REPORT 657 Seabed and overburden integrity monitoring for offshore CO2 storage OCTOBER 2023 Acknowledgements This guideline was written by the IOGP Environment Committee, in collaboration with the Carbon Capture, Transportation, and Storage (CCTS) Committee, Geomatics Committee, and Metocean Committee. Front cover photography used with permission courtesy of © Vismar UK/Shutterstock and © Red ivory/Shutterstock About The Report provides a set of common industry good practices for demonstrating the ongoing integrity of an offshore CO2 storage project and to provide assurance to the operator(s), local regulatory bodies, or public stakeholders that the injected CO2 remains in the storage unit over the full project lifecycle. Using these guidelines, the operator should be able to demonstrate that, in the case of anomalies or unexpected leakage detected in the overburden and/or at seabed, the necessary mitigation measures are in place to identify the issue promptly and thus reduce the impact of the leak to a minimum level. The scope and focus of this Report are on the marine environment, seabed, and shallow overburden, limited to the units above the storage complex. Based on recent research results and industrial projects, this Report proposes a full set of steps and approaches to be used along with advice on the specific available (or emerging) tools and techniques that can be used to provide industry with the most appropriate methods for defining pre-project start-up baseline conditions and the subsequent ongoing shallow focused monitoring plans during a project’s operational life span and after its decommissioning. 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REPORT 657 Seabed and overburden integrity monitoring for offshore CO2 storage Revision history VERSION DATE AMENDMENTS 1.0 October 2023 First release OCTOBER 2023 Seabed and overburden integrity monitoring for offshore CO2 storage Contents Introduction 5 1 Measurement, Monitoring, and Verification (MMV) concepts for CO2 storage 6 1.1 Context and concepts 6 1.1.1 The purpose of MMV 6 1.1.2 Deep-focused versus shallow-focused monitoring 6 1.1.3 MMV philosophy 7 1.1.4 MMV design 7 1.1.5 The bowtie risk assessment framework 8 1.1.6 Preventive monitoring 10 1.1.7 Contingency monitoring 10 2 Baseline and monitoring guidance 11 2.1 Data management 11 2.1.1 Data management justification 11 2.1.2 Data manager and owner roles 12 2.1.3 Data updates 12 2.1.4 Data integration 12 2.1.5 Building a GIS 13 2.1.6 Seabed and shallow overburden data management 15 2.1.7 Managing geodetic integrity 15 2.1.9 Use of existing datasets 18 2.2 Developing the near-surface MMV plan 21 2.2.1 The near-surface MMV - a key element of the overall MMV programme 21 2.2.2 Summary of typical datasets required 22 2.2.3 Ways of handling long-term variability/continuity (drifting baseline) 22 2.2.4 Identification and definition of anomalous events 23 2.2.5 Requirements for verification and attribution 24 2.2.6 Routine surveys versus targeted surveys 25 2.2.7 Anomaly response plans 26 3 Technical notes 28 3.1 Baseline methods 28 3.1.1 Geophysics 28 3.1.2 Environment 29 3.1.3 Metocean and geochemical data requirements 29 4 Seabed and overburden integrity monitoring for offshore CO2 storage 3.2 Monitoring methods 34 3.2.1 Acquisition platforms 34 3.2.2 Acquisition sensors (geophysics, hydroacoustic, geochemistry, biological) 38 3.2.3 Example missions and surveys 42 3.2.4 Data management, processing 46 3.3 Value of information 47 3.4 Workflow decision diagram (to help operators make appropriate choices) 47 Appendix A: Review of regulatory frameworks and standards relevant to seabed and overburden integrity 50 A.1. International Regulations 50 A.1.1 The London Protocol 50 A.1.2 The OSPAR convention: 50 A.2 European Regulations 51 A.2.1 Directive 2009/31/EC (CCS Directive) 51 A.2.2 Directive 85/337/EEC (EIA Directive) 52 A.2.3 Directive 92/43/EEC (Habitats Directive) 52 A.2.4 Directive 2003/87/EC (ETS Directive) 52 A.2.5 Directive 2004/35 (Environmental Liability Directive) 53 A.2.6 Directive 2008/56/EC (Marine Strategy Framework Directive) 53 A.2.8 Regulatory context in the UK 53 A.2.7 Regulatory context in Netherlands 54 A.2.8 Regulatory context in Norway 54 A.3. Examples of regulations from other countries 60 A.3.1 Australian regulations and guidelines 60 A.3.2 Japanese regulations 60 A.4 Standards and recommended practices 63 A.4.1 ISO 27924:2017 Carbon dioxide capture, transportation, and geological storage — Geological storage 63 A.4.2 ISO/FDIS 19901-10 Marine Geophysical Investigations and ISO/FDIS 19901-08 Marine Soil Investigations 63 A.4.3 DNV-RP-J203: Geological Storage of Carbon Dioxide 63 A.4.4 DNVGL-RP-F104: Design and operation of carbon dioxide pipelines 63 Appendix B: Case studies 64 References 66 5 Seabed and overburden integrity monitoring for offshore CO CO22 storage Introduction This Report provides a set of good practices for demonstrating the ongoing integrity of an offshore CO2 storage project and to provide assurance to operators, regulatory bodies, and public stakeholders that the injected CO2 remains in the storage unit as intended. The CO2 should remain underground for at least 1,000 years. With application of these guidelines, operating companies should be able to demonstrate that, in the case of anomalies or unexpected leakage detected in the shallow overburden (geological interval between the CO2 storage cap-rock and the seabed) and/ or at seabed, the necessary mitigation measures are in place to identify the issue promptly and thus reduce the impact of the leak to a minimum level, confined to the shallow overburden, and according to the regulation requirements. The scope and focus of this guidelines are on the marine environment, seabed, and shallow overburden, limited to the units above the storage complex. Based on recent research and development results and industrial projects, the Report proposes a full set of steps and approaches to be used along with advice on the specific available (or emerging) tools and techniques that can be used to provide industry with the most appropriate methods for defining pre-project start-up baseline conditions and the subsequent ongoing shallow focused monitoring plans during a project’s operational life span and after its decommissioning. 6 CO2 storage Seabed and overburden integrity monitoring for offshore CO2 1 Measurement, Monitoring, and Verification (MMV) concepts for CO2 storage 1.1 Context and concepts Geologic CO2 storage is a safe, reliable, and economically feasible technology to unlock the significant potential of offshore CO2 storage for effective climate change mitigation. To achieve this, a set of agreements need to be developed between operators, regulators, and a range of public stakeholders. Meeting legal requirements and demonstrating safe storage through a risk-based monitoring approach are essential. The purpose of a riskbased Measurement, Monitoring, and Verification (MMV) plan is to verify and ensure conformance and containment of the injected CO2. It is based on a systematic site-specific storage containment risk assessment using, for example, the bowtie method and leakage scenarios. Other drivers that influence MMV are country-specific regulatory requirements and stakeholder concerns. For more information, see IOGP Report 652 - Recommended practices for measurement, monitoring, and verification plans associated with geologic storage of carbon dioxide. 1.1.1 The purpose of MMV The main goals of a MMV plan can be summarized using the terms containment, conformance, and confidence. • Containment: provide evidence for the effectiveness of containment system and to address to stakeholder concerns about potential for leakage or to trigger early intervention if needed. • Conformance: demonstrate that the storage is progressing as expected and the longterm behaviour of the CO2 is understood, typically by showing that forward models are consistent with monitoring data. • Confidence: provide data for emission accounting, to support transfer of long-term responsibilities to the relevant authorities and to maintain license to operate (LtO). 