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Energy & Environmental Research Center (EERC)
FIRST WAVE OF INCENTIVE-DRIVEN CCS
PROJECTS PERMITTED IN NORTH DAKOTA, U.S.
Carbon Capture Summit
October 19th - 20th , 2022
Josh Regorrah
Permitting and Policy Specialist
© 2022 University of North Dakota Energy & Environmental Research Center.
REGULATORY FRAMEWORK DEVELOPMENTACROSS STATES
REGIONAL CARBON
SEQUESTRATION
PARTNERSHIP
PROGRAM
CHALLENGES TO CCUS DEPLOYMENT
REGULATIONS AND PERMITTING
LONG-TERM LIABILITY
ECONOMICS
TECHNOLOGY PROOF OF CONCEPT
INFRASTRUCTURE DEVELOPMENT
ADAPTIVE MANAGEMENT APPROACH TO PROJECT
IMPLEMENTATION
• Staged approach to manage uncertainty
and inform investment strategy
• Implementation can be accelerated
– Higher investment needed at lower
levels of confidence
– Concurrent vs. sequential
development
– Balance financial and technical risk
♦ Site qualification
♦ Permitting
♦ Incentive programs and revenue
♦ Investment
♦ 45Q start of construction
Generalized Timeline to Implement Geologic CO2 Storage
Operations
Drill and construct injection and monitoring
wells; install infrastructure; update permits
Investment & Construction
Regulatory Review
of Permit
Project Design &
Permit Application
Feasibility
Baseline Monitoring
AOR (legacy wells)
Financial Assurance
Unitization & Project Exhibits
Qualify Site/Project
Design Specifications
FEED
45Q Start
Construction by
01/01/2033
File
Permits
Receive
Permit
Approvals
Storage Facility
Defined
No. Injection Wells
No. Monitoring Wells
Go/
No-Go
Acquire pore space and
negotiate access agreements
Screening
Go/
No-Go
FID
Go/
No-Go
(3-6 months) (9-18 months) (6-18 months) (7-12 months +)
Legacy Data
Acquire
Site-Specific Data
Compliance with IRS 45Q Tax Credit Program:
EPA-Approved GHGR Subpart RR MRV Plan
Projects that Qualify for CARB LCFS Markets::
CARB LCFS Permanence Protocol
Welll Logs
Core Analysis
Sampling/Testing
Seismic
CO2 Point Sources
• Ethanol production
• Coal-fired power generation
• Gasification
• Fertilizer production
• Natural gas processing
• Natural gas power generation
• Industrial processes
Capture/Storage Models
• Source/sink-matched
• Source aggregation and storage hub
• Capture hub with distributed storage
• Hybrid storage with enhanced oil recovery,
minerals recovery, and/or other utilization
CCS PROJECTS IN NORTH DAKOTA
 Broom Creek Formation: >10
billion tons CO2 storage
potential
 RTE CCS: ~18 million tons
CO2 (if injecting up to 100
years)
 Broom Creek Formation:
>10 billion tonnes CO2 Storage Potential
• Red Trail Energy CCS:
~3 million tonnes of CO2 total
~100,000 tonnes per year
• Project Tundra:
~77 million tonnes of CO2 total
~4 million tonnes per year
• Dakota Gasification Company:
~26 million tonnes of CO2 total
~3 million tonnes per year
Project
Tundra
Dakota
Gasification
Company
GEOLOGIC STORAGE PERMITS IN NORTH DAKOTA
Image credit – EERC
Red Trail Richardton Ethanol Broom Creek Storage Facility No. 1
– Approved October 19, 2021
CarbonSAFE North Dakota Storage Facility
– Approved January 21, 2022
RED TRAIL ENERGY, LLC
Richardton, ND
12
23 millionbushels
of Corn
46 Employees 233,000 tons of
Coproducts
64 milliongallonsof
Ethanol
Approximately $350 million
of EconomicImpact
Over $149 million
in Gross Sales
Coproducts
Support 220,000
head of Cattle
928 Investors
Corn Oil Sold
for Biodiesel
Corn-Based Biorefinery
CCS Components
& Major Activities
2021 2022
Q1 Q2 Q3 Q4 Q1 Q2 Q3
Characterization &
Monitoring*
Capture System
Permits & Wells
CCS Components
& Major Activities
2019 2020
Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
Characterization &
Monitoring*
Capture System
Permits & Wells
Capture
Bids
Seismic Data
Acquisition
Near-Surface
Monitoring (start)
Drill RTE-10
Injection Well**
Well Design/Permit
Application (start)
*Includes
modeling/simulation
updates with major
data acquisition
events
**Stratigraphic test
(coring, testing,
logging)
Capture
Start
Injection
Start
Operational
Monitoring
Capture
Construction (start)
Core, Testing, & Downhole/
Baseline Monitoring
13
