CO2 storage guidelines and the science of monitoring: Achieving project success under the California Low Carbon Fuel Standard CCS Protocol and other global regulations

Abstract

Since the 2006 IPCC guidelines on carbon dioxide transport, injection and geological storage outlined the monitoring protocols required for geological CO2 storage as an emissions reduction technology, regulations for CO2 geological storage have been developing and evolving worldwide. The California Air Resources Board Low Carbon Fuel Standard CCS Protocol (LCFS CCSP) is the newest of these regulations to be enacted and thus represents the latest advancements in CO2 storage regulations. Synchronous with regulatory developments, years of research and project experience testing and applying monitoring technologies has created a paradigm shift in our approach to environmental monitoring and yet these learnings are not being fully incorporated into the developing regulations. Thus, if project developers seek only to adhere to the regulations, projects may miss the mark for long term success. Our analysis of the LCFS CCSP in relation to advances in monitoring indicates several technical challenges with the regulation as written including; (1) the requirement of prescriptive monitoring technologies, (2) a non-negotiable 100-year post injection site care period (PISC), (3) the expectation that environmental variations over the lifetime of a project can be predicted from a year of environmental baseline data, and 4) a definition of leakage that is inconsistent with technical capabilities and regulatory goals. We outline the relevant scientific learnings and discuss the ramifications of these requirements and the ways in which monitoring techniques can best be used to both satisfy the regulatory requirements and create long-term project success.