With climate change becoming a center of attention globally, much focus has pointed toward carbon capture and storage (CCS) in recent years. While USEPA has published general guidance for Class VI permitting, it is still a new permitting challenge for both scientists and regulators alike. Drawing on lessons learned from more familiar and well-developed regulatory frameworks will be beneficial.
In our Technical Bulletin, Applying Lessons Learned From Municipal Solid Waste and Coal Combustion Residuals to the Development of Testing and Monitoring Plans for CO2 Storage Projects, we focus on the testing and monitoring aspect of Class VI permitting and related complexities, including the project’s overall scale, enhanced costs, and enhanced regulatory risk. We discuss the key considerations for developing an effective CCS Testing and Monitoring Plan based on lessons learned from developed MSW and CCR monitoring programs, as well as how early planning and good judgment can help navigate the complexities associated with CCS projects and ultimately reduce those complexities and associated project costs.
Recommendations include meticulous site characterization efforts early in the CO2 storage project and tailoring the monitoring network. The latter includes placing monitoring wells based on multiphase modeling predictions, designing geochemically and geomechanically compatible monitoring wells, and using strategic statistical techniques to analyze and interpret monitoring data.
It is important to remember that for CO2 storage, groundwater monitoring is not intended to be the primary monitoring method for detecting fluid leakage and migration. It is only one of many required testing and monitoring methods. Even so, the monitoring network must be planned and established appropriately and then tightly coordinated with the other testing and monitoring methods to maximize the protection of underground sources of drinking water.
SCS Engineers will continue to post timely information, resources, and presentations to keep you well informed. These include additional guidance, industry reaction, and webinars with our teams using our website, on SCS Engineers LinkedIn, and on SCS YouTube on-demand forums.
Additional resources at your fingertips:
Did you miss the 2022 Annual GWPC & UIC Conference in Salt Lake City? We welcome you to view SCS Engineers’ presentation by Kacey Garber entitled “Sensitivity of Aquifer Chemistry to Changes in Carbon Dioxide Partial Pressure: Implications for Design of Groundwater Monitoring Protocols,” where Kacey discusses permitting requirements for groundwater monitoring for carbon sequestration and storage sites.
In her technical presentation, Kacey Garber of SCS Engineers discusses the great care taken in the design and operation of the injection of carbon compounds to ensure that the sequestration is effective and permanent. Each injection site also has permitting requirements for groundwater monitoring in any overlying aquifer as a protective measure. Because the injection and sequestration periods are long, CSS solutions need a cost-effective groundwater monitoring program with a robust sensitivity to detect any leakage. By establishing a groundwater monitoring protocol specific to the site, sensitive to changes in the partial pressure of carbon dioxide, and relatively insensitive to natural variability and hydrochemical facies changes, implementing optimal and cost-effective groundwater protection is possible. Using a case study, Kacey tells us how her team did this in detail.
Kacey Garber is an experienced groundwater project manager for active and closed landfills, including routine groundwater monitoring and statistical analyses; reports and permit applications; designing sampling and analysis plans; special groundwater studies; and conducting groundwater well construction planning and design.