1.1.2 Deep-focused versus shallow-focused monitoring To be effective, MMV plan should cover the area of influence where there is potential for impacts due to CO2 storage, including the displacement of formation fluids (different jurisdictions may call this an area of review or area of interest). Further, the MMV programme should assess a comprehensive spatial volume (geosphere, hydrosphere, biosphere, and the environment above a site) and should cover the pre-injection, injection, post-injection, and post-closure phases. The focus of this Report is on seabed and shallow overburden integrity monitoring for offshore CO2 storage projects and therefore a clear distinction between deep- and shallow-focused monitoring is made: • Deep-focused monitoring should identify unexpected migration of CO2 out of the primary storage units (geologic structure), into the overburden and possible movement out of the storage complex leading to a surface leakage. This containment monitoring should be considered an early warning system for leak detection. Refer to 7 Seabed and overburden integrity monitoring for offshore CO CO22 storage IOGP Report 652 - Recommended practices for measurement, monitoring, and verification plans associated with geologic storage of carbon dioxide for further details regarding MMV within geologic structures. • Shallow-focused monitoring aims to detect CO2 migration in the shallow subsurface (including the shallow overburden above the caprock) and possible leakage to surface or seabed. The shallow focused monitoring should be capable of detecting and quantifying possible leakage at the surface that is likely to pose a health and safety threat or environmental impact. Shallow-focused monitoring (for containment and contingency) relies upon near surface geophysical, geotechnical, and environmental monitoring technologies generally developed and implemented by marine geoscientists, oceanographers, and environmental scientists. An important issue connected with shallow-focused monitoring is differentiating possible CO2 leakage from the storage site from the natural variations in CO2 concentrations in the shallow subsurface or surface environments. Anomaly detection and assessment is usually needed before possible leakage can be confirmed. A thorough baseline understanding of the geological and oceanographic parameters will need to be established, firstly to detect anomalous events and, secondly, to determine their root cause. For example, natural fluid fluxes from the seabed are not uncommon and may be incorrectly attributed to injection activities. 1.1.3 MMV philosophy A base case MMV plan should be risk-based (both technical and non-technical risks) and should satisfy regulatory and potentially stakeholder requirements. Leakage scenario studies are recommended to inform acquisition of adequate baseline data to enable reactive contingency monitoring if loss of containment is suspected. A responsible operator of an offshore CO2 storage project will also wish to provide careful definition of the baseline conditions in the shallow overburden and seabed before project start-up, as a basis for demonstration of the ongoing integrity of the project over its lifespan, and eventually to demonstrate the project has no adverse implications for the marine or atmospheric environment. Expected changes to the marine environment and seabed due to other anthropogenic factors should also be considered. 1.1.4 MMV design The MMV design process works within this risk management framework and supports the storage (reservoir) screening process selection by evaluating site-specific storage risks (using the bowtie method, see Section 1.1.5) before proceeding to implement additional safeguards supported by monitoring in the following order: 1) Assess site-specific storage risks: establish definitions for loss of conformance and loss of containment. Identify potential threats and consequences associated with these risk events. 2) Characterize geological safeguards: identify and appraise the integrity and quality of the geological seals. 8 Seabed and overburden integrity monitoring for offshore CO2 storage 3) Select initial safeguards: identify and assess the engineering concept selections that provide safeguards against unexpected loss of well integrity. 4) Evaluate these initial safeguards: evaluate the expected efficacy of these initial safeguards in relation to the identified conformance and containment threats, and their potential consequences. 5) Establish monitoring requirements: define monitoring tasks to verify the performance of these initial safeguards and, if necessary, trigger timely control measures. 6) Select monitoring technologies: select monitoring technologies according to a costbenefit ranking where benefits are judged according to how effective each technology is at each task. 7) Establish performance targets: evaluate the expected monitoring capabilities. 8) Identify contingency monitoring technologies: develop alternative monitoring plans should technologies underperform, or alerts require additional information to assess containment risks. 9) Identify control measures: design interventions to reduce the likelihood or the consequence of any unexpected loss of conformance and containment. These include operational controls and updates to model-based predictions. 1.1.5 The bowtie risk assessment framework The bowtie method provides a framework for a systematic risk assessment of events with the potential to affect CO2 storage performance1,2. The bowtie shows the relationship between the five key elements (Figure 1) that describe how a risk might arise and how safeguards can provide effective protection against the risk and its associated consequences. • Top event: this is the unwanted event, placed in the centre of the bowtie. For example, this could be the movement of injected CO2 outside the geologic storage site. • Threats: these are the possible mechanisms that can lead to the top event. For example, the presence of a permeable fault or fracture system, stress of injection, or poorly plugged abandoned wells. • Consequences: these are the possible adverse outcomes due to the occurrence of the top event such as negative impact on the environment due to CO2 or associated brine emission. • Preventative safeguards: these decrease the likelihood of a threat leading to the top event. For example, multiple geologic seals reduce the likelihood of CO2 ever reaching the surface. • Corrective safeguards: these decrease the likelihood of significant consequences due to a top event. For example, the presence of additional permeable formation below the top seal of a geologic storage site provides an alternative secondary storage. 1 2 Dean M and Tucker O, 2017 Bourne S, Crouch S, and Smith M, 2014 9 Seabed and overburden integrity monitoring for offshore CO2 storage Figure 1: The elements of a bowtie used for subsurface containment risk assessment Within the context of a Measurement, Monitoring and Verification (MMV) plan, both preventative and corrective safeguards can take two distinct forms: Passive safeguards: These are always present from the start of operation and do not need to be activated. There are two types of passive safeguards: Geological barriers identified during site characterization and engineered barriers identified during engineering concept selections. Active safeguards: These engineered barriers may be brought into service in response to some indication of a potential upset condition to make the site safe. Active safeguards require three key components to operate effectively: • A ­ sensor capable of detecting changes with enough sensitivity and reliability to provide an early indication that some form of intervention is required. • A ­ decision logic to interpret the sensor data and select the most appropriate form of intervention. • A ­ control response capable of effective intervention to ensure continuing storage performance or to mitigate consequences. The combination of a sensor, decision logic, and a control response is the mechanism for the additional risk mitigation provided by the MMV plan. The monitoring requirements follow from the set of control measures that could prevent each threat (left side of the bowtie) or correct each consequence (right side of the bowtie) if triggered in time by reliable monitoring. 