IRGC Project Proposal

Regulation of Deep Geological Sequestration of Carbon Dioxide.

G. Morgan and E. Wilson

Introduction

Since the beginning of the industrial revolution, the atmospheric concentration of carbon
dioxide (CO2), released when coal, oil and natural gas are burned, has grown by
approximately 30%. Because of this continuing build-up of CO2 and other heat-trapping
greenhouse gases, the average temperature of the planet has already warmed by 0.6+0.2°C
and by the end of this century the increase will be between 1.4 to 5.8°C (IPCC WG1, 2001).
While these increases may sound modest, they are large enough to produce profound impacts.
For example, by the end of the century the Arctic Ocean may be ice-free in late summer1;
many alpine meadows and glaciers may be lost; many mangroves, coastal marshes and coral
reefs (key breeding grounds for many marine species) will have disappeared; tropical
hurricanes and typhoons will likely have become stronger; and, because water expands as it is
warmed, the sea level will have risen, threatening low lying areas such as Venice and the
Netherlands and adding to the impacts of storm surge (IPCC WG2, 2001; Arctic Climate
Impact Assessment, 2005). Several leading ocean scientists also think that there is a high
probability that by the end of the century the "thermohaline circulation," that today warms
Northern Europe, may collapse, bringing sudden and profound climate impacts (Zickfeld,
2005).

Unlike conventional pollutants, once they enter the atmosphere a large proportion of
greenhouse gases remain there for a century or more. Thus, to stabilize atmospheric
concentration of CO2 at a level that does not cause serious damage, the world is going to have
to reduce emissions by roughly an order of magnitude. This transformation will require a
complete and radical change in the nature and structure of the energy system posing a
significant challenge to those responsible for it and to the financial services sector. While
conservation will become increasingly important, even if we use energy much more
efficiently the world will still need more energy, especially to raise the standard of living of
more than 3 billion residents in the developing world.

Perhaps in a century the world will be able to meet its energy needs largely with renewable
sources such as wind energy or advanced solar coupled with energy storage or from new
technologies still in the early stages of development. However, for the next several decades
technical limitations and the high costs associated with renewable energy and storage mean

1
Thus destroying seal and polar bear habitat, profoundly disrupting the life of native peoples, and opening the
Arctic Ocean to marine shipping (and possible oil spills, etc.).
that much of the world's energy needs in a CO2-constrained world will still have to come from
fossil fuels.

Carbon capture and sequestration

Coal with carbon-capture and deep geological sequestration (CCS)2 is the most promising
emerging technology, and one that both technically and politically, could play a key
transitional role in moving us toward a carbon-managed energy system.

While carbon dioxide can be separated from flue gas after conventional combustion using
amine scrubbers, in the long run integrated gasification combined cycle (IGCC) or other
advanced coal technologies (such as combusting in pure oxygen) are likely to prove far more
cost effective. Once separated and transported, CO2 can be injected into deep (>1km
underground) geological formations such as aging oil fields (for enhanced oil recovery), coal
seams that are too deep to ever be mined, and deep briny aquifers. The majority of large point
sources of CO2 are within 300 km of potentially suitable storage formations. IGCC with CCS
is rapidly becoming a reality and various other advanced coal projects are planned 3. In
addition to electric power, the technology can also be used to produce hydrogen or "synthetic"
natural gas or liquid fuels. Assessments by several investigators (Rubin et al. 2004; Specker,
2005) and the recent special review conducted by the IPCC (2005) all indicate that the costs
of CO2-free electricity generated with CCS will probably be only about 20% more than the
costs of electricity produced with modern pulverized coal plants without CO2-capture.