Contract
Capture System
Drill RTE-10.2
Monitoring Well**
Baseline
Monitoring
RTE CCS ACTIVITES TIMELINE
1st ND Class VI
APPROVED
Class VI
Application
RTE CCS SITE
CCS Components
& Major Activities
2022 2022
Q1 Q2 Q3 Q4 Q1 Q2 Q3
Characterization &
Monitoring*
Capture System
Permits & Wells
CCS Components
& Major Activities
2020 2021
Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
Characterization &
Monitoring*
Capture System
Permits & Wells
Environmental Information
Volume (EIV) Drafted
Seismic Data
Acquisition
Near-Surface
Monitoring (start)
Drill J-LOC1
Well Design/Permit
Application
(J-ROC and J-LOC1)
*Includes
modeling/simulation
updates with major
data acquisition
events
**Stratigraphic test
(coring, testing,
logging)
EIV Submitted to
the DOE
Core, Testing, & Downhole/
Baseline Monitoring
16
Baseline
Monitoring
PROJECT TUNDRAACTIVITIES TIMELINE
Drill J-ROC1
Class VI Permits
Submitted
Class VI Permits
Approved
Permit to Drill
(Injection wells)
Milton R. Young
Station
CarbonSAFE
Phase III
Strat Test
(J-ROC1)
1 mile
CarbonSAFE
Phase II
Strat Test
(BNI-1)
J-LOC1 Well
(Potential
Monitor)
Facility
Coal fired power plant which can supply 250
MW (Unit 1) and 455 MW (Unit 2)
Tonnage ~4 million tonnes per annum
Injector Design
Three CO2 injectors into two storage
reservoirs: the Broom Creek and the Dead
Regulatory
Status (NDIC) Class VI Permit approved
PROJECT TUNDRA SITE
DAKOTAGASIFICATION
COMPANY GREAT
PLAINS CO2
SEQUESTRATION
PROJECT
• CO2 Capture Began in 2000
• 40 MMt Captured
• 26 MMt over an ~12-year injection
period
• First project to implement a pattern
injection approach to optimize
storage and project footprint
• Pending state approval
STORAGE FACILITY PERMIT
North Dakota CO2 Storage Facility
Permit (Class VI) Checklist
 Pore Space Access
 Geologic Exhibits
 Geologic Model and Simulations
 Area of Review (AOR)
 Supporting Plans
 Testing and Monitoring Plan
 Postinjection Site and Facility Closure Plan
 Emergency and Remedial Response Plan
 Worker Safety Plan
 Well Casing and Cementing Program
 Plugging Plan
 Financial Assurance Demonstration Plan
 Injection Well and Storage Reservoir Information
19
GEOLOGIC EXHIBITS
North Dakota CO2 Storage Facility
Permit (Class VI) Checklist
 Storage Reservoir
 Minerology
 Mechanisms of Geologic Confinement
 Geochemical Information of the Injection
Zone
 Confining Zones
 Upper Confining Zone
 Additional Overlying Confining Zones
 Lower Confining Zone
 Geomechanical Information of Confining
Zone
 Faults, Fractures, and Seismic Activity
 Potential Mineral Zones
20
STORAGE FACILITY PERMIT TIMELINE
App
Submitted
Draft Permit
Reg. Review
(60 days)
Landowner
Mineral
Notice
(45 Days)
Public Comment
Period
(30 days)
Public
Hearing
Public
Comment
Response
Final
Permit
Three Parts
1. Geologic Storage
2. Amalgamation
3. Financial Assurance
Response to significant comments
Written comments on draft permit
INTEGRATING PERMITTINGAND INCENTIVE PROGRAMS
22
LCFS Pathway 
Certified CI Values
 CO2 Credits
North Dakota CO2
SFP (Class VI)
California CCS
Protocol: CCS
Permanence
Certification
MRV Plan
CCS Project
Certification
Sequestration
Site
Certification
EPA Greenhouse Gas
Reporting Program
(GHGRP) Subpart
Resource Recovery (RR)
IRS Section 45Q
CCS Tax Credits
[+ 3rd party reviews]
[+ 3rd party verification]
Enhancement of Carbon Dioxide
Sequestration Credit (a.k.a. Section
45Q): Approved EPA Monitoring,
Reporting, and Verification (MRV) Plan
Low Carbon Fuel Standard (LCFS)
with CCS: Certified Carbon Intensity (CI)
Value + CCS Protocol Certification
CCS
INCENTIVES
• No sales tax on capture-
related infrastructure
• No sales tax on CO2 sold
for EOR
• Coal conversion tax: tax
reduction with CO2
capture (up to 50%)
• No sales tax on
construction of pipeline
• Property tax-exempt for 10
years (equipment)
• No sales tax on CO2 EOR infrastructure
• 0% extraction tax for 20 years for tertiary
incremental recovery
• Production tax still applies
• Projects beginning construction before January 1, 2033, can
claim credits for 12 years after operations begin.
