This DurabilityModule (Independent components of Isometric Certified Protocols which are transferable between and applicable to different Protocols.) details durability (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.) 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 (Independent components of Isometric Certified Protocols which are transferable between and applicable to different Protocols.) details durability and monitoring requirements for bio-oil (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.) and biomass storage (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”.) 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 (An output of a process that has no intended value to the producer.) 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 (Products that have a significant market value and are planned for as part of production.) 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 (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).). 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 (A United States Government agency that protects human health and the environment.) Underground Injection Control (UIC (Underground Injection Control)) 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:
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 (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).)emissions (The term used to describe greenhouse gas emissions to the atmosphere as a result of Project activities.) 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.
The subsurface monitoring approach developed and implemented by the Project Proponent (The organization that develops and/or has overall legal ownership or control of a Removal or Reduction Project.) or Operator (when the Project Proponent is not operating the cavern) must address, via the permitting process and permit compliance, or by additional efforts and documentation:
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.
Potential risks to expected durability of biomass and bio-oil are site specific and may include:
Projects must submit at least one address and/or specific geo-coordinates for the project. Projects may submit multiple project locations – please specify what role each location plays in the project.
[/R-EZXF-0]The
The emplacement cavern must have a current well permit issued by the responsible authority for the location of the injection facility and salt cavern., The permit mustthat specifically identify biomass, bio-oil or an equivalent type of injectate, as acceptable injectates is required. In addition, The Project must comply with all applicable local environmental, ecological and social requirements as well as those set out in the relevant Protocol (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.) and Section Uncertainty in Removals and Reductions of the Isometric Standard.
The Project Proponent must ensure that they meet the requirements of this Module. This monitoring plan must be signed off by a licensed geoscience professional (Professional Geologist (PG/P.Geo), Chartered Geologist (CGeol), European Geologist (EurGeol), or equivalent; suitably experienced in subsurface work and/or in salt cavern gas or waste storage. The sign-off is to confirm the plan is sufficient for the site, and the signed report must be submitted by the Project Proponent to Isometric as part of the PDD (The document that clearly outlines how a Project will generate rigorously quantifiable Additional high-quality Removals or Reductions.). Specifically, the reviewer should sign off on: (1) site characterization report; (2) risk register and mitigation plan; (3) Monitoring/Testing/Reporting plan; (4) well-integrity plan; and (5) demonstration of rigor equivalent to the listed permits. If the signed off permit is from within an approved regulatory regime (see Appendix 2), permit compliance can be used as evidence for requirements that align with this Module and have permit compliance as an evidence option. If a requirement does not allow permit compliance as evidence, the required evidence must be submitted by the Project Proponent.
[/G-01BC-0]For projects operating in locations outside of these regulatory regimes, the Project Proponent must ensure that they meet the requirements of this Module and are equally as rigorous as the permits listed above.
All projects are required to clearly report the regulations for which are utilized at the site, with any deviations from the relevant national/international standards outlined within the PDD upon submission to the relevant validation (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 governed. Validation must be completed by an Isometric approved third-party (VVB).) & verification (A process for evaluating and confirming the net 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).) body (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.)).
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 (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.) within 30 days of submission to the permitting authority, or upon request.
For monitoring requirements not covered under the Approved Permit, the Project Proponent (The organization that develops and/or has overall legal ownership or control of a Removal or Reduction Project.) remains responsible for collecting and reporting all required data directly to Isometric and the 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.) 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 (The organization that develops and/or has overall legal ownership or control of a Removal or Reduction Project.) must notify Isometric and the 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.) immediately of any changes which may impact monitoring requirements. Monitoring plans will be subject to reevaluation following such changes.
The cavern should be characterized in accordance with this Module and the permit application and approval requirements under the UIC or equivalentrelevant regulations. Cavern characterizations must include evaluation of cavern chemistry and conditions, where required, to ensure compatibility of the injectate with the salt cavern.
