
Storage Guideline 8: Recommended Guidelines for Post-Closure
(Section 4.3.2.3, page 104)
a. Certified closed sites should be managed by an entity or entities
whose tasks would include such activities as operating the
registries of sites, conducting periodic MMV, and, if the need
arises, conducting routine maintenance at MMV wells at closed
sites over time.
b. These entities need to be adequately funded over time to conduct
those post-closure activities for which they are responsible.

CCS GUIDELINES

1. the estimated magnitude and extent of the project footprint

(CO2 plume and the area of elevated pressure), based on
measurements and modeling;
2. that CO2 movement and pressure changes match model
predictions;
3. the estimated location of the detectable CO2 plume based
on measurement and modeling (measuring magnitude of
saturation within the plume or mapping the edge of it);
4. either (a) no evidence of significant leakage of injected or
displaced fluids into formations outside the confining zone,
or (b) the integrity of the confining zone;
5. that, based on the most recent geologic understanding of
the site, including monitoring data and modeling, the CO2
plume and formation water are not expected to migrate in
the future in a manner that encounters a potential leakage
pathway; and
6. that wells at the site are not leaking and have maintained
integrity.
e. Project operators who have demonstrated non-endangerment
should be released from responsibility for any additional
post-closure MMV, and should plug and abandon any wells
used for post-injection monitoring. At this point, the project can
be certified as closed, and project operators should be released
from any financial assurance instruments held for site closure.
In the event that regulators or a separate entity decide to
undertake post-closure monitoring that involves keeping an
existing monitoring well open or drilling new monitoring wells,
project operators should not be responsible for any such work

17

CCS GUIDELINES
18

A potential operator, financier, insurer, or regulator

can use these Guidelines as a benchmark
in evaluating potential project plans and as a reference on
the current technical understanding of best practices for CCS.

INTRODUCTION

P A R T

WHAT IS CCS?
Carbon dioxide capture and storage (CCS) is the term that applies to an array of technologies through

natural gas refining, ethanol production, and cement manufacturing plants. Once captured, the CO2
gas is compressed into a supercritical phase and transported to a suitable location for injection into
a very deep geologic formation, such as saline reservoirs, mature oil or gas fields, and potentially
unminable coal seams, basalts, or other formations. Once injected, the CO2 is isolated from the

CCS GUIDELINES

which carbon dioxide (CO2) is captured at industrial point sources, such as fossil-fuel combustion,

19

drinking water supplies and prevented from release into the

atmosphere by a primary confining zone that includes a dense layer
of rock that acts as a seal and through additional trapping
mechanisms. In general, it is expected that CO2 storage projects
will become more secure over time, as these additional trapping
mechanisms take effect (IPCC 2005, Fig. 5.9).

Why is CCS important?

CCS is considered an essential element in a portfolio of
approaches for reducing CO2 emissions because it appears to be
deployable and there is an enormous amount of potential storage
capacity located around the world. To make significant reductions
in greenhouse gas (GHG) emissions by mid-century, large-scale
reduction opportunities, including CCS, will most likely be needed
(IPCC 2005, Fig. SPM 7).

What is the status of CCS development?

CCS GUIDELINES

The technologies involved in CCS stand at various stages of

commercial readiness. Integrated projects that capture and store a
large volume of CO2 are being deployed in only a few instances,
and so far, not in any baseload power plants. As reported in the
2007 Massachusetts Institute of Technology (MIT) Future of Coal
study, additional demonstration at full scale is urgently needed to
determine that the technology will work as envisioned on a large
scale. This is critical to bringing the technology components to
commercial readiness and to providing information needed to
establish comprehensive legal and policy frameworks for
widespread deployment of CCS (MIT 2007).

20

Today a number of small demonstration projects are underway. In

the United States, the U.S. Department of Energy (DOE) sponsors a
research and development program that is investing in development
of the core technologies for capture, injection, and monitoring.
One part of this program is the Regional Carbon Sequestration
Partnerships, which is entering a third phase that will include more
than 25 small-scale and up to 7 large-scale injection projects.
Similar efforts are being started by governments around the world.
On the regulatory and policy fronts, the U.S. Environmental
Protection Agency (EPA) has released draft regulations governing
the injection of CO2 for storage. The Interstate Oil and Gas
Compact Commission (IOGCC) has issued model rules and policy
recommendations for CCS. And Washington State recently promulgated rules for geologic storage. These efforts are important,
but they alone will not be sufficient to facilitate the broad use of
CCS within a decade. Additional demonstrations and policies to
provide incentives for such demonstrations are urgently needed.

Why were these Guidelines developed and

through what process?
When this project was initiated in 2006, broad public awareness
of CCS was low. No regulations or policies specifically targeted
CCS, and there was open debate about whether and how the states
and/or EPA should regulate geologic storage. This debate was
fueled in part by the diverse facets of CCS. For example, although
much of the technical experience for CCS is drawn from the
petroleum and petrochemical industry, CO2 sources are typically
regulated under air quality rules at the state and federal levels: the
U.S. Department of Transportation regulates the safety of
supercritical CO2 transport through pipeline systems and injection is
typically overseen by environmental regulators when it involves
waste disposal and by oil and gas regulators when it involves oil
and gas operations. In addition, the natural gas industry is governed
by provisions in a separate Natural Gas Storage Act.
Since this project was launched, the U.S. EPA has released for public
comment draft rules governing injection of CO2, the U.S. Congress has
introduced a large number of legislative proposals to provide funding
and other incentives for demonstration projects, and other governments
and organizations around the world are also initiating efforts to develop
and deploy CCS. In July 2008, the leaders of the Group of Eight (G8)
expressed their support for CCS, saying in their official statement: We
strongly support the launching of 20 large-scale CCS demonstration
projects globally by 2010, taking into account various national
circumstances, with a view to beginning broad deployment of CCS by
2020 (G8 2008).
The World Resources Institute (WRI) convened a group of experts from
business, government, nongovernmental organizations (NGOs), and
others to develop the CCS Guidelines through an iterative process,
beginning with scoping meetings in 2006. WRI commissioned the initial
writing of the Guideline documents, with Thomas Curry (MJ Bradley &
Associates, LLC) authoring the capture section, WRI Research Analyst
Preeti Verma authoring the transport section, and Dr. S. Julio Friedmann
(Lawrence Livermore National Laboratory) authoring the storage
section. To ensure the development of robust and effective Guidelines,
WRI predicated its process on the following principles:
1. Protect human health and safety,
2. Protect ecosystems,
3. Protect underground sources of drinking water and other natural
resources,
4. Ensure market confidence in emission reductions through proper
GHG accounting, and
5. Facilitate cost-effective, timely deployment.
These guiding principles were developed by the WRI CCS project
team to ensure that the Guidelines reflect the objective of safe and
timely deployment of CCS. The authors used these guiding principles

as the basis to frame the recommendations. The original draft

Guidelines were released in December 2007 at a workshop where
invited experts gathered to review and discuss the draft documents.
The capture and transport sections were largely agreed upon by the
expert group, and were subsequently updated based on solicitations
for comments and one-on-one discussions that the authors initiated
with key stakeholders and experts. There was more debate about the
provisions in the storage section, and it was the subject of additional
expert meetings in March and June 2008. Revised versions of the
storage section were released as review drafts in February and May
2008. WRI Senior Associate Sarah Forbes and Sarah Wade (AJW, Inc.)
acted as supporting authors and editors for this effort following the
December 2007 meeting. During the March and June 2008 expert
meetings on the storage review drafts, invited stakeholders met to
discuss language and key issues in depth. Notice of updated draft
documents was sent to a broader stakeholder group for review, and
many stakeholders provided detailed written comments.
A public workshop that focused on all three sections (capture,
transport, and storage) was held in March 2008. An effort was made
to include in this workshop all parties who had previously expressed
interest in participating and learning more about the WRI process,
as well as organizations and individuals who could provide input to
further strengthen the Guidelines.
A final comprehensive review draft of the Guidelines was circulated
for review in July 2008. This review draft reflected the collective
input of the contributing stakeholders, listed at the front of this
document, although it should be noted that individual stakeholders
were not asked to endorse the Guidelines. The identification of the
individual stakeholders should not be interpreted as, and does not
constitute, an endorsement of these Guidelines by any of the listed
stakeholders. On July 31, 2008, WRI hosted an online meeting for
contributing stakeholders to kick off the peer review process. At that
time, contributing stakeholders expressed interest in establishing
an online forum to continue discussions. Throughout the review
process, contributing stakeholders were also notified by e-mail of
changes to the Guidelines.




March 2008Storage experts workshop to discuss February

review draft Guideline text in detail.
June 2008Storage experts workshop to discuss May review
draft storage text.
July 2008Contributing stakeholders Webinar.

By providing background information on technical issues, the CCS

Guidelines aim to facilitate the deployment of early CCS projects
and to build the ideas and information for a legal and policy
framework for CCS. The CCS Guidelines are meant to provide a
comprehensive introductory reference for those new to CCS who
need to understand how to responsibly conduct projects. A potential
operator, financier, insurer, or regulator can use these Guidelines
as a measure in evaluating potential project plans and as a
reference on the current technical understanding of best practices
for CCS. A policymaker can use them in establishing frameworks
that enable successful and responsible CCS deployments. It is
important to note that these Guidelines are not intended to replace
or provide the detailed technical knowledge that would be required
to select the location for or to design and operate a CCS project.
The other purpose of the CCS Guidelines is to clarify and present
the existing knowledge on how to make the deployment of CCS safe
and effective. There are some outstanding questions about how to
best deploy CCS at scale, and to get to those answers there is an
urgent need for conducting demonstration projects of varying sizes
and configurations. In this document, we acknowledge areas where
more research and demonstration are needed.

How should one approach these Guidelines?

The CCS Guidelines provide the reader with a comprehensive
overview of CCS. The first section focuses on capture, the second
on transport, and the third on storage. The Guidelines use a
few conventions:
 First, a topic often warrants additional discussion that is not
exactly germane to the narrative. We have placed such
discussions in text boxes throughout the document. Some of
these topics (e.g., the text box discussing The Composition of
CO2,) are included where it first makes sense to have the
discussion even though they are referred to in later sections of
the Guidelines.
 Second, because a number of different industries and
regulatory agencies are involved in activities that are directly
related to CCS, it is no surprise that a number of different terms
can apply to the same concept or item. We have attempted to
define and consistently use key termsfor example, using
storage to describe the concept of injecting CO2 for long-term
isolation or sequestration, and the term storage project
footprint to describe the area above the plume of injected CO2

CCS GUIDELINES

In summary, the following workshops were specifically targeted

toward the development and refinement of the Guidelines. WRI has
also conducted a series of workshops to identify and explore issues
related to CCS, which have informed the Guideline process and are
described in Appendix A:
 February 2006Kick-off and scoping workshop.
 December 2007Expert meeting to discuss draft Guidelines
for capture, transport, and storage.
 March 2008All stakeholders invited to public forum to
discuss February review draft Guidelines for capture, transport,
and storage.

21

and the area of significantly elevated pressure. These terms are

defined in the text when they are first used and are also defined
in the Glossary at the end of the report.
Third, there is significant overlap and iteration among and
between the capture, transport, and storage phases of a project
as we have defined them. We have done our best to reduce
repetition and redundancy by referring the reader to various
sections in the report as necessary. So, for example, in
discussing the nature of what is being injected in the storage
section, the reader will be referred to the discussion of captured
gases in the Capture section and pipeline requirements in the
Transport section.

The Guidelines are summarized at the front of this document

and are included at the end of each subsection of the text. We
urge the reader to fully consider the text used to explain and
provide background on the Guidelines.

Based on this process and the robust set of Guidelines presented

herein, we believe there is sufficient evidence that CCS projects can
be carried out safely and effectively to warrant quickly moving to
full-scale demonstrations. It is important for interested parties to
make the effort to understand the basic concepts involved in CCS, so
that they can feel confident about the likely safety of initial projects
and be informed participants in efforts to develop comprehensive
policy frameworks. CCS holds promise as an important tool in
addressing climate change, but that promise can only be realized if
projects are effectively deployed.

Recommended Best Practices for Community Engagement in CCS Projects

The figure below provides an example of emerging best practices

CO2 Handling

for meaningful community engagement. Community engage-

Although CO2 is an asphyxiant at high concentrations and can

ment has been recognized as an important part of industrial and

harm human health and the environment, it is benign at lower

municipal projects in the context of sustainable development. In-

concentration and is regularly handled as part of many differ-

tegrating community engagement in future CCS projects will be

ent industrial activities. As such, there are standards already

an essential component. Future work to identify CCS-specific

established for CO2 exposure and handling. Occupational hazards

community engagement guidelines may be warranted; these

can be can be minimized when workers adhere to safety stan-

Guidelines focus on the technical aspects of CCS demonstration

dards and use appropriate protective equipment. Following are

and deployment.

some examples of already established U.S. standards:



What Is CO2?

Occupational Safety and Health Administration (OSHA) General

Industry Permissible Exposure Limit (PEL): 5,000 parts per million

Carbon dioxide is a colorless, odorless gas made of two oxygen

(ppm), 9,000 milligrams per cubic meter (mg/m3) time-weighted
atoms covalently bonded to a carbon atom. It is the product of resaverage (TWA).
piration and is ubiquitous in the atmosphere. However, at high
concentrations it can cause asphyxiation, and because it is denser
than air it can pool in low-lying areas with poor air ventilation.

OSHA Construction Industry PEL: 5,000 ppm, 9,000 mg/m3 TWA.

American Conference of Governmental Industrial Hygienists

Threshold Limit Values: 5,000 ppm, 9,000 mg/m3 TWA; 30,000 ppm,
54,000 mg/m3 short-term exposure limit.

Current atmospheric CO2 concentrations are 385 parts per million,

which is an increase of over 100 ppm since the beginning of the

National Institute for Occupational Safety and Health Recommended Exposure Limits: 5,000 ppm TWA; 30,000 ppm short-term

mosphere and consequently heats the atmosphere, contributing

exposure limit.

in
g

Industrial revolution. CO2 absorbs infrared radiation in the at-

22

SOURCE: HERBERTSON 2008

io
n
is
s
m
om
De
c

ra
tio
n
Op
e

st
ru
c
Co
n

X
X
X
X

ig
n

(1) Identify stakeholders early.

(2) Define the intended outcomes of community engagement.
(3) Determine whether to inform, consult, or negotiate.
(4) Engage communities throughout the project cycle.
(5) Allow communities to raise grievances.
(6) Promote internal and external monitoring.

De
s

Principles for Meaningful Community Engagement

Co
n

CCS GUIDELINES

ce

pt

tio
n

to global warming.

X
X
X

X
X
X

X
X
X

X
X
X

CAPTURE

P A R T

2.1 INTRODUCTION
CO2 capture refers to the separation of CO2 from the other components in the flue gas or process stream

to point sources of CO2, with the CO2 being used for various purposes, including the production of
streams of CO2 for use to increase oil production via enhanced oil recovery (EOR) and for sale as a
food-grade product for carbonating beverages. However, the technology is not deployed at the scale
necessary to significantly reduce CO2 emissions. Deployment at that scale will require research to

CCS GUIDELINES

of a power plant or an industrial facility. CO2 capture technologies have been applied at small scales

23

CAPTURE

reduce the cost and improve the performance of capture technologies and a policy driver to reduce CO2 emissions. The capture
Guidelines are organized into two sections: the current state of CO2
capture technologies, and the potential non-CO2 environmental
impacts of the technologies. The capture Guidelines consider the
potential application of existing regulatory structures to capture
facilities and suggest best practices.
Developing appropriate regulatory structures and industrial best
practices for capture is important given the potential scale of
deployment. According to DOEs Energy Information Administration
(EIA), coal-fired power plants emitted over 1.9 billion metric tons
of CO2 in the United States in 2006 (U.S. DOE/EIA 2007). The current
commercialized technology for CO2 capture involves the use of
monoethanolamine (MEA) to separate the CO2 from the flue gas
stream. Not counting the significant initial start-up quantity of MEA,
coal-fired facilities would have to replace the MEA at a rate of
about 1.5 kilograms per metric ton of captured CO2 (Rao and Rubin
2006). If 90 percent of the CO2 emitted in 2006 were captured, the
entire existing U.S. coal fleet would require about 2.5 million metric
tons of amines annually. In 2005, the annual worldwide demand for
MEA was about 1.3 million metric tons (Dow 2007). Deploying
capture technologies will not be simple, even with a commercially
mature approach like MEA.
While the addition of CO2 capture and compression processes to
an existing or new power plant will require owners and operators
to learn new processes and adopt additional safety protocols, these
methods, guidelines, and regulations are in use in other industries.
As stated by the Intergovernmental Panel on Climate Change (IPCC)
in its review of CO2 capture, The monitoring, risk and legal aspects
associated with CO2 capture systems appear to present no new
challenges, as they are all elements of long-standing health, safety
and environmental control practice in industry (IPCC 2005).

2.2 TECHNOLOGY OVERVIEW

CCS GUIDELINES

To provide a point of reference for the discussions that follow, this

section offers a brief overview of the three primary approaches to CO2
capture (pre-combustion, post-combustion, and oxy-fuel combustion)
and discusses topics that could be important for technology selection.

24

The data in this section are estimations based on published reports

about state-of-the-art technology. Improvements in existing
technologies and advanced technologies for capturing CO2 will almost
certainly develop over time as more facilities are built with capture
devices in place (Rubin et al. 2006). Several advanced technologies
based on the use of membranes, sorbents, new solvents, and other
capture mechanisms are being developed.
While there have been a limited number of demonstrations of
capture on power plants (and none on a large scale), power plants
represent, in aggregate, the largest potential reduction of CO2 to
which CCS can be applied. The IPCC estimated that there were
almost 5,000 large power plants worldwide in 2002, with
combined annual emissions of over 10 billion metric tons of CO2.
The next largest source of industrial emissions in 2002, cement
production, had 1,000 sources and combined annual emissions of
over 900 million metric tons of CO2 (IPCC 2005). Given both the
complexity and the potential scale of deployment for CO2 capture
from power plants, this section focuses on guidance for CO2
capture from power plants, although the guidance can be applied
across industry sectors.
Figure 1 shows the location of potential CO2 sources in parts of
North America. Electric generation (shown in blue) is the most
prevalent potential source, particularly in the eastern half of the
United States.
An emerging question for capture technologies is the appropriate
level of capture. In the demonstration phase, there is some
technical uncertainty about what level of capture can be achieved.
DOE has established a goal for CO2 capture of 90% at an increase
in cost of energy services of less than 20% for post-combustion
(such as MEA) and oxy-fuel combustion, and less than 10% for
pre-combustion capture. The timeline for DOEs capture research is
to demonstrate a series of cost-effective CO2 capture technologies
at pilot scale by 20121 (Figueroa et al. 2008; U.S. DOE/NETL 2007c).
It is imperative that full-scale demonstration plants move forward
to provide plant operators and regulators with a sense of capture
performance on commercial-scale facilities. That knowledge will
give operators additional confidence developing strategies to
reduce CO2 emissions. To this effect, Congress is considering some

Developing appropriate regulatory structures

and industrial best practices for capture
is important given the potential scale of deployment.

Figure 1: North American CO2 Sources

CAPTURE

S O U R C E : C A R B O N S E Q U E S T R AT I O N AT L A S O F T H E U N I T E D S TAT E S A N D C A N A D A , D O E / O F F I C E O F F O S S I L E N E R G Y / N E T L , N O V E M B E R 2 0 0 8

bills that would kick-start large-scale deployment of the technology,

such as the Carbon Capture and Storage Early Deployment Act (U.S.
Congress 2008).

The implication of the energy penalty from an emissions accounting

perspective is that the captured emissions are not equal to the

Recognizing the impact of the energy penalty on emissions, the

IPCC 2006 Guidelines for National Greenhouse Gas Inventories
include recommendations for calculating emissions from a facility
with capture (Eggleston et al. 2006). It suggests using projected
emissions without capture (based on fuel consumption) less the
amount captured for transport (assuming the CO2 is metered during
preparation for transport).

2.2.1 Capture from Power Plants

Three main approaches are used to capture CO2 from power plants:




Post-combustion capture,
Pre-combustion capture, and
Oxy-fuel combustion.

Post-combustion capture refers to the separation of CO2 from the flue

gas of a combustion process. Fuel sources can be any hydrocarbon,

CCS GUIDELINES

Because separation and compression of CO2 require a significant

amount of additional energy, a facility with capture has to be larger
than a facility without capture to achieve the same energy output.
For example, capture of 90 percent of the CO2 from a supercritical
pulverized coal (SCPC) plant using current technologies would result
in increased fuel consumption of 24-40 percent compared to similar
plants without CO2 capture and compression (IPCC 2005). As a result
of this energy penalty, the percentage of CO2 that is captured is
not equal to the percentage of CO2 that is avoided through capture.
Under this scenario, an SCPC plant that emitted 1 million tons of
CO2 per year prior to capture would generate 1.241.4 million tons
of CO2 after the addition of capture equipment in order to generate
the same amount of electricity. Assuming 90 percent of the CO2
captured, 1.121.26 million tons would be captured, an amount that
exceeded the original amount of CO2 emissions from the
uncontrolled plant. Under this scenario 124,000140,000 tons of
CO2 would still be emitted from the plant.

avoided CO2 emissions. Rather, the avoided emissions are equal to

the emissions from a similarly sized facility without capture less the
emissions to the atmosphere after capture. In the case described
above, the avoided emissions would be equal to 1 million tons of
original emissions minus 124,000140,000 tons that are still emitted
after capture, for a total of 860,000876,000 tons of CO2 avoided.

25

CAPTURE
CCS GUIDELINES
26

such as coal, natural gas, or oil. For coal plants, post-combustion

capture is typically associated with subcritical pulverized coal (PC),
SCPC, ultra-supercritical pulverized coal (USCPC), and circulating
fluidized bed (CFB) plants. Pre-combustion capture involves the
generation of syngas (carbon monoxide plus hydrogen (CO+H2)),
followed by the shift reactions to convert the CO to CO2. CO2 is then
separated from hydrogen, and the hydrogen can be burned in a
turbine or used as fuel in a heater. Pre-combustion capture is often
associated with integrated gasification combined cycle (IGCC)
technology; however, post-combustion capture technologies can also

Table 1: Planned CO2 Capture and Storage Projects

Project Name

Location

Feedstock

Size (MW, except as noted) Capture Process

Start-up Date

Total Lacq
Vattenfall Oxyfuel
AEP Alstom Mountaineer
Callide-A Oxy Fuel
GreenGen
Williston
Kimberlina
NZEC
AEP Alstom Northeastern
Sargas Husnes
Scottish & Southern Energy Ferrybridge
Naturkraft Krst
Fort Nelson
ZeroGen
WA Parish
UAE Project
Appalachian Power
Wallula Energy Resource Center
RWE npower Tilbury
Tenaska
UK CCS Project
Statoil Mongstad
RWE Zero CO2
Monash Energy
Powerfuel Hatfield
ZENG Worsham-Steed
Polygen Project
ZENG Risavika
E.ON Karlshamn

France
Germany
USA
Australia
China
USA
USA
China
USA
Norway
UK
Norway
Canada
Australia
USA
UAE
USA
USA
UK
USA
UK
Norway
Germany
Australia
UK
USA
Canada
Norway
Sweden

Oil
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Coal
Gas
Gas
Coal
Coal
Gas
Coal
Coal
Coal
Coal
Coal
Gas
Coal
Coal
Coal
Gas
Coal/ Petcoke
Gas
Oil

35
30/300/1000*
30
30
250/800**
450
50
Undecided
200
400
500
420
Gas Process
100
125
420
629
600700
1600
600
300400
630 CHP
450
60,000 bpd
900
70
300
5070
5

2008
200815
2008
2009
2009
200915
2010
2010
2011
2011
201112
201112
2011
2012
2012
2012
2012
2013
2013
2014
2014
2014
2015
2016
Undecided
Undecided
Undecided
Undecided
Undecided

SOURCE: MIT 2008

* 30/300/1000 = Pilot (start time 2008)/Demo/Commercial (anticipated start time 20102015)

** 250/800 = Demo/Commercial
bpd = barrels per day
CHP = combined heat and power
Petcoke = petroleum coke

Oxy-fuel
Oxy-fuel
Post-combustion
Oxy-fuel
Pre-combustion
Post-combustion
Oxy-fuel
Undecided
Post-combustion
Post-combustion
Post-combustion
Post-combustion
Pre-combustion
Pre-combustion
Post-combustion
Pre-combustion
Pre-combustion
Pre-combustion
Post-combustion
Post-combustion
Post-combustion
Post-combustion
Pre-combustion
Pre-combustion
Pre-combustion
Oxy-fuel
Pre-combustion
Oxy-fuel
Post-combustion

Advanced Pulverized Coal Combustion

and compressed, although some cleaning to remove contaminants

may be necessary before compression.

The discussion of capture approaches mentions three types of pulverized coal plants: subcritical pulverized coal, supercritical
pulverized coal (SCPC), and ultra-supercritical pulverized coal
(USCPC). While the vast majority of existing coal-fired power
plants in the United States are subcritical power plants, the current state-of-the-art technology for new U.S. pulverized coal-fired

While all of the approaches appear promising for capture from

power plants, none has been demonstrated on a commercial scale
(IPCC 2005). Table 1 shows some of the planned CO2 capture
projects as of July 2008 (all of the projects are expected to include a
storage component).

power plants is SCPC, with developers considering USCPC. Power

successfully operating USCPC power plants.

All three technologies employ similar processes, injecting finely
ground coal through burners into a furnace for combustion, but
they operate at different temperatures and pressures. As the
names imply, subcritical plants operate at the lowest temperatures
and pressures of the three, and USCPC units operate at the highest temperatures and pressures. USCPC units are constructed with
advanced materials that are able to handle the advanced temperatures and pressures. While specific parameters vary from
facility to facility, a new subcritical unit might operate at 16.5
megapascals (MPa) (~2,400 pounds per square inch (psi)) and
565C/565C (1,050F/1,050F). The current U.S. Department of Energy research and development targets for USCPC units are 34.5
MPa (~5,000 psi) and 732C/760C (1,350F/1,400F).
By designing a power plant to operate at higher temperatures and
pressures, plant owners are able to increase the generating efficiency. A newly constructed pulverized coal unit without CO2
capture may have a generating efficiency (high heating value
(HHV)) of 37 percent, while new SCPC and USCPC may have HHVs
of 39 percent and 43 percent, respectively. At higher efficiencies,
less coal is needed to generate the same amount of electricity output, resulting in lower air emissions per unit of power output and
reducing the amount of CO2 that needs to be captured. The addition of CO2 capture technologies to any combustion technology
will result in an energy penalty that decreases the generating efficiency, as discussed elsewhere in this section.
SOURCES: MIT 2007; U.S. DOE/NETL 2007

be applied to IGCC. Most studies suggest it is more cost-effective to

use pre-combustion technologies with IGCC because the CO2 can be
captured at higher pressures compared to post combustion (IPCC
2005). These are described in detail below.

Post-combustion capture requires the addition of a capture system

(to separate the CO2 from the other flue gas components and
concentrate the CO2) and a compression system (to compress the
CO2 and prepare it for transport). Leading post-combustion capture
technologies also require significant cleaning of the flue gas before
the capture device. In particular, sulfur levels have to be low (less
than 10 parts per million (ppm) and possibly lower) to reduce
corrosion and fouling of the system. Figure 2 shows a sample block
diagram for post-combustion capture from a power plant.
As shown in Figure 2, after leaving the boiler, flue gas is cleaned
with a scrubber that removes sulfur dioxide (SO2) and a device that
removes particulate matter (PM). The diagram shows the use of
limestone slurry for this purpose, suggesting use of wet flue gas
desulphurization (FGD). While wet FGD would not be a required
component, it might be needed to reduce the sulfur content to the
required level. Also, note that the flue gas cleanup area would
include a device for PM collection. The flue gas then enters an
absorption column (represented by the CO2 capture box) that
contains the amine solution. As the flue gas contacts the amine in
the absorption column, the CO2 is absorbed into the amine solution.
The flue gas then exits the stack, and the amine solution is sent to
a stripping column, where the CO2 is removed from the amine
solution through an increase in the solution temperature. The amine
is recycled and sent to the absorption tower, while the CO2 is
cooled, dried, and compressed to a supercritical fluid (MIT 2007).
Besides the use of an amine solution (chemical absorption into
solution), the options for post-combustion capture include physical
adsorption with a solvent (ionic liquids) or a sorbent (metal organic
frameworks), membrane separation from the gas (membrane/amine
hybrids or enzymatic CO2 processes), and cryogenic separation by
distillation or freezing (U.S. DOE/NETL 2007c). Chemical absorption
into a solution is currently the preferred approach for separating
CO2 from flue gases at low concentrations, such as those associated
with power plants. There is considerable experience using amines,
such as MEA, for the separation of CO2 during natural gas
processing and in the development of food-grade CO2. While
expensive, it is currently considered a commercial post-combustion
capture process (MIT 2007).

CCS GUIDELINES

Oxy-fuel combustion involves the combustion of fuel in an oxygen-rich

environment to dramatically increase the CO2 concentration of the
resulting flue gases. The increased CO2 concentration (typically
>80%) of the flue gas stream facilitates CO2 separation. Oxyfiring
produces lower emissions of nitrogen oxides (NOx) compared to
air-blown combustion. After combustion, the flue gas can be captured

2.2.1.1 Post-Combustion Capture

CAPTURE

providers in Europe, Japan, and China have constructed and are

27

Figure 2: Post-Combustion Capture from a Pulverized Coal-Fired Power Plant

Limestone Slurry

Condensate Return

Flue Gas Clean-up

CO2 Capture

Feed Air
Coal Feed

Boiler/ Superheater

Stack Gas

CO2

CAPTURE

Condensate

Ash & Wet Solids

Compression and
Dehydration

Low Grade Steam

Steam Turbine/
Generator

CO2
Electric Power

ADAPTED FROM MIT 2007

Recently, companies have announced projects using other solvents,

such as advanced amines or aqueous ammonia. Ammonia-based
capture devices have received particular attention from industry as
potentially more cost-effective than amine scrubbing. Pilot plant
projects with both ammonia and chilled ammonia processes are
scheduled for 2008. Capture technology companies have announced
agreements to test the solvents on larger-scale units, if those projects
are successful. Other post-combustion approaches, such as physical
absorption into ionic liquids, membrane separation, enzymatic
processes, and cryogenic separation, are also under development.

2.2.1.2 Pre-Combustion Capture

Pre-combustion capture involves the removal of CO2 after the coal
is gasified into syngas, but before combustion in an IGCC unit. As
shown in Figure 3, the first step involves gasifying the coal. Then,
a water-gas shift reactor is used to convert carbon monoxide in
the syngas and steam to CO2 and hydrogen. This increases the
concentration of CO2, improving CO2 capture efficiency and increasing
the amount of carbon (in the form of CO2) that can be removed using

this process. The CO2 is removed using either a chemical or a physical

solvent, such as Selexol, and is compressed. The hydrogen is
combusted in a turbine to generate electricity (MIT 2007).
While both IGCC and pre-combustion CO2 capture technologies are
considered available, only four gigawatts of IGCC power plants have
been built worldwide as of the end of 2007 (IPCC 2005). None of the
existing IGCC plants have the technologies needed to capture the CO2.
When CO2 is separated from the syngas (as in pre-combustion
capture), a turbine that can function in a hydrogen-rich environment is
needed. Hydrogen-fired turbines are being developed for this purpose,
and have been demonstrated but are not at the same state of
technological readiness as syngas-fired turbines.

2.2.1.3 Oxy-Fuel Combustion

Oxy-fuel combustion involves the combustion of fossil fuels in an
oxygen-rich environment (nearly pure oxygen mixed with recycled
exhaust gas), instead of air. Combustion under these conditions
reduces the formation of nitrogen oxides, so that the gas leaving the
combustion zone is primarily CO2 and is easier to separate and

Figure 3: Pre-Combustion Capture on an IGCC Power Plant

CCS GUIDELINES

Feed Air

28

Air Separation
Unit

Vent Gas

Combustion
Air

Nitrogen Diluent

Oxygen
Coal Feed

Gasifier

Bottom Slag
ADAPTED FROM MIT 2007

Shift Reactor

Sulfur Removal

CO2 Capture/
Compression

Sulfur Product

CO2 Product

Power
Generation
Block

Stack Gas
Electric
Power

Figure 4: Oxy-Fuel Combustion With Capture

Feed Air

Air Separation Unit

Nitrogen
Recycle Exhaust Gas
Lime Slurry

Stack Gas

Oxygen
Flue Gas Clean-up

CO2

Ash & Wet Solids

Steam Turbine/
Generator

CAPTURE

Boiler

Coal Feed

CO2 Compression/
Purification System

Electric Power

ADAPTED FROM MIT 2007

remove. As shown in Figure 4, an air separation unit supplies oxygen

to the boiler where it mixes with the recycled exhaust gas. After
combustion, the gas stream can be cleaned of PM, nitrogen oxides,
and sulfur. After condensing out the water, the flue gas has a CO2
concentration that is high enough to allow direct compression.
However, the compressed flue gas may have to be further cleaned
of co-constituents to reach the same purity as the compressed CO2
resulting from post-combustion capture. As of 2008, oxy-fuel power
plants are in the early stages of development with pilot-scale
construction currently underway in Europe and in North America as
documented in Table 1 (MIT 2007).
Figure 5 summarizes some of the critical challenges for capture
identified by the DOE. The boxes under Research Pathways list
the sorbents, solvents, membranes, and other process technologies
that could be used to separate CO2. As shown in the key, DOE
considers those marked with a C to be commercially available,
those marked with a P to be pilot scale, and those marked with
an L to be laboratory scale or conceptual.

Using CO2 Capture Technology to Produce Food-Grade CO2

Operators of at least three U.S. coal-fired power plants capture CO2
from flue gas for sale as food-grade CO2. Two of those facilities are
cogeneration plants operated by AES: AES Warrior Run in Cumberland, Maryland, and AES Shady Point in Panama, Oklahoma.

A E S WA R R I O R R U N ( H O LT 2 0 0 8 )

AES Warrior Run is a 180-megawatt (MW) coal-fired facility that

started commercial operation in February 2000, and AES Shady
Point is a 320-MW coal-fired facility that started operation in January 1991. Both facilities use a circulating fluidized bed boiler to

2.2.2. Capture from Industrial Sources

ture CO2 from a slip stream of the flue gas. At AES Warrior Run,
facility operators capture about 10 percent of the CO2 generated
at the facility, compared to about 5 percent at AES Shady Point.
After capture, the CO2 at both facilities is purified for sale as a
food-grade product.
To capture the CO2, operators strip CO2 from a portion of the
plants flue gas using an ABB Lummus scrubber system with monoethanolamine (MEA) as its solvent.
S O U R C E S : I E A G H G R & D 2 0 0 8 B ; H O LT 2 0 0 8 ; K I G E R 2 0 0 8

CCS GUIDELINES

Although the worldwide potential for CO2 capture from power

plants is large, there may be early opportunities to demonstrate the
technology in the industrial sector based on commercial experience
and potential economic advantages, such as revenue from EOR.
(Policies that incentivize capture from power plants could shift the
economic considerations.) Capture from industrial process streams
has existed for over 80 years (IPCC 2007). Most facilities currently
vent the CO2 to the atmosphere, although some compress it and sell
it as food-grade or industrial CO2.

generate electricity and a post-combustion capture device to cap-

29

Figure 5: Critical Challenges Associated With CO2 Capture Technologies

CAPTURE: CRITICAL CHALLENGES
CAPTURE

Parasitic load
 Scale-up

Cost-effective oxygen
 Application to existing fleet

Energy-efficient capture processes

 Integration with advanced fuel conversion systems

CAPTURE

RESEARCH PATHWAYS
Chemical Solvents
AminesC
Advanced aminesP
Aqueous ammoniaL
PostCombustion

Physical Solvents
Ionic liquidsL
N2/CO2 Membranes
Membrane/amine hybridsL
Enzymatic CO2 processesL

PreCombustion

Oxygen
Supply

Chemical Sorbents
Amine-enriched sorbentsL
Metal organic frameworksL

N2/CO2 Membranes
Membrane/amine hybridsL
Enzymatic CO2 processesL

Chemical Sorbents
Metal organic frameworksL

Physical Solvents
GlycolC
MethanolC
Ionic liquidsL

Physical Sorbents
Metal organic frameworksL

Cryogenic oxygen production (distillation)C

Ion transport membranesL
Ceramic autothermal reactor (CAR)L
Conventional oxyfuel with recirculation
Oxygen transport membranesL
Chemical loopingL

Heat and pressure

integration with base
power plant

CO2 compression

Co-sequestration

Membranes
Polymer, ceramic, hollow fiber
membrane supportsL

OxyCombustion

Physical Sorbents
Metal organic frameworksL

Chemical Solvents
AminesC

Novel
HydratesL

CROSS CUT PATHWAYS

O2 quality
(oxy- and
post- combustion)
CO2 quality (permitting/
transportation)
Post combustion
capture: CO2 recycle to
concentrate flue gas

KEY
C

Commercially available

Pilot scale

Laboratory scale/conceptual

C A R B O N S E Q U E S T R AT I O N T E C H N O L O G Y R O A D M A P A N D P R O G R A M P L A N 2 0 0 7 , D O E / O F F I C E O F F O S S I L E N E R G Y / N E T L , A P R I L 2 0 0 7

CCS GUIDELINES

Existing large-scale demonstrations of CO2 storage to date involve

industrial capture of CO2 from natural gas processing (Sleipner, In
Salah, and Snohvit) or coal gasification (Weyburn).2

30

The Sleipner Project, the longest-running large-scale CCS project

in the world, began capturing CO2 from natural gas processing off
the coast of Norway in 1996. During natural gas processing, CO2
naturally present in a natural gas stream is stripped from produced
natural gas in order to increase the purity for delivery into the
market. In many other plants, this stripped CO2 is vented to the
atmosphere. At Sleipner, the CO2 is captured using a conventional

amine capture process, and is then stored in a saline reservoir under

the North Sea.
Other industrial processes that are potential candidates for CO2
capture are steel, cement, ammonia, and ethanol production.
Capture from steel or cement production would be similar to
post-combustion capture or oxy-fuel combustion with capture (IPCC
2005). Ammonia plants are a potentially attractive source because
they generate a relatively pure stream of CO2 as a byproduct. Ethanol
production results in a relatively pure CO2 stream (more than 85
percent), and it can be captured, cleaned, and stored or used for EOR

Table 2: Existing and Proposed CO2 Storage Demonstration Projects

Project Leader

Location

CO2 Source

Size (million metric tons per year) Start Year

Sleipner
Weyburn
In Salah
K12-B
Zama
Snohvit
Ketzin
Decatur
Gorgon
Cranfield
Entrada
TAME
Lindach
Casablanca

StatoilHydro
Pan Canadian
BP
Gaz de France
Apache
StatoilHydro
CO2Sink
MGSC
Chevron Texaco
SECARB
SWP
MRCSP
Rohoel
Repsol

Norway
Canada
Algeria
Netherlands
Canada
Norway
Germany
Illinois, U.S.
Australia
Mississippi, U.S.
Colorado/Wyoming, U.S.
Ohio, U.S.
Austria
Spain

Gas Processing
Coal Gasification
Gas Processing
Gas Processing
Gas Processing
Liquefied Natural Gas Processing
Hydrogen Production
Ethanol Production
Gas Processing
Gas Processing
Gas Processing
Ethanol Production
Industrial
Refinery

1
1
1.2
0.2
0.067
0.7
0.03
0.3
3.3
1
1.1
0.28
0.3
0.5

1996
2000
2004
2004
2006
2008
2008
2009
2009
2008-9
2008-12
2011
TBD
TBD

CAPTURE

Project

SOURCE: MIT 2008

CO2 Avoided =
CO2 emitted without capture CO2 emitted with capture

(Abadi et al. 2005). Ethanol production is the source of CO2 for a

large-scale storage project announced for Illinois, which is scheduled
to begin in 2009 and conclude in 2012 (ADM 2008). Capture from
industrial sources can yield experience that can be directly applied to
capture and storage from power plants.

2.2.3 Capture Economics

Table 3 highlights some processes that could be targeted for CO2

capture and provides cost estimates from a range of sources. The
cost estimates are shown in dollars per metric ton of CO2 avoided.
As discussed, avoided CO2 is calculated as the emissions from a

The costs of capture from different processes often reflect the CO2
concentrations in the flue gas or process stream. Lower cost options
for CO2 capture are often associated with processes that produce
more concentrated CO2 streams (e.g., industrial plants where
operators only need to compress a process stream to prepare it for
transport) (Dooley et al. 2006).
The ranges of costs in Table 3 suggest the uncertainty associated
with the cost of capture. While continued research and development
is expected to reduce the cost (McKinsey 2008), capture represents
the largest cost associated with CCS and is a significant barrier to
widespread adoption of the technology. Note that all cost estimates
are highly variable based on site-specific conditions and the

CCS GUIDELINES

The process of removing CO2 from flue gas or a process stream is

heavily dependent on the system pressure and CO2 concentration. At
high pressures and concentrations, CO2 is easier to remove and
compress. In some cases, such as in the fermentation of ethanol, the
process gas can be compressed and transported with limited need for
additional treatment. In other cases, such as in pulverized coal
combustion for electricity, the CO2 has to be chemically separated
from scrubbed flue gas before it can be compressed for transport.

similarly sized facility without capture less the emissions to the

atmosphere after capture. The cost estimates in Table 3 include the
costs of capture, compression, transport, storage, and, in most
cases, monitoring. As detailed in the notes below Table 3, capture
and compression dominate the cost of CCS, with estimates for
transport, storage, and monitoring ranging from $5 to $10 per metric
ton of CO2. All of the estimates in Table 3 are relative to the same
facility without capture.

31

availability of raw materials. As described in the accompanying text

box, capital costs associated with construction have increased
dramatically in all industrial sectors in recent years.

CAPTURE

2.2.4 Managing Carbon Dioxide

and Co-Constituents
As discussed in more detail in the transport section, to fulfill the
contractual requirements of transport and potential regulatory
requirements of subsequent storage, facility operators will likely
have to dry the CO2, remove co-constituents, and compress it into
a supercritical phase before it leaves the facility. Facility operators
who install CO2 capture equipment will have to follow rules and
adopt practices associated with managing CO2 on site during the
capture and compression stages. Facility operators must be aware

of the health, safety, and environmental risks associated with

concentrated CO2, and must be mindful of potential worker
exposure to co-constituents in the CO2 stream. Given the extensive
industrial experience handling CO2 for EOR and for sale as a
food-grade product, no new regulatory structures need to be
adopted. Rather, operators at facilities where CO2 has historically
not been handled will have to follow existing regulations.
When CO2 is captured from power plants, it contains water. When
combined with water, CO2 forms carbonic acid that has the potential
to corrode pipelines (it is possible, but significantly more expensive, to
construct pipelines that are resistant to this corrosion). The captured
CO2 can also contain hydrogen sulfide (H2S) (pre-combustion) and the
other co-constituents shown in Table 4.

Table 3: Capture Technologies and Costs

Plant Type

Capture Process

Avoided Costs ($ per metric ton of CO2 avoided)

IPCC ($2002)a

MIT ($2005)c

DOE/NETL ($2006)d

EPRI ($2007)e

$30$71

$75

$57$63

$43

$39$56f

NA

NA

NA

NA

Supercritical Pulverized Post-combustion capture

Coal-Fired Power Plant with amines (MEA)
IGCC Power Plant
Pre-combustion capture

$14$53

Refinery Flue Gas

~$35b

$40.4 + $5 for
transport and storage
$19.3 + $5 for
transport and storage
NA

~$34b

NA

Ethanol

Chemical absorption/
flue gas recycling
No capture; dehydration
and compression only

SOURCES: IPCC 2005; MIT 2007; DOE/NETL 2007F; BOORAS 2007

NOTES:

a. IPCC avoided cost estimates include transport costs of $0$5 per metric ton of CO2 and geological storage costs of $0.6$8.3 per metric ton of CO2. The
costs reported by the IPCC are based on a range of studies reviewed in preparation of IPCC 2005.
b. IPCC avoided cost estimates for capturing CO2 from refinery flue gas and ethanol do not include the costs of transport and storage.
c. Researchers at MIT estimated that transportation and storage would add $5 per metric ton of CO2 avoided. They did not include monitoring in their cost
estimate. They reviewed their estimate for a supercritical pulverized coal-fired power plant with post-combustion capture in September 2008 and adjusted
their estimate to $52 per metric ton of CO2 (in 2005 dollars). They reported that they did not have enough information to revise the estimates for IGCC with
pre-combustion capture. MITs estimates assume the use of a mature technology, after the deployment of several plants with the technology.
d. Values originally reported in short tons, converted to metric tons. DOE/NETL included transportation, storage, and monitoring costs in its estimates for both
captured and avoided costs. The costs were reflected in the 20-year levelized cost of electricity used to calculate the costs per metric ton. The assumptions
included the cost of transporting CO2 50 miles for storage in a geologic formation with over 30 years of monitoring. DOE/NETL estimated these costs to add
about 4 mills per kilowatt-hour, representing about 10% of the total carbon capture and sequestration costs.

CCS GUIDELINES

e. The EPRI CCS and IGCC estimates include a 10% contingency for first-of-a-kind technologies. The cost of electricity used to calculate the avoided CO2 cost

32

includes $10 per metric ton for transportation and storage.

f. EPRI IGCC estimate is for an average IGCC facility, and the range includes results for both Illinois #6 bituminous and Powder River Basin coal. EPRI found
that the GE Total Quench technology using Illinois #6 bituminous would fall below the range shown here ($30$34 per metric ton of CO2 avoided).
Avoided = based on avoided CO2 emissions, costs are relative to the same technology without capture; DOE/NETL = U.S. Department of Energy/National
Energy Technology Laboratory; EPRI - Electric Power Research Institute; IGCC = integrated gasification combined cycle; IPCC = Intergovernmental Panel on
Climate Change; MEA = monoethanolamine; NA = not available.

Table 4: Concentrations of Co-Constituents in Dried CO2, Percent by Volume

SO2

NO

H2S

H2

CO

CH4

N2/Ar/O2

Total

<0.01
0.5

<0.01
0.01

0.010.6
-

0.82.0
-

0.030.4
-

0.01
-

0.01
0.030.6
3.7

0.01
2.12.7
4.2

<0.01
<0.01

<0.01
<0.01

<0.01
-

1.0
-

0.04
-

2.0
-

0.01
1.3
4.1

0.01
4.4
4.1

Coal-Fired Plants

Post-combustion capture
Pre-combustion capture (IGCC)
Oxy-fuel
Gas-Fired Plants

CAPTURE

Post-combustion capture
Pre-combustion capture (IGCC)
Oxy-fuel
SOURCE: IPCC 2005.

a. The SO2 concentration for oxy-fuel and the maximum H2S concentration for pre-combustion capture are for cases where these co-constituents are
deliberately left in the CO2, to reduce the costs of capture. The concentrations shown in the table are based on use of coal with a sulfur content of 0.86%.
They would be directly proportional to the fuel sulfur content.
b. The oxy-fuel case includes cryogenic purification of the CO2 to separate some of the N2, Ar, O2 and NOx. Removal of this unit would increase impurity
concentrations but reduce costs.
c. For all technologies, the impurity concentrations shown in the table could be reduced at higher capture costs.
Ar = argon; CO = carbon monoxide; H2S = hydrogen sulfide; IGCC = integrated gasification combined cycle; N2 = nitrogen; NO = nitric oxide;
O2 = oxygen; SO2 = sulfur dioxide.
SOURCE: IPCC 2005

The potential for co-constituents in the CO2 stream raises questions

about downstream impacts and the necessary composition and
dryness of CO2 before it is transported and stored. As discussed in
the transport section, pipeline operators transporting CO2 for EOR
contractually require facility operators to provide a CO2 stream of a
certain composition. This is done for a variety of reasons, including
health and safety, corrosion prevention, and EOR operator requirements. This issue is discussed in more detail in the transport section.
The potential issues or impacts associated with underground
injection of co-constituents are not clearly defined due to lack of

Hydrogen Sulfide
The presence of co-constituents may create additional health and
safety concerns and place additional regulatory requirements on
a facility. Of particular concern is the handling of hydrogen sulfide (H2S). Exposure to low concentrations of H2S (<50 parts per
million (ppm)) can cause eye, nose, or throat irritation. At levels
above 500 ppm, H2S can lead to a loss of consciousness or even
death. The Occupational Safety and Health Administration has
guidelines for handling H2S in an industrial setting.