10 Seabed and overburden integrity monitoring for offshore CO2 storage 1.1.6 Preventive monitoring To maximize detection efficiency and to avoid both false positives and false negatives, a thorough understanding of the marine environment is required. Understanding natural variations is a key issue for shallow monitoring and leak detection, and baseline datasets are an important part of the process. Studies so far have shown that CO2 concentrations in the marine environment vary significantly on daily and seasonal timescales and vary spatially (near-shore versus far-shore) so that establishing a baseline for anomaly detection is itself challenging. Therefore, the use of natural and artificial tracers to enable attribution (e.g., establish if the detected CO2 is from the storage operation) should be assessed. Preventative monitoring near risk features (active pockmarks, shallow faults, abandoned wells, etc.) is recommended considering any potential leakage paths from the reservoir to these features. Early warning signals concerning anomalies detected within the storage unit (reservoir) are likely recorded by borehole technologies (e.g., pressure and temperature gauges) or geophysical methods (e.g., time-lapse seismic). 1.1.7 Contingency monitoring It is expected that the deep-focused monitoring will indicate a potential loss of containment well in time to deploy shallow contingency monitoring. Several research and development projects have studied such shallow contingency monitoring and benchmarked the technologies with controlled CO2 releases resulting in guidelines for CO2 leak detection (gas phase or dissolved phase), location, attribution, and quantification. The studies (QICS, RISCS, ECO2, STEMM-CCS, ETI-MMV, ACT4Storage)3 have also shown that the impact of emitted CO2 is generally limited in space and time due to rapid mixing and dissolution. These projects have demonstrated and qualified several technologies based on nearsurface geophysics, hydro-acoustics, and bio/geochemistry. Some methods use static seabed detection systems (landers) while others use dynamic platforms (surface vessels, AUVs, ROVs, gliders). The technology options which are available are diverse, but likely will require further maturation for long-term deployment, efficient data processing, and enhanced interpretation to enable real-time decision making. 3 QICS = Quantifying and Monitoring Potential Ecosystem Impacts of Geological Carbon Storage (http://www.qics.co.uk) RISCS = Research into Impacts and Safety in CO2 Storage, http://www.riscs-co2.eu/ ECO2 = Sub‐seabed CO2 storage: Impact on Marine Ecosystems, https://www.eco2-project.eu/ STEMM-CCS = Strategies for Environmental Monitoring of Marine Carbon Capture and Storage, https://www.stemm-ccs.eu/ ETI-MMV = Energy Technologies Institute - Measurement, Monitoring and Verification of CO2 Storage https://www.eti.co.uk/ programmes/carbon-capture-storage/measurment-modelling-and-verrfication-of-co2-storage-mmv ACT4Storage = Acoustic and Chemical Technologies for environmental monitoring of geological carbon storage, https://www.ngi.no/eng/Projects/ACT4storage-Technologies-for-monitoring-of-CO2-storage 11 Seabed and overburden integrity monitoring for offshore CO2 storage 2 Baseline and monitoring guidance 2.1 Data management Technical data is a key business asset and fundamental to efficient business processes and quality decisions. It is an integral part of an offshore CO2 storage lifecycle management, supporting better understanding of near surface, well, and reservoir assessment, and facility performance. Obtaining the necessary data to optimize system performance, mitigate HSSE risk, and meet legal and regulatory requirements requires planning and clear links to outcomes. Given the number of data options available, a clearly defined and budgeted data management plan is a key component of a successful MMV project. The data management plan should be defined considering: • Data requirements – existing and new • Data generation, acquisition, processing, and storage requirements • Data governance requirements - ensuring a consistent approach to data handling • Data management requirements over life of field - including storage, retrieval, quality control, spatial integrity, accessibility, visualization, privacy and security • Methodologies and standards requirements for creating, accessing, and regularly updating across diverse data tiers • Data handling requirements at design, planning, execution, and completion stages • Data usage and metadata requirements across multiple applications/software, algorithms, analytics - ensuring high availability and rapid disaster recovery • Data curation, archive and destruction in compliance with retention schedules and guidelines The data management plan should be an active document, updated during the project as required, and referenced in the MMV plan, with a short summary of the data management approach. 2.1.1 Data management justification The CCS MMV plan should ensure that data is accessible, readily discoverable and fit for purpose in terms of quality (completeness, correctness, consistency, currency). Data definition owners should define the business rules by which data quality is measured and quality tagged. Prospective data users should be supported by fully searchable metadata, published in data repositories, and prepared to recognized standards. Data should be accessible to the asset team as well as business partners, customers, suppliers, regulators and other external parties to support effective use and exchange of information and valid business decisions. 12 Seabed and overburden integrity monitoring for offshore CO2 storage Regulatory requirements for greenhouse gas titleholders may include collection and retention of reports, cores, cuttings, and samples that can be retrieved in compliance with applicable legal, regulatory, and contractual obligations. This may include geophysical, geotechnical, and geological survey reports, and all associated processing, interpretation, survey data and reports within the greenhouse gas injection monthly report for each well in the license area. 2.1.2 Data manager and owner roles Dedicated, specialist MMV data acquisition and management support is strongly recommended, to provide suitable points of contact and expertise. The data manager coordinates and manages the collation and archiving of trusted data, to ensure current best practice is followed and long term data availability. The data manager is also responsible for maintaining an evergreen data management plan. The asset owner defines what data, documentation and drawings (including as-builts) are maintained, and for ensuring data availability and currency. Technical integrity assurance should be based on a minimum set of defined drawings and documentation. The final decision on documentation requirements is the responsibility of the eventual asset manager. Storing this data shall conform to agreed asset specific data and document management standards. 2.1.3 Data updates Changes to information technology, applications and services should be managed according to defined processes, to ensure information risks are assessed and appropriate controls are implemented. Data should be built in a consistent manner, supporting accurate interpretation and analysis which in turn promotes better data maintenance and decision-making processes. Review and approval processes should control trusted master data creating and labelling, such that the status of information is always clear. 