As part of the permit application, the Operatorit must demonstratebe demonstrated, where applicable, that the cavern:
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 (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.) the injectate behavior and for comparison to future measurements:
Table 1: List of cavern characterization requirements
Parameter | Purpose |
|---|---|
Volume and geometry of the salt cavern | To demonstrate the capacity of the cavern to receive and safely store emplaced material, and to help determine operating pressures. |
Confirmation of minimum cavern wall and roof thickness and distance from edge of salt or other caverns as set by the regulating body | To demonstrate cavern integrity. |
Confirmation of low permeability, lack of highly soluble minerals and structural integrity of salt cavern | To demonstrate lack of migration pathways (A collection of Removal or Reduction processes that have mechanisms in common.) and that any emplaced material will be trapped and unable to migrate out of the cavern |
Identification and characterization of porosity, permeability and mineralogy of the salt cavern "host" rock, and any interbeds of non-salt layers that may be present | To demonstrate lack of migration pathways. |
Cavern specific geotechnical characterization to ensure cavern integrity. For example, things that would typically be done during pre-construction like determination of rock mechanics and regional stress, including strength measurements (e.g., unconfined & confined compressive strength, constant mean stress compression and extension tests, tensile strength) of the cavern walls and overlying formations, compression tests, dissolution tests, overburden/horizontal stress, constant stress creep tests. | To determine Cavern integrity and potential risks. |
Temperature, pH and conductivity/chloride concentration and fluid pressure of the cavern brine. | To determine optimum conditions for cavern stability and identify potential interaction of the injectate under these conditions with the storage complex which may impact whether any potential products (e.g., biogas) are produced and injectate stability. |
Total carbon | To determine baseline concentrations that can be compared to during operation to identify |
δ13C of the compounds of the injectate, where applicable | For determining the source (Any process or activity that releases a greenhouse gas, an aerosol, or a precursor of a greenhouse gas into the atmosphere.) of any produced biogas and extent of reactions (e.g. methanogenesis) as a result of injection. |
Geochemical composition of USDWs within the AOR (where required in the permit) this should include but is not limited to pH, temperature, density, conductivity, total dissolved solids and dissolved gas concentrations | As a baseline (A set of data describing pre-intervention or control conditions to be used as a reference scenario for comparison.) for future measurements to determine if CO2 leaks are occurring. |
An assessment of the potential for ground subsidence and | To determine the risk of ground subsidence and determine a baseline topography across the area of Influence. |
Maximum allowable surface injection pressure | To determine the maximum allowable injection pressure to maintian cavern intergrity. |
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 (The escape of CO₂ to the atmosphere after it has been stored, and after a Credit 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.) as a direct result of brine injection.
Cavern characterization is required to be reviewed every five years as part of the projectProject (An activity or process or group of activities or processes that alter the condition of a Baseline and leads to Removals or Reductions.)Crediting Period (The period of time over which a Project Design Document is valid, and over which Removals or Reductions may be Verified, resulting in Issued Credits.) (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.
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.
The Project Proponent or Operator (when the Project Proponent does not operate the cavern) must ensure that the emplacement well is constructed in compliance with the EPA UIC or equivalent permit. All documentation and records of well construction are required to be maintained and available for review, at any time during the project lifetime.
[/R-RCAG-1]At a minimum, the Operator must ensure that any legacy wells which may exist within the delineated AOR have been evaluated and wells which pose a risk to durability are properly plugged prior to emplacement in order to:
Casing, cement (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.), tubing, packer, wellhead, valves, piping, or other materials used in the construction of each well associated with theThe projectProject must have sufficient structural strength and be designed for beyond the life of theThe projectProject. All surface casing will be set below the lowermost USDW and cemented to the surface. All well materials must be compatible with fluids with which the materials may be expected to come into contact, including the injectate and cavern brines (e.g., corrosion-resistant well casings) and must meet or exceed standards developed for such materials by API, ASTM (A standards organization that develops and publishes voluntary consensus international standards.), ISO, or comparable standards. Utilized standards are required to be clearly outlined within the project design document (PDD) (The document that clearly outlines how a Project will generate rigorously quantifiable Additional high-quality Removals or Reductions.) submitted by the Project Proponent.
The casing and cementing program must be designed to prevent the movement of fluids out of the sequestration zone and above the storage complex.