CCS GUIDELINES
33

CAPTURE

Escalating Costs

Retrofit of CO2 Capture on an Existing Plant

A number of factors have contributed to a recent escalation of

The costs in Table 3 and the discussion of capture technologies for

costs, not just for carbon dioxide capture and storage, but for all

power plants focus on capturing CO2 from new coal-fired power

large-scale projects in the electric sector. These factors include an

plants. Given the size of the existing coal-fired fleet and associ-

increased demand for resources (raw materials, engineering ex-

ated CO2 emissions (1.9 billion metric tons of CO2 in the United

pertise, and labor) as well as larger economic pressures, such as

States in 2006 according to the Energy Information Administra-

the declining value of the dollar relative to other currencies, the

tion), the application of capture technologies to existing coal-fired

tightening of capital markets, and increasing oil prices.

power plants is a potentially important source of CO2 reductions.

As with new pulverized coal-fired power plants, post-combustion

The increased demand for resources comes from a number of areas.

capture technologies are the most mature (although lacking comForemost is economic growth in developing countries, particularly
mercial-scale demonstration), while oxy-fuel technologies appear
China, and the corresponding increased demand for metals, steel, and
to be promising (although they are in a much earlier stage of decement. Additionally, there has been a pull on resources to rebuild oil
velopment). Given the limited number of integrated gasification
and gas platforms and refineries in the aftermath of recent hurricanes;
combined-cycle plants, it is unlikely that pre-combustion retrofit
to install air pollution control devices on power plants in response to
will be deployed on a significant scale, except in cases where profederal air regulations; and to develop the tar sands in Canada.
posed units are built with the intention of installing the
As an example of the impact of these economic pressures, a num-

technology in the future.

ber of recent projects have announced cost increases:



Recent analyses by the Electric Power Research Institute and the

Estimates of a new coal-fired power plant in Kansas proposed
U.S. Department of Energy suggest that retrofit of capture will cost
by Westar increased by 2040 percent over 18 months.

more for any of the approaches than new construction with capEstimates of a 1,600-megawatt (MW) coal fired power plant in
ture. As a reference point, installing sulfur dioxide scrubbers on
Nevada proposed by LS Power Development and Dynegy more
existing units was, on average, 1.21.8 times as expensive as inthan tripled over two years.

stalling them on new units. The recent analyses also suggest that
Estimates of an 800-MW supercritical pulverized coal power plant
the energy penalty associated with application of the approaches
at Taylor Energy Center in Florida rose by $400 million (20 perto existing units will be greater than it would be on a new unit.
cent) over 17 months, resulting in the cancellation of the project.

Estimates for a 630-MW integrated gasification combined-cycle

In addition to costs, retrofitting post-combustion capture on an ex-

plant in Indiana proposed by Duke Energy rose from $1.985 bil-

isting pulverized coal power plant will require operators to

lion to $2.35 billion due to the increased cost of resources and

consider available space near a facility; a 500-MW power plant will

demand for labor.

require about six acres of space close to the plant to install postcombustion capture technologies. Upgrades to existing air quality

Two frequently cited cost indices are the IHS/Cambridge Energy

Research Associates (CERA) Power Capital Costs Index (PCCI) and

equipment may also be required in some cases because CO2 sorbents require significant sulfur removal from the flue gas.

the IHS/CERA Downstream Construction Cost Index (DCCI). The

PCCI suggests that the cost of new power plant construction in

Installing oxy-fuel technology on an existing coal-fired power

North America has increased by 130 percent since 2000, with a 69

plant will also require space considerations for the addition of an

percent increase since 2005. Focusing on coal, the PCCI suggests

air separation unit and any additional flue gas cleaning equip-

coal power plant capital costs increased by 2.3 percent between the

ment. Owners installing oxy-fuel equipment will also have to

third quarter of 2007 and the first quarter of 2008, and 78 percent

ensure that there is no leakage of air into the unit.

since 2000. The DCCI recorded annual increases of 16 percent in

S O U R C E S : U . S . D O E / E I A 2 0 0 7 ; D A LT O N 2 0 0 8 ; C I F E R N O 2 0 0 7 , 2 0 0 8 .

2006 and 14 percent in 2007. In the first quarter of 2008, the DCCI

CCS GUIDELINES

was 6 percent higher than it was in the third quarter of 2007.

34

SOURCES: FERNANDO ET AL. 2008; IHS/CERA 2008; MIT 2007

CAPTURE GUIDELINE 1: RECOMMENDED GUIDELINES FOR CO 2 CAPTURE

a. Demonstrations of all capture approaches (pre-combustion, post-combustion, and oxy-fuel
combustion) are urgently needed on commercial-scale power plants to prove the
technologies.
b. There should be recognition of the potential challenges in achieving the theoretical
maximum capture potential before the technologies are proven at scale. This may
necessitate flexibility in establishing appropriate capture rates for early commercial-scale
projects with the amount of CO2 captured at a facility dependent on both technology

legislators; however, there is potential risk that this could create disincentives for reducing
sources of anthropogenic CO2 if the standard is set too stringently. Ultimately, the emphasis

CAPTURE

performance and the specific goals of the project.

c. Standards for the levels of co-constituents have been proposed by some regulators and

should be on employing materials, procedures, and processes that are fit-for-purpose and
assessing the environmental impacts of any co-constituents, along with the benefits of CO2
emissions reduction as part of a comprehensive CCS risk assessment. Facility operators,
regulators, and other stakeholders should pay particular attention to potential downstream
impacts of co-constituents in the transport and storage aspects of the project.

Capture from industrial process streams

has existed for over 80 years.

actual demonstration. Given the uncertainty, it is not technically or

economically feasible to prescribe any standards or give guidelines
for CO2 composition.
There are potential financial advantages to leaving some
co-constituents in the CO2 stream. For example, the maximum H2S
concentration for pre-combustion capture in the coal-fired power
plant case in Table 4 reflects an operator not doing any further
treatment, or intentionally leaving the H2S in the syngas. Including
the H2S with CO2 leaving the facility could result in a cost savings
because the operator would not need to install sulfur recovery
equipment (Claus plant) or find an alternative method for disposing
of the elemental sulfur (IPCC 2005). However, in this scenario the
costs for pipeline monitoring will increase because of the presence
of H2S in the pipeline.

2.3 NON-CO 2
ENVIRONMENTAL IMPACTS
CCS technologies have the potential to play a large role in reducing
CO2 emissions. However, it is important to consider the impacts of
the technologies on other parts of the environment. This section
reviews the impacts on other air emissions (e.g., non-CO2 air
emissions), solid waste generation, and water use associated with

CCS GUIDELINES

CO2 composition requirements could also affect the costs associated

with oxy-fuel combustion. The flue gas from oxy-fuel combustion
could require significant cleaning before transport if it is expected to
meet the same minimum requirements for CO2 composition as
post-combustion capture. Unlike the other capture technologies,
almost 100 percent of the CO2 in the flue gas in oxy-fuel combustion
can be dehydrated and compressed (IPCC 2005). (However, CO2 that

is generated by the air-separation unit to produce the oxygen for

combustion is not captured.) It is expected that the gas will be
compressed and fed to a cryogenic purification process to reduce
the concentration of co-constituents. Facilities could clean the gas
stream to close to 100 percent CO2 purity by including distillation in
the cryogenic separation unit. This would result in a concentrated
stream of co-constituents that would have to be properly handled. As
an example of the co-constituents, the data in Table 4 assume that
SO2 is intentionally left in the CO2 stream for co-storage, and that
nitrogen (N2), argon (Ar), oxygen (O2) and oxides of nitrogen (NOx)
are partly removed using cryogenic purification. An operator could
reduce costs by removing less of the co-constituents if allowed.

35

current CO2 capture technologies, and considers the existing

regulatory structure for dealing with these issues. The discussion of
the Clean Air Act focuses on its use to regulate non-CO2 emissions
and does not consider the potential regulation of CO2 under the
Clean Air Act.

CAPTURE

The CO2 capture process requires significant modifications to

coal-fueled power plants, including pulverized coal (PC) combustion
or IGCC processes. For PC plants, a post-combustion capture plant

must be added. For IGCC, process modifications include the

installation of chemical units to absorb the CO2, shift reactors to
react carbon monoxide in the syngas with steam to produce CO2
and hydrogen, or an air separation unit to provide oxygen for
combustion. Environmental impacts occur both upstream and
downstream of the unit. Upstream impacts include those associated
with resource extraction, while downstream impacts include
changes in air emissions and water use and increased handling of
solid wastes, including hazardous wastes.

Table 5: Impacts of CCS System and Energy Penalties on Plant Resource Consumption and Emission Rates
(Capture Plant Rate and Change from Reference Plant Rate, kg/MWh)
Capture Plant Parametera

PC-CCSb (kg/MWh)

IGCC-CCSc (kg/MWh)

NGCC-CCSd (kg/MWh)

Rate

Rate

Rate

Change
from Reference

Change
from Reference

Change
from Reference

Resource Consumption

Fuel
Limestone
Ammonia
CCS reagents

390
27.5
0.80
2.76

93
6.8
0.19
2.76

364

0.005

50

0.005

156

0.80

23

0.80

107
0.001
0.77
0.23

704
0.29
0.18
0.22

97
0.011
0.10

720
0.13
0.01

43

0.11
0.002

342

0.02
0.002

28.1
49.6
NA
4.05

6.7
12.2
NA
4.05

34.2

7.7
0.005

4.7

1.2
0.005

0.94

0.94

Atmospheric Emissions

Carbon dioxide
Sulfur oxides
Nitrogen oxides
Ammonia
Solid Wastes/Byproduct

Ash/slag
FGD residues
Sulfur
Spent CCS sorbent

SOURCE: RUBIN ET AL. 2007, 44444454

a

The net power output of all plants is approximately 500 MW. Coal plants use Pittsburgh #8 coal with 2.1% sulfur, 7.2% ash, 5.1% moisture and 303.2 MJ/kg
LHV basis. Natural gas LHV = 59.9 MJ/kg. All plants capture CO2 emissions and compress to 13.7 MPa (1,990 psi).

Pulverized coal plant based on a supercritical unit with SCR, ESP and FGD systems, followed by an amine system for CO2 capture. SCR system assumes
2 ppm ammonia slip. SO2 removal efficiency is 98% for reference plant and 99% for capture plant. Net plant efficiency (LHV basis) is 40.9% without CCS and
31.2% with CCS.

IGCC system based on Texaco quench gasifiers (2 + 1 spare), two GE 7FA gas turbines, 3-pressure reheat HRSG. Sulfur removal efficiency is 98% via hydrolyzer

CCS GUIDELINES

plus Selexol system; Sulfur recovery via Klaus plant and Beavon-Stretford taigas unit. Net plant efficiency (LHV basis) is 39.1% without CCS and 33.8% with CCS.

36

NGCC plant using two GE 7FA gas turbines and 3-pressure reheat HRSG, with an amine system for CO2 capture. Net plant efficiency (LHV basis) is 55.8%
without CCS and 47.6% with CCS.

CCS = carbon dioxide capture and storage; ESP = electrostatic precipitator; FGD - flue gas desulfurization; GE = General Electric; HRSG = heat recovery steam
generator; IGCC = integrated gasification combined cycle; kg = kilogram; LHV = lower heating value; MJ = megajoule; MPa = megapascals; MW = megawatt;
MWh = megawatt-hour; NA = not available; NGCC = natural gas combined cycle; PC = pulverized coal; ppm = parts per million; psi = pounds per square inch;
SCR = selective catalytic reduction.

and compression equipment. For each technology, the first column

(Rate) presents the rate in kilograms (kg) per megawatt-hour (MWh)
for the factor being measured at a plant with CCS. The second column
(Change from Reference) shows the incremental change of the
measured factor from the reference case. All of the increases shown
in Table 5 are driven by the increased need for energy, except for the
CCS reagents, ammonia (NH3), and the spent CCS sorbent, which are
direct waste products from the capture process.
CAPTURE

The data shown in Table 5 compare new facilities with capture to

new facilities without capture. Retrofit of capture technologies on
existing coal-fired power plants would result in greater efficiency
losses and increased resource consumption. The rating of a
500-MW plant can drop by 40 percent to 294 MW with the addition
of CO2 capture devices (MIT 2007). The impact of adding capture to
an IGCC or NGCC plant is also not insignificant, resulting in
respective increases in fuel consumption of 50 and 23 percent.

2.3.1 Air Emissions

The main reasons for increased environmental impacts are the
significant parasitic energy loss, or energy penalty associated with
the capture of the CO2 and the subsequent regeneration of the
solvent or sorbent, and the use and disposal of the solvent or
sorbent. The energy penalty means that either a facility would have
to be resized to combust additional fossil fuels in order to make up
for lost energy output, or additional generation capacity (from a nonor low-CO2-emitting source) would have to be constructed to make
up for any lost output. The IPCC Special Report: Carbon Dioxide
Capture and Storage estimated that capture of 90 percent of CO2
using current technologies would result in an increased fuel
consumption of 2440 percent for new SCPC plants, 112 percent
for natural gas combined-cycle (NGCC) plants, and 1425 percent
for IGCC systems compared to similar plants without CO2 capture
and compression (IPCC 2005).
Table 5 shows the results of an analysis conducted by researchers at
Carnegie Mellon University using the Integrated Environmental
Control Model. The researchers used the model to compare
consumption of resources and generation of solid waste and air
emissions for PC, IGCC, and NGCC plants with CO2 capture and
compression equipment to identical facilities without the CO2 capture

The second set of data in Table 5 (atmospheric emissions) shows

the impact of CO2 capture and compression equipment on air
emissions. Power plants with CO2 capture would emit a CO2-depleted
flue gas to the atmosphere. The concentrations of SO2 in the flue gas
would be lower than in the flue gas of plants without CO2 capture,
since it is removed upstream of capture to enable the CO2 capture
process to operate effectively. Other air pollutant emission rates per
MWh would increase relative to reference plants without capture.
NOx emissions increase at all the facilities considered in Table 5 and
ammonia emissions would increase at PC and NGCC plants as a
result of ammonia slip from the selective catalytic reduction on the
PC facility (as described in the footnotes to the table) and ammonia
released by amine-based capture systems. These increases in NOx
and ammonia emissions could lead to increased nitrogen levels in
water bodies, resulting in eutrophication and compromising water
quality (Koornneef et al. 2008).
Information on emissions from oxy-fuel combustion is limited, since
there are currently no commercial-scale oxy-fuel-fired power plants,
and only limited pilot-scale testing has been performed. The flue gas
from oxy-fuel combustion consists mainly of CO2 and water vapor,
along with excess oxygen. After removal of the water vapor, the
CCS GUIDELINES

It is important to consider the impacts

of capture technologies
on other parts of the environment.

37

CAPTURE

amount of CO2 in the gas stream can vary from 80 to 98 percent,

depending on the fuel used and the particular oxy-fuel combustion
process. Looking back to Table 4 which included the co-constituents
left in the CO2 stream, the researchers assumed SO2 was deliberately
left in the CO2 stream and cryogenic purification was used to separate
out NOx, N2, Ar, and O2. Facilities could make alternative decisions
based on economic, system, transportation, or storage constraints.
For example, potential corrosion of the furnace and CO2 transportation
systems due to high SO2 concentrations in the flue gas could result
in the need for desulphurization of the recycled flue gas. These
decisions will affect the quantity of any air emissions, water releases,
or solid wastes.

2.3.1.1 New Source Performance Standard

and New Source Review
In the United States, new power plants and major modifications to
existing plants are subject to New Source Performance Standards
(NSPS) and New Source Review (NSR) requirements under the
Clean Air Act. NSPS set air pollutant emission limitations for new
and modified sources. Under Section 111 of the Act, the EPA is
required to publish and periodically revise a list of industry
categories and to establish standards of performance reflecting
the degree of emission reduction achievable through application of
the best system of emission reduction (Clean Air Act of 1990). The
standards must take into consideration cost, non-air impacts, and
energy requirements. The purpose of the NSPS program is to
prevent deterioration of air quality from the construction of new
and modified sources, and to reduce emission control costs by
building air pollution controls into the initial design of new builds
and major modifications to existing plants.
The NSR program is a preconstruction permitting program governing new sources of emissions and major modifications to existing
sources. New and modified sources subject to NSR located in areas
that are in attainment of standards for regulated air pollutants
(such as SO2, nitrogen oxides (NOx), ozone, and PM) must install

best available control technology (BACT), while new and modified

sources located in nonattainment areas must install lowest
achievable emission reduction (LAER) air pollution control technology.
Case-by-case determinations of BACT and LAER emission limitations
must be at least as stringent as the NSPS for any source category for
which an NSPS has been set, and often are set more stringently than
NSPS. This is particularly true for LAER determinations. BACT is an
emission limit based on the maximum degree of reduction of each
pollutant subject to regulation which is achievable (CFRb), taking
into account energy, environmental, and economic costs. LAER is
that rate of emissions which reflects:
(A) the most stringent emission limitation which is contained in
the implementation plan of any State for such class or category
of source, unless the owner or operator of the proposed source
demonstrates that such limitations are not achievable, or
(B) the most stringent emission limitation which is achieved in
practice by such class or category of source, whichever is most
stringent (CFRa).
As a result, new U.S. power plants that are proposed with CO2 capture
systems will also have to be equipped with state-of-the-art emission
controls representing NSPS and either BACT or LAER technology.
The situation with respect to retrofitting existing power plants is
more complicated. Modifications of existing major sources are only
subject to NSPS and NSR if (1) the modification is a non-routine
physical change or change in operation, and (2) the modification
will result in a new air pollutant being emitted or an increase in air
pollutant(s) previously emitted.
With regard to the first criterion, the retrofit of CO2 capture
technology to an existing PC plant, whether it be post-combustion
capture technology or oxy-fuel technology, would be considered
a non-routine physical change under EPAs NSPS and NSR
regulations. The question is whether the installation of CO2 capture
technology will result in a new air pollutant being emitted from the
facility or an increase in emissions of an air pollutant previously

CCS GUIDELINES

Table 6: Estimated Raw Water Usage With and Without CO2 Capture

38

Unit Type

Without CO2 Capture (gallons per minute)

With CO2 Capture (gallons per minute)

Subcritical Pulverized Coal

Supercritical PC
IGCC (GEE Gasifier)
IGCC (CoP Gasifier)
IGCC (Shell Gasifier)
NGCC

6,212
5,441
4,003
3,757
3,792
2,511

14,098
12,159
4,579
4,135
4,563
4,681

SOURCE: U.S. DOE 2007A

CoP = ConocoPhillips; GEE = General Electric Energy; IGCC = integrated gasification combined cycle; NGCC = natural gas combined cycle.

Wet Versus Dry Cooling

Thermal power plants can be cooled by transferring the heat produced by electricity generation either to a body of water
(once-through cooling) or to the atmosphere through a recirculating wet cooling system, through a dry cooling system, or
through a hybrid system that incorporates elements of both recirculating wet cooling and dry cooling.
In a once-through cooling system, water is withdrawn from the
environment, passed through a steam condenser and returned,
slightly heated, to the source. No water is consumed or evaporated
within the cooling system, but the evaporation rate from the re-

CAPTURE

emitted, thereby triggering the second criterion. Under the NSPS

program, emission increases are determined by comparing maximum hourly emissions (expressed in pounds per hour (lbs/hr)) prior to
the proposed change with projected maximum hourly emissions after
the change. Under the current NSR regulations, emission increases
are determined by comparing actual annual emissions (in tons) prior
to the change with projected annual emissions (in tons) after the
proposed change. If a post-combustion CO2 capture system were
added to an existing PC plant and the plant were not resized, it is
likely that emissions would not increase on a per-ton basis (although
emissions would increase per net MWh). However, if the plant were
resized to overcome the capture plants parasitic power load (energy
penalty) and maintain a power output consistent with its original
production, emissions of NOx and mercury are likely to increase. In
either case, it is also possible, that new air pollutants, such as
ammonia, could be emitted from solvent-based capture processes.

ceiving water is slightly higher.

In recirculating wet systems, smaller amounts of water (typically
23 percent of the amount withdrawn for once-through cooling)
are taken into the plant, but the majority is evaporated in the

Similarly, it is possible that emission increases would result if an

existing PC plant were converted to an oxy-fuel-fired facility,
thereby subjecting the facility to NSPS and/or NSR requirements.

cooling equipment (in mechanical or natural draft cooling

towers), with very little water returned to the receiving water
body. Water withdrawn from a local source is circulated continuously through the cooling system. The cooling system must be
replenished with make-up water to replace that lost to evapo-

2.3.2 Water Use

Power plants, with or without CO2 capture, use large amounts of
water. Table 6 lists estimates for raw water use at facilities with
and without CO2 capture on facilities with a 550-MW net output.
DOE calculates the raw water usage as the difference between the
total demand for water by processes and the internal recycled
water available within processes (boiler feedwater blowdown,
condensate, etc.). Therefore, the measurement represents the
actual consumption of water. The majority of the water (71
99 percent) is consumed through the cooling process (assumed to
be recirculating wet systems, described in the text box). Note that
water use for PC power plants more than doubles with the addition
of capture equipment.
The impacts of increased water use associated with CO2
capture are related to the increased need for system cooling. As
an alternative to wet cooling, facilities could use dry cooling
technologies. There is a tradeoff between energy use and water
use when dry cooling is employed. As a facility reduces water use,
it increases energy use, which creates an additional energy penalty

ration and blowdown.

In dry systems, the ultimate heat rejection to the environment is
achieved with air-cooled equipment that discharges heat directly to
the atmosphere by heating the air. Dry systems reduce water use
at a plant by eliminating the use of water for steam condensation,
but increase energy consumption.
In hybrid wet-dry systems, both wet and dry components are included
in the system, and they can be used separately or simultaneously for
either water conservation or plume abatement purposes. Design
studies have ranged from 30 to 98 percent reduction in water use compared to recirculating wet cooling.
The factors designers should consider when choosing a system
include:


Water availability, use, and consumption;

System costs; and

Environmental issues associated with water withdrawal and

discharge.

SOURCE: MAULBETSCH 2002.

CCS GUIDELINES

Water use for PC power plants

more than doubles
with the addition of capture equipment.

39

CAPTURE GUIDELINE 2: RECOMMENDED GUIDELINES FOR ANCILLARY ENVIRONMENTAL IMPACTS

FROM CO 2 CAPTURE
a. When constructing a new facility or retrofitting an existing facility in the United States,
operators must comply with requirements under the Clean Air Act and the Clean Water Act,
as appropriate.
b. Options for minimizing local and regional environmental impacts associated with air
emissions, use of water, and solid waste generation should be evaluated when considering
technologies for capture.
c. Use of capture technologies could result in hazardous or industrial waste streams.

CAPTURE

Operators must follow guidelines and regulations for the handling and disposal of industrial
or hazardous wastes.
d. Operators should investigate the use of combustion wastes as beneficial byproducts.
e. Currently, EPA is considering regulation of coal combustion wastes that are sent to landfills
or surface impoundments, or used as fill in surface or underground mines. Potential impacts
of the volume and concentrations of hazardous materials in the waste stream from facilities
with CO2 capture should be evaluated in this context.

(Maulbetsch 2002). The tradeoffs between dry cooling and wet

cooling will be essentially the same as they are for a plant without
CO2 capture, and will be driven by local conditions and water
availability. This tradeoff would most likely be balanced based on
the location of the plant and its potential water demand compared
to available water resources.
Water availability is becoming a concern in many U.S. regions, and it
is likely that permitting any facility that uses a large amount of water
will become increasingly difficult. This challenge is compounded in
the climate change context, because the baseline water temperature
may be higher, in addition to decreased water availability.
Retrofit of CO2 capture equipment onto an existing plant will require
amendments to a facilitys Phase I National Pollutant Discharge
Elimination System (NPDES) permit. The delivery, storage, and
handling of combustion products and solvents or sorbents will require
incorporating the processes into an existing facilitys Storm Water
Management and Spill Prevention Control and Countermeasures
plans (U.S. DOE/NETL 2007b).

CCS GUIDELINES

2.3.3 Solid Waste

40

With the increased fuel consumption, there will be a proportional

increase in solid wastes, such as bottom ash, boiler slag, and fly
ash, as represented by the ash/slag row in Table 5. There will also
be an increase in the consumption of ammonia and limestone to
reduce NOx and SO2 emissions, as well as wastes associated with
the use of amines or other sorbents (IPCC 2005). None of the wastes
generated from capture processes are expected to be unknown or
substantially more hazardous than the wastes generated by
conventional plants (U.S. DOE/NETL 2007b). It is expected that

existing rules governing solid and hazardous wastes will cover the
additional wastes associated with capture. If necessary, facilities
can process chemicals from post- or pre-combustion solvents
to remove metals and dispose of the spent solvents through
incineration (IPCC 2005).
While the solid wastes from coal combustion contain toxics
(including arsenic, mercury, chromium, lead, selenium, cadmium,
and boron), the U.S. Congress categorized fossil fuel combustion
wastes as special wastes in amendments to the Resource
Conservation and Recovery Act (RCRA), and exempted them from
federal hazardous waste regulations (Subtitle C of RCRA) until EPA
could complete additional studies. In a series of determinations
beginning in the late 1980s, EPA found that most of the exemptions
should remain. However, in 2000 EPA determined that coal
combustion wastes that are disposed of in landfills and surface
impoundments and used as fill in surface or underground mines
should be regulated as nonhazardous solid wastes under Subtitle D
of RCRA (U.S. EPA 2000). It further concluded that no additional
regulations are warranted for fossil fuel combustion wastes that
are beneficially used (for roadways, cement and concrete products,
etc.). To date, EPA has not proposed regulations under RCRA
Subtitle D. However, some individual states have promulgated their
own rules for handling solid wastes from coal-fired facilities.

CAPTURE ENDNOTES
1

Increase in cost includes sequestration activities

coal gasification differs from IGCC in that the final product of coal gasification
is a syngas that can be used in place of natural gas while an IGCC facility
gasifies the coal and combusts the product to generate electricity

TRANSPORT

P A R T

3.1 INTRODUCTION
Transporting CO2 from point-of-capture to storage sites is an important linking step in the CCS project

operations, pipeline transport is considered to be the most cost-effective and reliable method of
transporting CO2 for onshore CCS (Svensson 2004). The transport Guidelines are organized into four
sections: design and operations, safety and integrity, siting and pipeline access, and tariff regulations.

CCS GUIDELINES

cycle. Although CO2 is transported via pipelines, ships, and tanker trucks for EOR and other industrial

41

Current pipeline operational practices are described to provide

context. The Guidelines are intendedto help regulators, policymakers, and industry prepare for the potential development of a
large-scale CO2 pipeline infrastructure.

3.1.1 Developing CO2 Pipeline

Infrastructure for CCS

CCS GUIDELINES

TRANSPORT

Deploying CCS at a scale required to mitigate global warming will

require transporting substantial quantities of CO2 from capture to
storage sites.

42

The nature and extent of the network of CO2 pipelines that would
be necessary to transport such amounts of CO2 will depend on many
factors, including the proximity of storage sites to the capture
facilities, the costs to acquire pipeline rights of way and associated
permits, the cost to construct the pipelines, and the attendant
costs to operate the pipelines and comply with operations and
maintenance regulations.

3.1.2 CO2 Pipeline Operating Experience

In the United States, significant CO2 pipeline operating experience
exists in the EOR industry. Since the early 1970s, pipeline companies
have been successfully operating a substantial CO2 pipeline
infrastructure (Figure 6), transporting an estimated 0.78 trillion cubic
feet of CO2 per year through an estimated 3,900 miles1 of infrastructure, through pipelines of varying diameters, mainly for use in
EOR.2 The Permian Basin region of West Texas and New Mexico
remains the center of CO2-based EOR activity. The oldest longdistance CO2 pipeline in the United States is the 140-mile Canyon
Reef Carriers pipeline, which began service in 1972 for EOR in
regional Texas oil fields. The longest CO2 pipeline, the 502-mile Cortez
pipeline, has been delivering about 20 million metric tons of CO2 per
year to the CO2 hub in Denver City, Texas, since 1984.

CO2 Composition
CO2 used for carbon dioxide capture and storage is typically in the
supercritical stage, where the density resembles a liquid but it expands to fill space like a gas. Supercritical CO2 is purchased, as a

The CO2 pipeline networks developed for the CCS market will evolve
over time. Early projects are likely to rely on a mix of options,
including use (or expansion) of the existing CO2 pipeline infrastructure and the development of dedicated pipelines that are sized
and located for individual projects to accommodate the CO2
specifications of those projects. Under other scenarios, a fully
integrated network that utilizes CO2 from several sources may be
practical. In light of the overall costs associated with CO2 pipelines,
including the uncertainty about future material costs and cost
recovery, some analysts anticipate that the CO2 network for CCS
will begin with short pipelines from CO2 sources located close to
storage sites, with a larger regional network of interconnected lines
developing as the number of projects grows (MIT 2007). Another
study estimates that storage reservoirs may be sufficiently
distributed, such that 77 percent of the total annual CO2 emissions
from the major North American sources may be stored in reservoirs
directly underlying these sources, and an additional 18 percent may
be stored within 100 miles of the original sources (Dahowski et al.
2006). As geologic formations are characterized in more detail and
suitable repositories are identified, CO2 sources can be mapped
against storage sites with increasing certainty.

commodity, for use in many industrial processes. In the climate

change context CO2 is most often classified as an important
greenhouse gas, an emission, orin some countriesa waste.
There is concern that the classification of CO2 under various U.S.
regulatory programs (e.g., air, waste, drinking water protection)
may trigger unintended requirements that impose increased cost
without increasing project performance or safety.
In response to this concern, the Interstate Oil and Gas Compact
Commission recommends that CO2 not be classified as a waste and,
in fact, suggests that states adopt legislation recognizing CO2 of certain purity as a commodity. At least one state (Oklahoma) has
followed this lead. International frameworks have taken varied
approaches. For example, Australia regulations use greenhouse gas
substances and the London Protocol specifies carbon dioxide
streams from carbon dioxide capture processes for sequestration.
Some stakeholders have advocated for setting a CO2 purity standard of >90 percent, but many feel that there is enough
uncertainty regarding the precise composition of the CO2 stream
that it is best to simply design projects with materials and procedures that account for any co-constituents in the gas stream.

Deploying CCS at a scale required

to mitigate global warming will require
transporting substantial quantities of CO2
from capture to storage sites.

3.2 PIPELINE DESIGN

AND OPERATIONS
3.2.1 Pipeline CO2 Composition
Prior to transport, captured CO2 is conditioned to remove impurities
and compressed into supercritical form. The U.S. Department of
Transportations (DOTs) Office of Pipeline Safety (OPS) defines
pipeline CO2 as a fluid consisting of more than 90 percent CO2
molecules compressed to a supercritical state. There are currently
no composition requirements (e.g., moisture or co-constituents) for
the transport and geologic storage of CO2 (MIT 2007). While there
is no established standard for permitted levels of impurities in CO2
for CCS, the pipeline-quality CO2 compositions adhered to by the
major EOR pipeline operators constitute best practice. Currently,
these requirements are built into contracts between the supplier
and the transporter and between the transporter and the end user.

While not strictly a transport issue, the impact of injection of

co-constituents with CO2 is unknown on a large scale and will most
likely affect the requirements for CO2 purity. For the sole purpose of
storage, the threshold for impurities could be different; hence, the
processing requirements and pipeline standards could be uniquely
prescribed for a particular project (described as Type I in the
textbox). On the other hand, interest in developing a network of
interconnectable pipelines, for maximum utilization of geologic
storage sites with or without oil recovery opportunities, may
indicate the need for of a set of CO2 specifications for pipelines
similar to the ones in use today for EOR.

Means of Transporting CO2

CO2 Pipeline Regulations

Pipelines are the dominant mode of transporting CO2. In the

Existing CO2 pipelines are subject to diverse local, state, and fed-

United States there is an estimated 3,900 miles of CO2 pipelines

eral regulatory oversight. The U.S. Department of Transportations

transporting CO2 for enhanced oil recovery operations. Tanker and

Office of Pipeline Safety (OPS) sets minimum safety standards for

pipelines transporting hazardous liquids, including CO2 (CFR 49

industries. About 100,000 tons of CO2 are transported annually for

Part 195). OPS regulates interstate pipelines and certifies states to

these industriesfar less than the amounts expected to be asso-

carry out intrastate pipeline regulation and enforcement activi-

ciated with a commercial-scale power plant, or even ethanol,

ties. In contrast to natural gas pipelines, which are subject to siting

cement, or natural gas refining output. The advantage of pipeline

and rate regulation under the Natural Gas Act of 1938 (as

transportation of CO2 is that it can deliver a constant and steady

amended) by the Federal Energy Regulatory Commission, there is

supply of CO2 without the need for intermediate storage along

no federal general certification of pipeline construction or rate

a distribution route. Ship transportation of large quantities of

regulation and no federal protection from the entry of compet-

CO2 may be feasible when it needs to be transported over long

ing CO2 pipelines. Under the Mineral Leasing Act, however, CO2

distances or overseas; however, many anthropogenic CO2 sources

pipelines may be subject to access and rate conditions imposed by

are located far from navigable waterways, so such a scheme will

the Bureau of Land Management when they cross federal lands,

still most likely require pipeline construction between CO2 sources

and are in any event subject to rate and some siting regulation

and port terminals.

by individual states.

CCS GUIDELINES

ship CO2 transportation is mainly found in the food and beverage

TRANSPORT

Captured CO2 may contain impurities like water vapor, H2S, N2,
methane (CH4), O2, mercury, and hydrocarbons that may require
specific handling or treatment. Before transport, the CO2 is
dehydrated to levels below 50 ppm of water. Presence of water
above this level is not desirable from an operational standpoint
(Aspelund and Jordal 2007). CO2 reacts with water to form carbonic
acid, which is corrosive. Additionally, under the appropriate thermodynamic conditions, hydrates (solid ice-like crystals) can form and
plug the pipeline (Barrie et al. 2004). H2S is toxic, even at low
concentrations of 200 ppm. Pipelines containing H2S will require
extra due diligence, particularly near populations. However, it is
important to note that it is possible to safely store H2S with CO2;
facilities in Canada have been disposing of H2S through injection in
geologic formations since 1989 (Heinrich et al. 2004).3 Injection of

acid gas4 currently occurs at 39 active operations in Alberta and

northeastern British Columbia. Since surface desulfurization through
the Claus process is generally uneconomical, and the surface
storage of the produced sulfur constitutes a liability, more operators
are turning to acid gas disposal by injection into deep geologic
formations. Dehydration is particularly important in these cases,
because H2S reacts with water to form sulfuric acid, which is highly
corrosive and may also result in pipeline cracking, increasing the
potential for leaks. The presence of CH4 affects the exhibited vapor
pressure of CO2 and complicates the accurate prediction of flow
(Svensson 2004). In EOR applications, in particular where organic
materials are present for bacteria, oxygen is tolerable only in minute
quantities (10 ppm). Even in deep saline formations organics may be
present, and significant quantities of oxygen in the gas stream could
allow for formation of bacterial colonies, affecting the injection
operations. Additionally and significantly, mercury is present in coal
and is a natural byproduct of the combustion process; it could
condense in the pipeline system and create operational issues as
well as implications for storage.

43

TRANSPORT

Figure 6: Existing CO2 Pipelines in the U.S.

A D A P T E D F R O M N AT C A R B D ATA B A S E , C O U R T E S Y O F S T E V E M E L Z E R

3.2.2 Pipeline Operating Temperature

and Pressure
The most efficient way to transport CO2 is in a supercritical
phase.4 The critical point at which CO2 exists in a supercritical phase
is 1,070 psi (73 atmospheres (atm)) and 88 F (31 C) (Figure 6). CO2
is generally transported at temperature and pressure ranges
between 55 F and 110 F and 1,250 psi (85 atm) and 2,200 psi (149.6
atm), respectively (Mohitpour et al. 2007; Kinder Morgan 2006). The
upper pressure limit is mostly due to economic concerns, and is set
to the ASME-ANSI 900# flange rating (the maximum pressures for
ANSI 900# flange is material dependent).5 The lower pressure limit
is set by the phase behavior of CO2, and should be sufficient to
maintain supercritical condition. The upper temperature limit is
determined by the compressor-station discharge temperature and
the temperature limits of the external pipeline coating material. The
o

CCS GUIDELINES

44

lower temperature limit is set by winter ground temperature

(Farris 1983).
It is important for operators to maintain single-phase flow in CO2
pipelines by avoiding abrupt pressure drops. In a two-phase flow,
two physical phases are present in the pipeline simultaneously
(e.g., liquid and gas, or supercritical fluid and gas), which creates
problems for compressors and other transport equipment,
increasing the chances of pipeline failure (IPCC 2005). At pressures
very close to the critical point, a small change in temperature or
pressure yields a very large change in the density of CO2, which
could result in a change of phase and fluid velocity, resulting in slug
flow.6 Transmission pipelines may experience changing temperatures because of both weather and pipeline conditions. Operators
should include a wide margin of safety above the rated critical
pressure of CO2 to avoid complications.

EOR Industry CO2 Purity Specifications

Primary Types of CO2 Pipelines

For enhanced oil recovery, the CO2 concentration in the gas trans-

Existing CO2 pipelines operate at pressures ranging from 1,250

portable via pipeline typically ranges from 95 to 99 percent. At

to 2,200 pounds per square inch (psi.) Since most natural gas

pressure in a reservoir, CO2 can combine with components in the oil

pipelines operate at pressures at or below 1,200 psi, CO2 pipelines

to create miscibility, wherein the fluid combination moves through

are constructed specifically for transporting CO2 and are normally

the reservoir with a viscosity like that of a liquid rather than a gas.

listed as either Type II or Type III pipelines. Acceptable CO2 and

For this to happen in the reservoir, the CO2 should be quite pure. De-

co-constituent concentrations for both pipeline types are shown

pending on the depth of the reservoir and properties of the oil, this

in the table below.

may be 90 percent purity or higher. Other constituents can also be

important. Nitrogen and methane raise the pressure at which the

The majority of the CO2 pipelines in North America can be listed

as Type II pipelines, which serve multiple sources and user lines and

dense phase is reached, as well as the minimum miscibility pressure.

have a strictly limited composition. Less common Type III pipelines
A subtle feature of using highly purified CO2 (>95%) that is not

have relaxed composition standards when compared to Type II

readily apparent at first glance is its ability, when compressed and

pipelines. The best example of a Type III pipeline is the pipeline that

cooled, to form a supercritical fluid. Should significant amounts of

connects the Dakota Gasification plant near Beulah, North Dakota

noncondensable gases such as oxygen, nitrogen, or methane be

with the Weyburn enhanced oil recovery (EOR) project in southern

Saskatchewan. This pipeline carries a CO2 mix that has a relatively
higher hydrogen sulfide (H2S) concentration. It should be noted that

the pipeline designer should conduct appropriate compositional

extra operational precautions are required at both the source and

simulations to guarantee that supercritical phase behavior can be

the sinks when there are high H2S concentrations. As a result of the

achieved at proposed pipeline operating conditions. Additionally,

different composition standards, it will not be easy for operators

oxygen may also lead to overheating at the injection point due to

to connect Type III pipelines to Type II pipelines.

reaction with oil and formation of bacterial colonies.

SOURCES: ZHANG ET AL. 2004; ASPELUND AND JORDAL 2007.

Type I pipelines do not exist in todays CO2 EOR industry, but can

TRANSPORT

present in the CO2 stream, it may not be possible to practically produce a supercritical fluid. Thus, for any proposed gas composition,

be developed for a specific single use (i.e., a single CCS project).

These pipelines can be applied to situations wherein case-by-case

3.2.3 Pipeline Design

There are existing design and safety criteria to ensure safe and
reliable transport of CO2. Pipeline designers consider the pressure,
temperature, and properties of the fluid; the elevation or slope of
the terrain; dynamic effects, such as earthquakes, waves, currents,
live and dead loads,7 and thermal expansion and contraction; and
the relative movement of connected components. The compressibility and density of CO2 undergo significant nonlinear variation in
normal pipeline operating conditions (within normal pipeline
pressure and temperature ranges). Therefore, the design of CO2
pipelines requires point-by-point estimation of fluid properties using
computational models (MRCSP 2005).

CO2 EOR pipeline network of Type II pipelines.

Parameter

Type I

Type II

Type III

CO2% by volume
H2Sppmbw
Sulphurppmbw
Total hydrocarbons% by volume
CH4% by volume
C2 + hydrocarbons% by volume
CO% by volume
N2% by volume/weight
O2ppm by weight/volume
H2O#/mmcf* or ppm by volume**

>95%
<10
<35
<5
<4
<10
<25*

>95%
<20
<30
<5
<4
<10
<30*

>96%
<10,000
<0.7
<23,000
<1,000
<300
<50
<20**

C2 = carbon; CH4 = methane; CO = carbon monoxide; CO2 = carbon dioxide;

H2O = water; H2S = hydrogen sulfide; mmcf = millions of cubic feet;
N2 = nitrogen; ppm = parts per million; O2 = oxygen;
ppmbw = ppm by weight
TA B L E C O U R T E S Y O F S T E V E M E L Z E R .

CCS GUIDELINES

For pipeline construction, selection of pipe diameter, wall thickness,

material strength, and toughness depends on the transmissible fluids
temperature, pressure, composition, and flow rate. For example, fluid
flow rates are lower in larger-diameter pipes. Lower fluid flow rates
result in fewer pressure drops, allowing a pipeline designer to
consider reducing the pressure requirements for CO2 entering the
pipeline, or reducing the number of compressors along the pipeline.
However, the installation costs of pipelines rise with increases in
diameter. A designer will consider the economic tradeoff of increasing
pipeline diameter with the cost of CO2 compression.

specifications for CO2 composition are appropriate based upon the

capture system, but they cannot be connected with the existing

45

Figure 7: Variation of CO2 Density as a Function

of Temperature and Pressure

CCS GUIDELINES

TRANSPORT

SOURCE: BACHU 2003

46

Compression is the largest operating cost for the transmission system.

Compressors convert the transmissible gas from atmospheric pressure
to supercritical state, the desired transmissible phase. Moreover,
depending on the length and terrain of pipeline, recompression or
decompression of CO2 may be required to maintain supercritical phase
CO2. The CO2 pipeline industry currently uses centrifugal, single-stage,
radial-split pumps for recompression, rather than compressors
(Mohitpour et al. 2007). These booster pumping stations are installed
as required to maintain sufficient pressure at high elevation points,
in order to ensure a single-phase CO2 flow (Nestleroth 2007). For
reference, the compression unit at the Great Plains Synfuel Plant
consists of two 8-stage compressors. Feedgas is taken at 3 pound per
square inch gauge (psig) and compressed to 2,700 psig, which is in
the supercritical range for CO2 (Perry and Eliasson 2004).
Avoiding initiation and propagation of longitudinal-running fractures
is also essential. Fracture arresters are typically installed every 500
meters (545 yards), and lower-strength steel and thicker-wall pipe
are employed (IPCC 2005; Mohitpour et al. 2007). The pipelines for
CO2 transportation are usually constructed of steel (60,00080,000
psi yield strength), such as American Petroleum Institute (API) X60or X80-grade material. The optimum strength and wall thickness are
determined based on the aforementioned factors, as well as
fabrication and handling considerations. To reduce the chances of
corrosion, CO2 pipelines typically have an external coating of
fusion-bonded epoxy or polyurethane with full cathodic protection;
internal pipeline coatings are also available and can be applied
where appropriate (MRCSP 2005).
The main components of a pipeline include valves, compressors,
booster pumps, pig launchers and receivers, batching stations and

instrumentation, metering stations, and Supervisory Control and

Data Acquisition (SCADA) systems. Valves are typically used for
control functions around compressor and metering stations and at
the injection sites. One important consideration in pipeline design
is the distance between block valves. Block valves are used to
isolate sections of pipe in the event of a leak or for maintenance.
Block valves are spaced every 1632 kilometers (1020 miles),
depending on the location of the pipe, and are installed more
frequently near critical locations, such as road and river crossings
and urban areas. Installing block valves more frequently increases
both the cost of the pipeline and the risk of leakage from the valves
themselves. The farther apart the valves are installed, the greater
the volume contained between the valves, which increases the
distance from the pipeline required for the gas to dissipate to a safe
level in the event of a pipeline rupture (Gale and Davidson 2004).
Current pipeline design safety standards already take into
consideration valve spacing as a function of pipeline diameter and
surrounding land use.
Instrumentation along the pipeline is typically used to measure the
flow rate, pressure, and temperature of the CO2 and provides
sufficient information for the pipelines normal operation. The
instrumentation is located at compressor and metering stations and
sometimes at the block valves. SCADA systems are used for remote
monitoring and operation of the compressor stations and the
pipeline. These systems are designed to provide operators at a
central control center with sufficient data on the status of the
pipeline to enable them to control the flows through the compressors and the pipeline as necessary (MRCSP 2005). Metering is
used for computational pipeline monitoring (CPM) leak-detection
systems for single-phase lines (without gas in the liquid). Currently
CO2 pipelines are not required to have CPM, mainly because it is
technically difficult. Other leak-detection methods, such as pressure
point analysis and aerial and visual surveys, may be used to ensure
safe CO2 transport.
The majority of onshore CO2 pipelines are buried over most of their
length, to a depth of 1-1.2 meters (3-4 feet), except at metering or
pumping stations, and most offshore lines are also usually buried below
the shallow water seabed. In deeper water, only pipelines with a
diameter of less than 400 millimeters (16 inches) are trenched and
sometimes buried to protect them against damage by fishing gear (IPCC
2005). The exact depth varies based on project-specific needs, and
variances can be granted where appropriate.
Experience from decades of pipeline operations suggests that designing and operating CO2 pipelines do not pose any new challenges. The
optimum solution is site specific and will depend on different factors,
including volumes of gas to be transmitted, gas composition, local
population density, topography, and meteorological conditions.

TRANSPORT GUIDELINE 1: RECOMMENDED GUIDELINES FOR PIPELINE DESIGN AND OPERATION

a. CO2 pipeline design specifications should be fit-for-purpose and consistent with the
projected concentrations of co-constituents, particularly water, hydrogen sulfide (H2S),
oxygen, hydrocarbons, and mercury.
b. Existing industry experience and regulations for pipeline design and operation should be
applied to future CCS projects.

3.3 PIPELINE SAFETY

AND INTEGRITY
3.3.1 Pipeline Safety Regulations
OPS administers a national regulatory program to ensure the safety
of pipelines transporting natural gas and other gases, liquefied
natural gas, hazardous liquids, and CO2.8 CO2 pipelines are
regulated under the same rules as hazardous liquid pipelines9
codified in 49 CFR 195 (CFRe).

Pipeline safety statutes do allow for individual states to assume the

intrastate regulatory, inspection, and enforcement responsibilities
under an annual certification. To qualify for certification, a state must
adopt the minimum federal regulations and may adopt additional or
more stringent regulations, so long as they are not incompatible. A
state must also provide for injunctive and monetary sanctions that
are substantially the same as those authorized by the pipeline safety
statutes. Currently, 14 states are certified to regulate intrastate CO2
pipelines.10 A state that does not satisfy the criteria for certification
may enter into an agreement to undertake certain aspects of the

For the 34 states that are not certified or that have not entered into
an agreement with OPS to regulate CO2 pipelines at the state level,
the safety regulations in 49 CFR 195 apply (CFRe).

3.3.2 Comparative Safety of CO2 Pipelines

The risks posed by increasing CO2 pipelines should be manageable
based on the extensive CO2 pipeline operating experience of
industry. The DOT data suggest that the impacts from CO2 pipeline
incidents are typically less than those from natural gas and
hazardous liquid pipelines. As measured by the lack of fatalities
and injuries, and significantly lower property damage, impacts from
CO2 pipeline incidents are typically less than those from natural gas
and hazardous liquid pipelines.

