Biomass or Bio-oil Storage in Salt Caverns

1.0 Introduction

Durability refers to the length of time for which CO2 is removed from the Earth's atmosphere and therefore cannot contribute to further climate change. This Module details durability and monitoring requirements for bio-oil and biomass storage in salt caverns.

Salt caverns have historically been used to store or dispose of a wide variety of materials including hydrocarbons, brine, industrial and even nuclear waste. Salt's viscoelastic properties make caverns nearly impermeable to emplaced materials, reducing the risk of migration. Additionally, under stress salt deforms slowly resulting in the cavern closing around the wastes over long time periods and specific cavern conditions, entombing them within the low permeability salt¹. The geometry of salt caverns influences their storage capacity, stability, and integrity. Homogeneous salt caverns are within salt domes or thick salt beds and are solely surrounded by salt. Their stability and integrity are based on the rock salt only. Inhomogeneous salt caverns are within bedded salts or salt breccias, their stability and integrity are based on the properties of rock salt and non-salt permeable structures.

This Module is applicable for bio-oil or biomass slurry emplacement into salt caverns that have been approved by the relevant permitting authority. Storage within salt caverns can occur when the salt cavern is no longer viable for high pressure natural gas cycling or compressed air storage, or other waste storage. The emplacement and storage of fluids and waste products into salt caverns has been occurring since the 1940s and 1950s respectively².

Bio-oil is a dark, viscous liquid typically between pH 2-3 (but up to 6), consisting of oxygenated hydrocarbon compounds³⁴. Prior to emplacement, the pH may be buffered and/or salinity raised as required by permitting. Bio-oil can have co-products like biochar mixed into it ahead of injection underground. Within this Module, we use the words ‘bio-oil’, and ‘bio-oil with biochar’ and ‘injectant’ interchangeably. The storage of bio-oil in salt caverns is relatively new and has not been well studied and documented as of December 2023.

Biomass slurry is an organic waste (e.g., manure, food waste, agricultural waste, paper sludge) mixed with on-site brine. The slurry contains compounds like carbon, nitrogen, phosphorus, oxygen, hydrogen, sulfur, and trace elements found in the organic waste.

As both bio-oil and biomass (hereafter known as "the injectate") are expected to be denser than the surrounding subsurface brine in the cavern it is expected that they will sink to the bottom during emplacement. Displaced brine is pumped out of the cavern and injected back into a different subsurface reservoir. The durability of the injectate stored within salt caverns depends on the characteristics of the injectate, the salt and any bedded layers, and the interactions between the two being well defined and monitored. This, when coupled with capping and closure of subsurface reservoirs as per the U.S. EPA Underground Injection Control (UIC) or equivalent permitting requirements, removes the CO₂ stored within the injectate from the atmosphere for geological timescales⁴⁵⁶⁷⁸.

Potential risks to the expected durability of biomass and bio-oil are as follows:

• Emplacement may cause cavern wall dissolution.
  • Any liquid within the emplaced material that is below salt saturation may cause dissolution of the cavern walls. Prior to cavern emplacement, material must be salt saturated as required by the governing UIC or equivalent permit. For example, salt crystals may be added commensurate to bio-oil water content and biomass may be mixed with displaced cavern brine to minimize salinity differences within the cavern and mitigate dissolution.
  • The low pH of bio-oil can induce reactions with the cavern infrastructure, which may decrease durability by providing conduits for migration out of the cavern. Mineral blankets can be used to protect the tubing string from continuous exposure to emplaced materials and/or the bio-oil buffered to a higher pH.
• Injectate may be converted to bio-gases within the cavern such as CO2, CH4, N, O2, H2S and VOCs.
  • The emplaced material could biodegrade to form CO2, CH4, N, O2 and VOCs and other short-chain hydrocarbons. Microbial activity could also cause H2S formation. Gas formation may increase the pressure within the cavern decreasing the stability. Any signs of gas formation should be monitored as part of the operation and post-emplacement monitoring plan (see Sections 3.1.3& 3.2). Any gases produced will be considered removed because of the impermeable cavern walls and roof and well design preventing the migration of buoyant phases (such as biogas). Any releases of C bearing gasses from the salt cavern must be deducted from the net CO2e removal (see Section 3.3).
• Emplacement may lead to a loss of cavern integrity, for example via pressure and/or temperature differentials which could lead to fluid expansion/reduction and fracturing on closure.
  • Differences in cavern pressure compared to the surrounding formation could result in the deformation of salt, for example via fracturing, salt creep or roof collapse. This could result in subsidence, the leakage of the injectate outside of the cavern and to USDWs/the atmosphere and/or a decrease in cavern volume. As the injectate will be denser than the brine it is replacing it is likely to increase the cavern stability. Any signs of pressure or temperature differentials must be monitored and emplacement/closure procedures adapted accordingly. The overlying strata can also provide support for the overburden reducing the risk of roof collapse.

This section outlines requirements for evaluating emplacement and storage, with a focus on cavern characterization, infrastructure construction and monitoring. The post-emplacement monitoring plan detailed in Section 3.2 acts to address and mitigate these potential risks to durability. Section 34.30 addresses accounting for any GHG emissions associated with monitoring the geologic storage of CO₂ during the project operations, closure, and post closure periods.

Monitoring of the emplacement cavern, and overlying formations and surface where applicable, must be completed to ensure that any emplaced material remains stored within the confines of the salt cavern and does not migrate outside of the cavern, nor result in decay of the injectate and subsequent re-emission as CH₄, CO₂ or other volatiles. The emplacement cavern, and overlying formations and surface where applicable, must be monitored in accordance with thethis U.S.Module EPAand Underground Injection Control (UIC) or equivalentany permitting requirements as specified in the operating permit for the salt cavern issued by the relevant regulatory body. This Module addresses minimum requirements for emplacement well design, construction, operation, and monitoring to ensure proper cavern storage design construction and monitoring to ensure durability of storage. Although typically these requirements will be addressed in full in the UIC permit or equivalent, the emplacement of bio-oil and biomass into caverns is a novel approach for which permitting decisions and requirements are still in development and may not be consistent based on the evaluation and development of permitting approaches by each responsible authority. Therefore, critical concepts and requirements are documented here for consistency and to ensure proper cavern storage design construction and monitoring to ensure durability of storage.