The problem of CCS regulation

As CCS technology becomes widespread, the sequestration of carbon dioxide in deep

geologic reservoirs must be regulated in such a way as to protect ecological and public health
and ensure that overarching climate objectives are met (Wilson, et al., 2004). The lack of
consistent norms and standards, both domestically and internationally could simultaneously
increase the investment portfolio risk and exacerbate the potential harm to local populations

2
We use the word "sequestration" because it is neutral. Some use "storage" but that word implies an intention
of future use of the material being stored, which is not really accurate. Some use the word "disposal" which is
accurate, but carries negative connotations because of inadequate past care in other disposal programs.
3
The chemical industry operates more than a hundred gasifiers world wide. For example, Eastman Chemical
operates two in the Tennessee, which achieve reliabilities above 98%. There are two operating gasifiers now
being used to generate electricity in the US – the Wabash Valley Plant in Indiana and the Tampa Electric Polk
Station in Florida. The residual tar-burning Sarlux plant in Sardinia (producing, steam, H2 and electricity) and
the solid and liquid waste plus coal SVZ plant in Spreewitz, Germany (producing electricity, steam and
methanol) are also operational IGCC plants, using a variety of feedstocks. Vattenfall plans to build a lignite
fueled Oxyfuel plant with carbon capture at Schwarze-Pumpe, Germany, to be operational in 2008. In the US
both AEP and Southern are planning to build gasification plants. CO2 has long been used for enhanced oil
recovery in the oil industry. In the US a pipeline has been built from the North Dakota Great Plains Synfuels
coal gasification plant up to the Weyburn oil field in Saskatchewan, Canada where it is injected for enhanced oil
recovery. In Europe CO2 sequestration has been underway for several years at Statoil's offshore Sleipner field in
the Norwegian North Sea. Sequestration is also underway in the Algerian desert at the In Salah gas project built
by BP-Amoco, Statoil and Sonatrach.
and the environment from uncontrolled leakage to the surface or near subsurface4. From the
perspective of a carbon trading scheme, the value of a tonne of sequestered CO2 is dependent
on the security of the storage reservoir. Inconsistent criteria for injection, monitoring, and
verification of injected CO2, as well as unresolved legal questions, will potentially increase
transaction costs, create unnecessary project liability and add an overall level of uncertainty to
the investment portfolio of carbon sequestration projects.

If CCS is to be widely used, regulatory frameworks must be developed which:

- Assess the adequacy of proposed reservoirs and then track the disposition of the
injected materials.5
- Resolves issues of sub-surface rights.6
- Assure that the process is safe, and protect the local environment.7
- Assure that leak rates to the atmosphere (if any) are known and fall below acceptable
limits.
- Assure that permits associated with injected CO2 can be reliably traded in national and
international markets, and that the value of those permits is well enough established to
allow insurance and other guarantees to operate.

Aim and scope of the project

To date very little work has been done to develop and evaluate possible alternative regulatory
frameworks, or explore how a range of different national regulations might coalesce into an
agreed international regulatory framework. For example, the recent IPCC review of CCS
gives these topics only very cursory treatment in comparison with the much more extended
discussions provided on technical and economic issues.

In order to produce initial results promptly while also begin comprehensive in the longer run,
we plan to divide the project into two phases:

Phase 1: Will focus on North America and Europe, because these two regions are first likely
to engage in CCS on a large scale and also have developed relevant legal frameworks.

Phase 2: After completing Phase 1, and building on the results from that work we hope to
move on to examine the situation in Japan, New Zealand, Australia, China, India and other
major coal-burning countries.

4
The potential negative publicity associated with any large scale accident should not be underestimated and
could significantly stall or derail the widespread adoption of this novel technology, without which the world may
find it virtually impossible to reduce CO2 emissions by > 90%.
5
In much current injection activity involving other types of waste fluids, characterization of the receiving
reservoir is conducted only as a "paper" and computational modeling study.
6
Laws governing sub-surface injection of waste fluids are often quite different from those governing mineral
rights. Issues of trespass and liability can become very important (Wilson, 2004).
7
In many cases there is no long-term monitoring of the fate of the injected fluid beyond checking that there is
not leakage around the well stem itself. One important exception has been the work of Statoil at its Sleipner
field in the Norwegian North Sea where regular systematic imaging has allowed a continued monitoring of the
fate of the injected fluid.
In Phase 1 of the project a team of investigators under IRGC will:
1) Review existing national regulations governing deep geological injection.
2) Evaluate those regulations as they may or may not support the needs of safe and
permanent large-scale injection of CO2.8
Then, informed by the results of tasks 1 and 2,
3) Commission several qualified authors to prepare brief outlines of what they believe
would constitute an appropriate regulatory framework.
4) Run a small invitational workshop at which each of the proposals is outlined, and then
the pros and cons of each are discussed.
5) Prepare a final IRGC report which discusses the pros and cons of alternative
regulatory approaches (and reproduces the several specific proposals prepared for the
workshop in a set of appendices). We would also plan to covert this into a paper to be
published in the referred scientific literature.
6) Run a discussion workshop with relevant stakeholders to present and discuss findings
and identify future steps.

