Experience in developing

CO2 storage under the

Directive on the geological
storage of carbon dioxide

March 2022

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I
 AUTHORS

Tim Dixon IEA Greenhouse Gas

Chris Gittins Taqa Global

Stuart Haszeldine University of Edinburgh

Vit Hladik Czech Geological Survey

Bureau de Recherches
Thomas Le Guénan
Géologiques et Minières
Filip Neele TNO

Gloria Thürschmid Energie Beheer Nederland

Owain Tucker Shell

Ceri Vincent British Geological Survey

Charles-Albert Bareth Zero Emissions Platform

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This document has been prepared on behalf of the Advisory Council of the European Zero
Emission Technology and Innovation Platform (ETIP ZEP). ZEP exists to advise the European
Commission on Carbon Capture Utilisation and Storage Technologies and associated
policies. The information and views contained in this document are the collective view of
the Advisory Council and not of individual members, or of the European Commission.
Neither the Advisory Council, the European Commission, nor any person acting on their behalf,
is responsible for the use that might be made of the information contained in this publication.

This project has received funding from the European Union’s Horizon 2020
research and innovation programme under grant agreement No 826051

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Table of content

Reflections and recommendations 6

1. Introduction 8
1.1 Background 8
1.2 Directive on the geological storage of CO2 8
1.3 Objective of the report 9
2. Storage permit application 11
2.1 Data about the potential operator 11
2.2 Characterisation of the storage site and complex 12
2.3 CO2 purity & Injection 13
2.4 Seismicity & Monitoring 14
2.5 Permit documents & updates 15
3. Storage types / principles 17
3.1 Introduction 17
3.2 Depleted hydrocarbon fields, without pressure support (confined stores) 19
3.3 Depleted hydrocarbon fields, with pressure support (partially-confined stores) 19
3.4 Producing hydrocarbon fields 20
3.5 Saline formations (partially-confined stores) 21
3.6 Saline formations (unconfined stores) 21
3.7 Risk-led management through monitoring, modelling and verification 22
4. Transition from production to storage 25
CASE 1 25
CASE 2 26
CASE 3 28
5. Closure and transfer of responsibility 29
6. Financial security 31
6.1 What is it? 31
6.2 What is the issue? 31
6.3 Potential solutions 32
6.4 Missing definition 33
7. Blended storage 34
8. Conclusion 36
9. Annex: Guidance Documents 37
References 39

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Executive summary

The Intergovernmental Panel on Climate awarded to PORTHOS, are prime examples of

Change (IPCC) report ‘Climate Change 2022 – permanent CO2 storage capacities in Europe.
Impacts, Adaptation and Vulnerability’ Such projects provide the storage
describes the current impact of climate change infrastructure required to reach and exceed
including hot extremes, wildfires, heavy the Commission’s goal.
precipitations, flooding, tree mortality,
biodiversity loss, reduced food and water The success of these permanent CO2 storage
security, increase in diseases, rising projects relies on a clear legal framework that
displacements, and damages to key economic provides operators with regulatory certainty.
sectors and infrastructure. To stay in line with The Directive on the geological storage of
the 1.5°C scenario, the EU needs reach net- carbon dioxide, adopted by the European
zero greenhouse gases emissions by 2050. The Parliament and the Council in 2009, aims to
European Climate Law puts this objective at provide such clarity. The purpose of the
the heart of the European Green Deal and the guidance documents published in 2011 is to
EU climate action. help in the implementation of the Directive.

Carbon capture and storage (CCS) are proven The main objective of this report is to highlight
and cost-efficient technologies, available now how the Guidance Documents could be made
and necessary for Europe to reach net-zero CO2 simpler, clearer and easier to use, and to
emissions by 2050. CCS technologies can make propose improvements to these Guidance
a significant contribution to climate change Documents to support the work by regulators
mitigation. Their potential for carbon and project developers. The Directive itself
emissions abatement and removal is should not be opened up for review, since
scientifically proven and acknowledged by the storage permit applications have been
European Taxonomy for Sustainable Activities developed under the Directive and increasing
and the European Commission’s ‘Clean Planet experience with regulators and project
for All’ scenario. developers is already showing evidence of
evolving interpretation. Another objective of
The EU benefits from the North Sea basin, this report is to share knowledge with
which has tens of billions of tonnes of CO2 companies, projects, governments, and
storage capacity and has safely stored CO2 competent authorities based on previous
since 1996. The recently launched CCS project experience.
Longship in Norway and the positive
developments in the Netherlands, with The key message in the report is that
Connecting Europe Facility (CEF) funding being competent authorities should engage early

5
and frequently with operators and project made and operations can remain
managers. Another key message is to avoid efficient.
increasing or further detailing the • The competent authority needs to
requirements in the Guidance Documents. decide on liabilities of asset owners
and production license holders.
Reflections and • The competent authority needs to
develop a clear pathway that allows
recommendations future storage operators to access the
Section 2 of this report highlights the information required and to undertake
importance to clearly communicate the site appraisal activities.
functional requirements for CO2 storage
ZEP would like to recommend the following
operation. ZEP would like to recommend the
updates to the Guidance Documents regarding
following updates to the Guidance Documents:
the case when the current operator aims to
• Competent authorities should engage
stay and start a CCS project:
with the project early in the process to
• The competent authority should ask
provide clarity and to avoid
the existing joint-venture partners to
misunderstandings and delays.
give the production license back or
• Operators should have the right to
become partners on the new project.
object to surface and subsurface
• The competent authority should either
activities impacting the viability of an
take over the partners’ shares to
ongoing project.
ensure further progress in CCS or find
• The operator should have the
new partners, if the joint-venture
possibility to update the interim
partners do not want to work on the
documents/plans more efficiently, and
new project.
directly after the commissioning phase
• In case of competition between the
of the storage system.
current operator and interested third
• The competent authority should
parties, the competent authority
provide clear oversight of the project
should develop a strategy to evaluate
and support the process after the start
all available project plans and ensure
of injection.
that permits are granted on objective,
• The competent authority should not
transparent and non-discriminatory
apply more stringent requirements to
criteria.
depleted hydrocarbon reservoirs than
• Competition must be limited to the
to new deep saline formations.
contract area or returned production
Section 4 analyses the transition from the license areas.
production of hydrocarbon to future CO2 • The Guidance Document should
storage activities. ZEP would like to provide more clarity regarding the
recommend the following updates to the consequences and responsibilities if a
Guidance Documents regarding the case when storage site is used in a different
the current operator aims to stop activities in stratigraphic interval.
the current production license area:
ZEP would like to recommend the following
• The current operator must report its
updates to the Guidance Documents regarding
intention to the competent authority
the case when an existing operator is blocking
upfront, so that other plans can be
a license:

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 • The competent authority should
require from an operator holding a
production license to annually publish
their plans for CO2 storage.
• The competent authority should
publish a guideline to provide advice
on how to manage a field and its
abandonment.

Section 5 discusses the closure and transfer of

responsibility to the competent authority. ZEP
would like to recommend the following update
to the Guidance Documents:
• The competent authority should
discuss and agree with the operator
the criteria for the demonstration of
permanent storage on a case-by-case
basis.
• The competent authority should make
sure that provisional post-closure
plans and the financial mechanism do
not increase in scope unless a
significant irregularity occurs during
site operations.

Section 6 addresses the fact that the operator

must set up a fund to cover the costs after the
transfer of responsibility of the storage site.
ZEP would like to recommend the following:
• The operator should set up insurance
schemes that include public and
private funding. If that is not possible,
the operator should calculate the size
of the fund based on a percentile of
costs and not on expected values.
• National governments should have a
robust and independent review of the
risks and impose risk criteria for low-
probability incidents.

Finally, in section 9, ZEP is recommending

specific amendments to Guidance Documents
2, 3 and 4.

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1. Introduction
cross-border, European CO2 transport and

1.1 Background 1.2 The Directive

Climate change is one of the biggest challenges The geological storage of CO2 is regulated by
of our times – temperatures are rising, drought the Directive on the geological storage of CO2
and wildfires are starting to occur more (‘the Directive’), which sets out the
frequently, rainfall patterns are shifting, requirements for safe and secure storage 3.
glaciers and snow are melting, and the global Member States (MS) retain the right to
mean sea level is rising. As one of the determine the areas within their territory from
signatories of the Paris Agreement, the which storage sites may be selected. MS also
European Union has adopted the European have the right not to allow storage on their
Climate Law in 2021 that states “solutions that territory at all (or to give priority to any other
are based on carbon capture and storage (CCS) use of the subsurface). The Directive has been
and carbon capture and use (CCU) technologies transposed into national legislation in all MS.
can play a role in decarbonisation, especially The Directive is accompanied by four non-
for the mitigation of process emissions in binding Guidance Documents (GD) which were
industry”. Twenty EU Member States (MS) released in 2011:
have included CCS in their National Energy and • GD1 – CO2 Storage Life Cycle Risk
Climate Plans (NECP) for the period 2021 – Management Framework
2030 1. • GD2 – Characterisation of the Storage
Complex, CO2 Stream Composition,
To enable emitters across Europe to connect to Monitoring and Corrective
safe geological CO2 storage, European non- Measures
discriminatory, open-access CO2 transport and • GD3 – Criteria for Transfer of
storage infrastructure will be crucial. For the Responsibility to the Competent
CO2 transport infrastructure there is a need for Authority
a new EU regulatory framework. The Zero • GD4 – Financial Security and Financial
Emissions Platform (ZEP) is currently preparing Mechanism
a proposal for how such a framework should be
Even if these Guidance Documents are non-
designed. ZEP has proposed an EU CCS and
binding, experience has shown that, at times,
CCU strategy 2 where the focus is the successful
these GDs are treated as binding. Geological
development and large-scale deployment of
storage of CO2 is allowed in nineteen countries
storage infrastructure.
in Europe – although, in some cases, certain
regions are excluded, or limits are imposed –

1 CO2Geonet. "State-of-play on CO2 geological storage in 32 European countries — an update" (2021).

2 Zero Emissions Platform. EU Strategy for CCS and CCU (2021).
3 Eur-Lex. Directive 2009/31/EC of the European Parliament and of the Council of 23 April 2009 on the geological

storage of carbon dioxide.