• Salt Cavern Characterization: the proposed storage cavern, surrounding areas that could or would be affected by the salt cavern’s integrity, overlying formations and Area of Review⁸⁹ (AOR) must have been adequately characterized to demonstrate cavern suitability for storage and containment of the injectate. If an AOR is not defined within the permit, the Project Proponent/Operator must define an AOR. See Section 2.2 for further details.
• Emplacement Infrastructure Construction and Performance: the proposed storage cavern infrastructure and emplacement system must be designed in accordance to the UIC or equivalent permit and relevant API and ISOstandards (e.g., API standard 65- part 2 on "Isolating Potential Flow Zones During Well Construction"⁹¹⁰), including design and specification of wellbore and well materials to ensure proper long term operation of the well when injecting and protection of the lowermost underground source of drinking water (USDW).
• Emplacement System Operation & Monitoring: the Operator must specify operating conditions and monitoring systems and approaches, such as gas detection, and other systems to ensure that the emplaced material remains in the cavern, the salt cavern is not negatively impacted by operations, automatic safety precautions are in place to minimize potential for exceeding allowable operating conditions, and conditions can be monitored for compliance or deviation from requirements. Reporting of operations will be in accordance with the UIC or equivalent governing body.
• Closure and Post-Closure Requirements: Requirements for proper closure of the salt cavern and emplacement facility, as well as post closure requirements and post-emplacement monitoring to ensure the injectate remains sequestered durably in the cavern and poses no net environmental harm, the cavern is properly monitored, and any non-compliance is addressed with corrective actions.

Specifically, the followingrequirements requirementsin this Module must be met to ensure durable storage of injectate in the salt cavern. The Project Proponent is responsible for ensuring these requirments are met, inlcuding providing the data to Isometric.

1.1 Monitoring Requirement Risk Categories

Potential risks to expected durability of biomass and bio-oil are site specific and may include:

• Risk A: Emplacement may cause cavern wall dissolution.
  • Any liquid within the emplaced material that is below salt saturation may cause dissolution of the cavern walls. Prior to cavern emplacement, material must be salt saturated as required by the governing permitting regime. For example, salt crystals may be added commensurate to bio-oil water content and biomass may be mixed with displaced cavern brine to minimize salinity differences within the cavern and mitigate dissolution.
  • The low pH of bio-oil can induce reactions with the cavern infrastructure, which may decrease durability by providing conduits for migration out of the cavern. Mineral blankets can be used to protect the tubing string from continuous exposure to emplaced materials and/or the bio-oil buffered to a higher pH.
• Risk B: Emplacement may lead to a loss of cavern integrity, for example via pressure and/or temperature differentials which could lead to fluid expansion/reduction and fracturing on closure.
  • Differences in cavern pressure compared to the surrounding formation could result in the deformation of salt, for example via fracturing, salt creep or roof collapse. This could result in subsidence, the leaking of the injectate outside of the cavern and to USDWs/the atmosphere and/or a decrease in cavern volume. As the injectate will be denser than the brine it is replacing it is likely to increase the cavern stability. Any signs of pressure or temperature differentials must be monitored and emplacement/closure procedures adapted accordingly. The overlying strata can also provide support for the overburden reducing the risk of roof collapse.
• Risk C: Injectate may be converted to bio-gases within the cavern such as CO₂, CH₄, N₂, O₂, H₂S and VOCs(volatile organic compound).
  • The emplaced material could biodegrade to form CO₂, CH₄, N₂, O₂ and VOCs and other short-chain hydrocarbons. Microbial activity could also cause H₂S formation. Gas formation may increase the pressure within the cavern decreasing the stability. Any signs of gas formation should be monitored as part of the operation and post-emplacement monitoring plan (see Sections 3.1.3& 3.2. Any gases produced will be considered removed because of the impermeable cavern walls and roof and well design preventing the migration of buoyant phases (such as biogas). Any releases of C bearing gasses from the salt cavern must be deducted from the net CO₂e removal (see Section 4.0).
• Risk D: Biomass/bio-oil emplacement results in leaks in emplacement, monitoring or legacy wells.
  • Biomass/bio-oil can damage integrity of any emplacement monitoring wells.

2.0 Permitting and Cavern Characterization

2.1 Permitting

The

2.2 Evidence Reporting

For Projects with an Approved Permitting Regime and in good standing with the permitting authority, monitoring requirements which identify "Approved Permit" under Evidence Reporting (see Monitoring Requirement Tables in Appendix 1) may be satisfied through submissions to the permitting authority.

The Storage Operator must maintain copies of all data and evidence submitted to the permitting authority against these requirements and must provide such records to Isometric and the VVB within 30 days of submission to the permitting authority, or upon request.

For monitoring requirements not covered under the Approved Permit, the Project Proponent remains responsible for collecting and reporting all required data directly to Isometric and the VVB according to the frequencies and standard reporting timelines specified in this module.

In the case of changes to the permit9 requirements, permitting authority, and/or regulatory environment, the Project Proponent must notify Isometric and the VVB immediately of any changes which may impact monitoring requirements. Monitoring plans will be subject to reevaluation following such changes.

