Toward a Law of the UndergroundDeveloping a regulatory framework for geologic carbon capture and storageCaitlin Augustin

MVA Project DOE Award # FE0001580 GPS

◦ Measure surface deformation with high temporal resolution

InSAR◦ Measure surface

deformation with high spatial resolution

Seismology◦ Measure Vp/Vs at selected

test site and locate microearthquakes as indicators of fluid migration

Geochemistry◦ Measure key geochemical

parameters at test site

TECHNOLOGY BACKGROUND

Definition

The capture of carbon dioxide

from a large point source and

subsurface storage in such a manner

that it never reaches the atmosphere

Storage SitesZone Type Averag

e Depth

of injectio

n (meter

s)

Count of

active zones

Count of potential

zones

Oil reservoir (EOR)

1454 1751 1,000+

Depleted Oil/Gas reservoir

1840 942 1,000+

Unmineablecoalseams

1500-3000

33 unknown

Saline water(brine reservoirs)

1800-2300

274

355 planned

sites, count unknown

1. Oil and Gas Journal Enhanced Recovery Survey (2010)2. Current State of issues concerning Underground Natural

Gas Storage (2004)

3. Big Sky CO2 Project

4. CCS @ MIT (2012)Depth measure: US Energy Information Administration

Process

Adoption Short to mid-term emissions reduction

technology It is estimated that geologic carbon

capture and storage (CCS) could be used to achieve between 15% and 55% of the carbon emission reductions necessary to avoid dangerous levels of climate change. (IPCC, IEA, IRGC)

DISSERTATION PROJECT

Problem Statement1. Fundamentally there is not a clear

accounting of what happens to injected carbon dioxide, and there is no clear set of legal guidelines covering CCS

2. Implementation of large-scale, transboundary CCS projects are largely unaddressed. Likely first order scenarios that need to be considered are

1. When CO2 injection is contained within one state, but there is the potential for CO2 migration towards or subsurface pressure changes in a neighboring state

2. Situations where the storage reservoir spans one or more political boundaries

3. There exists an inadequate and incomplete probabilistic risk assessment framework for evaluating potential leaks and health impacts

Objectives1. Understand subsurface reactions in

storage reservoirs at the field-scale2. Develop a probabilistic risk

assessment for future geologic sequestration scenarios

3.  Expose the inadequacies of existing legal frameworks governing CCS

4.  Analyze transboundary security issues stemming directly from CCS

5. Propose a framework for a Law of the Underground

Expected Contributions

1. First geochemical models of Teapot Dome, Wyoming

2. First Bayesian risk analysis of CCS

3. First Bayesian risk analysis of natural CO2 leaks

4. First comprehensive Law of the Underground

Related Research

Geology

Caraballo AC, Rabindran P, Winning

G, et al. (2010)

Wilkinson et al (2009)

Luquot et al (2009)

Zerai et al (2006)

White et al (2005)

Xu et al (2005)

Engineering

Vinogradov (2011)

Birkholzer (2010)

Chabora and Benson (2009)

Nordbotten (2008)

Class, H et al. (2009)

Englehardt, J.D. (1995)

Policy

Bradsher, K and Barboza, D. (2011)

Bertinelli, L., Camacho, C. and Zou, B, (2011)

Hart (2011)

Hardisty et al (2011)

Endres (2010)

De Figueiredo et al (2006, ‘07, ‘09)

Rubin, E.S., McCoy, S.T., Apt, J. (2005)

Rissland, E. L., Ashley, K. D., & Branting, L. K. (2005)

Methodology

A Law of the

Underground

Geochemical Modeling

Bayesian Statistics

Legal Research

Transboundary Analysis

Policy

Geology

Engineering

DISSERTATION DATA SOURCES

Theoretical datasetClass, et al 2009

◦ “A Benchmark study on problems related to CO2 storage in geologic formations

Parameters◦ model domains◦ model input

parameters,◦ boundary conditions◦ simulation times◦ expected model

outputs

Class, H ,et al. (2009) “A benchmark study on problems related to CO2 storage in geologic

formations.” Computational Geosciences 13.4: 409-434.