TRANSPORT

While OPS is primarily responsible for developing, issuing, and enforcing

pipeline safety regulations for interstate pipelines, it may authorize a state
to act as its agent to inspect interstate pipelines. For hazardous liquid
pipelines, currently six states maintain oversight of the interstate pipelines
thatcrosstheirstate(U.S.DOT2005).Evenwheretheoversightisdelegated
to a state, OPS retains responsibility for enforcement of the regulations for
interstate pipelines.

pipeline safety program for intrastate facilities on behalf of OPS. While

the state agency under such an agreement will inspect pipeline
operators to ascertain their compliance with federal safety regulations,
any probable violations are reported to OPS for enforcement action.
Kentucky and South Carolina operate their intrastate CO2 pipelines
under such an agreement.

The main cause for CO2 pipeline incidents appears to be material failure
(i.e., relief valve failure, valve/gasket/weld or packing failure), followed
by corrosion and outside force (Gale and Davidson 2007; Kadnar 2007).
While CO2 is more benign than many other fluids transported through
pipelines, it is important to note that the CO2 pipeline incident statistics
are also probably related to the fact that there are many fewer miles
of CO2 pipelines than pipelines transporting other fluids, and they tend
to be located in less populated areas.

3.3.3 Environmental Health and Safety

CCS GUIDELINES

Surface risks of CO2 leakage from pipelines are covered by state

environmental, health, and safety regulations, which are established
by OSHA and the U.S. Department of Labor, and adopted and
enforced mainly by the states (Chaudhuri 2006). The National
Institute for Occupational Safety and Health (NIOSH) also carries out
research and publishes its own recommendations for workplace
safety. However, only those promulgated by OSHA have the force of
law. The permissible exposure and air contamination limit for CO2 as
specified by OSHA is 5,000 ppm (U.S. DOL/OSHA 2007).

47

TRANSPORT

Siting a pipeline involves determining the route,

assessing the environmental impacts at the proposed route,
evaluating route alternatives,
and acquiring the rights of way.
The presence of co-constituents, particularly H2S, can also pose
significant safety challenges for pipeline operations. According to
NIOSH, the exposure threshold at which CO2 is immediately
dangerous to life or health is 40,000 ppm; for H2S, it is 100 ppm. The
Subcommittee on Consequence Actions and Protective Assessments
(SCAPA) provides the recommendations for emergency preparedness
to assist in safeguarding the health and safety of workers and the
public. The SCAPA has developed Preventive Action Criteria (PAC),
which provide chemical exposure limit values for well over 3,000
chemicals to support emergency response planning applications. Key
components of the PACs are the Temporary Emergency Exposure
Limits (TEELs). TEEL-2 refers to the maximum concentration in air
below which it is believed nearly all individuals could be exposed
without experiencing or developing irreversible or other serious
health effects or symptoms that could impair their abilities to take
protective action. For H2S, the limit for TEEL-2 is 27 ppm. The final risk
assessment report for the four candidate FutureGen sites in Illinois
and Texas presents a detailed discussion on potential risks associated
with CO2 pipeline operations (U.S. DOE 2007b). Overall, the discussion
found the risks to be reasonably manageable. Of the identified risks,
exposure to H2S releases was identified as one of the more prominent
concerns about pipeline rupture or puncture for both workers outside
of the immediate vicinity of a release and nearby populations.
OPS regulations have been very effective in ensuring the safety of CO2
pipelines, In the 19902002 period there were 10 incidents, caused by
relief valve failure (4), weld/gasket/valve packing failure (3), corrosion
(2), and outside force (1). The incident rate was 0.00032 km-1 yr-1 (IPCC
2005). However, the administrative burden of these regulations is

considered heavy, and OPS currently exempts from regulation (49 CFR
195) certain low-stress11 pipelines, such as production, processing,
gathering, and distribution pipelines; in-plant pipelines; and pipelines located in rural areas.12 DOT has issued a Notice of Proposed
Rulemaking, proposing to extend the pipeline safety regulations to the
exempted pipelines (CFRe).

3.3.4 Addressing Potential Public

and Environmental Concerns
To help address potential public concerns about pipelines, it is
important for regulators and the industry to characterize potential
risks. The potential consequences of CO2 incidents can be modeled
on a site-specific basis using several standard methods, taking into
account such local conditions as topography, meteorology, and
population density (IPCC 2005). For example, the EPA has a list of
simulators used to model exposure hazards. These tools, which were
used for the FutureGen environmental impact assessment (U.S. DOE
2007b), can help predict the potential impact of CO2 releases from
point sources, providing information to potential regulators and
stakeholders regarding concerns about pipeline siting.
Other ways of addressing the potential risks are leak-detection
odorants and pipeline monitoring systems (visual and aerial). Odorants
are often added to natural gas distribution pipelines for leak detection
because of the concerns about the toxicity and flammability of natural
gas. The potential benefits as well as the costs of adding odorants to
CO2 pipelines, particularly pipelines running through heavily populated
areas, should be assessed. Unlike leaks from natural gas pipelines,

TRANSPORT GUIDELINE 2: RECOMMENDED GUIDELINES FOR PIPELINE SAFETY AND INTEGRITY

a. Operators should follow the existing Occupational Safety and Health Administration (OSHA)
standards for safe handling of CO2.

CCS GUIDELINES

b. Plants operating small in-plant pipelines should consider adopting Office of Pipeline Safety

48

(OPS) regulations as a minimum for best practice.

c. Pipelines located in vulnerable areas (populated or ecologically sensitive or seismically active
areas) require extra due diligence by operators to ensure safe pipeline operations. Options for
increasing due diligence include decreased spacing of mainline valves, greater depths of
burial, and increased frequency of pipeline integrity assessments and monitoring for leaks.
d. If the pipeline is designed to handle H2S, operators should adopt appropriate protection for
handling and exposure.

leaks from CO2 pipelines are usually noticeable due to formation of

visible gas, solid droplets, and temperature changes. Because CO2 is
denser than air, it has the potential to accumulate in low-lying areas
under the right conditions; however, it tends to disperse very quickly,
preventing accumulation. While it is highly unlikely that CO2 could
slowly leak from a pipeline and accumulate in a low-lying area (such
as a basement), this remote possibility warrants a further evaluation
of whether odorants should be considered in high-consequence areas.
Mercaptans, naturally present in the Weyburn pipeline system, are
the most effective odorants, but are not broadly suitable for this
application because they are degraded by oxygen and moisture, even
at very low concentrations. Disulfides, thioethers, and ring compounds
containing sulfur are alternatives (IPCC 2005; Usher 1999). The
challenge with odorants is that they increase the cost of using
pipelines, and they are an added constituent in the injection stream.

As CO2 pipelines are developed at the scale required for CCS,

legislation imposing federal siting and economic regulation of CO2
pipelines could be warranted. In this case, the jurisdiction of these
pipelines could fall under the purview of the Federal Energy
Regulatory Commission (FERC) or the Surface Transportation Board
(STB). However, at the commencement of the development of
interstate CO2 pipelines during the late 1970s, both FERC and the
Interstate Commerce Commission (ICC, a precursor agency to STB)
determined that Congress had not extended regulatory jurisdiction
over CO2 pipelines under the existing applicable statutes (i.e., the
Natural Gas Act of 1938 and the Interstate Commerce Act) (Vann,
and Parfomak 2008).

3.4.1 Siting of CO2 Pipelines

Unlike interstate natural gas pipelines, which are regulated by FERC15

and whose owners may exercise eminent domain if they receive a
certificate of public convenience and necessity under Section 7(c) of

Implications of CO2 Properties on Pipeline Siting

CO2 is colorless, odorless, tasteless, nonflammable, nonpoisonous,
and soluble in water. CO2 occurs naturally in the air we breathe
and in deposits in the subsurface. A continuous exposure to CO2
at just over a 2 percent concentration can cause depressions of the
central nervous system in humans. At concentrations higher than
10 percent, it can cause severe injury or death due to asphyxiation. A property of CO2 that needs to be considered when selecting
a pipeline route is the fact that CO2 is denser than air and can
therefore accumulate to potentially dangerous concentrations in
low-lying areas.

Siting Natural Gas Pipelines

Natural gas pipelines are regulated by the Federal Energy Regulatory
Commission (FERC). For interstate natural gas pipelines, developers
must obtain a certificate of public convenience and necessity from
FERC, which establishes the terms and conditions under which the
pipeline may be built and initially operated, and also confers eminent
domain authority for siting pipelines. For intrastate natural gas
pipelines or distribution lines, the applicable state law typically provides a mechanism under which a right of eminent domain may be
acquired. The state agencies currently involved in the various processes

If a landowner and the pipeline company cannot agree to a price, or

if a landowner refuses to grant an easement, the pipeline company
may, in some states, acquire the right to use the land through the
power of eminent domain.14 Federal and state governments

related to siting a pipeline or distribution pipeline may include public utility commissions, natural resource commissions, oil and gas
commissions, environmental protection agencies, transportation commissions, and departments of agriculture and human health.

CCS GUIDELINES

Siting a pipeline involves determining the route, assessing the

environmental impacts at the proposed route, evaluating route
alternatives, and acquiring the rights of way. Acquiring the rights of
way usually involves gaining access to a portion of the shoulder of
a road, or obtaining an easement on private property (MRCSP 2005).
A rights-of-way agreement between the pipeline operator and
landowner is a form of easement.13 A new pipeline developer can
either use an existing rights-of-way corridor or create a new one
by negotiating with each landowner along the route.

A common carrier pipeline is subject to special duties under the

applicable laws that generally seek to ensure fair terms of access
and reasonable rates. The question whether a particular pipeline is
a common carrier under the law of a particular state may depend on
the particular legislative provisions of state law, the facts of the case,
and judicial decisions. As put by one court, [t]here is scarcely any
field of law more ancient or more written on than that of carriers (U.S.
Court of Appeals 1960). Whether the pipeline in question is
operating in interstate or intrastate commerce, however, is generally
not relevant to whether it is or is not a common carrier (Gorton 1971;
Speta 2002; Wyman 1904; Burdick 1911; Pitsch and Bresnahan 1996).

TRANSPORT

3.4 CO 2 PIPELINE
SITING REGULATION

have the constitutional power to grant public utilities and common

carriers the power of eminent domain to acquire land for public
purposes, and some states have granted this power by legislation
to certain public utilities and common carriers.

49

TRANSPORT

the Natural Gas Act, no comparable federal certification is required

to construct a CO2 pipeline, nor is there any mechanism for
developers of proposed CO2 pipelines to obtain a federal right of
eminent domain.16
The U.S. Department of the Interiors Bureau of Land Management
(BLM) regulates the siting of CO2 pipelines for EOR on BLMmanaged lands. The Federal Land Policy and Management Act of
1976 (FLPMA) and the Mineral Leasing Act of 1920 as amended
(MLA) contain provisions for granting rights of way for siting
pipelines on federal lands managed by BLM (U.S. DOI/BLM/OS
2001; USCa). The FLPMA allows BLM to grant rights of way for
pipelines transporting liquids and gases, other than water and
other than oil, natural gas, synthetic liquid or gaseous fuels, or any
refined product produced therewith. Under the MLA, BLM can
permit oil and natural gas pipelines. A significant difference
between the MLA and the FLPMA is that the MLA imposes a
common carrier requirement, while the FLPMA does not. Recent
BLM practice has been to consider CO2 as a natural gas (as CO2
is mainly obtained from natural sources), and thus to grant rights of
way under the MLA, which could make CO2 pipelines eligible for
the common carrier requirement.
For CCS, older and well-established natural gas pipeline corridors
may in some cases allow additional pipelines for CO2 to be laid
using the same right of way by negotiating an agreement with the
existing right-of-way owner, which may facilitate siting of CO2
pipelines. However, the availability of this option will depend on
the particular wording of the existing right-of-way agreement or
perhaps on the terms under which a particular parcel of land was
originally acquired (whether through negotiation or through a
condemnation proceeding). Public and private landowners may seek
additional compensation for construction of an additional pipeline,
and their right to do so is likely to vary, depending on the applicable
law and the particular facts of the situation. Thus, the extent to
which new CO2 pipelines will be able to take advantage of current
state condemnation statutes and regulations that will grant the
power of eminent domain will vary state by state.
For the construction of new pipelines on a scale required for
large-scale deployment of CCS, some form of federal eminent
domain may be appropriate under which CO2 pipelines might be

considered a public utility or a common carrier. Obtaining a

certificate of public convenience and necessity (such as the one
required for interstate natural gas pipelines to obtain eminent
domain from FERC) may help development of a CO2 pipeline, as it
would mean that the pipeline is being treated as a public utility,
giving a pipeline developer authority to condemn a right of way.
Conversely, a common carrier requirement may complicate CO2
pipeline development, particularly if several sources of CO2 want to
use the same pipeline to transport to a common sink. Different
carriage regulations address the question of allocating available
capacity or adding new capacity very differently, and it is not clear at
present what type of capacity allocation and access rules may be
appropriate for the CCS industry. This issue has already arisen on
federal lands managed by BLM. Although the agency currently
permits CO2 pipelines for EOR under the MLA, CO2 pipeline companies
seeking to avoid common carrier requirements under CCS schemes
may litigate to secure rights of way under the FLPMA (Parfomak
2008). For example, in Exxon v. Lujan, Exxon argued that its
application for a CO2 pipeline right of way should have been granted
under the FLPMA rather than the MLA. The crux of the case was the
reasonableness of BLMs classification of CO2 as a natural gas under
the MLA. Exxon contended that the term natural gas should be
applied to the hydrocarbon fuel, while BLM maintained that natural
gas under the MLA has a broader meaning, referring to all naturally
occurring gases (MRCSP 2005). This may require reconsideration for
CCS, as the CO2 will be supplied from anthropogenic sources and may
not fit under the definition of a natural gas.
Oversight by multiple agencies that regulate different aspects of
siting CO2 pipelines could cause delays and increase costs for
pipeline developers. For interstate pipelines, developers must gain
approval from numerous state agencies and individual landowners
to acquire rights of way. Negotiating with multiple agencies in two
or more states could be a time-consuming and expensive task for
developers. But since differing rules will apply in the various states,
much of this complexity will be unavoidable. One possible approach
to streamline this process could be to set up a one-stop permitting
process for CO2 pipelines, where the various permitting steps
required in the state can be handled by one agency in consultation
with interested parties and concerned agencies. The power of

CCS GUIDELINES

TRANSPORT GUIDELINE 3: RECOMMENDED GUIDELINES FOR SITING CO 2 PIPELINES

50

a. Considering the extent of CO2 pipeline needs for large-scale CCS, a more efficient means of
regulating the siting of interstate CO2 pipelines should be considered at the federal level,
based on consultation with states, industry, and other stakeholders.
b. As a broader CO2 pipeline infrastructure develops, regulators should consider allowing CO2
pipeline developers to take advantage of current state condemnation statutes and
regulations that will facilitate rights-of-way acquisition negotiations.

eminent domain could be included in the enabling statute or

regulations of such a siting agency. Thus, rather than having two
separate proceedings, one for siting and one for eminent domain, a
siting agency could be authorized to make both determinations at
once. An entity that obtains a siting certificate would automatically
have the power of eminent domain (MRCSP 2005).
Depending on terrain and length of CO2 pipeline, pumping stations
may be required and could become another siting issue. As the
pumps are above ground, nearby residents could have issues with
potential noise, view, safety, and security concerns. In addition, fuel
(or electricity) to operate the pumps will be required to be brought
to the site. With natural gas pipelines, the gas is often taken from
the pipeline and used to fuel compressors.

3.5 PIPELINE ACCESS

AND TARIFF REGULATION

Pipelines constructed for the exclusive use of a single power plant

for on-site or nearby CO2 storage could be considered an extension
of the plant. Alternatively, they could be considered a non-plant
asset providing a transportation service for a fee, in which case the
costs could still be recovered by the utility in its rates as an
operating cost. This could raise questions about cost recovery for
electric utilities under state utility regulations.

Current Models for CO2 Pipeline Ownership

Current CO2 pipelines are primarily owned privately, and pipeline
contracts/capacities are negotiated by the pipeline owner(s)/
operator(s). These are both owned by one owner/operator and by
a group of owners/operators (common ownership). For common
ownership, every owning party has pooled its ownership into one
entity. Tariffs are commonly calculated by dividing the annual cost
of capital plus operating costs by the annual throughput volumes.
All parties receive or pay a common tariff. One example of this
model is the Bravo Dome pipeline, moving CO2 from northeastern
New Mexico to the Slaughter field in Hockley County, Texas.
The second type of pipeline ownership, divided ownership, is one
wherein several parties own a piece of the pipeline but retain their
interest as separate and distinct. They negotiate individual contracts

STB regulations ensure that pipelines fulfill common carrier

obligations by charging reasonable rates; providing rates and services
to all upon request; not unfairly discriminating among shippers;

independently, and separate tariffs are calculated for each individual owner. Because the existing pipelines are privately owned,
there is effectively no open access.

CCS GUIDELINES

Unlike FERC, STB does not require pipeline companies that are
subject to its regulation to file tariffs and justify their rates. STB
may begin a jurisdictional pipeline rate investigation only in
response to a complaint filed against the pipeline operator by a
third party. Thus, STB acts as a forum for resolution of disputes
related to pipelines within its jurisdiction. Parties who wish to
challenge a rate or another aspect of a pipelines common carrier
service may petition the STB for a hearing; there is no ongoing
regulatory oversight. In contrast, natural gas pipeline operators
must generally obtain approval from FERC prior to placing a new
pipeline in service, and FERC is in charge of establishing just and
reasonable rates in consultation with both consumers and the
industry, and may review rates for natural gas pipelines on its own
initiative (Parfomak and Folger 2008).

Natural gas pipelines operate on the basis of a particular form of

mandatory contract carriage,19 where shippers generally have the
opportunity to contract for a reservation of available capacity in the
pipeline on a nondiscriminatory basis for a specified period of time.
Parties who hold firm, contracted capacity are normally not subject
to proration at the behest of other shippers, thus guaranteeing that
their shipments will flow. As additional capacity is needed to serve
new shippers, open seasons20 are typically held to determine the
interest and economic feasibility of adding new capacity. The open
seasons in natural gas pipelines are often used to ensure capacity
is awarded without undue discrimination to all parties who meet
the open season requirements.

TRANSPORT

While FERC currently regulates access to and rates for interstate

(and certain intrastate) pipelines transporting natural gas (under the
Natural Gas Act and subsequent statutes) and oil pipelines (under
the ICA),17 the STB18 has regulatory oversight over the access and
rates for pipelines transporting a commodity other than water, gas,
or oil (including CO2) (USCb). For the purpose of EOR, CO2 is considered as a commodity. However, it is important to note that for the
purpose of geologic storage, CO2 may be considered a pollutant.
Conflicting classification of CO2 has important implications for CO2
pipeline development. The IOGCC proposed that CO2 be considered
a commodity because the captured CO2 will be sold as a valuable
commodity for EOR and enhanced coalbed methane applications
(Parfomak and Folger 2008).

establishing reasonable classifications, rules, and practices; and

interchanging traffic with other pipelines or transport modes. Under
the STBs current approach (common carrier regulation), shippers may
not contract for specific quantities of capacity and, therefore, do not
pay related monthly demand/reservation charges. Payment is only
for capacity utilization based on actual throughput volumes. The
advantage for common carrier shippers is that they pay as they go
on actual delivered volumes. The disadvantage is that the shipper
may not contract for a specific level of assured capacity.

51

TRANSPORT GUIDELINE 4: RECOMMENDED GUIDELINES FOR PIPELINE ACCESS AND TARIFF REGULATION
a. The federal government should consult with industry and states to evaluate a model for
setting rates and access for interstate CO2 pipelines. Such action would facilitate the
growth of an interstate CO2 pipeline network.

TRANSPORT ENDNOTES
1

The 3900 miles represents the regulated pipelines as per the U.S. Department of
Transportation records.

greater than 457 mm (18 in) or when they pass through High-Consequence Areas.
10

Louisiana, Maryland, Minnesota, Mississippi, New York, Oklahoma, New

In contrast to CO2 pipelines, there are more than 980,000 miles of natural gas

Mexico, Texas, Virginia, Washington, and West Virginia.

distribution pipeline in place as per Department of Transportation 2003 statistics.

3

In addition to providing a cost-effective alternative to sulfur recovery, the deep injection

11

of acid gas reduces emissions of noxious substances into the atmosphere and alleviates

minimum-yield strength of the pipeline (CFRf).

12

unincorporated city, town, village, or any other designated residential or commercial

the context of current efforts to reduce anthropogenic emissions of CO2, these acid-gas

area, such as a subdivision, a business or shopping center, or community development.

TRANSPORT

In the supercritical state, CO2 has the characteristics of both a liquid and a gas,

The rural areas are considered to be the nonenvironmentally sensitive areas (CFRf).
13

to construct, operate, and maintain a pipeline across the land. An easement does

such as density. Low viscosity is important for pipeline transport. In the

not grant an unlimited entitlement to use the right of way. The rights of the

is 100 times lower than in the liquid phase. Important from a cost standpoint,

easement owner are set out in the easement agreement.

14

Under current law there is no federal eminent domain power granted for the

given pipe cross-section than transport as a lower-pressure gas.

construction of CO2 pipelines. A number of states, however, do allow the use of

eminent domain for CO2 pipeline construction under certain conditions.

ASME/ANSI (American Society of Mechanical Engineers/American National

Standards Institute) pipe flanges that are made to standards called out by

15

For interstate natural gas pipelines, FERC has jurisdiction over tariffs and rights of way.

ASME/ANSI B16.5 or ASME/ANSI B16.47 are typically made from forged

16

AlthoughCO2 pipelinesarenotexplicitlyexcludedfromFERCjurisdictionbystatute,FERC

such as 150#, 300#, 600#, and 900#, and 1500 #. These Pressure Classes have

ruledin1979thatpipelinescarryingCO2 arenotsubjecttoFERCregulation(Cortez1979).
17

FERC does regulate transportation rates and capacity allocation for oil pipelines. It is

The two-phase flow pattern, usually called slug flow, is encountered when

important to note that historically oil pipelines were regulated under the Interstate

gas and liquid flow simultaneously in a pipe, over certain ranges of flow rates.

Commerce Act (ICA). The ICA, as amended by the Hepburn Act of 1905, provided that

It is characterized by long "Taylor" bubbles, also called gas slugs, rising and

the ICC was to have jurisdiction over rates and certain other activities of interstate oil

nearly filling a pipe cross-section. In a slugging column, with flowing gas and

pipelines, as these pipelines were considered to be common carriers. This jurisdiction

Live and dead loads refer to the forces exerted on the pipeline. The live loads are

was transferred to FERC in the Department of Energy Organization Act of 1977.

CCS GUIDELINES
52

18

STB is decisionally independent of and administratively affiliated with DOT.

forces that are temporary, of short duration, or movingfor example snow, wind,

Pursuant to the ICA the primary mission of STB involves resolving railroad

earthquake, traffic movements. The dead loads are weights of material,

disputes. It is the successor agency to the ICC. Pipelines, like railroads, are

equipment, or components that are relatively constant throughout the structures

common carriers used by more than one company for the transportation of

lifefor example, load due to settlement.

goods. Therefore, the ICA also assigned the ICC (and thus the STB) oversight
authority over pipelines transporting a commodity other than water, gas or oil.

OPS safety jurisdiction over pipelines covers more than 3,000 gathering,
transmission, and distribution operators, as well as some 52,000 master meters

FERC is not involved in the oil pipeline siting process. However, as with natural gas,

both pressure and temperature ratings for specific materials (Nayyar 2000).

liquid, the flow field is extremely complex.

7

Eminent domain is the power of government to take private land for public use.

supercritical transport allows for substantially higher throughput through a

materials and have machined surfaces. They are typically in "Pressure Classes,"

An easement is a limited perpetual interest in land that allows the pipeline owner

maintaining the compressibility of a gas and some of the properties of a liquid,

supercritical phase, the viscosity of CO2 is the same as in the gas phase, which

49 CFR 195.2 defines rural area as an area outside the limits of any incorporated or

are being injected at the same time because it is costly to separate the two gases. In
injection operations represent an analogue to geological storage of CO2.
4

49 CFR 195.2 defines low-stress pipeline as a hazardous liquid pipeline that is

operated in its entirety at a stress level of 20 percent or less of the specified

the public concern resulting from sour gas production and flaring. Although the purpose
of the acid-gas injection operations is to dispose of H2S, significant quantities of CO2

States certified to regulate intrastate pipelines are: Alabama, Arizona, California,

19

Pipeline owners and financial lenders desire these long-term contracts for firm

and liquefied natural gas operators who own and/or operate approximately 1.6

capacity to ensure repayment of the capital cost of building the pipeline. Without

million miles of gas pipelines, in addition to over 200 operators and an estimated

these commitments, gas pipeline projects, which by their nature involve a longer

155,000 miles of hazardous liquid pipelines.

payout than oil projects, could not be financed. Shippers need the contract
quantity commitment to ensure capacity is available to support their needs.

Although CO2 pipelines are classified as hazardous, CO2 is not defined as a

hazardous substance. It is a Class L, highly volatile, nonflammable/nontoxic

20

Open seasons are commercial opportunities for potential customers to compete for

material (CFRg, CFRe, Appendix B, Table 4). CO2 pipelines are treated as hazardous

and acquire capacity on a proposed or existing pipeline. Open seasons inform project

and are reviewed as high-risk hazardous pipelines when they have a diameter

sponsors of shippers needs so they may adjust the project design accordingly.

STORAGE

P A R T

4.1 INTRODUCTION
4.1.1 Terminology
CO2. These include injection under underground injection control (UIC) well classes (Classes I, II, and
V in particular) and injection for natural gas storage. In drawing on experts from these areas for help
in developing the storage Guidelines, it has become clear that certain terms are used very differently
within these injection programs and sometimes even between different state programs implementing

CCS GUIDELINES

Existing injection programs provide experience for geologic storage, also known as sequestration, of

53

the same injection program. The Glossary at the end of the Guidelines
includes terms as they are used in this document and should be
consulted by the reader. In addition, a few terms that are particularly
important for geologic storage are included here.
Storage is the primary term used to refer to geologic sequestration
throughout this document. There is some debate about whether
the term sequestration, storage, or disposal is the most useful in
describing the injection and long-term isolation of CO2. There are
numerous considerations surrounding each term.

CCS GUIDELINES

STORAGE

Project footprint is used as a convenient way to refer to the land

surface area overlying the geologic space occupied by injected CO2
(CO2 plume) and the related geologic space in which there is
significantly elevated pressure in the formation fluid caused by the
injection of CO2. For purposes of this document, significantly
elevated pressure is defined as the area where the pressure
differential is sufficient to cause adverse impacts to overlying
receptors, such as the movement of injected or displaced fluids
above the confining zone into an underground source of drinking
water (USDW). The terms CO2 plume or injected CO2 and area of
elevated pressure will be used when specifically referring to the
components of the project footprint.

54

Closure is used to signify the period during which injection at a

project ceases, and it is demonstrated that the project does not
endanger public health and the environment. Wells within a project
are plugged and abandoned after they stop receiving CO2 or cease
to be used for monitoring (commonly referred to in other programs
as closed or plugged wells). Plugging and abandoning individual
wells can happen throughout a project as well, and is one part of
the site closure process.

4.1.2 Organization of
the Storage Guidelines
The storage Guidelines are organized in three parts. This first section
is meant to give the reader an understanding of the performance
expectations for appropriately sited, operated, and closed projects.
It includes an overview of the key components and issues faced
by storage projects, including the challenges associated with the
expected variation among projects. This section provides an introduction to the array of issues that must be considered in determining
what constitutes a safe and effective storage site, developing
appropriate operation and closure plans, and addressing contingencies. It also serves as an introduction to the different stages
of a project and those cross-cutting issues that are considered
throughout the life of a project.

One finding that has emerged through the process of developing

these Guidelines with stakeholders is that storage projects will
unfold through a series of iterations and feedback loops: initial site
characterization, well drilling and construction will be used to start
a project; feedback from the initial injection and monitoring will be
used to cancel, modify, or expand operations; as individual wells
and injection zones reach capacity, they will be plugged and
abandoned; as a project reaches capacity and the operator
demonstrates non-endangerment, the site will be closed.
The second section of the storage Guidelines builds on the first
section by describing these feedback loops and their integration
within an individual storage project. This section also introduces
the concept of regional issues that become important when several
projects use the same geologic resource, underscoring the importance for coordination among storage projects in regions where
multiple projects are utilizing the same reservoir(s).
The final section examines specific issues and explicitly states the
recommended Guidelines for each aspect of storage. In developing
this section, it was clear that certain issues, such as measurement,
monitoring, and verification (MMV), cut across all phases of a
storage project. Therefore, this section presents cross-cutting
issues first, and then describes issues related to specific phases of
a storage project. This section includes an explanation of the
technical rationale supporting the Guidelines. In most cases, the
recommendations are aimed at a performance-based approach,
focusing on the key pieces of information needed, rather than
prescribing how an operator should obtain that information. This
reflects both the evolving state of knowledge and technologies for
storage, and the heterogeneity in geologic resources.

4.1.3 Carbon Storage

Performance Expectations
In 2005, the IPCC released the IPCC Special Report: Carbon Dioxide
Capture and Storage, representing the current scientific consensus
on the important role and efficacy of CCS as a strategy to mitigate
climate change (IPCC 2005). This report put forth a set of findings
that included two qualified statements about geologic storage
(emphasis added):
22. With appropriate site selection based on available subsurface
information, a monitoring programme to detect problems, a
regulatory system and the appropriate use of remediation methods
to stop or control CO2 releases if they arise, the local health,
safety and environmental risks of geological storage would be
comparable to the risks of current activities such as natural gas
storage, EOR, and deep underground disposal of acid gas.

25. Observations from engineered and natural analogues as well

as models suggest that the fraction retained in appropriately
selected and managed geological reservoirs is very likely to
exceed 99% over 100 years and is likely to exceed 99% over
1,000 years.

Figure 8: Conceptual Risk Profile of a Storage Project

Injection
begins

Injection
stops

2 x injection
period

3 x injection
period

n x injection
period

MONITOR
SOURCE: BENSON 2007

4.1.4 Implications of Potential

Deployment Pathways
The challenge with geologic storage, one that is captured in the
IPCC statements in Section 4.1.3, is that no two sites are alike, even
within the same geologic formation. As a result, there is significant
need for the use of performance standards and flexibility, rather
than rigid numeric standards and technical requirements for the
siting, design, operation, and closure of storage projects. This
challenge is underscored by the diversity in likely deployment
pathways for storage projects. There is a strong temptation in
developing these Guidelines to assume a typical or standard
project. The reality is more likely that CCS will emerge from a
number of differently sized projects that involve a combination of
different CO2 sources, compositions, infrastructure configurations,
and geologic reservoir types.

CCS GUIDELINES

The challenge with geologic storage

is that no two sites are alike,
even within the same geologic formation.

STORAGE

Based on the IPCC report and discussions among experts, these

storage Guidelines assume that:
1. Scientific investigation and technical knowledge can provide the
basis for safe and effective injection of CO2 into specific geologic
formations for long-term storage, keeping it isolated from drinking
water supplies and preventing release to the atmosphere.
2. Existing monitoring techniques are capable of measuring the
amount of CO2 injected, and delineating the project footprint after
injection. These monitoring techniques can be applied using a
risk-based strategy to ensure that sensitive populations and
environments are safeguarded. New monitoring techniques can
improve the effectiveness and/or reduce the cost of detection
and tracking.
3. Injected CO2 is more permanently trapped in the subsurface over
time, as storage mechanisms reduce CO2 mobility and, ultimately,
virtually eliminate the potential threat to drinking water supplies
and the atmospheric climate. Figure 8 depicts this concept. In
this conceptual example, the relative risks associated with a
project are shown starting at zero before injection begins,
increasing during injection operations, flattening out as injections
cease, and finally declining over time as the pressure of the
injection CO2 stabilizes or reaches background levels and other
trapping measures take place. This diagram will be referred to
again in the Guidelines to illustrate risk concepts.
4. Contingent mitigation/remediation planning can be applied in
advance of project initiation and updated throughout operations to
ensure that any unexpected and undesired movement of injected
CO2 will be detected early, and if detected, addressed as needed.
5. In the United States, there is the technical potential1 to sequester
hundreds of billions of tons of CO2 in saline formations and oil and
gas fields that are located reasonably near large sources of
anthropogenic CO2. Globally, there is a conservatively estimated
technical potential of at least 2,000 GtCO2 [Gigatons of carbon
dioxide] of storage capacity in geological formations, including
saline, oil and gas formations, coal seams (potentially), and other
formations. The final volumes of proven storage reserves may

be significantly smaller than the technical potential, but are still

likely to be very large.
6. The emerging CCS industry benefits from the significant
knowledge and best practices developed during over 35 years of
CO2 EOR. Because geologic storage will include new requirements, it is important to acknowledge that a significant amount
of new technological learning and advancement is expected over
time. With experience, the best practices for storage will evolve.

55

This variability underscores the need for flexibility in adapting

current regulatory frameworks to the field of CCS, and iterating and
updating practices as new operations and diverse projects proceed.
It is expected that initial projects will evolve from the well-known
subsurface conditions of oil and gas provinces, so as to minimize
early project risks. As the base of experience and practice grows,
regulations should evolve.

4.1.4.1 CO2 Sources

Today there is a variable supply of CO2 whose volume and characteristics will be heavily influenced by policy and market signals. These,
in turn, will be influenced by the results of and confidence in early
storage efforts. This means that the first CCS projects are likely to rely
more on readily captured CO2 (industrial sources) slip-stream capture
at full-scale plants and/or pilot-scale plants with full-scale capture.
As large power plants ramp up capture (90 percent of the volume of
total projected emissions or better), storage projects will need to
accommodate larger volumes of CO2.

STORAGE

4.1.4.2 CO2 Transport

Depending on the economics of capture and processing of the CO2,
early projects are likely to rely on a mix of transportation options,
including use (or expansion) of the existing pipeline infrastructure
and the development of dedicated pipelines. These individual
pipelines would be sized and located for individual projects and
designed to accommodate the project-specific CO2 composition. As
a result, a standard composition for CO2 delivered for storage is
unlikely. Much like CO2 standards in EOR today, these factors will
vary based on project details, and individual storage project designs
will be taken into account.

CCS GUIDELINES

4.1.4.3 Reservoir Types and Project Sizes

56

The largest potential capacity for CCS is in saline formations, and

it is this significant capacity that drives interest in CCS as a climate
change solution (IPCC 2005; Dooley et al. 2006; U.S. DOE/NETL
2007a). However, in the near term, mature oil and natural gas fields
are likely to be the financially attractive sites for storage because of
the comparative wealth of information regarding site-specific
subsurface geology, existing infrastructure, and economic incentive
in the form of recovered oil or natural gas, which will help defray
the costs of capture, transportation, injection, and monitoring.
With higher oil prices, increased availability of CO2, and incentives
for storage, the EOR industry could provide a mechanism for
sequestering significantly more CO2 than it does currently. Mature or
abandoned natural gas fields may also provide large advantages for
early storage projects. Reservoirs, such as coal seams or basalt

formations, are also potential alternatives in some areas, and there

will continue to be interest in conducting pilot- or larger-scale storage
pilot projects in these kinds of formations. However, these formations
have very different physical structures, geochemistry, trapping
mechanisms, industrial bases, and regulatory frameworks compared
to the other storage options. These Guidelines are geared toward
near-future CCS deployment and focus on saline formations and oil
and natural gas fields. They do not address other formation types,
such as coal seams and basalt in detail.
Another consideration is project size and scale. In many discussions
about storage, the implied deployment model seems to involve one
large CO2 source linked to one large storage project site. The reality
may be quite different, as early projects will most likely vary in size
for a number of reasons related to the nature of the project, the
source of CO2, cost, and other factors. Further, as new CCS projects
are proposed, there may be a move toward the use of pipeline
networks through which the CO2 from several sources may be
combined and then distributed to several different storage projects.
Ultimately, the characteristics of any specific site need to be
considered in absolute terms: Is the site suitable for storage, given
the specific geology and the reservoir context?
Although there are many possible future deployment scenarios, the
Guidelines focus on storage at an individual project scale with
injection into single large reservoirs, noting how size/scale might
affect certain assessments.

4.1.5 Identification of Storage Issues

Addressed in the Guidelines
A challenge in presenting Guidelines for storage is in organizing
feedback processes into the linear format of a paper. This section
of the Guideline presents a brief overview of issues related to
storage that need to be considered in the Guidelines. In the subsequent sections, these issues will be explored in detail.

4.1.5.1 Specific Stages of a Storage Project

SITE CHARACTERIZATION AND SELECTION
Site characterization and selection is perhaps the most important
step in ensuring the safety and integrity of a storage project. During
this phase, much of the site-specific data are collected and permits
applications are developed. (Note: permits may be required for
certain site-characterization activities, such as seismic reflection
surveys.) Even though a site may be economically attractive, data
collected during site characterization should be used to assess the
technical feasibility of a site. The primary question is how to determine if a site is suitable for storage. The storage Guidelines describe

the characteristics a target reservoir should (and in some cases

should not) have, and what information is needed to prove that the
project will be able to proceed effectively and economically to
sequester the proposed volume of CO2. Some of the data collected
during this phase may be proprietary, or contain information controlled
by a owner under copyright, patent, or trade secret laws. Where data
availability is mentioned, non-proprietary data should be released.

Estimating Storage Capacity

A number of geologic reservoirs appear to have the combined
technical potential to sequester billions of tons of CO2. The potential to store and retain captured CO2 can be considered a type
of resource. Like all geological resources (e.g., oil, gold), storage capacity can be estimated through conventional analyses and
approaches that involve a number of defined assumptions.

PROJECT OPERATIONS
Project operations is often narrowly defined as the period of active
CO2 injection. However, in these Guidelines, site preparation and well
construction are included as part of operational activities. The
operational Guidelines underscore the need for integrated planning
and project-specific considerations in well and facility design. An
emphasis is also placed on collecting and analyzing operational data,
maintaining sufficient flexibility in the operational plans to adapt as
new information becomes available, and planning for contingencies.

Many estimates developed to date are regional or basin-scale resource estimates. This type of analysis applies regional estimates
for porosity, formation thickness, fluid saturation, and density of
stored CO2 over large areas to develop an estimate of potential capacity. A site geologic analysis involves the acquisition of more
detailed data at a specific reservoir level and will illustrate
changes within a potential reservoir across a basin. This work,
though more detailed than the regional analysis, still will not replace the level of work required for specific-site characterization,
or to develop an estimate of proved reserves.

POST-CLOSURE
Post-closure is the period of time after certification of site closure.
At this stage, the storage project should not endanger human health
and the environment. The Guidelines propose a set of expectations
for a site in the post-closure period, as well as potential mechanisms
for managing post-closure MMV activities, to the extent needed.

A number of cross-cutting issues apply to all stages of a storage effort.

MMV TOOLS
MMV tools enable operators to measure aspects of site surface and
subsurface conditions, and to use these measurements to analyze,

simulate, and forecast CO2 behavior. Because MMV activities

represent a critical component of safe geologic storage, they should
occur throughout the life cycle of a storage project. These activities
allow an operator to develop a comprehensive understanding of the
subsurface geology and the surface and near-surface environmental
conditions at the site. By conducting a site characterization and
implementing the MMV plan, an operator will be able to effectively
manage risk of unexpected leakage. Further, implementation of a
robust MMV plan during the early stages of a CCS project and
through operations will increase the certainty around demonstration
of non-endangerment, thus facilitating certification of site closure.

RISK ASSESSMENT
Risk assessment is an important component of a CCS project that
is conducted and updated throughout a project, rather than as a
one-time action. Risk assessment should be integrated with the
MMV program and should include approaches to mitigate the risk
of negative impacts upon the surface, a USDW, or outside the
project footprint. One key component of a risk assessment is
identifying potential leakage pathways (e.g., faults, wells,
fractures). This identification is then integrated with the MMV plan.
Should injected CO2 migrate toward an identified pathway, a
mitigation contingency or remediation measure is implemented. A
comprehensive risk assessment is needed early in the project, but
risks should be continually assessed and integrated with the MMV
plan. One method for ensuring this needed integration is to link the
models used for risk assessment and the subsurface models that
are developed and informed by MMV.

CCS GUIDELINES

4.1.5.2 Cross-Cutting Issues

SOURCES: IPCC 2005; DOOLEY ET AL. 2006; U.S. DOE/NETL 2007A

STORAGE

SITE CLOSURE
Site closure occurs when injection ceases, the final wells are plugged
and abandoned, and the site is certified for closure. Although
individual wells may be temporarily or permanently plugged and
abandoned or converted to a monitoring well during operations,
Guidelines related to these activities are included under site closure.
Plugging and abandonment of wells is the primary task in site closure,
and storage projects will benefit from existing knowledge and
standard approaches. The Guidelines specify that operators conduct
a final assessment of all wells, and that data regarding each site are
reported in a publicly accessible registry. During site closure,
operators will undertake post-injection monitoring to demonstrate
that the storage project does not endanger human health and
the environment. Certification of site closure is contingent on
this demonstration.

57

Current Regulatory Framework for Underground Injection

These Guidelines are being released in the context of an evolving regulatory framework. Several states and the U.S.
Environmental Protection Agency (EPA) have initiated rulemaking for CO2 geologic sequestration. A draft EPA rule was released
in July 2008, and a final rule is planned for 2011. EPA has the authority to regulate CO2 geologic sequestration wells under the Safe
Drinking Water Act through the Underground Injection Control
(UIC) Program.
The United States historically has safely injected CO2 and other
materials in the subsurface. Some of the stated storage Guidelines
are covered under existing UIC rules for Class I or Class II wells.
However, because long-term storage of large volumes of CO2 presents unique issues (relative buoyancy of CO2, corrosivity in the
presence of water, mobility in the subsurface), the draft rule
would create a new Class VI for CO2 geologic storage wells and
call for some significantly different provisions regarding well
construction; measurement, monitoring, and verification; and
closure. Several key issues may not be resolved in the state rules
or the first release of the new draft UIC rule, and could significantly affect the ease of permitting storage projects.
The Guidelines include and explain important recommendations,

CCS GUIDELINES

STORAGE

even where there is an existing or proposed requirement under

58

FINANCIAL RESPONSIBILITY
Financial responsibility must span the entire life of a project (from
capture through post-closure stewardship) and must include
adequate assurance that there is sufficient funding to cover the
net present value of estimated closure (including well plugging
and abandonment, MMV, and foreseeable mitigation) and
post-closure (including foreseeable MMV and corrective action).
Because of the uncertainty surrounding early storage projects and
the potential difficulty of attracting investment, policymakers
should carefully evaluate options for the design and application
of a risk management framework for such projects. This risk
management framework should appropriately balance relevant
policy considerations, including the need for financial assurances,
without imposing excessive barriers to the design and deployment
of CCS technology. This is the least-defined cross-cutting area,
and will be a topic of future discussion and analysis. It should also
be noted that the Guidelines do not specify the degree or nature
of financial responsibility following site closure.
PROPERTY RIGHTS
Landowners of land above or near storage projects may be directly
affected by pore space ownership and property rights issues.
Ensuring that the operator has obtained the right to access a
private landowners land for monitoring purposes and/or to use

the emerging regulatory frameworks. A few important considerations include:



Who owns the storage rights, and how they will be aggregated?

What happens when the predicted CO2 plume crosses state

boundaries and differing regulatory jurisdictions?

Permitting an individual well versus permitting a carbon

dioxide capture and storage field or reservoir (i.e., area permit).

Determination of the area of review requirements.

Differences in state-level authority, legislation, or regulatory

interpretation.

Differences in publicly available data.

the subsurface pore space under that land is critical. A full-scale

storage project could affect many landowners. Projects in
regions where there is little experience with subsurface industry
operations (e.g., oil and gas and natural gas storage) may face
greater challenges in establishing agreements with landowners.
Communication and clarification of property rights should
be established early in the planning phases, and data on the
site should be maintained in public databases through the
post-closure phases. These concerns should be addressed by
policymakers through legislative clarity concerning key property
rights issues.

Draft Australian CCS Regulation

On May 16, 2008, the Government of Australia released draft carbon

Protection of Existing Petroleum Interests

dioxide capture and storage (CCS) legislation, which was referred

The draft legislation contains a number of safeguards to protect

to the House of Representatives Standing Committee on Primary

existing petroleum interests (and, more generally, producing in-

Industries and Resources for review. The Committee reported on Au-

terests). In particular, the legislation contemplates that the Minister

gust 15. The report provides an endorsement of the proposed

will not be able to approve a GHG storage operation (including an

regulatory framework and makes a number of recommendations for

exploratory operation) if the Minister concludes that the proposed

changes to the draft, which are largely aimed at refining regulatory

operation may cause a significant risk of significant adverse

processes. The draft legislation takes the form of a comprehensive set

impact on those petroleum interests in the absence of an agree-

of amendments to the Commonwealths Offshore Petroleum Act

ment between the parties.

2006 and is designed to provide an enabling framework for objectiveClassification of Storage Formations
based regulation for CCS in offshore waters.
In addition to the three forms of tenure are classifications of storThe proposed legislation accomplishes two main objectives: (1) it pro-

age formations. Each classification is associated with increased

vides a disposition or tenure scheme for parties to acquire the right

knowledge of the geological formation that is proposed for injection

to store GHGs in the offshore; and (2) it provides a regulatory frame-

and storage: potential, eligible, or identified. While a tenure holder

work for reviewing and approving CCS operations on a case-by-case

may inject GHGs into potential and eligible formations for appraisal

basis, with individual site plans and closure plans. In delivering on

purposes, approval for injection for permanent storage requires that

both of these objectives, the legislation also provides a framework

there be a declaration of an identified GHG storage formation.

for deciding upon the competing claims of petroleum operations and

Regulations for Site Selection and Approval and Site Closure
CCS operations. The draft legislation identifies site selection and apThe draft legislation identifies site selection and approval of storproval and site closure as areas for regulation and proposes a
age sites and site closure as two major issues that need new
framework. Finally, the legislation proposes to leave both short-term
regulations for CCS. Both issues are dealt with through the use of a
and long-term liability with the operator/licensee, largely on the
site plan that is linked to the specific identified GHG storage forbasis of laws of general application.
mation. The approach is outcome oriented in that the overall goal
The Disposition or Tenure Scheme

is to achieve safe and secure storage in a formation. Site closure

The draft legislation offers a three-tiered GHG tenure scheme mod-

builds on the site plan, requiring a program (and funding) for long-

eled on the current petroleum regime: (1) a GHG assessment permit,

term monitoring and verification by the Commonwealth.

(2) a GHG holding lease, and (3) a GHG injection license. The GHG
Liability
assessment permit is a short-term exploration interest. Permits are
active exploration and injection and the period post-injection until
bid). The GHG holding lease is designed to offer some security to an
site closure. Long-term liability refers to liability post-closure. The
explorer who has obtained a declaration of an identified GHG stordraft legislation proposes that in general the liabilities associated

STORAGE

In the Australian system, short-term liability covers the period of

issued based on a competitive bidding process (work-bid or cash-

age formation, but who has yet to secure a source of GHGs. The GHG
with operating and closing an injection facility should be dealt with
injection license is the only tenure form that permits GHG injection
in the same way as conventional offshore oil and gas operations.
for other than evaluative reasons. It is the functional equivalent of
The effect of this is to apply the default tort rules of the common
a production license in a petroleum disposition scheme. The three
law and impose continuing long-term liability principally on the opforms of tenure need not be held sequentially. In particular, an operator/licensee. As result the proposal will not affect an explicit
erator might proceed directly from the GHG assessment permit to
transfer of liability from the operator/licensee to the government.
the GHG injection license. The tenure scheme is underpinned by a
While there may be a de facto transfer of liability in the event of
series of prohibitions. The legislation prohibits the unauthorized exdefunct operator, such a de facto transfer will not impose a legal
ploration (s. 249AC) or injection and storage of substances (s. 249CC)

S O U R C E S : A U S T R A L I A N G O V E R N M E N T 2 0 0 6 ; B A N K S A N D P O S C H WAT TA 2 0 0 8
Note: The legislation applies to greenhouse gas substances (and not simply CO2). The term is defined as: (1) CO2, or (2) a prescribed gas, or (3) a mixture of the above plus
incidental GHG-related substances and detection agents. Incidental GHG-related substances would include substances incidentally derived from the source material, capture,
transportation, injection, or storage. A detection agent is a substance added to the mixture to facilitate monitoring.

CCS GUIDELINES

duty on government to compensate those who may be harmed.

in an offshore area.