2.23 CavernSite Characterization

As part of the permit application, the Operatorit must demonstratebe demonstrated, where applicable, that the cavern:

• Is of sufficient volume to receive the total anticipated volume of the injectate stream;
• Is free of transmissive faults and fractures and of sufficient extent and thickness to contain the emplacement volume, displaced cavern brines and any biogas generation;
• Has structural integrity (i.e., cavern walls are of an adequate thickness and extent and it is not in close proximity to other caverns or the salt boundary, no evidence of salt creep, salt has sufficient compressive and shear strength) such that it will prevent migration of the injectate, brine or biogas above the storage complex, towards the surface and atmosphere and/or USDWs;
• Low permeability and thickness of cavern to prevent vertical or lateral migration of the injectate, brine or biogas above the storage complex, towards the surface and atmosphere and/or USDWs;
• The operatorOperator must also identify a suitable formation for displaced brine injection.

In addition, the Project Proponent must also characterize the followingparameters listed in Table 1 to assess the risk of leakageleaks, develop the operation conditions for injection and monitoring plans, model the injectate behavior and for comparison to future measurements:

Table 1: List of cavern characterization requirements

Salt cavern characterization can be provided in the form of previous characterizations and historical data, as long as the requirements outlined within this Module are met.

The Project Proponent or Operator (when the Project Proponent does not operate the cavern) is required to demonstrate that there is an approved permit for displaced brine injection in place. It is a requirement that re-injection of the brine must occur within a closed system to avoid any contact and equilibration with the atmosphere, resulting in potential reversals. The Project Proponent is required to assess and quantify any potential reversals as a direct result of brine injection.

Cavern characterization is required to be reviewed every five years as part of the projectProjectCrediting Period (see the relevant Isometric Standard section) at a minimum, or at the UIC Programs Director's or equivalentsregulators request, or when monitoring and operational conditions warrant, as indicated by a significant change in site conditions, injectate characteristics, or monitoring data. The review must include a comparison of pre-emplacement project assumptions to actual measured conditions including salt cavern capacity, the structural integrity of the cavern, and specific operating conditions observed during emplacement. Estimates revised with any acquired monitoring data should demonstrate that the planned emplacement volume will remain within the salt cavern until the end of the post-emplacement monitoring period.

2.4 Site Visits

Project validation and verification must incorporate site visits to project facilities in accordance with the requirements of ISO 14064-3, 6.1.4.2, including, at minimum, site visits during the first Validation or Verification of a Project, to the capture and (if applicable) storage site. Verifiers should whenever possible observe operation of the capture and storage processes to ensure full documentation of process inputs and outputs through visual observation and validation of instrumentation, measurements, and required data quality measures.

A site visit must occur at least once during each project validation. Additional site visits may be required if there are substantial changes to field operations over the course of a project's validation period, or if deemed necessary by Isometric or the VVB. Site visit plans are to be determined according to the VVB's internal assessment, in consultation with Isometric.

2.5 Well Construction Requirements

• determining the integrity of the cement and casing.
• conducting any necessary action to repair defects.
• determining whether the existing well materials are adequate for the new function of the well.
• determining the diameter of the hole, any deviations from vertical, and any significant curvature or bends in the well should be compared with the size of the proposed monitoring equipment.
• existing well materials should be checked to ensure that they are compatible with fluids with which they will come into contact, such as carbon dioxide and carbon dioxide-rich brines if they are completed in the injection zone.
• any flaws in the casing or cement will need to be repaired.

3.0 Monitoring

Monitoring of emplacement, system integrity as well as for subsurface migration is required in order to identify and measure potential leaks and/or validate update models as appropriate.

3.1.1 InjectateEmplacement and OperationalInjectate Monitoring

• Emplaced material must be gravity fed or emplaced at a surface pressure beneath that which is specified in the permit, ensuring the cavern does not become over-pressurized [B]. If emplacement is not gravity fed, emplacement pressure should be monitored continuously. Annulus pressure must be measured continuously.
• The volume of emplaced material must be monitored appropriatelycontinuously. For example by monitoring the rate of injection or by using the weight of biomass/bio-oil emplaced and as well as the amount of water added where applicable [B].
• Limitations on composition of the injectate, including, but not limited to pH, temperature, conductivity/chloride concentration, if relevant, to ensure the injectate does not negatively impact the emplacement well, associated facilities and the cavern walls via inducing dissolution, reaction, or other degradation pathways, resulting in increased potential for migration of the emplaced material [A].
  • Records of laboratory analyses and relevant permit limitations to demonstrate compliance must be maintained in accordance with the well permit and available for review at any point during the Crediting Period or post closure.
• Analysis of the injectate withonce sufficientper frequencyinjection batch to yield data representative of its chemical and physical characteristics, sufficient toand demonstrate there is minimal effect on the cavern. In addition, analysis of the injectate must demonstrate compliance with the well permit and be available for review [A,B,C].  Injectate analysis should consist of the following parameters using industry standard or indicated methods using properly calibrated equipment:
  • Total C content (for further details see Section 7.3.3.1 of the relevantBiomass Geological Storage Protocol or Section 7.4.1.1 of the Bio-oil Geological Storage Protocol)
  • pH
  • Temperature
  • Chloride concentration or alternative determination as required by the regulator
  • Density (bio-oil)
  • Total acid number (TAN) (bio-oil)
  • Water content (bio-oil)
  • Bio-oil consituents (bio-oil)

For all injectate monitoring and analyses, sufficient samples must be analyzed to determine that the composition of the injectate is within specified parameters in the UICapproved permit or equivalent, where required.

For samples taken each emplacement batch, each individual batch that is emplaced should be analyzed and characterized to ensure composition variation from batch to batch is accounted for. Samples should be well mixed and representative.

For samples measured per feedstock type, a representative value should be used. These measurements should be repeated to find representative values every time there is a material upstream process change like a new biomass feedstock. If a blended feedstock is emplaced, samples should be taken for each emplacement batch.

