Railroad Commission of Texas - Regulations for Geologic Storage of Carbon Dioxide - Dave Hill - Global CCS Institute – Nov 2011 Regional Meeting


Published on

As a part of the Institute's strategic focus on assisting CCS projects through knowledge sharing, three North American roadshow events will help the industry share project experiences and knowledge about CCS. Taking place in the US and Canada, the three events include:

• Austin, Texas on November 8, 2011;
• Calgary, Canada on 10 November, 2011; and
• Washington, D.C. on 19 January, 2012.

The first roadshow focused on sharing project experiences and knowledge from the projects in North America but also brought in projects from Europe (Don valley) and Australia (Callide) so that regionally diverse experiences could be shared amongst a global audience.
Attendance at the event was around 30 to 35 which allowed open and frank discussions around technical, management, and regulatory issues and how these challenges can impact on a project’s advancement and decision making processes.

Published in: Business, Technology
  • Be the first to comment

  • Be the first to like this

No Downloads
Total views
On SlideShare
From Embeds
Number of Embeds
Embeds 0
No embeds

No notes for slide

Railroad Commission of Texas - Regulations for Geologic Storage of Carbon Dioxide - Dave Hill - Global CCS Institute – Nov 2011 Regional Meeting

  1. 1. Texas Regulations for Geologic Storage of Carbon Dioxide Global CCS Institute Austin Regional Meeting Austin, Texas November 8, 2011 Dave Hill, CCS Program Railroad Commission of Texas
  2. 2. Texas and CO2 GS (CCS)Overview of Legislation (Senate Bill 1387)Class VI Wells “Phase I” of Chapter 5Comparison of Phase I with Federal RulesEOR/EGR Activities “Phase II” of Chapter 5Report to the Legislature
  3. 3. Senate Bill 1387 (SB 1387)• SB1387: In 2009, the Texas Legislature passed, and the governor signed a bill, “relating to the capture, injection, sequestration, or geologic storage of carbon dioxide”. This was in response to a federal draft rule creating a new class of injection wells, known as Class VI wells under the Underground Injection Control (UIC) part of the Safe Drinking Water Act SDWA). Other well classes remained unchanged.
  4. 4. Anthropogenic Carbon Dioxide• SB 1387 in large measure deals with anthropogenic CO2 which is “ carbon dioxide that would otherwise be released to the atmosphere…”. This includes CO2 that has been stripped from another fluid stream (ex: gas processing plant), or captured from an emissions source. This does not include naturally occurring CO2 recaptured, recycled, or reinjected as part of enhanced oil recovery (EOR) operations
  5. 5. SB 1387 JURISDICTIONRRC jurisdiction over anthropogenic CO2 GS (CCS) In reservoirs productive of oil, gas, or geothermal resources in the past, or potentially in the future  In saline formations above or below such reservoirs RRC jurisdiction over extraction of anthropogenic CO2 No change in CO2 EOR/EGR jurisdiction
  6. 6. SB 1387 CO2 Ownership and Stewardship- Stored CO2 is property of the storage operator or his heirs, successors, or assigns- Unless found to be abandoned, CO2 not the property of the owner of the surface or mineral estate- Allows owner to extract anthropogenic CO2
  7. 7. SB 1387 REQUIREMENTSRRC responsibilities regarding CO2 GS  RRC/TCEQ MOU update  RRC rules consistent with EPA rules  RRC to seek enforcement primacy  Reports to the Legislature
  8. 8. SB 1387 REQUIREMENTSSTATUS  RRC/TCEQ MOU adopted 08-30-2010  CCS Phase I adopted 12-20-2010  CCS w/EOR/EGR, Phase II, adopted 7-17-11  Enforcement primacy: In progress  Combined joint report published 12-01-2010
  9. 9. RRC CO2 GS REGULATIONS Phase I16 TAC Chapter 5 includes the same elementsas federal rules:  Site characterization  AoR and corrective action  Well construction/Plugging  Mechanical integrity/Monitoring  Emergency response  Financial Security  Post-injection facility care
  10. 10. Site CharacterizationMaps: §5.203 (b) requires surface mapsdepicting property boundaries, wells, and otherpertinent surface features, such as surface waterbodies, roads, houses, and pipelines.