This project is especially relevant because:

• The control of CO2 is a global problem,and any adopted policies will have an effect
throughout all industry sectors;
• International assurances must be provided so that nations that are doing deep
geological sequestration do so in a safe and robust way, ensuring that it does not put
the planet at risk of sudden catastrophic releases that could harm people, the economy
and the environment;
• Trading of CO2 permits will need to involve all the major industrial nations and which
will require standardized rules, and internationally accepted standards, monitoring and
certification upon which major insurance and other financial institutions can rely.
• Inadequate regulatory frameworks may, among other things, cause obstacles for
investors if legal and reliability issues remain unresolved or ambiguous.

Costs and time scale of the project

We estimate the direct cost of steps 1 and 2 of Phase 1 of the project at ~25k USD (~32k
CHF) and of steps 3 to 6 at ~145k USD (~186k CHF). For phase 2, the costs will be a further
~20k USD (~25k CHF) for steps 1 and 2 and ~100k USD (~128k CHF) for steps 3 to 6.

Duration of Phase 1 of the project: approximately 1 year

Project coordinator: Prof. Elizabeth Wilson (resumé attached) will serve as project
coordinator

IRGC Steering Committee: Lutz Cleemann, Wolfgang Kröger, Granger Morgan

8
For the US, and Canada and excellent start on Steps 1 and 2 is provided by recent work of Wilson (2004),
Keith et al. (2006) etc.
References:
Arctic Climate Impact Assessment, Impacts of a Warming Arctic, Cambridge University Press, 2004.

IPCC, Climate Change 2001, report of WG1, The Scientific Basis, and WG2 Impacts, Adaptation and
Vulnerability, Cambridge University Press, 2001.

IPCC, Carbon Dioxide Capture and Storage, The Intergovernmental Panel on Climate Change, Bert Metz,
Ogunlade Davidson, Heleen de Coninck, Manuela Loos, Leo Meyer (editors), 2005.

Keith, D.W., J. Guiardina, G. Morgan, E. Wilson. "Regulating the Underground Injection of CO2,"
Environmental Science and Technology, in press.

Rubin, Edward S., Anand B. Rao and Chao Chen, "Comparative assessment of fossil fuel power plants with CO2
capture and storage," Proceedings of the 7th International Greenhouse Gas Technologies Conference,
Vancouver, Canada, Sep 5-9, 2004.

Specker, Steven, "New Base Load Generation Options: Portfolio of technologies," EPRI Summer Seminar,
2005, available at:
http://mydocs.epri.com/docs/CorporateDocuments/Newsroom/SumSem_Specker.pdf

Wilson, E.J., M. Figueiredo, "Geologic Carbon Dioxide Sequestration: An analysis of subsurface property law,"
Environmental Law Reporter, in press, 2006.

Wilson, E.J., "Subsurface Property Rights: Implications for Geologic CO2 Sequestration, in Underground
Injection Science and Technology, J. Apps and C.-F. Tsang, (editors), in press.

Wilson, E.J., D.W. Keith, and M. Wilson, "Considerations for a Regulatory Framework for Large-Scale
Geologic Sequestration of Carbon Dioxide: A North American Perspective," Proceedings of the 7th
International Greenhouse Gas Technologies Conference, Vancouver, Canada, Sep 5-9, 2004.

Wilson, E. J., T. L. Johnson, D. W. Keith, “Regulating the Ultimate Sink: Managing the risks of geologic CO2
storage.” Environmental Science and Technology , 37, 3476-3483, 2003.