3.1.1.1 Continuous Gas Monitoring

Wells must have species-specific gas detectors (or equivalent sensors/imaging) capable of detecting, at minimum, CO₂, CH₄ and propane (C₃H₈), with alarms and injection shut-off systems (e.g., automatic shut-off or procedures in place for manual shut off of injection/operation), including for a gaseous release (CO2, hydrocarbons, or other GHGs) and injection pump shutoff when maximum pressure is reached or maximum flow rate is exceeded. IfWhere site-specific risk assessment identifies additional species of concern (e.g., H₂S, VOCs, other hydrocarbons), detection capability for those species must also be provided. The Project Proponent must justify the injectateselected isdetector nottype(s) and their suitability for the site conditions in athe gaseousPDD phase, then detectors[C].

Detectors/alarms maymust either be placed on any producing wells (e.g., brine producing wells/tanks for salt caverns) asor anat alternative tothe wellhead monitoring. Wellhead monitoring is then required if  If gas is detected at either location and is foundattributed to be a result of biogas formation, continuous detection must be established at the wellhead and brine locations. The determination that detected gas is attributable to biogas formation must be made by the Project Proponent and reported to Isometric and the VVB [C].

If gas detection alarms are activated at any monitored well, thea operator"Triggered Gas Investigation" is initiated (Section 3.1.3.1). The Operator must immediately investigate and identify as expeditiously as possible (or in accordance with permit requirements) the cause of the alarm or shutoff, and report the instance to theIsometric. validationWhere a Triggered Gas Investigation (Section 3.1.3.1) is already active, individual alarm events must be logged and verificationreported bodybut (VVB)do not require a separate investigation unless they indicate a materially different or escalating condition [C].

3.1.2 System Integrity Monitoring

3.1.3 Migration and Storage Reversal Monitoring

• Continuous or high frequency monitoring of cavern pressure to ensure the cavern does not become overpressurized thus reducing the risks to the cavern integrity and thisfor leakageleaks [B].
• Periodic sonar surveys should also be conducted to quantify thecavern emplaced materialfill and confirm containment as well as any salt creep that may be occurring (cavern geometry). At a minimum this should be done prior to emplacement, and when cavern capacity is expected to be at set points based on cavern specific data, for example at 33% and 66% full or at 50% full, and in agreement with regulators. The Operator may use an alternative but equivalent method than sonar surveys if agreed with the Project Proponent (if different to the Operator) and with the regulating body. This must be documented in the PDD [A,B].
• Cavern fill monitoring is required to provide information about the sump depth and its evolution, for example by comparison of the volume emplaced and cavern volume, that is confirmed quarterly by a depth to top of emplaced volume check.
• Analysis of the displaced brine stream withonce sufficientper frequencyinjection to yield data representative of its chemical and physical characteristicsbatch using industry standard or indicated methods and quality and properly calibrated equipment [A,B,C]:
  • Volume (continuous e.g., by flow rate)
  • pH
  • Temperature
  • Conductivity/chloride concentration
  • Total organic carbon concentration
• MonitoringIf an increase in TOC during monitoring is recorded, the cause of the compositionincrease must be determined. Supporting evidence of anythe gasproposed recoveredmechanism, and evidence refuting alternative mechanisms, must be submitted to Isometric and the VBB.
• Bio-oil constiunets (if present/required by permit)

For all emplacement monitoring and analyses, sufficient samples must be analyzed to determine that the composition of the injectate is within specified parameters in the UIC or equivalentapproved permit, where required. Each individual batch of injectate that is emplaced should be analyzed and characterized to ensure composition variation from batch to batch is accounted for. Samples should be from a well mixed and representative container of the injectate. Requirements for C content analysis are set out in Section 7.3.3 of the relevant Protocols.

If any leaks are detected from the cavern, the Project Proponent/Operators must undertake corrective measures as set out in their monitoring plan submitted and approved by the permitting authority. If the cavern is found to have lost integrity, the Operator must halt emplacement whilst they conduct an assessment to determine whether there are any leaks and whether the loss of containment and/or well mechanical integrity and/or cavern integrity can be repaired prior to recommencing operations. The amount of CO₂ lost must also be quantified and subtracted from the overall total of CO₂ storedstorage.

Re-evaluations of the emplaced material must also be implemented when warranted based on observational or quantitative changes of the monitoring parameters of the salt cavern, including but not limited to:

• Loss of cavern or well integrity and migration of the injectate outside the salt cavern
• Materially elevated pressure/temperature

3.1.3.1 Triggered Gas Investigation

When the continuous gas detection system (Section 3.1.1.1) detects gases from the cavern, or gas is recovered in the displaced brine stream (or from monitoring wells or representative sampling locations when available), a Triggered Gas Investigation must commence. This investigation comprises gas composition analysis (including CO₂, CH₄, N₂, O₂ and VOCs ) and isotope analysis (such as δ¹³C-CO₂,CH₄) to determine the source and extent of detected gases. Both analyses are initiated concurrently,  isotope analysis is not contingent on results from composition analysis [C]. Discrete samples should be taken and analysed in the lab (e.g., by gas chromatography and isotope-ratio mass spectrometry). Gas analysis must be conducted on a monthly basis.

Results must be compared to baseline values obtained prior to emplacement, differences must be assessed by the Project Proponent to see if they are attributable and material to The Project. There are two options for determining a baseline, once the liquid petroleum gas (LPG) has been vented and gas measurements plateau following a spike from venting:

• Once the LPG has been vented, if the gas measurements plateau and no gas is detected, the background will be zero and any gas later detected will be attributed to The Project.
• Once the LPG has been vented, if there is still detectable gas during the gas measurement plateau, the baseline should be taken as the plateau measurement following LPG venting.
• If no baseline was established after venting, any gas later detected will be attributed to The Project.

3.1.3.2 Leaks

The Project Proponent/Operators must prepare an emergency reponse plan which outlines corrective actions which will be taken in case of biomass/biogas leaks. The plan must be submitted and approved by the competent permitting authority.