2.1.4 Data integration Data integration is required from several wide-ranging datasets including atmospheric, water column, seabed, shallow subsurface/overburden, in-well, and reservoir sources. The following data integration and management aspects should be considered during the project planning and execution stages. Suitable specialist support should be engaged where necessary (IT, data management, subsurface, geospatial/GIS, environmental, geochemical, survey, metocean, etc.). 2.1.4.1 Data models Relevant models should be utilized to support automation and standardization of data storage, exchange, integration, and analysis. Examples include the SSDM (Seabed Survey Data Model), PPDM (Professional Petroleum Data Management), WITSML (Wellsite Information Transfer Markup Language), SEGY/SEGD (Society of Exploration Geophysicists formats geophysical data – seismic and shallow geophysical) and P1, 2, 6 and 7-formats (IOGP seismic and wellbore position data formats). 13 Seabed and overburden integrity monitoring for offshore CO2 storage 2.1.4.2 Live data streaming This may be required, for example for seabed pressure monitoring, leak detection, subsea CO2 detection etc. Delivery mechanism, storage medium, latency, bandwidth, redundancy, and reliability should all be considered when designing the data transmission model, based on the criticality, volume and update frequency of the data being streamed. 2.1.4.3 Spatial integrity of data The majority, if not all datasets used or acquired have a spatial component (position). For some datasets, positional accuracy may not be particularly important for integration and analysis (e.g., low resolution regional data types). For many, however, positional accuracy impacts appropriate integration with other datatypes (or time-series analysis) and subsequent interpretation and business decision making processes. Thus, spatial integrity management is important, from acquisition and processing, through data loading and storage, to manipulation, visualization, and exchange/export. Appropriate Coordinate Reference Systems (CRS) and coordinate operations should be fully defined and managed for all aspects of the project. 2.1.4.4 Data visualization and interpretation/analytics applications Several licensed applications may be required to integrate and visualize different datatypes. Typically, software tools may comprise a combination of geophysical/geological subsurface application/s, and an enterprise GIS (Geographic Information System). The GIS component facilitates storage, integration, management, and visualization of several atmospheric, water column, environmental, seabed and shallow geology components. Appropriate management of the MMV enterprise GIS would typically be a core role for the MMV specialist. 2.1.5 Building a GIS Geographic Information System (GIS) software is a flexible and scalable geospatial data integration, visualisation and analysis platform, employed across a broad range of industries and businesses. IOGP members currently use GIS across the exploration and production lifecycle to manage both surface and subsurface data. This existing industry GIS experience, capability and structure is relatively easily transferable to offshore CO2 storage developments. A shallow overburden MMV plan can be considered as another use case for an organization’s enterprise GIS. A key GIS strength is its ability to integrate a variety of data themes across an Area of Containment (AoC), and Area of Influence (AoI). Highlighting spatial and temporal relationships between infrastructure, interpreted geology, plume modelling, injection profiles, monitored responses, and observable change features provides a powerful tool for data driven decision making throughout the lifespan of an offshore CO2 storage project. Due to the duration and complexity of an offshore CO2 storage project, a wide variety of data are acquired, from initial baseline datasets to preventative and contingency monitoring elements. This requires engagement of acquisition contractors to deliver various survey scopes, including infield and downhole sensor deployment. Large data volumes and diversity places significant focus on efficient and consistent data delivery and structure. 14 Seabed and overburden integrity monitoring for offshore CO2 storage It is recommended that a multi-disciplinary team is established to steer development of the GIS. It should establish organisational awareness of the system’s integration, visualization, analytical and publishing role for current operational and containment status at the user desktop, rather than as a specialist’s back-office tool. This establishes a key complementary GIS role in visualizing the MMV plan. The GIS will update as the offshore CO2 storage project progresses through the preinjection, injection, closure and post-closure phases, with the highest activity during the pre-injection and injection phases. Ongoing data management support, however, will continue through to post-closure, as highlighted in Figure 2. Pre-Injection Injection Closure Post-Closure GIS development in support of the MMV Plan 3rd Party and Baseline Data Integration of Site Monitoring Data Compilation of existing Company and 3rd Part data representing the context of the CCS Development, Including: Integration of monitoring datasets, demonstration of seal integrity, CO2 Plume extent and environmental sampling that demonstrates site injection Conformance and minimal seisicity impacts. Integration of monitoring datasets acquired postinjection phase, to demonstrate long term containment of CO2 Plume, and no adverse impact to environment. Ongoing integration of datasets from (minor) monitoring activity, to demonstrate long term containment of CO2 Plume, and no adverse impacts to the environment. In case of Containment breach, identified anomalies subsurface and potentially at seabed that demonstrate location and magnitude of emissions, impact to environment and biosphere. Prepare to Stakeholder engagement for transfer of liability. GIS database used to evidence agreed handover with Government. Administrative Boundaries, Site Areas, Metocean Currents, Seabed / Environmental / Geochemistry / Subsurface Baseline, Well Integrity, Fluid Migration Pathways, Modelled Plume Migration. Preparing for Site Closure Site Handover Reporting Figure 2: Phase development and utilization of GIS for an offshore CO2 storage project Two scenarios below illustrate how the GIS may be implemented, representing low and high case system customisation and resourcing requirements: Cartographic reference: in a relatively simpler application, the GIS visualization may provide a static cartographic reference across the AoC/AoI, utilizing, as a minimum, the GIS data layering capability to develop various themed map products for reporting. With appropriate version control, this GIS implementation style still enables access to historical reference data, as new data is incorporated into the active dataset. Spatial/temporal dashboard: a more complex solution has a stronger focus on digitalization, via a dynamic visual dashboard of spatial features and temporal monitoring data, representing injection sequence history and response. As an production/injection data can be displayed alongside available pressure response data, co-located with near-surface observations and evaluated against available plume migration models. Project teams may focus on a cartographic reference solution initially, but as the project matures into injection, a spatial temporal dashboard solution is likely to develop, to support MMV plan accessibility across multiple disciplines, and to support better-informed business decisions. 