59

Figure 9: Integration Within a Storage Project

Site screening and
early characterization

Site selection
Operators will collect and integrate data
that will affect siting, development, operations,
and closure in an iterative fashion.

Continued characterization
pre-injection

Project permitting
and approval

Baseline monitoring
and characterization

Injection begins

Operational injection and

monitoring

Injection ends

Project decommission

Post-injection monitoring

Site activity ceases

COURTESY OF S. J. FRIEDMANN, LLNL

STORAGE

4.2 INTEGRATION WITHIN

AND AMONG CCS PROJECTS
Essential to the success of a storage project is integration among
storage project phases (e.g., site characterization and selection,
operations, site closure, and post-closure) and among various
projects that use the same regional geologic formation.

4.2.1 Integration Within a CCS Project

CCS GUIDELINES

Figure 9 illustrates important interaction in the planning and

execution of each phase in the CCS project chain. It is not intended
to be exhaustive and does not include public or community
engagement, which should take place throughout the project. Such
engagement should be prioritized, and best practices should be
followed (Herbertson 2008).

60

Site screening and early characterization can best be defined as

exploration for a potentially suitable site. A typical approach would
include first developing an understanding of the regional geology and
then gradually moving toward more detailed site characterization and
data collection that over time result in an increasingly detailed
subsurface model. At a broad level, the operator may apply screening
criteria based on general site characteristics, such as population,
current land use, or presence of critical habitat for threatened and

endangered species. In addition, there are important geologic

screening criteria, including the presence of confining zones,
properties of the storage reservoir, underground storage capacity, and
the extent to which factors that would reduce storage security (e.g.,
significant seismic activity or faults with the potential to impact
protected resources or reach the near surface) are absent. At this
point in the project, the geologic information will be gained from
existing records of past operations or geologic studies in the region.
A number of tools and approaches that can facilitate early site
screening are discussed in greater detail in Section 4.3.2.1.
Once a project passes early site screening, it might be selected for
more detailed characterization. The detailed site characterization
effort is an exploratory process in which the operator gains
site-specific geological information to better understand (with
supporting data) the geologic conditions that were identified during
early site screening. As a site is characterized in detail, the operator
gradually begins to understand the nuances of the site-specific
geology. At this point in the project, there are still questions about
the subsurface that will only be answered through continued
investigation and site preparation. Based on the first round of pilot
projects, the best understanding of CO2 movement will only be
achieved through monitoring of CO2 itself after initial injection
(Doughty et al. 2008). That said, sufficient data will have been

collected to conduct a preliminary risk analysis, design the project,

and develop a preliminary model of the subsurface.

Individual wells may be temporarily or permanently plugged and

abandoned throughout operations, but a site will close only after
injection has ceased. This phase of a project will include plugging
and abandoning the majority of wells and conducting final wellbore
assessments at older wells that were plugged and abandoned
earlier either as part of the storage project or for use in other
purposes. Following site closure, there maybe an additional period
of post-closure monitoring, during which the site is assessed
periodically to demonstrate that the project does not endanger
human health and the environment.

Before drilling and completing any new wells, the operator will
need to obtain land and property access rights and work with the
regulatory agency to obtain the needed permits. Permit applications
for wells require a significant amount of information, including
detailed information regarding the well specifications (depth,
materials, location, etc.); the known information about the
subsurface geology; data gathered during site characterization;
submission of a subsurface model and monitoring plan; and detailed
maps of surface and subsurface features. Permitting requirements
will also include identification of any known faults and historical
seismic activity and, frequently, recent seismic surveys.

4.2.1.1 Timeline for a Theoretical Project

If permits are received and the project scale is approved, a project

will enter the site preparation and construction phase. The injection
and monitoring wells will be drilled and completed according to the
specifications in the permit. Throughout this phase, additional data
on the subsurface will be collected and used to further characterize
the site and validate the subsurface model. Baseline measurements
for monitoring will also be made.
Prior to operational injection, the operator may use the newly drilled
injection and monitoring wells to obtain additional information
about the subsurface. Water floods and CO2 injection tests may be
conducted to provide new detail that will be incorporated into the
subsurface model and further the understanding of the local
geology. Throughout operations, data will be collected and used to
periodically validate and, if necessary, update the model(s). Through
this process, over time, the models will evolve to more closely
represent subsurface conditions and predict the behavior of injected
CO2. Ongoing site characterization, monitoring, and simulation
models will inform operational decisions.

STORAGE

It is difficult to establish a generic timeline for a storage project

because of the vastly different starting points. In some locations, the
regional geology is well understood and characterized, while others
will need substantial research and characterization up front. Figure 10
maps the conceptual project risk profile (first shown in Figure 8) to a
timeline for a project located in a new reservoir. Several experts have
considered a conceptual approach to project responsibility or oversight
(Wright 2008). An emerging view suggests a timeline in which site
characterization and selection take anywhere from 1 to 7 years to
complete and are fully the responsibility of the owner/operator.
Injection operations last anywhere from 10 to 50 years, depending on
the site, and are the responsibility of the owner/operator. Site closure
overlaps with operations slightly, as some wells will be plugged and
abandoned before a site is closed by an owner/operator. During site
closure, injection will cease and the majority of injection wells will be
plugged and abandoned, except for those used in monitoring.
Monitoring will be carried out to demonstrate that the project does not
endanger human health and the environment. Once a project is certified
as closed, it would be managed by the government or an institution
created for that purpose.

Figure 10: Projected Timeline for a CCS Project

Time in Years

1-7

Site Characterization and Selection

Injection
stops

2 x injection
period

3 x injection
period

n x injection
period

10-50

1-5

10 plus

Operations

Closure

Post-Closure

CCS GUIDELINES

Injection
begins

ADAPTED FROM BENSON 2007

61

4.2.2 Integration Among Storage Projects:

Basin Scale Management
Important integration concerns are the potential cumulative impacts
of several large-scale storage projects in a single region, and the
potential for one project to impact anothers storage reservoir
through overlapping areas of elevated pressure (such as depicted in
Figure 11). These concerns are not new to injection industries. Once
oil was discovered in the United States, there was a race to find, lay
claim to and exploit oil fields. Six states used the constitutional
right for states to compact or work together to address regional

problems by forming the IOGCC, which comprises the oil and gas
regulators from member states. Faced with unregulated petroleum
overproduction and the resulting waste, the states endorsed and
Congress ratified a compact to take control of the issues (see
IOGCC). Since then, the IOGCC membership has expanded to
include nearly all of the U.S. states. This model has been used by
states in the mid-Atlantic/Northeast region of the country to
address ground-level ozone. Similar models are found in regulatory
programs that aim to protect watersheds and estuarine systems by
imposing controls throughout multistate regions.

Figure 11: CO2 Injection Plumes and Hydrostatic Pressure Viewed by Plan and Section

STORAGE

CO2 Injection Plumes and Hydrostatic Pressure Front Over Time

(Section view)

CCS GUIDELINES

CO2 Injection Plumes and Hydrostatic Pressure Front Over Time

(Plan view)

62

C O U R T E S Y O F I L L I N O I S S TAT E G E O L O G I C A L S U R V E Y

In the case of storage, it is expected that the primary approach to

project development in the United States will be for private industry
to propose projects that make sense economically and environmentally. Given the current technical understanding of the scope of
large-scale, sustained CO2 injection projects, it is unlikely that there
will be substantial negative effects associated with any single,
well-chosen site in the early stages of a decentralized approach to
deployment (Bradshaw et al. 2005). It is not as clear that this will
remain the case as multiple well-chosen sites begin to be located
near other sites. In the context of the Guidelines development
stakeholders have discussed the potential effects of dozens of large
projects sited within the same region, where the near- and far-field
effects of single projects might begin to interfere with each other
or with regional systems. Concerns include the effect of interacting
areas of elevated pressure (shown in Figure 11 as the hydrostatic
pressure front) and potential impacts on groundwater quality by
displacement of large volumes of fluid formations, changes in
regional geologic uplift or subsidence patterns, or changes in
regional crustal stress orientations and magnitudes. These are
issues that have been occasionally encountered in other large-scale
injection or production deployments (E.J. Wilson et al; 2003; Wilson
and de Figueiredo 2006), and as such, are credible concerns that
can be and will most likely need to be addressed at the regional or
reservoir basin level. Figure 11 illustrates the potential interference
that could be experienced between sites that are located close to
each other.

The oil and gas industry often employs the practices of regulated well
spacing and lease and/or tract unitization to reduce waste, conserve
the resource, and optimize economic recovery, while minimizing field
development costs. Regulators often get involved in well spacing decisions in order to optimize production of oil or gas. Unitization is the
process of managing an oil or gas field that is owned by many parties as if it were managed by one party. These same concepts are
appropriate in thinking about designing storage projects.
Image 1, below, depicts the injected CO2 and the area of increased pressure in the groundwater. If two wells or projects are spaced close
together, the project footprints can interfere with each other (Image 2).
If they are placed too far apart, the space in between, which might
have been suitable for storage, is wasted (Image 3). And finally, an
appropriate location minimizes the amount of wasted space, and operations do not interfere with each other (Image 4). Future work needs
to be done to develop an understanding of optimal spacing for CO2,
capture and storage wells.

CO2

Conceptual representation
of injected CO2 and area of
elevated pressure

Pressure
IMAGE 1

IMAGE 2

IMAGE 3

CCS GUIDELINES

Essential to the success of a storage project

is integration among storage project phases
and among various projects
that use the same regional geologic formation.

IMAGE 4

STORAGE

Basin scale management is a key area for research, and several

studies are now underway, including using natural geologic system
interaction as a model. Because these concerns are about deployment of multiple large injection systems, they do not present an
impediment to near-term development of commercial storage
projects. However, project developers should anticipate future
investigations into the potential effects of multiple project
deployments. The result of this research might be a recommendation
for more centralized regulation of storage projects and well spacing.
Regulators should consider how to most efficiently address this
concern in order to reduce the chance of unintended consequences.
This issue is discussed in more detail in the Site Selection and
Characterization section.

Well Spacing and Unitization

63

4.3 DETAILED DISCUSSION OF STEPS

INVOLVED IN IMPLEMENTING
A STORAGE PROJECT
This section includes the detailed technical Guidelines for storage
practices designed to enable future storage deployments that are
safe, effectively retain injected CO2, are accepted by the public, and
can be implemented cost-effectively.

Use of Predictive Models

Codes are the computer software (e.g., TOUGH, ECLIPSE) used to
develop models, while models incorporate site-specific data into
the mathematical framework of the code. Using a dynamic model,
one can perform simulations in order to predict and understand
potential changes under different scenarios or conditions. Models
can be used to perform sensitivity analysis, allowing modelers to
observe the relative importance of each input variable in influ-

4.3.1 Cross-Cutting Issues

encing the output.

Four issues cross-cut the single stages of a storage project: MMV,

risk assessment, financial responsibility, and property rights. They
are described as cross-cutting issues because they all apply to each
of the single stages that follow. They are described first in an effort
to avoid redundancy and repetition later in this document.

Subsurface flow simulations (also called hydrogeologic or

dynamic models) are used to predict CO2 plume movement and
the rate and degree of CO2 trapping mechanisms (i.e., dissolution),
and to identify where to locate wells to best utilize storage capacity and avoid potential leaks. For CO2 capture and storage
(CCS), flow simulations may incorporate multiphase flow processes

4.3.1.1 Measurement, Monitoring,

and Verification

STORAGE

As discussed earlier, MMV is presented as a cross-cutting issue

because the tools and approaches used in MMV are applied for
various reasons throughout the lifetime of a storage project. Further,
the results from MMV should be used in an iterative process in
conjunction with modeling to inform site selection, construction,
operation, closure, and long-term stewardship or mitigation of
leakage should the need arise. MMV provides the interface between
the project and regulators, insurers, carbon markets, and the public.
A variety of parameters can and should be measured, and numerous
techniques or tools are available today. The temptation is to
prescribe a standard set of tools that is deemed appropriate.
However, the reality is that what may be a meaningful measurement at one site may prove virtually useless at another site (Wright
2008). Likewise, there may be a preferable substitute for a common
test that is either an emerging technology or better suited for a
particular site. Geologic conditions vary among potential sites,
driving the need for flexibility in determining the specific MMV tools
deployed at any one project.

CCS GUIDELINES

The focus of these Guidelines is thus (1) describing the potential

applications of MMV, (2) identifying the important parameters, and
(3) describing existing techniques and approaches used to collect or
develop MMV data. New approaches for MMV are being developed

64

(e.g., immiscible displacement, capillary trapping); geochemical reactive transport (e.g., mineralization, metal mobilization); and
geomechanical processes (e.g., confining zone deformation, fracturing). For CCS, the subsurface flow simulation should encompass
the target reservoir and confining zone, as well as a buffer zone
at the highest resolution practical. Periodic history-matching and
simulation updates should be required.
The foundation of the subsurface flow simulation is a representation of the geologic structure of the system (i.e., earth or
static model) that incorporates available site characterization
data, such as results from well-log interpretations and seismic
surveys. Typically, a three-dimensional grid is created, with up
to millions of grid-blocs, or cells. Geostatistics may be used
to assign reservoir properties (e.g., porosity, permeability, etc.) to
each cell, interpolating where data are not available. As additional data are gathered during the site selection, characterization, and monitoring phases of the project, it is essential that
the model be updated.
System-level models can use elements from subsurface flow models, as well as from models of other stages of the CCS process (e.g.,
pipeline transport) to support risk-based scenario evaluation.
Such system models can be designed to include probabilistic data,
including such factors as potential future economic conditions or
uncertain regulatory requirements.

Given the current technical understanding

it is unlikely that there will be substantial negative effects
associated with any single, well-chosen site
in the early stages of deployment.

Microseismic Monitoring
Microseismic monitoring uses a down-hole receiver array that is
positioned at depth in a hole near the injection well. An image of
the fracture position and orientation can be generated by mapping detected microseisms (micro-earthquakes) that may be
hydraulically triggered by shear slippage along an existing or
newly created fracture. Microseismic mapping can be performed
in the injection well in cases where suitable offset monitoring
wellbores are not available. A benefit of microseismic fracture
mapping is the ability to measure very small seismic events;
however, it is often difficult to detect events that are more than
800 meters away. In general, microseismic tools work best where
permeability is not very high and where the rocks contain abundant natural fractures. Microseismic arrays were tested at
Weyburn and are being considered at In Salah (Wright 2008).

as technology improves or new questions arise. In addition to

considering the best suite of MMV tools for each project, it is also
important to consider how to adopt new techniques, if warranted,
as they are developed.

INJECTED AND DISPLACED FLUIDS

Monitoring the location of the CO2 plume should begin during

injection and continue after injection ceases until there is a
satisfactory demonstration of non-endangerment (as discussed in
section 4.3.2.3). Once injection ceases, the factors driving subsurface CO2 displacement (buoyancy and pressure) dissipate or
become stabilized (Benson 2007). In that context, the frequency of
surveys may substantially decrease relative to the operational
phase. During injection, plume location monitoring can be used to
evaluate the validity of the subsurface flow simulation of the CO2
plume by history-matching, or showing that the predicted behavior
matches actual conditions. The goal of plume monitoring during
closure is similar to that of monitoring during the operational phase.
However, because there is no longer a source of active CO2
injection, the monitoring results collected during this period will be
used to validate simulations of plume movement and identify
unanticipated migration toward potential leakage pathways under
the new conditions. After some finite amount of time, it should
be possible to understand how the reservoir heterogeneity,
gravitational forces, and decline in pressure affect continued
migration and validate that understanding. The duration and
frequency of monitoring may increase or decrease based on
site-specific information and site performance.

Pressure monitoring is an important tool in managing in-situ stress,

with the primary goal of ensuring that fractures that may compromise
the confining unit(s) are not created, and existing sealing faults are
not reopened. Experience in working with subsurface environments
indicates that some fracturing of the injection reservoir itself may

CCS GUIDELINES

RESERVOIR PRESSURE AND IN-SITU STRESS MONITORING

STORAGE

In general, MMV has multiple applications throughout a project

life cycle:
 Measurement of rock properties (such as porosity and permeability) and subsurface characteristics are key factors in selecting
suitable locations for CCS projects.
 MMV data on subsurface characteristics form the basis for a
reservoir model and subsurface flow simulation that is used to
predict the migration of injected CO2. The model or simulation
informs regulatory review, acquisition of property rights, and
project design.
 Measurements of the flow rate, injected volume, and composition
of CO2 are used to improve the performance of a project through
modifications in the operations plan and to demonstrate compliance with permit requirements.
 Monitoring wells are established to collect data, including
reservoir pressure (sometimes in the porous zone immediately
above the primary confining zone) and formation fluid chemistry.
 Periodic characterization of the project footprint is used to
validate and update the reservoir model and flow simulation, and
to ensure public and environmental safety.
 Ongoing MMV data are used to assess the subsurface flow
simulations and to determine if any mitigation steps are necessary.
 Mechanical integrity tests are taken to monitor and demonstrate
the integrity of the injection and monitoring well(s).

KEY MONITORING PARAMETERS

This section outlines some of the important parameters for MMV:
 Monitoring for injected or displaced fluids is used to update and
validate the subsurface models.
 Reservoir pressure (injection zone) and in-situ stress monitoring
aids in detection of a breach in the confining zone(s).
 Monitoring zone (immediately above the confining zone(s))
pressure and temperature allows for early detection of CO2
movement outside the confining zone(s).
 Well integrity monitoring allows for increased confidence that
fluid movement is not occurring via the wellbore outside the
injection tubing.
 Monitoring CO2 concentrations and fluxes and fluid composition
enables detection of CO2 in the groundwater or at the surface.
Table 7 summarizes the key parameters that should be monitored
and indicates some of the techniques that are commonly used to
assess those parameters. Note that selection of techniques will be
site-specific as well as fit-for-purpose.

65

Table 7: Key Geologic and Environmental Parameters to Monitor

Parameter

Project footprint at depth

Reservoir pressure and temperature

In-situ stress

Well performance and integrity

Surface and near-surface

CO2 concentrations and fluxes

STORAGE

NOTE:

Techniques
 Time-lapse

seismic
 Crosswell seismic
 Reservoir saturation tools
 Vertical seismic profiling
 Electrical surveys
 Microseismic
 Microgravity
 Monitoring wells
 InSAR/tilt/GPS
 Downhole pressure sensors
 Bragg fiberoptic grating
 Thermocouples
 Microseismic
 Triaxial tensiometers
 Other downhole stress tools
 Cement and casing imaging logs
 Vertical seismic profiling
 Well-head detection devices
 Mechanical integrity testing
 Groundwater sampling surveys
 CO2 monitors
 Artificial and natural isotopes
 Soil-gas surveys
 Atmospheric eddy correlation
 LIDAR
 Sidescan sonar

CCS GUIDELINES

CO2 and pressure geometry and location

Evaluating integrity of confining unit(s) and wells

Evaluating integrity of confining unit(s) and wells

Evaluating integrity of wells, monitoring CO2

Unanticipated leakage; early detection;

mitigation planning

the measurement, monitoring, and verification (MMV) methods discussed in this table are some of the common approaches used, but this is not intended
as a prescriptive or exhaustive list of potential MMV methods that may be useful in a project. For additional information see IEA GHG R&D 2008c.

GPS = global positioning system; LIDAR = light detection and ranging

help increase storage capacity. Pressure should be monitored with

care and with emphasis on not compromising the confining zone(s).
Pressure measurements can be taken in existing wellbores
(i.e., down-hole) with existing tools.

66

Information Gathered

After injection stops, the geomechanical risks will decrease as

reservoir pressure dissipates or stabilizes over time. The rate of
dissipation is a function of reservoir heterogeneity and permeability,
and the size of the pressure gradient. For many reservoirs, Darcys
Law2 provides a reasonable first-order characterization of how
pressure will dissipate, and many simulators can provide accurate
and reasonably precise predictions regarding pressure change
through time. Given the anticipated pressure dissipation after
closure, however, there is not a technical basis for requiring
measurement of pressure for long durations after injection.

MONITORING IN THE DEEP SUBSURFACE

ABOVE THE INJECTION ZONE

If CO2 migrates from the storage formation into an overlying porous

formation, it will most likely affect the overlying formations pore
pressure, temperature, and fluid chemistry. This means that
measurements for changes in pressure, temperature, and fluid
chemistry in deep monitoring zones may be an effective means of
early detection of leakage. Because these are direct measurements, they require wellbore access (via monitoring and/or injection
wells) to at least the depth of the monitoring zone. It is possible
that seismic methods may be able to detect pressure changes in
the monitoring zone and may provide an alternative to direct
measurements of the deep subsurface.

WELL INTEGRITY MONITORING

Maintenance of well integrity is essential, because a well failure

could create a conduit for flow between all formations penetrated by the well and the surface. Wells are constructed from
materialscement (most often Portland-based) and steelthat
may be degraded when exposed to carbonic acid and formation
fluid (carbonic acid is formed when CO2 comes in contact with the
formation fluids in the reservoir).
Wells with casing that are fully centralized and have a competent
cement job will most likely be exposed to carbonic acid under
diffusion-controlled conditions, where reaction rates will be slow.
Studies (Carey et al. 2006) have indicated that well cements hold
their integrity, with some reaction with CO2, over decades, but more
research is needed before the implications for leakage by
degradation from carbonic acid are fully understood.
The objective of well integrity monitoring is to prevent leakage and
contamination of drinking water supplies (during and after
operations), and to demonstrate that the risk of well leakage is
sufficiently low during operation and for safe closure certification.
Well integrity should be measured through the use of cement and
casing mapping tools, as well as mechanical integrity tests.
Integrity testing is an important requirement and common practice
in existing regulations governing underground injection wells as
well as oil and gas production wells.

SURFACE OR NEAR-SURFACE
CO 2 CONCENTRATIONS AND FLUXES

Although surface monitoring should not be used as a primary

leak-detection measure, it may be useful in detecting very slow or

alkaline earth metals can be measured and used to detect potential CO2, migration. Groundwater monitoring is advised as a tool
to consider throughout a CCS project. Assessment of the baseline
water chemistry and mineral content is key to enabling future detection changes in groundwater quality. Much of the analysis can
be completed using conventional laboratory techniques, complemented with simple one-dimensional geochemical modeling.
SOURCE: CARROLL AND AINES 2008

diffuse seepage. CO2 that begins migration shortly after injection

may take a substantial period of time to reach the surface, especially
through natural pathways, such as heterogeneous reservoirs. Thus,
time to the surface will be a function of path permeability, path length,
and reactivity; lower permeability, longer paths, and higher reactivity
are generally likely to increase the time needed to reach the surface.
Since these kinds of leaks are most likely to travel through
groundwater systems to the surface, groundwater geochemical
monitoring is likely to suffice as the near-surface monitoring tool for
the long term. Additional surface monitoring tools, such as CO2
sensors and soil gas flux measurements, may be useful during
operational project phases or in higher-risk locations, but natural
variability in CO2 fluxes would need to be accounted for and could
even undermine the effectiveness of these measurements.
DEVELOPING A PROJECT-SPECIFIC
MONITORING PLAN
A large number of possible tools and approaches could provide key
information to operators, regulators, and other stakeholders. There
is no technical agreement at present regarding a minimal or
preferred set of tools for a given circumstance, nor is a uniform set
of tools expected to work for all projects. However, the stakeholder
group believes the current state of knowledge is sufficient for an
operator to select tools and methods that can provide the most
important information and services, and future regulations should
be flexible to allow for the operator to choose the tools that will
best facilitate effective monitoring for a given site. Over time,
assuming adequate site performance and increased understanding
of site geology, it is possible that the MMV needed for a site will
decrease based on performance and validation. Any changes in an
approved MMV plan would need to be accepted by a regulator
before they could become effective.

It is important to understand the limitations of MMV techniques

and, therefore, of MMV programs. For example, monitoring
programs cannot quantify all aspects of CO2 fate and transport in
the subsurface. Nor should they be expected to detect all leakage

CCS GUIDELINES

Many stakeholders view the need for surface monitoring (air and
soil gas fluxes) as being a potential requirement for public
acceptance; many experts believe because of the relatively low
cost, it should be included in an MMV suite. However, some surface
monitoring tools have been shown to give false positives (e.g.,
tracers, soil surveys) (T.H. Wilson et al. 2007, Ya-Mei. ang et al.
2008), and with substantial wellbore and subsurface monitoring,
stakeholders expect that any CO2 leakage should be detected long
before it reaches the surface.

Changes in pH, alkalinity, and concentration of calcium or other

STORAGE

Researchers have found that for wells that are exposed to static
carbonic acid, the rate of degradation and thus the risk of leakage
will diminish over time because of buffering reactions between
carbonic acid and the alkaline cement. Although wells are
constructed of materials that may degrade, experience is beginning
to suggest that the quality of the construction may have a larger
impact on the integrity of wells than the materials used in
construction. This is an area where more research is needed (IEA
GHG R&D 2005).

Groundwater Monitoring

67

in every location. All monitoring programs are limited by the

complexities of the subsurface and atmosphere and by the
detection limits of the tools. Currently available precision for CO2
EOR well-head flow meter accuracy in the United States is roughly
1% (API 1995). As such, direct metering of the injected volume
should not be expected to provide precision beyond this standard.
Because of the variability in project sites, these Guidelines do not
suggest requiring a specific set of monitoring tools. However, the
following key techniques should be considered, if they can be used
to provide useful data given the site characteristics and are
reasonably cost-effective:
 Pressure, temperature, and fluid chemistry monitoring in the
injection reservoir and a monitoring zone immediately above the
primary confining zone,
 Vertical seismic profiling,
 Seismic and time-lapse seismic (3- and 4-D),
 Use of tiltmeters, InSAR, or other surface deformation detection tools,
 Microseismic monitoring, and
 Surface air monitoring.
There is particular sensitivity to any regulatory requirements for
3- or 4-D seismic tests because of potential limitations in some
geologic formations. Although the first two commercial CCS
projects (Sleipner and Weyburn) used 4-D seismic for plume
location very successfully, there are some places where it will not
work (Arts et al. 2002; Wilson and Monea 2004).
ELEMENTS OF A MEASUREMENT,

CCS GUIDELINES

STORAGE

MONITORING, AND VERIFICATION PLAN

68

The main elements of an MMV plan include determining the extent

of the area to be monitored and establishing plans for baseline,
operational, and closure monitoring.

Monitoring Area. The definition of the monitoring area will be, in

part, a regulatory consideration. Because of inherent uncertainties
with subsurface geologies, this area should begin with the
projected CO2 plume over the project lifetime. For example, the
Washington State storage rule (WAC 173-218-115) defined the area
as: The boundaries of the geologic sequestration project which
shall be calculated to include the area containing ninety-five
percent of the injected CO2 mass one hundred years after the
completion of all CO2 injection or the plume boundary at the point
in time when expansion is less than one percent per year, whichever
is greater. (State of Washington 2008).
In addition to the projected CO2 plume, the monitoring area should
include any area of significantly elevated pressure. Significantly
elevated pressure is considered to be a level of pressure to
potentially cause adverse impacts to overlying receptors. For
example, any pressure that would raise a column of water to the
lowermost USDW and, in most cases, outside the confining zone is
significant. Combined, these two areas form the project footprint.
The extent of the project footprint may change over the lifetime of
the project. Monitoring should occur over the project footprint, be
informed by data gathered during the site characterization, and be
updated in real time with newly collected operational monitoring
data used to update the model of the subsurface CO2 plume. The key
to this performance-based approach will be defining the interval
between model updates by identifying what constitutes the need to
re-evaluate the subsurface model. One approach that could be
followed would be to review the monitoring area along with a permit
renewal application, or to have a required periodic re-evaluation.

Baseline Monitoring. Effective MMV relies on establishing an

initial baseline before injection, and then monitoring after injection
begins to detect and characterize changes in important parameters.
Thus, it is essential to establish a pre-injection baseline. Baseline surveys should be conducted for each relevant monitoring
parameter. In some cases, this will require simply the deployment
of tools or one round of data collection to define the initial state
(e.g., 3-D seismic, microgravity). For other tools or approaches, it
may require weeks, months, or even years of monitoring and
characterization to understand the natural fluctuations at a site
(atmospheric or soil CO2). Potential operators should understand the
nature of their site in order to predict their monitoring needs and
deploy their preferred monitoring suite far enough in advance to
establish a baseline with sufficient accuracy and precision for
successful site management. This must take place over enough of
the project footprint to fully monitor the first project stage. EOR
sites may pose unique challenges for baseline monitoring and any
challenges with collecting such baseline data should not preclude
secure storage at an EOR site.
Operational Monitoring. Operational monitoring for a large-scale
CO2 injection facility will closely resemble the injection facilities of
a CO2 EOR flood. This has been the case at the existing commercial
operations at Weyburn, In Salah, and Sleipner. In particular, standard
monitoring, such as injection volume, well-head and down-hole
pressure, and injection zone monitoring are expected in order to
satisfy local safety requirements and the basic needs of operators to
know that the CO2 is properly handled (Melzer et al. 1996a).

4-D seismic surveys are collected by sending sound waves into

the ground from a controlled source (on land this is commonly
a Vibroseis truck) and gathering them with geophones set out in
a dense array. The acoustic wave signals can detect small changes
in density and velocity, including those caused by variations in
rock and fluid properties at depth. These signals are processed and
rendered in a 3-D grid called a seismic volume. A fourth dimension is achieved when the seismic data are acquired at different
times over the same area.
SOURCES: ARTS ET AL. 2002; WILSON AND MONEA 2004

Step-rate tests: These tests are collected before injection to

reveal the maximum allowable pressure without inducing failure
or formation parting pressures (Magruder et al. 1990; Pittaway
and Runyan 1990).
 Pattern balancing: In the case where fluid is withdrawn, this
information helps to improve the advance of the flood, thereby
increasing the amount of CO2 that contacts rock and formation
fluids. It derives from the other data but requires separate analysis.

CCS GUIDELINES

Closure Monitoring. Once injection ceases, CO2 will continue to

displace water, migrate, dissolve, and mineralize. The pressure
within the injection formation will decline as the pressure
decreases, and more CO2 will be permanently trapped as a residual
or dissolved phase. Reactive, CO2-rich formation fluids will be
buffered through dissolution and precipitation, thereby reducing
their reactivity and increasing their pH. Figure 12 shows the
conceptual risk profile used at the beginning of the Guidelines. Here
it has been modified to show the possibility that any single project
will not have a smooth, even progression of risk, but instead may
experience site-specific risks due to geochemical reactions and
rock kinetics not fully described in site characterization. During the
operational life of a project, MMV programs may detect these
risk-exposure pathways, and adjustments in the MMV strategy can
be made. There is a continuing potential to encounter previously
uncharacterized risk-exposure pathways post-closure, although the
likelihood of this may decrease after injection. Because the risk of
leakage is expected to decline through time, the amount of
monitoring after site closure should be less than that during
operation. While many of the key parameters remain important
(e.g., reservoir pressure), the degree of sophistication and diligence
can be reduced based on site-specific performance showing that
the plume is behaving as predicted in the simulation model. In the
case where this performance is not achieved during the
operational life of a project and/or post-closure MMV gives rise
to concerns, the MMV program will most likely be extended or
expanded during post-closure.

STORAGE

Jarrell et al. (2002) write extensively on the operational monitoring

needed for CO2 EOR with conventional technology and accepted
approaches. Some of these parameters (e.g., produced oil volume) will
not be relevant for saline formation storage projects. However, the
following are key components of operational monitoring for CCS projects:
 Pre-injection well logging: If operators plan to use existing
wells for injection, then they will need to investigate the well
history, integrity, perforation status, and injection profiles. In some
cases, redesign, recompletion, and re-evaluation may be needed.
 Injection metering: All injection wells should have flow meters
and pressure sensors to accurately measure injection into each well.
 Injection profiles: This temperature or tracer type logging
reveals where the injectant is flowing. Such measurements are
not continuous, but may be required early in the injection and on
an occasional basis afterward (e.g., once a year).
 Reservoir pressure data: This may be accomplished either with
down-hole pressure sensors or by inverting surface pressure and
injection data, given knowledge of the injection profile.
Down-hole sensors should be deployed (Magruder et al. 1990;
Pittaway and Runyan 1990).

4-D Seismic Surveys

69

Figure 12: Conceptual Risk Profiles

for a Large CCS Project Through Time

Injection
begins

Injection
stops

2 x injection
period

3 x injection
period

n x injection
period

MONITOR
The green shaded curve represents a project with increasing pressure to
some predetermined limit and decreasing risk subsequent to injection.
The black line represents an alternate potential risk profile in which
secondary increases in risk are a function of local geochemical risks of
transport processes.
ADAPTED FROM BENSON 2007

STORAGE GUIDELINE 1: RECOMMENDED GUIDELINES FOR MMV

a. MMV requirements should not prescribe methods or tools; rather, they should focus on the
key information an operator is required to collect for each injection well and the overall

STORAGE

project, including injected volume, flow rate or injection pressure, composition of injectate,
spatial distribution of the CO2 plume, reservoir pressure, well integrity, determination of any
measurable leakage, and appropriate data (including formation fluid chemistry) from the
monitoring zone, confining zone, and underground sources of drinking water (USDWs).
b. Operators have the flexibility to choose the specific monitoring techniques and protocols
that will be deployed at each storage site, as long as the methods selected provide data at
resolutions that will meet the stated monitoring requirements.
c. MMV plans, although submitted as part of the site permitting process, should be
updated as needed throughout a project as significant new site-specific operational
data become available.
d. The monitoring area should be based initially on knowledge of the regional and site geology,
overall site-specific risk assessment, and subsurface flow simulations. This area should be

CCS GUIDELINES

modified as data obtained during operations warrant. It should include the project footprint

70

(the CO2 plume, the extent of injected or displaced fluids, and any areas of significantly
elevated pressure). Groundwater quality monitoring should be performed on a site-specific
basis based on injection zone to USDW disposition.
e. MMV activities should continue after injection ceases as necessary to demonstrate
non-endangerment, as described in the post-closure section (see Storage Guideline 7d).

A Conceptual Approach to Selecting Appropriate MMV Tools

British Petroleum (BP) has presented a conceptual approach for

selecting appropriate measurement, monitoring, and verification

(MMV) tools based on work conducted for the In Salah project. The

The Park quadrant represents techniques that have high costs

and a low information value. These techniques are not attractive.

The Focused Application quadrant represents techniques that

figure below depicts a graph with axis for (1) the benefit of the in-

provide valuable information about the project but are high in

formation on the vertical scale and (2) the cost of obtaining the

cost. These approaches might be used judiciously. For example,

information on the horizontal scale. In both cases, these aspects should

careful planning might be undertaken to ensure that, if used, 4-D

be evaluated based on the specific characteristics of the site at hand.

seismic is run in such a way as to provide maximal information.

Based on the site-specific geology at the In Salah project site, po-

The dotted line on the graph represents a hypothetical cost/

tential MMV techniques were identified, both techniques that are

benefit horizon for selecting MMV tools. As a preliminary assess-

thought to be key MMV tools (in dark green), as well as techniques

ment, those techniques located to the left of the red dotted line

that the project wished to test (in light green). It is important to

appear to make sense for the project and those outside of this

note that the MMV techniques indicated in the figure are ones con-

horizon may be inappropriate.

sidered in the In Salah research project. This figure is not being used
Once a preliminary assessment pointed to a potential suite of
to suggest that all of the MMV techniques listed are appropriate for
appropriate MMV techniques, further analysis was done to deterother projects, but rather to highlight the process used at In Salah
mine their cost-effectiveness. A few techniques were found to be
to determine which MMV techniques best suited that project.
more effective than originally anticipated, while others were
Combined, this graph creates four quadrants:


found to be less informational or more expensive to conduct.

The Just Do It quadrant represents techniques that have a high

This conceptual approach may be useful to developers and regulators
information value and a low cost.

in considering how to determine the most appropriate MMV strategy.

The Consider quadrant represents techniques that do not
appear to provide significant information value, but are considered because they are low-cost techniques.

LOW
Microbiology

CONSIDER

KEY

PA R K

Flowmeters
Cross-well
EM

Aquifer Studies

BENEFITS

Annulus
Sampling

Tracers

Wellhead
Monitoring

STORAGE

Dynamic
Modelling
Water
Chemistry

TO BE
TESTED

Tiltmeters

Satellite
Imaging

Airborne Flux

Surface EM

Cement
CO2 work
Surface Flux

Logging

Observation
Wells

Geochemistry

Geomechanics

JUST DO IT

Microseismic

Soil Gas

4-D VSP

F O C U S E D A P P L I C AT I O N
4-D Seismic

HIGH
LOW
SOURCE FOR FIGURES: WRIGHT 2008

COSTS

HIGH

CCS GUIDELINES

Wellbore
Sampling

4-D Gravity

71

CCS GUIDELINES

STORAGE

4.3.1.2 Risk Assessment

72

Risk assessment and management is included as a cross-cutting

issue because it is used not only to help select project sites and
design operations plans, but also, throughout the life of a CCS
project, to ensure its continued safety and integrity through operations, closure, and post-closure. Risk assessment involves the
identification (or qualification) and quantification of hazards,
including the probability of features, events, and processes that can
result in undesirable impacts on human health, the environment,
and potentially other receptors. Once risks are assessed, a project
developer may choose not to proceed with a project or manage
those risks through decisions in the project design, operations, and
MMV plans. Risk mitigation is the planning for and implementation
of contingency plans, should the need arise, to remediate adverse
impacts. Such planning should also include risk reduction measures,
identifying potential negative impacts and taking steps to reduce
their likelihood and/or severity. Since the approach to risk should be
consistent during any stage of a CCS project, it is described in detail
here and referred to as needed throughout the rest of the Guidelines.
Risk assessment is central to many industrial activities. A body of
literature and established practices for this type of analysis already
exist (U.S. EPA 2008e; Duguid and Celia 2006; Friedmann 2004;
Oldenburg et al. 2002). It is assumed that project developers will

utilize these approaches to evaluate and manage risks that are

reasonably common to large industrial projects, such as power
plants and oil production operations. This section draws from that
body of knowledge to focus on the primary risk of concern in
relation to CCS: the potential for CO2 leakage resulting in adverse
impacts on human health and the environment.
Any viable site for storing CO2 will most likely include some number
of identified hazards. When appropriately characterized and
managed, the hazards for most sites will not present a substantial
leakage risk (IPCC 2005). The risks associated with the hazards
identified should also influence MMV strategies for a given site.
Potential operators should undertake substantial efforts within the
proposed site area to identify hazards and assess the risk of
leakage through mapping, analysis, and simulation.
HAZARD IDENTIFICATION
Hazard identification should focus on the main potential pathways
for CO2 leakage: (1) insufficiency of the confining unit(s) or cap
rock failure, (2) artificial penetrations (wells), (3) transmission
through faults and fractures, and (4) naturally occurring or induced
seismic events that may lead to new or expanded transmissive
faults cross-cutting protected resources or reaching near the
surface environment (Friedmann 2007).

PROTECTING THE INTEGRITY OF THE CONFINING ZONE

Later in the Guidelines, the characteristics of a good confining zone

are discussed in depth, including areal extent and rock properties.
In addition, priority should be placed on evaluating any potential
vulnerability in the primary cap rock and the remainder of the
confining unit(s). An important vulnerability stems from overpressurization of the injection reservoir. It is standard practice
to address this concern by controlling injection pressure and
monitoring reservoir pressure.
From a technical perspective, there are several ways to measure
the yield strength of a cap rock, including laboratory tests on core
samples and conventional well tests (e.g., leak-off test, parting
pressure tests, step-rate tests). These tests are used to calculate
the reservoir pressure that would induce failure (known as fracture
gradient or fracture pressure). Typically, the injection permit
requires that injection pressures remain below levels that approach
the fracture pressure or would unduly increase reservoir pressure.
During risk assessment, a developer should define this threshold
for the unique geology of that CCS project site and implement
control measures to ensure that injection pressures do not induce
failure. Most injection regulations require an operator to ensure
that injection operations do not exceed some portion of the fracture
pressure. While using this kind of a numeric standard may be
appropriate in most cases, under certain stress, mechanical
strength, and poroelastic conditions, fault valving (causing
otherwise non-transmissive areas of a fault plane to intermittently
transmit fluid) can happen even if injection pressures are set
at levels that avoid fracturing the cap rock. Specific geologic
conditions may require setting an injection pressure that is well
below the fracture pressure.

Deep wells pose a challenge for CCS. They are necessary for
injection and monitoring, and they provide the access necessary for
acquiring site characterization data to define the thickness and
areal extent of potential storage reservoirs and confining units. The
challenge is that while more wells that penetrate the deep
subsurface provide more information about the subsurface geology,
they also pose an increased risk as a potential pathway for leakage.
By penetrating the confining zone (or cap rock), the same wells that
provide critical data also potentially compromise the primary

Despite the long, successful history of well engineering, there are

potential failure mechanisms that could allow CO2 to escape from
storage reservoirs through wellbores (Gasda et al. 2004; Scherer et
al. 2005). The integrity of a wellbore is influenced by several factors,
including the age of the well, type and condition of casing, quality
of completion, number of re-completions, method of plugging and
abandonment, and post-closure history (Ide et al. 2006).
Several approaches can be employed to understand well-related
leakage potential and to mitigate potential risks. There have been
several attempts to generate statistical and physical methods to
quantify the risks associated with wells in a CCS project (Celia et
al. 2006). Careful review of public drilling and completion records
archived by state agencies can inform this type of analysis and
generate regional or basin-scale screening tools. In addition,
conventional geophysical tools can detect casing from old
unknown wells, including buried, lost, and mislocated wells
(Veloski and Hammack 2006). These surveys have increased in
popularity due to their relatively low cost and high utility. Finally, it
is possible to monitor wells directly through regular surveys to
detect leakage. In the event that leaks are detected, conventional
approaches (Rabia 1986) can be used to re-complete active wells or
plug abandoned wells.
FAULTS

The wide variety of geologic formations around the world presents

a complex, heterogeneous collection of materials. Over time, this
material has undergone horizontal and vertical movement, which
has flexed, folded, and fractured the strata. These features, events,
and processes have created areas with oil and gas accumulations
and potential CO2 storage sites, but they also represent potential
leakage pathways. In the context of CO2 capture and geologic
storage, the impact of the presence of faults is highly site specific.
Some faults are conduits for rapid fluid migration, while others seal
the confining zone and prevent fluid migration (More et al. 1994).

STORAGE

ARTIFICIAL PENETRATIONSWELLS

storage mechanisms for CO2 storage: physical trapping. To maintain

operational integrity, wells that are no longer in operational service
should be cased and cemented (this occurs during construction) and,
ultimately, plugged and abandoned (Jarrell et al. 2002).

In considering the role of faults at a potential site, two important

points should be emphasized:
CCS GUIDELINES

The results from MMV should be used in an iterative process

in conjunction with modeling to inform site selection,
construction, operation, closure, and long-term stewardship.

73

CCS GUIDELINES

STORAGE

(1) The presence of seismically active faults does NOT exclude a

site from either holding CO2 or being considered for storage,
although a strong demonstration must be made that there would
be no risk of leakage resulting from seismic activity. There are
many places in the world where large volumes of buoyant fluids
(e.g., oil, gas, and CO2) are trapped indefinitely in the presence
of seismic activity, including California, Wyoming, Alaska,
Turkey, Western Australia, Papua New Guinea, Indonesia, and
Iran. After the injection of almost 9,000 metric tons of CO2 in the
Nagaoka CCS demonstration, operations were disrupted by the
Mid-Niigata Chuetsu 6.0-magnitude earthquake. Following
careful evaluation, it was determined that the wells, the
reservoir, and the facility were intact and undamaged, and
injection resumed (RIITE 2008).

74

(2) Many aspects of a fault affect its ability to trap CO2 at a site.
These include the geometry of the fault, its complexity, the
orientation of the fault relative to regional stresses, the amount
and distribution of fault gouge, and the occurrence of either
elevated or reduced pressure nearby (Yielding 1997). In some
cases, it is relatively straightforward to obtain key pieces of
information that can be used to understand the potential risks
presented by a fault or network of faults. Recently, Chiaramonte
et al. (2007) gathered information to estimate the potential for
faults within one oil field to transmit CO2. In their calculation,
one fault had a very low chance of becoming transmissive, and
would require injections well above reasonable operational
pressures to act as a leakage conduit. In contrast, another fault
network in a different part of the field would act as a conduit
for CO2 in the presence of even a small injection. If this were an
operational site, the southern part of the field would be a good
zone of storage, while the northern part would not because of
the possibility for transmissive faults at operational pressures.
This example highlights the need for careful site characterization
in selection and the importance of high-quality data.
The presence of large, active faults should not necessarily preclude
prospective sites from selection as storage sites. Rather, the complex
nature of faults in and associated with potential injection sites must
be characterized, considered, and managed as part of a risk
assessment and MMV plan. Hazard identification should focus on
faults that could be transmissive within the injection reservoir or
confining zone and expected project footprint, as faults only represent
a substantial hazard if they can transmit large volumes of CO2.
SEISMICITY

It has been known for roughly 40 years that, under some circumstances, injection of large fluid volumes can generate seismic
activity (Wesson and Craig 1987). In most cases, these effects will
be quite small, but under the wrong circumstances they may be

quite large. The most spectacular example comes from the Rocky
Mountain Arsenal near Denver, Colorado (Evans 1966). In that case,
injection of large volumes of fluid produced earthquakes as large as
magnitude 5.3 (Evans 1966; Healy et al. 1968). It is important to
note that at that site, the target rocks were completely impermeable, and as a result of injection of fluids, sustained very large
pressure buildups in the rocks fractures. This is not likely to be true
for commercial CO2 storage sites, where injection will occur in
porous rock units.
One relevant case of induced earthquakes involves the Rangely oil
field in northwestern Colorado (Hefner and Barrow 1992). This site
was the target of a series of experiments led by Stanford University
to generate small earthquakes in the hope of preventing larger
events. Between 1969 and 1972, the researchers injected very large
volumes of water into a fault in order to cause earthquakes (Raleigh
et al. 1976). The fault was selected because it was thought to be
close to failure. After several series of injections, the team was
able to generate several seismic events. However, the largest of
these events was magnitude 3.1, which could barely be felt at the
surface. The overwhelming majority of induced earthquakes were
less than magnitude 1, too small to feel at the surface. After these
experiments, the Rangely field became a site of active CO2 injection
(Klusman 2003b).
Injection of CO2 near a fault will not automatically trigger a large
earthquake. As discussed above, the case of Rangely demonstrates
that large CO2 injections are possible without inducing earthquakes.
Similarly, the history of water-flooding and formation fluid injection
in California oil fields also demonstrates that large volumes of fluid
may be injected next to large faults without causing failure.
However, careful site characterization and operation, along with a
risk assessment, are critical to managing seismicity, and the
uncertainties related to CO2 injection can only be answered with
large-scale injection tests.
Seismic risks related to elevated pressure during injection should be
assessed during site characterization. Appropriate MMV should be
designed to (1) assess the validity of the characterization and (2) to
ensure that any pressure or fluid composition thresholds leading to
unacceptably high risks are avoided. Microseismic monitoring is a
mature technology that shows promise as a tool to achieve these goals.

EVALUATION OF RECEPTOR IMPACTS

As stated earlier, the expectation is that appropriately selected
and managed sites will retain the injected CO2 for thousands of
years, and that leaks to the atmosphere are unlikely (IPCC 2005).
A comprehensive risk assessment is part of that site management.
For the purposes of risk assessment, a priority is to evaluate what
would happen if CO2 migrated unexpectedly through the confining

unit(s), potentially resulting in undesirable impacts on a variety of

potential receptors. While still in the subsurface, CO2 could impact
sources of drinking water or diminish the value of mineral rights.
If leaked to the surface, CO2 could collect and harm humans,
animals, and plants; cause other property damage; and contribute
to climate change.