If any leaks are detected from the storage complex or there are significant irregularities from the used model(s), the Project Proponent/Operators must undertake corrective measures as set out in their monitoring plan submitted and approved by the competent authority. For a loss of conformance with models/expected behaviors, the Project Proponent must halt injection whilst they identify the cause of this loss, and then revise the monitoring plan to account for this change of migration. If there is a leak the Project Proponent must halt injection whilst they conduct an assessment to determine if the loss of containment can be repaired prior to injection beginning again. The amount of CO₂e lost must also be quantified and subtracted from the overall total stored.

Further information on the risk and attribution of reversals, see Section 4.0.

3.2 Post-emplacementEmplacement Monitoring Plan

The aim of this post-emplacement monitoring plan is to put in place scientific and/or operational monitoring practices which go beyond requirements of the UIC or equivalent injection permits specified under the UIC or equivalents well classes allowed under this Protocol. This is in order to prove beyond reasonable doubt that storage is expected to be durable on geologic timescales at which point the cavern can be closed. Post-emplacement monitoring must focus on using a combination of direct (e.g., pressure, temperature) and indirect methods (e.g., sonar surveys, simulation studies) as discussed in Section 3.1.3 to confirm containment of the injectate and any biogas produced to ensure durability. The requirements in this section should be followed until the closure of the cavern (see Section 36.50).

1. MonitoringContinuous monitoring of the cavern pressure (daily),and formation fluid temperature (6[B]. monthly)Cavern andfill cavernmust volumebe (periodically)recorded once at the end of operations. This can provide information regarding the cavern's natural closure characteristics and any ensuant pressure buildup, as well as information on mechanical integrity of the wellbore, salt creep-closure rate analysis, and flow rate calculation.
2. IntermittentContinuous gas detection (Section 3.1.1.1) must remain operational until closure of the well [C]. Monthly gas composition monitoring via species-specific gas monitors (with a resolution of at least 0.01 vol%) or lab analysis, if sampled, for emissions of CO2₂, CH4₄, hydrocarbons (including short-chain alkanes), N₂, O2₂ and VOCs at the wellhead (6 monthly) is required, where applicable and when gas volumes allow, until closure of the well [C]. If any emissions outside of the normal average baseline range for any of these gases occur, thena furtherTriggered monitoringGas ofInvestigation gases(Section should3.1.3.1) takemust place.be Furtherinitiated, monitoring entails measurements ofcomprising:
   1. Concentrations (e.g., CO₂, CH₄, N₂, O₂ and VOCs), usually measured by GC-MS
   2. Stable isotope compositions of CO₂, CH₄ (δ¹³C of CO₂, CH₄ and δD of CH₄), usually measured by an isotope ratio mass spectrometer (IRMS), to determine the source of the bio-gas emissions. δ¹³C must be measured against the standard reference material Vienna Pee Dee Belemnite (VPDB). δD must be measured against the standard reference material Vienna Standard Mean Ocean Water (VSMOW).
3. PeriodicSurface surfaceelevation subsidenceand displacement monitoring, for example using GPS or SAR/inSAR, which willmust be performed every 2 years and compared to baseline data and trends or reference points [B]. This will be used to monitor for indication of salt movement or cavern roof collapse.
4. System IntegrityCorrosion monitoring shouldmust continuebe onconducted a cadence specified by the UIC permit or equivalent . If no ongoing system integrity monitoring is specifiedannually, thenand external mechanical integrity teststesting shouldmust continuebe conducted annually for the first three years after injection [D]. Annulus pressure must be measured monthly, but this frequency can be reduced if measurements are shown to be statistically invariable.
5. The total carbon content of the displaced brine must be measured once at the cadenceend specifiedof duringoperations as an end-member sample for accurate carbon accounting [A]. The following measurements may also be required as per the operationalpermitting phase,authority thisor cancertified be changed as a result of information gathered during the operational/post-emplacement phase and with agreement from Isometric.geologist:

• Formation fluid pH
  • Formation fluid conductivity/salinity
  • USDW pH
  • USDW density
  • USDW TDS

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4.30 Risk of Reversal

BasedThe reversal risk shall be determined on the present understanding, projects applicable to this Protocol are categorized as having a Veryproject Lowby Riskproject Level of Reversal according to the Isometric Standard Risk Assessment Questionnaire. This is because salt caverns are impermeable (and thus act like a closed system)basis. There should be no reversals (as salt is impermeable) unless there is a loss of cavern or well integrity, and this technology does not yet have a documented history of reversals. ABased 2on present levels of scientific knowledge, ++Projects applicable to this Module are typically categorized as having a Very Low Risk Level of Reversal according to the Isometric Standard Risk Assessment Questionnaire (also found in the relevant Protocol). This results in a 1%  buffer pool for willProjects beusing setthis asideStorage as a precaution against CO2 or CH4 gas release or C release during brine displacementModule. This reversal risk will be reassessed at the renewal of the Crediting Period++, or when new scientific research and understandingknowledge arisesare produced.

In instances where reversals are determined to be a result of negligence by the storage operator, Project Crediting may be ceased. Reversals will be accounted for by projects and the Isometric Registry as detailed in the Reversals and Buffer Pools Section 5.6 of the Isometric Standard.

3.3

4.1 Attribution of reversals

When a reversal is detected and quantified, there are multiple considerations that will be taken into account to attribute the reversal to whatever has been emplaced in the cavern.

1. If the Project Proponent was the only entity emplacing into a given cavern, the Project Proponent will take on 100% of the reversal.

2. If the Project Proponent was one of multiple entities emplacing into that cavern, the Project Proponent will be allocated a percentage of the reversed CO₂₂ proportional to the mass of emplaced material. For example:

• A cavern has a total of 200t of material emplaced at the time when the reversal is detected.
• The Project Proponent has emplaced 50t of material in that salt cavern.
• The amount of reversed CO₂ ₂ has been quantified to be 10t.
• The Project Proponent must compensate for 25% (50/200) of 10t CO₂₂ = 2.5t of CO₂₂ .