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while it is prohibited to store CO2 geologically does not provide all desired details. Member
in nine countries 4. This means that CO2 storage States are responsible for the interpretation of
activities in Europe will have to comply with the framework, transposition, and application
the Directive. Permit applications and draft of the Directive. Both project developers and
permits for CO2 storage are required to be competent authorities will be developing
submitted by MS to the European Commission experience in translating the requirements set
(‘the Commission’) for opinion. out in the Directive into effective and efficient
practical requirements and this process will
The Directive “establishes a legal framework challenge the first wave of projects. Indeed,
for the geological storage of CO2 and specifies based on their experience in CO2 storage
that environmentally safe CO2 geological development and their interactions with
storage means the permanent containment of regulatory bodies in several Member States,
CO2 in such a way as to prevent and, where this ZEP has found that there might be ambiguity in
is not possible, eliminate as far as possible the way the Directive is interpreted.
negative effects and any risk to the
environment and human health” 5. Key
elements of the Directive are:
1.3 Objective of the report
• the requirement to set up a The aim of this report is to facilitate the work
Measurement, Monitoring and of operators and public authorities working on
Verification programme that is fit for the deployment of CO2 storage projects. The
purpose; recommendations provided here aim to
• the transfer of liability after the end of improve the guidance documents supporting
injection and after a post-injection the Directive on the geological storage of CO2
period (until CO2 has become stable in and provide stakeholders involved in CO2
the reservoir); and storage projects with the best possible advice.
• the provision of a financial security for This report brings together results and findings
both is expected – e.g., post-injection of several first-of-a-kind CO2 storage projects
monitoring, facilities removal – and that have been or are being developed under
unforeseen cost – e.g., post-closure the Directive, for the benefit of new regulators
leakage and remediation. and project developers. Where possible or
relevant, suggestions are given to competent
An assessment of the Directive was carried out authorities or project developers to speed up
in 2015, following the timeline set out in Article and facilitate the development of future
38 of the Directive. At that time, the storage projects.
Commission concluded that there was
insufficient experience with application of the This report aims to be a reliable, independent
Directive to perform an in-depth assessment of reference document for authorities and
its effectiveness and efficiency 6. A review of applicants, by addressing uncertainties,
the Directive was delayed until more suggesting potential solutions and providing
experience with CCS in the EU becomes recommendations in the dialogue between
available. operators and competent authorities. The
The Directive is a legal framework, as such it

4 CO2Geonet. “State-of-play on CO2 geological storage in 32 European countries — an update” (2021).

5 European Commission website. Implementation of the CCS Directive. Guidance Document 1.
6 European Commission. Report on review of Directive 2009/31/EC on the geological storage of carbon dioxide

(2015). Annex 2.

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authors of this report have experience in
applying for permits for CO2 storage in the EU
and the UK.

The report does not request changes to the

Directive. Nor has a need been identified for
further or more detailed requirements in the
Guidance Documents. Several storage permit
applications have been developed under the
Directive and increasing experience with
regulators and project developers is already
showing evidence of evolving interpretation of
the Directive. The report offers suggestions to
improve the Guidance Documents, which also
aim to support regulators and project
developers.

This report discusses the following topics:

• Learnings from the storage permit
application process (Section 2)
• How the Directive applies to different
storage types and how risks impact
closure (Section 3)
• How their typical risks can be managed
through injection system design,
monitoring, and operation (also
Section 3),
• And how these risks impact closure,
handover (Section 5) and financial
security (Section 6).

Section 4 discusses some of the key issues

around the transition from hydrocarbon
production to CO2 storage. These are related to
the interplay between legislation on
exploration and production activities and
licenses on the one hand, and exploration and
storage activities and licenses on the other.
Section 7 discusses combining hydrocarbon
production and CO2 storage. The findings in
this report may be used in an update of the
Guidance Documents to the Directive.
Proposed improvements to the existing
Guidance Documents are listed in the Annex.

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2. Storage permit application

The Directive establishes a legal framework for imposing restrictions or requirements for
the environmentally safe geological storage of future projects. Before detailed technical
CO2 with the purpose of permanent requirements can be properly defined, more
containment to prevent negative effects and experience with CO2 storage projects still
risks to environment and human health. needs to be accumulated to sufficiently cover
Member States need to ensure that storage the diversity of storage cases.
permits are awarded on the basis of objective,
published and non-discriminatory criteria.
Nevertheless, CO2 storage developers should
2.1 Data about the potential
face similar requirements for the permitting operator
and operation of a storage project across
This subsection addresses the need for a fully
Member States.
transparent communication of a) the
requirements potential operator(s) need to be
Once the Directive is implemented in
proven technically competent for CO2 storage
legislation, Member States still have the right
operation, and b) the related evaluation
to adopt national provisions, e.g., to provide
criteria. Flexibility needs to be granted with
more clarity on the requirements. Practical
regard to modifications of the operator’s
experience from the storage license
organisation, which can potentially be required
applications in the Netherlands (P18-4 in 2011,
at a later stage.
P18-2 in 2021 7) has shown that some parts of
the Directive (and Guidance Documents) could
The competent authorities (CA) should be fully
benefit from increased clarity regarding the
transparent on the requirements potential
intent and expectations around content and
operator(s) need to submit to successfully
deliverables, and better describe potential
demonstrate technical competence. This could
criteria that must be taken into consideration
be supported by providing a detailed list of
before starting the storage license application
essential requirements and evaluation criteria
process. These elements of the Directive are
that form the basis for their review. During the
discussed below.
permitting process, some flexibility is needed
in case of a reorganisation on the applicant’s
The required clarifications could find a place in
side.
an update of the Guidance documents. The
focus should be set on specifying functional
Information about the applicant is of course
requirements instead of unnecessarily
part of the storage permit and therefore to be

7 Website of the Rijksdienst voor Ondernemend Nederland (Netherlands Enterprise Agency). Onderwerpen
(Topics). Bureau Energie projecten (Office of Energy Projects). Lopende projecten (Ongoing projects). Porthos
Transport en opslag van CO2 (Porthos Transport and storage of CO2).

11
communicated to the CA. Any changes related The definition and characterisation of the
to these details, but also regarding storage complex is an essential part in the
modifications to the operator’s organisation storage license application, in particular in
structure, need to be provided and might relation to containment requirements. This
initiate another full review. In case of the involves, among others, a careful definition of
latter, the CA needs to make sure that the the caprock, especially where several sealing
same evaluation criteria are applied with the layers are included in the storage complex. In
same level of detail. In general, however, a such a case, one needs to define the main
storage permit application is submitted several (“primary”) caprock and the additional
years prior to the start of injection (ca. 4-5 (“secondary”), shallower layer with sealing
years). This means that the details of the potential. Annex I of the Directive and GD 2
organisation, roles, legal entities etc. will not provide a high-level overview of the main steps
be established at this early stage. The CA needs to be followed by the operator for the
to make sure that these aspects shall not characterisation and assessment of the storage
interfere with the more technical application. complex and surrounding area, but do not
The final proof of competence can therefore indicate the level of detail of the underlying
realistically be done months before the actual studies. This provides the flexibility to perform
injection once the establishment of the legal site-specific analyses.
entities has been completed.
While site and complex are defined in the
To summarise, these are the Directive, the translation of these concepts
recommendations to MS: into licensing in MS is, in essence, left to the
• CAs are advised to provide clarity project developer and CA. The bounds of the
around the requirements for CO2 storage complex, highly relevant to project
storage permit applicants developers, will be strongly site specific. In
• Given the relatively long duration of a addition to the limits of the storage complex,
storage project, there should be some storage capacity is also one of the key
flexibility in the permitting process, properties that define the viability of a storage
related to changes in the organisation site. CA guidance in this area would be needed
(e.g., legal entities) of the storage at an early stage of storage feasibility
project. assessment. Therefore, consultation and
discussion between the project developer and
the CA should start before project
2.2 Characterisation of the development reaches an advanced level and
should be held on a regular basis.
storage site and complex
Characterisation is an essential part in the Apart from activities related to the CO2 storage
storage license application. A review of other project, which will happen within the storage
activities planned in the area is crucial to complex, activities above or below the storage
ensure safe storage operation. Containment of complex also need to be addressed, (e.g.,
the storage site is key and requirements for the installation of wind farms). These activities
assessment need to be communicated by the may hinder monitoring plans and could
CA at an early stage of the license application therefore potentially hold up CCS project
process. development. New projects should therefore
consult with ongoing projects and take into

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account their impact. In case of interference, subsurface activities (causing changes
existing projects should have the right to in pressure).
object. The Dutch “Noordzee akkoord 8” may • It is advised that storage in depleted
already be a good structure to manage fields should be equally addressed in
different uses of the Dutch North Sea sector. the GDs than storage in saline aquifers,
as their properties may lead to
Many operators are now employing structured different criteria, risks and timelines
risk assessment techniques to demonstrate that are mores tringent compared to
that containment is expected to be secure. storage in deep saline aquifers.
There is still a lot of uncertainty, however, in
areas where expert opinion judges that the
geological and engineering evidence will 2.3 CO2 purity & Injection
indicate storage security, but where there is This subsection highlights the importance to
not direct “proof”. Operators spend a lot of clearly communicate the functional
time debating if the CA will agree with the requirements for storage operation and
operator assessment or not. Some CAs are addresses the discussion about CO2
willing to engage early on, while others take specifications.
the position of “submit the permit application
and we will make an assessment”. It would be The CA could support the applicants by sharing
recommended that the GDs encourage CAs to functional requirements regarding storage
engage early and often in establishing their operation, whereby safe storage is the main
acceptance or otherwise of the operator’s goal. For example, it is essential to know the
containment assessment. Furthermore, the type of maximum allowed pressure (initial,
Directive and GDs focus on aspects of CO2 hydrostatic etc.) and its reference (depth). In
storage in (deep saline) aquifers without addition, the expected pressure safety margin
reference to storage in depleted hydrocarbon needs to be communicated upfront. It is
reservoirs. recommended that site-specific geo-
mechanical assessments and modelling are
The following recommendations are made: taken into account for this purpose.
• it is recommended that CAs engage
early and often in the development of Furthermore, the information from GD 2 that a
storage projects, specifically in relation CO2 stream needs to consist “overwhelmingly
with the definition of the boundaries of carbon dioxide” is not specific but should
of the project (i.e., storage site and prevent a disposal of other waste products via
storage complex), and potential the CO2 flow. Potential impact on pipeline and
interference with other activities in the storage integrity, but also public health and
area. environment, that might be related to CO2
• New projects need to consult with stream composition, needs to and will be
ongoing projects. There should be the critically evaluated by the CA in the course of
right to object to activities impacting an environmental impact assessment.
the viability of an ongoing project. This However, the GD could provide support by
includes surface (pipelines, power describing the considerations that might apply
cables, wind farms etc.) and for different aspects of the CCS chain and are