[/G-EMT0-0]If pre-existing wells are being used for injection or monitoring, special considerations are necessary to ensure the integrity of the well and to prevent fluid migration along the borehole. These must be agreed and checked by the regulating body to determine construction and safety is consistent with well construction requirements. All checks and modifications must be recorded and all records kept. This must include the following:
[/G-29NN-0]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.
The Project Proponent or Operator (when the Project Proponent does not operate the cavern) is required to ensure that the emplacement facility complies with this Module and the well permit, including the development and implementation of the well operating plan as required by the permit. If the permit (for Projects within an approved permitting regime) or approved monitoring plan (for those outside of these jurisdictions) has different monitoring requirements to those stated here, please provide justification of any deviation within the PDD. The Project Proponent must monitor the composition of the injectate and ensure it complies with the relevant permits. All other monitoring is required by the cavern Operator (or Project Proponent if they are operating the cavern) to ensure all material emplaced into or produced from the cavern must be sampled and analyzed in accordance with the approved written waste analysis plan required by the authorizing agency. At a minimum, the permit and associated well operating plan must consider the following:
[/R-C165-1]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 (Raw material which is used for CO₂ Removal or GHG Reduction.) 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.
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. validation and verification body (VVB) (Third-party auditing organizations that are experts in their sector and used to determine ifWhere a projectTriggered conformsGas toInvestigation the(Section rules3.1.3.1) is already active, regulations,individual andalarm standards set out by a governing body. A VVBevents must be approved by Isometric prior to conducting validationlogged and verification.)reported but do not require a separate investigation unless they indicate a materially different or escalating condition [C].
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:
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:
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 (The escape of CO₂ to the atmosphere after it has been stored, and after a Credit 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.), see Section 4.0.
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).
The Project Proponent/Operators must follow any post-emplacement requirements of the UIClocal orpermitting equivalents permit for the specified projectregime, in addition to the following:
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 (A common and recognized insurance mechanism among Registries allowing Credits to be set aside (in this case by Isometric) to compensate for Reversals which may occur in the future.) 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 (The period of time over which a Project Design Document is valid, and over which Removals or Reductions may be Verified, resulting in Issued Credits.)++, 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 (A database that holds information on Verified Removals and Reductions based on Protocols. Registries Issue Credits, and track their ownership and Retirement.) as detailed in the Reversals and Buffer Pools Section 5.6 of the Isometric Standard.
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.
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:
In instances where reversals are determined to be a result of negligence by the Operator or Project Proponent, project crediting may be ceased.
[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.
The Operator must ensure that all permit requirements associated with planning for, preceding with and monitoring of well or storage cavern closure are adhered to and documented as required by the permit. A Cavern Closure Plan must be prepared in accordance with the permit requirements. Site closure must follow this plan and any relevant regulatory jurisdiction requirements for site decommissioning. This must include plugging of any wells within the AOR.
[/R-E9GE-1]CO2 storage agreements with pore space owners will ensure activity in the storage cavern is prohibited for perpetuity following emplacement, ensuring that the injectate will not be subject to pressure disturbances (i.e, emplacement or production activities) in the salt cavern.
[/G-NYHA-0]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:
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.
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 (A period during which a Project has any obligations, under the selected Protocol, to submit ongoing Monitoring data to Isometric and the VVB. ).
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.
Rebecca Tyne, Ph.D.
Nicholas Ashmore, Ph.D.
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.