Zickfeld, K. , A. Levermann, T. Kuhlbrodt and S. Rahmstorf, G. Morgan, D. Keith, "Present state and future
fate of the Atlantic meridional overturning circulation as viewed by experts," manuscript being finalized for
submission to Climatic Change, Potsdam Institute for Climate Impact Research
2005.
 Elizabeth Joan Wilson

Contact Information

Humphrey Institute of Public Affairs

University of Minnesota
301 19th Avenue South
Minneapolis, MN 55455
Phone: 612-626-4410
Email: [email protected]

Current Position

University of Minnesota Assistant Professor

Humphrey Institute of Public Affairs August 2005- present
Center for Science, Technology and Public Policy
Minneapolis, MN 55455

• Teach courses to graduate students on environmental, energy and climate policy

Research Interests

Environmental and Energy Policy: regional, national, and international scales, multi-pollutant and
multi-media analysis, carbon constrained economy, geologic carbon sequestration
Science and Technology Policy: development of emerging technologies, diffusion, unanticipated
consequences and externalities, development of governance and regulatory systems for emerging
technologies
Sustainable Development

Education

Ph.D., Engineering and Public Policy December 2004

Carnegie Mellon University, Pittsburgh, PA
Title : Managing the Risks of Geologic CO2 Sequestration: A Regulatory and Legal Analysis
Dissertation Committee:
David W. Keith, Carnegie Mellon University, Engineering and Public Policy (chair)
M. Granger Morgan, Carnegie Mellon University, Engineering and Public Policy
Sally M. Benson, Lawrence Berkeley National Laboratory
David Gerard, Carnegie Mellon University, Engineering and Public Policy

Master in Human Ecology September 1997

Vrije Universiteit Brussel, Brussels, BELGIUM magna cum laude
Title: Incorporating Environmental Variables into Municipal Solid Waste Planning: Case Study
Pamplona Region, Spain

BA in Environmental Studies June 1991

University of California, Santa Cruz, California

Education Abroad Program August 1989 - August 1990

University of Nairobi, Nairobi, KENYA

Academic and Research Experience

US Environmental Protection Agency Environmental Scientist

Atmospheric Protection Branch May 1999- August 2005
Office of Research and Development
Research Triangle Park, NC 27711

• Perform and publish technology assessments within a multidisciplinary global change context
• Contributing author to IPCC special report on Carbon Capture and Sequestration
• Member of EPA’s working group on geologic carbon sequestration
• Detailed to Department of Energy’s National Energy Technology Laboratory to research
geologic carbon sequestration, 2001-2002
• Manage adaptation of MARKAL energy-economic model for New England states to facilitate
evaluation of regional climate and energy policy options

Centre Entreprise-Environnement Researcher

IAG Management School, October 1996- April 1999
Catholic University of Louvain
1348 Louvain-la-Neuve, BELGIUM

• Explore use of Life Cycle Analysis tools in municipal solid waste management and
planning
• Assess effectiveness of integrated waste and resource management in 11 European cities,
analyzing factors that influence system management, decision-making, and policy choice
• Lead international, interdisciplinary research team on municipal planning, solid waste and
recycling management

Publications

Refereed

Keith, D.W., J. Guiardina, G. Morgan, E. Wilson. "Regulating the Underground Injection of

CO2," Environmental Science and Technology (expected publication December 2005)
Wilson, E.J., M. Figueiredo. "Geologic Carbon Dioxide Sequestration: An analysis of
subsurface property law," Environmental Law Reporter (accepted September 2004,
expected publication February 2006)

Wilson, E.J., Subsurface Property Rights: Implications for Geologic CO2 Sequestration, in
Underground Injection Science and Technology, J. Apps and C.-F. Tsang, Editors.
2004: in press.

Wilson, E.J., D.W. Keith, and M. Wilson, Considerations for a Regulatory Framework for
Large-Scale Geologic Sequestration of Carbon Dioxide: A North American
Perspective, in Peer Reviewed Proceedings of the 7th International Greenhouse Gas
Technologies Conference, E. Rubin and D.W. Keith, Editors. 2004, Elsevier:
Vancouver.

Wilson, E. J., T. L. Johnson, D. W. Keith. 2003 “Regulating the Ultimate Sink: Managing the
risks of geologic CO2 storage.” Environmental Science and Technology 37, 3476-
3483.

Wilson, E. J. (2002). “Life cycle inventory for Municipal Solid Waste management.” Waste
Management and Research 20: 16-22.