15 Seabed and overburden integrity monitoring for offshore CO2 storage The associated GIS development plan and resourcing requirements should be clearly represented in the project’s data management plan. 2.1.6 Seabed and shallow overburden data management For seabed and shallow subsurface/overburden data management, implementation of the IOGP Seabed Survey Data Model (SSDM) is recommended. Originally developed as an oil and gas industry standard for storing, managing, visualizing, and analyzing seabed, shallow sub-surface, and environmental sampling survey data, this fully scalable and extensible model is equally applicable to the management of seabed and shallow-subsurface surveys for offshore CO2 storage projects. This model is described in the following documents: • IOGP Report 462-1 - Guidelines for the use of the Seabed Survey Data Model: this Report provides the SSDM specification for oil and gas exploration and production, handling collection of various seabed and shallow-subsurface survey data in GIS format. • IOGP Report 462-02 - Guideline for the delivery of the Seabed Survey Data Model: this Report provides SSDM guidance to contractors, covering structure and deliverable requirements for GIS data provided to oil and gas operators. Geographic data modelling terminology is used to describe data structure, attribution, cartographic representation, and delivery. The SSDM provides an industry-recognized data model, and a starting point for scaling and extension as required to support management of any additional CCS MMV datatypes not already directly covered by the model, as well as the management of similar data themes at a deeper geological setting within the containment complex. Topics currently not covered in the SSDM include management of various seabed and downhole (continuous) sensor data, plume modelling data, and other types of contextual GIS data. There is some allowance for water column data within SSDM’s environmental sampling objects. While SSDM v2 was designed primarily for static geophysical seabed site surveys, and thus continuous measurement data is not directly catered for, SSDM is extensible, so other use cases, including offshore CO2 storage monitoring, can be incorporated into the model, as part of an enterprise GIS solution. For pipeline data models generally, and the management of seabed data acquired via pipeline inspections, including interfacing with SSDM, see IOGP Report 462-3 - Interfaces between pipeline data models and the OGP Seabed Survey Data Model. 2.1.7 Managing geodetic integrity In support of broader development of the Enterprise GIS database for an offshore CO2 storage project, because ‘location’ is the key integration attribute, data from seismic interpretation and well data management systems often requires the verification of legacy coordinate reference systems and other positioning elements (along with previously acquired shallow geophysical, oceanographic, environmental data etc.). Table 1 outlines some key references for spatial integrity management of various legacy and newly acquired datatypes. 16 Seabed and overburden integrity monitoring for offshore CO2 storage Table 1: Key references for spatial integrity management of various legacy and newly acquired datatypes Theme Purpose Key Reference Geodetic integrity A GIS environment integrates a range of legacy and new data. Ensuring that an appropriate contemporary Coordinate Reference System (CRS) for the location of interest, along with associated transformation parameters for legacy CRSs is key to accurate mapping/visualization, analysis of spatial relationships, and the integrity of reported coordinates, both horizontal and vertical. • IOGP Report 373-01 - Geodetic awareness guidance note Offshore CO2 storage projects require specific awareness of relevant legacy wells and detailed planning of both water producing and CO2 injection wells. Spatial verification of legacy and planned wellbores is a key component of operating performance and risk management. The combination of well and seismic data required particular care with respect potential uncertainty in reported coordinates or location-based references one, other, or both datatypes. • IOGP Report 373-16 - Guidelines for the quality control of proposed well coordinates Wells 17 • IOGP EPSG Geodetic Parameter Dataset • IOGP Report 373-21 -Grid Convergence – Geomatics guidance note 21 • IOGP Report 373-24 -Geomatics Guidance Note 24 – Vertical data in oil and gas applications • Geospatial Integrity of Geoscience Software (GIGS) • IOGP Report 483-7 - P7/17 Wellbore Positioning Data Exchange Format (and User Guide) Seabed and overburden integrity monitoring for offshore CO2 storage Theme Purpose Key Reference Seismic A key workflow is end-to-end management of seismic data within trace interpretation systems, and interpreted horizon and fault export into the GIS environment. Referenced guidelines cover 2D, 3D and time lapse seismic and the 3D seismic bin grid data model. • IOGP Report 483-1u - OGP P1/11 Geophysical position data exchange format – User Guide • IOGP Report 483-6u - IOGP P6/11 Seismic Bin Grid Data Exchange Format - User Guide • IOGP Report 483-6g -Guidelines for the use of the P6 Bin Grid Data Model Shallow subsurface and seabed geophysical data Shallow seismic datasets (high • IOGP Report 373-18-1 resolution and ultra-high resolution Guidelines for the conduct of seismic, and sub-bottom profiler) offshore drilling hazard site broadly may be treated the same surveys as reservoir seismic from a spatial • IOGP 373-18-2 - Offshore integrity perspective. Other key Drilling Hazard Site Surveys – CO2 storage monitoring datasets Technical Notes (e.g., multi-beam echosounder (MBES), and side-scan sonar (SSS) imagery), along with other datasets such as seabed pressure sensors (depth), inclination and acoustic/laser leak detection imagery also require careful spatial management and integration, whether point data or imagery, or interpreted results. Environmental, oceanographic data satellite/ aerial imagery The spatial elements of such • IOGP Report 629 - Application of datasets typically is of lower Remote Sensing Technologies importance, due to their often for Environmental Monitoring more regional scale. However, environmental and oceanographic data is often point sampled’ and CRS and positioning integrity is required to ensure accurate spatial integration with other datatypes, allowing appropriate conclusions to be drawn from the attributes. Likewise, appropriate georeferencing is required for satellite and aerial imagery. 2.1.8 Gathering baseline datasets The near-surface site characterization of the CO2 storage site should be well understood to determine what monitoring readings constitute anomalous and then to determine their source. Section 2.2.2 details the typical datasets that would be used in monitoring. When considering shallow monitoring, the focus is on the determination of containment breaches, rather than conformity or confidence. 18 Seabed and overburden integrity monitoring for offshore CO2 storage At the highest level, these fall into the two categories of being geological characteristics and oceanographic ones. The specifics of these will be examined throughout the guidance sections of this document. To highlight the importance of a robust dataset it is best to introduce the concepts of how a leak will impact these categories. Geological symptoms will be the presence of features of fluid flux disturbance on the sediment, chimney structures and pockmarks visible through geophysical examination while the sediment chemistry can give indications of contamination. Oceanographic measurements take place in the water column where a gaseous phase leak will provide a bubble stream while CO2 concentration will be elevated causing a reaction in the carbonate system. The benthic region is highly dynamic with the movement of water, daily and seasonal factors forcing variability in many of the parameters we are looking to give us an indication of a leak. These are examined in more detail in Section 2.1.4. At this stage it is sufficient to simply identify that a baseline is required to identify anomalous events against, and that the baseline itself has a natural variability. The longer a baseline monitoring campaign is, the more valuable it will be to capture this variability. 