8 Website of Noordzeeloket. Nieuws (News). Noordzeeakkoord (North Sea Agreement) (2020).

13
related to CO2 specifications. Corrosion of CCS chain, including corrosion and
transport facilities, well material and other safety issues.
equipment due to impurities, wet conditions, • The EU should support the
solids etc. needs to be addressed, along with development of a common
safety issues for local population, e.g., understanding on CO2 specifications,
regarding H2S content. Based on current CCS e.g., by funding further research and
experience, a definitive standard for CO2 inviting relevant experts to establish a
specifications cannot be established, i.e., they benchmark satisfying all parts of the
should therefore be agreed on a case by base- CCS chain (from emitter via
basis. The GDs (notably GD 2) should, pipeline/shipping transport to
therefore, advocate for possible limits to storage). Such research projects
certain impurities for HSE reasons but leave should investigate the interaction of
the operability of the CO2 stream to the impurities within the CO2 stream with
projects. The purity of the CO2 stream should pipelines, wells, storage formations
have a technical operational basis, not a legal etc.
or permitting basis.

An EU-wide approach could promote the 2.4 Seismicity & Monitoring

development of a common understanding of EU-wide approved CCS-specific technical
CO2 specifications, their impact on all parts of standards are generally very limited or not
the CCS chain and the process of reaching existent (e.g., well abandonment, seismic risk
interoperability. A future EU standard for CO2 analysis and monitoring). It would be useful if
specifications would be highly recommended the GDs were to provide some guidance about
in light of a unique capturing process on the the minimum technical requirements that
emitter’s side, but, more importantly, for need to be met when standards of related
future cross border CO2 transport provided activities are used as reference while CCS-
that this does not prevent perfectly good specific standards are still unavailable.
projects by imposing unnecessarily restrictive
limits on contaminants. A risk-based approach is beneficial, especially
when assessing risk of containment and
Both topics discussed here, pressure limits in induced seismicity. One suggestion can be to
the storage site and composition of the CO2, make use of the bow-tie method 9, which
will have a strong impact on the underlying appears to be well suited to CO2 storage
business case of a CO2 storage project. To projects. The bow-tie risk assessment also
summarise, these are the recommendations reflects the nature of the barriers to prevent
suggested improvements to the GD: threats and mitigate consequences related to
• The CA should clearly communicate a potential hazard. In addition, expert
the functional requirements to storage judgement melded with quantitative failure
operations from the beginning. frequency data is used to analyse risk / hazard.
• The GD should describe the Furthermore, the GDs could also discuss the
considerations and possible limits that level of acceptable risk (e.g., the level of
might apply for different aspects of the seismicity onshore vs offshore). Another
example is HSE risk assessments, which need

9 Website of BVT Engineering Professional Services. Using the bow tie method to develop critical risk controls.

14
to be done for environmental and personal projects, onshore and offshore. Suggestions
safety. Would extra flexibility in case of are made in the Annex to improve the GD2 by
unmanned offshore injection sites be the addition of an attribution step in the
acceptable in that case? Such considerations process before triggering quantification
would have a considerable impact on the monitoring11.
closure plans for the storage complex and
subsequent post-abandonment monitoring The following recommendations to EU are
and allow some room for maneuver – within made with regard to suggested improvements
the accepted limits – during the CO2 injection to the GD:
period. • While CCS-specific standards remain
non-existent, the GDs could provide
The focus on safety is essential but needs to be support by discussing the applicability
reasonable with regard to what is technically of standards from other related
feasible (site-specific) and what can be activities; relevant topics include well
delivered when (ALARP 10). The latter requires abandonment, seismic risk analysis
mutual understanding between authorities and monitoring.
and CCS operators, especially when it comes to • The sections on monitoring in the GDs
the level of detail of provisional versus final could be extended with a discussion
versions of risk management, monitoring, around ‘acceptable risk’, applied to
closure, and corrective measures plans (see different storage options, such as
also the next subsection). The combination of onshore vs offshore.
proven technical capability, focus on safety via • GDs could be updated regarding
a risk-based approach, along with a monitoring, taking on board recent
transparent and open communication can also advances.
help to increase public acceptance.

Since the drafting of the Directive and the 2.5 Permit documents &
Guidance Documents, monitoring techniques
have made progress, including in what is updates
known as ‘attribution monitoring’. These are a This subsection addresses the need for a
suite of techniques for surface and near- certain level of flexibility regarding potential
surface monitoring that enable an anomaly of updates of permit documents at a later stage,
higher CO2 to be determined whether it is from once new data becomes available. Mutual
the stored CO2 or from another origin such as trust based on frequent communication
biogenic sources. This is important because, as between the CA and the operator will be a
it is written, when monitoring under the prerequisite for a successful permit
Directive suspects a leak, it triggers monitoring application.
under the EU ETS Directive to quantity
emissions, whether or not they are from the According to the Directive, several plans and
CO2 storage site. These attribution techniques assessments need to be submitted in the
have been tested and proven at several course of the storage permit application:
projects including at controlled release

10ScienceDirect. “As Low as Reasonably Practicable (Process Safety)”, Bai and Jin (2016).
11International Journal of Greenhouse Gas Control. “Improving monitoring protocols for CO2 geological storage
with technical advances in CO2 attribution monitoring”, Dixon and Romanak (2015).

15
 • Assessment of CO2 storage safety ambiguities related to the application process
including risk management; and the detail of its requirements. Transparent
• Monitoring plan; discussions providing consistent information
• Abandonment / Closure plan; could be ensured by assigning spokespeople,
• Corrective measures plan. preferably unchanging over the whole period
of preparation and the storage application
In addition to the above, local regulations may process itself (3-10 years expected). After the
require additional plans and assessments as start of injection, CAs may want to have
part of the permit application. experience exchange sessions to discuss data
and potential anomalies. This could be done by
At the time of the submission of the introducing a Technical Committee per storage
application, not all details of the injection and site where the CA and their advisors together
storage system are available. This explains why with the CO2 storage operator have a seat.
these plans are “interim” versions. These initial
documents already need to have sufficient To summarise, these are the
quality and level of detail, which again recommendations to Member States:
underlines the importance of clear
• Early engagement of CAs is needed to
requirements communicated upfront. After
provide clarity (e.g., on the required
review of the storage application documents,
level of detail in the interim
the CA can award a storage permit if the
documents/plans) and guidance
documents are regarded as sufficient but will
where needed and to avoid
insist that the four documents be updated
misunderstandings and delays.
before first injection (and again after a defined
• It is suggested to CAs that the delivery
period). When the Front End Engineering and
of the updates of the documents/plans
Design (FEED) is completed and the
may be done more efficiently, shortly
parameters of the final transport and injection
after the commissioning phase of the
system are known, the documents can be
storage system.
updated. However, an update of the
• A well-organised project oversight and
documents is likely to be made once the first
support process after the start of
monitoring and injection data are available
injection would be beneficial.
during the system’s commissioning phase. This
may include changes to the monitoring plan,
following improved insight in the storage
system derived from early injection and
monitoring data.

To enable a good understanding of the

requirements for a storage permit application,
frequent communication, e.g., through open
discussions between operators and CA,
including their technical advisors, would be
beneficial already at an early stage. Such a low-
threshold approach would provide more clarity
and early guidance to the applicants and could
avoid delays caused by misunderstandings or

16
3. Storage types / principles

3.1 Introduction
There are a range of deep geological storage Storage Resource for Europe has been
options for CO2, including saline aquifers and attempted through several research projects.
depleted/depleting hydrocarbon fields (Figure Where data is available, CO2 storage resources
1). have been identified through European

research projects such as FP7 CO2StoP and

Figure 1: Injection of CO2 into multiple geological H2020 ESTMAP. These are displayed on the
formations at a storage site; a saline aquifer (upper EGDI platform 13. Data availability and maturity
reservoir) and a depleted oil field (lower reservoir). Image
of assessment varies.
courtesy Shell (Tucker 2018).