Table A1 Pre-Injection Monitoring Requirements
Requirement | Measurement Description | Measurement Method | Base Frequency | Required | Requirement Conditions | Required Evidence | Evidence Reporting | Section Reference | ||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
Porosity & Permeability | Porosity & permeability of | Laboratory | Once | Required | Porosity | Approved | ||||||||
Subsurface structures and features | Baseline assessment of | Sonar survey or depth to fill; historical data from cavern construction | Once | Required | Testing data — survey results | Approved Permit, literature, or testing data | [Section 2.2] | |||||||
Cavern volume | Once | Required | Predicted total volume | Approved Permit, literature, or testing data | [Section 2.2] | |||||||||
Well bottom cavern pressure | Pressure of fluids in the | Bottomhole | Once | Required | Testing data — pressure logs | Testing data | ||||||||
Emergency Response Plan | Written emergency response plan and procedure in case significant loss of | Required | Emergency response plan | Emergency response plan | Section 3.1 | |||||||||
Formation fluid temperature | Temperature probe; calculation | Once | Required | Testing data; calculation — temperature log | Approved Permit or testing data | |||||||||
Formation fluid pH | pH meter | Once | Required | Testing data — pH | Approved Permit or testing data | |||||||||
Formation fluid conductivity/salinity | e.g., conductivity probe or other | Once | Required | Testing | Approved | |||||||||
TOC of the formation water | TOC of displaced brine on the first day of injection to represent background cavern conditions | e.g., | Once | Required | Testing | Approved | ||||||||
Maximum allowable emplacement pressure | Maximum pressure at injection wellhead to prevent fracturing of | In coordination with regulator | Once | Required | Permit | Permit | ||||||||
Surface elevation & displacement | e.g., SAR/InSAR, surface or subsurface tiltmeters, GPS instruments | Once | Required | Baseline surface elevation data | Approved Permit or testing data | |||||||||
USDW temperature | Temperature probe; calculation | Once | Required under certain circumstances | If required by permit | Testing data — temperature | Approved Permit or testing data | ||||||||
USDW salinity/conductivity | e.g., conductivity probe or other method | Once | Required under certain circumstances | If required by permit | Testing data — conductivity, salinity, or chloride content | Approved Permit or testing data | ||||||||
USDW dissolved gas concentration | Gas chromatography | Once | Required under certain circumstances | If required by permit | Testing data — gas concentrations | Approved Permit or testing data | ||||||||
USDW pH | pH meter | Once | Required under certain circumstances | If required by permit | Testing data — pH | Approved Permit or testing data | ||||||||
USDW density | Standard methodology | Once | Required under certain circumstances | If required by permit | Testing data — density | Approved Permit or testing data | ||||||||
USDW TDS | TDS meter | Once | Required under certain circumstances | If required by permit | Testing data — TDS | Approved Permit or testing data |
Table A2 Operational Monitoring Requirements
Requirement | Measurement Description | Measurement Method | Base Frequency | Required by the Protocol | Requirement Conditions | Required Evidence | Evidence Reporting | Section Reference | |||
|---|---|---|---|---|---|---|---|---|---|---|---|
Emplacement pressure | Surface emplacement pressure; must either be gravity fed or emplaced below maximum allowable emplacement pressure | Wellhead pressure sensors | Continuous | Required | Testing data — pressure log | Approved Permit or testing data | |||||
Emplacement rate and volume | The rate and amount of material being emplaced | Flow meter | Continuous | Required | Testing data — flow data | Testing data | |||||
Injectate stream pH | pH meter | One sample per | Required | If | Testing data — pH | Approved Permit or testing data | Section 3.1.1 | ||||
Injectate stream temperature | Temperature | Daily | Required | Testing | Approved | 3.1.1 | |||||
Injectate conductivity or other salinity measurement | e.g., | One sample per day | |||||||||
Required | Testing data — conductivity, | ||||||||||
Testing | |||||||||||
| 3.1.1 | |||||||||||
TOC of injectate | Total organic carbon | e.g., TOC analyzer | One | Required | Testing | Testing data | |||||
Analysis of bio-oil constituents | Gas chromatography–mass spectrometry | One sample per injection batch | Required under certain circumstances | If bio-oil is being injected | Testing data — concentrations of bio-oil constituents | Testing data | |||||