2.1.9 Use of existing datasets Most injection sites will have pre-existing datasets from their use as production sites, exploration, or research. Model data may also prove useful, especially in exploring the exposure to and result of risk events. Work from adjacent industries, for example offshore wind site surveys, could also prove valuable. All legacy data will have to be verified to determine: • Its relevance to CCUS applications, as the data was unlikely to have been collected for this purpose • The current validity of the data, given the dynamic nature of the water column and shallow seabed • The repeatability of the data: was the original collection methodology sufficiently temporally and spatially accurate Given the high level of assurance needed to prove the baseline state of the storage area, it is unlikely that existing data will prove sufficient on its own. The use of existing datasets would prove valuable in demonstrating changes prior to a fresh baseline, to establish natural variation. 2.1.9.1 Shallow geology and seafloor morphology Shallow geology and near-surface geophysical/hydroacoustic datasets (using a SubBottom Profiler (SBP), Multi-Beam Echo Sounder (MBES), and/or Side Scan Sonar (SSS)) could be expensive to acquire, in particular over wide areas. Using legacy datasets, when available, could be attractive at a preliminary stage, and would typically be used to identify active natural leak characteristics such as pathways through the sediment and pockmarks. Identifying the natural range of pockmark sizes and locations would prove very valuable in change monitoring during injection operations. Datasets would need to have sufficient resolution to capture these leak features. For shallow geology monitoring, time-lapse 19 Seabed and overburden integrity monitoring for offshore CO2 storage approaches using any technology (HR seismic, MBES, SBP), it is important to consider and be consistent between survey tool parameters such as pulse file used (pulse length, power, frequency range) and acquisition parameters (direction of survey, altitude, and position). Leakage pathways and seabed surface expressions will be dependent on leak rates and shallow overburden composition, it is therefore difficult to define absolute resolutions required and baseline conditions will be limited by the technology available. The credibility of legacy data will also need to be carefully assessed concerning its age and change forcing factors. In areas with high sediment mobility driven by seabed composition and tidal and current forcing, features can change rapidly. In such a case, historic data would be extremely useful with new data to assess natural change. Seabed displacement may also be measured though bathymetric data. Any induced seabed deformation through injection operations is likely to be in the centimetric range at most and differences caused by measurement techniques should be carefully considered. Marine environment and hydrodynamics The marine environment covers both the biology of the storage site and chemistry of the water column and shallow subsurface. It is highly likely that an environmental impact assessment, as defined by the regulator, will have taken place, which will provide a statutory biological baseline even in the presence of large amounts of historical data. In release experimentation the chemical parameters of pH, dissolved CO2, nutrients, nitrate, phosphate and O2, were identified as leakage indicators for CO2 and markers to attribute the source of any changes to biogenic or injection activity.4 These chemical parameters are subject to large diurnal and seasonal variability. In these circumstances, as broad a dataset as possible is desirable so as to fully understand the natural range. A historical record of these parameters would be extremely useful but given the very specific circumstances for their collection it is unlikely that they would exist. The paucity of this data may drive a monitoring strategy based on relative changes observed rather than thresholds being exceeded. For a site with existing infrastructure, there are likely to be suitable hydrographic datasets from preconstruction, and construction measurement campaigns, and potentially also ongoing integrity management campaigns. These will give local forcing mechanisms for dispersion of leaks at higher risk points of interest, such as the injection site. Dispersion via a leakage pathway somewhere in the whole complex site unidentified in site characterization will be on a scale impractical for a comprehensive monitoring campaign. In this case, adjacent legacy datasets may be used in conjunction with tide and current modelling to understand leak dispersion. Biological receptors From the release experiments conducted with close observation of marine wildlife in the UK, no impact was observed in bivalve organisms and megafauna but impacts were observed on microbial and microbenthic community structure. Nevertheless, overall use of responses in biological receptors as an indication of leaks, and by extension their individual or population reactions to leaks, is considered unreliable. 4 Dean M et al, 2020 20 Seabed and overburden integrity monitoring for offshore CO2 storage 2.1.10 Capturing temporal variations Figure 3 shows the variation and range of pH modelled for two potential storage sites in the UK North Sea. The significant range experienced at all stages of the year indicate the complexity of chemical detection in the context of natural variability. These ranges are typical of shelf seas that overlay storage complexes, with an annual variation of 0.2-0.4 pH Marine deployable sensors can reliably detect pH with a resolution of 0.01pH and so this is determined to be the threshold for detectability.5 Figure 3: Climatology of modelled pH ranges in the North Sea (a) northern region which seasonally stratifies, (b) southern region which remains mixed throughout the year 2.1.11 Identification of missing data or survey gaps Section 3 (Technical Notes) of this document provides a detailed list of the data and surveys required for an MMV plan for the relevant regulatory area. An overview of likely datasets is provided in Section 2.2.2. As discussed in Section 2.1.3, legacy data may be used so long as it passes criteria on relevance, currency, and repeatability and completeness of metadata. If the data fails to meet these criteria, then a new measurement campaign should be undertaken. 5 Blackford J et al, 2014 21 Seabed and overburden integrity monitoring for offshore CO2 storage There may be synergies with other developments in the area over the use of data or leveraging assets in the area. That is to say, if a vessel is already in the area conducting preconstruction surveying for windfarms, it would save costs to identify these opportunities early and combine missions. In limited cases, it may be possible to fill measured data gaps with model data where there are enough measured data points to calibrate a model or otherwise demonstrate high credibility. Caution should be applied to this methodology, as it will create an artificial baseline which anomalies would be measured against. 2.2 Developing the near-surface MMV plan 2.2.1 The near-surface MMV - a key element of the overall MMV programme The near-surface MMV (shallow monitoring) is an intrinsic element of the overall MMV plan which is comprehensive in space and has distinct phases of operation. The interconnection between the near-surface MMV and the overall risk-based MMV programme is described below in terms of the CO2 storage operation phases. 2.2.1.1 Pre-injection phase The containment subsurface characterization of a geologic storage site is performed to identify potential leakage risks (wells, faults). Leakage scenario studies are key in this phase and a storage site may disqualify if deeper and shallower risk features have the potential to connect. As part of this phase, baseline data should also be collected to identify near-surface risk areas (active seepages, protected species) and to enable comparison of data (to establish conformance and verify containment) with later phases in the project. Some projects may reuse existing near-surface data from hydrocarbon phases of a depleted reservoir. Synergies should be identified with other environmental permitting efforts. 