• Tax credits claimed by the taxpayer capturing the emissions or
transferred to operators of CO2 EOR projects.
• Tax credit for CO2 stored in a qualified EOR project (10-year
ramp-up to a maximum of $60/tonne in 2033).
• Tax credit for CO2 stored in a saline formation (10-year ramp-up
to a maximum of $85/tonne in 2033).
45Q Tax Credits
• Credits trading price range
$218 - $64 per ton (October
2022)
West Coast LCFS
Markets
North Dakota CCUS Incentives
Image Credit – EERC
EPA GHGRP
Subpart RR MRV Plan
(IRS 45Q)
 Monitoring Area
Delineation
 Leakage Pathways
Evaluation
 Mass Balance and
Sequestration
Volumes
The adaptive management approach
developed at the EERC has helped guide
projects towards successful CCS projects.
CCS projects are incentivized to operate
based on a variety of voluntary markets
each with their own regulatory
requirements.
The risk of a project is contingent on
financial scope and expected timelines.
BALANCING INCENTIVES AND TECHNICAL RISKS
Lessons Learned:
Outreach
 Open houses
 Results of geologic characterization and
monitoring provided to landowners
 Webpage with FAQ
 Visibility in the community
 Frequent engagement and briefings to
regulators and county/city
commissioners
 Alternative approaches to in-person
outreach activities
– Informational videos, virtual question-
and-answer forums, and a series of
media/materials releases, etc.
25
Images Credit: Energy &
Environmental Research Center
Energy & Environmental
Research Center
University of North Dakota
15 North 23rd Street, Stop 9018
Grand Forks, ND 58202-9018
www.undeerc.org
701.777.5000 (phone)
701.777.5181 (fax)
Josh Regorrah
Permitting and Regulatory Specialist
jregorrah@undeerc.org
701.777.5346 (phone)
THANK YOU Critical Challenges. Practical Solutions.
EERC-CCS Projects

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EERC-CCS Projects

  • 1.
  • 2. Energy & Environmental Research Center (EERC) FIRST WAVE OF INCENTIVE-DRIVEN CCS PROJECTS PERMITTED IN NORTH DAKOTA, U.S. Carbon Capture Summit October 19th - 20th , 2022 Josh Regorrah Permitting and Policy Specialist © 2022 University of North Dakota Energy & Environmental Research Center.
  • 5.