The identification of storage sites requires Potential storage sites or stores need to fulfil
exploration to characterise and assess the essential criteria of having sufficient
potential storage sites. The CO2 Storage commercially accessible capacity for the
Resources Management System 12 provides a desired quantities of CO2. This capacity
consistent approach to describing projects and typically comprises well-connected natural
associated storable quantities, progressing spaces (pores/fractures) within the rock. The
from Prospective Storage Resources to other prerequisite for a potential geological
Commercial Capacity. An assessment of Total store is that there must be high confidence the

12 Society of Petroleum Engineers. “CO2 Storage Resources Management System” (2017).

13 Website of the European Geological Data Infrastructure. Map viewer.

17
injected CO2 will remain securely trapped consideration of pressure support and
within the storage site, which is usually permeability barriers.
provided by an overlying impermeable seal
that can trap the buoyant CO2. Additionally, ETI (2016) and Tucker (2018) categorise stores
storage sites are usually selected such that in terms of connectivity and discuss associated
lateral movement of the CO2 is restricted by implications 1415. A summary is presented here:
the structural or storage formation rock • Fully confined (or closed) stores;
properties of the geological trap, as lower storage reservoir is hydraulically
permeability barriers reduce the area potential isolated and the CO2 is trapped by
for lateral migration beyond storage complex structural/stratigraphic permeability
boundaries and therefore, the area that needs barriers (Figure 2b). Where
to be characterised and monitored to provide hydrocarbons have been extracted
assurance that the CO2 is securely stored. To from such stores, low reservoir
enable efficient use of the potential capacity, pressures can result. Where these
geological CO2 storage sites are usually structures are filled with brine,
selected so that CO2 is stored at sufficient pressure management will be required
pressure to be in a dense liquid-like phase to avoid increasing pressure to the
(typically below approximately 800 m). point where trap integrity is negatively
impacted.
For stores with sufficient capacity, the next • Partially-confined (or open) stores;
consideration is how much of the pore volume where buoyant CO2 is trapped by
can be utilised in a technically and structural and/or lithostratigraphic
economically viable way. This is largely boundaries but hydraulic connection
controlled by the permeability (connection enables pressure equilibration over
between spaces within the rock) and time. Geological permeability barriers
connectivity of the store to surrounding rock retain the buoyant CO2 within a
bodies. CO2 injection will increase pressure confined area (Figure 2a). These traps
within the storage reservoir. The impact of this may contain (or may have contained)
pressure increase will depend on the hydrocarbons and may be connected
connected space within the storage reservoir, to a large saline aquifer system. As oil
which may extend far beyond the limits that and gas are extracted, depending on
will be reached by the injected CO2. Pressure the connected aquifer, pressure may
increase will be more rapid in stores that have be (partially) maintained as saline
nearby impermeable barriers. Connectivity of water flows into the trap to replace the
the storage reservoir that allows outflow or hydrocarbons. Pressure support via
inflow of fluids is also important: if a potential hydraulic connection to the trap will
store is well connected, then injected CO2 can affect CO2 storage capacity and
more easily displace native pore fluids (mostly injection strategies.
salty water) increasing storage potential. The • Unconfined stores; CO2 is injected at
pressure increase may raise pressure above depth into a large hydraulically
the initial pressure of the store. Assessing connected storage formation. CO2 is
usable storage capacity therefore requires retained through dissolution and

14 Energy Technologies Institute. “Progressing Development of the UK’s Strategic Carbon Dioxide Storage
Resource” (2016).
15 IOPscience. "Carbon Capture and Storage", Tucker (2018).

18
 residual trapping (i.e. CO2 left behind formations – termed sub-hydrostatic) if they so
as the plume migrates – Figure 2c). choose. In theory a simple pressure gauge and
Where these potential stores have a application of a variation of the ideal gas law
high degree of hydraulic connectivity, can completely monitor such a store.
careful resolution of issues, with
regard to lateral confinement and the A key advantage of depleted fields without
main mode of trapping the CO2 pressure support is that high injection rates are
underneath the seal, is required. possible without risk for too high local pressure
(as no water has to be pushed away) nor a risk
of unstable displacement and potential escape
of CO2 under any spill point. Confined stores,
where the final pressure is maintained below
hydrostatic, reduce the chance of CO2 escaping
during injection as any well-related open
pathway will see fluids flow into the store.
After closure the well pathways are plugged
and geological pathways will have been
Figure 2: Storage categories (Tucker, 2018), courtesy Shell excluded by characterization helped by the
fact that the gas field existed and was
For open and partially open stores, the demonstrated to be highly depleted. It is
pressure footprint will be larger than the CO2 possible to inject above initial pressure till near
footprint and the implications of this in terms the formation strength of the caprock seal, but
of storage integrity and impacts on adjacent there is not much scope for expansion due to
users of the subsurface require consideration. rapid pressure rise per injected mass.
Examples of confined hydrocarbon stores
without pressure support are the P18-2 and
3.2 Depleted hydrocarbon P18-4 proposed storage sites of the PORTHOS
fields, without pressure project in Rotterdam.

support (confined stores) 3.3 Depleted hydrocarbon

Where the pressure has been reduced, this
offers the opportunity to achieve high storage fields, with pressure support
efficiency since the pore space is readily
available. One challenge where hydrocarbon (partially-confined stores)
fields lack pressure support is if very low Hydrocarbon fields may contain oil, gas,
pressures have been achieved as a result of condensate or a mixture of fluids. These stores
hydrocarbon extraction. In this highly depleted are generally at least partially confined since in
case CO2 injection strategies are required to an open hydraulically connected volume,
avoid solid hydrates forming at the injection hydrocarbons will migrate until trapped by
point. In confined stores the monitoring structural/stratigraphic features. The ability
requirements are very simple since the CO2 is for the store to trap buoyant fluids over
contained in the original “closed box”. The geological time scales is often considered
injection operator can also elect to leave the proven by the presence of hydrocarbons.
store at a reduced pressure (below that of the
water pressure in the surrounding rock

19
Where hydrocarbons have been extracted, resource (residual and dissolution trapping as
pressure is usually reduced compared with the well as structural trapping) CO2 injection wells
initial pressure which presents the opportunity might aim for the deeper flank of the structure
to inject CO2 until the initial site pressure is or stratigraphically deeper, but hydraulically
reached. This is generally viewed as a positive connected parts of the storage reservoir or re-
aspect since the trap has proven integrity at use of existing wells and top-down filling of the
the initial site pressure (provided the seal has trap is also an option and can result is lower
not been damaged by the reduction in exposure to geological risk and salt
pressure during hydrocarbon operations which precipitation challenges.
is extremely rare and unlikely). Medium to
strong pressure support can reduce available Well completions also need to consider the
capacity if the aim is to reach initial pressure of implications of the mixing of CO2 and reservoir
the storage reservoir. However, as long as fluids. An additional consideration is to assess
some overpressure is permitted, strong if there is the possibility for hydrocarbons to
pressure support is excellent for storage migrate out of the trap as CO2 is injected. A
because it demonstrates the ability to dissipate special case worth mentioning for storage in
pressure (what flows in quickly can flow out hydrocarbon fields is the potential pressure
quickly). In order to optimise use of the implications if CO2 is injected into depleted
potential store, where data and models regions of hydrocarbon fields where other
indicate trap integrity will be maintained, there regions are still producing if these areas are in
is the potential to inject substantial mass pressure communication.
above the initial pressure (little pressure
increase per injected mass). Data and models from the hydrocarbon
production history will inform and provide
Sites with pressure support (depleted confidence in models of the site response to
hydrocarbon fields, partially confined aquifers) CO2 injection. Hydrocarbons and CO2 can result
can achieve good storage efficiencies owing in a similar response from some geophysical
structural storage (buoyancy compared to techniques therefore monitoring CO2 injected
water helps) but typically require lower into depleted hydrocarbon fields requires a
injection rates and/or more wells as the water different monitoring programme to saline
that invaded the field has to be carefully aquifers. The risks are, however, different as
pushed back out. mentioned before: a depleted field is a trap
that has held hydrocarbons often for millions
A major consideration when evaluating re-use of years.
of hydrocarbon fields for CO2 storage is legacy
wells. These may need to be re-entered and
decommissioned to ensure storage integrity –
3.4 Producing hydrocarbon
at times this can require drilling of intersection fields
wells as the practice of leaving a clean seabed
Injection of CO2 into hydrocarbon fields can be
(safety and environmental reasons) means
used to accelerate recovery rates though
that once a well has been decommissioned
pressure support or by reducing viscosity of
offshore it is not possible to reattach. Onshore
the fluid moving through the reservoir. The
it can be done but excavation and a process
Directive does not regulate this activity, but
termed “reheading” a well. This is not a simple
states that, in case CO2 storage is an objective
or low-cost operation. For increased storage

20
in an enhanced production project, the case for the Gorgon CO2 store in Australia). At
Directive provisions for environmentally safe the depths considered for CO2 storage, the
storage of CO2 should apply. Some discussion reservoir fluids are usually much ‘saltier’ than
on ‘blended storage’ is included later in this seawater, with associated disposal
report. At the moment, no Enhanced Oil considerations. Pressure support and
Recovery (EOR) projects are operating under permeability barriers would control achievable
the Directive, i.e., projects injecting CO2 with injection rates and storage capacity.
the additional objective of storing CO2.
The contrast in properties between brine and
Experience from the USA, where CO2 is dense phase CO2 is an advantage for
injected into the Denver Unit of the Wasson monitoring. In addition, in aquifers that are not
field and is qualified for storage under the near to exploited oil or gas resources, there are
Environmental Protection Agency Part RR generally few or no legacy wells, avoiding the
regulation, is that the monitoring programme requirement for extensive well re-
for operating the EOR field was sufficient for completions. However, it must be noted that
storage monitoring. This is, naturally case although there are normally many fewer wells,
specific, but an operating EOR field collects a unfortunately these wells can often lack deep
lot of monitoring information to ensure that isolation plugs – there was no risk of
the economic objectives are achieved so it is hydrocarbon leakage so only shallow
likely that only small modifications to this will environmental plugs may have been installed.
be sufficient for CCS Monitoring, measuring This means leakage paths via legacy wells must
and verification (MMV). also be carefully assessed for saline
formations. Sleipner is an example of a
partially confined aquifer store, here the size of
3.5 Saline formations the store and reservoir properties are such
(partially-confined stores) that water production has not been necessary.
Saline aquifer stores can be open formations or
structural/stratigraphic traps. Saline aquifers 3.6 Saline formations
are generally believed to offer the largest
storage capacity. There are generally fewer (unconfined stores)
data than for hydrocarbon fields due to fewer Where a large saline aquifer without
commercial opportunities and therefore permeability barriers is being considered for
aquifer stores generally have greater storage, CO2 is retained through residual
uncertainty that needs to be resolved through trapping and dissolution trapping as the plume
site investigation, and unfortunately (for migrates. CO2 dissolves rapidly into contacted
operators and funders wanting pre-startup native brine pore fluids till the brine is CO2
confidence of sustained injection rates), often saturated then the process slows almost to a
during the early years of injection. halt (it can be forecasted to continue on a
millennial scale!).
CO2 injection would be expected to raise
pressure above initial levels owing to the As a result of the large hydraulically connected
presence of native brine. Where confined, volume, pressure impacts would be expected
brine production may be necessary to manage to be minimal, unless there are undetected
pressure in the storage reservoir (this is the permeability barriers. The location of the CO2

21
plume would need to be tracked to verify An iterative loop between data collection
modelling predictions and confirm location of (monitoring) and modelling will show
the plume with respect to geological and improving confidence that the storage site is
manmade (wells) potential leak paths. Saline well understood and ultimately that it can be
formations, like depleted fields, may also be safely decommissioned after cessation of
penetrated by legacy wells and these wells injection. A catalogue of monitoring
may need re-completion to ensure security of techniques is provided by IEAGHG 16. The
storage. maturity of these techniques in terms of
application to CO2 storage site varies from
proven to experimental. There is no shortage
3.7 Risk-led management of techniques either adapted from decades of
through monitoring, hydrocarbon exploration and production or
developed specifically for CO2 storage sites.
modelling and verification The applicability of these techniques to storage
Risk-led site management seeks to ensure sites will vary depending on the geological
secure storage of CO2 by managing and characteristics and fluids within the reservoir.
mitigating the identified risks at a specific site. It is common for the range of monitoring tools
Many risks will be common to all storage sites, to reduce over time as understanding of the
but the mitigation techniques and the available storage site increases and the value of
data to inform risk management will vary techniques is proven at a specific site.
(Table 1). Risk also varies over time as data is
collected during CO2 injection and the
response of the site is proven. There is a
common perception that geological risk is
highest at the cessation of injection (when
pressure is at its highest), however, this will be
mitigated by data collected during CO2
injection. Uncertainty in the ability of traps in
saline aquifers to contain the CO2 is higher
compared with traps in hydrocarbon fields that
have been proven to trap buoyant fluids of
geological timescales.