In instances where reversals are determined to be a result of negligence by the Operator or Project Proponent, project crediting may be ceased.

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5.40 Calculation of CO₂e_Emissions

[math: CO_{2}e_{Emissions}] is the total greenhouse gas emissions associated with a given Reporting Period, [math: RP], or batch, [math: n].

Equations and emissions calculation requirements for [math: CO_{2}e_{Emissions}], including considerations for monitoring activities, are set out in the relevant Protocol and are not repeated in this Module.

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6.50 Closure Requirements

The Operator must monitor the cavern following emplacement completion to determine the three-dimensional extent of the injectate and cavern integrity and demonstrate that no injectate migration out of the salt cavern is occurring, as per the post-emplacement monitoring plan in Section 3.2, above. In addition, due to the emplacement of biomass and bio-oil being a nascent field, if they are emplaced into a cavern alongside another waste material, the long-term effect of the multiple waste types, their interaction and impact on abandonment, has not been investigated and will require stringent monitoring both during emplacement, post emplacement and closure. Post-closure monitoring, for example, surface subsidence monitoring, may be required by the permit and all requirements must be followed.

Prior to closure, an assessment must be completed to demonstrate that cavern integrity will be maintained (for example proving the absences of salt fracture generation) and the emplaced material can be considered stabilized, eliminating the risk of migration or release of the injectate or its degradation products from the cavern to the atmosphere. The cavern integrity assessment must be conducted in the following ways:

1. Measurement of Cavern pressure to ensure it is not pressurized. It must be demonstrated that any natural increase in pressure in the closed cavity due to long-term convergence does not exceed the fracture pressure.
2. Alternatively emerging technologies for measuring cavern integrity can be used, and will be outlined in subsequent Protocol versions and as measurement and monitoring technologies advance.

If the cavern integrity can be demonstrated by the above methods, and is independently reviewed and certified by a registered Professional Geologist (i.e., Chartered Geologist or equivalent), the emplaced material and salt cavern will be considered stabilized and additional monitoring post-closure may be discontinued if allowed under the applicable permit.

The long term stability of the cavern system should also be monitored by measuring surface movement over a period determined and agreed with the UIC or equivalents governing body and will be subject to change. The UIC or equivalents executive director or equivalent may extend the period of post closure monitoring if they determine that the well or cavern may endanger an underground source of drinking water or freshwater aquifer and subject to ongoing analysis.

3

7.5.10 Record keeping

All records associated with the characterization, design, construction, injection operation, monitoring, and cavern closure must be developed, reported in the projectProject design document, to the VVB's and to proper authorities as required by the permit.

AllRecords recordsof laboratory analyses and relevant permit limitations to demonstrate compliance must be maintained in accordance with the well permit and available for review at any point during the Crediting Period or post closure.

Records of all analyses and injections must be maintained by the storage facility or Project Proponent and provided for verification purposes for a minimum of 10five years after wellthe closureend of the monitoring period. 

All closure and post-closure monitoring records must be maintained by the Project Proponent for a minimum of 10 years after closure.These records must be available to be consulted by interested parties for future clarifications if needed.

48.0 Contributors

Rebecca Tyne, Ph.D.

Nicholas Ashmore, Ph.D.

9.0 Definitions and Acronyms

Independent components of Isometric Certified Protocols which are transferable between and applicable to different Protocols.

The amount of time carbon removed from the atmosphere by an intervention – for example, a CDR project – is expected to reside in a given Reservoir, taking into account both physical risks and socioeconomic constructs (such as contracts) to protect the Reservoir in question.

Independent components of Isometric Certified Protocols which are transferable between and applicable to different Protocols.

A mixture of water, organic acids, aldehydes, ketones, sugars, phenols, and other organic compounds derived from the thermal breakdown of biomass. Thermal breakdown of biomass is achieved via thermochemical processes, such as pyrolysis, which heat biomass in low- or no-oxygen environments to high temperatures (~e.g. 350-650°C). Bio-oil is often also referred to as pyrolysis oil or bio-crude.

Describes the addition of carbon dioxide removed from the atmosphere to a reservoir, which serves as its ultimate destination. This is also referred to as “sequestration”.

An output of a process that has no intended value to the producer.

Products that have a significant market value and are planned for as part of production.

A location where carbon is stored. This can be via physical barriers (such as geological formations) or through partitioning based on chemical or biological processes (such as mineralization or photosynthesis).

A United States Government agency that protects human health and the environment.

Underground Injection Control

Those gaseous constituents of the atmosphere, both natural and anthropogenic (human-caused), that absorb and emit radiation at specific wavelengths within the spectrum of terrestrial radiation emitted by the Earth’s surface, by the atmosphere itself, and by clouds. This property causes the greenhouse effect, whereby heat is trapped in Earth’s atmosphere (CDR Primer, 2022).

The term used to describe greenhouse gas emissions to the atmosphere as a result of Project activities.

The organization that develops and/or has overall legal ownership or control of a Removal or Reduction Project.

The area surrounding an injection well described according to the criteria set forth in the U.S. Code of Federal Regulations § 40 CFR.146.06, which, in some cases, such as Class II wells, the project area plus a circumscribing area the width of which is either 1⁄4 of a mile or a number calculated according to the criteria set forth in § 146.06.

A worldwide federation (NGO) of national standards bodies from more than 160 countries, one from each member country.

Standard physical constants as well as standard values set forth by bodies such as the National Institute of Standards and Technology (NIST) or others.

An aquifer, or a portion of one, which supplies or has the possibility to supply any public water supply system, or drinking water for human consumption.

for open systems, biogeochemical and/or physical interactions which occur during the removal process that decrease the CO₂ removal .

The steps of a Project Proponent’s Removal or Reduction process that result in carbon fluxes. The carbon flux associated with an activity is a component of the Project Proponent’s Protocol.