Wilson, E. J. (2002). “Life cycle inventory for Municipal Solid Waste management: Part 2
MSW management scenarios and modeling.” Waste Management and Research 20:
23-36.

Wilson, E. J., F. R. McDougall, J. Willmore. (2001). “Euro-trash: searching Europe for a

more sustainable approach to waste management.” Resources Conservation &
Recycling 31: 327-346.

Academic Reports and Other Publications

Wilson, E.J., Forbes McDougall, and Jane Willmore, 1998, “ Towards Integrated
Management of Municipal Solid Waste” Volumes I and II, a report for the European
Recovery and Recycling Association, August 1997, Centre Entreprise-Environnement, Institut
d’administration et de gestion, Université catholique de Louvain, Belgium

Wilson, E. J. (1998) “Life Cycle Inventory Tools in Pamplona, Spain”, Warmer Bulletin,
February 1998.

Conference Presentations

Wilson, E.J., (2004), Considerations for a Regulatory Framework for Large-Scale Geologic
Sequestration of Carbon Dioxide: A North American Perspective, at the 7th International
Greenhouse Gas Technologies Conference, Vancouver, CA, 5-9 September, 2004.
Wilson, E. J. (2003). “Subsurface Property Rights: Implications for Geologic CO2 Storage”
Second International Symposium on Underground Injection Science and Technology,
Berkeley, CA, October 22-25, 2003.

Wilson, E. J. and D. W. Keith (2003). “Geologic Carbon Storage: Understanding the Rules of
the Underground”. Proceedings of the 6th Greenhouse Gas Control Conference, Kyoto, Japan,
1-4 October 2002.

Wilson, E. J., 2001, “Assessing the Regulatory Environment for the Geological Sequestration
of CO2”, presented at the Ground Water Protection Council Conference, Reno, Nevada, 22-
26 September, 2001.

Wilson, E. J., 1998, “Life Cycle Inventory Tools Applied to the Pamplona Region, Spain”,
presented and published in conference proceedings of the Management in Europe in the 21st
Century, 3rd Community of European Management Schools Conference, Institut
d'Administration et de Gestion, Louvain-la-Neuve, Belgium, May 7-9, 1998

Wilson, E. J., 1998, “Incorporating the Environment into Municipal Solid Waste Planning”,
presented at Systems engineering models for waste management, International Workshop,
Göteborg, Sweden, 22-25 February, 1998

Wilson, E.J., 1997 “Influences of Paper Collection on Material Collection and Waste
Management Objectives: A Curbside Dublin Case Study” published in the conference
proceedings of the 13th Municipal Solid Waste Management and Technology, Philadelphia,
PA, Nov. 17-19, 1997

Kestemont, M. P. and E. J. Wilson, 1997, ‘Selective Collection in Prato, Italy,’ Explorec,

Porte-de-Versailles, France, 26-28 March, 1997

Additional Professional Experience

San Francisco Clean City Coalition Program Coordinator

Golden Gate Disposal August 1994-September 1995,
San Francisco, CA 94107

• Published solid waste education and environmental newsletter and publicity materials
• Managed community and youth programs, grant writing, large event planning
• Planned and taught about solid waste management to school and community groups

Embassy of Belgium, Co-operation Executive Assistant

Section December 1993 - May 1994
Dar es Salaam, TANZANIA

• Managed Micro-Intervention Program, evaluating small development grant proposals

National Institute for the Environment Environmental Educator
and the Conservation of Nature Peace Corps Volunteer
BURUNDI, Central Africa June 1992 - November 1993

• Planned and implemented nation-wide environmental education program for Burundian

high schools
• Designed and conducted a national evaluation of environmental clubs
• Developed and taught courses to environmental clubs and community groups
• Created and launched an environmental newsletter for secondary school clubs

United Nations Environment Program Intern

P.O. Box 30552 February - May 1990
Nairobi, KENYA

• Evaluated and analyzed OUTREACH Network users survey for the Information and Public
Affairs division

Job Related Honors, Languages

Awarded Funds for Scientific Development Scholarship (Catholic University of Louvain)

Strong French, good Spanish and fair Swahili