Average solids concentration of injectate | Weight of total solids | One sample per production batch | Required | Testing data — average solids content | Testing data | ||||||
Total acid number (TAN) of bio-oil | Titration (ASTM D664-18e2, ASTM D3339-21, ASTM D974-22) | One sample per injection batch | Required under certain circumstances | If bio-oil is being injected | Bio-oil characterization — total acid number | Testing data | |||||
Density of injectate | Density of the biomass/bio-oil being injected | Standard methodology | One sample per injection batch | Required | Testing data — density | Testing data | |||||
Water content of bio-oil | One sample per injection batch | Required under certain circumstances | If bio-oil is being injected | Water concentration (wt%) | Testing data | ||||||
Annulus pressure | Pressure within the wellbore annulus | Annulus pressure sensor | Continuous | Required | Testing data — pressure log | Approved Permit or testing data | |||||
Corrosion monitoring | Monitoring of well casing for | Corrosion | Annual | Required | Testing data — evidence of no corrosion | Approved Permit or testing data | |||||
External mechanical integrity tests | Monitoring of external integrity (cement) to prevent leaks from the | e.g., | Annual | Required | Testing data — no evidence of loss of well conformity | Approved Permit or testing data | |||||
Well | Pressure of fluids in the cavern | Bottomhole pressure sensor or calculated from wellhead pressure sensors | Continuous | Required | Testing data — pressure logs | Testing data | |||||
Subsurface structures and | To | Periodic, | Once | Required | Testing data — survey results | Approved Permit, literature, or testing data | Section 3.1.3 | ||||
Cavern fill | Depth to fill, sonar survey or equivalent | Quarterly | Required | Testing data — cavern fill | Testing data | ||||||
Wellhead gas composition | Species-specific gas monitors (≥0.01 vol% resolution), gas chromatography, or lab analysis if sampled | Monthly | Required under certain circumstances | If Triggered Gas Investigation is ongoing | Concentration of gaseous species present | Testing data | |||||
Induced seismicity | Monitoring for seismic activity caused by operations | Monitor regional seismic data for events using existing databases | Continuous | Required | Notification of any events over magnitude 2.7 | Notification of seismic event | |||||
Surface elevation & displacement | e.g., SAR/InSAR, surface or subsurface tiltmeters, GPS instruments | Every 2 years | Required | Surface elevation data | Approved Permit or testing data | ||||||
Formation fluid pH | pH of the displaced brine | pH meter | Initially | Required | Testing data — pH | Approved Permit or testing data | Section 3.1.3 | ||||
Formation fluid conductivity/salinity | Salinity/conductivity of the displaced brine | e.g., conductivity probe or other method | Initially | Required | If | Testing data — conductivity, salinity, or chloride content | Approved Permit or testing data | Section 3.1.3 | |||
Formation | Temperature of the displaced cavern brine | Temperature probe; calculation | Initially | Required | Testing data — temperature log | Approved Permit or testing data | Section 3.1.3 | ||||
Total carbon in the formation fluid | Gas chromatography | As per permit | Required under certain circumstances | If required by permit | Testing data — carbon concentration | Approved Permit or testing data | |||||
Formation fluid bio-oil constituents | Analysis of bio-oil constituents in displaced brine | Gas chromatography-Mass Spectrometry | As per permit | Required under certain circumstances | If required by permit, or if leak determined | Testing data - concentrations of bio-oil constituents in water samples | Testing data | ||||
Formation fluid TOC | Total organic carbon of displaced brine | TOC analyzer | Every two weeks for 3 months; if consistent, monthly for 6 months; then quarterly for 2 years; then every 6 months | Required | wt% C in displaced brine | Testing data | |||||
USDW pH | pH meter | As per permit | Required under certain circumstances | If required by permit | Testing data — pH | Approved Permit or testing data | |||||
USDW density | Standard methodology | As per permit | Required under certain circumstances | If required by permit | Testing data — density | Approved Permit or testing data | |||||
USDW TDS | TDS meter | As per permit | Required under certain circumstances | If required by permit | Testing data — TDS | Approved Permit or testing data | |||||
Cavern fill | Determination of cavern fill depth | Sonar surveys | Once — end of operations | Required | Testing data — sonar survey | Testing data |
Table A3 Post-Injection Monitoring Requirements