Monitoring storage sites enables operators to

provide assurance that the CO2 is securely
trapped and that the site is responding as
expected (Table 2). The monitoring footprint of
the site will depend on the extent of the
expected impacts of CO2 storage and the
identified risks for CO2 migration out of the
storage trap, here the benefit of fully/partially
confined stores is clear.

16 Website of IEA Greenhouse Gas. Monitoring Selection Tool.

22
Table 1: Summary of risks most applicable to various
storage types

Depleted field storage, Depleted field storage with Partially-confined saline Unconfined saline
no pressure support pressure support aquifer formation storage aquifer storage
If fully isolated with no If substantial or full hydraulic Pressure at or greater than Pressure impacts expected
hydraulic support: support then pressure may surrounding rock during to be small unless
pressure will be lower remain close to hydrostatic injection, pressure permeability barriers are
than surrounding rock and to the pressure in equilibration after injection present .
including after injection surrounding rocks. ceases: risk of loss of
ceases (operator choice), containment highest at end of
near-zero containment injection (highest pressure);
risk. then slowly decreases.
CO2 fully contained by CO2 may migrate outside CO2 may migrate outside CO2 not contained by
structure. Selection of the original gas/oil location the original gas/oil location structure; plume tracking
storage site always on and the storage site needs to and the storage site needs to required.
integrity basis. include the region to which include the region to which
the CO2 (and hydrocarbons) the CO2 might migrate.
might migrate.
Boundaries ensure CO2 CO2 tracking to confirm CO2 tracking to confirm Lack of boundaries
location is fully location over time and location over time. CO2 requires CO2 tracking to
constrained, differential demonstration of trend tracking to confirm location establish location over
pressure keeps CO2 in toward gravity stable over time and demonstration time and allow prediction
place. CO2 tracking serves equilibrium. of trend toward gravity stable of rate of migration and
limited to no purpose – equilibrium. ultimately forecasting of
this is a closed box with plume stability and
gas in it. progress toward leak risk
areas.
Injection and legacy wells Injection and legacy wells are Injection and legacy wells are Injection and legacy wells
are the only feasible once more the largest leak once more the largest leak are once more the largest
potential leak pathways risk. Monitoring during risk. Monitoring during leak risk. Monitoring
and these can be injection can demonstrate the injection can demonstrate the during injection can
monitored by simple point absence of leakage. absence of leakage. demonstrate the absence
monitoring techniques of leakage.
(onshore and offshore).
Only if pressure is
increased above initial (or
there is significant flow
into the system leading to
recharge) is leakage
possible – and again this
should be of a point
source nature and
detectable.

23
Table 2: Summary of monitoring requirements for various storage types

Depleted field storage, no Depleted field storage Partially-confined Unconfined saline

pressure support with pressure support saline aquifer aquifer storage
formation storage
No plume. CO2 mixes with residual Plume (CO2 + CO2 plume to be CO2 plume to be monitored
gas or oil inside sealed structure. hydrocarbons) to be monitored to prove to confirm it has not
monitored if it will stability (e.g. seismic). migrated outside the area
extend beyond original predicted by modelling
hydrocarbon location (e.g. seismic or observation
(e.g. seismic). wells, possibly with
geochemical sampling).

CO2 does not displace water. CO2 Blended CO2 + CO2 displaces and CO2 displaces and dissolves
blends with gas or oil. There is no hydrocarbon plume dissolves into water. into water. There is a
plume. 3D seismic cannot displaces and dissolves There is a plume which plume which can be
differentiate between CO2 and gas into water. There is a can be tracked with 3D tracked with 3D seismic
but there is the possibility to inject plume which can be seismic and maybe and maybe observation
into the water leg to improve tracked with 3D seismic observation wells. There is wells. There is a plume
residual trapping and increase and maybe observation a plume which can be which can be tracked with
storage resource by enhanced wells. tracked with 3D seismic, 3D seismic, also post-
dissolution, then CO2 plume would also post-injection. injection.
be visible.

Boundaries ensure CO2 location is CO2 tracking to confirm CO2 tracking to confirm Lack of boundaries requires
fully constrained. Differential location over time. location over time (e.g. CO2 tracking to establish
pressure keeps CO2 in place. seismic). location, hence monitoring
Monitoring requirement requirement.
significantly reduced, pressure
monitoring required.

Monitoring of injection (annuli and well pressures) and legacy wells (surface locations) to demonstrate that there are no
active flow pathways to atmosphere or water

24
4. Transition from production to
storage

Since depleted hydrocarbon reservoirs are becoming Regarding this topic, three potential cases have been
highly attractive for CO2 storage projects, the identified, which range from the situation where the
transition from previous production to future CO2 current operator aims to stop its current activities
storage activities needs to be planned in an (Case 1), intends to continue, and start a CCS-project
appropriate manner. (Case 2) or is blocking the current license (Case 3).

A hydrocarbon operator is obliged to place human

and environmental safety at the forefront of their
Case 1
plans. In addition, operators aim to reduce cost once It is assumed that the current operator aims to stop
an asset reaches the end of its life. This means that activities in the current production license area.
operators seek to safely decommission wells and The intent shall be reported to the authority upfront,
infrastructure as soon as possible after the end of such that other plans can be made, and slack can be
production operations. Even after hydrocarbon avoided. Smart handling with regard to
production has ceased it can still cost millions of euros decommissioning is crucial as infrastructure from
per year to maintain a platform, and even more to hydrocarbon production might be needed for later
upgrade facilities to make them ready for further CCS projects. Cost efficiency needs to be checked first,
decades of service for CO2 injection. Note too that as certain activities can only be done (from a cost
every visit to an offshore facility or every marine efficiency point of view) for a certain amount of time,
survey place staff at risk – this risk is managed to as e.g., mothballing. In any case, decommissioning
low as reasonably practicable (ALARP) but still exists. obligations must certainly be taken over, although the
The first step in the safety pyramid is to avoid the precise actor responsible for the takeover needs to be
activity that creates the risk. At the end of discussed. Since hydrocarbon operators often
hydrocarbon production rapid removal is always cooperate with partners for their activities, they also
beneficial, as the older the platform the more need to decide if they wish to stay in the field or leave,
corrosion takes place on legs and topsides. Finally, the since CO2 storage might not be part of their core
safest well is a plugged and abandoned well. As a business. In case they decide to leave, there needs to
result, there has to be a compelling reason for a be a discussion on how they will be reimbursed for the
production operator not to remove infrastructure as value of their assets (i.e., platform, wells, remaining
rapidly as possible. production left in the ground) and whether/to whom
they must pay the latest estimates of
This preference for rapid removal is at odds with the decommissioning (some of this is already covered in
desire to adapt multiple platforms and wells for CO2 hydrocarbon law). At this stage it needs to be noted
storage service in an orderly and planned way. Some that CO2 high pressure decommissioning is always
facilities might need to wait many years before much more expensive than depleted pressure gas
conversion to CO2 storage duty. decommissioning driven mainly by the need for full
bore formation plugs.

25
Tax leakage is a topic that must be addressed. In some
jurisdictions petroleum tax is much higher than
Case 2
It is assumed that the current operator aims to stay
standard corporation tax. Operators are allowed to
reclaim the cost of decommissioning against profits and start a CCS project within the current production
license area.
taxed in earlier years. If the facility is transferred to a
In any case, existing joint-venture partners need to be
CCS operator which might be exposed to lower
taken into account and will have to agree to give the
taxation, tax relief for decommissioning might be lost.
production license back or become partners on the
How will operators who leave the partnership be
new project. Reactions from joint venture partners
assessed for decommissioning costs when tax leakage
can vary between being extremely eager (they may
is involved? According to Article 6.1 of the Directive,
even wish to take over operatorship of the storage
Member States shall ensure that no storage site may
permit), to wishing an immediate (and profitable) exit.
be operated without a storage permit […], and that no
A discussion about the costs and reimbursements will
conflicting uses are permitted on the site. A carve out
follow. Reimbursement could be made either for
of the storage site from the production license is
share of the remaining production value left in the
therefore best done at production cessation. The
ground, or for assets “value" by being relieved of
storage site is officially part of a storage license when
in force, which it is likely to be on the day of first decommissioning liability (see paragraph on tax
leakage above) by the receiving party. Another open
injection many years later. So, there is a period with
question might, however, arise if none of the existing
the storage site outside any permit, but
decommissioning and other liabilities for the closed partners are interested in a participation. In this case
it needs to be defined who will be taking over their
reservoir, wells and maybe platform (if dedicated to
shares. In case there are no other interested parties,
single reservoir) must sit somewhere. It therefore
needs to be decided what liabilities sit with owner of this role might potentially have to be taken by the
State to ensure further progress in CCS. Eventually,
assets and which with production or storage license
other industrial partners may get on board, e.g .via an
holder. If everyone agrees to do a simultaneous carve
out/carve in, it is highly recommended to go for the application or bid round.
required preparations well in advance to avoid having
In addition, potential competition might come from
the carve out / carve in procedure delay the first
third parties that also want to start a CCS project
injection.
within the same license area. In such a case, the CA
needs to have smart strategy to evaluate all available
The following recommendations are made for Case 1:
project plans and therefore ensure that the permits
• The intent of the current operator (and
are granted on the basis of objective, transparent and
potential joint venture (JV) partners) shall be
non-discriminatory criteria. Proof of the technical
reported to the CA upfront, such that other
competence of the potential operator(s) certainly is
plans (e.g., re-use of existing infrastructure
an essential part of the storage application process
instead of decommissioning) can be made
(Article 7.2). The current operators are very likely to
and slack can be avoided.
have an advantageous position here, based on their
• The CA needs to decide on liabilities of asset
long-term activities and experience in the field,
owners and production license holders.
however, there is no priority to them according to the
• A clear pathway needs to be developed such
law. Based on the subsurface know-how they have
that any future storage operator is able to
gathered over the years, there’s most likely also no
access the information required to undertake
need for them to first apply for exploration storage
site appraisal activities (e.g., re-use of wells,
license to generate the information necessary for
well maintenance records, annulus pressure
selection of storage sites.
data, reservoir performance etc.).