2.2.1.2 Injection phase The expectation is that subsurface and borehole monitoring data (deep-focused) will provide early warning should loss of containment be expected. Should such alerts occur, a review of the containment risk-assessment (using the bowtie for example) would be initiated which in turn could trigger contingency monitoring including near-surface monitoring over the area of interest. In the unlikely case of emission to the marine environment, quantification of the emitted volume is required, and corrective measures will have to be implemented. Close and transparent collaboration with the regulator will be expected. If no loss of containment is suspected, time-lapse near-surface monitoring focusing on high-risk areas (wells, natural seeps, pockmarks) to verify site performance may still be required by the regulator and other stakeholders. 22 Seabed and overburden integrity monitoring for offshore CO2 storage 2.2.1.3 Closure phase After injection ends, containment will have been verified and conformance established, i.e., subsurface models have been calibrated with MMV data and the long-term behaviour of the CO2 plume, including potential further migration, is understood. Post closure near-surface monitoring data will be collected to demonstrate the absence of undesired impacts to the marine environment. Collectively, the MMV data covering all phases and areas of a CO2 storage project will enable transfer of long-term responsibility to the competent authority. 2.2.2 Summary of typical datasets required The near-surface site characterization of a CO2 storage complex may need datasets collected for geophysical, shallow geotechnical sampling, environmental and hydrodynamic parameters, to enable near-surface MMV plan definition. The collection methodology for the monitoring measurement campaign typically should be the same, or at least similar to the baseline campaign. Geophysical datasets are examined in detail at Section 3.1.2. These are shallow subsurface geophysics for the identification of various near surface and surface particular features related to fluid flow to be considered as shallow hazards, such as shallow gas, chimneys, fractures, and faults that may act as seal bypass providing fluid flow pathways to shallower depth and pockmarks that are the seabed expression of focused fluid seepages at seabed. Bathymetry will also provide an indication of breaches of containment or conformity as seabed deformation will provide an expression of CO2 storage behaviour. Near-surface datasets are examined in detail in Section 3.1.3. These datasets fall into the categories of chemical and biological indicators of: • Biological activity which may influence leak indicators • Carbonate chemistry Ecosystem data Hydrodynamic datasets are examined in detail at Section 3.1.4. These are principally for the identification of the current conditions so that the water movement can be accurately modelled, and the chemical dispersion of a leak understood. 2.2.3 Ways of handling long-term variability/continuity (drifting baseline) Natural variability presents a challenging aspect to the shallow monitoring of the storage complex, shifting the baseline by which anomalies can be detected. In geophysical measurements there will be an evolving state of the seabed, such as sand bar migration, erosion. Although this is a complexity, it is unlikely to mask leakage events, a difficulty chemical monitoring of the water column is highly exposed to. The carbonate system of the water column can be measured by factors of dissolved inorganic carbon (DIC), dissolved CO2 (ρCO2), total alkalinity (TA), and pH; all of which are subject to natural change driven by processes such as respiration, photosynthesis, formation, and breakdown of shell structures and CO2 exchange with the atmosphere. Increased CO2 causes acidification in seawater through the formation of carbonic acid and release of hydrogen ions. 23 Seabed and overburden integrity monitoring for offshore CO2 storage Increased atmospheric CO2 has already resulted in a mean sea surface pH reduction from 8.2 to 8.1.6 Under the median IPCC scenario of atmospheric carbon increasing to 500ppm by 2050, a decrease of pH of approximately 0.1 is forecast in the UK North Sea. Evidence from observations shows that the UK is consistent with global trends.7 The trend for pH being -0.0036±0.00034 pH units per year for the North Sea. While this variation and trend is notable, the effect of it will be dwarfed by the diurnal and seasonal variability discussed in Section 2.1.4, and management techniques will be contained within these shorter-term fluctuations. 2.2.4 Identification and definition of anomalous events Any measurement in the shallow overburden and at seabed of particular proxies that indicates an unexpected behaviour of the stored CO2 is an anomalous event. This is reliant on a thorough monitoring campaign to establish the baseline conditions and reliable modelling of expected changes during injection to determine what is truly an anomalous event. An anomaly response plan, with escalation measures is discussed at Section 2.2.8. It should be noted that all the anomalous features listed below can either occur naturally, already be present, or be due to events unrelated to CO2 injection. This further emphasizes the need for robust baselining to ensure that existing or naturally explainable features are not attributed to injection activities. 2.2.4.1 Geophysical anomalies Geophysical anomalies will be taken from the baseline conditions discussed in Section 6.1.1. Features detected that would be an indication of loss of containment would be accumulation of gas in shallow sediment, chimney, and fracture structures that act as conduits of fluid flow and pockmarks as the result of fluid flux at the sediment surface. Bathymetry data indicating seabed deformation can also give indications of deep or shallow changes that would indicate expected performance against conformance or breaches in containment. While more closely linked to the near-surface methodologies, changes in the sediment chemistry can also provide leak indications. This may prove more stable than water column measurements as it will be less exposed to hydrodynamic forcing and biological effects. 2.2.4.2 Environmental/chemical anomalies Environmental and chemical anomalies will be measured against the baseline conditions discussed at Sections 3.1.3 and 3.1.4. Chemical detections will indicate the loss of containment through the presence of tracer elements, precursor materials (brine) or changes in the carbonate system. Changes in the chemical composition may be caused by displaced materials, typically formation brine, which may or may not be anomalous. 6 7 Birchenough S, Williamson P, and Turley C, 2017 pH and ocean acidification, UKAMMS, https://moat.cefas.co.uk/ocean-processes-and-climate/ocean-acidification/ 24 Seabed and overburden integrity monitoring for offshore CO2 storage The most practical parameter to measure to detect the presence of CO2 is pH (see Section 3.2.2.1). A natural range of 0.2-0.4 pH can be expected at continental shelf storage sites, which will mask a leak to sensors with a practical detection resolution of 0.01pH. This drives a methodology of identifying outlying data points rather than absolute thresholds. Gaseous phase leaks will produce a bubble plume in the water column even if leaked CO2 will likely be rapidly dissolved into water. Acoustic surveys are most likely going to detect emissions although chemical sensors would be relevant to attribute and quantify when a leak has been detected. 