The escape of CO₂ to the atmosphere after it has been stored, and after a Certificate has been Issued. A Reversal is classified as avoidable if a Project Proponent has influence or control over it and it likely could have been averted through application of reasonable risk mitigation measures. Any other Reversals will be classified as unavoidable.

The organizationterm thatused developsto and/orrepresent hasthe overallCO₂ legaltaken ownershipout orof controlthe atmosphere as a result of a Removal or Reduction Project.

A worldwide federation (NGO) of national standards bodies from more than 160 countries, one from each member country.

Standard physical constants as well as standard values set forth by bodies such as the National Institute of Standards and Technology (NIST) or others.

An activity orCDR process or group of activities or processes that alter the condition of a Baseline and leads to Removals or Reductions.

The period of time over which a Project Design Document is valid, and over which Removals, Reductions or Environmental Attributes may be Verified, resulting in Issued Certificates.

The document that clearly outlines how a Project will generate rigorously quantifiable Additional high-quality Removals or Reductions.

A document that describes how to quantitatively assess the net amount of CO₂ removed by a process. To Isometric, a Protocol is specific to a Project Proponent's process and comprised of Modules representing the Carbon Fluxes involved in the CDR process. A Protocol measures the full carbon impact of a process against the Baseline of it not occurring.

RawThe materialdocument that clearly outlines how a Project will generate rigorously quantifiable Additional high-quality Removals or Reductions.

A systematic and independent process for evaluating the reasonableness of the assumptions, limitations and methods that support a Project and assessing whether the Project conforms to the criteria set forth in the Isometric Standard and the Protocol by which the Project is usedgoverned. Validation must be completed by an Isometric approved third-party (VVB).

A process for CO₂evaluating Removaland orconfirming GHGthe Reductionnet Removals and Reductions for a Project, using data and information collected from the Project and assessing conformity with the criteria set forth in the Isometric Standard and the Protocol by which it is governed. Verification must be completed by an Isometric approved third-party (VVB).

Third-party auditing organizations that are experts in their sector and used to determine if a project conforms to the rules, regulations, and standards set out by a governing body. A VVB must be approved by Isometric prior to conducting validation and verification.

A calculation, series of calculations or simulations that use input variables in order to generate values for variables of interest that are not directly measured.

A collection of Removal or Reduction processes that have mechanisms in common.

Any process or activity that releases a greenhouse gas, an aerosol, or a precursor of a greenhouse gas into the atmosphere.

A set of data describing pre-intervention or control conditions to be used as a reference scenario for comparison.

An activity or process or group of activities or processes that alter the condition of a Baseline and leads to Removals or Reductions.

The period of time over which a Project Design Document is valid, and over which Removals, Reductions or Environmental Attributes may be Verified, resulting in Issued Certificates.

A chemical substance used for construction that sets, hardens, and adheres to other materials to bind them together. Ordinary Portland Cement (PC) is the most common cement used in modern concrete. Other types of cement include Ground Granulated Blast-furnace Slag (GGBS), Pulverised Fly Ash (PFA) and natural pozzolans.

A standards organization that develops and publishes voluntary consensus international standards.

Raw material which is used for CO₂ Removal or GHG Reduction.

Total Dissolved Solids.

A satellite-based navigation system.

A common and recognized insurance mechanism among Registries allowing Certificates to be set aside (in this case by Isometric) to compensate for Reversals which may occur in the future.

A database that holds information on Verified Removals and Reductions, and reviewed EACs, based on Protocols. Registries Issue Certificates, and track their ownership and Retirement.

A period during which a Project has any obligations, under the selected Protocol, to submit ongoing Monitoring data to Isometric and the VVB.

510.0 Appendix 1: Monitoring Plan Requirements

This appendix details how the Project Proponent must monitor, document and report all metrics identified within this Module to demonstrate the durability of CO₂ removal. Following this guidance will ensure the Project Proponent measures and confirms CO₂ removed and long-term storage compliance, and will enable quantification of the emissions removal resulting from the Project activity during the Project Crediting Period, prior to each Verification.

This methodology utilizes a comprehensive monitoring and documentation framework that captures the GHG impact in each stage of a Project. Monitoring and detailed accounting practices must be conducted throughout to ensure the continuous integrity of the net CO₂e and crediting.

The Project Proponent must develop and apply a monitoring plan according to ISO 14064-2 principles of transparency and accuracy that allows the quantification and proof of GHG emissions removals.

611.0 Appendix 2: Approved Permitting Regimes

Here is a list of regulatory regimes, which have strong track records of safe injection and publicly available robust regulations. If a signed off permit is from one of these regulatory regimes and specifically states the biomass feedstock being injected is approved for injection, compliance with the permit can be used as evidence for certain requirements (Appendix 1). As new regulatory regimes are developed, this list will be updated.

Current approved regulatory regimes:

• U.S. EPA Underground Injection Control (UIC)
• UK Environment Agency
• Saskatchewan Ministry of Energy and Resources.
• Alberta Energy Regulator (AER)

12.0 Relevant Works

ASTM D5291-21 Standard Test Methods for Instrumental Determination of Carbon, Hydrogen, and Nitrogen in Petroleum Products and LubricantsLubricants_. (2021, November). https://www.astm.org/standards/d5291

_ASTMASTM D373-21 Standard Test Methods for Determination of Carbon, Hydrogen and Nitrogen in Analysis Samples of Coal and Carbon in Analysis Samples of Coal and Coke
_(2021, April). https://www.astm.org/d5373-21.html

Buzogany, R., Reveillere, A., Lampe, B., Borglum, S., Karimi-Jafari, M., Bernhardt, H., 2022. Abandonment of salt caverns: Phase 1: Gap Analysis. Solution Mining Research Institute Research Report 2022-1.