A Conceptual Approach to Risk Assessment

Schlumberger Carbon Services (a service provider for carbon
dioxide capture and storage; measurement, monitoring, and
verification; and risk assessments) recently presented an example
of a risk assessment for a planned storage project in Illinois. To
develop this risk assessment, Schlumberger convened a group of
experts to rank a list of more than 80 risk elementsor features,

HUMAN AND ECOSYSTEM IMPACTS

Risks to people and ecosystems arise from the potential for CO2 to
accumulate in low-lying areas or areas with poor air ventilation. If CO2
leaks to the surface in areas with poor ventilation, such as basements
or shallow dips in the ground, it can accumulate to levels that could
cause stress or even asphyxiation in humans and animals. For humans,
concentrations above 50,000 ppm can cause unconsciousness, with
possible death at concentrations above 100,000 ppm. Plants are
affected when the roots become saturated with CO2.
CO2 quickly dissipates into the atmosphere; however, it is heavier
than air, and there are known fatalities associated with natural
releases of CO2 (Lewicki et al. 2006). An important part of risk
assessment is developing an understanding of the general
topography and population base of the area above a storage
project. Although the EPA Program does not require it, other
regulatory programs administered by EPA require modeling and
analysis of calm conditions (where wind does not expedite
dispersion) in evaluating airborne emission risks. Operators should
consider modeling denser-than-air releases. If potential concerns
are identified, then steps can be taken to prevent adverse impacts.

events, and processes (FEPs)based on likelihood (L) and severity (S). These rankings were developed through a group process
and independent surveys of the experts.
The rankings were assessed through two methods. First, the team
developed a combined (L*S) ranking and compared group and individual ratings. Second, the team mapped FEPs on a grid, with
severity on the vertical axis and likelihood on the horizontal axis.
These approaches provide the project team with a good assessment
of concerns that could arise at the specific site and will enable
them to both incorporate those risks into the reservoir models and
also to mitigate those risks through careful planning and operations. This kind of assessment will also help the team to design a
monitoring plan and interact with the public and regulators. It is
important to note that this kind of assessment can be repeated
over time; it is not a static analysis.
S O U R C E : H N O T TAVA N G E - T E L L E E N 2 0 0 8 .

GROUNDWATER

The potential of a diffuse subsurface CO2 leak to affect human health

and safety is minimal in many regions, because of atmospheric
mixing that prevents high atmospheric CO2 concentrations from

making contact with a potential receptor (Bogen et al. 2006; Lewicki

et al. 2006). A circumstance that might produce higher rates of CO2
release (and thus high concentrations and greater potential for
receptor impacts) is uncontrolled venting from abandoned or
orphaned wells, but even those cases are not expected to result in
substantial receptor impacts (Bogen et al. 2006). As described
above, another circumstance that could result in high concentrations
of CO2 would be if a slow leak accumulated in an unventilated area.
These scenarios can be avoided with proper site selection and
diligent risk analysis, MMV, and contingency mitigation plans.

CCS GUIDELINES

ATMOSPHERIC RELEASE

STORAGE

Risks to groundwater quality arise from the potential for CO2 to

mobilize organic or inorganic compounds, acidification, and
contamination by trace compounds in the CO2 stream, intrusion of
native saline groundwater into USDWs, and the potential for the
CO2 to displace subsurface fluids on a regional scale. The risks
resulting from CO2 migrating from the injection zone into a potable
aquifer need to be better understood. Scientific studies bounding
the potential harm to groundwater resources from CO2 leakage
would provide better constraints on the overall relevance of this
risk. For example, if a site has high natural occurrences of toxic
metals (e.g., arsenic) or high volatile organic carbon content, site
assessors would need to analyze the site hydrology and
geochemistry to understand potential health effects for a given CO2
leakage rate and concentration (Friedmann et al. 2006).

75

Risk management plans for CCS projects

should span the project life cycle
and be updated periodically to evaluate risks
based on any new data collected.
In considering the potential atmospheric release hazards at a site,
one should consider existing cases of CO2 well failure (Bachu 2000;
Gouveia et al. 2005; Holloway et al. 2007). These can serve as the
basis for scenarios to understand potential impacts of site release.

CCS GUIDELINES

STORAGE

The other risk from atmospheric release is the contribution of the

released CO2 to global climate change, negating the benefits
assigned to a storage project. There may be several ways of
addressing this risk, including discounting the climate change
benefit, using insurance or options on allowances, and other
financial risk management approaches.

76

RISK MANAGEMENT
Once risks are understood, a project developer can take steps to
avoid or manage them. These include deciding not to proceed with
injection at a particular site. However, other steps can be taken to
modify the design as well as the operation. MMV plans contribute
by providing early detection to ensure risks are not realized. Risk
management plans for CCS projects should span the project life
cycle and be updated to evaluate the risks associated during capture,
transportation, and injection of the CO2, as well as risks associated
with post-closure storage. As shown in Figure 10, the risk of CO2
leakage to the atmosphere is expected to be greatest during
the early operational phases of a storage project. Examples of
operational leakage include compressor failures that result in the
need to vent CO2, wellbore failures, and other incidental operational
emissions. Many of these risks are relatively common to large
industrial projects, and there are standard practices for managing
them. However, some of these risks are unique to storage.
MITIGATION OR REMEDIATION PLANNING
To mitigate the risks of unanticipated migration of the CO2 plume
and potential leakage, operators should develop a contingency
mitigation plan or remediation strategies, and make efforts to
reduce identified risks. The approach should reflect both the site
hazard priority and the concerns of local regulators and
communities regarding potential impacts to groundwater, the
atmosphere, or the confining unit(s). For example, if groundwater
contamination is both a particular site hazard and regulated
under stringent local water quality guidelines, then a specific
mitigation plan for groundwater contamination should be part of
the operational management plan. Potential operators should

develop minimal mitigation plan requirements. It is important that

the contingency mitigation plans are neither unduly burdensome
nor too lax. One method used in Chevrons Gorgon Project in
Australia is a mitigation plan that includes defined actions in
response to indicators (signposts) with technology descriptions
(Chevron Australia).
To address the anticipated risks, several approaches could be
considered based on project-specific leakage risks. Table 8
summarizes the potential risk scenarios and remediation options. It
is important to note that while mitigation techniques may exist,
careful consideration as to cost and effectiveness needs to be given
before employing these approaches. In some cases, leakage will
not result in contamination and may not require significant
mitigation. In other cases, a mitigation technique may prove to be
very costly or may result in other issues needing to be addressed,
such as produced brines or waste materials requiring disposal. The
potential environmental impacts of remediation options should be
part of a comprehensive environmental impact study.

Table 8: Possible Risk Scenarios and Remediation Options for Geologic Carbon Storage Projects
Risk Scenario

Leakage through faults,

fractures and spill points

Leakage through active

or abandoned wells

Leakage into the

vadose zone and
accumulation in soil

Accumulation of CO2
in groundwater

off valves to stop injection.

 Lower injection rates/pressure.
 Lower reservoir pressure by removing water or other fluids from the storage reservoir.
 Create a hydraulic barrier by increasing reservoir pressure upstream of the leak.
 Install chemical sealant barriers to block leaks (Jarrel et al. 2002).
 Stop injection, extract CO2 from storage reservoir, and re-inject it into a more suitable reservoir.
 Repair leaking wells by replugging with cement.
 Repair leaking injection wells with standard well recompletion techniques, such as replacing the injection tubing
and packers.
 Plug and abandon wells that cannot be repaired.
 Create a hydraulic barrier by increasing reservoir pressure upstream of the leak.
 Install chemical sealant barriers to block leaks.
 Stop injection.
 Extract CO2 from the vadose zone and soil gas by standard vapor extraction techniques.
 Pump CO2 away from trenches or other low-lying areas, and either vent or reinject it in the subsurface.
 Employ passive remediation, such as diffusion and barometric pumping to slowly deplete one-time releases of CO2
into the vadose zone. This method may not be effective for managing ongoing releases, because it is relatively slow.
 Irrigation and drainage or alkaline supplements (such as lime) can be used to remediate soils that have acidified
because of CO2 exposure.
 Create a hydraulic barrier by increasing reservoir pressure upstream of the leak.
 Install chemical sealant barriers to block leaks.
 Stop injection.
 Drill wells that intersect the accumulations in groundwater, and use them to extract the CO2, either in pure form
or dissolved in groundwater.
 Dissolve mineralized CO2 in water, and extract it as a dissolved phase through a groundwater extraction well.
 Pump CO2-contaminated groundwater to the surface, and aerate it to remove the CO2. For possible trace element
contamination, pump-and-treat methods can be used.
 Create hydraulic barriers to immobilize and contain any contaminants by appropriately placed injection and
extraction wells.
 Employ passive methods that rely on natural biogeochemical processes.
 Create a hydraulic barrier by increasing reservoir pressure upstream of the leak.
 Install chemical sealant barriers to block leaks.
 Stop injection.
 Manage potential slow indoor releases with basement/substructure venting or pressurization. Both would have
the effect of moving soil gases away from the indoor environment.
 Create a hydraulic barrier by increasing reservoir pressure upstream of the leak.
 Stop injection.
 Use fans to disperse CO2, similar to radon fans.
 Shallow surface water bodies that have significant turnover (shallow lakes) or turbulence (streams) will quickly
release dissolved CO2 back into the atmosphere.
 Do not locate projects near deep, stably stratified lakes; however, if impacted, active systems for venting gas
accumulations in these lakes have been developed and applied at Lakes Nyos and Monoun in Cameroon.
 Create a hydraulic barrier by increasing reservoir pressure upstream of the leak.
 Install chemical sealant barriers to block leaks.
 Stop injection.
C O N T I N U E S N E X T PA G E

CCS GUIDELINES

Accumulation in
surface water

 Shut

STORAGE

Accumulation of CO2
in indoor environments
with chronic low
level leakage

Mitigation/Remediation Options

77

Table 8: Possible Risk Scenarios and Remediation Options for Geologic Carbon Storage Projects (continued)
Risk Scenario

Large releases of CO2

to the atmosphere

Mitigation/Remediation Options
 Use

large fans to rapidly dilute CO2 to safe levels for releases inside a building or confined space.
 Dilution from natural atmospheric mixing (wind) will rapidly dilute CO2 from outdoor releases over a large area in
many cases.
 Install chemical sealant barriers to block leaks.
 Stop injection.

SOURCES: IPCC 2005; U.S. DOE 2007B

STORAGE GUIDELINE 2: RECOMMENDED GUIDELINES FOR RISK ASSESSMENT

a. For all storage projects, a risk assessment should be required, along with the development
and implementation of a risk management and risk communication plan, should be required
for all storage projects. At a minimum, risk assessments should examine the potential for
leakage of injected or displaced fluids via wells, faults, fractures and seismic events, and
the fluids potential impacts on the integrity of the confining zone and endangerment to
human health and the environment.
b. Risk assessments should address the potential for leakage during operations, as well as
over the long term.
c. Risk assessments should help identify priority locations and approaches for enhanced
MMV activities.
d. Risk assessments should provide the basis for mitigation/remediation plans for response to
unexpected events; such plans should be developed and submitted to the regulator in
support of the proposed MMV plan.
e. Risk assessments should inform operational decisions, including setting an appropriate
injection pressure that will not compromise the integrity of the confining zone.
f. Periodic updates to the risk assessment should be conducted throughout the project life
cycle based on updated MMV data and revised models and simulations, as well as

STORAGE

knowledge gained from ongoing research and operation of other storage sites.
g. Risk assessments should encompass the potential for leakage of injected or displaced
fluids via wells, faults, fractures, and seismic events, with a focus on potential impacts on
the integrity of the confining zone and endangerment to human health and the environment.
h. Risk assessments should include site-specific information, such as the terrain, potential
receptors, proximity of USDWs, faults, and the potential for unidentified borehole locations
within the project footprint.
i. Risk assessments should include non-spatial elements or non-geologic factors (such as
population, land use, or critical habitat) that should be considered in evaluating a specific site.

CCS GUIDELINES

4.3.1.3 Financial Responsibility

78

In the context of geologic storage, financial responsibility is the

obligation of the project operator to pay for defined activities
associated with the operation of a CCS project. Specifically,
financial assurance is predicated on the expected value of the
estimated cost to conduct closure (including well plugging and
abandonment, MMV, and foreseeable mitigation (remediation)). In
certain situations, financial assurance can also be used to hedge

the financial consequences of potential cost overruns associated

with these activities, as well as the financial consequences of
unanticipated events (e.g., compressor breaks, CO2 migration).
Typically, regulators are concerned with ensuring that adequate
funds are in place to close or complete projects, and financiers or
risk managers are concerned with ensuring that the costs are
predictable and adequate funds are in place for the entire life of
the project.

Project developers will estimate these costs during project planning and will use this information to evaluate return on investment
and financial risk exposure. These will be important drivers for
determining whether to proceed with a project, and serve as an
essential foundation for obtaining financing. As project size and
uncertainty increase, so does financial risk. Companies will strive
to minimize and mitigate this risk through a variety of means. A
financial responsibility framework will establish the obligations of
various parties to guarantee the construction, operation, closure,
and, to the degree appropriate, safe post-closure monitoring of their
facilities. Further, an effective financial assurance framework will
(E.J. Wilson et al. 2007):
1. Ensure funds are adequate;
2. Ensure funds are readily accessible;
3. Establish minimum standards for financial institutions securing
funds (or underwriting risk);
4. Ensure continuity of financial responsibility, if and when sites are
transferred;
5. Not impose excessive barriers to projects that have public benefits.

In response, an effort has been made to break down the components

of potential financial responsibility. During each stage of a project,
there will be some need to conduct MMV; based on the MMV
findings, unplanned changes in operations plans or implementation

Several models have been proposed to balance the need to hold

project operators/owners accountable for the performance of their
projects and to ensure that in the event of costly damages, project
operators/owners have some ways to mitigate their financial risk
exposure. One potential approach is found in the oil and gas
industrys orphan well programs. Under these programs, existing
well operators pay a fee into a fund that is usually managed by a
state and that can be used to pay for completion or mitigation at
wells that have been orphaned (IOGCC and U.S. DOE/NETL 2008).
Other proposed models rely on a combination of individual and
shared risk management systems, which involve federal indemnity
for a portion of the potential responsibility.

CCS GUIDELINES

A remaining issue to be resolved with respect to financial

responsibility and CCS projects is the degree to which financial
assurance is necessary to cover the costs of potential long-term
stewardship at sites that are certified as closed. In theory, wellsited, constructed, operated, and closed projects should not pose a
threat to human health and the environment. In thinking about
storage, and especially the first demonstration projects, there is a
higher degree of uncertainty about when it will be possible to
demonstrate non-endangerment in order to complete site-closure.
This uncertainty may increase the perceived risk exposure to levels
that serve as a barrier to investment.

As described in the WRI Issue Brief on CCS liability:

It is generally accepted that financial responsibility requirements
serve as an inducement to firms to properly operate and maintain
their facilities. In the case of CCS, the intent is to minimize the
number of orphaned facilities, ensure proper long-term stewardship, and mitigate any environmental risks from site releases. At
its core, financial responsibility is an issue of risk management. A
well-established financial responsibility program will balance
stakeholder interests and ensure the safe closure and responsible
post-closure stewardship and monitoring. Specifically, an
effective financial responsibility framework will ensure that
developers and operators maintain adequate financial resources
to fulfill their near- and long-term obligations. Additionally, it will
encourage competition and foster beneficial market impacts,
including (E.J. Wilson et al. 2007):
 Targeted Capital Investment, whereby firms have the incentive to
design, site and operate facilities that reduce the likelihood of
injury to environmental/public health and minimize litigation risk.
 Deterrence and Precaution, whereby firms will have the incentive
to undertake operating decisions that consider environmental
(and remediation) costs.
 Optimal Pricing and Consumption, whereby firms are stimulated
to appropriately internalize costs, minimizing excessive consumption of environmentally damaging goods

STORAGE

Current regulations governing underground injection wells require

project owners and/or operators to demonstrate financial assurance
for the costs of plugging and abandoning wells, certification of site
closure (MMV), and foreseeable mitigation (remediation). Generally,
the accepted instruments for financial assurance are third-party
financial mechanisms, including trust funds, surety bonds, letters of
credit, insurance, or self-insurance through a financial test and/or
corporate guarantees. CCS facilities will be required to demonstrate
financial assurance for CCS activities as part of U. S. EPA proposed
rule for Geological Sequestration. The requirement to enforce
financial assurance provisions may be delegated to primacy states
with primacy authority under the EPA UIC Program.

of mitigation measures may be required. If problems arise, there may

be the need to undertake mitigation (remediation), and potentially
address compensatory damages, as well as related tort liability.
Stakeholders have noted that these financial consequences have
the largest potential uncertainty and seem to be of the greatest
concern. The challenge is in designing a financial responsibility
framework that encourages a project operator/owner to minimize
occurrence of these events, and therefore minimizes the attendant
financial burden. Nonetheless, despite best efforts, problems may
arise that are due not to negligence but instead to incomplete
scientific or technical understanding.

79

STORAGE GUIDELINE 3: RECOMMENDED GUIDELINES FOR FINANCIAL RESPONSIBILITY

a. Based on site-specific risk assessment, project operators/owners should provide an expected
value of the estimated costs of site closure (including well plugging and abandonment, MMV,
and foreseeable mitigation (remediation) action) as part of their permit application. These
cost estimates should be updated as needed prior to undertaking site closure.
b. Project operators/owners should demonstrate financial assurance for all of the activities
required for site closure.
c. Policies should be developed for adequately funding the post-closure activities that become
the responsibility of an entity assuming responsibility for long-term stewardship, as
described in the Post-Closure section.
d. Because of the public good benefits of early storage projects and the potential difficulty
of attracting investment, policymakers should carefully evaluate options for the design
and application of a risk management framework for such projects. This framework
should appropriately balance relevant policy considerations, including the need for
financial assurances, without imposing excessive barriers to the design and deployment

CCS GUIDELINES

STORAGE

of CCS technology.

80

Discussions are underway to determine the best approach to ensure

financial responsibility for storage projects. This is a topic that
warrants further discussion among the stakeholder group, as there
are significantly divergent views on the scope, need for, and nature
of financial responsibility mechanisms for CCS. Future stakeholder
discussions and resulting recommendations will consider the
usefulness and potential structure for a private/public framework to
be adopted at the state or federal level. In the meantime, the above
preliminary Guidelines are recommended. It should be acknowledged that these financial responsibility Guidelines may be
modified as a result of future stakeholder discussions. Also, they do
not specify the degree or nature of financial responsibility following
site closure certification.

Storage on Federal Lands

Federal lands offer attractive social and economic advantages for
private and public storage projects, including ease of gaining
legal access to surface and subsurface property with clear ownership, enhancing national energy security, and providing for early
deployment of critical carbon mitigation technology. In accordance with federal statutory mandates, the U.S. Department of the
Interiors (DOI) Bureau of Land Management and the Minerals
Management Service should take steps to create the policies and
procedures in the near term that allow for the responsible
deployment of storage in the long term.
DOI is currently working to develop a framework for geologic
storage on public lands and will be providing a report to the Senate

4.3.1.4 Property Rights and Ownership

Energy and Natural Resources Committee and House Natural Re-

Property rights and ownership are considered cross-cutting issues

because an operator of a storage project will need to work with a
number of property owners throughout the project life cycle to
obtain legal access to surface and subsurface pore space. Access
to the subsurface pore space containing the CO2 plume should be
procured during the early planning stages of the project, along with
surface access for any monitoring that would occur on property
beyond what is owned by the operator. However, continued

Potential storage sites on federal lands in different formation types.

A proposed framework for leasing public land for geologic storage.

A procedure for public review of storage plans.

A procedure for protecting natural and cultural resources.

A framework for issuing rights of way for CO2 pipelines on public lands.

The status of federal leasehold and mineral estate liability for

sources Committee in December 2008, including recommendations for:

long-term stewardship.

Potential operators should undertake substantial efforts

within the proposed site area to identify hazards
and assess the risk of leakage
through mapping, analysis, and simulation.

communication with neighboring affected landowners is essential

throughout a storage project, especially as land use and ownership
may change through the course of a projects operational life, and
doing so can help ensure the success of long-term stewardship.
There are many analogues to storage from a property-ownership
perspective, including experience gained through the oil and gas
industry. In the United States, there are important nuances in
property rights that vary significantly by state. This section proposes
Guidelines that will help facilitate clarity in ownership issues for
storage projects.
SUBSURFACE OWNERSHIP
In the U.S. context, it is likely that surface owners also own the
right to the pore space unless they have explicitly included pore
space in the lease or sale of the mineral rights in the subsurface.
However, there is not full clarity on this issue, and some believe
that for storage in mature oil and gas fields, project developers may
need to acquire both the surface and the mineral rights if those
have been previously separated. It is expected that this issue will
gain clarity only after a series of state legislative actions and case
law are developed.

Once clarity about the requirements for obtaining ownership rights

is established, the operator can lease or buy the storage pore space
from the necessary property owners, just as mineral rights and
natural gas pore space are leased or bought in many states. In cases

CCS GUIDELINES

Many states as well as the IOGCC have supported the notion

that pore space ownership should follow surface ownership
(Nowakowski 2008). In March 2008, Wyoming became the first
state to enact a law that clarifies ownership for storage pore space.
The law went into effect in July 2008 and clearly states that in
Wyoming, pore space for carbon storage follows the surface owner.
A New Mexico report completed in December 2007 also
recommends this approach to ownership, with likely discussions
expected during the 2009 session.

In the European Union, pore space is owned by the state, which

significantly simplifies ownership (Haszeldine et al. 2007).
Ultimately, it is not clear how subsurface property rights will be
resolved, either nationally or internationally. In the short term,
operators are served in all contexts by working with states and
governments on legal clarification and to site early projects where
there are small numbers of surface owners (e.g., large ranches,
state land) and where the informed consent of the community can
be secured.

STORAGE

Currently, there are two theoretical models for access to the pore
space for CO2 injection and ownership for CO2 injection into saline
formations in the U.S. context (de Figueiredo 2007). Neither model
was reviewed by the stakeholder group; both are provided for
illustrative purposes.
 Private ownership model, where the surface owner owns the pore
space rights. These can be sold or leased or condemned and can
be purchased or leased accordingly, or condemned and captured
by eminent domain.
 Public interest model, where much like the air space where the
federal government establishes the flight patterns for public safety,
there may be a rationale for government influence over the pore
space in the public interest of addressing climate change.

where a lease agreement cannot be established, eminent domain

could be applied. Eminent domain for natural gas storage pore space
has been applied in several states, including Illinois and New York,
but other states have chosen not to invoke eminent domain for this
purpose. The existing variety in the application of law for property
ownership of mineral resources could complicate projects where the
CO2 plume will cross state boundaries. So far, in the United States,
the discussions on pore space ownership have emphasized that the
operator should procure unambiguous legal access to storage pore
space based on the laws in that jurisdiction/state. Some have also
proposed that storage pore space be unitized in the same way that
oil and gas fields are unitized, which would ease the leasing process
for potential operators.

81

LAND ACCESS AND GEOPHYSICAL TRESPASS

Access to the surface and subsurface for both injection and
monitoring is central to storage operations. Before injection, it is
absolutely imperative to have unambiguous authority to access the
pore space involved, through subsurface leases, surface owner
agreements, or grants from the state or federal government (IOGCC
2007). No operator should undertake subsurface injection without
clear access from title holders to the injection zone.

STORAGE

It may be necessary to monitor in a region that, within reason, is

larger than or different from the predicted project footprint. This may
be a result of inaccurate subsurface characterization and injection
simulation. However, even if all predictions and characterizations
are accurate, many geophysical or hydrological monitoring methods
will require an area larger than the project footprint. In the case of
3- or 4-D seismic, microseismic, or gravimetric surveys, a surface
area larger than the project footprint is needed to extend geophones
to gain fold and resolution. In the case of wellbore monitoring,
prudence, regulation, or technical accuracy may require monitoring
of wells beyond the project footprint.
In cases where monitoring needs may extend beyond the CO2
plume, geophysical trespass (unauthorized collection of geophysical
data) may become an issue. In such cases, monitoring activities
may collect information that demonstrates a lack of other mineral
resources (e.g., oil and gas) at a site (Wilson and de Figueiredo
2006). Since the opportunity to survey and explore is in itself an
asset, monitoring can cause damages to some parties (such as loss
of property value). More likely, concern over geophysical trespass
may limit monitoring opportunities in a way that does not serve
operators, regulators, or public stakeholders. This issue will require
further focus from potential CCS parties and legislators. It may be
possible in the near term to avoid this issue by initiating projects in
areas where these issues are straightforward (e.g., public lands,

existing oil fields), or where extensive exploration, production, or

subsurface operation has made these issues moot.

SUBSURFACE TRESPASS
AND RESOURCE DEGRADATION
Subsurface trespass, the reduction in value of mineral resources
due to subsurface incursions, is likely to prove a cause for legal
action (IOGCC 2007, Wilson et al. 2006). In most cases, incursions
are local and limited, and commonly occur near the boundary of
subsurface operations. There is an established body of case law
associated with water flooding, enhanced oil recovery, and natural
gas storage that can be applied to actions where subsurface
trespass is suspected or maintained. Similarly, there is a base of
operational experience that can be used to prevent or mitigate
subsurface trespass. This includes modeling and simulation to
anticipate potential problems and wells to intercept fluid migration
and prevent trespass. While this may present potential risk to
operators, proper site characterization, planning, and monitoring
should be able to avoid trespass and its associated legal troubles.

In contrast, it is possible that large injections or multiple large

injections in a reservoir may result in far-field resource degradation
where no attribution is possible. One hypothetical case involves
shallow formation fluid intrusion caused by displacement of saline
formation waters far from injected CO2. In a region where many
injections are occurring, attribution may be impossible (this
situation could be made worse by transboundary issues). While
there is no particular action or Guidelines for potential operators in
this regard, it may be useful for state and federal regulators or
legislators to begin to consider this problem to provide clarity for
future cases.

STORAGE GUIDELINE 4: RECOMMENDED GUIDELINES FOR PROPERTY RIGHTS AND OWNERSHIP

a. Potential operators should demonstrate control of legal rights to use the site surface and/or
subsurface to conduct injection and monitoring over the expected lifetime of the project
within the area of the CO2 plume and (where appropriate) the entire project footprint.
Regulators will also need access for inspection.
b. Continued investigation into technical, regulatory, and legal issues in determining pore

CCS GUIDELINES

space ownership for CCS is warranted at the state and federal levels. Additional legislation

82

to provide a clear and reasonably actionable pathway for CCS demonstration and
deployment may be necessary.
c. MMV activities may require land access beyond the projected CO2 plume; therefore, land
access and any other property interest for these activities should be obtained.
d. Operators should avoid potential areas of subsurface migration that might lead to claims of
trespass and develop contingencies and mitigation strategies to avoid such actions.

4.3.2 Project Stage Issues

This section describes the issues arising during site characterization
and selection, operations, and site closure.

Figure 13: Geologic Storage Reservoir

with Multiple Confining Zones

4.3.2.1 Site Characterization and Selection

Site characterization and selection is the most important step in
ensuring the integrity of a storage project. This step provides the
opportunity to evaluate a series of geologic and nongeologic factors
that will influence the design, cost, and ultimate success of a
potential storage project.
Suitable storage sites have both a confining zone and a storage
formation, as shown in Figure13. The confining zone(s) must prevent
vertical migration of CO2. Typical confining zones, or cap rock layer,
can be shales and thick deposits of evaporites (e.g., gypsum, salts).
Storage formations must have sufficient porosity for storage
capacity and sufficient permeability to allow injection of the
captured CO2. Typical target formations can be clastic sedimentary
rocks (such as sandstones or conglomerates) or carbonates (such
as limestones or dolostones). Under the right circumstances, other
kinds of formations might serve as storage reservoirs, such as
unminable coal seams, basalts, and evacuated salt caverns.
The conceptual approach for site characterization and selection is
a selection process in which a small number of candidate sites are
identified based on readily available information and preferences.
Then the sites are further investigated, which includes site-specific
risk assessments as described earlier, to evaluate and rank them.
Finally, detailed site characterizations are conducted to finalize site
selection and prepare permit applications. This approach is
described in the second part of this section.
STORAGE

The suitability of a site for storage is a function of three primary

technical factors: the effectiveness of a confining zone in preventing
upward migration of CO2; the injectivity of the storage reservoir;
and the volumetric capacity of the reservoir to hold injected CO2.
These factors are discussed in the third part of this section. In areas
with significant pre-existing data (e.g., mature oil and gas fields),
site characterization will be easier to complete. In areas with very
little pre-existing data about the subsurface, site characterization
will be a more involved process that will require more time and
expense to complete.

C O U R T E S Y O F I L L I N O I S S TAT E G E O L O G I C A L S U R V E Y

CCS GUIDELINES

THE GOAL OF SITE CHARACTERIZATION

The purpose of a storage project is to store CO2 underground
indefinitely (IPCC 2005). The goal of site characterization is to set the
stage for successful long-term storage. It is important to consider the
following points in establishing Guidelines for site characterization:
 Certain basic information about the rock formations throughout
the United States (and perhaps most of the world) exists in state

83

CCS GUIDELINES

STORAGE

and other public geologic surveys. Additional information is also

held by private firms. This basic information includes the location
of sedimentary basins and other general characteristics; it will
serve as a preliminary screening tool.
 Detailed information about a site may be extensive in areas
where there has been exploration for oil or minerals and will be
less extensive in areas where there has been limited exploration.
With characterization and development of the storage site, the
level of knowledge will grow.
 A specific regulatory framework for CO2 storage operations is still
emerging (E.J. Wilson et al. 2007). However, much of the basic
framework can be drawn from related areas. For example, in July
2008 the EPA issued a proposed rule covering CO2 injection for
storage projects. If finalized, this rule would require specific site
characterization and selection activities for CO2 injection wells.
Further, there are established provisions for addressing
subsurface trespass in the oil and gas industry that could be used
as models for storage.
 There are many viable strategies to detect leakage should it
occur, and a suite of potential mitigation and remediation
strategies to prevent human health, safety, and environmental
impacts. The human health, safety, and environmental risks from
CO2 exposure require high concentrations (Snodgrass 1992;
Rice 2004). Potential areas where CO2 could accumulate should
be identified through the risk assessment and should be a
consideration in site selection.

84

Initial site characterization will help to make a credible case that

CO2 can be injected and stored safely and effectively at a site
indefinitely. This would be similar to the characterization necessary
to sustain natural gas storage, defend oil and gas exploration
investments, and permit industrial waste injectionall of
which carry similar uncertainties in their initial stages. As such,
pre-injection site characterization should provide:
 A geologic analysis of the storage reservoir(s) and confining
zone(s), as well as an analysis of the chemistry of the groundwaters in the vicinity of the proposed storage project. Both
will contribute to establishing baseline information for future
MMV analysis.
 A field development plan for the storage project, including well
and facility designs, injection pattern, and possible evolution of
the injection pattern, as well as deployment of MMV tools and
risk management plans.
 A demonstration of the ability to meet financial responsibilities in
the operation and closure of the storage project.
These goals may be readily met with existing tools and techniques.
The ability to select and operate a site effectively will improve
through time (Mignone and Socolow, in review).
A CONCEPTUAL APPROACH TO SITE
CHARACTERIZATION AND SELECTION
The process of site characterization and selection has been
described as an exploration for bounded pore space. It is a series of
steps that is used first to identify and assess potential sites and
then to confirm the selection and promotion of chosen sites.

Acquiring the information needed

to assess the suitability of a reservoir for storage
will usually require investments in drilling,
surveying, and site-specific data collection.
To minimize cost and impact, site characterization tends to follow a
down-selection process. As a first step, the operator develops a
conceptual model of the regional geology, which serves as the basis
for the computational reservoir model. This conceptual model is based
on readily available data, and includes the general location and
classification of rock types in a selected area, known wells, faulting,
and seismic activity. Candidate locations are identified based on a
series of technical and nontechnical site-specific factors. Technical
factors include data from existing core samples, available seismic
surveys, records and descriptions of existing or plugged and
abandoned wells, and other available data (some of which may need
to be purchased if held by private companies). Nontechnical factors
include the location of CO2 emission sources, property ownership, land
use, and available infrastructure. Once a small number of candidate
sites are prioritized, an operator may start doing some test drilling or
other on-site measurements, such as seismic survey work to develop
site-specific reservoir models, and make a final site selection. In an
area where there is not an extensive amount of existing data from
core samples and other tests, this work may need to be conducted
over a large area and could involve multiple test wells.

In the context of this discussion, there are potential tradeoffs in

site performance between having more or less site characterization.
Each site is different, and the level of necessary site characterization will vary. This is not to suggest that one general type of site
is better than another. For example, sites in well-characterized

CHARACTERISTICS OF EFFECTIVE CONFINING ZONE(S)

A primary geologic confining zone is essential for effectively

sequestering large volumes of CO2. Injected CO2 will be buoyant, thus
gravitational (buoyancy) forces will drive CO2 upward from the
injection point to the top of the storage formation. A confining zone
(also called a cap rock, confining unit, or seal) is a geologic formation
that overlies the target formation. It can impede this buoyant flow
effectively because it is very fine grained and has extremely small
pore throats (making it essentially impermeable to CO2) (Watts 1987;
Harrington and Horseman 1999). In many reservoirs, this will be the
most important trapping mechanism of the injection target. For a
confining zone to be effective, it must be laterally extensive and thick
enough to counter the total buoyant forces of a CO2 accumulation at
depth over the injection area. Marine and lacustrine shales and thick
deposits of evaporites (e.g., anhydrite/gypsum, salts) are common cap
rocks in a confining zone. As geologic analogs have demonstrated,
evaporites exhibit rheologic properties (flow), which in the presence
of CO2 contributes to healing fractures, preserving the lateral
continuity of the sealing formation.

CCS GUIDELINES

Implicit in this discussion is the notion that after detailed review,

some candidate sites may not qualify for use. Such sites are similar
to dry holes in the oil business. That is, although the preliminary
data suggested they would be good locations for storage, actual
results from drilling, and perhaps even test injection, reveal that
the geology is such that they should not be used for long-term
injection and storage. The site characterization process may also
reveal that some sites have weaknesses that could be addressed
through appropriate project design and operation.

KEY FACTORS IN RESERVOIR SUITABILITY

These Guidelines focus on three main reservoir attributes: the
effectiveness of the confining zone(s) that will serve as the primary
mechanism for ensuring injected CO2 does not migrate vertically;
the injectivity or rate at which CO2 can be injected into the reservoir;
and the estimated capacity of the injection field. These factors
(along with community support) are critical in determining the
suitability of a site and in comparing potential sites. Not all of the
information necessary to assess these three factors is going to be
readily available without investing in drilling, surveying, and
sampling activities.

STORAGE

The information gathered during site characterization is assembled

into a permit application, a reservoir model, and the preliminary
project design. If a permit is granted, an operator will complete
the initial site characterization by completing initial injection
wells, conducting injection tests as needed, and validating the
reservoir model.

geology may be spatially limited or may have a larger number of

deep boreholes, so may require a different emphasis in risk
assessment and management and more wellbore characterization
work. For some deep saline formations, the lack of pre-existing
characterization may result in a need for more iteration in the early
stages of a project. A homogeneous, deeper, and well-sealed saline
reservoir may not encounter these issues. The key practice is
iteration, and ability to match expectations or predictions through
the course of site evaluation.

85

Storage Mechanisms
Several mechanisms work in combination to ensure that CO2 remains in the storage reservoir. Supercritical CO2 is buoyant, and will
migrate upward. This migration can be prevented by a confining
zone overlying the injection formation. Storage through this physical trapping contains very high fractions of CO2, and acts
immediately to limit vertical CO2 migration. Capillary trapping can
immobilize a substantial fraction of CO2. This mechanism also acts
immediately and is sustained over long time scales. CO2 trapped this
way may be considered permanently trapped. A fraction of the CO2,
will dissolve into other pore fluids, including hydrocarbons (oil
and gas) or brines. Depending on the fluid composition and reservoir condition, this may occur rapidly (seconds to minutes) or over
a period of tens to hundreds of years. Over very long time scales,

There are many conventional approaches to assessing the

characteristics outlined above. To begin, if a rock unit already traps
hydrocarbons at depth, especially natural gas, then it is highly likely
that it will also trap CO2 (Klusman 2003b). Thickness of a confining
zone can be assessed with conventional well-logging tools and
techniques, and stratigraphic mapping and analysis can be used to
assess likely lateral continuity. In addition, capillary entry pressure
measurements on core samples can quantify the amount of buoyant
force a cap rock lithology can maintain before failure. Ultimately,
characterizations must also rely on estimates of geomechanical,
hydrodynamic, and confining zone integrity for the rock system, fault
system, and well system. The more confining units present, the
greater their thickness and extent, the better engineered the wells,
and the higher the confidence that the reservoir will serve as a good
site for storage.

much of the dissolved CO2 may react with minerals in the rock volume to dissolve or precipitate new carbonate minerals, often
called mineral trapping. Precipitation of carbonate minerals permanently binds CO2 in the subsurface; dissolution of minerals
generally neutralizes carbonic acid species and increases local pH,
buffering the solutions and trapping CO2 as an ionic species (usu-

CCS GUIDELINES

STORAGE

ally bicarbonate) in the pore volume.

86

For a seal to be considered suitable for storage, it must be predictable

and have:
a. Large,laterallycontinuouscoverageovertheproposedinjectionreservoir;
b. Low vertical permeability;
c. High capillary entry pressure;
d. Sufficient thickness to trap the expected volume of CO2;
e. The expectation that faults and fractures, if present, will seal;
f. The ability to prevent vertical migration of injected CO2,
demonstrated through pressure differential, salinity differential,
or a history of trapping oil or gas;
g. Adequate rheological (fluid flow) properties; and
h. Clear indications that any artificial penetrations of the confining
zone will also properly trap CO2.
The confining zone can be enhanced by the presence of a structural
trap. A trap is a geologic formation in a structural or stratigraphic
position that can receive and retain a large volume of CO2 for a
sustained period of time by constraining lateral migration of
injected CO2. Traps can be formed in naturally occurring rock folds
or structures, or they may be naturally created through faulting. Oil,
natural gas, and natural deposits of CO2 are typically found in traps
into which they have migrated and have been stored for millions of
years. Another type of storage opportunity might exist in an area
with a laterally extensive confining zone that is formed according to
the regional dip (angle) of the geologic formation(s).

Conventional data sets and analyses can and do underlie current

site characterizations. Some of these include depth-structure maps,
well-log correlations, well completion records, 2-D and 3-D seismic
volumes, and fault maps. Many of these data sources are interpretations and contain various degrees of certainty. As such, precise
quantitative estimates may be difficult or impossible to provide.
Such precision, however, is not necessary to accurately characterize
site effectiveness. For example, continuity and thickness of cap rock,
presence and properties of multiple confining zones, and structural
closure may be easily defined with limited data and analysis. Other
aspects (e.g., Mohr failure criteria, capillary entry pressure) are
straightforward but require basic analysis (Streit and Hillis 2004).
Some aspects are fairly straightforward but require a degree of
geological sophistication (e.g., fault reactivation potential, fault-seal
analysis, in-situ stress tensor characterization) (Wiprut and Zoback
2002; Gibson-Poole et al. 2005; Friedmann and Nummedal 2003).
Some factors are extremely difficult to define (e.g., well behavior in
50100 years) and cannot be unambiguously circumscribed in any
reasonable operational context. However, relevant data sets can
provide a technical basis for assessing the likely degree of efficacy
and safety, and relevant procedures (e.g., aeromagnetic surveys) can
serve as a component of due diligence in relation to unexpected and
difficult-to-define phenomena.
Again, relevant analogs and empirical characterization can be used
to help determine the effectiveness of the confining zone(s) as
appropriate, until standard measures and best practices are broadly
accepted. For example, if a regionally extensive shale unit is an
effective regional hydrocarbon-confining zone, that information should
positively affect the determination of CO2 storage effectiveness; if the
hydrocarbon is natural gas, the likely effectiveness of the confining
zone is greater (Watts 1987). In some cases, this type of data and
analysis can provide the most important and most accurate information available to characterize likely site effectiveness.

INJECTIVITY

CAPACITY

Injectivity describes the rate of injection that can take place in a

given well and reservoir. As indicated in Table 9, injectivity is
calculated based on a variety of data, including effective thickness
over the injection interval, reservoir permeability, bulk connectivity,
and reservoir pressure. The units of injectivity can vary with the
data source, and include m3/day/Pascal/m and barrels/day/psi/ft.
Much of the data exist for oil and gas fields, but would be available
only on a limited basis for other targets, such as saline formations.
However, conventional wells, geophysical surveys, and core analysis
would be able to provide reasonable estimates of injectivity for a
project. Crucially, the injectivity depends on the interval of reservoir
exposed to the wellbore; thus, injectivity may be increased through
drilling long-reach horizontal wells or increasing well count. If there
is damage to the reservoir at the wellbore that restricts injectivity,
a small hydraulic fracture or acid stimulation may be applied
to correct it.

Storage capacity is measured in units of volume (standard cubic

feet, barrels). Several parameters are used to generate a capacity
estimate, of which pore volume is the most important. Pore volume
is a bulk term based on effective formation thickness and porosity.
Estimates of pore volume can be derived from data generated
through core analysis, wireline logs, or geophysical surveys. In
some cases, 3-D seismic surveys may be combined with well data
to estimate the formation porosity (Saggaf et al. 2003; Bachrach
and Dutta 2004). Often, a hydrodynamic simulation is needed to
estimate overall storage capacity.

The amount of data needed to properly quantify injectivity may vary

by site, but it is highly unlikely that one well and a limited geological or geophysical survey could alone provide enough data to
prove a reservoir has the needed injectivity. In many commercial
applications, the degree of reservoir connectivity is not well
understood for many years. Empirical and theoretical approaches
will be important and can provide additional information and allow
for consideration of multiple scenarios. In many cases, injectivity
data from neighboring oil, gas, and water wells, plus information
from analogous reservoirs, can provide this information.

A second key parameter in capacity estimates is the utilization factor,

or the effective pore volume. This is the fraction of the pore volume
that would actually retain or store injected CO2. Utilization factor is
a function of the fluid already present in the reservoir, and reservoir
heterogeneity at all scales, ranging from pore-throat diameters to
kilometer-scale connectivity, unit architecture, and residual phase (or
capillary) trapping (Juanes et al. 2006; Ide et al. 2007). The utilization
factor is also a function of the development strategy and well
planning, such that capacity can be increased by more wells or better
well design. Utilization factors vary from site to site, and can range
between 5 and 50 percent, although most are less than 25 percent.
An important consideration is that estimates of capacity are
affected by reservoir heterogeneity, which determines the shape of
the CO2 plume. Reservoir pressure constraints also affect the
ultimate capacity of a reservoir.

CCS GUIDELINES

Site characterizations should be used to estimate the volume that

would be stored as a dissolved phase, as a trapped residual phase,
or as a trapped contiguous, buoyant phase (these proportions will
also affect effectiveness or storage integrity). Statements of these
assumptions would allow for easy updating of initial capacity
estimates once new data become available. In practical terms,
analog and empirical data sets should be considered for initial
capacity estimates, but further scientific understanding regarding
trapping mechanism assumptions is needed; this is an important
area for additional research.

STORAGE

Inherent in any discussion regarding capacity are the assumptions

about storage mechanisms. Capacity assessments for saline
formations sometimes assume or calculate a dissolved fraction of
CO2 of 36 percent (Bachu and Adams 2003). In the case of a
structural or stratigraphic closure, a substantial fraction of the pore
volume might be filled with CO2 as a pure phase. Moreover, CO2
buoyancy may make it difficult to store CO2 in a substantial fraction
of the available pore space. Finally, it may be extremely difficult to
predict the amount of residual phase trapping (capillary trapping)
without extensive sampling and analysis, and this is a focus of
research efforts (Holtz and Bryant 2005).

87

Table 9: Examples of Information and Data Sources for Characterization of Storage Sites
Attribute of Formation Key Information

Proof of functional
confining zone(s)

 Presence,

number,
continuity, thickness,
and character of
confining zone
 Fault azimuth and offset
 Surface and formation
well density
 Well construction and
plugging history

Basic Data Sources

 Cores

 Stratigraphic

 Well-logs
 Structure

maps
 In-situ stress
 Well location maps
 Well drilling and
plugging records
 3-D seismic volumes

 Conventional core

Injectivity
 Thickness,

porosity, and
permeability
 Production/flow rate
 Delivery rate connectivity

Capacity
 Accessible

pore-volume
 Lateral extent
 Area of injection
 Trapping mechanism
.

analysis
 Well-logs
 Production

history
or
leak-off tests
 Pressure
 Conventional core
analysis
 Well-logs
 Structure maps
 3-D seismic data
 Injection

Basic Analysis

analysis
 Structural analysis
 Reservoir models
 Simple calculation
 Mohr-Coulomb failure calculation
 Conventional simulation
 Core analysis
 Well location verification
 Well logging-through casing
(e.g., cement bonding logs)
 Stratigraphic analysis
 Population of static geological
models
 Core plug analysis
 Conventional simulation
 Well pump tests/
injection tests
 Stratigraphic analysis
 Structural analysis
 Static geomodels
 Simple calculation
 Conventional simulation
 3-D seismic mapping

Advanced Analysis
 Aeromagnetic

surveys

 Capillary

entry
pressure tests
 Fault segmentation
analysis
 Advanced simulation

 Detailed

stratigraphic
characterization
 Hydro-fracture
analysis
 Special core analysis

 Advanced

simulation
 Fill-spill analysis
 Special core analysis

STORAGE

METHODS FOR ASSESSING RESERVOIR SUITABILITY

Examples of the information and potential data sources used to

assess the three primary attributes of a potential storage formation
(confining zone(s), injectivity, and capacity) are found in Table 9.
This information is typically required by regulators as part of an
injection permit application. It is important to note that some of this
analysis will be conducted after receipt of the appropriate permit,
while the plans for completing the injection well and plan are being
completed. The selection of tools listed in Table 9 will be based on
site-specific geology, as well as operational plans and needs.
APPLICATION OF OIL AND GAS INDUSTRY

CCS GUIDELINES

INSIGHTS AND METHODOLOGIES

88

A considerable amount of understanding of trapping systems,

operating experience, and technology developed by oil and gas
operations is directly applicable to storage site characterization
and selection. Examples of proven natural geologic CO2 traps offer
insights useful to storage projects.
Many of the data, tools, and analytical approaches outlined in
Table 9 are employed by the oil and gas industry, including the sources
of key data and the tools for understanding the subsurface environ-

.
ment. Several
steps involved in site characterization are analogous
to activities used by oil and gas operators during exploration:
 Identifying regional prospective areas or plays based on limited
geological data. This specifically involves identification of major
regional formations that would serve as either good reservoirs or
good confining zones.
 Identifying and selecting specific locations that have the highest
chance of success. This involves finding the optimal combination
of maximal storage capacity and minimal risk.
 Understanding and managing the uncertainty in the geological
structures, strata, data, and conceptual models to provide firm
constraints to engineers and decision makers.
 Providing enough information for development planning, including
operating pressures and well design.
 Ensuring that important nontechnical issues (e.g., land access) do
not prohibit or inhibit work at the site.

As discussed in the Risk Assessment section, other considerations

beyond the effectiveness of the confining zone, injectivity, and estimated
capacity should be used in selecting sites, including:
 Proximity to sensitive populations;
 Ecosystems (including critical habitat for threatened/endangered
species);

Current and projected land use in the nearby area;

Property rights and the number of landowners involved;
 The ease of implementing recovery, mitigation, or remediation
activities if such a need arises (these may be required for financial assessment purposes);
 Demonstration of technical and financial assurance on the part of
the owner/operator or developer; and
 Proximity and vulnerability of underground resources (e.g., underground drinking water, mineral resources).


SITE CHARACTERIZATION
AS AN OPERATIONAL CONCERN
Planning that occurs during the site characterization phase is critical
to operational success. Site characterization is the first step in
planning monitoring networks, locating potential injection projects,
developing operational guidelines, seeking regulatory and public
approval, and obtaining project financing (Cook 2006). It is also
critical to the safe and effective long-term storage of CO2 underground. Proper characterization and planning will reduce costs;
failure to undertake appropriate steps in site characterization could
create operational problems and expose an operator to liability.
Finally, tremendous amounts of information about a site are
gathered during the operational injection phase. Care should be
taken to incorporate this information into the site understanding to
both improve the performance of the site and avoid failures.

