Legal and related scientific issues with regard to the transfer of responsibility of CO2 storage sites
report
In this report a number of issues are put forward associated with the Transfer of
Responsibility as defined in art. 18 of the EU Directive on the geological storage of carbon
dioxide (2009/31/EC). The most important conclusion is that the added value of a postclosure
delay, for example 20 years, until the responsibility take-over by the Competent
Authorities is basically nil. The work done in risk assessment and characterization before a
storage permit is requested must already have been convincing on health, safety and
environmental (HSE) issues before a CO2 storage permit is issued. In the subsequent
injection phase ongoing modeling and monitoring have added to the conviction that the
storage takes place in accordance with the requirements of the Directive. Furthermore, the
injection phase presents the most severe test on the storage container, whereas postclosure
the subsurface system approaches equilibrium.
In discussing equilibrium timescales it is put forward that container-wide geochemical
equilibrium may take many thousands of years to establish. Pressure equilibrium
(hydrostatic equilibrium) may take hundreds of years for large containers. Thus, in many
cases it will be impractical to install a waiting period for even hydrostatic equilibrium to have
occurred
Responsibility as defined in art. 18 of the EU Directive on the geological storage of carbon
dioxide (2009/31/EC). The most important conclusion is that the added value of a postclosure
delay, for example 20 years, until the responsibility take-over by the Competent
Authorities is basically nil. The work done in risk assessment and characterization before a
storage permit is requested must already have been convincing on health, safety and
environmental (HSE) issues before a CO2 storage permit is issued. In the subsequent
injection phase ongoing modeling and monitoring have added to the conviction that the
storage takes place in accordance with the requirements of the Directive. Furthermore, the
injection phase presents the most severe test on the storage container, whereas postclosure
the subsurface system approaches equilibrium.
In discussing equilibrium timescales it is put forward that container-wide geochemical
equilibrium may take many thousands of years to establish. Pressure equilibrium
(hydrostatic equilibrium) may take hundreds of years for large containers. Thus, in many
cases it will be impractical to install a waiting period for even hydrostatic equilibrium to have
occurred
TNO Identifier
533399
Publisher
TNO
Collation
13 p.