26
Somewhat more clarity is needed on the priority given conditions in the annuli of existing wells, potentially
to exploration license holders, as indicated in Article causing sustained casing pressure, CO2, or brine flow
6.3 in the Directive. Except for Norway, where the to surface, and even integrity issues. These co-
storage license system is legally independent from the location issues should be discussed, and ideally
petroleum license system, it must be clear that a addressed in Guidance Documents and ideally also in
storage exploration permit cannot be awarded or held local legislation.
for a potential storage site that is already producing
and part of an existing production permit. The latter The following recommendations are made for Case 2:
seems obvious, especially when referring to those • The existing joint-venture partners need to be
parts of the Directive where it is given that Member asked upfront to agree to give the production
States shall ensure that no conflicting uses of the license back or become partners on the new
storage complex are permitted during the period of project.
validity of the permit. However, it is not specifically • In case existing partners do not want to
mentioned. continue, the State might decide to step in (or
alternatively find new partners) by taking
There is the interesting case where a storage license over their shares to ensure further progress in
is sought for a stratigraphic unit that is different from CCS.
the hydrocarbon producing unit. In the Norwegian • In case of competition between the current
Northern Lights project the Johansen formation is operator and interested third parties, the CA
deeper than the Sognefjord formation from which the needs to have smart strategy to evaluate all
Troll field produces. Exploration license 001 – the first available project plans and therefore ensure
exploitation license issued under the Norwegian CO2 that the permits are granted based on
storage regulations – does not really overlap with the objective, transparent and non-
Troll production license, but the CO2 plume is discriminatory criteria.
expected to ultimately (after Troll ceases production) • It is recommended that competition shall be
migrate to under the Troll field. In the UK the Strategic limited to open acreage, or returned
CO2 storage appraisal project (UK Strategic Storage production license areas, but never for
Appraisal Project UK SSAP, funded by DECC) identified potential storage sites inside existing
a potential Bunter store overlying the deeper production licenses (in the same stratigraphic
producing Schooner field. interval), to ensure no conflicting uses of
areas with granted licenses.
Apart from the exception given by the Norwegian • The GD, and ideally also MS, should provide
system, competition can generally be for open more clarity regarding consequences and
acreage, or returned production license areas, but responsibilities in case of a storage site being
never for potential storage sites inside existing used in a different stratigraphic interval (with
production licenses (in the same stratigraphic regard to decommissioning of wells, zonal
interval), to ensure no conflicting uses of areas with isolation to avoid damaging storage potential
granted licenses. Where a store is in a different etc.).
stratigraphic interval, questions start to arise around
decommissioning of wells that potentially penetrate
the store. It is recommended that MS consider the
consequences of overlaps and make it clear where
responsibility lies for zonal isolation so that storage
potential is not damaged. Similarly, injecting CO2 near
or above a producing field can alter the pressure

27
Case 3
It refers to the situation of an existing operator strategies as well as data acquisition
blocking a license, which in any case should be avoided recommendation.
to guarantee continuous progress in the energy
transition.
This case might explain why there is no clear priority
given to current operators in the storage application
process. To overcome this potential standoff, it is
recommended that operators holding production
licenses are asked to annually publish their plans (or
lack of plans) for CO2 storage for every field, especially
those listed and ranked high in a national CO2
potential storage database kept up to date by a
national authority. Guidance on how to manage a
field, and its abandonment, to enable future CO2
storage should be published. These should include
subsurface isolation strategies as well as data
acquisition recommendation.

Such a guideline would support further progress in the

future of CCS. In case operators are reluctant to store
CO2 it is recommended that they shall annually
publish their estimate of production cease date and
agree with the CA to market/advertise/offer high
ranking fields long in advance of production cease.
This means that data in huge quantities are being
made available to interested parties, e.g., through CO2
storage exploration licenses, and operator/JV parties
(who may be interested), being obliged to
negotiate/plan/submit storage permit applications.

The following recommendations are made for Case 3:

• It is recommended that operators holding
production licenses are asked to annually
publish their plans (or lack of plans) for CO2
storage for every field, especially those listed
and ranked high in a national CO2 potential
storage database kept up to date by a national
authority, ensuring data is appropriately
archived where a field does not immediately
transition to a storage site.
• A guideline should be published to provide
advice on how to manage a field, and its
abandonment, including subsurface isolation
•

28
5. Closure and transfer of
responsibility

Closure and subsequent transfer of responsibility to Any reference to minimum periods should be
the CA is allowed by the Directive when all available removed or ignored – there is no universal technical
evidence indicates that the stored CO2 will be justification for such periods. Each store should be
completely contained, when financial obligations evaluated in a site-specific manner, examining the
have been met (Article 20 – financial contribution to evolution of containment risk over time, and the
post-transfer costs), when the site has been sealed effect of conformance and containment monitoring
and the injection facilities have been removed, and during project life on constraining the forecast bounds
after a minimum period after closure, no shorter than of the risk evolution.
20 years (unless otherwise agreed with the CA).
The recommendation is therefore that criteria for
Different storage sites have differing risk profiles. The demonstration of permanent storage are discussed
difference in the risk profiles of the various storage and agreed with the CA on a case-by-case basis. For
types show that the criteria for transfer of structurally constrained storage the aim will be to
responsibility should primarily be based on technical demonstrate that the injected CO2 is approaching a
merits (elements of evidence showing that CO2 will gravity stable equilibrium in the store, and that the
remain safely stored) rather than on a minimum well penetrations and caprock seal system are
period. For instance, depending on confinement, the effective. If the store is in a depleted field with no
time to reach plume stability may vary immensely: it appreciable hydraulic connection to the wider
should be rapid in the case of a depleted reservoir formations, then the pressures will not increase,
without pressure support, while it can take years in barring some thermal effects, for millennia. If the
stores with pressure support. For a store is in hydraulic connection to a wider saline
structural/stratigraphic store it would be better to use formation, then the pressure might decline if the CO2
the term “approaching a gravity stable equilibrium” has been injected at rates that cause a local pressure
rather than “plume stability”. build-up or if the store was not depleted or might
increase if the store has not reached hydrostatic
The 20-year minimum monitoring post closure and equilibrium and is still recharging from a depleted
before transfer of responsibility to the CA and 30-year field state.
monitoring contribution post transfer to the State are
regarded as very unhelpful when trying to justify For migration assisted storage the key is to
investment in CO2 storage. It would be much more demonstrate that the plume will not approach or
helpful if the GD could lay out the framework in the interact with areas of enhanced leakage risk – this
context of the relevant risks, so that the CA agrees might be an obviously leaking fault zone, the end of
first the criteria for demonstration of permanent the caprock, an outcrop, or more likely legacy well
storage and then agrees the format of the post penetrations (Table 3).
transfer to the state monitoring, if any.

29
Table 3: post-closure monitoring
Depleted field Depleted field storage with Partially-confined saline Unconfined saline aquifer
storage, no pressure support aquifer formation storage storage
pressure support
No useful monitoring Post-injection and post-closure Post-injection and post-closure Post-injection and post-
is possible after monitoring possible – generally monitoring possible – generally closure monitoring possible.
closure. focused on wells. focused on wells.
Min 20 years + min 30 years,
Delays in closure Min 20 years + min 30 years, or Min 20 years + min 30 years, or or shorter if stability of plume
increase risk – wells shorter if progress toward shorter if progress toward can be proven or if it can be
are only possible gravity stable equilibrium can gravity stable equilibrium can shown that conformance is
leakage path. The risk be demonstrated. be demonstrated. calibrated and that forward
of blowout is greatest modelling shows no increase
when intervening in a in risk.
well. An open well is
always a risk.

Min 0 years
monitoring
Above-zone Above-zone monitoring Above-zone monitoring Above-zone monitoring
monitoring (overburden, seabed, water (overburden, seabed, water (overburden, seabed, water
(overburden, seabed, column): shallow seismic or column): shallow seismic or column): shallow seismic or
water column) serves seabed surveys may highlight seabed surveys may highlight seabed surveys may highlight
no purpose, but catastrophic breaches, catastrophic breaches, catastrophic breaches,
shallow seismic and otherwise for migration out of otherwise for migration out of otherwise for migration out
seabed surveys may storage complex to higher storage complex to high layers of storage complex to high
be sufficient. layers will not bear useful info will not bear useful info before layers will not bear useful
before centuries or more have centuries or more have info before centuries or more
elapsed. elapsed. have elapsed.