  11. 11. Site CharacterizationMaps: §5.203 (c) requires geologic andtopographic maps, cross sections, discussion ofknown or suspected transmissive faults.• This section requires formation data includingdepth, areal extent, mineralogy, permeability,porosity, fm pressure, and basic geochemistryfrom sources such as logs, cores, and surveys.• Geomechanical data on fractures, ductility,rock strength and stress.
  12. 12. Area of Review (AOR) and Corrective Action (CA)• AOR & CA: §5.203 (d) requires the owner / operator (O/O) to delineate the AOR, identify wells requiring corrective action, and perform the corrective action on those wells.• Requires computational modeling that considers properties and volumes of CO2, fm properties, and other available data. Predict lateral and vertical plume migration.• Tabulate and document status of wells in the AOR.
  13. 13. Injection Well Construction• Injection Wells: §5.203 (e) requires wells to be constructed to prevent movement of fluids that will endanger USDW’s, allows proper testing devices and continuous monitoring.• Construction with casing and cement of sufficient strength and quality to maintain integrity during the design life of the well.• Requires wells to have casing installed in a manner that protects USDW’s
  14. 14. Logging, Sampling, & Testing Before Injection§5.203 (f) requires the applicant to submit a plan to gather data after permitting and before injection. Intent is to verify formation properties, assure conformance well specifications, and to provide baseline data. Plan has 3 major aspects.• Logs and surveys of newly drilled wells,• Determination of Hydro-geology of the injection and confining zones,• Sampling to include temperature, pH, conductivity, reservoir pressure, and static fluid level of the injection zone. Core analyses that are representative are also required.
  15. 15. Mechanical Integrity Testing• §5.203 (h) requires mechanical integrity testing before beginning injection operations and at least once every 5 years thereafter.• This subsection also requires a mechanical integrity testing plan as part of the permit application. This plan should detail site specific methods and related considerations.
  16. 16. Operating Information & Plan• §5.203 (i) requires an operating plan. This is to include proposed operating parameters such as CO2 injection rates and volumes, injection pressure, source of the CO2, and chemical and physical characteristics of the injectate.• The plan is to address potential issues including mechanical failure, transmissive fractures, and impact to USDWs.
  17. 17. Monitoring, Sampling, & Testing After Initiation of Operation• §5.203 (j) requires a plan to verify that the geologic storage facility is operating as permitted and that the injected fluids are confined to the injection zone.• Requirements include continuous recording devices for pressure, rate and volume, monitoring of USDW’s, corrosion monitoring, and monitoring of geochemical and geophysical changes.
  18. 18. Well Plugging• §5.203 (k) requires a plan for plugging injection and monitoring wells. This includes requirements for final reservoir and mechanical testing, flushing, as well as cement pumping and compatibility. This also includes notification requirements.
  19. 19. Emergency and Remedial Response Plan• §5.203 (l) requires a plan for emergency and remedial response. This is to describe proposed actions to be taken to address escape of CO2 from the permitted interval, accounts for the entire AOR, addresses potential safety issues, and also includes emergency response, security measures, and training.
  20. 20. Post Injection Care and Closure• §5.203 (m) requires a plan for post injection storage facility care and closure. This plan is to include the predicted position of the CO2 plume and associated pressure front at closure, post injection monitoring locations and their methods and frequencies, a proposed reporting schedule, and an estimated cost of plan activities.
  21. 21. Notice and Hearing§5.204 describes notice and hearing requirements. This includes• Notice by local publication,• Placing a copy of the application in a public place in the nearest city,• Criteria for a list of persons to be notified,• Hearing requirements
  22. 22. Fees, Financial Responsibility, and Financial Assurance§5.205 includes description of Fees, Financial Responsibility, and Financial Assurance requirements. This includes• Fees to be paid for permit applications, and per ton injected,• Requirements to verify financial responsibility,• Criteria to be met for financial assurance regarding various operations and phases of the facility,• Notice of adverse financial conditions