These projects have been primarily associated with research and/or

natural gas recovery operations. CCS associated with commercial
power plants could be at significantly larger scales. For example, a
1,000-MW IGCC power plant with 90 percent CO2 capture would

As referenced in the basin-scale discussion, the location of several

storage projects of this scale within a single region could pose
challenges as several projects compete for a finite volume of pore
space. Further, not all storage projects will tie an individual source to
a single injection well. A few sources may share a pipeline to a larger
storage field, or the specific characteristics of the local geology may
require multiple injection wells for one site. For example, three
injection wells are used for the 1 million metric tons per year injected
in BPs In Salah project. Although its easiest to think in terms of one
source and one injection well, this will likely not always be practical.
In the site characterization and selection phase, it is essential that
subsurface reservoir models be developed that accurately model
the injection at the planned scales. This model development will
most likely assist in determining the number of injection and
monitoring wells needed, and is a precursor to finalizing operational
plans. At a regional scale, cooperation and coordination among
projects that use the same basin should be required, and can be
facilitated through requirements for maintaining public databases
that include sufficient data regarding storage projects.

EMERGING TOOLS FOR SCREENING SITES

Several tools can help project developers evaluate potential storage
sites. Typically, these are risk assessment tools that use a decision
tree approach to characterize sites and the factors that may
contribute to leakage or increased susceptibility to impacts from
leakage. The tools assist the user with a methodic analysis of
potential features, processes, events, and receptors of concern.
Such an assessment can be used to determine what measures may
be necessary to prevent or mitigate any identified risks, or even to
make a go/no-go decision about proceeding with a site.

STORAGE

INJECTION SCALE
Successful operational experience with injecting CO2 in the subsurface at rates of ~1 million metric tons of CO2 per year has been
demonstrated through projects like Sleipner (Statoil), Weyburn
(EnCana), and In Salah (BP). The Gorgon project (Chevron) is
currently the largest proposed project, and is near completion at
the rate of ~3 million metric tons per year. The DOE regional
partnerships have also conducted smaller-scale research injections
(thousands of tons), with a validation phase planned for 20082010
during which 500,0001,800,000 tons will be injected at each of
several projects during a 3-year injection period.

produce over 6 million metric tons of CO2 per year. Assuming an

operational lifetime of 60 years, that translates to 320 million
metric tons of CO2. Translated to reservoir barrels, that would be
120,000200,000 barrels per day or 2.84.4 billion barrels over a
60-year operation.

One of the tools to be released is expected to be a site certification

framework tool developed by the CO2 Capture Project, a research
consortium of oil, gas, and electric industry representatives working
in collaboration with federal governments (CCP 2007). Another tool
CCS GUIDELINES

Site characterization and selection

is the most important step in ensuring
the integrity of a storage project.

89

Figure 14: Conceptual Figure of the EPA Vulnerability Evaluation Framework

GEOLOGICAL SEQUESTRATION SYSTEM
AND GEOLOGICAL ATTRIBUTES

POTENTIAL IMPACT CATEGORIES

AND RECEPTORS
Human populations

Lateral extent
Human
health/welfare

Capillary
entry pressure
Permeability

Travel time

CO2 STREAM

CONFINING
SYSTEM

Wells

Faults/fracture zones

SPATIAL AREA
OF EVALUATION

Unanticipated
migration
and leakage
(of CO2 and
other fluids)

Cultural/recreational
resources

Atmosphere

Economic resources

Sensitive species
Ecosystems

Geochemical
processes

Populations covered by
Executive Orders

Legislatively protected
species

Tectonic activity
Water quality

STORAGE

Geomechanical
processes

Groundwater
and
surface water

Physical capacity
INJECTION
ZONE

Injectivity

Regional
groundwater flow
Protected/sensitive
drinking water supplies

Pressure
changes

Geosphere

Geochemical and geomechanical processes

A D A P T E D F R O M U . S . E PA 2 0 0 8 G

CCS GUIDELINES

is a Vulnerability Evaluation Framework (VEF) developed by EPAs

Office of Air and Radiation, and released as a supporting technical
document to the draft UIC geologic sequestration rule (U.S. EPA
2008g). The conceptual VEF is depicted in Figure 14.

90

Finally, CO2-PENS, developed by DOEs Los Alamos National

Laboratory, is a system-level framework and model that can be used
to screen multiple sites and determine the long-term risks
associated with CO2 storage at specific sites (Pawar et al. 2008).

SITE CHARACTERIZATION
AND SELECTIONSUMMARY
In reviewing the framework for detailed site characterization, a few
points stand out:


Site selection will often involve selection from a number of

promising sites. Prospective sites can be ranked according to
key criteria that affect the effectiveness of storage. Such criteria
will be based on the results of early research-oriented projects,
as well as natural analogues where CO2 and/or hydrocarbons

STORAGE GUIDELINE 5: RECOMMENDED GUIDELINES FOR SITE SELECTION AND CHARACTERIZATION

a. General Guidelines for Site Characterization and Selection
1. Potential storage reservoirs should be ranked using a set of criteria developed to
minimize leakage risks. Future work is needed to clarify such ranking criteria.
2. Low-risk sites should be prioritized for early projects.
3. As required by regulation, storage reservoirs should not be freshwater aquifers or
potential underground sources of drinking water.
4. Confining zone(s) should be present that possess characteristics sufficient to prevent
the injected or displaced fluids from migrating to drinking water sources or the surface.
5. Site-specific data should be collected and used to develop a subsurface reservoir model
to predict/simulate the injection over the lifetime of the storage project and the
associated project footprint. These simulations should make predictions that can be
verified by history-matching within a relatively short period of time after initial CO2
injection or upon completion of the first round of wells. The reservoir model and
simulations should be updated periodically as warranted and agreed with regulators.
6. Saline formations and mature oil and gas fields should be considered for initial projects.
Other formations, such as coal seams, may prove viable for subsequent activity with
additional research.
b. Guidelines for Determining Functionality of the Confining Zone(s)
1. Confining zone(s) must be present and must prevent the injected or displaced fluids from
migrating to drinking water sources as well as economic resources (e.g., mineral
resources) or the surface.
2. Operators should identify and map the continuity of the target formation and confining
zone for the project footprint and confirm the integrity of this confining zone(s) with
appropriate tools. Natural and operationally induced fractures (or the likely occurrence
thereof) should be identified.
3. Operators should identify and map auxiliary or secondary confining zones overlying the
primary and secondary target formations, where appropriate.
4. Operators should identify and locate all wells with penetrations of the confining zone
likely performance and integrity based on completion records and visual surveys. These
data should be made publicly available.
5. Operators should identify and map all potentially significant transmissive faults,

STORAGE

within the project footprint. A survey of these wells should be conducted to assess their

especially those that transect the confining zone within the project footprint.
6. Operators should collect in-situ stress information from site wells and other sources to
assess likely fault performance, including stress tensor orientation and magnitude.
c. Guidelines for Determining Injectivity
1. If sufficient data do not already exist, operators should obtain data to estimate injectivity
over the projected project footprint. This may be accomplished with a sustained test
injection or production of site well(s). These wells (which could serve for injection,
monitoring, or characterization) should have the spatial distribution to provide

3. Operators should obtain and organize porosity and permeability measurements from core
samples collected at the site. These data should be made publicly available.
C O N T I N U E S N E X T PA G E

CCS GUIDELINES

reasonable preliminary estimates over the projected project footprint.

2. Water injection tests should be allowed in determining site injectivity.

91

STORAGE GUIDELINE 5: CONTINUED

d. Guidelines for Determining Capacity
1. Operators should estimate or obtain estimates of the projected capacity for storing CO2
with site-specific data (CO2 density at projected reservoir pressure and temperature) for
the project footprint. This should include all target formations of interest, including
primary and secondary targets. Capacity calculations should include estimates of the
net vertical volume effectively utilized or available for storage and an estimate of likely
pore volume fraction to be used (utilization factor).
2. Operators should collect and analyze target formation pore fluids to determine the
projected rate and amount of CO2 stored as a dissolved phase. These data should be
made publicly available as necessary for permitting and compliance purposes.
3. Operators should obtain estimates of phase-relative permeability (CO2 and brine) and the
amount of residual phase trapping. One possible approach is to use core samples with
sufficient spatial density to confirm the existence of the trapping mechanisms throughout
the site and to allow their simulation prior to site development. Estimates should be
updated with site-specific monitoring and modeling results. These data should be made

CCS GUIDELINES

STORAGE

publicly available as necessary for permitting and compliance purposes.

92

have been effectively trapped. Future work will need to address

the specific criteria and methodology for implementation.
 In general, conventionally acquired data appear sufficient.
Absent a specific need, advanced tools or special measurements
should not be required. Rather, well-log data, conventional core
analysis, and basic geological maps serve the primary data needs.
Several commercial projects nationwide and worldwide are
proceeding on this basis. A regulator or financier may request to
see this information.
 There are some common work requirements. All projects
will need a reservoir model that is based on stratigraphic and
structural analysis. The same is true for conventional multiphase-flow simulation. In some cases, 3-D seismic data
acquisition and mapping may provide key information (but should
not be uniformly required).
 The site selection process should strive for accuracy, rather
than precision. This point derives from the goals of initial
characterization, which focus on determining whether a site
appears suitable. Prospective sites may lack data sufficient to
precisely estimate some parameters. However, there is often
enough data to accurately assess site performance. As a
development proceeds, more data will become available to
provide greater precision and accuracy.
 The amount of data needed will vary case by case. The
density of data, the depth of prior operational knowledge, the
number of wells likely to intersect the plume, and the local geology
will all play a role in how much new information will need to be
collected. Operators, regulators, and stakeholders need to
understand this variability and consider regulatory frameworks

flexible enough to encompass many different geological settings

and data sets. For example, before allowing injection, current
regulatory frameworks for injection wells require a certain amount
of information and additional data gathered during drilling.
 Analog data are of value. In many cases, certain kinds of data
or data density may be absent. Where appropriate, existing
information can serve to provide important information about a site.
However, if local data are severely limited or if little is known about
a particular reservoir, new information is likely to be required.

4.3.2.2 Operations
As described earlier, the operational phase of a project overlaps
with activities that take place during site characterization and
selection as well as closure. The primary activities of this phase
include operational planning, site preparation, pre-injection drilling,
well and facility construction, logging and operational data
collection, and injection planning and execution. Many of the stated
operational guidelines may be standard industry practices or
requirements under existing regulatory regimes that should be
applied through best practices and regulations for CCS projects.
OPERATIONAL PLANNING AND MANAGEMENT
Robust operational plans are needed that include integration and
feedback with MMV plans, as well as contingency mitigation/
remediation plans based on the risk assessment. Operational planning
should include establishing the technical plan for construction and
drilling, a management plan, and an implementation plan.

The suitability of a site for storage is a function of three primary technical factors:
the effectiveness of a confining zone in preventing upward migration of CO2;
the injectivity of the storage reservoir;
and the volumetric capacity of the reservoir to hold injected CO2.
Information gained during site characterization, along with the
engineering requirements dictated by the CO2 source, provides a
technical basis for operational planning. These data inform
operational and capital decisions that must be made before
injection can begin. For some CCS projects, particularly in saline
reservoirs, limited information will be available to make these
decisions. Operators should ensure that sufficient flexibility exists
in their plans to adapt to the unexpected and maintain safe and
effective project execution.
One important step prior to commencing CO2 injection is to define
the structure of its implementation through a project management
plan (Melzer et al. 1996b). Defining the team, its structure of
accountability, and clear expectations for each member will help to
ensure that the implementation moves forward smoothly to
operation. Given the anticipated long duration of storage projects,
this plan should be resilient to changes in management and
fluctuations in economics. As a best practice, project operators
should develop a transparent operational plan and implementation
schedule. It is likely such a plan will be required by regulators as
part of the permit application.

build a new plant with 2060 percent capture, but anticipating

additional capture facilities in the future.
Decisions of timing and staging are inherently different for storage
in saline formations and mature oil and gas fields. For oil and gas
fields, enhanced hydrocarbon recovery considerations are likely to
play an enormous role in decision making (Jarrell et al. 2002).
However, the economics of enhanced recovery may drive decisions
that run counter to maximizing CO2 storage. To date, there is little
information and no consensus on how timing and staging of
injection trade off between maximizing recovery and maximizing
storage, and no relevant information as to how early choices in EOR
affect the latter outcome (Kovscek and Cakici 2005).

CCS GUIDELINES

TIMING AND STAGING

Operational decisions will include deciding when to commence
injection, where to inject, and in how many stages or steps.
Operations may be staged in two different ways: starting in one
area of the proposed project and expanding laterally, or starting
with one injection zone and expanding vertically into another
(Masoner and Wackowski 1995; Jarrell et al. 2002). In the near
term, choices about timing and staging of injection will follow new
policies and regulations concerning CO2 emissions as well as
permitting and economic constraints for early projects. For example,
potential operators may choose to vent a fraction of a pure CO2
stream in the near term, with the expectation of increasing the
number of compressors and injection wells as regulatory
constraints on CO2 emissions grow. Similarly, power generators may

STORAGE

The project implementation plan should include the framework for

injection operations, including timing and staging of injection, well
and facility design, plans for establishing the injection pressure and
rate, corrosion prevention procedures, and operational data collection.
Each of these topics is described in detail in subsequent sections.

93

Conventional data sets and analyses

can and do underlie current site characterizations

STORAGE

For saline formations, the inclination may be to deploy enough wells

all at once to handle large volumes of CO2, say on the scale of a
large power plant. The timing may be set by the start-up of generating plants, and the project may require a single stage. There are
two strong disadvantages to such projects: the initial capital outlay
will be the largest in this context, and the risk will be the highest
(Jarrell et al. 2002). To minimize the financial and operational risks,
potential saline formation project operators may want to look for
opportunities to stage injection, possibly in as many as four stages.
Such staging can reduce the financial and operational risks associated with trying to start all at once by allowing for additional
characterization wells and surveys.
Operators will need to work closely with CO2 suppliers to ensure
that drilling and injection schedules meet the needs of generators
and point source suppliers on a technical basis. An important
parameter in proper storage project planning is the CO2 delivery
contract that will include delivery volumes at a given temperature,
pressure, and purity. Potential operators may need to provide
storage for a fixed volume and a fixed rate. To honor the terms of
this contract, operators may require flexible storage options to
handle problems at wells, troubles with injectors, or unforeseen
geological limits on injectivity. They should consider having capacity
to manage potential unanticipated pipeline surges if any could
arise. An alternative would be to seek regulations that would allow
a maximum allowance for venting in the event of equipment failure.

SITE PREPARATION AND WELL CONSTRUCTION

CCS GUIDELINES

WELL AND FACILITY DESIGN

94

Wells and facilities for geological storage should be designed with

the following objectives:
 To ensure operational safety and effectiveness;
 To improve operational performance;
 To optimize well spacing, thereby minimizing capital and
operating costs and environmental impacts; and
 To minimize the size of the CO2 plume (site-specific considerations).
To achieve these goals, many factors will be considered, including
the presence and availability of prior wells, rock properties,
injection rate per well, data gathering needs, composition of new
and prior casing and tubing, well monitoring plans, and number of
likely injection zones. Full-flow reservoir injection simulations will

be needed to compare different drilling configurations, well counts,

and perforation lengths. Injection pressures will be constrained by
the formation parting or fracture pressure. Selective injection
equipment may be necessary to pack (or close) off different
injection zones and limit risk of wellbore failure (Franks 1991). This
equipment is often required by regulators, and operators should
draw on past CO2-EOR experience in well construction design and
material selection (Stone et al. 1989).
PRE-INJECTION DRILLING

Drilling will provide access to the subsurface for data collection,

injection, and monitoring. In some (maybe many) wells, actual
geological conditions could differ from what was predicted. These may
include subtle or substantial differences in injection target thickness,
porosity, permeability, or even presence of the target reservoir. Wells
may also encounter small faults not found during characterization.
Differences between the expected and actual geology are most
probable in saline formation injections without nearby wells or
detailed geophysical surveys. Conventional wireline logs, including
the so-called quad combo (gamma ray, resistivity, bulk density,
and neutron porosity) and well-diameter caliper logs are likely to
be sufficient for lithologic characterization, although some special
well logs (e.g., Formation MicroImager, FMI) may be needed. If there
is no formation parting pressure or stress azimuth information in
areas around planned injection wells, this information should be
gathered and integrated into the project management plan.
Ultimately, representative conventional and sidewall cores of the
cap rock and the reservoir are likely to be needed to reduce
uncertainty. In the case of saline formation projects, these cores
should be described and analyzed to confirm or modify hypotheses
of subsurface lithology and rock property distributions.
Once this information is gathered and analyzed, potential operators
must decide whether the differences between expected and discovered
geology and rock properties merit revision of geological models and
flow simulations. It is very important to modify these models to
incorporate these new data if substantial differences are detected.
WELL CONSTRUCTION

Initial experience suggests that existing tools for well construction

and design are adequate, provided the materials are fit-for-purpose.

In many cases, stakeholders believe that traditional casing material

(steel) and cement (Portland cement) will prove to be sufficient.
Advanced corrosive-resistant cements are under development and
being tested in some research projects. Additional research is being
conducted on the effects of composition, curing, and fluid exposure
on cements (Kutchko et al. 2007; Duguid 2008; Duguid et al. 2006;
Anstice et al. 2005). These may be evaluated as the technology
progresses and when the site-specific conditions suggest it may be
warranted. All wells should be cased and cemented, but there is
considerable discussion regarding whether the cement needs to
extend to the surface. Long stands of cement require staging tools
to relieve column pressures and can create pathways to the surface.
Figure 15 shows the placement of cement and casing in a typical
U.S. UIC Class II (EOR) injection well. In some cases, Class II wells
are constructed using more rigorous standards if the site-specific
conditions warrant. UIC Class I wells are constructed similarly, but
face more rigorous requirements for both construction and testing
than typical Class II wells.

Figure 15: Example of a Class II or EOR Injection Well

EPAs draft UIC regulations for CO2 injection wells (Class VI) outline
performance standards for well construction, and it should be noted
that some state regulations currently require all wells to be
cemented to the surface. Exemptions to this requirement may be
warranted in some geologic settings; however, at a minimum, the
cement should extend from the injection zone to an area above the
confining zone or cap rock that overlies the confining unit. This will
ensure that CO2 cannot move between formations along the well
bore. If a secondary confining unit is present, the cement should
extend above that as well. Exact well designs may vary among
sites, depending on site-specific geologic conditions.
STORAGE

Well integrity, including cement location and performance, should be

tested after construction is complete to ensure the compatibility of the
materials with the subsurface environment. Well design, including the
placement of the casing, has implications on which MMV technologies
may be employed, underscoring the need for integrated planning.
SOURCE: NMOCD

INJECTION GUIDELINES
Once injection is planned and permitted, storage operations must
proceed in a safe and effective way. These operations will be
similar to conventional CO2-EOR operations in many ways,
including the choice of equipment and established occupational
safety requirements.

The appropriate tools and experience in setting the injection

pressure and rate are available from EOR experience and are not
expected to differ substantially from existing UIC regulations for
Class II wells. One important difference is that because the
reservoir is being produced during EOR injections, the pressure

Water injection step tests can be used before injection to determine

the maximum allowable pressure. Sometimes the tests require
some fracturing of the reservoir. However, since this information is
of critical importance to successful geological storage operations,
potential operators should be allowed to conduct water injection
step tests at all prospective sites and permitted wells within the
injection footprint.

CCS GUIDELINES

SETTING INJECTION PRESSURE AND RATE

dissipates. Gaseous CO2 is compressible and changes state

dramatically with small pressure and temperature changes, making
setting the target injection pressures and rates for wells more
complex than for water injection. For supercritical CO2, densities
more closely match typical liquid density.

95

Resolving Differences
Between Predicted and Measured Performance
As discussed in the measurement, monitoring, and verification
(MMV) section, one value of operational data is validating the subsurface model. What happens when the model and data disagree?
The operator must analyze the information and determine whether
a model update is warranted or if a contingency mitigation or remediation measure should be considered.
Following are examples of signals that may warrant an unscheduled model update or consideration of a contingency mitigation:


Higher or lower than predicted reservoir pressure.

Reservoir pressure that approaches the identified limits of the cap rock.

Loss of injectivity.

Injecting CO2 above formation fracture or parting pressure could be

valuable to increasing injectivity or could be needed for achieving
injection rates. While in the near term injecting above formation
fracture or parting pressure is not recommended, a regulatory
framework should not rule out this option in the future because
occasionally injections exceeding these pressure levels may be
needed to regain injectivity and flow of CO2. In such cases, induced
fracture geometries should be controlled so that the confining zone
is never penetrated (Fry et al. 2005). Setting an injection rate is a
complex process that needs to take into account site-specific
characteristics and operational history.

Unexplained movement of the CO2 toward a source of drinking

water or the surface.

MMV data that indicate unexpected change relative to baseline

CO2 measurements (e.g., far-field microseismic events).

Dramatically different plume geometry and extent of migration

rate compared to predicted.

A key challenge in developing Guidelines for CO2 capture and storage is characterizing uncertainty (or the level of confidence in
predictions), identifying how to monitor for this uncertainty, and
outlining the management options an operator has in addressing
the unexpected. In the context of the environmental impact statement for Chevrons Gorgon project in Australia, a methodology for

CCS GUIDELINES

STORAGE

identifying signposts was developed, which merits consideration

96

DEHYDRATION AND CORROSION CONTROL

for future projects. Signposts are metrics that specify which meas-

Corrosion control helps ensure site performance and effective

storage, reduces unanticipated shutdowns that could lead to
venting, and reduces operational expense. CO2 will dissolve quickly
in water to form carbonic acid, which is corrosive for most carbon
steels. Although some CO2 EOR projects have shown little corrosion
(Pittaway and Rosato 1991), others have exhibited substantial
degradation of tubing or casing (Holm and OBrien 1987). Corrosion
prevention does not require expensive alloys or coatings for
operations, but does require operational diligence and mitigation
(Jarrell et al. 2002).

urements indicate when an unexpected result has occurred. For

Dehydration of the injectate is a critical component of corrosion

management. Water present in the injectate will form carbonic
acid; dehydration removes water from the injectate, reducing the
presence of carbonic acid and, thus, corrosion (Ball and Harrell
1985). Commercial dehydrators are readily procured, but the
equipment must be properly sized to CO2 facilities. Even then, minor
pitting is likely to occur, and regular inspection and periodic
ultrasonic scanning is recommended. Continuous or periodic
introduction of inhibitors has proven useful in many contextsmore

example, to address uncertainty regarding potential failure of the

seal, the stated signpost is seismic and/or borehole monitoring
showing CO2 stratigraphy above the Dupuy (the injection reservoir).
Development of such project-specific signposts can be a useful tool
in communicating the potential impacts of a project and summarizing potential management options (Chevron Australia 2005).

so than plastic coatings, chrome-7 alloys, or batch inhibitors (Jarrell

et al. 2002).
In addition to the engineering solution of dehydrating the CO2
stream, natural factors reduce the potential for carbonic acid
formation. First, the chemical reaction where CO2 is converted to
carbonic acid is limited by kinetics, such that only about 1 percent
of the available CO2 can be converted.3 Also, when dehydrated CO2
is continuously injected, a bubble effect occurs where the nearby
rocks are dewatered, making formation water unavailable for in-situ
carbonic acid formation.

OPERATIONAL LOGGING
AND DATA COLLECTION INFORM OPERATIONS

It is expected that CO2 injection projects will operate for at least

20 years and quite possibly for as long as 60 years. Whether this
takes place in one stage or multiple stages, it is expected that some
injection conditions may change dramatically over the project
lifetime. Previously unidentified reservoir heterogeneities, changes
in porosity and permeability due to precipitation or dissolution of
minerals, or pressure interference between wells could present
conditions that require alternative approaches to reservoir management. New wells may become necessary, old wells may require
workovers or shut-in, and injection patterns may need rebalancing. To
understand these changes, monitoring, data analysis, and reservoir

modeling should occur throughout a projects operation. Many of the

standard tools for operational monitoring are described in the
cross-cutting MMV section, and these tools may include well-head
metering of injection, well-head sensors for pressure and CO2,
injection profiling, reservoir pressure data (down-hole sensors if
possible), step-rate tests, and pattern balancing.
It will be prudent for investigators to optimize operations. Operational data should be used to run new simulations and prepare new
development plans that redress difficulties encountered. This
creates an iterative approach to improving injection operations by
increasing performance and reducing costs.

STORAGE GUIDELINE 6: RECOMMENDED GUIDELINES FOR INJECTION OPERATIONS

a. A field development plan should be generated early on in the permitting phase.
b. Operators should develop transparent operational plans and implementation schedules,
with sufficient flexibility to use operational data and new information resulting from MMV
activities to adapt to unexpected subsurface environments.
c. Operational plans should be based on site characterization information and risk
assessment; they should include contingency mitigation/remediation strategies.
d. Storage operators should plan for compressor and well operations contingencies with a
combination of contractual agreements for upstream management of CO2, backup equipment,
storage space, and, if necessary, permits that allow venting under certain conditions.
e. Wells and facilities should be fit-for-purpose, complying with existing federal and state
regulations for design and construction.
f. The reservoir and risk models should be recalibrated (or history-matched) periodically,
based on operational data and re-run flow simulations. Immediate updates should be made
if significant differences in the expected and discovered geology are found.
above the confining zone.
h. Well integrity, including cement location and performance, should be tested after construction
is complete, and routinely while the well is operational, as required by regulation.

STORAGE

g. The casing cement in the well should extend from the injection zone to at least an area

i. Water injection tests should be allowed at all prospective CCS sites.

j. Injection pressures and rates should be determined by well tests and geomechanical
studies, taking into account both formation fracture pressure and formation parting pressure.
Rules should not establish generally applicable quantitative limits on injection pressure and
rates; rather, site-specific limitations should be established as necessary in permits.
k. Operators should adhere to established workplace CO2 safety standards.
l. Operators should implement corrosion management approaches, such as regularly checking
facilities, wells, and meters for substantial corrosion. Corrosion detected should be inhibited

m.Operational data should be collected and analyzed throughout a projects operation and
integrated into the reservoir model and simulations. The data collected should be used to
history-match the project performance to the simulation predictions.

CCS GUIDELINES

immediately, or damaged facility components should be replaced. Dehydration of the

injectate should be required to prevent corrosion, unless appropriate metallurgy is installed.

97

CCS GUIDELINES

STORAGE

4.3.2.3 Managing the End of a Storage Project:

Site Closure and Post-Closure

98

It is important to set expectations for managing the end of a storage

project that are achievable and meet the likely needs of potential
regulators and public stakeholders, ensuring the likely permanent
storage of the CO2. To this end, successful site closure and postclosure should entail the following:
a. Site closure encompasses both the plugging and the abandonment of each individual well within a project, as well as the
closure of the overall project. The majority of site closure
activities will take place once all injection has ceased.
b. Site closure does not end until post-injection monitoring and
modeling demonstrate with a high degree of confidence that
neither injected nor displaced fluids endanger human health and
the environment, all wells have been plugged and abandoned, and
records have been transferred to a public database.
c. Successful site closure should have the following qualities:
1. There should be no migration or release of CO2 from closed sites
through geological or engineering hazards that could compromise
human health or safety.
2. CO2 retention levels should be high enough to avoid health and
safety impacts and to substantially contribute to atmospheric
stabilization goals.
3. Closure should be accomplished using reasonable, established,
and cost-effective methodologies.
4. Once a site is certified as closed, it should continue to be safe,
effective, and secure.
d. Project operators who have demonstrated non-endangerment
should be released from financial responsibility for further
additional MMV activities. Operators should plug and abandon
any wells used for post-injection monitoring. At this point, the
project can be certified as closed, and project operators should
be released from any financial assurance instruments held for
site closure. In the event that regulators or a separate entity
decide to undertake post-closure monitoring that involves
keeping an existing monitoring well open or drilling new
monitoring wells, project operators should not be responsible for
any such work or associated mitigation or remediation arising
out of the conduct of post-closure MMV.
e. Policymakers should carefully evaluate options for the design and
application of a risk management framework for long-term
stewardship. This will be a topic of future discussions and analysis.

SITE CLOSURE
The primary activities of site closure include plugging and
abandoning individual wells, conducting a final assessment, and, as
needed, reworking all of the wells potentially affected by the
storage project. Regulatory programs governing the construction
and operation of wells require the operator to submit records
describing the wells to be kept in a publicly accessible database.
This section of the Guidelines reiterates the importance of this
reporting, and describes the type of data related to storage project
closure that should be included to facilitate future stewardship.
WELL PLUGGING AND ABANDONMENT

The importance of well plugging and abandonment is underscored

for storage because of three critical factors associated with injected
CO2: (1) CO2 is buoyant; (2) in the presence of water, it can be both
reactive and corrosive; and (3) pressure in the reservoir will increase
during active injection. These factors could lead to degrading the well
components, including casing, cement, and the spaces surrounding
them. The proper plugging and abandonment of wells during site
closure will facilitate the long-term protection of health, safety, and
the environment through retention of CO2 in the subsurface.
All oil, gas, and other UIC wells must undergo plugging and abandonment procedures as specified in existing regulations. For CO2
injection wells or other wells in the project footprint, plugging and
abandonment is the final task to ensure injected CO2 is isolated from
drinking water supplies or the atmosphere, and is central to the task
of proper site closure. Many states and countries have developed
regulations for this practice that govern integrity testing and
placement of cement or mechanical plugs in the well (Figure 17).
These regulations provide a default standard for plugging and
abandonment as minimum standards. However, the unique nature of
CO2 storage places some additional concerns and considerations, as
discussed below.
Materials. As described in the section on well construction,
materials for storage wells should be fit-for-purpose. Portland
cement is the industry standard for plugging of wells. Following the
development of cement compositional standards by the American
Petroleum Institute in 1953, Portland cement has proven
performance under a variety of operating conditions, including acid
gas disposal and CO2-EOR.

Site closure is certified when there has been a demonstration

that the CO2 is properly contained within the confining zone
and will not endanger public health and the environment.

A number of researchers have raised concerns that carbonic acid

formed from CO2 injection could lead to Portland cement corrosion,
potentially compromising the long-term performance of a CO2
storage site (Dow 2007; Gasda et al. 2004). Specifically, exposure
to carbonic acid can cause degradation through the cements loss
of density and/or strength, and increased porosity (IEA GHG R&D
2005; Crow et al. 2008).

The efficacy of Portland cement is an area of active research and

debate within the technical community, and some stakeholders

FINAL WELLBORE ASSESSMENT

Wells are the primary potential leakage pathway for closed storage
projects. The final assessment is intended to ensure that injected
CO2 will not escape through closed wells. It consists of a assembling a comprehensive set of data describing the location, condition,
and plugging procedures for every well that will be potentially
affected by the storage project. Based on an assessment of the

CCS GUIDELINES

There is also field experience in managing corrosion in tubing by

coating it with cement, which has been a standard practice with
CO2-EOR injections (Schremp and Robertson 1975). There is limited
literature regarding potential for corrosion of metal casing or tubing
by CO2, although operational corrosion management is well documented (Larkin 2006;. Newton and McClay 1977). It is not clear if
special alloys or coatings provide any benefit in the field, and
research on post-closure well material performance under realistic
laboratory and/or field settings is recommended.

Procedures. Plugging and abandonment is a well-established

technology with many standard procedures for wells (Williams et al.
2000; Jarrell et al. 2002). Most states have regulations regarding
the length of plug and acceptable procedures. The requirements
regarding these specifications differ, depending on the nature of
the well and the injectate. At present, it appears that standard
approaches and methodologies are likely to prove sufficient for
plugging CO2 injection wells, provided that the materials do not
degrade (see previous section on materials). However, given the
central importance of plugging and abandonment, research should
evaluate the need to develop technical standards for plugging CO2
injection wells and ensuring storage integrity in the future that
differ from current standard practices.

STORAGE

Recent laboratory experiments have confirmed that CO2 does

degrade cements, although comparisons between the laboratory
responses and field data and samples suggest that any risks are
likely manageable (MIT 2007; IEA GHG R&D 2006; Skinner 2003;
Sweatman 2008). Potentially aiding the case for Portland cement,
field studies conducted on core samples for existing well casings
show that cements may become more resistant to corrosion and
leakage with time. The SACROC study of well casing core samples
in wells used for EOR show a mineralization within the cement that
reduces porosity and leads to equilibrium in the reaction between
the cement surface and CO2 infused formation fluid. Recent work at
SACROC supports this, in that there has been no leakage of CO2 into
fresh groundwater within the site (Duncan 2008).

support the use of newer corrosion-resistant materials. The IPCC

Special Report also suggested that, where possible, operators
should consider using cements designed to be resistant to CO2
corrosion (IPCC 2005). However, field trials of special cements
remain inconclusive, and while they do inhibit corrosion, concerns
remain about the strength, bonding, and long-term performance of
these novel materials (Gardner and Carpenter 2008; IEA GHG R&D
2006). On this basis, the stakeholder group generally agreed that it
is premature to set Guidelines for use of novel materials in plugging
wells beyond current regulatory requirements and practice. Rather,
efforts should focus on plugging procedures.

99

data, some wells may need to be further investigated and possibly

reworked. In conducting a final assessment, it is important to
consider the integrity of the whole well, including the annulus,
casing, and wellbore. The methods for testing an engineered
system (well) can be conducted in the subsurface and, to a certain
extent, at the surface.

fluid systems would indicate this is not an observed phenomenon,

old wells can be reasonably assessed through surface surveys that
visually inspect the closure plates and use commercial hand-held
CO2 detectors to find evidence of failure, integrity loss, or material
flux. Soil gas surveys and hand-held CO2 detectors could also be
used to find evidence of failure, integrity loss, or material flux.

SUBSURFACE ASSESSMENTS FOR WELLBORE INTEGRITY

CERTIFICATION OF SITE CLOSURE

Cased-hole logging is used to understand wellbore environmental

performance over long time periods. This approach is widely used
by operators of geological storage industrial analogs, such as oil
wells. Continued improvements in logging technology are being
made, and at some point in the future the CCS community may
select a preferred suite or set of tools. Until such a time, logging
should be used in a final assessment to demonstrate:
a. a high quality of cement bond to casing and formation in the
primary sealing interval, using a cement bond log with no pathways or fractures;
b. limited corrosion of the wellbore casing; and
c. continued conformance to other regulatory requirements.

Site closure is certified when there has been a demonstration that

the CO2 is properly contained within the confining zone and will not
endanger public health and the environment. During the closure
period and depending on the specific characteristics of the storage
reservoir, the pressure of the injected CO2 stabilizes or begins to
dissipate to the point at which it can be demonstrated that the
injected CO2 does not endanger human health and the environment.
Certain MMV activities should be carried out during the closure
period to make this demonstration. These MMV activities may
indicate the need to rework some closed wells or to mitigate the
migration of injected CO2. Once the site is certified for closure by
the applicable regulatory agency, project operators are relieved of
the responsibility for further MMV and any associated mitigation or
remediation arising out of the conduct of post-closure MMV, and
any financial assurance instruments held in place for site closure
are returned or voided.

Several methods, such as cement bond logging, flow-behind casing,

oriented acoustic, and ultrasonic logging, can help to verify that
both casing and cement maintain integrity before plugging.

STORAGE

In addition, several other approaches can be used in the subsurface

to assess integrity. These include pressure tests, radioactive tracer
tests, thermal tests, and mechanical integrity testing.
Until technically based CCS-specific standards are accepted into
practice, regulators should remain flexible regarding the tools needed
to conform to these goals. Regulators should also accommodate
new cost-effective tools as they become available, provided they
meet requirements.

CCS GUIDELINES

SURFACE ASSESSMENT

100

A number of assessments can be conducted at the surface to aid in

a final assessment. Magnetometers can be used to locate the steel
plates and other metal components of old wells. Commonly when
wells are plugged and abandoned, cement plugs are placed at
strategic depths to ensure that hydrocarbons or potential contaminants do not reach the surface (Figure 16), and steel plates are
welded onto the upper casing units. Most wells within the field are
likely to be plugged and abandoned this way, and it may be
impractical, unreasonable, or imprudent to reopen all old wells
within the field for logging.
It is possible that well integrity failures at significant depth could
bring carbonic acid to shallow depths within the well, ultimately
risking corrosion and integrity losses at the surface. While the
considerable experience with plugged wells with either CO2 or H2S

DEMONSTRATION OF NON-ENDANGERMENT

A comprehensive discussion of MMV as integral to all storage

project phases is regarded as a cross-cutting topic. In the closure
phase, the key MMV question is: At what point can it be demonstrated with a high degree of confidence that the injected CO2 does
not endanger human health and the environment? This is a primary
concern of the public and regulators as well as operators.
A fundamental factor in making this demonstration is to show that
there is a reasonably consistent history-match in the magnitudes
and trends of modeled and measured behavior of the injected CO2.
Specific criteria for making this and other key determinations would
include demonstrating the following:
 the estimated magnitude and extent of the project footprint (CO2
plume and area of elevated pressure), based on measurements
and modeling;
 that CO2 movement and pressure changes match model predictions;
 the estimated location of the detectable CO2 plume based on
measurement and modeling (measuring magnitude of saturation
within the plume or mapping the edge of it);
 either (a) no evidence of significant leakage of injected or
displaced fluids into formations outside the confining zone, or (b)
the integrity of the confining zone;

Figure 16: Examples of How Cased and Uncased Wells Are Abandoned
Cased Abandoned Well

Uncased Abandoned Well

SOURCE: IPCC 2005



The following parameters will be useful in most cases and should

be monitored unless site-specific conditions suggests otherwise:
CO2 plume location, injection reservoir pressure, well integrity, and
the geochemistry and pressure of the subsurface in a porous zone
above the primary confining zone. In addition, near-surface
monitoring may be useful as a safeguard in areas with sensitive
populations or ecosystems. The specifications for post-injection
MMV, including the duration and spatial extent, need to be driven
by the characteristics of each site.

Reservoir Pressure. In some cases, reservoir pressure will be

substantively higher at project closure than project inception. In all
cases, unless pore fluids are produced, pressure will be highest at
closure. After injection ceases, the geomechanical risks will
decrease as reservoir pressure dissipates over time. The rate of
dissipation is a function of reservoir heterogeneity, permeability,
and the size of the pressure gradient. For many reservoirs, simple
analytical calculations (like Darcys Law) may provide a reasonable
first-order characterization of how pressure will dissipate, and
simulators can provide accurate and reasonably precise predictions
regarding pressure change through time.
Operators can continue down-hole pressure monitoring with the
existing tools and methods used during the operational phase. Given

CCS GUIDELINES

CO2 Plume Location. Once injection ceases, the area of elevated

pressure and CO2 concentration from injection operations will stabilize
or dissipate. After some finite amount of time, it should be possible to
understand how the reservoir heterogeneity, gravitational forces, and
decline in pressure affect continued migration of the injected CO2. Plume
location is determined through a combination of direct measurement
and the use of flow simulation modeling. The validity of the flow

simulation is demonstrated through history-matching of predicted and

measured plume characteristics. The flow simulation for CO2 migration
is developed during the site characterization process, and is then
updated, calibrated, and validated during active injection and during
post-injection monitoring. The methodology for determining the plume
location will vary based on the geological conditions at the site; differing
combinations of direct measurement and updated simulations will prove
useful based on the MMV collected throughout the project.

STORAGE

that, based on the most recent geologic understanding of the site,

including monitoring data and modeling, the injected or displaced
fluids are not expected to migrate in the future in a manner that
encounters a potential leakage pathway; and
 that wells at the site are not leaking and have maintained integrity.

101

the anticipated pressure stabilization or dissipation after closure,

however, there is no reason to measure pressure for long durations
after injection. The objective of reservoir pressure monitoring is to
match the predicted pressure drop to the observed pressure drop,
or to demonstrate that the pressure behaves as expected and that
the risk of failure has decreased enough for safe closure.

CCS GUIDELINES

STORAGE

Well Integrity. Even after injection ceases and the storage project
enters the closure phase, wells represent the most important hazard
element and well failure represents the largest potential risk. The
potential for well failure will be a function of potential flaws as
well as reservoir pressure and chemistry. As discussed above,
reservoir pressure will drop through time after injection ceases. In
almost all cases, this will reduce the mechanical failure potential
for wells. Pressure monitoring and the mechanical integrity tests
conducted at site closure provide a rigorous basis to assess
mechanical risks. Future research and modeling are warranted to
assist with more confident determination of risk profile through
time. The objective of well integrity monitoring is to prevent
contamination of drinking water supplies and ensure retention of
CO2, or to demonstrate that the risk of well failure has decreased
enough for safe closure.

102

Subsurface Monitoring of a Porous Zone Located Above the

Primary Confining Zone. Monitoring the formation fluid chemistry
and pressure of the deepest porous zone located above the primary
confining zone during the time period where reservoir pressure is
increasing (active injection) is thought to be an effective approach for
early detection of leakage across the primary confining zone. When
such MMV is included in a project plan, these measurements will
contribute to a successful determination of non-endangerment. It is
important to note that depending on local geologic and hydrologic
conditions, this technique will not work in all cases in all areas.
Near-Surface Monitoring and Detection. As discussed above, the
risks associated with pressure and chemistry should generally
decrease with time; therefore, the need for surface monitoring arrays
should decrease as well. However, CO2 that begins migration shortly
after injection may take a substantial period of time to reach the
surface, especially through natural pathways such as faults and
heterogeneous reservoirs. This time to the surface will be a function
of path permeability, path length, and reactivity; lower permeability,
longer paths, and higher reactivity are generally likely to increase the
time needed to reach the surface. The flux of CO2 along tortuous
natural pathways is likely to be small, and significant human health
risks are unlikely. Since these kinds of leaks are most likely to travel
through groundwater systems to the surface, groundwater geochemical monitoring is likely to suffice in detecting any substantial flux.

Influence of Geologic Conditions on Duration and Spatial Extent

of Post-Injection MMV. As discussed in the site characterization
section, all storage reservoirs must have a primary confining zone
that prevents vertical migration of injected CO2. Many storage sites
will also have a primary trap that physically constrains the lateral
migration of injected CO2. In all cases, secondary trapping will begin
to take place through a series of mechanisms, including residual
trapping, dissolution of CO2 into the formation fluid, and mineralization. As these trapping mechanisms take effect, the potential for
injected CO2 to migrate will diminish over time.
Rapid or unexpected post-injection migration is a point of concern.
There are two ways to evaluate its potential. The first is to take
physical measurements that show that the injected CO2 plume has
stopped moving or has stabilized, and that the residual pressure
throughout the reservoir is returning to levels near the original
hydrostatic pressure of the reservoir. In reservoirs with lateral seals,
it could take a relatively short period of time to see stabilization. In
this kind of configuration, a CO2 accumulation will remain intact,
trapped in the reservoir indefinitely. Over the long term, there may
be interest in monitoring the pressure of the reservoir for a finite
duration to determine if leakage is occurring.
In other reservoir configurations with limited or no lateral traps, it
may take longer for the plume to stabilize. In these cases, it may be
acceptable to use a combination of geophysical measurements and
validated model predictions to satisfactorily demonstrate that the
plume will stabilize and does not endanger human health and the
environment. To rely on this approach, the models would need to be
vetted by experts and would need to have been updated, calibrated,
and validated throughout the operational life of a project as well as
during the post-injection monitoring period.
Finally, low-permeability sites may have less injectivity, but may also
have much more residual phase trapping and capillary resistance to
flow. This aspect may ultimately prove to be valuable in assessing
storage resource. It bears repeating that CCS has yet to be deployed
into an active carbon market; as such, decision makers and potential
regulators should refrain from prescriptive solutions without a sound
technical basis.
COMPLETION OF SITE CLOSURE

Once it has been demonstrated that the storage project does not
endanger public health and the environment, the project operator
should qualify for regulatory approval of certification of site closure.
At this point, the project operator should be released from
additional MMV requirements and any associated mitigation or
remediation arising out of the conduct of post-closure MMV, and
any financial assurance instruments for site closure should be
released. This process should formally recognize the appropriate
operation and closure of a site.

STORAGE GUIDELINE 7: RECOMMENDED GUIDELINES FOR SITE CLOSURE

a. Continued monitoring during the closure period should be conducted in a portion of the
wells in order to demonstrate non-endangerment, as described below.
b. For all other wells, early research and experience suggest that conventional materials and
procedures for plugging and abandonment of wells may be sufficient to ensure project
integrity, unless site-specific conditions warrant special materials or procedures. A final
assessment should include a final cement bond log across the primary sealing interval of
all operational wells within the injection footprint prior to plugging, as well as standard
mechanical integrity and pressure testing.
c. Operators should assemble a comprehensive set of data describing the location, condition,
plugging, and abandonment procedures, and any integrity testing results for every well that
will be potentially affected by the storage project.
d. Satisfactory completion of post-injection monitoring requires a demonstration with a high
degree of confidence that the storage project does not endanger human health or the
environment. This includes demonstrating all of the following:
1. the estimated magnitude and extent of the project footprint (CO2 plume and area of
elevated pressure), based on measurements and modeling;
2. that CO2 movement and pressure changes match model predictions;
3. the estimated location of the detectable CO2 plume based on measurement and modeling
(measuring magnitude of saturation within the plume or mapping the edge of it);
4. either (a) no evidence of significant leakage of injected or displaced fluids into
formations outside the confining zone, or (b) the integrity of the confining zone;
5. that, based on the most recent geologic understanding of the site, including monitoring
data and modeling, the injected or displaced fluids are not expected to migrate in the
future in a manner that encounters a potential leakage pathway; and
6. that wells at the site are not leaking and have maintained integrity.
e. Project operators who have demonstrated non-endangerment should be released from
responsibility for any additional post-closure MMV, and should plug and abandon any wells
used for post-injection monitoring. At this point, the project can be certified as closed, and
site closure. In the event that regulators or a separate entity decide to undertake
post-closure monitoring that involves keeping an existing monitoring well open or drilling
new monitoring wells, project operators should not be responsible for any such work or

STORAGE

project operators should be released from any financial assurance instruments held for

associated mitigation or remediation arising out of the conduct of post-closure MMV.

f. If one does not already exist in a jurisdiction, a publicly accessible registry should be
created for well plugging and abandonment data.
g. As a condition of completing site closure, operators should provide data on plugged and
abandoned wells potentially affected by their project to the appropriate well plugging and
abandonment registry. This would include the location and description of all known wells
in the storage project footprint, and the drilling, completion, plugging, and integrity testing
records for all operational wells.
h. The site-specific risk assessment should be updated based on operational data and

CCS GUIDELINES

observations during closure.

103

REGISTRATION AND REPORTING

Because there are always uncertainties in the subsurface, it is

possible that even properly completed, operated, and abandoned
wells could fail at some future date. Wells represent a potential
leakage pathway that could require some degree of mitigation.
Further, as understanding of unexpected events and the performance of wells over long time periods evolves, additional,
possibly CCS-specific, well plugging and abandonment measures
may prove reasonable to implement at wells that were previously
plugged and abandoned.

STORAGE

Currently, most regulations governing the construction, operation,

and closure of wells include requirements for the operator to submit
records for inclusion in publicly accessible databases. To simplify
and expedite any conditional re-examination or re-entry of storage
wells or wells potentially affected by a storage project, operators
should be required to submit site closure information to the
appropriate regulatory agency to complete site closure. This would
include the location and description of all known wells in the project
footprint, and the drilling, completion, plugging, and integrity testing
records for all operational wells. In addition to location, description,
and well records, the registry may also include an estimate of the
plume footprint for a given period of time. This information should be
included in the site closure documentation but should also have been
filed with each well when it was operational.

POST-CLOSURE
Given the expected number and scale of storage sites, as well as
the intended long-term duration of CO2 retention in the subsurface,
additional management of sites certified as closed is/may be
warranted. Therefore, these Guidelines recommend that an entity
be tasked (or created) with oversight that would include such
activities as operating the registries of sites; conducting periodic
MMV; and, if the need arises, conducting routine maintenance at
MMV wells. This effort could be funded by a fee assessed on
sequestered tons or through some other mechanism.

The subject of certification and management of the closed sites has

been a matter of substantial discussion among potential operators,
insurers, regulators, subject experts, and potential legislators (de

Figueiredo 2007; IOGCC 2007). Several goals and concerns are

worth noting, some of which are in apparent conflict:
 One objective is to create the right set of incentives for project
developers to invest in and safely site, construct, operate, and
close storage projects. Conversely, incentives should not make it
more cost-effective for project operators to take undue risks in
these activities or to be negligent. Private companies may be
reluctant to engage in storage operations if required to carry a
financial commitment and liability out into the indefinite future,
which could impede deployment of the technology.
 Second, given the expected volume of CO2 to be sequestered over
time frames that may outlast the lifetimes of the private project
owners, it is important to ensure that institutions are in place to track
closed sites and to attend to concerns, if any, that arise over time. It
is important to ensure that such institutions have adequate funding
to carry out these activities. There is concern that provisions put in
place today would need to withstand changes in government,
technology, and across generations, presenting a number of legal
and ethical challenges.
 Third, despite best efforts and best scientific understanding, some
storage projects may fail, resulting in migration of CO2 and related
damages. Concern about this risk could discourage early projects.
Given the societal benefit of learning more about storage,
innovative risk management solutions may be warranted for these
projects and may include public-private partnerships or other
models for limited transfer of financial responsibility (e.g.,
Price-Anderson, the Asbestos Fund, leaking underground storage
tank funds, and rate-based funds where a small surcharge is added
to either production or sales to offset potential mitigation costs).