  • 6. CHALLENGES TO CCUS DEPLOYMENT REGULATIONS AND PERMITTING LONG-TERM LIABILITY ECONOMICS TECHNOLOGY PROOF OF CONCEPT INFRASTRUCTURE DEVELOPMENT
  • 7. ADAPTIVE MANAGEMENT APPROACH TO PROJECT IMPLEMENTATION • Staged approach to manage uncertainty and inform investment strategy • Implementation can be accelerated – Higher investment needed at lower levels of confidence – Concurrent vs. sequential development – Balance financial and technical risk ♦ Site qualification ♦ Permitting ♦ Incentive programs and revenue ♦ Investment ♦ 45Q start of construction
  • 8. Generalized Timeline to Implement Geologic CO2 Storage Operations Drill and construct injection and monitoring wells; install infrastructure; update permits Investment & Construction Regulatory Review of Permit Project Design & Permit Application Feasibility Baseline Monitoring AOR (legacy wells) Financial Assurance Unitization & Project Exhibits Qualify Site/Project Design Specifications FEED 45Q Start Construction by 01/01/2033 File Permits Receive Permit Approvals Storage Facility Defined No. Injection Wells No. Monitoring Wells Go/ No-Go Acquire pore space and negotiate access agreements Screening Go/ No-Go FID Go/ No-Go (3-6 months) (9-18 months) (6-18 months) (7-12 months +) Legacy Data Acquire Site-Specific Data Compliance with IRS 45Q Tax Credit Program: EPA-Approved GHGR Subpart RR MRV Plan Projects that Qualify for CARB LCFS Markets:: CARB LCFS Permanence Protocol Welll Logs Core Analysis Sampling/Testing Seismic
  • 9. CO2 Point Sources • Ethanol production • Coal-fired power generation • Gasification • Fertilizer production • Natural gas processing • Natural gas power generation • Industrial processes Capture/Storage Models • Source/sink-matched • Source aggregation and storage hub • Capture hub with distributed storage • Hybrid storage with enhanced oil recovery, minerals recovery, and/or other utilization
  • 10. CCS PROJECTS IN NORTH DAKOTA  Broom Creek Formation: >10 billion tons CO2 storage potential  RTE CCS: ~18 million tons CO2 (if injecting up to 100 years)  Broom Creek Formation: >10 billion tonnes CO2 Storage Potential • Red Trail Energy CCS: ~3 million tonnes of CO2 total ~100,000 tonnes per year • Project Tundra: ~77 million tonnes of CO2 total ~4 million tonnes per year • Dakota Gasification Company: ~26 million tonnes of CO2 total ~3 million tonnes per year Project Tundra Dakota Gasification Company
  • 11. GEOLOGIC STORAGE PERMITS IN NORTH DAKOTA Image credit – EERC Red Trail Richardton Ethanol Broom Creek Storage Facility No. 1 – Approved October 19, 2021 CarbonSAFE North Dakota Storage Facility – Approved January 21, 2022
  • 12. RED TRAIL ENERGY, LLC Richardton, ND 12 23 millionbushels of Corn 46 Employees 233,000 tons of Coproducts 64 milliongallonsof Ethanol Approximately $350 million of EconomicImpact Over $149 million in Gross Sales Coproducts Support 220,000 head of Cattle 928 Investors Corn Oil Sold for Biodiesel Corn-Based Biorefinery
  • 13. CCS Components & Major Activities 2021 2022 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Characterization & Monitoring* Capture System Permits & Wells CCS Components & Major Activities 2019 2020 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Characterization & Monitoring* Capture System Permits & Wells Capture Bids Seismic Data Acquisition Near-Surface Monitoring (start) Drill RTE-10 Injection Well** Well Design/Permit Application (start) *Includes modeling/simulation updates with major data acquisition events **Stratigraphic test (coring, testing, logging) Capture Start Injection Start Operational Monitoring Capture Construction (start) Core, Testing, & Downhole/ Baseline Monitoring 13 Contract Capture System Drill RTE-10.2 Monitoring Well** Baseline Monitoring RTE CCS ACTIVITES TIMELINE 1st ND Class VI APPROVED Class VI Application
  • 15.
  • 16. CCS Components & Major Activities 2022 2022 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Characterization & Monitoring* Capture System Permits & Wells CCS Components & Major Activities 2020 2021 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Characterization & Monitoring* Capture System Permits & Wells Environmental Information Volume (EIV) Drafted Seismic Data Acquisition Near-Surface Monitoring (start) Drill J-LOC1 Well Design/Permit Application (J-ROC and J-LOC1) *Includes modeling/simulation updates with major data acquisition events **Stratigraphic test (coring, testing, logging) EIV Submitted to the DOE Core, Testing, & Downhole/ Baseline Monitoring 16 Baseline Monitoring PROJECT TUNDRAACTIVITIES TIMELINE Drill J-ROC1 Class VI Permits Submitted Class VI Permits Approved Permit to Drill (Injection wells)