Case Study dataset DOE Rocky

Mountain Oilfield Testing Center◦ Injection schedule◦ Lithology◦ Injectant data◦ GIS maps◦ Well logs◦ Core data (porosity

and permeability)◦ Seismic

From DOE dataset

Case Study site: Teapot Dome, WY

CO2 injection into three unique formations (Tensleep, Shannon, 1st Wall Creek)

Situated near major metropolitan area

Reservoir borders Native American territorial lands

Map of NPR-3 Injection Site

Natural CO2 Leaks dataset290 point dataset

compiled dataset from◦ Googas Database◦ USGS Volcanics◦ EPA

Data contains◦ Volume (metric tons)

leaked per 24 hours◦ Type of leak◦ Human fatalities◦ Human injuries◦ Animal fatalities◦ Latitude/longitude

Map of Googas database leak locations

Commercial Leaks dataset18 point dataset

compiled from◦ News sources◦ Literature review

Data contains◦ Volume (metric tons)

leaked per 24 hours◦ Type of leak◦ Latitude/longitude◦ Human fatalities*

*not available for all sites

Leak at Weyburn, Canada injection site

DISSERTATION CHAPTERS

Ch 1: IntroductionMotivation for the Study

◦CCS is performed by public and private actors across local, national and international governments

◦The cross-cutting nature of CCS means law has been created without scientific basis, leading to unrealistic monitoring standards and arbitrary injection frameworks

◦Law is proposed and interpreted at all levels, from the local to federal to international, leading to overlapping and conflicting regulatory regimes

Ch 1: IntroductionDescription of the Knowledge Gaps

◦ Subsurface interactions: There is a need for a better understanding of long-term storage, migration and leakage processes.

◦ Probabilistic Risk Profiles: To date, there have been no few at quantifying risk on a site by site basis using probabilistic methods, and no attempts at quantifying on a larger scale. Furthermore, no research has been undertaken to do predictive Bayesian modeling on GCCS site information and use these techniques to develop a risk profile for future injection scenarios.

◦ Regulation: Current knowledge about the legal and regulatory requirements for implementing GCCS remains inadequate. There exists no appropriate framework to facilitate the implementation of GCCS and manage the associated long-term liabilities. Clarification is needed regarding potential legal constraints on geological storage (either terrestrial or sub-seabed.)

Ch 1I: 3-D Reservoir Characterization—Chapter OverviewThis chapter will focus on the

development field-scale reservoir models of potential injection sites. These models are intended to form the basis of the reactive-transport models of CO2 injection in Ch II

Potential fields must be characterized on reservoir architecture and lithology ◦ This characterization can highlight potential injection

hazards such as groundwater contamination, pressure build up, and fracture/fault presence.

Ch 1I: 3-D Reservoir Characterization—Chapter Approach

Software◦ PetraSim◦ Trinity

5,000 and 10,000 point grids

Data◦ Class, et al◦ Teapot Dome

Petr

asi

m p

roble

m (

rese

rvoir

is

invert

ed,

stra

tified b

ase

d

on t

epera

ture

)

Petr

asi

m b

ench

mark

pro

ble

m(r

ese

rvoir

is

stra

tified b

ase

d o

n

litholo

gy)

Ch 1I: 3-D Reservoir Characterization—Preliminary Results/Next Steps Tough 2 has no

visualizer and is cumbersome to work with◦ PetraSim is a far

easier toolTough 2 cannot

handle oil as a fluid◦ Use basin modeling

techniques from petroleum geology which allow oil to behave as a fluid

Trinity software

Zetaware Trinity © Basin Model of an unnamed oil

field

Ch III: 2-D and 3-D Reactive Transport Modeling—Chapter OverviewThis chapter will present the results of

modeling of CO2–brine–mineral reactions in sandstone, carbonate, and mixed mineral assemblage reservoirs

The 2-D reactive transport models should demonstrate mineral-trapping and solubility-trapping of CO2 over specified time scales

The 3-D models should show the evolving pressure field over an injection site, the migration of the CO2 plume over time, and the reservoir deformation resulting from injection

Ch III: 2-D and 3-D Reactive Transport Modeling—Chapter ApproachSoftware

◦ PetraSim◦ Geochemist’s

Workbench5,000 and 10,000

point grids20, 50, 100 year

reaction periodsData

◦ Class, et al◦ Teapot Dome

Pre

cipit

ati

on o

f si

deri

te f

rom

a s

andst

one r

ese

rvoir

Pre

cipit

ati

on o

f daw

sonit

e e

fr

om

a s

andst

one r

ese

rvoir

Ch III: 2-D and 3-D Reactive Transport Modeling—Preliminary Results and Next StepsWe discovered a

glitch in GWB models where more carbonates were precipitating than possible

Attending a summer 2013 GWB training workshop

Reaction path modeling from Zerai, et al (2005)

Chapter IV: Predictive Risk Assessment —Chapter OverviewWith GCCS, it will be impractical and

impossible to collect comprehensive empirical data regarding geologic reservoir leaks. For these reasons, together with the expense of field data collection, there is a need for a statistical technique integrating limited data collection with stochastic modeling.