Requirement | Measurement Description | Measurement Method | Base Frequency | Required by the Protocol | Requirement Conditions | Required Evidence | Evidence Reporting | Section Reference | |||
|---|---|---|---|---|---|---|---|---|---|---|---|
Annulus pressure | Pressure within the wellbore annulus | Annulus pressure sensor | Initially monthly; may be reduced over time | Required | Testing data — pressure log | Approved Permit or testing data | |||||
Corrosion monitoring | Monitoring of well casing for corrosion | Corrosion coupons, flow loops, multi-finger calipers | Annually | Required | Testing data — evidence of no corrosion | Approved Permit or testing data | |||||
External mechanical integrity tests | Monitoring of external integrity (cement) to prevent leaks from the well into surrounding media | e.g., | Initially annually; may be reduced after a minimum of 3 years | Required | Testing | Approved Permit or testing data | |||||
Well bottom cavern pressure | Pressure of fluids in the cavern | Bottomhole pressure sensor or calculated from wellhead pressure sensors | Continuous | Required | Testing data — pressure logs | Testing data | Section 3. | ||||
Wellhead gas composition | Species-specific |
| Required under certain | If wellhead gas is | Concentration | Testing | |||||
Induced seismicity | Monitoring for seismic activity caused by operations | Monitor regional seismic data for events using existing databases | Continuous | Required | Notification of any | Notification | |||||
Surface | e.g., | Every 2 years | Required | Surface | Approved Permit or testing data |
| |||||
Formation | pH meter | As per permit | Required under certain circumstances | If required by permit | Testing data — pH | Approved Permit or | |||||
Formation | e.g., | ||||||||||
As per permit | Required | If required by permit | Testing data — conductivity, salinity, or chloride content | Approved Permit or testing data | |||||||
Formation fluid temperature | Temperature of cavern brine fluid | Temperature probe; calculation | Continuous unless otherwise stated in the permit | Required | Testing data — temperature log | Approved |
| ||||
Formation | Total |
| |||||||||
Once | Required | Testing data — TC (wt% C) | Approved Permit | ||||||||
USDW | pH | As | Required under certain circumstances | If required by permit | Testing data — pH | Approved Permit or testing data | |||||
USDW density | Standard methodology | As per permit | Required under certain circumstances | If required by permit | Testing data — density | Approved Permit or testing data | |||||
USDW TDS | TDS meter | As per permit | Required under certain circumstances | If required by permit | Testing data — TDS | Approved Permit or testing data | |||||
Cavern fill | Determination of cavern fill depth | Sonar surveys | Once — end of operations | Required | Testing data — sonar survey | Testing data |
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:
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
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. ↩
https://www.ieabioenergy.com/wp-content/uploads/2019/09/Task-39-Drop-in-Biofuels-Full-Report-January-2019.pdf↩
Dusseault, M.B., Rothenburg, L., Bachu, S., 2002. Sequestration of CO2 in Salt Caverns. Journal of Canadian Petroleum Technology. https://doi.org/10.2118/2002-237↩
Davidson, B.C., Dusseault, M.B., 1997. Salt Solution Caverns for Petroleum Industry Wastes. SPE/EPA Exploration and Production Environmental Conference. https://doi.org/10.2118/37889-MS↩
Duyvestyn, G.M., Davidson, B.C., Dusseault, M.B., 1998. Salt Solution Caverns for Petroleum Industry Toxic Granular Solid Waste Disposal. SPE/ISRM Rock Mechanics in Petroleum Engineering. https://doi.org/10.2118/47250-MS↩
Davidson, B.C., Dusseault, M.B., Lemieux, B., 1997. Design And Management Of Salt Solution Caverns For Toxic Waste Disposal. https://doi.org/10.2118/97-151↩
Area of Review (AOR) is the representation of the cavern extent on the ground surface; a surface delineation of subsurface pressure influence resulting from emplaced materials ↩︎ ↩
Influence Area is the area defined for subsidence monitoring by the regulatory agency or operator, if not otherwise specified in the permit ↩
For Class V wells, the well must be permitted and not 'authorized by rule', and must consider the specific emplacement and durable storage of bio-oil and/or biomass in the geologic reservoir. As of writing, the utilization of Class V wells should be limited to wells operating under the Other / Experimental category of Class V wells or other appropriate well type as approved by the UIC permitting authority. ↩︎ ↩
Cal. Code Regs., tit. 14, § 1724.14, “Pre-Rulemaking Discussion Draft 04-26-17 Updated Underground Injection Control Regulations,” (2017). Not accesible in the EU, Copy available on request. ↩