  • 17. Milton R. Young Station CarbonSAFE Phase III Strat Test (J-ROC1) 1 mile CarbonSAFE Phase II Strat Test (BNI-1) J-LOC1 Well (Potential Monitor) Facility Coal fired power plant which can supply 250 MW (Unit 1) and 455 MW (Unit 2) Tonnage ~4 million tonnes per annum Injector Design Three CO2 injectors into two storage reservoirs: the Broom Creek and the Dead Regulatory Status (NDIC) Class VI Permit approved PROJECT TUNDRA SITE
  • 18. DAKOTAGASIFICATION COMPANY GREAT PLAINS CO2 SEQUESTRATION PROJECT • CO2 Capture Began in 2000 • 40 MMt Captured • 26 MMt over an ~12-year injection period • First project to implement a pattern injection approach to optimize storage and project footprint • Pending state approval
  • 19. STORAGE FACILITY PERMIT North Dakota CO2 Storage Facility Permit (Class VI) Checklist  Pore Space Access  Geologic Exhibits  Geologic Model and Simulations  Area of Review (AOR)  Supporting Plans  Testing and Monitoring Plan  Postinjection Site and Facility Closure Plan  Emergency and Remedial Response Plan  Worker Safety Plan  Well Casing and Cementing Program  Plugging Plan  Financial Assurance Demonstration Plan  Injection Well and Storage Reservoir Information 19
  • 20. GEOLOGIC EXHIBITS North Dakota CO2 Storage Facility Permit (Class VI) Checklist  Storage Reservoir  Minerology  Mechanisms of Geologic Confinement  Geochemical Information of the Injection Zone  Confining Zones  Upper Confining Zone  Additional Overlying Confining Zones  Lower Confining Zone  Geomechanical Information of Confining Zone  Faults, Fractures, and Seismic Activity  Potential Mineral Zones 20
  • 21. STORAGE FACILITY PERMIT TIMELINE App Submitted Draft Permit Reg. Review (60 days) Landowner Mineral Notice (45 Days) Public Comment Period (30 days) Public Hearing Public Comment Response Final Permit Three Parts 1. Geologic Storage 2. Amalgamation 3. Financial Assurance Response to significant comments Written comments on draft permit
  • 22. INTEGRATING PERMITTINGAND INCENTIVE PROGRAMS 22 LCFS Pathway  Certified CI Values  CO2 Credits North Dakota CO2 SFP (Class VI) California CCS Protocol: CCS Permanence Certification MRV Plan CCS Project Certification Sequestration Site Certification EPA Greenhouse Gas Reporting Program (GHGRP) Subpart Resource Recovery (RR) IRS Section 45Q CCS Tax Credits [+ 3rd party reviews] [+ 3rd party verification] Enhancement of Carbon Dioxide Sequestration Credit (a.k.a. Section 45Q): Approved EPA Monitoring, Reporting, and Verification (MRV) Plan Low Carbon Fuel Standard (LCFS) with CCS: Certified Carbon Intensity (CI) Value + CCS Protocol Certification
  • 23. CCS INCENTIVES • No sales tax on capture- related infrastructure • No sales tax on CO2 sold for EOR • Coal conversion tax: tax reduction with CO2 capture (up to 50%) • No sales tax on construction of pipeline • Property tax-exempt for 10 years (equipment) • No sales tax on CO2 EOR infrastructure • 0% extraction tax for 20 years for tertiary incremental recovery • Production tax still applies • Projects beginning construction before January 1, 2033, can claim credits for 12 years after operations begin. • Tax credits claimed by the taxpayer capturing the emissions or transferred to operators of CO2 EOR projects. • Tax credit for CO2 stored in a qualified EOR project (10-year ramp-up to a maximum of $60/tonne in 2033). • Tax credit for CO2 stored in a saline formation (10-year ramp-up to a maximum of $85/tonne in 2033). 45Q Tax Credits • Credits trading price range $218 - $64 per ton (October 2022) West Coast LCFS Markets North Dakota CCUS Incentives Image Credit – EERC EPA GHGRP Subpart RR MRV Plan (IRS 45Q)  Monitoring Area Delineation  Leakage Pathways Evaluation  Mass Balance and Sequestration Volumes
  • 24. The adaptive management approach developed at the EERC has helped guide projects towards successful CCS projects. CCS projects are incentivized to operate based on a variety of voluntary markets each with their own regulatory requirements. The risk of a project is contingent on financial scope and expected timelines. BALANCING INCENTIVES AND TECHNICAL RISKS
  • 25. Lessons Learned: Outreach  Open houses  Results of geologic characterization and monitoring provided to landowners  Webpage with FAQ  Visibility in the community  Frequent engagement and briefings to regulators and county/city commissioners  Alternative approaches to in-person outreach activities – Informational videos, virtual question- and-answer forums, and a series of media/materials releases, etc. 25 Images Credit: Energy & Environmental Research Center
  • 26. Energy & Environmental Research Center University of North Dakota 15 North 23rd Street, Stop 9018 Grand Forks, ND 58202-9018 www.undeerc.org 701.777.5000 (phone) 701.777.5181 (fax) Josh Regorrah Permitting and Regulatory Specialist jregorrah@undeerc.org 701.777.5346 (phone) THANK YOU Critical Challenges. Practical Solutions.