California Air Resources Board. (2018, August 13). Carbon Capture and Sequestration Protocol under the Low Carbon Fuel Standard. https://ww2.arb.ca.gov/sites/default/files/2020-03/CCS_Protocol_Under_LCFS_8-13-18_ada.pdf

Charm Industrial. (2023). Bio-oil Carbon Capture & Sequestration Protocol Under the LCFS. DRAFT.

Charm Industrial. (2023). FAQ | Fastest growing carbon removal technology. Charm Industrial. Retrieved June 14, 2023, from https://charmindustrial.com/faq

Diebold, J.P. (2000). A Review of the Chemical and Physical Mechanisms of the Storage Stability of Fast Pyrolysis Bio-Oils. https://www.nrel.gov/docs/fy00osti/27613.pdf

Energy Information Administration. (n.d.). Biomass explained - U.S. Energy Information Administration. EIA. Retrieved June 14, 2023, from https://www.eia.gov/energyexplained/biomass/

International Energy Agency. (n.d.). Insights Series 2015 - Storing CO2 through Enhanced Oil Recovery -- Analysis. IEA. Retrieved June 14, 2023, from https://www.iea.org/reports/storing-co2-through-enhanced-oil-recovery

International Organization for Standardization. (2006). ISO 14040:2006 Environmental management --- Life cycle assessment --- Principles and framework. https://www.iso.org/standard/37456.html

International Organization for Standardization. (2006). ISO 14044:2006 Environmental management --- Life cycle assessment --- Requirements and guidelines. https://www.iso.org/standard/38498.html

International Organization for Standardization. (2008). Evaluation of measurement data --- Guide to the expression of uncertainty in measurement (ISO JGCM GUM). https://www.iso.org/sites/JCGM/GUM/JCGM100/C045315e-html/C045315e.html?csnumber=50461

International Organization for Standardization. (2011). ISO 14066:2011 Greenhouse gases --- Competence requirements for greenhouse gas validation teams and verification teams. https://www.iso.org/standard/43277.html

International Organization for Standardization. (2017). ISO/IEC 17025:2017 General requirements for the competence of testing and calibration laboratories. https://www.iso.org/standard/66912.html

International Organization for Standardization. (2019). ISO 14064-2:2019. Greenhouse Gases - Part 2: Specification With Guidance At The Project Level For Quantification, Monitoring And Reporting Of Greenhouse Gas Emission Reductions Or Removal Enhancements. ISO. https://www.iso.org/standard/66454.html

International Organization for Standardization. (2019). ISO 14064-3:2019. Greenhouse gases --- Part 3: Specification with guidance for the verification and validation of greenhouse gas statements. ISO. https://www.iso.org/standard/66455.html

Isometric. (n.d.). Isometric --- Glossary: Defining the terms that appear regularly in our work. Isometric. https://isometric.com/glossary

Kansas Department of Health and Environment. Underground Hydrocarbon Storage Program. Retrieved November 15, 2023, from https://www.kdhe.ks.gov/315/Underground-Hydrocarbon-Storage-Program

Matthews, J.B.R. (Ed.). (2018). IPCC, 2018: Annex I: Glossary. In: Global Warming of 1.5°C. An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of... Cambridge University Press. https://doi.org/10.1017/9781009157940.008

Methodology for assessing the quality of carbon credits, Version 3.0. (2022, May). https://carboncreditquality.org/methodology.html

National Renewable Energy Laboratory. (2016). Quantification of Semi-Volatile Oxygenated Components of Pyrolysis Bio-Oil by Gas Chromatography/Mass Spectrometry (GC/MS) Laboratory Analytical Procedure (LAP). https://www.nrel.gov/docs/fy16osti/65889.pdf

National Renewable Energy Laboratory. (2021, October 7). Determination of Carbon, Hydrogen, Nitrogen, and Oxygen in Bio-Oils Laboratory Analytical Procedure (LAP). https://www.nrel.gov/docs/fy22osti/80967.pdf

National Renewable Energy Laboratory. (2022). Corrosivity Screening of Pyrolysis BioOils by Short-Term Alloy Exposures Laboratory Analytical Procedure (LAP). https://www.nrel.gov/docs/fy22osti/82631.pdf

National Renewable Energy Laboratory. (2022). Elemental Analysis of Bio-Oils by Inductively Coupled Plasma Optical Emission Spectroscopy (ICP-OES) Laboratory Analytical Procedure (LAP). https://www.nrel.gov/docs/fy22osti/82586.pdf

Pereira, J.C., 2012. Common Practices -- Gas Cavern Site Characterization, Design, Construction, Maintenance, and Operation. Solution Mining Research Institute, Research report RR2012-03.

Sandalow, D., Aines, R., Friedman, J., McCormick, C., & Sanchez, D. (2020, October 2). Biomass Carbon Removal and Storage (BiRCS) Roadmap. https://www.osti.gov/servlets/purl/1763937

Schmidt, H., Anca-Couce, A., Hagemann, N., Werner, C., Gerten, D., Lucht, W., & Kammann, C. (20118, August 17). Pyrogenic carbon capture and storage. GCB Bioenergy, 11(4), 573-591. https://onlinelibrary.wiley.com/doi/full/10.1111/gcbb.12553

Society of Petroleum Engineers. (2020, April 13). Enhanced oil recovery (EOR) - PetroWiki. PetroWiki. Retrieved June 14, 2023, from https://petrowiki.spe.org/Enhanced_oil_recovery_(EOR)

Stas, M., Auersvald, M., Kejla, L., Vrtiska, D., Kroufek, J., & Kubicka, D. (2020, May). Quantitative analysis of pyrolysis bio-oils: A review. TrAC Trends in Analytical Chemistry, 126. https://www.sciencedirect.com/science/article/abs/pii/S0165993620300868

U.S. Environmental Protection Agency. (2014). Test Methods for Evaluating Solid Waste: Physical/Chemical Methods Compendium (SW-846). https://www.epa.gov/hw-sw846/sw-846-compendium