The key in all cases is to demonstrate that the risk of the storage operator is often requested to project the
a significant irregularity is decreasing over time. It is cost of storage at the beginning of the project. The
important to stress too that the monitoring does not duration of the closure period and the nature of
start at the end of the store, it generally starts at the monitoring can impact these costs. It would be
point of baseline characterisation and, in the case of a advantageous for projects if the expectation were
depleted field, starts at the beginning of production. that the provisional post closure plans and the
As a result, many stores will have between 30 years Financial Mechanism (FM) were not foreseen to
and 70 years of monitoring already booked. change (increase) in scope unless a significant
irregularity were to occur during site operations.
In all cases the characterisation process, combined
with monitoring during operation, is designed to
reduce the chances of catastrophic leakage to near
zero. It is highly likely, therefore, that closure and
handover can proceed much faster than the indicated
20 years. CCS projects require certainty – in general

30
6. Financial security

6.1 What is it? 6.2 What is the issue?

Article 19 of the Directive requires that operators set The main issue with the FS is that its amount can vary
up a Financial Security (FS) to be able to “meet the a lot depending on interpretations. If MS requires a
obligations of the permit”. The FS should be valid large FS, to be provided almost exclusively by the
before the start of injection, after closure and until the operator, this can:
transfer of responsibility. After the transfer of • Prevent “smaller” operators from acquiring a
responsibility, the Directive asks for a Financial storage permit, if they are not able to collect
Mechanism to cover the costs, mostly of long-term the funds upfront or provide enough financial
monitoring. This chapter focuses on the FS. guarantees.
• Increase the cost of CO2 storage for society as
The main principle behind the FS is that Member a whole: providing cash upfront is not “free”
States should not have to pay if the operator fails in and so it can be a substantial line in the
any way. Any permit awarded comes with associated operator’s budget. This means that the
requirements and so the FS should cover the costs of operator must increase its fee for storage to
these requirements, in the situation where the stay within its profitability target. In the end,
operator is not able or willing to pay.It is useful to if storage of CO2 is a service to society
distinguish expected and unexpected requirements. (mitigation of climate change), then this
Expected requirements are composed of: service becomes more expensive.
• Eventual continuation of operations
There is indeed an optimal range as a too small
• Monitoring and reporting during operations
amount of FS means that the MS will need to use
• Closure of the site (including well
public money to cover expenses if the operator just
abandonment)
stops.
• Post-closure monitoring

Unexpected requirements are those that arise in case The biggest issue in determining the correct range of
of leakage or significant irregularity: amount in the FS is in dealing with the unexpected
• Implementation of corrective measures requirements. By design, the likelihood of leakage or
• Additional monitoring significant irregularities should be low to very low. For
• Acquisition of emission credits in case of instance, ZEP indicated in a report a conservative
leakage to the atmosphere or the water value of 1.79% risk of a significant irregularity over
column. 500 years 17. We can illustrate the point with different
scenarios:
In practice, this FS can take many forms and GD4 lists • Scenario 0: operations happen as planned. No
many possibilities ranging from upfront cash deposits significant irregularity detected. The operator
to private insurances.

17Website of the Zero Emissions Platform. "CO2 Storage Safety in the North Sea: Implications of the CO2 Storage Directive"
(2019).

31
 fulfils all requirements of the Directive. So, 90% of the time, FS needed will be zero, 8.9% of
Amount of FS needed is €0. the time it will be €10 million, 1% of the time it will be
• Scenario 1a: operator ceases activity during €60 million and 0.1% of the time € 510 million.
injection, MS has to take over, continues If the MS requires a FS of €510 million, then it is too
operations for N years, then closes and large for most companies, and this can impede the
abandons the site. No significant irregularity deployment of CO2 storage.
occurs. The amount of FS needed is equal to On the other hand, expected costs are:
the cost of operations and monitoring for N (10*8.9%)+(60*1%)+(510*0.1%) = €2 million; but the
years, plus the cost of closure and post- MS cannot accept an amount based on expected costs
closure obligations. because € 2 million is useless 100% of the time (either
• Scenario 1b: operator ceases activity during not used at all, or not enough to cover any cost). This
injection; MS takes over for 5 years before illustrates why GD4 advises against using expected
transferring activities to another operator. costs for setting the FS.
The amount of FS needed is equal to the cost
of operations and monitoring for 5 years.
• Scenario 2: a significant irregularity is
6.3 Potential solutions
detected, and the operator takes the The previous part shows that it may be necessary to
appropriate corrective measures. Amount of have separate instruments for the “expected” and the
FS needed is € 0. “unexpected” parts.
• Scenario 3: a significant irregularity is
The main possibility to cover potentially large, but
detected, and the operator fails to take the
unlikely costs is to have risk-sharing mechanisms such
appropriate corrective measures. MS has to
as an insurance. Insurance schemes can be created
take the corrective measures, and then
with various shares of public and private funds. While
operate and close the site. Amount of FS
market maturity of CO2 storage is low, mostly public
needed is the cost of corrective measures
insurance schemes can provide enough leverage to
(including ETS credits) plus the cost of
help the development of CO2 storage. Then Public-
operations and monitoring for N years and
Private Partnership (PPP) can be developed when
cost of closure and post-closure obligations.
market maturity increases, and 100% private
Scenario 3 is significantly less likely than all other insurances can be used in a fully mature market.
scenarios (assuming it is not unlikely that an operator Public funds could be set on a European, regional
will default), and yet is probably an order of (e.g., for North Sea region, or onshore western
magnitude above the others in terms of costs. For Europe) or national level. Groups of large companies
illustrative purposes, let us assume that costs for such as OGCI could also help to organise such risk
expected requirements (i.e., cost of routine sharing mechanisms schemes. Such funds are
monitoring, operations, and closure) is about €10 mentioned in GD4.
million. We make the hypotheses of two kinds of
irregularities: “moderate” irregularities, which have a These types of solutions are discussed for instance in
1% chance of happening and may cost up to €50 the field of deep geothermal energy: see for example
million to remediate; “dramatic” irregularities, which the H2020 GEORISK project 18. Seyidov & Weimann
have a 0.1% chance of happening and may cost up to (2020) 19 show how the insurance schemes can
€500 million to remediate. Let us also assume that the transition depending on market maturity. The permit
operator always defaults when there is an irregularity. application for storage of the Porthos project in the

18 Website of the GEORISK project.

19 Website of the GEORISK project. Proposal for a transition in the Risk Mitigation Schemes, Seyidov and Weimann (2020).

32
Netherlands, in the depleted offshore P18-2 gas field
proposes a FS fund that contains an insurance for the
rare events. The preliminary response from the
regulator is to accept this solution 20. The insurance
costs appear to be M€ 25-30 (see table on page 51 of
the reference). Permit annexes on the insurance costs
are not publicly available.

If a shared risk mechanisms (such as insurance) is not

possible, then the recommendation for individual
projects, is to base the required amounts on a
percentile of costs (e.g. P75 or P90), not on expected
values. In the example above, it may be acceptable to
cover moderate irregularities, but not large
irregularities. For this to be acceptable, MS may
decide to have a robust and independent review of
the risks and to impose risk criteria for low probability
events.

6.4 Missing definition

There is a missing definition in the Directive. It would
be very helpful if a definition could be added to GD4.
‘Associated surface and injection facilities’ means the
well bores, the equipment inside the wells used for
injection or monitoring of CO2 and the wellheads.
These make up part of the storage site until the wells
are eventually sealed and the wellheads and casing
down to regulated depth removed. These do not
include any equipment or installations beyond the
wellheads since these play no part in sealing CO2
underground.
Ideas:
1) A fund for pooled liability, which could be set
up along NER or Innovation Fund lines (i.e.,
using emission allowances);
2) Create a post-closure company;
3) Government underwriting during early
phases of CCS roll-out; and
4) Proper insurance system once enough CCS
projects are ongoing, where ‘enough’ remains
to be defined.

20Website of the Rijksdienst voor Ondernemend Nederland (Netherlands Enterprise Agency). Ontwerpbesluit vergunning voor
het permanent opslaan van CO2 in het opslagvoorkomen P18-2 (Draft decision permit for the permanent storage of CO2 in
storage facility P18-2). Article 20.

33
7. Blended storage cost. In this scenario the storage project development

In many European countries, mainly in the central, cost. In this scenario the storage project development
eastern, and south-eastern part of the continent, can benefit from the knowledge and experience of the
depleted and nearly depleted onshore hydrocarbon field operator and from synergies between
fields will be the primary target of first pilot and operations. If CO2 is recycled, additional energy is
demonstration CO2 storage projects (ECO-BASE required for separation and, depending on the source
2017 21, ENOS 2020 22 , STRATEGY CCUS 2021 23). These of the energy, might reduce the net climate benefit
are usually the sites with a higher level of geological compared to a pure storage operation. Similar merits
knowledge and often reduced pressure of the can be expected for combining CO2 storage with oil
reservoirs, and opportunities to reduce cost by production in depleting oil fields.
making use of existing wells and surface facilities. Interestingly there are other benefits of the hybrid
When compared with saline aquifers where all of this approach. Projects that look to take advantage of low-
is not present, these can be much more cost effective pressure depleted fields face the challenge of
as a climate mitigation response, though they might managing the CO2 phase envelope and related Joule
well be of smaller total storage resource. Thomson cooling. This means that they often have to
have a slow start with gas phase injection or need to
Consider the case of a large gas field, still in heat the CO2 (requiring energy and possibly producing
production. In one scenario the field stops production, some GHG emissions). Early start of injection might
possibly early, and transitions to storage. The field well avoid this challenge, albeit bringing with it the
owners need to be compensated for the lost gas potential need for gas processing and re-injection of
production to be motivated to change the field into a any produced CO2.
CO2 storage site. Some of the facilities need to be
maintained while the field is not producing, but the In an oil field combining hydrocarbon production with
old facilities can be removed, and new ones installed. CO2 injection may reduce the need for water injection
In the second scenario injection starts while the field to maintain pressure. In the USA some fields use CO2
is still producing. The injectors are naturally placed as as the pressure support fluid as opposed to water,
far away from the producers as possible. They might either because of water availability or reservoir or oil
well increase pressure and CO2 may flow to the properties. This is CO2 for secondary recovery not
producers. Any producer where CO2 is detected is tertiary (or EOR) recovery. The downside of a switch
either shut in or diverted to a CO2 removal unit (and to CO2 support might be the need to replace all steel
the CO2 is diverted back to injection). The downside is on surface and in wells due to risk of corrosion if the
the need to add injection and gas separation facilities field is not already sour service (CO2 or H2S naturally
while still maintaining production facilities, but the present in the produced fluids). In some reservoirs the
additional produced gas sales can compensate for the maintenance of reservoir pressure reduces or

21 ECOBASE. ‘Establishing CO2 enhanced oil recovery Business advantages in South Eastern Europe’.
22 ENOS. “Towards a strategic development plan for CO2-EOR in the Vienna Basin” (2020).
23 Strategy CCUS. "Description of CCUS business cases in Eight southern European regions" (2021).