STORAGE ENDNOTES
1

Technical potential as defined in the IPCC Third Assessment Report is the

amount by which it is possible to reduce GHG emissions by implementing a
technology or practice that already has been demonstrated (IPCC 2001)

Darcys Law is used to understand fluid flow through a geologic reservoir,

where flow (units of volume over time) is calculated based on permeability,
pressure, and area as well as the viscosity of the fluid.

The actual fraction of CO2 that enters the dissolved phase is a fraction of the
CO2 in contact with water and the limitations of reaction kinetics.

CCS GUIDELINES

STORAGE GUIDELINE 8: RECOMMENDED GUIDELINES FOR POST-CLOSURE

104

a. Certified closed sites should be managed by an entity or entities whose tasks would include
such activities as operating the registries of sites; conducting periodic MMV; and, if the
need arises, conducting routine maintenance at MMV wells at closed sites over time.
b. These entities need to be adequately funded over time to conduct those post-closure
activities for which they are responsible.

SUPPLEMENTARY
INFORMATION

P A R T

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105

GLOSSARY AND ACRONYMS

Note: in drafting this glossary the authors have drawn heavily from
two key resources: (1) Glossary included in EPAs draft UIC Class VI
Rule http://www.epa.gov/safewater/uic/pdfs/prefr_uic_co2rule.pdf
and (2) Schlumbergers online oilfield glossary http://www.glossary.
oilfield.slb.com/default.cfm
2-D, 3-D, and 4-D: two-, three-, and four-dimensional
3-D seismic: Seismic energy is used to determine the composition,
fluid content, extent, and geometry of rocks in the subsurface.
Three-dimensional (3-D) seismic surveys include numerous vertical
and horizontal sampling lines, resulting in enough spatial resolution
to provide detailed information about fault distribution and
subsurface structure characteristics.
4-D seismic: 3-D seismic data acquired over the same area at
different times, allowing for observations in changes in fluid
location and saturation, pressure, and temperature over time. It is
sometimes also referred to as time-lapse seismic.
above-zone monitoring: Monitoring (pressure, temperature, fluid
chemistry, etc.) in the porous zone above the confining zone.
ADM: Archer Daniels Midland Company
AEP: American Electric Power
amines: Chemicals used to separate carbon dioxide from flue gas
in post-combustion capture. The current commercialized technology
involves the use of monoethanolamine.
ANSI: American National Standards Institute
API: American Petroleum Institute
Ar: Argon

CCS GUIDELINES

area of pressure elevation: A zone of elevated pressure created

by the injection of carbon dioxide into the subsurface. For geologic
storage, this refers to the area where there is a pressure differential
sufficient to cause adverse impacts to overlying receptors, such as
the movement of injected or displaced fluids above the confining
zone into an underground source of drinking water.

106

area of review: The region surrounding the geologic storage

project that may be affected by the injection activity. The area of
review is based on computational modeling that accounts for the
physical and chemical properties of all phases of the injected
carbon dioxide stream and includes the area of elevated pressure.
ASME: American Society of Mechanical Engineers
atm: Standard atmosphere. This unit of pressure is defined as being
precisely equal to 101.325 kilopascals.

atmospheric eddy correlation: Measurement of the fluxes within

the atmosphere over time. For carbon dioxide capture and storage,
this type of measurement can be made at the surface to detect
changes in carbon dioxide concentrations.
baseload power plant: A plant that produces electricity at an
essentially constant rate. These plants are operated to maximize
system mechanical and thermal efficiency and minimize system
operating costs. A baseload plant is typically characterized by
relatively high fixed costs and low unit operating costs.
Traditionally, coal and nuclear plants and some high-efficiency
steam electric plants have been considered baseload plants
(Spectra Energy).
basin scale: Over a large area or basin that encompasses a
potential storage reservoir with significant lateral extent. This area
may cross state boundaries.
BACT: Best available control technology. An emissions limitation
(including a visible emissions standard) based on the maximum
degree of reduction for each regulated pollutant that would be
emitted from a source when considering energy, environmental, and
economic impacts and other costs. The reductions must be
achievable with available methods, systems, and techniques for
controlling a given pollutant.
Barrel-mile: One barrel, transported one mile, equals one
barrel-mile, normally measured in billion barrel-miles. There are 42
gallons in a barrel (Association of Oil Pipe Lines).
BAU: Business as usual
BLM: Bureau of Land Management. A bureau within the U.S.
Department of the Interior, BLM is responsible for carrying out a
variety of programs for the management and conservation of
resources on 258 million surface acres, as well as 700 million acres
of subsurface mineral estate. These public lands make up about 13
percent of the total land surface of the United States and more than
40 percent of all land managed by the federal government.
block valves: Valves used to isolate sections of pipe in the event
of a leak or for maintenance. Block valves are typically spaced every
1632 kilometers (1020 miles), depending on site-specific
conditions, and are often installed more frequently near critical
locations, such as road and river crossings and urban areas.
BP: British Petroleum.
bpd: Barrels per day
Bragg fiber-optic grating: A short segment of optical fiber that
reflects particular wavelengths. It can be used as an optical filter
and is relevant to carbon dioxide capture and storage in the context
of distributed temperature sensing in the well bore.

cap rock: A geologic formation stratigraphically overlying the

injection zone that acts as a barrier to fluid movement (synonyms:
confining zone, seal).

demonstration that the CO2 is properly contained within the

confining zone and will not endanger public health, the environment,
or natural resources.

capacity: Estimate of the pore volume that is expected to be

available to store carbon dioxide over the project lifetime. Capacity
estimates should be specific to the target injection zone at the
proposed project site.

CFB boiler: Circulating fluidized bed. CFB boilers use coal in

3/8-inch pieces (rather than pulverized) mixed with limestone and
burn it at lower temperatures (1,5001,650F) compared to
conventional boilers. Air is blown into the boiler to suspend, or
fluidize, the mixture. Criteria pollutant emissions are reduced in CFB
applications because the limestone is to lime in the boiler, which
absorbs sulfur dioxide, and lower combustion temperatures yield
less nitrous oxide emissions (Blankinship 2008).

capillary entry pressure: Capillary forces hold a fluid in a capillary

or a pore space. Capillary entry pressure is dependent on the
properties of the fluid and surface and dimensions of the space.
The capillary pressure curve is important for understanding
saturation distribution in the reservoir and affects fluid flow through
the subsurface.
carbonate: A class of sedimentary rock whose chief mineral
constituents (95 percent or more) are calcite and aragonite (both
CaCO3) and dolomite [CaMg(CO3)2], a mineral that can replace
calcite during the process of dolomitization. Limestone, dolostone
or dolomite, and chalk are carbonate rocks. Although carbonate
rocks can be clastic in origin, they are more commonly formed
through processes of precipitation or the activity of organisms, such
as coral and algae. Carbonate rocks can serve as hydrocarbon
reservoir rocks, particularly if their porosity has been enhanced
through dissolution.
casing: The pipe material placed inside a drilled hole to prevent it
from collapsing. The two types of casing in most injection wells are
surface casing, which is the outermost casing that extends from
the surface to the base of the lowermost underground source of
drinking water, and long-string casing, which extends from the
surface to or through the injection zone.
CCS: Carbon dioxide capture and storage. The process of capturing
carbon dioxide from an emission source, converting it to a
supercritical state, transporting it to an injection site, and injecting
it into deep subsurface rock formations for long-term storage. CCS
is sometimes referred to in the literature as carbon dioxide capture
and sequestration.

CERA: Cambridge Energy Research Associates

certification of site closure: Formal acknowledgment by the
regulatory body that an operator has completed requirements at a
site. Certification of site closure takes place when there has been a

CH4: Methane. A hydrocarbon that is a greenhouse gas with a

global warming potential most recently estimated at 23 times that
of carbon dioxide (based on the IPCC Third Assessment Report). It
is emitted from a variety of both anthropogenic and natural sources.
Anthropogenic sources of methane include fossil fuel production,
animal husbandry, rice cultivation, biomass burning, and waste
management. Natural sources of methane include wetlands, gas
hydrates, permafrost, termites, oceans, freshwater bodies, nonwetland soils, and other sources, such as wildfires.
characterization: Collecting data and building a model that
incorporates the characteristics of the reservoir that are pertinent
to its ability to store carbon dioxide.
chemical absorption: A chemical process whereby molecules from
the flue gas absorb to other molecules to yield pure carbon dioxide.
Class I UIC well: Permitted under the Underground Injection Control
Program, Class I wells inject hazardous and nonhazardous wastes into
deep, isolated rock formations that are thousands of meters below the
lowermost underground source of drinking water. Class I wells are
classified as hazardous, nonhazardous industrial, municipal, or radioactive,
depending on the characteristics of the fluid injected. The construction,
permitting, operating, and monitoring requirements are more stringent
for Class I hazardous wells than for the other types of injection wells.
There are approximately 550 Class I wells in the United States.
Class II UIC well: Permitted under the Underground Injection
Control Program, Class II wells inject fluids associated with oil and
natural gas production. Most of the injected fluid is salt water, which
is brought to the surface in the process of producing oil and gas. In
addition, brine and other fluids (including carbon dioxide) are

CCS GUIDELINES

cement: The material used to support and seal the well casing to
the rock formations exposed in the borehole. A cement plug also
protects the casing from corrosion and prevents movement of
injectate up the borehole. The composition of the cement may vary,
based on the well type and purpose, and may contain latex, mineral
blends, or epoxy.

CFR: Code of Federal Regulations. The codification of the general

and permanent rules published in the Federal Register by the
executive departments and agencies of the U.S. federal government.
The CFR is divided into 50 titles that represent broad areas subject
to federal regulation. Each volume of the CFR is updated once each
calendar year and is issued on a quarterly basis (GPO Access).

107

injected to enhance oil and gas production. There are approximately

144,000 Class II wells in operation in the United States, which
collectively inject over 2 billion gallons of brine every day.
clastic: Sediment consisting of broken fragments derived from
pre-existing rocks and transported elsewhere and redeposited
before forming another rock. Examples of common clastic
sedimentary rocks include siliciclastic rocks, such as conglomerate,
sandstone, siltstone, and shale.
Claus plant or process: A sulfur-recovering unit that uses the Claus
process to remove sulfur from a gas stream. The multistep Claus
process recovers sulfur from gaseous hydrogen sulfide in raw
natural gas or in byproduct gases from industrial processes, such as
those created refining crude oil.
CO: Carbon monoxide
CO+H2: Carbon monoxide plus hydrogen
CO2: carbon dioxide. A naturally occurring gas that is also a
byproduct of the combustion of fossil fuels, biomass, other
industrial processes, and land-use changes. CO2 is the principal
anthropogenic greenhouse gas responsible for global warming. It is
the reference gas against which other greenhouse gases are
measured; therefore, it has a global warming potential of 1.

CCS GUIDELINES

CO2 Capture Project: An international effort funded by eight of the

worlds leading energy companies. Working with governments,
nongovernmental organizations, and other stakeholders, the project
aims to reduce the cost of CO2 capture from combustion sources
and develop methods for safely storing CO2 underground.

108

CO2 enhanced oil recovery: The improved or tertiary recovery of oil

by miscible displacement of oil through injection of carbon dioxide.
CO2-PENS: Developed by the U.S. Department of Energys Los
Alamos National Laboratory, a system-level framework and model
that can be used to screen multiple sites and determine the long-term
risks associated with carbon dioxide storage at specific sites.
CO2 plume: The underground extent, in three dimensions, of the
injected carbon dioxide.
co-constituent: Non-carbon dioxide compounds in the emissions
stack gas or process stream captured for compression and transport
to a geologic storage location.
common carrier pipeline: A pipeline system used by many entities
that must be accessible upon reasonable request. Common carrier
status depends on whether the substance being transported via
pipeline is in or affecting interstate commerce and/or whether
the state law requires that it be a common carrier. Almost all
interstate pipelines are common carriers (Shell Pipeline).
CPM: Computational pipeline monitoring. A software-based
monitoring tool that allows the pipeline dispatcher to respond to a
pipeline operating anomaly that may be indicative of a leak or
release (U.S. EPA 1997).
condemn a right of way: Declare a property convertible to public
use under the right of eminent domain.
confining zone: A geologic formation, group of formations, or part
of a formation stratigraphically overlying the injection zone that acts
as a barrier to fluid movement (synonyms: cap rock, seal).

contingent mitigation: A key component of the operational

planning process that takes account of reasonably foreseeable
events that may prevent completion of normal operations. The
formal plans and procedures for any operation should include normal
operating procedures, contingency plans, and emergency responses.
CoP: Conoco Phillips
core analysis: Laboratory analyses performed on the formation
core samples as part of a site characterization process.
criteria pollutant: The 1970 amendments to the Clean Air Act
required EPA to set National Ambient Air Quality Standards for
certain pollutants known to be hazardous to human health. EPA has
identified and set standards to protect human health and welfare
for six pollutants: ozone, carbon monoxide, total suspended
particulates, sulfur dioxide, lead, and nitrogen oxide. The term,
"criteria pollutants" derives from the requirement that EPA must
describe the characteristics and potential health and welfare
effects of these pollutants. It is on the basis of these criteria that
standards are set or revised.
crust: The thin, outermost shell of the Earth that is typically
346 miles (575 kilometers) thick. The crust overlies the more
dense rock of the mantle, which consists of rocks composed of
minerals like pyroxene and olivine, and the iron and nickel core of
the Earth.
cryogenic separation: Cryogenic separation by distillation or
freezing is a method for post-combustion carbon dioxide capture.
Cullender and Smith: A method used for calculating static
bottom-hole pressure in gas wells.
demonstration: Study of the feasibility of disseminating,
implementing, or applying research and development findings. In
this context, a demonstration project is designed to prove the
feasibility of carbon dioxide capture and storage, which is critical
for the potential deployment of the technology.
deployment: Implementation of a technology to realize its economic
and social benefits following its successful demonstration.

Easement: A legal agreement that allows the pipeline owner to

construct, operate, and maintain a pipeline across the land. An
easement does not grant an unlimited entitlement to use the right
of way; rather, the rights of the easement owner are set out in the
easement agreement.

EHS: Environment, health, and safety

EIA: U.S. Energy Information Administration. An independent
statistical agency within the U.S. Department of Energy.
EJ: Exajoule. A unit of energy. One EJ is equal to 1018 Joules.
eminent domain: Federal and state governments have the
constitutional power to grant public utilities and common carrier
pipelines the power of eminent domain to acquire land for public
purposes.
EOR: Enhanced oil recovery. Also referred to as tertiary recovery,
the third stage of oil (or other hydrocarbon) production, during which
sophisticated techniques that alter the original properties of the oil
are used. EORs purpose is not only to restore formation pressure,
but also to improve oil displacement or fluid flow in the reservoir.
EOR can begin after a secondary recovery process or at any time
during the productive life of an oil reservoir. The three major types
of EOR operations are chemical flooding (alkaline flooding or
miscellar-polymer flooding), miscible displacement (carbon dioxide
injection or hydrocarbon injection), and thermal recovery (steamflood or in-situ combustion).
EPPA: Emissions Predictions and Policy Analysis. A global, applied,
general-equilibrium model of economic growth, international trade,
and greenhouse gas emissions run by the Massachusetts Institute
of Technology Joint Program on the Science and Policy of Global
Climate Change. The model is used to calculate paths of future
greenhouse gas emissions, and to provide economic analysis of
proposed control measures.
EPRI: Electric Power Research Institute
ESP: Electrostatic precipitator. A pollution control device for
removing particulate matter from a waste gas stream in a power
plant or industrial process.
FEP: Features events and processes
FERC: Federal Energy Regulatory Commission. An independent
federal agency that regulates the interstate transmission of
electricity, natural gas, and oil. FERC also reviews proposals to build
liquefied natural gas terminals and interstate natural gas pipelines,
as well as licensing hydropower projects. FERC has regulatory
oversight over the rates and access of interstate natural gas and
oil pipelines, as well as the siting of interstate natural gas pipelines.

CCS GUIDELINES

dry cooling: A method for cooling thermoelectric power plants

whereby air-cooled equipment discharges heat directly to the
atmosphere by heating the air. Dry systems reduce water use at a
plant by eliminating the use of water for steam condensation, but
increase energy consumption compared to wet cooling systems.

ECBM: Enhanced coalbed methane. The process of injecting a gas

(e.g., carbon dioxide) into coal, where it is adsorbed to the coal
surface and methane is released. Methane can be captured and
produced for economic purposes.

109

FGD: Flue gas desulfurization. Also known as a scrubber, an

environmental control technology used for removing sulfur dioxide
from the exhaust flue gas in power plants.
FHWA: Federal Highway Administration. An agency within the U.S.
Department of Transportation.
fill-spill analysis: A method to identify traps or leak points in a
subsurface reservoir.

ft: Feet
FutureGen: Initiative launched by the U.S. Department of Energy
(DOE) in 2003 to build a 275-megawatt integrated gasification
combined-cycle (IGCC) carbon dioxide capture and storage (CCS) plant.
DOE announced a restructuring of the FutureGen approach in January
2008, proposing to use federal funding to demonstrate CCS technology
at multiple commercial-scale IGCC or advanced coal power plants, in
lieu of a single demonstration (U.S. DOE/NETL 2007d).

flange: A connection profile used in pipe work and associated

equipment to provide a means of assembling and disassembling
components. The design and specification of a flange relate to the
size and pressure capacity of the equipment to which it is fitted.

G8: Group of Eight. An exclusive body of the worlds leading seven

industrialized nations (France, Germany, Italy, Japan, United Kingdom,
United States, Canada) and Russia. The members of the G8 set out to
tackle global challenges through discussion and action. Since 1975, the
members of the G8 have been meeting annually to deal with the major
economic and political issues facing their domestic societies and the
international community as a whole (G8 2008).

FLPMA: Federal Land Policy and Management Act. Passed in 1976,

FLPMA provided guidance for multiple-use management of public
lands by the Bureau of Land Management (U.S. DOI/BLM/OS 2001).
FMI: Formation Micro Imager. Developed by Schlumberger, the FMI
records high-resolution microelectrical wellbore data. Microresistivity
data are mapped to produce wellbore images that document bed
boundaries, stratigraphic surfaces, and fractures with resolution
approaching 5 millimeters.
formation fluid: The brine originally trapped in the geologic formation.
CCS GUIDELINES

fracture arresters: Used on the pipelines to control ductile fractures.

fit-for-purpose: Designed to function according to specific

conditions and parameters, fit-for-purpose is not a standard, but
reflects the flexibility in choosing the materials and procedures,
depending on the level of co-constituents in the carbon dioxide
stream. Given the lack of knowledge and uncertainty regarding the
effect of injecting co-constituents in the storage reservoir, this
flexibility is warranted in choosing material or designing regulations.

flange rating: The rating of flange reflects the design pressure a

flange can withstand. There are several standards for pipeline flange
rating. Pipe flanges that are made to standards called out by
ASME/ANSI B16.5 or ASME/ANSI B16.47 are typically made from
forged materials and have machined surfaces (the biggest difference
between 16.5 and 16.47 is in the diameter). They are typically in
pressure classes such as 150, 300, 600, 900, 1500, and 2500 pounds.
These pressure classes have pressure and temperature ratings for
specific materialfor example, a steel 900 steel flange is rated up to
2,200 pounds at temperatures of less than 100F.

110

fracture: A crack within a rock (not related to foliation or cleavage

in metamorphic rock), along which there has been no movement.
Fractures can enhance the permeability of rocks by connecting
pores together. For this reason, fractures are induced mechanically
in some reservoirs to boost hydrocarbon flow.

formation fracture pressure: Pressure level above which the

injectate will initiate a new fracture in intact rock.
formation parting pressure: The pressure level above which the
injectate will propagate, open, or extend a pre-existing flaw in rock
(a fault, fracture, bedding plane, etc.).

GE: General Electric

GEE: General Electric Energy
geologic storage: Also called geologic sequestration, refers to the
indefinite isolation of carbon dioxide in subsurface formations.
Injected carbon dioxide is trapped within the pore space, dissolved
in formation fluids, and (over long time periods) mineralized.
GHG: Greenhouse gas. Gases that absorb infrared radiation in the
atmosphere, including (but not limited to) water vapor, carbon
dioxide, methane, nitrous oxide, hydrochlorofluorocarbons, ozone,
hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride.
Gorgon project: A project undertaken by the Australian
subsidiaries of Chevron, ExxonMobil, and Shell to develop the
greater Gorgon gas fields located in the offshore region of western
Australia. The carbon dioxide produced during the natural gas
processing will be injected into deep formations for geologic
storage (U.S. DOE 2008).
GPS: Global positioning system. A space-based radio-navigation
system that provides reliable positioning, navigation, and timing
services to civilian users on a continuous worldwide basis. For
anyone with a GPS receiver, the system will provide accurate
location and time information in all weather, day and night,
anywhere in the world.

GtCO2: Billion metric tons of carbon dioxide

GW: Gigawatt. One GW is equal to one billion watts.
H2: Hydrogen
H2CO3: Carbonic acid
H2O: A molecule of water.
H2S: Hydrogen sulfide. A colorless gas that is odorless at high
concentrations, but smells like rotten eggs in low concentrations.
Hydrogen sulfide is produced during the decomposition of organic
matter and occurs with hydrocarbons in some areas. H2S is toxic; its
effect depends on duration, frequency, and intensity of exposure
and the susceptibility of the individual.
hazard: Risk assessment terminology that identifies potential
undesirable outcomes that a potential project should consider.
HHV: High heating value. The amount of heat produced by the
complete combustion of a unit quantity of fuel. A high heating value
is obtained when all combustion products are cooled and the water
vapor formed during combustion is condensed.
high-consequence area: As per US DOT Pipeline hazard and
safety regulations 49 CFR 195, 195.450 Definitions (CFRf)High
consequence area means: (1) A commercially navigable waterway,
which means a waterway where a substantial likelihood of
commercial navigation exists; (2) A high population area, which
means an urbanized area, as defined and delineated by the Census
Bureau, that contains 50,000 or more people and has a population
density of at least 1,000 people per square mile; (3) An other
populated area, which means a place, as defined and delineated
by the Census Bureau, that contains a concentrated population,
such as an incorporated or unincorporated city, town, village, or
other designated residential or commercial area; (4) An unusually
sensitive area, as defined in 195.6.
history-match: Calibrate
HRSG: Heat-recovery steam generator. A generator that recovers
heat from a hot gas stream and produces steam that can be used
in a process or to drive a steam turbine. A common application for
an HRSG is in a combined-cycle power station, where hot exhaust
gas from a gas turbine is fed to an HRSG to generate steam, which
in turn drives a steam turbine.

ICA: Interstate Commerce Act. Passed in 1887, the ICA created the

ICC: Interstate Commerce Commission. Created by the Interstate

Commerce Act of 1887, the ICCs objective was to make and enforce
regulations concerning interstate commerce. The agency was
abolished in 1995, and its remaining functions were transferred to
the Surface Transportation Board within the U.S. Department of
Transportation.
IEA: International Energy Agency
IECM: Integrated Environmental Control Model. Developed by
Carnegie Mellon University for the National Energy Technology
Laboratory, the IECM allows systematic analysis of emission control
options for coal-fired power plants employing a variety of
pre-combustion, combustion, and post-combustion control methods
(U.S. DOE/NETL 2008).
IGCC: Integrated gasification combined cycle. Technology that
produces electricity by first gasifying coal to produce syngas (a
mixture of hydrogen and carbon monoxide). After cleanup, the
syngas is burned in a gas turbine that drives a generator. The
turbine exhaust goes to a heat recovery generator to raise steam,
which drives a steam turbine.
in: Inch
In Salah project: Based in Algerias In Salah gas development area,
the In Salah project is a joint venture of British Petroleum, Sontrach,
and Statoil. It involves the development of seven proven gas fields
in the southern Sahara, 1,200 kilometers south of Algiers. Around
1 million metric tons of carbon dioxide is injected into the reservoir
each year for geologic storage (CO2 Capture and Storage).
Injection zone: Target geologic formation where CO2 is injected.
Injectivity: A measure of the ability of the reservoir to store the
injected CO2; injectivity is a function of the reservoirs porosity and
permeability.
IOGCC: Interstate Oil and Gas Compact Commission. A multistate
government agency that promotes the conservation and efficient
recovery of domestic oil and natural gas resources, while protecting
health, safety, and the environment.
IPCC: Intergovernmental Panel on Climate Change. An independent
scientific body tasked with assessing the scientific, technical, and
socioeconomic information relevant for understanding the risk of
human-induced climate change.
kg: Kilogram
km: Kilometer

CCS GUIDELINES

hybrid wet-dry cooling: Systems separately or simultaneously use

wet and dry cooling technologies for either water conservation or
temperature impact abatement purposes associated with
thermoelectric power production.

Interstate Commerce Commission. It was designed to address the

issues of railroad abuse and discrimination.

111

lacustrine: Pertaining to an environment of deposition in lakes, or

an area having lakes. Because deposition of sediment in lakes can
occur slowly and in relatively calm conditions, organic-rich source
rocks can form in lacustrine environments.
LAER: Lowest achievable emission reduction. The level of control
required of a major source of pollution subject to New Source Review
requirements for nonattainment areas. The LAER requirement applies
only to the criteria pollutants for which the region is designated as not
being in attainment with emission standards. LAER employs the most
stringent emissions limitation contained within the implementation
plan of any state for the stationary source category. Facility operators
much meet the LAER, unless they can demonstrate that such
emission limitations are not achievable.
leakage: Significant movement of the carbon dioxide plume outside
the confining zone.
leak-off test: A test to determine the strength or fracture pressure
of the injection reservoir. The results of the leak-off test dictate the
maximum pressure that may be applied to the well. To maintain
safe operations, the maximum operating pressure is usually slightly
below the leak-off test result.
leasehold: The right to hold or use property for a fixed period of
time at a given price, without transfer of ownership, on the basis of
a lease contract.
LHV: Lower heating value. The amount of heat released by
combusting a specified quantity of fuel, assuming that the produced
water remains as a vapor and the heat of the vapor is not recovered.
LIDAR: Light detection and ranging. An optical remote-sensing
system that measures the property of scattered light to collect
topographic data.
lithology: The macroscopic nature of the mineral content, grain
size, texture, and color of rocks.
live and dead loads: Forces exerted on a pipeline. Live loads are
forces that are temporary, of short duration, or movingfor
example snow, wind, earthquake, and traffic movements. Dead
loads are weights of material, equipment, or components that are
relatively constant throughout the structures lifefor example,
load due to settlement.
CCS GUIDELINES

LNG: Liquefied natural gas

112

logging: The measurement versus depth or time, or both, of one or

more physical properties in or around a well. The term is derived
from the word log used in the sense of a record or a note.
low-stress pipelines: The U.S. Department of Transportations
Pipeline and Hazardous Materials Safety Administration defines a

low-stress pipeline as a hazardous liquid pipeline that is operated

in its entirety at a stress level of 20 percent or less of the specified
minimum yield strength of the line pipe (CFRf).
m: Meter
MEA: Monoethanolamine. An organic chemical compound used to
separate CO2 from flue gas in post-combustion capture.
membrane separation: The process for separating carbon dioxide
from the flue gas using membrane/amine hybrids or enzymatic CO2
processes. Permeation of CO2 through polymeric membranes occurs
where a constituent passes through the membrane by diffusion and
sorption by the fluid on the other side of the membrane. The driving
force is achieved either by pressure or by concentration difference
across the membrane.
metal organic frameworks: Crystalline compounds comprised of
metal ions coordinated to organic molecules to form one-, two-, or
three-dimensional porous structures. These frameworks are used
as sorbents for post-combustion carbon dioxide capture.
MGSC: Midwest Geological Sequestration Consortium
microgravity: Small changes in gravity that result from changes or
movement in the subsurface.
microseismic: Microearthquakes triggered by subsurface movements.
MIT: Massachusetts Institute of Technology
MLA: Mineral Leasing Act of 1920, as amended, 30 U.S.C. 181 et
seq. Under the MLA, the Bureau of Land Management grants leases
for development of deposits of coal, phosphate, potash, sodium,
sulfur, and other leasable minerals on public domain lands and on
lands having federal reserved minerals. The MLA establishes
qualifications for mineral lessees, sets out maximum limits on the
number of acres of a particular mineral that can be held by a lessee,
and prohibits alien ownership of leases, except though stock
ownership in a corporation (Feriancek 1999).
mitigation: The effort to reduce loss of life and property by
lessening the impact of accidents or, in this case, potential damage
resulting from carbon dioxide leaks.
mm: Millimeter
MMS: Minerals Management Service. A bureau within the U.S.
Department of the Interior that manages the nations natural gas,
oil, and other mineral resources on the outer continental shelf.
MMS also collects, accounts for, and disburses more than
$8 billion per year in revenues from federal offshore mineral leases
and from onshore mineral leases on federal and Native American
lands (U.S. DOI/MMS).

MMV: Measurement, monitoring, and verification.

NGO: Nongovernmental organization

monitoring wells: Wells that collect data, including reservoir

pressure, temperature, formation fluid chemistry, and other key
reservoir characteristics.

NH3: Ammonia. A pungent, colorless gas formed mainly from

volatilization of decomposing excreta or fertilizers. Ammonia is
found in small quantities in the atmosphere, being produced from
the putrefaction of nitrogenous animal and vegetable matter. Due
to its many uses, ammonia is one of the most highly produced
inorganic chemicals.

MPa: Megapascal. A unit of pressure. One megapascal is equal to

106 Pascals.
MRCSP: Midwestern Regional Carbon Sequestration Partnership
MW: Megawatt. One MW is equal to 1 million watts. The watt is
the International System of Units (SI) standard unit of power
(energy per unit time), the equivalent of one joule per second. Watt
measures the rate of energy use or production.

NIOSH: National Institute for Occupational Safety and Health. A

federal agency within the U.S. Department of Health and Human
Services that conducts research and makes recommendations for
workplace safety. However, only regulations promulgated by the
Occupational Safety and Health Administration have the force of law.

MWh: Megawatt-hour

NO: Nitric oxide

N2: Nitrogen

NO2: Nitrogen dioxide

N2O: Nitrous oxide

NOX: Oxides of nitrogen. The gases consisting of one molecule of

nitrogen and varying numbers of oxygen molecules. Nitrogen oxides
are produced in the emissions of vehicle exhaust and from power
stations. In the atmosphere, nitrogen oxides can contribute to the
formation of photochemical ozone (smog), impair visibility, and have
health consequences; thus, they are considered pollutants.

NA: Not available

NETL: National Energy Technology Laboratory. A national laboratory
owned and operated by the U.S. Department of Energy.
NG: Natural gas

NPDES: National Pollutant Discharge Elimination System. As

authorized by the Clean Water Act, the NPDES permit program
controls water pollution by regulating point sources that discharge
pollutants into U.S. waters.
NSPS: New Source Performance Standards. National standards
that set air pollutant emission limitations for new and modified
sources. Under Section 111 of the Clean Air Act of 1990, the U.S.
Environmental Protection Agency is required to publish and

CCS GUIDELINES

NGCC: Natural gas combined cycle. Generating facilities that use

natural gas as a fuel in a gas turbine. Electricity is produced from
the generator coupled to the gas turbine, and the hot exhaust gas
from the turbine is used to generate steam in a waste hest recovery
unit. The steam is then used to produce more electricity. The output
from both the gas turbine and the steam turbine electrical
generators is combined to produce electricity very efficiently.

113

periodically revise a list of industry categories and to establish

standards of performance reflecting the degree of emission
reduction achievable through application of the best system of
emission reduction. The purpose of the NSPS program is to prevent
deterioration of air quality from the construction of new and
modified sources of pollution and to reduce control costs by building
air pollution controls into the initial design of new builds and major
modifications to existing plants (CFRb).
NSR: New Source Review. A preconstruction permitting program,
established by the U.S. Congress as part of the 1977 Clean Air Act
Amendments, governing new sources and major modifications to
existing sources of pollution. New and modified sources subject to
NSR located in areas in attainment of standards for regulated air
pollutants (such as sulfur dioxide, nitrous oxide, ozone, and
particulate matter) should install best available control technology
(BACT), while new and modified sources located in nonattainment
areas should install lowest achievable emission reduction (LAER)
control technology. Case-by-case determinations of BACT and LAER
emission limitations should be at least as stringent as the New
Source Performance Standard (NSPS) for any source category for
which an NSPS has been set and often are set stricter than the NSPS.
This is particularly true for LAER determinations (U.S. EPA 2008d).

CCS GUIDELINES

NZEC: Near-Zero Emission Coal. The joint UK-China initiative to

address the challenge of increasing energy production from coal in
China and the need to tackle growing carbon dioxide emissions.
Additionally, the UK-China NZEC agreement was signed at the
EU-China Summit under the UKs presidency of the EU in September
2005 as part of the EU-China Partnership on Climate Change. The
agreement has the objective of demonstrating advanced, near-zero
emissions coal technology through carbon dioxide capture and
storage in China and the European Union by 2020.

114

OSHA: Occupational Safety and Health Administration. An agency

within the U.S. Department of Labor charged with developing
and enforcing environmental, health, and safety standards for
workplace safety.
oxy-fuel combustion: Involves pulverized coal, supercritical
pulverized coal, ultra-supercritical pulverized coal, and circulating
fluidized bed combustion in an oxygen-rich environment to
dramatically increase the CO2 concentration of the resulting gases.
After combustion, the flue gas can be captured and compressed,
although it will most likely be cleaned before compression.
P: Pascal. The International System of Units (SI) standard unit for
measuring pressure. The Pascal is a measure of perpendicular force
per unit area.
PAC: Preventive Action Criteria. Criteria developed by the
Subcommittee on Consequence Actions and Protective Assessments
that provide chemical exposure limit values for well over 3,000
chemicals to support emergency response planning applications.
parasitic energy loss: Also referred to as an energy penalty, the
energy used by a control device. Instead of being converted into
electricity or being used to power a process, the energy is used to
reduce the emissions from the facility.
PC: Pulverized coal
PEL: Permissible exposure limit. The Occupational Safety and
Health Administration (OSHA) sets enforceable PELs to protect
workers against the health effects of exposure to hazardous
substances. PELs are regulatory limits on the concentration of a
substance in the air. They may also contain a skin designation.
OSHA PELs are based on an 8-hour time-weighted average
exposure (U.S. DOL/OSHA 2007).

O2: Oxygen

petcoke: Petroleum coke

OPS: Office of Pipeline Safety. The federal safety authority for

ensuring the safe, reliable, and environmentally sound operation of
the U.S. pipeline transportation system. Acting through OPS, the
U.S. Department of Transportations (DOTs) Pipeline and Hazardous
Materials Safety Administration administers the DOTs national
regulatory program to ensure the safe transportation of natural gas,
petroleum, and other hazardous materials by pipeline. OPS develops
regulations and other approaches to risk management to ensure
safety in design, construction, testing, operation, maintenance, and
emergency response of pipeline facilities (U.S. EPA 2008c; CFRe).

PHMSA: Pipeline and Hazardous Materials Safety Administration.

An agency within the U.S. Department of Transportation.

open season: Commercial opportunities for potential users to

compete for and acquire capacity on a proposed or existing pipeline.
Open seasons can influence the ultimate project design.

physical adsorption: Adsorption can be either physical or chemical

in nature. Physical adsorption resembles the condensation of gases
to liquids and depends on the physical, or van der Waals, force of
attraction between the solid adsorbent and the adsorbate molecules.
pipeline metering: Methods and tools for measuring the volume of
liquid in the pipeline necessary for accounting purposes.
plugging and abandonment: To prepare a well to be closed permanently, after injection stops and project operations are complete.
PM: Particulate matter. Very small pieces of solid or liquid matter,
such as particles of soot, dust, fumes, mists, or aerosols. The physical
characteristics of particles, and how they combine with other
particles, are part of the feedback mechanisms of the atmosphere.
point source: The anthropogenic source of emissions that is
located at an identifiable point in space. The term covers stationary
sources, such as sewage treatment plants, power plants, other
industrial establishments, and similar buildings and premises of
small spatial extension.
pore space: A discrete void within a rock that can contain air,
water, hydrocarbons, or other fluids.
portland cement: ASTM (American Society for Testing and
Materials) C150 defines portland cement as hydraulic cement
(cement that not only hardens by reacting with water but also forms
a water-resistant product) produced by pulverizing clinkers consisting
essentially of hydraulic calcium silicates, usually containing one or
more of the forms of calcium sulfate as an inter ground addition
(U.S. DOT/FHWA).
post-combustion capture: The addition of a capture and
compression system on the back end of the power plant to capture
the carbon dioxide from the flue gas and compress it for transport.
post-closure: The period after certification is received, when the
responsibility transfers from the operator to another entity.
ppm: Parts per pillion. The number of parts of a chemical found in
one million parts of a particular gas, liquid, or solid.
PRB: Powder River Basin

pressure wave: Area of elevated pressure that is associated with

the injected carbon dioxide plume.
Price-Anderson Act: Passed in 1957, the Price-Anderson Act
partially indemnifies the nuclear industry against liability claims

primacy under EPA UIC program: Developed by the U.S.

Environmental Protection Agency (EPA), the Underground Injection
Control Program requirements were designed to be adopted by states,
territories, and tribes. These jurisdictions can submit an application
to EPA to obtain primary enforcement responsibility, or primacy, to
oversee the injection activities within their jurisdictions (CFRd).
project footprint: An area potentially impacted by the injection of
carbon dioxide that includes the carbon dioxide plume as well as
the area of elevated pressure.
psi: Pounds per square inch or pound-force per square inch. In the
United States, psi is the primary unit of measure for pressure.
Almost all pressure instruments are specified and display in psi
units. A 1-pound-force applied to an area of 1 square inch, 1 psi
equals 6,894.76 Pascals.
psig: Pound per square inch gauge
pulverized coal power plants: Power plants that generate
electricity by injecting finely-ground coal through burners into a
furnace for combustion. Pulverized coal (PC) power plants are
differentiated by the temperatures and pressures of operation.
Subcritical PC units are the least efficient, and typically operate at
about 1,000F) and 2,400 pounds per square inch (psi). Supercritical
PC units are the next most efficient, and operate at around 1,050F
and 3,500 psi. Ultra-supercritical PC units are the most efficient, and
operate above 1,200F and 5,000 psi. The majority of existing PC units
in the United States are subcritical. Ultra-supercritical units require
advance materials and have been successfully constructed and
operated in Europe and Japan.
R&D: Research and development
radioactive tracer test: Generally used in injection wells to avoid
radioactive contamination at the surface. The main applications of
radioactive tracers include establishing flow profiles in injection
wells, detecting fluid movements behind the pipe, and locating
leaking packers and fluid movement between wells.
RCRA: Resource Conservation and Recovery Act. The public law
that creates the framework for the proper management of
hazardous and nonhazardous solid waste.
receptor: A receptor is sensitive to the risks of potential release of
carbon dioxide. For the purposes of risk assessment, a priority is to
evaluate whether migration of the CO2 from the confining unit(s)

CCS GUIDELINES

pre-combustion capture: Associated with integrated gasification

combined cycle, pre-combustion capture involves the capture of
carbon dioxide after the coal is converted into syngas but before
combustion of the syngas.

arising from nuclear incidents, while still ensuring compensation

coverage for the general public. The Act establishes a no-fault
insurance-type system in which the first $10 billion is funded by
industry, and any claims above $10 billion are covered by the federal
government (U.S. DOE 2008b).

115

could have undesirable impacts on a variety of potential receptors.

For example, while still in the subsurface, CO2 could affect sources
of drinking water or diminish the value of mineral rights. If leaked
to the surface, CO2 could collect and harm humans, animals, and
plants, cause property damage, and diminish the climate benefits
of storage.
Regional Carbon Sequestration Partnerships: In 2003, DOE
created a network of seven Regional Carbon Sequestration Partnerships
to help develop the technology, infrastructure, and regulations to
implement large-scale carbon dioxide sequestration in different regions
and geologic formations within the United States. The seven
partnerships are: Big Sky Regional Carbon Sequestration Partnership,
Plains CO2 Reduction Partnership, Midwest Geological Sequestration
Consortium, Midwest Regional Carbon Sequestration Partnership,
Southeast Regional Carbon Sequestration Partnership, Southwest
Regional Partnership on Carbon Sequestration, and the West Coast
Regional Carbon Sequestration Partnership (U.S. DOE 2008a).
remediation plan: A corrective action plan that outlines methods for
mitigating potential hazards or undesirable outcomes. Remediation
plans should be based on site-specific risk assessments.
reservoir: A discrete geologic formation, such as the injection
reservoir for storing carbon dioxide.
retrofit: Addition of new technologies or features to an existing
system, such as the addition of carbon dioxide capture technology
to an existing power plant.
rheological properties: Rheology is the study of the deformation
and flow of matter. The rheological properties of a liquid are
dominant features that can be quantified to characterize its
behavior, and the response of a liquid to a forced shearing flow is
the basis for determining its specific rheological properties. General
qualitative terms used to describe these properties are viscoelastic,
Newtonian, non-Newtonian, thixotropic, and dilatant. Quantitative
parameters used are viscosity, elasticity, shear rate, shear strain,
and shear stress.

CCS GUIDELINES

right of way: Usually involves gaining access to a portion of the

shoulder of a road, or obtaining an easement on private property.
The pipeline right of way consists of a parcel of land under which
the pipeline is buried. Right of way is often about 15 meters (50
feet) wide.

116

risk assessment: A scientifically based process comprising four

steps: hazard identification, hazard characterization, exposure
assessment, and risk characterization.
RST: Reservoir Saturation Tool. A tool used for evaluating fluid
saturation. The traditional methods of evaluating fluid saturation
behind casing are limited to either high-salinity water or nontubing

wells. The RST overcomes these limitations by combining both

thermal decay time and carbon oxygen logging in a tool slim enough
to log through tubing.
rural areas: The Code of Federal Regulations defines rural areas as
areas outside the limits of any incorporated or unincorporated city,
town, village, or any other designated residential or commercial
area, such as a subdivision, a business or shopping center, or
community development. Environmentally sensitive areas are
classified separately (CFRf).
SACROC: Scurry Area Canyon Reef Operators Committee. A
carbonate reef complex in the Permian Basin of west Texas. SACROC
is the oldest carbon dioxide-enhanced oil recovery site in the United
States, with CO2 injection since 1972. For the past 38 years, more
than 55 million tons of CO2 have been injected in SACROC.
SCADA: Supervisory Control and Data Acquisition. SCADA systems
utilize computer technology to continuously gather data (e.g.,
pressure, temperature, and delivery flow rates) from remote
locations on the pipeline. SCADA systems can also provide input
for real-time models of the pipeline operation (U.S. EPA 1997).
SCAPA: Subcommittee on Consequence Actions and Protective
Assessments. Provides the recommendations for emergency
preparedness to assist in safeguarding the health and safety of
workers and the public.
SCPC: Supercritical pulverized coal
selective catalytic reduction: A control technology that injects
ammonia into the exhaust across a catalyst bed, causing a
reduction reaction that destroys nitrogen oxide.
SDWA: Safe Drinking Water Act. Authorizes the U.S. Environmental
Protection Agency (EPA) to set national health-based standards for
drinking water to protect against both naturally occurring and
man-made contaminants that may be found in drinking water. EPA,
states, and water systems then work together to make sure that
these standards are met. The SWDA was originally passed by
Congress in 1974 to protect public health by regulating the nations
public drinking water supply. Amended in 1986 and 1996, the law
requires many actions to protect drinking water and its sources:
rivers, lakes, reservoirs, springs, and groundwater wells. The SDWA
does not regulate private wells that serve fewer than 25 individuals
(U.S. EPA 2008d).
sealing fault: The term fault seal is used to describe the effect
of fault zones on impairing across-fault fluid flow. These dynamic
seals might not be capable of retaining hydrocarbons over a
geological timescale, but their relatively low permeability may
inhibit movement of carbon dioxide.

SECARB: Southeast Regional Carbon Sequestration Partnership.

SPE: Society of Petroleum Engineers

Shale: A fine-grained, fissile, detrital sedimentary rock formed by

consolidation of clay- and silt-sized particles into thin, relatively
impermeable layers. It is the most abundant sedimentary rock. Its
typical fine grain size and lack of permeability, a consequence of
the alignment of its platy or flaky grains, allow shale to form a good
cap rock for hydrocarbon traps.

subsidence: Movement of land downward relative to the surface.

Subsidence of a surface can be induced due to several reasons, such
as dissolution of limestone, mining, faults, extraction of natural gas
and oil, extraction of underground water, and seasonal effects.

SI: International System of Units standard unit

side-scan sonar: A system for acoustic surveying deployed in
marine environments to yield an image of the seafloor and shallow
sediments. The side-scan sonar generates a pulse on the order of
30120 kilohertz that is reflected from the seafloor.
Sleipner project: The Sleipner project has been injecting 1 million
tons of carbon dioxide per year since 1996 without leakage. The
CO2 from a natural gas processing facility is injected into salt water
containing a sand layer called the Utsira formation, which lies 1,000
meters (3,280 feet) below sea bottom (Statoil).
slip-stream capture: The capture of a portion of a process or exhaust
stream instead of the entire stream. Slip-stream capture is particularly useful in demonstration projects where the entire process or
exhaust stream would be too large for the demonstration device to control.
slug flow: A two-phase flow pattern, usually called slug flow, is
encountered when gas and liquid flow simultaneously in a pipe,
over certain ranges of flow rates. Slug flow is characterized by long
Taylor bubbles, also called gas slugs, rising and nearly filling a
pipe cross-section. In a slugging column, with flowing gas and
liquid, the flow field is extremely complex.
SO2: sulfur dioxide
sorbents: Absorbents and adsorbents, referred to as sorbents,
are used in environmental, industrial, agricultural, medical, and
scientific applications to retain liquids and gases. Absorbents
incorporate substances throughout the body of the absorbing
material, while adsorbents gather substances over the surface of
the material (U.S. EPA 2008b).

SOX: Sulfur oxides. A general term used to describe the oxides of

sulfurpungent, colorless gases formed primarily by the combustion
of fossil fuels. Sulfur oxides, which are considered major air pollutants,
may damage the respiratory tract as well as vegetation.

STB: Surface Transportation Board. Created in the Interstate

Commerce Commission Termination Act of 1995, STB is the successor
agency to the Interstate Commerce Commission. STB is decisionally
independent but is administratively affiliated with the U.S.
Department of Transportation. Its primary mission is to resolve railroad
disputes. Pipelines, like railroads, are common carriers used by more
than one company to transport goods. Therefore, the Interstate
Commerce Act also assigned the Interstate Commerce Commission
(and thus the STB) authority over pipelines transporting a commodity
other than water, gas or oil (U.S. DOT/STB).
SWP: Southwest Regional Partnership
TAME: The Midwest Regional Carbon Sequestration Partnership is
conducting a field test that would permanently store carbon dioxide
deep below the ground underneath the recently completed The
Andersons Marathon Ethanol LLC, or TAME, ethanol plant near
Greenville, Ohio (MRCSP 2008).
target formation: A geologic storage formation for CO2 injection.
Suitable target formations must have sufficient porosity for storage
capacity and sufficient permeability to allow injection of the
captured CO2. Typical target formations can be clastic sedimentary
rocks, such as sandstones or conglomerates, or carbonates, such
as limestones or dolostones. Under the right circumstances, other
kinds of formations might serve as storage reservoirs, such as
unminable coal seams, basalts, and evacuated salt caverns.
TBD: To be determined
TEEL: Temporary emergency exposure limit. The chemical exposure
limit value, used for Protective Action Criteria for emergency
planning of chemical release events (SCAPA 2008).
thermocouples: A thermoelectric temperature sensor consisting of
two dissimilar metallic wires, coupled at the probe tip (measurement
junction) and extended to the reference (known temperature)

CCS GUIDELINES

sour gas: A term used for gases that are acidic either alone or when
associated with water. Two sour gases associated with oil and gas
drilling and production are hydrogen sulfide and carbon dioxide.
Sulfur oxides and nitrogen oxides, generated by oxidation of certain
sulfur- or nitrogen-bearing materials, are also in this category, but
are not found in the anaerobic conditions of the subsurface.

supercriticalfluid:Defined as a substance above its critical temperature

and critical pressure. The critical point represents the highest
temperature and pressure at which the substance can exist as a vapor
and liquid in equilibrium. The critical point at which CO2 exists in a
supercritical phase is 1,070 pounds per square inch (73 atmospheres)
and 88 F (31 C). In the supercritical state, CO2 has the characteristics
of both a liquid and a gas, maintaining the compressibility of a gas
and some of the properties of a liquid, such as density.