  23. 23. Permit Standards• §5.206 states RRC may issue a permit if: No endangerment/injury to oil, gas, other minerals USDW’s protected from permitted activities No endangerment/injury to human health/safety Reservoir suitable for preventing CO2 escape/migration Applicant meets statutory and regulatory requirements  Plans in §5.203 are approved and followed
  24. 24. Reporting and Record Keeping• §5.207 includes reporting and record keeping requirements. This includes test records and operating reports. Depending on the information reported, reporting frequency may be within 24 hours, or at other intervals such as monthly, semi-annual, or annual
  25. 25. State-specific elements:Letter from TCEQ Executive Director (GAU)Use of other rules where appropriate, including • SWR 1 – Notice of bankruptcy • SWR 13 – Well completion • SWR 14 – Well plugging • SWR 46 – EOR/EGR • SWR 78 – Financial assurance for wells • Water Well Driller rules
  26. 26. Differences from EPA:Differences from EPA regulations:  Do not imply more than one confining zone necessary  No prohibition against storage above USDW  External MIT once every 5 years  No default (50-yr) post-injection monitoring  Phased financial assurance on corrective action  5 yr (rather than 10 yr) records retention  More flexibility
  27. 27. ENFORCEMENT PRIMACY: EPA Split jurisdiction Work Load
  28. 28. RRC CO2 GS REGULATIONS Phase II Associated with EOR/EGRPURPOSE - §5.301: Provide for certification of GSof CO2 incidental to enhanced recovery operationsfor which:  there is a reasonable expectation of more than insignificant future production volumes or rates as a result of the injection of anthropogenic CO2 ; and  operating pressures no higher than reasonably necessary for enhanced recovery
  29. 29. RRC CO2 GS REGULATIONS Associated with EOR/EGR (Phase II)Registration for Certification §5.303 Requires registration of enhancedrecovery facility for which the operator proposesto document GS of anthropogenic CO2 incidentalto enhanced recovery
  30. 30. RRC CO2 GS REGULATIONS Associated with EOR/EGR (Phase II)Application and Fee §5.304 Establishes registration applicationrequirements, including registration andcertification fees for each facility.
  31. 31. RRC CO2 GS REGULATIONS Associated with EOR/EGR (Phase II)Monitoring, Sampling and Testing Plan: §5.305 requires this plan in order to allow adetermination by mass balancing or actual systemmodeling of the quantities of anthropogenic CO2permanently stored within the enhanced recoveryreservoir for documentation to RRC. In lieu of mass balance or modeling, the O/omay comply by submitting to the RRC a copy ofinformation submitted to EPA under Subparts RR orUU of 40 CFR Part 98, of GHG Rules
  32. 32. RRC CO2 GS REGULATIONS Associated with EOR/EGR (Phase II)Standards for Certification under §5.306:To verify geologic storage of CO2, operator mustmaintain, and be in compliance with, approvedtesting, monitoring, and reporting plan.RRC may then annually issue a certificationprovided that all other requirements are met.
  33. 33. SB 1387 JOINT REPORTTwo reports were required under Sections 9 and 10 of SB 1387. One by GLO, and one by RRC & TCEQ. The UT-Bureau of Economic Geology was directed to assist in each. A comprehensive report was issued by the four state agencies.Intended to provide policy information, discussion of technical issues, and legislative recommendations to the Texas Legislature in response to their requirements.
  34. 34. Report Highlights• Discusses regulatory framework for leasing state lands and addressing related legal and legislative issues• Recommends a permitting process for saline aquifers not productive of oil, gas, or geothermal resources• Discusses procedures for public comment• Discusses Financial Assurance options and addresses long term liability issues for post operational phases• Discusses the means of ensuring the quality of natural and cultural resources• Recommends criteria to identify candidate sites in seven specified geologic settings
  35. 35. SB 1387 JOINT REPORThttp://www.rrc.state.tx.us/ Clicko Forms, Maps & More (near the top) Click •Publications First Document, pdf format
  36. 36. Questions?david.hill@rrc.state.tx.us 512 463 3011