34
eliminates the risk of earthquakes and tremors. As the the tail end of hydrocarbon production with the first
CO2 concentration increases at wellheads the gas phase of CO2 injection in cases where this is an option.
phase becomes less valuable or useable unless However, future storage site operators, possible
oxyburners are installed and a supply of oxygen is investors, as well as regulators need clear assurance
available, or gas treatment/sweetening is installed. that:
The export from the installation becomes electricity 1. Temporary combination of CO2 storage as
and oil. The supply of CO2 then comes from the described by the Directive and enhanced
burning of own produced gas with the oxyburner flue hydrocarbon recovery is accepted from a legal
gas reinjected as near pure CO2. and regulatory point of view;
2. The CO2 accumulated and trapped in the
The second scenario is attractive, but the transition reservoir during the “blended storage” phase is
period from pure production to pure storage is, considered geologically stored within the
however, challenging from both technical and meaning of the Directive, Article 3;
regulatory points of view. A supporting argument is 3. The CO2 back produced from the reservoir
that hydrocarbons produced with help of CO2 together with the hydrocarbons after CO2
injection have significantly lower carbon footprint breakthrough to the production wells, captured
than oil and gas produced by traditional methods by a gas separation unit and re-injected is still
(e.g., Stewart & Haszeldine (2014) 24), largely imported considered stored, and only the CO2 leaked or
to Europe from other parts of the world. This is an vented from the surface facilities is reported as
important factor for the transition period before the emitted pursuant to the Commission
use of fossil hydrocarbons can be fully abandoned. Implementing Regulation 2018/2066 on the
The Directive handles the transition period only monitoring and reporting of greenhouse gas
vaguely in Article 20, as combination of Enhanced emissions 25;
Hydrocarbon Recovery (EHR) with geological storage 4. The back-produced CO2 is not considered a
of CO2. Guidance Document 2 (chapter 1.3.2) only significant irregularity or leakage from the
provides general recommendations without many storage complex within the meaning of the CCS
details that might be useful to CO2 storage regulators. Directive.
Moreover, there is no experience available in Europe
With proper oversight and with MMV programmes to
concerning the transition of a producing hydrocarbon
ensure accounting of injected and back-produced CO2
field into a CO2 storage reservoir; this also includes the
flows blended storage could prove a driver for
regulatory aspects of the matter. The main
subsequent pure storage. It is recommended to
uncertainty relates to the conversion (or perhaps co-
provide clearer guidance on the topic in the Guidance
existence) of an existing hydrocarbon exploitation
Documents.
permit (production license) and a CO2 storage permit.

There is a need for clarity about converting producing

hydrocarbon fields to CO2 storage reservoirs. While
early CO2 storage projects in Europe that use
(offshore) depleted hydrocarbon fields as the storage
reservoir commence injection after the end of oil or
gas production, there may be advantages in merging

24 Scottish Carbon Capture & Storage. "Carbon Accounting for Carbon Dioxide Enhanced Oil Recovery", Stewart and Haszeldine
(2014).
25 Eur-Lex. Commission Implementing Regulation (EU) 2018/2066 of 19 December 2018 on the monitoring and reporting of

greenhouse gas emissions.

35
8. Conclusion

The Directive sets out the requirements for safe and 8.1 Competent Authorities
secure storage. It is a legal framework and, as such, it
does not provide exhaustive details. Member States One of the recurring recommendations to CA is their
are responsible for interpretation of the framework, early engagement with project developers. CA
its transposition, and the application of the Directive guidance is needed in several areas.
in a country-specific manner. Both project developers
and competent authorities are developing experience
in translating the requirements set out in the Directive 8.2 Guidance Documents
into effective and efficient practical rules. This process
has been challenging for the first wave of projects. The Guidance Documents are for guidance only, e.g.,
“do not represent an official position of the
The report presents some of the results and findings Commission are not legally binding”. The Directive
from several first-of-a-kind CO2 storage projects that and its requirements are legally binding. However, it
have been, or are being, developed under the allows for flexibility in relation to most concerns
Directive, for the benefit of regulators and project around post-closure responsibilities and the financial
developers. Its authors have experience in applying security and financial mechanisms.
for permits for CO2 storage to the Commission. Where
possible or relevant, suggestions are given to Guidance Documents GD3 and GD4 have assumed
competent authorities or project developers to speed storage in new deep saline formations (also known as
up and facilitate the development of future storage virgin aquifers) rather than the possibility of storage
projects. In that regard the report aims to be a in depleted hydrocarbon reservoirs. Whilst intended
reliable, independent reference document for for guidance only, their suggestions on requirements
authorities and applicants, by addressing could be misinterpreted and applied in a more
uncertainties and suggesting potential solutions. stringent way to depleted hydrocarbon reservoirs
than is necessary, as detailed previously in this report.
The report does not request changing the Directive For clarification in interpretation and to help avert a
and does not identify a need for further or more CA from ‘over-interpreting’ the Guidance documents
detailed requirements in the Directive. Several for application to depleted hydrocarbon fields we
storage permit applications have been developed suggest the addition of some text in GD3 and GD4. For
under the Directive and increasing experience with GD2, it is suggested that attribution monitoring is
regulators and project developers is already showing added as a step (see section 2). These elements are
evidence of evolving interpretation. provided in the Annex.

The report does offer suggestions to improve the

Guidance Documents, which also aim to support
regulators and project developers.

36
Annex: Guidance Documents

Relevance to storage in depleted

hydrocarbon reservoirs
Guidance Documents GD3 and GD4 have assumed another origin such as biogenic sources. This is
storage in new deep saline formations (also known as important because, as it is written, when monitoring
virgin aquifers) rather than the possibility of depleted under the Directive suspects a leak, it then triggers
hydrocarbon reservoirs. For clarification, monitoring under the ETS Directive to quantity
interpretation and to help avert a competent emissions, whether or not they are from the CO2
authority from ‘over-interpreting’ the Guidance storage site (Dixon and Romanak 2015).
Documents for application to depleted hydrocarbon
fields, the suggested amendments to GD3 and GD4
are in bold as follows:
Suggested amendments
Suggested amendments to GD2 are as follows, with
new text in bold.
“Note that the examples given in this guidance
document are based upon CO2 storage in a deep
saline formation. Storage in depleted hydrocarbon Page 96
“Environmental monitoring for leakage out of the
reservoirs present a different risk profile and are
storage complex towards, at or
likely to be easier to prove secure and permanent
storage as required in the Directive Article 18.2(a-c), near the surface, on land or offshore:
for example the Competent Authority may be able to • Detection of suspected leakage anomaly;
agree a shorter minimum period for post-closure • Attribution of anomaly
responsibilities and transfer of responsibility, as • Quantification of leakage (if attributed to the
allowed for in the Directive Article 18.1(b).” CO2 storage project);
• Accounting and quantification of emissions
This text would be inserted at the end of the last from the storage complex for surrender of
paragraph in page 1 in GD3 and at the end of the last emissions trading allowances for any leaked
paragraph in section1 in GD4. emissions under EU ETS Directive 2003/87/EC
(if attributed to the CO2 storage project);
• Safety and Environmental impacts (if
Attribution monitoring attributed to the CO2 storage project).”
Since the drafting of the Directive and GD2,
monitoring techniques have advanced in what is Figure 5 Monitoring Plan Elements
known as ‘attribution monitoring’. These are a suite of “Environmental (Leakage)
techniques for surface and near-surface monitoring • Detection of suspected leak or anomaly
that enable an anomaly of higher CO2 emissions to • Attribution of anomaly
atmosphere or water column to be determined • Leak quantification
whether they are from the stored CO2 or from • Emissions/ETS impact

37
 • Safety & Environmental impacts “ • Leak Quantification
• Flux gas measurement
• Impact: HSE Monitoring
Page 98
• CO2 Concentration
Figure 6 Different methods and techniques suitable
• Water sampling/analysis
for monitoring
“Environmental Onshore • Ecosystems surveys”
• Leak and Anomaly Detection
• Sampling and geochemical analysis Page 103
• Seismic Onshore
• pressure interference “For onshore sites, the strategy, issues and
• Soil gas technology options for leakage detection and
• Vegetation stress quantification will be different to offshore sites.
• Eddy covariance tower The detection limits of surface monitoring techniques
• Attribution of anomaly are determined by environmental parameters as well
• Isotopic analysis as the sensitivity of the monitoring instruments
• Chemical tracers (natural and themselves.
artificial) In near-surface systems on land, CO2 fluxes and
• Process-based method concentrations are determined by uptake of CO2 by
• Leak Quantification plants during photosynthesis, root respiration,
• Soil gas microbial respiration in soil, deep natural outgassing
• Surface gas measurement of CO2 and exchange of CO2 between the soil and
atmosphere (Oldenburg & Unger, 2003). Any surface
• …
leakage of CO2 from a manmade CO2 storage reservoir
• Impact: HSE Monitoring
needs to be distinguished from the variable natural
• CO2 Concentration
background (Oldenburg & Unger, 2003; Klusman,
• Water
2003a, c, Dixon & Romanak 2015). Analysis of stable
• sampling/analysis
and radiogenic carbon isotope ratios in detected CO2
• Soils acidity
can help this process, also chemical tracers (natural
• Surface deformation
and artificial) and process-based methods. Most
• Ecosystems surveys” techniques require calibration or comparison with
baseline surveys made before injection starts, e.g. to
“Environmental Offshore determine background fluxes of CO2 emissions.”
• Leak and anomaly Detection
• CO2 flux and concentration
monitoring
• Water sampling and geochemical
analysis
• High resolution geophysics
• Seismic
• Attribution of anomaly
• Isotopic analysis
• Chemical tracers (natural and
artificial)
• Stoichiometric methods

38
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39
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