117

junction. The temperature difference between the probe tip and the
reference junction is detected by measuring the change in voltage
(electromotive force) at the reference junction (efunda).
time-lapse seismic: Seismic data from the surface or a borehole
acquired at different times over the same area to assess changes
in the subsurface with time. Time-lapse seismic data can repeat
2-D, 3-D (yields 4-D seismic data), crosswell, and/or VSP data.
tort liability: A tort is an injury to another person or to property
that is compensable under the law. Negligence, gross negligence,
and intentional wrongdoing are types of tort (NC State).
tortuous: Complex, marked with bends, or not straightforward. In
this context, the tortuous leaks are associated with faults with lower
permeability, longer paths, and higher reactivity, which is likely to
increase the time needed for carbon dioxide to reach the surface in
case of leakage. The flux from tortuous leaks along natural hazards
is likely to be small, and significant human health risks are unlikely.
Since these kinds of leaks are most likely to travel through
groundwater systems to the surface, groundwater geochemical
monitoring is likely to suffice in detecting any substantial flux.
transmissive fault: A fault or fracture with sufficient permeability
and vertical extent to allow rapid migration of large volumes and
prompt movement of fluids between formations.
trapping mechanisms: Mechanisms by which carbon dioxide is
stored in the geologic formations, including physical (pore space
trapping) and chemical (dissolution) processes that take place both
quickly and over long time periods (mineralization).
TWA: Time-weighted average. An average value of exposure over
the course of an 8-hour work shift. The permissible exposure limit
can be defined in two ways: ceiling values and 8-hour TWAs.

CCS GUIDELINES

UIC: Underground Injection Control. Administered by the U.S.

Environmental Protection Agency (EPA), the UIC Program is
responsible for regulating the construction, operation, permitting,
and closure of injection wells that place fluids underground for
storage or disposal. EPAs regulations group injection wells into six
groups or classes, including the new Class VI geologic
sequestration class (U.S. EPA 2008c).

118

USCPC: Ultra-supercritical pulverized coal. USCPC units are highly

efficient and require advanced materials. They have been
successfully constructed and operated in Europe and Japan.
U.S DOE: United States Department of Energy. A cabinet-level
department of the U.S. government with an overarching mission of
advancing the national, economic, and energy security of the United
States; promoting scientific and technological innovation in support
of that mission; and ensuring the environmental cleanup of the
national nuclear weapons complex.

U.S. DOI: United States Department of the Interior. A cabinet-level

department of the U.S. government and the principal conservation
agency of the United States. Through its eight bureaus and
agencies, DOI manages 500 million acres of surface land, or about
one-fifth of the land in the United States.
U.S. DOT: United States Department of Transportation. A cabinetlevel department of the U.S. government with a mission to serve the
country by ensuring a fast, safe, efficient, accessible, and convenient
transportation system that meets vital national interests and enhances
the quality of life of U.S. citizens. DOT is comprised of 13 operating
administrations and bureaus, each with its own management and
organizational structure, including the Surface Transport Board and
Pipeline and Hazardous Materials Safety Administration.
U.S. EPA: United States Environmental Protection Agency. A federal
agency that leads the environmental science, research, education,
and assessment efforts in the United States.
USDW: Underground source of drinking water. An aquifer or portion
of an aquifer that supplies any public water system; or that contains
a sufficient quantity of groundwater to supply a public water
system, and currently supplies drinking water for human
consumption; or that contains fewer than 10,000 milligrams per liter
of total dissolved solids and is not an exempted aquifer.
vadose zone: The region of aeration above the water table. Water
within this interval, which is moving downward under the influence
of gravity, is called vadose water, or gravitational water.
VEF: Vulnerability Evaluation Tool. Developed by the U.S.
Environmental Protection Agency, an analytical framework that
identifies and offers approaches to evaluate the potential for a
carbon dioxide capture and storage (CCS) project to experience
carbon dioxide leakage and associated impacts. The VEF is focused
on the three main parts of CCS systems: the injection zone, the
confining system, and the CO2 stream.
VSP: Vertical seismic profiling. A technique of seismic measurements
used for correlation with surface seismic data. In VSP the energy
source, the detectors, or both, are in a borehole. Hydrophones,
geophones, or accelerometers inside the wellbore record reflected
seismic energy originating from a seismic source at the surface near
the well.
wellbore: The physical hole that makes up the well. It can be
cased, open, or a combination of both.
well integrity: The application of technical, operational and
organizational solutions to reduce the risk of uncontrolled release
of formation fluids throughout the entire life cycle of the well and
of course safety aspects (Petroleum 2004).

wet cooling: A method of cooling thermal power plants using water,

either by once-through cooling systems or recirculating wet systems
Weyburn project: Carbon dioxide injection and storage underground in depleted oil fields is occurring in the Weyburn oil field in
Saskatchewan, Canada. The source of CO2 is a gasification plant in
Bulah, North Dakota (IEA GHG R&D).
wireline log: A method of continuous measurement of formation
properties with electrically powered instruments. The record of
measurements, typically a long strip of paper, is called a log. In
wireline measurements, the logging tool is lowered into the open
wellbore on a multiple-conductor, contra-helically armored wireline.
Once lowered to the bottom of the interval of interest, the logging
tool takes measurements on the way out of the wellbore.

WRI: World Resources Institute

ZENG: Zero Emission Norwegian Gas. A program being co-developed
by Lyse Energi AS, Nebb Engineering AS, Procom Venture AS, and
CO2-Norway. The program is currently undertaking a 7.6 million NOK
Concept Definition study and is working toward an investment
decision for a 5070 megawatt electric demonstration power plant
at Risavika, Norway. The power generation process being developed
will result in zero emission of both carbon dioxide and oxides of
nitrogen. It provides an alternative to conventional gas-fired power
plants with post-combustion CO2 capture. One of the key technologies
being considered in the ZENG Risavika concept is a gas generator
developed by Clean Energy Systems, USA that enables combustion
of natural gas and oxygen to form CO2 and steam.

CCS GUIDELINES
119

APPENDIX A:
EARLY WRI CCS STAKEHOLDER MEETINGS
WRI has conducted a series of discrete workshops to identify and
explore issues related to CCS. These workshops, briefly summarized
in this appendix, helped inform the Guidelines process and are
documented on the WRI Web site (http://www.wri.org/). Meetings
and activities that were part of the Guidelines development
process, beginning in December 2007, are summarized in the
Introduction to this document.

FEBRUARY 2006:
FIRST CCS MEETING
Participants were invited to this kickoff meeting because of their
expertise in the CCS field. During this preliminary workshop,
participants discussed the possibility of working toward Guidelines
for CCS. An end result was the subsequent formation of working
groups in two key areas: measurement, monitoring, and verification
(MMV) and liability. A summary of that first workshop is available at
http://pdf.wri.org/carboncapture_060228_workshopsummary.pdf.

CCS GUIDELINES

FEBRUARY 2006SEPTEMBER 2006:

LIABILITY AND MMV WORKING GROUP MEETINGS
The liability and MMV working groups met periodically by phone
after the initial CCS meeting. During this phase, stakeholders made
hands-on contributions. The liability working group worked to develop
case studies for legal and regulatory analogs. The compilation of that
work is available at http://pdf.wri.org/Full_Case_Studies_Info.pdf.

120

SEPTEMBER 2006:
FIRST CCS LIABILITY WORKSHOP
As a result of this workshop, WRI began work to develop a straw
proposal for CCS liability policy (see http://pdf.wri.org/css_liability_
summary_092906.pdf). At this time, some concern was raised about
the need to include stakeholders who oppose CCS approaches. The
liability working group decided that, to have the technical
discussions needed to arrive at a robust set of Guidelines, the
group would include only representation from stakeholders who
agreed with evaluating CCS as a potential tool for reducing
greenhouse gas emissions.

OCTOBER 2006:
MMV ROLE-PLAY WORKSHOP
Workshop participants simulated a public/regulatory hearing on the
potential siting of a CCS project. The workshop summary and list of
attendees (primarily researchers and industry representatives) are available
at http://pdf.wri.org/ccs_siting_workshop_summary_110806.pdf.

JUNE 2007:
TECHNICAL AND INSURANCE EXPERTS MEETING
WRI convened a group of technical and insurance experts to explore
long-term liability issues related to CCS (http://pdf.wri.org/ccs_liability_
workshop_final_060507.pdf). At this time, the development of the
Guidelines was identified as a separate activity that was part of a
larger WRI stakeholder process.

NOVEMBER 2007:
SECOND CCS LONG-TERM LIABILITY MEETING
Participants recommended that WRI convene small working groups
to follow up on key issues identified during the meeting and share
results of these discussions in a liability paper, working toward
integration with the Guidelines development effort. Future work will
better define the Guidelines for long-term liability (http://pdf.wri.org/
wri_ccs_liability_nov1_workshop.pdf).

APPENDIX B:
GUIDELINES FOR POLICYMAKERS
Capture

Storage

Demonstrations of all capture approaches (pre-combustion,

post-combustion, and oxy-fuel combustion) are urgently
needed on commercial-scale power plants to prove the
technologies. (Capture Guideline 1a)
There should be recognition of the potential challenges in
achieving the theoretical maximum capture potential before the
technologies are proven at scale. This may necessitate
flexibility in establishing appropriate capture rates for early
commercial-scale projects with the amount of CO2 captured at
a facility dependent on both technology performance and the
specific goals of the project. (Capture Guideline 1b)
Standards for the levels of co-constituents have been proposed
by some regulators and legislators; however, there is potential
risk that this could create disincentives for reducing sources of
anthropogenic CO2 if the standard is set too stringently.
Ultimately, the emphasis should be on employing materials,
procedures, and processes that are fit-for-purpose and assessing
the environmental impacts of any co-constituents, along with the
benefits of CO2 emissions reduction as part of a comprehensive
CCS risk assessment. Facility operators, regulators, and other
stakeholders should pay particular attention to potential impacts
of co-constituents in the transport and storage aspects of the
project. (Capture Guideline 1c)
When constructing a new facility or retrofitting an existing
facility in the United States, operators must comply with
requirements under the Clean Air Act and the Clean Water Act,
as appropriate. (Capture Guideline 2a)

Policies should be developed for adequately funding the

post-closure activities that become the responsibility of an
entity assuming responsibility for long-term stewardship, as
described in the Post-Closure section. (Storage Guideline 3c)
Because of the public good benefits of early storage projects
and the potential difficulty of attracting investment,
policymakers should carefully evaluate options for the design
and application of a risk management framework for such
projects. This framework should appropriately balance relevant
policy considerations, including the need for financial
assurances, without imposing excessive barriers to the design
and deployment of CCS technology. (Storage Guideline 3d)
Continued investigation into technical, regulatory, and legal
issues in determining pore space ownership for CCS is
warranted at the state and federal levels. Additional legislation
to provide a clear and reasonably actionable pathway for CCS
demonstration and deployment may be necessary. (Storage
Guideline 4b)
Certified closed sites should be managed by an entity or entities
whose tasks would include such activities as operating the
registries of sites; conducting periodic MMV; and, if the need
arises, conducting routine maintenance at MMV wells at closed
sites over time. (Storage Guideline 8a)
These entities need to be adequately funded over time to
conduct those post-closure activities for which they are
responsible. (Storage Guideline 8b)

Transport


Considering the extent of CO2 pipeline needs for large-scale

CCS, a more efficient means of regulating the siting of
interstate CO2 pipelines should be considered at the federal
level, based on consultation with states, industry, and other
stakeholders. (Transport Guideline 3a)

CCS GUIDELINES

The federal government should consult with industry and states

to evaluate a model for setting rates and access for interstate
CO2 pipelines. Such action would facilitate the growth of an
interstate CO2 pipeline network. (Transport Guideline 4a)

121

APPENDIX C:
GUIDELINES FOR REGULATORS
Capture

Transport

CCS GUIDELINES

122

There should be recognition of the potential challenges in

achieving the theoretical maximum capture potential before the
technologies are proven at scale. This may necessitate
flexibility in establishing appropriate capture rates for early
commercial-scale projects, with the amount of CO2 captured at
a facility dependent on both technology performance and the
specific goals of the project. (Capture Guideline 1b)
Standards for the levels of co-constituents have been proposed
by some regulators and legislators; however, there is potential
risk that this could create disincentives for reducing sources of
anthropogenic CO2 if the standard is set too stringently.
Ultimately, the emphasis should be on employing materials,
procedures, and processes that are fit-for-purpose and assessing
the environmental impacts of any co-constituents, along with
the benefits of CO2 emissions reduction as part of a
comprehensive CCS risk assessment. Facility operators,
regulators, and other stakeholders should pay particular
attention to potential impacts of co-constituents in the transport
and storage aspects of the project. (Capture Guideline 1c)
When constructing a new facility or retrofitting an existing
facility in the United States, operators must comply with
requirements under the Clean Air Act and the Clean Water Act,
as appropriate. (Capture Guideline 2a)
Use of capture technologies could result in hazardous or
industrial waste streams. Operators must follow guidelines and
regulations for the handling and disposal of industrial or
hazardous wastes. (Capture Guideline 2c)
Currently, EPA is considering regulation of coal combustion
wastes that are sent to landfills or surface impoundments, or
used as fill in surface or underground mines. Potential impacts
of the volume and concentrations of hazardous materials in the
waste stream from facilities with CO2 capture should be
evaluated in this context. (Capture Guideline 2e)

CO2 pipeline design specifications should be fit-for-purpose and

consistent with the projected concentrations of co-constituents,
particularly water, hydrogen sulfide (H2S), oxygen, hydrocarbons,
and mercury. (Transport Guideline 1a)
Existing industry experience and regulations for pipeline design
and operation should be applied to future CCS projects.
(Transport Guideline 1b)
Operators should follow the existing OSHA standards for safe
handling of CO2. (Transport Guideline 2a)
Plants operating small in-plant pipelines should consider
adopting OPS regulations as a minimum for best practice.
(Transport Guideline 2b)
Pipelines located in vulnerable areas (populated, ecologically
sensitive, or seismically active areas) require extra due
diligence by operators to ensure safe pipeline operations.
Options for increasing due diligence include decreased spacing
of mainline valves, greater depths of burial, and increased
frequency of pipeline integrity assessments and monitoring for
leaks. (Transport Guideline 2c)
If the pipeline is designed to handle H2S, operators should
adopt appropriate protection for handling and exposure.
(Transport Guideline 2d)
As a broader CO2 pipeline infrastructure develops, regulators
should consider allowing CO2 pipeline developers to take
advantage of current state condemnation statutes and
regulations that will facilitate right-of-way acquisition
negotiations. (Transport Guideline 3b)

Storage


MMV requirements should not prescribe methods or tools;

rather, they should focus on the key information an operator is
required to collect for each injection well and the overall
project, including injected volume; flow rate or injection
pressure; composition of injectate; spatial distribution of the
CO2 plume; reservoir pressure; well integrity; determination of
any measurable leakage; and appropriate data (including
formation fluid chemistry) from the monitoring zone, confining
zone, and USDWs. (Storage Guideline 1a)

MMV plans, although submitted as part of the site permitting

process, should be updated as needed throughout a project as
significant new site-specific operational data become available.
(Storage Guideline 1c)
The monitoring area should be based initially on knowledge of
the regional and site geology, overall site specific risk
assessment, and subsurface flow simulations. This area should
be modified as warranted, based on data obtained during
operations. It should include the project footprint (the CO2
plume and area of significantly elevated pressure, or injected
and displaced fluids). Groundwater quality monitoring should
be performed on a site-specific basis based on injection zone to
USDW disposition. (Storage Guideline 1d)
MMV activities should continue after injection ceases as
necessary to demonstrate non-endangerment, as described in
the post-closure section. (Storage Guideline 1e)
For all storage projects, a risk assessment should be required,
along with the development of a risk management and risk
communication plan. At a minimum, risk assessments should
examine the potential for leakage of injected or displaced fluids
via wells, faults, fractures, and seismic events, and the fluids
potential impacts on the integrity of the confining zone and
endangerment to human health and the environment. (Storage
Guideline 2a)
Risk assessments should address the potential for leakage
during operations as well as over the long term. (Storage
Guideline 2b)

Risk assessments should help identify priority locations and

approaches for enhanced MMV activities. (Storage Guideline 2c)
Risk assessments should provide the basis for mitigation/
remediation plans for response to unexpected events; such
plans should be developed and submitted to the regulator in
support of the proposed MMV plan. (Storage Guideline 2d)
Risk assessments should inform operational decisions, including
setting an appropriate injection pressure that will not compromise
the integrity of the confining zone. (Storage Guideline 2e)

Periodic updates to the risk assessment should be conducted

throughout the project life cycle based on updated MMV data
and revised models and simulations, as well as knowledge
gained from ongoing research and operation of other storage
sites. (Storage Guideline 2f)
Risk assessments should encompass the potential for leakage
of injected or displaced fluids via wells, faults, fractures, and
seismic events, with a focus on potential impacts to the
integrity of the confining zone and endangerment to human
health and the environment. (Storage Guideline 2g)
Risk assessments should include site-specific information such
as the terrain, potential receptors, proximity of USDWs, faults,
and the potential for unidentified borehole locations within the
project footprint. (Storage Guideline 2h)
Risk assessments should include non-spatial elements or
non-geologic factors (such as population, land use, or critical
habitat) that should be considered in evaluating a specific site.
(Storage Guideline 2i)
Based on site-specific risk assessment, project operators/
owners should provide an expected value of the estimated
costs of site closure (including well plugging and abandonment,
MMV, and foreseeable mitigation/remediation action) as part of
their permit application. These cost estimates should be
updated as needed prior to undertaking site closure. (Storage
Guideline 3a)
Project operators/owners should demonstrate financial
assurance for all of the activities required for site closure.
(Storage Guideline 3b)
Potential operators should demonstrate control of legal rights
to use the site surface and/or subsurface to conduct injection,
storage, and monitoring over the expected lifetime of the project
within the area of the CO2 plume and (where appropriate) the
entire project footprint. Regulators will also need access for
inspection. (Storage Guideline 4a)
Continued investigation into technical, regulatory, and legal
issues in determining pore space ownership for CCS is
warranted at the state and federal levels. Additional legislation
to provide a clear and reasonably actionable pathway for CCS
demonstration and deployment may be necessary. (Storage
Guideline 4b)
MMV activities may require land access beyond the projected
CO2 plume; therefore, land access and any other property
interest for these activities should be obtained. (Storage
Guideline 4c)

CCS GUIDELINES

Operators should have the flexibility to choose the specific

monitoring techniques and protocols that will be deployed at
each storage site, as long as the methods selected provide data
at resolutions that will meet the stated monitoring requirements.
(Storage Guideline 1b)

123

CCS GUIDELINES

124

Operators should avoid potential areas of subsurface migration

that might lead to claims of trespass and develop contingencies
and mitigation strategies to avoid such actions. (Storage
Guideline 4d)

Potential storage reservoirs should be ranked using a set of

criteria developed to minimize leakage risks. Future work is
needed to clarify such ranking criteria.(Storage Guideline 5a.1)
Low-risk sites should be prioritized for early projects. (Storage
Guideline 5a.2)

As required by regulation, storage reservoirs should not be

freshwater aquifers or potential underground sources of
drinking water. (Storage Guideline 5a.3)
Confining zones must be present that possess characteristics
sufficient to prevent the injected or displaced fluids from
migrating to drinking water sources or the surface. (Storage
Guideline 5a.4)
Site-specific data should be collected and used to develop a
subsurface reservoir model to predict/simulate the injection
over the lifetime of the storage project and the associated
project footprint. These simulations should make predictions
that can be verified by history-matching within a relatively short
period of time after initial CO2 injection or upon completion of
the first round of wells. The reservoir model and simulations
should be updated periodically as warranted and agreed with
regulators. (Storage Guideline 5a.5)
Confining zones must be present and must prevent the injected
or displaced fluids from migrating to drinking water sources as
well as economic resources (e.g., mineral resources) or the
surface. (Storage Guideline 5b.1)
Operators should identify and map the continuity of the target
formation and confining zone for the project footprint, and
confirm the integrity of the confining zone(s) with appropriate
tools. Natural and drilling- or operationally-induced fractures
(or the likely occurrence thereof) should be identified. (Storage
Guideline 5b.2)

Operators should identify and map auxiliary or secondary

confining zones overlying the primary and secondary target
formations, where appropriate. (Storage Guideline 5b.3)
Operators should identify and locate all wells with penetrations
of the confining zone within the project footprint. A survey of
these wells should be conducted to assess their likely
performance and integrity based on completion records and
visual surveys. These data should be made publicly available.
(Storage Guideline 5b.4)

Operators should identify and map all potentially significant

transmissive faults, especially those that transect the confining
zone within the project footprint. (Storage Guideline 5b.5)
Operators should collect in-situ stress information from site
wells and other sources to assess likely fault performance,
including stress tensor orientation and magnitude. (Storage
Guideline 5b.6)
If sufficient data do not already exist, operators should obtain
data to estimate injectivity over the projected project footprint.
This may be accomplished with a sustained test injection or
production of site wells. These wells (which could serve for
injection, monitoring, or characterization) should have the
spatial distribution to provide reasonable preliminary estimates
over the projected project footprint (Storage Guideline 5c.1)
Water injection tests should be allowed in determining site
injectivity. (Storage Guideline 5c.2)
Operators should obtain and organize porosity and permeability
measurements from core samples collected at the site. These
data should be made publicly available. (Storage Guideline 5c.3)
Operators should estimate or obtain estimates of the projected
capacity for storing CO2 with site-specific data (CO2 density at
projected reservoir pressure and temperature) for the project
footprint. This should include all target formations of interest,
including primary and secondary targets. Capacity calculations
should include estimates of the net vertical volume effectively
utilized or available for storage and an estimate of likely pore
volume fraction to be used (utilization factor). (Storage
Guideline 5d.1)
Operators should collect and analyze target formation pore
fluids to determine the projected rate and amount of CO2 stored
as a dissolved phase. These data should be made publicly
available as necessary for permitting and compliance purposes.
(Storage Guideline 5d.2)
Operators should obtain estimates of phase-relative
permeability (CO2 and brine) and the amount of residual phase
trapping. One possible approach is to use core samples with
sufficient spatial density to confirm the existence of the
trapping mechanisms throughout the site and to allow their
simulation prior to site development. Estimates should be
updated with site-specific monitoring and modeling results.
These data should be made publicly available as necessary for
permitting and compliance purposes. (Storage Guideline 5d.3)
A field development plan should be generated early on in the
permitting phase. (Storage Guideline 6a)

significant differences in the expected and discovered geology

are found. (Storage Guideline 6f)


Operational plans should be based on site characterization

information and risk assessment; they should include
contingency mitigation/remediation strategies. (Storage
Guideline 6c)
Storage operators should plan for compressor and well
operations contingencies with a combination of contractual
agreements relating to upstream management of CO2, backup
equipment, storage space, and, if necessary, permits that allow
venting under certain conditions. (Storage Guideline 6d)
Wells and facilities should be fit-for-purpose, complying with
existing federal and state regulations for design and
construction. (Storage Guideline 6e)
The reservoir and risk models should be recalibrated (or
history-matched) periodically, based on operational data and
re-run flow simulations. Immediate updates should be made if

Well integrity, including cement location and performance,

should be tested after construction is complete, and routinely
while the well is operational, as required by regulation.
(Storage Guideline 6h)
Water injection tests should be allowed at all prospective CCS
sites. (Storage Guideline 6i)
Injection pressures and rates should be determined by well
tests and geomechanical studies, taking into account both
formation fracture pressure and formation parting pressure.
Rules should not establish generally applicable quantitative
limits on injection pressure and rates; rather, site-specific
limitations should be established as necessary in permits.
(Storage Guideline 6j)
Operators should adhere to established workplace CO2 safety
standards. (Storage Guideline 6k)
Operators should implement corrosion management approaches,
such as regularly checking facilities, wells and meters for
substantial corrosion. Corrosion detected should be inhibited
immediately, or damaged facility components should be replaced.
Dehydration of the injectate should be required to prevent
corrosion, unless appropriate metallurgy is installed. (Storage
Guideline 6l)
Operational data should be collected and analyzed throughout
a projects operation and integrated into the reservoir model
and simulations. The data collected should be used to
history-match the project performance to the simulation
predictions. (Storage Guideline 6m)
Continued monitoring during the closure period should be
conducted in a portion of the wells in order to demonstrate
non-endangerment, as described below. (Storage Guideline 7a)
For all other wells, early research and experience suggest that
conventional materials and procedures for plugging and
abandonment of wells may be sufficient to ensure project
integrity, unless site-specific conditions warrant special
materials or procedures. A final assessment should include a
final cement bond log across the primary sealing interval of all
operational wells within the injection footprint prior to
plugging, as well as standard mechanical integrity and pressure
testing. (Storage Guideline 7b)

CCS GUIDELINES

Operators should develop transparent operational plans and

implementation schedules with sufficient flexibility to use
operational data and new information resulting from MMV
activities to adapt to unexpected subsurface environments.
(Storage Guideline 6b)

The casing cement in the well should extend from the injection
zone to at least an area above the confining zone. (Storage
Guideline 6g)

125

Operators should assemble a comprehensive set of data

describing the location, condition, plugging, abandonment
procedures, and any integrity testing results for every well that
will be potentially affected by the storage project. (Storage
Guideline 7c)

6. that wells at the site are not leaking and have maintained
integrity.


Satisfactory completion of post-injection monitoring requires a

demonstration with a high degree of confidence that the
storage project does not endanger human health or the
environment. (Storage Guideline 7d) This includes
demonstrating all of the following:
1. the estimated magnitude and extent of the project footprint
(CO2 plume and the area of elevated pressure) based on
measurements and modeling;
2. that CO2 movement and pressure changes match model
predictions;
3. the estimated location of the detectable CO2 plume based on
measurement and modeling (measuring magnitude of
saturation within the plume or mapping the edge of it);

4. either (a) no evidence of significant leakage of injected or

displaced fluids into formations outside the confining zone, or
(b) the integrity of the confining zone;

CCS GUIDELINES

5. that, based on the most recent geologic understanding of

the site, including monitoring data and modeling, the CO2
plume and formation water are not expected to migrate in
the future in a manner that encounters a potential leakage
pathway; and

126

Project operators who have demonstrated non-endangerment

should be released from responsibility for any additional
post-closure MMV, and should plug and abandon any wells
used for post-injection monitoring. At this point, the project can
be certified as closed, and project operators should be released
from any financial assurance instruments held for site closure.
In the event that regulators or a separate entity decide to
undertake post-closure monitoring that involves keeping an
existing monitoring well open or drilling new monitoring wells,
project operators should not be responsible for any such work
or associated mitigation or remediation arising out of the
conduct of post-closure MMV. (Storage Guideline 7e)
If one does not already exist in a jurisdiction, a publicly
accessible registry should be created for well plugging and
abandonment data. (Storage Guideline 7f)
As a condition of completing site closure, operators should
provide data on plugged and abandoned wells potentially
affected by their project to the appropriate well plugging and
abandonment registry. This would include the location and
description of all known wells in the storage project footprint,
and the drilling, completion, plugging, and integrity testing
records for all operational wells. (Storage Guideline 7g)
The site-specific risk assessment should be updated based on
operational data and observations during closure. (Storage
Guideline 7d)

APPENDIX D:
GUIDELINES FOR
PROJECT DEVELOPERS AND OPERATORS
Capture

Transport

There should be recognition of the potential challenges in

achieving the theoretical maximum capture potential before the
technologies are proven at scale. This may necessitate
flexibility in establishing appropriate capture rates for early
commercial-scale projects, with the amount of CO2 captured at
a facility dependent on both technology performance and the
specific goals of the project. (Capture Guideline 1b)
Standards for the levels of co-constituents have been proposed
by some regulators and legislators; however, there is potential
risk that this could create disincentives for reducing sources of
anthropogenic CO2 if the standard is set too stringently.
Ultimately, the emphasis should be on employing materials,
procedures, and processes that are fit-for-purpose and assessing
the environmental impacts of any co-constituents, along with the
benefits of CO2 emissions reduction as part of a comprehensive
CCS risk assessment. Facility operators, regulators, and other
stakeholders should pay particular attention to potential impacts
of co-constituents in the transport and storage aspects of the
project. (Capture Guideline 1c)
When constructing a new facility or retrofitting an existing
facility in the United States, operators must comply with
requirements under the Clean Air Act and the Clean Water Act,
as appropriate. (Capture Guideline 2a)
Options for minimizing local and regional environmental
impacts associated with air emissions, use of water, and solid
waste generation should be evaluated when considering
technologies for capture. (Capture Guideline 2b)
Use of capture technologies could result in hazardous or
industrial waste streams. Operators must follow guidelines and
regulations for the handling and disposal of industrial or
hazardous wastes. (Capture Guideline 2c)

CO2 pipeline design specifications should be fit-for-purpose and

consistent with the projected concentrations of co-constituents,
particularly water, H2S, oxygen, hydrocarbons, and mercury.
(Transport Guideline 1a)
Existing industry experience and regulations for pipeline design
and operation should be applied to future CCS projects.
(Transport Guideline 1b)
Operators should follow the existing OSHA standards for safe
handling of CO2. (Transport Guideline 2a)
Plants operating small in-plant pipelines should consider
adopting OPS regulations as a minimum for best practice.
(Transport Guideline 2b)
Pipelines located in vulnerable areas (populated, ecologically
sensitive, or seismically active areas) require extra due diligence
by operators to ensure safe pipeline operations. Options for
increasing due diligence include decreased spacing of mainline
valves, greater depths of burial, and increased frequency of
pipeline integrity assessments and monitoring for leaks.
(Transport Guideline 2c)
If the pipeline is designed to handle H2S, operators should
adopt appropriate protection for handling and exposure.
(Transport Guideline 2d)

Storage


Operators should investigate the use of combustion wastes as

beneficial byproducts. (Capture Guideline 2d)

Operators should have the flexibility to choose the specific

monitoring techniques and protocols that will be deployed at
each storage site, as long as the methods selected provide data
at resolutions that will meet the stated monitoring requirements.
(Storage Guideline 1b)

CCS GUIDELINES

MMV requirements should not prescribe methods or tools;

rather, they should focus on the key information an operator is
required to collect for each injection well and the overall
project, including injected volume; flow rate or injection
pressure; composition of injectate; spatial distribution of the
CO2 plume; reservoir pressure; well integrity; determination of
any material leakage; and appropriate data (including formation
fluid chemistry) from the monitoring zone, confining zone, and
USDWs. (Storage Guideline 1a)

127

CCS GUIDELINES

128

MMV plans, although submitted as part of the site permitting

process, should be updated as needed throughout a project as
significant new site-specific operational data become available.
(Storage Guideline 1c)
The monitoring area should be based initially on knowledge of
the regional and site geology, overall site specific risk
assessment, and subsurface flow simulations. This area should
be modified as warranted, based on data obtained during
operations. It should include the project footprint (the CO2
plume and area of significantly elevated pressure, or injected
and displaced fluids). Groundwater quality monitoring should
be performed on a site-specific basis based on injection zone to
USDW disposition. (Storage Guideline 1d)
MMV activities should continue after injection ceases as
necessary to demonstrate non-endangerment, as described in
the post-closure section. (Storage Guideline 1e)
For all storage projects, a risk assessment should be required,
along with the development and implementation of a risk
management and risk communication plan. At a minimum, risk
assessments should examine the potential for leakage of
injected or displaced fluids via wells, faults, fractures, and
seismic events, and the fluids potential impacts on the integrity
of the confining zone and endangerment to human health and
the environment. (Storage Guideline 2a)

Risk assessments should address the potential for leakage

during operations as well as over the long term. (Storage
Guideline 2b)
Risk assessments should help identify priority locations and
approaches for enhanced MMV activities. (Storage Guideline 2c)

Risk assessments should provide the basis for mitigation/

remediation plans for response to unexpected events; such
plans should be developed and submitted to the regulator in
support of the proposed MMV plan. (Storage Guideline 2d)
Risk assessments should inform operational decisions,
including setting an appropriate injection pressure that will not
compromise the integrity of the confining zone. (Storage
Guideline 2e)
Periodic updates to the risk assessment should be conducted
throughout the project life cycle based on updated MMV data
and revised models and simulations, as well as knowledge
gained from ongoing research and operation of other storage
sites. (Storage Guideline 2f)

Risk assessments should encompass the potential for leakage

of injected or displaced fluids via wells, faults, fractures, and
seismic events, with a focus on potential impacts to the
integrity of the confining zone and endangerment to human
health and the environment. (Storage Guideline 2g)
Risk assessments should include site-specific information, such
as the terrain, potential receptors, proximity of USDWs, faults,
and the potential for unidentified borehole locations within the
project footprint. (Storage Guideline 2h)
Risk assessments should include non-spatial elements or
non-geologic factors (such as population, land use, or critical
habitat) that should be considered in evaluating a specific site.
(Storage Guideline 2i)
Based on site-specific risk assessment, project operators/
owners should provide an expected value of the estimated costs
of site closure (including well plugging and abandonment, MMV,
and foreseeable mitigation/remediation action) as part of their
permit application. These cost estimates should be updated prior
to undertaking site closure. (Storage Guideline 3a)
Project operators/owners should demonstrate financial
assurance for all of the activities required for site closure.
(Storage Guideline 3b)
Potential operators should demonstrate control of legal rights
to use the site surface and/or subsurface to conduct injection
and monitoring over the expected lifetime of the project within
the area of the CO2 plume and (where appropriate) the entire
project footprint. Regulators will also need access for
inspection. (Storage Guideline 4a)
Continued investigation into technical, regulatory, and legal
issues in determining pore space ownership for CCS is
warranted at the state and federal levels. Additional legislation
to provide a clear and reasonably actionable pathway for CCS
demonstration and deployment may be necessary. (Storage
Guideline 4b)
MMV activities may require land access beyond the projected
CO2 plume; therefore, land access and any other property
interest for these activities should be obtained. (Storage
Guideline 4c)
Operators should avoid potential areas of subsurface migration
that might lead to claims of trespass and develop contingencies
and mitigation strategies to avoid such actions. (Storage
Guideline 4d)

Low-risk sites should be prioritized for early projects. (Storage

Guideline 5a.2)
As required by regulation, storage reservoirs should not be
freshwater aquifers or potential underground sources of
drinking water. (Storage Guideline 5a.3)

Confining zones must be present that possess characteristics

sufficient to prevent the injected or displaced fluids from
migrating to drinking water sources or the surface. (Storage
Guideline 5a.4)
Site-specific data should be collected and used to develop a
subsurface reservoir model to predict/simulate the injection
over the lifetime of the storage project and the associated
project footprint. These simulations should make predictions
that can be verified by history-matching within a relatively short
period of time after initial CO2 injection or upon completion of
the first round of wells. The reservoir model and simulations
should be updated periodically as warranted and agreed with
regulators. (Storage Guideline 5a.5)

Saline formations and mature oil and gas fields should be

considered for initial projects. Other formations, such as coal
seams, may prove viable for subsequent activity with additional
research. (Storage Guideline 5a.6)
Confining zones must be present and must prevent the injected
or displaced fluids from migrating to drinking water sources as
well as economic resources (e.g., mineral resources) or the
surface. (Storage Guideline 5b.1)
Operators should identify and map the continuity of the target
formation confining zone for the project footprint, and confirm
the integrity of the confining zone(s) with appropriate tools.
Natural and drilling- or operationally-induced fractures (or the
likely occurrence thereof) should be identified. (Storage
Guideline 5b.2)
Operators should identify and map auxiliary or secondary
confining zones overlying the primary and secondary target
formations, where appropriate. (Storage Guideline 5b.3)
Operators should identify and locate all wells with penetrations
of the confining zone within the project footprint. A survey of
these wells should be conducted to assess their likely
performance and integrity based on completion records and
visual surveys. These data should be made publicly available.
(Storage Guideline 5b.4)

Operators should identify and map all potentially transmissive

faults, especially those that transect the confining zone within
the project footprint. (Storage Guideline 5b.5)
Operators should collect in-situ stress information from site
wells and other sources to assess likely fault performance,
including stress tensor orientation and magnitude. (Storage
Guideline 5b.6)
If sufficient data do not already exist, operators should obtain
data to estimate injectivity over the projected project footprint.
This may be accomplished with a sustained test injection or
production of site wells. These wells (which could serve for
injection, monitoring, or characterization) should have the
spatial distribution to provide reasonable preliminary estimates
over the projected project footprint (Storage Guideline 5c.1)
Water injection tests should be allowed in determining site
injectivity. (Storage Guideline 5c.2)
Operators should obtain and organize porosity and permeability
measurements from core samples collected at the site. These
data should be made publicly available. (Storage Guideline 5c.3)
Operators should estimate or obtain estimates of the projected
capacity for storing CO2 with site-specific data (CO2 density at
projected reservoir pressure and temperature) for the project
footprint. This should include all target formations of interest,
including primary and secondary targets. Capacity calculations
should include estimates of the net vertical volume effectively
utilized or available for storage and an estimate of likely pore
volume fraction to be used (utilization factor). (Storage
Guideline 5d.1)
Operators should collect and analyze target formation pore
fluids to determine the projected rate and amount of CO2 stored
in a dissolved phase. These data should be made publicly
available as necessary for permitting and compliance purposes.
(Storage Guideline 5d.2)
Operators should obtain estimates of phase-relative
permeability (CO2 and brine) and the amount of residual phase
trapping. One possible approach is to use core samples with
sufficient spatial density to confirm the existence of the
trapping mechanisms throughout the site and to allow their
simulation prior to site development. Estimates should be
updated with site-specific monitoring and modeling results.
These data should be made publicly available as necessary for
permitting and compliance purposes. (Storage Guideline 5d.3)

CCS GUIDELINES

Potential storage reservoirs should be ranked using a set of

criteria developed to minimize leakage risks. Future work is
needed to clarify such ranking criteria. (Storage Guideline 5a.1)

129

CCS GUIDELINES

130

A field development plan should be generated early on in the

permitting phase. (Storage Guideline 6a)

Operators should develop transparent operational plans and

implementation schedules with sufficient flexibility to use
operational data and new information resulting from MMV
activities to adapt to unexpected subsurface environments.
(Storage Guideline 6b)
Operational plans should be based on site characterization
information and risk assessment; they should include
contingency mitigation/remediation strategies. (Storage
Guideline 6c)
Storage operators should plan for compressor and well
operations contingencies with a combination of contractual
agreements relating to upstream management of CO2, backup
equipment, storage space, and, if necessary, permits that allow
venting under certain conditions. (Storage Guideline 6d)

Wells and facilities should be fit-for-purpose, complying with

existing federal and state regulations for design and
construction. (Storage Guideline 6e)
The reservoir and risk models should be recalibrated (or
history-matched) periodically, based on operational data and
re-run flow simulations. Immediate updates should be made if
significant differences in the expected and discovered geology
are found. (Storage Guideline 6f)

The casing cement in the well should extend from the injection
zone to at least an area above the confining zone. (Storage
Guideline 6g)
Well integrity, including cement location and performance,
should be tested after construction is complete, and routinely
while the well is operational, as required by regulation.
(Storage Guideline 6h)
Water injection tests should be allowed at all prospective CCS
sites. (Storage Guideline 6i)
Injection pressures and rates should be determined by well
tests and geomechanical studies, taking into account both
formation fracture pressure and formation parting pressure.
Rules should not establish generally applicable quantitative
limits on injection pressure and rates; rather, site-specific
limitations should be established as necessary in permits.
(Storage Guideline 6j)
Operators should adhere to established workplace CO2 safety
standards. (Storage Guideline 6k)

Operators should implement corrosion management

approaches, such as regularly checking facilities, wells and
meters for substantial corrosion. Corrosion detected should
be inhibited immediately, or damaged facility components
should be replaced. Dehydration of the injectate should be
required to prevent corrosion, unless appropriate metallurgy
is installed. (Storage Guideline 6l)
Operational data should be collected and analyzed throughout
a projects operation and integrated into the reservoir model
and simulations. The data collected should be used to history
match the project performance to the simulation predictions.
(Storage Guideline 6m)
Continued monitoring during the closure period should be
conducted in a portion of the wells in order to demonstrate
non-endangerment, as described below. (Storage Guideline 7a)
For all other wells, early research and experience suggest that
conventional materials and procedures for plugging and
abandonment of wells may be sufficient to ensure project
integrity, unless site-specific conditions warrant special
materials or procedures. A final assessment should include a
final cement bond log across the primary sealing interval of all
operational wells within the injection footprint prior to
plugging, as well as standard mechanical integrity and pressure
testing. (Storage Guideline 7b)
Operators should assemble a comprehensive set of data
describing the location, condition, plugging, abandonment
procedures, and any integrity testing results for every well that
will be potentially affected by the storage project. (Storage
Guideline 7c)
Satisfactory completion of post-injection monitoring
requires a demonstration with a high degree of confidence
that the storage project does not endanger human health or the
environment. (Storage Guideline 7d) This includes demonstrating
all of the following:
1. the estimated magnitude and extent of the project footprint
(CO2 plume and the area of elevated pressure), based on
measurements and modeling;
2. that CO2 movement and pressure changes match model
predictions;
3. the estimated location of the detectable CO2 plume based
on measurement and modeling (measuring magnitude of
saturation within the plume or mapping the edge of it);

4. either (a) no evidence of significant leakage of injected or

displaced fluids into formations outside the confining zone,
or (b) the integrity of the confining zone;

5. that, based on the most recent geologic understanding of the

site, including monitoring data and modeling, CO2 plume and
formation water are not expected to migrate in the future in
a manner that encounters a potential leakage pathway; and,
6. that wells at the site are not leaking and have maintained integrity.


The site-specific risk assessment should be updated based on

operational data and observations during closure. (Storage
Guideline 7h)

CCS GUIDELINES

Project operators who have demonstrated non-endangerment

should be released from responsibility for any additional
post-closure MMV, and should plug and abandon any wells
used for post-injection monitoring. At this point, the project can
be certified as closed and project operators should be released
from any financial assurance instruments held for site closure.
In the event that regulators or a separate entity decide to
undertake post-closure monitoring that involves keeping an
existing monitoring well open or drilling new monitoring wells,
project operators should not be responsible for any such work
or associated mitigation or remediation arising out of the
conduct of post-closure MMV. (Storage Guideline 7e)

As a condition of completing site closure, operators should

provide data on plugged and abandoned wells potentially
affected by their project to the appropriate well plugging and
abandonment registry. This would include the location and
description of all known wells in the storage project footprint,
and the drilling, completion, plugging, and integrity testing
records for all operational wells. (Storage Guideline 7g)

131

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LIST OF FIGURES
Figure 1:

North American CO2 Sources

25

Figure 2:

Post-combustion Capture from a Pulverized Coal-Fired Power Plant

28

Figure 3:

Pre-combustion Capture on an IGCC Power Plant

28

Figure 4:

Oxy-Fuel Combustion With Capture

29

Figure 5:

Critical Challenges Associated With CO2 Capture Technologies

30

Figure 6:

Existing CO2 Pipelines in the U.S.

44

Figure 7:

Variation of CO2 Density as a Function of Temperature and Pressure

46

Figure 8:

Conceptual Risk Profile of a Storage Project

55

Figure 9:

Integration Within a Storage Project

60

Figure 10:

Projected Timeline for a CCS Project

61

Figure 11:

CO2 Injection Plumes and Hydrostatic Pressure Viewed by Plan and Section

62

Figure 12:

Conceptual Risk Profiles for a Large CCS Project Through Time

70

Figure 13:

Geologic Storage Reservoir With Multiple Confining Zones

83

Figure 14:

Conceptual Figure of the EPA Vulnerability Evaluation Framework

90

Figure 15:

Example of a Class II or EOR Injection Well

95

Figure 16:

Examples of How Cased and Uncased Wells Are Abandoned

101

LIST OF TABLES
Planned CO2 Capture and Storage Projects

26

Table 2:

Existing and Proposed CO2 Storage Demonstration Projects

31

Table 3:

Capture Technologies and Costs

32

Table 4:

Concentrations of Co-Constituents in Dried CO2 (Percent by Volume)

33

Table 5:

Impacts of CCS System and Energy Penalties on Plant Resource Consumption and Emission Rates
(capture plant rate and change from reference plant rate, kg/MWh)

36

Table 6:

Estimated Raw Water Usage With and Without CO2 Capture

38

Table 7:

Key Geologic and Environmental Parameters to Monitor

66

Table 8:

Possible Risk Scenarios and Remediation Options for Geologic Carbon Storage Projects

77

Table 9:

Examples of Information and Data Sources for Characterization of Storage Sites

88

CCS GUIDELINES

Table 1:

143

PHOTO CREDITS
COVER AND SIDE TABS
(middle) Plains CO2 Reduction Partnership; (bottom) Midwest
Geological Sequestration Consortium
ACKNOWLEDGEMENTS AND DISCLAIMER
(4) Plains CO2 Reduction Partnership
EXECUTIVE SUMMARY
(8) Midwest Geological Sequestration Consortium; (9) Plains CO2
Reduction Partnership; (10) Midwest Regional Carbon Sequestration
Partnership/Battelle; (11) Midwest Regional Carbon Sequestration
Partnership/Battelle; (13) Midwest Regional Carbon Sequestration
Partnership/Battelle; (16) Midwest Geological Sequestration Consortium;
(17) Midwest Regional Carbon Sequestration Partnership/Battelle; (18)
Midwest Regional Carbon Sequestration Partnership/Battelle
PART 2 CAPTURE
(26) Midwest Regional Carbon Sequestration Partnership/Battelle;
(29) Adapted from Holt, 2008; (33) Plains CO2 Reduction Partnership;
(37) Midwest Regional Carbon Sequestration Partnership/Battelle
PART 3 TRANSPORT
(47) Plains CO2 Reduction Partnership
PART 4 STORAGE
(53) Midwest Regional Carbon Sequestration Partnership/Battelle; (55)
MidwestRegionalCarbon Sequestration Partnership/Battelle;(58) Midwest
Regional Carbon Sequestration Partnership/Battelle; (63) Midwest Regional
Carbon Sequestration Partnership/Battelle; (68) Midwest Geological
Sequestration Consortium; (70) Midwest Geological Sequestration
Consortium; (72) Midwest Regional Carbon Sequestration Partnership/
Battelle; (75) Midwest Geological Sequestration Consortium; (76)
Southeast Regional Carbon Sequestration Partnership; (80) Midwest
Geological Sequestration Consortium; (81) Southeast Regional Carbon
Sequestration Partnership; (84) Midwest Geological Sequestration
Consortium; (87) Plains CO2 Reduction Partnership; (91) Plains CO2
Reduction Partnership; (96) Midwest Geological Sequestration Consortium;
(99) Midwest Regional Carbon Sequestration Partnership/Battelle

CCS GUIDELINES

PART 5 SUPPLEMENTARY INFORMATION

(105) Midwest Geological Sequestration Consortium; (108) Midwest
Geological Sequestration Consortium; (113) Midwest Geological
Sequestration Consortium

144

APPENDIX A
(119) Preeti Verma, World Resources Institute 2007
APPENDIX C
(125) Midwest Geological Sequestration Consortium; (126) Midwest
Geological Sequestration Consortium
APPENDIX D
(131) Midwest Geological Sequestration Consortium
BIBLIOGRAPHY
(136) Midwest Geological Sequestration Consortium
PHOTO CREDITS
(144) Midwest Regional Carbon Sequestration Partnership/Battelle
INSIDE BACK COVER
Southeast Regional Carbon Sequestration Partnership

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CCS GUIDELINES

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