Predictive Bayesian modeling techniques have been developed and demonstrated for exploiting limited information for decision support in many other situation, this chapter will adapt and apply them to CCS.

Chapter IV: Predictive Risk Modeling—Chapter Approach

Develop a probabilistic risk profile using a compound Poisson model◦ Incident frequency modeled

using the predictive Bayesian form of the Poisson distribution

◦ Incident size modeled using the predictive Bayesian form of the truncated Pareto I distribution

Run a 1,000,000 point Monte Carlo simulation with 100,000 sampled for replacement

1

10

100

1000

log (incident sizes)

log (

pro

babilit

y d

ensit

y)

Empirical PDF for natural leaks historic data

Chapter IV: Predictive Risk Modeling—Preliminary Results

In risk analysis, the formula “Risk = Probability × Consequence” is applied as a way to categorize high, medium, and low risk scenarios◦ results of this simulation show that

the probability of large volume leakage is so small that the risk would actually be classified as “low”

This first application of Bayesian methods to the carbon capture and storage problem corroborates recent research results from other schools◦ (Robers , 2011) “more likely to be

struck by lightening than die from CCS leak”

100 1000 10000 1000000.00000001

0.0000001

0.000001

0.00001

0.0001

0.001

0.01

log (n*z total incident size) metric tonslo

g (

pro

bib

ilit

y d

ensit

y)

0 20000 40000 60000 80000 1000000.0000

0.1000

0.2000

0.3000

0.4000

0.5000

0.6000

0.7000

total leakage volume

pro

babilit

y

Resu

ltin

g c

om

pound

dis

trib

uti

on o

ver

a 2

0 y

ear

pla

nnin

g p

eri

od

Resu

ltin

g p

robabili

ty

dis

trib

uti

on o

ver

a 2

0 y

ear

pla

nnin

g p

eri

od

Chapter IV: Predictive Risk Modeling—Next StepsBuild model based on known

commercial leak dataCompare commercial leak profile

and natural leak profile

Chapter V: Legal analysis—Chapter Overview Intergovernmental agencies have focused on

regulating isolated components of CCS rather than the process as a whole.

CCS does not fall easily within the regulation of international legislation, as existing laws were designed prior to this technology being developed. Very few countries have developed the necessary frameworks for sequestration regulations and in many cases haven’t even determined which regulatory authorities have jurisdiction.

Intergovernmental laws, national laws from the 50+ countries adopting GCCS, and regional laws from major adopters (such as the United States) will be analyzed.

Chapter V: Legal analysis—Chapter Approach

“case-based” approach◦ Simply put, the present

problem of interpretation must be solved based on the solutions to similar past problems.

◦ In particular, one tries to resolve interpretation problems by considering past applications of the rules and terms in question: by examining precedent cases, comparing and contrasting these with the instant case, and arguing why a previous interpretation can (or cannot) be applied to the new case.,

Chapter V: Legal analysis—Preliminary Results and Next StepsCategorized all property law

regimes in relation to subsurface ownership

Identified all laws governing (or potentially governing) carbon dioxide

Identified international laws governing (or potentially governing) CCS

Chapter VI: Transboundary Security Situations—Chapter Overview

Chapter VI: Transboundary Security Situations—Chapter Approach Game theory will be applied to a

transboundary injection model with two actors

◦ Countries commit to an emissions reduction target◦ Emissions potential stays constant◦ Cost of reduction of one emissions unit◦ Penalty cost of not reducing one emissions unit

Noncooperative model◦ Individual economic success optimized

Cooperative model◦ Joint economic success optimized

Based on Olli Tahvonen (1994) “Carbon dioxide abatement as a differential game”

Chapter VII: Law of the UndergroundSubsurface ownershipTreatment of carbon dioxideLiability regimesDisaster mitigation

TimelinePercentage completed/ topic

10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Problem designed and model built

Data collected Analysis run and refined

Writing chapter

Bayesian Models: natural leaks

                 Spring

2013

Bayesian Models: commercial leaks

                 

Spring

2013

Legal Analysis                Spring

20133-D Reservoir Characterization (Trinity)

                 Summer

2013

3-D Reservoir Characterization (PetraSim)

               Fall

2013

2-D Reactive Transport Modeling

               Fall

2013

3-D Flow Modeling                  

Spring2014

Differential Games Modeling                

Summer2014

Policy Recommendations

                 Fall

2014