2.2.5 Requirements for verification and attribution With leak features being both naturally occurring and subject to natural variability, verification of anomalies as true provides a challenging task. The anomaly response plan (Section 2.2.7) suggests a methodology for this. There is a high probability of false positive anomaly detections against individual parameters. For a confident detection, verification will require multiple detections of a single parameter and/or corroboration against other parameters (co-variance). Attribution is the requirement to identify the cause of any anomaly as linked to injection activities and in multiple user areas, the operator responsible for an anomaly. There is a strong coupling between verification and attribution requirements. Both require natural causes to be discounted. This starts with assessing the baseline data from store characterization and understanding the information from the deep-focused monitoring situation. Leakage mechanisms in storage units seals and overburdens need to be well understood. A shallow monitoring ‘detection event’ without correlation with a deeper feature is extremely unlikely. If correlation is established this would then also provide evidence for attribution for the origin of the leak as being from the storage complex (and the responsible operator). Shallow monitoring chemical sensor requirements for verification and attribution are examined at section 3.2.2.1. Phosphate and nitrate sensors are used to determine whether changes in pH or ρCO2 are due to biological activity. The need for temporal and spatial context of information drives requirements in data handing and display. This is discussed in Section 3.1.1. The use of tracer elements assigned to operators to aid attribution has been suggested. However, the inclusion of tracer elements into the sequestered CO2 is not yet confirmed as standard practice and may not be practicable. 25 Seabed and overburden integrity monitoring for offshore CO2 storage 2.2.6 Routine surveys versus targeted surveys The survey strategy will be a key part of forming the overall monitoring plan. Reviewing the regulations for monitoring across the UK8, EU9, Australia10 and Japan11, there is broad recognition that monitoring periodicity is driven by specific store characteristics to determine conformity and containment and is not explicitly defined. It should be noted that the US has the additional complexities of conforming to state and federal laws. While a periodicity is not stated by any of these jurisdictions, there are several parameters that are, by their nature, continuously monitored such as volumetric flow, temperatures, and pressures at the injection head. The wide area monitoring plan for the rest of the storage site is then to be submitted by the operator, demonstrating sufficient reasoning for their frequency of surveying. This section will examine the factors to be considered when determining this frequency. Routine surveys will be at programmed intervals to cover set areas. Seismic imaging12 will need to be at a frequency to determine containment and conformity to modelled plume migration. Conformity will demonstrate the plume is behaving as expected and avoiding high risk areas, such as outcropping and old infrastructure. If high levels of confidence can be established on the containment from deep monitoring, then shallow wide area monitoring may not be required. If it is determined that wide area shallow monitoring is required, there are several concepts of operation that have emerged for monitoring of the seabed and water column over the storage complex. These are examined in section 3.2. This has largely focussed on the use of uncrewed surface and subsurface platforms for chemical and hydroacoustic suits. Mobile chemical sensors will be extremely sensitive to high spatial and temporal fluctuations in the baseline conditions of the carbonate system. As such periodicity will not form a major consideration in mobile chemical sensors as the they will look to detect outlying measurements (jumps or step changes) within their own dataset. Targeted surveys will either be as a response to concerns driven by known high risk factors or as part of anomaly response, the latter of which is discussed in Section 2.2.8. Where there is a high-risk factor, such as the CO2 plume encountering abandoned infrastructure or influencing flux of a saline aquafer outcrop, a targeted near-surface survey may be conducted at this point. Careful consideration should be applied to whether this can be adequately captured by a single survey, or whether continuous monitoring needs to be established via a seabed lander. 8 9 10 11 12 The Storage of Carbon Dioxide (Licensing etc.) Regulations 2010, itself referencing the EU regs below DIRECTIVE 2009/31/EC, Annex II Environmental Guidelines for Carbon Dioxide Capture and Geological Storage - 2009 Act on the Prevention of Marine Pollution and Maritime Disaster These will have to be applied for under The Offshore Petroleum Activities (Conservation of Habitats) Regulations, 2001 26 Seabed and overburden integrity monitoring for offshore CO2 storage 2.2.7 Anomaly response plans A formal anomaly response or corrective measures plan should be written by a responsible operator and customized to the particular storage formation. Actions on breaches of containment are outside the scope of this document, but will be dealt with in accordance with the requirements of the licensing authority, acting in accordance with the operator’s internal emergency response plan as part of the wider report on major hazards (OGC/IOGP/ IPIECA Recommended Practice for a Common Operating Picture for Oil Spill Response is a good example on emergency response). Reporting will be in accordance with the requirements of the licensing authority. In the absence of specific CCS regulations covering leakage response, best practice should be taken from the oil and gas and MARPOL regulations of the jurisdiction. The severity of the anomaly detected will drive the urgency of the response plan. At the lowest end, it may simply be an anomaly that differs from modelled conformity with no evidence of compromised containment, in which case the understanding of the performance of the store can be updated. For anomaly detection that indicate the breach of primary containment, which is most likely as part of deep monitoring, efforts should be made to confirm other containment mechanisms. This may include further analysis or recollection of the data to establish the integrity of secondary or higher-level containment mechanisms. Anomalies in shallow monitoring present more difficulties as they indicate a complete failure of containment mechanisms and are subject to a far more dynamic marine environment. Such environment is much more likely to present false positives, especially when analysing chemical data against thresholds that may indicate a leak but could be due to biogenic or other factors. Actions taken here are to report the incident as required by the licensing authority and internal safety processes. Efforts should then be taken to establish the veracity of the anomaly, this may be by repeat surveying, analysis of the data and/ or establishing permanent monitoring at a position of interest. While detection systems are commonly referred to as Measuring, Monitoring and Verification, many have an initial functionality of detection without measurement. If quantification of a leak is required, then care should be taken to deploy the correct system and methodology to achieve this. An example of verification and escalation methodology is presented in Figure 4. 27 Seabed and overburden integrity monitoring for offshore CO2 storage DETECTION Survey-based Bubble detection with ship or AUV CO2(g,d) detectable? NO Fixed Installations with chemical or acoustic sensors CO2 (g,d) detectable? Chemical sensors on AUV or CTD CO2(g,d) detectable? YES Y Detection of leakage of CO2 likely high leakage rate (g,d) N N No leakage detectable N Presence of CO2 (g,d) and a plume height approx. >2m Benthic chambers, pH eddy coveriance, Lab on Chip gradient CO2(g,d) detectable close to sediment? Y pH optodes, microprofiler, sediment geochem CO2 (g,d) detectable in sediment? Y N Y Low or high leakage rate of CO2 (g,d) close to the sediment Higher leakage rate with plume height ca.>1m No leakage detectable CO2(g,d) detected in sediment LEAKAGE DETECTED VERIFICATION & ATTRIBUTION Process-based Stoichiometry / Simulation based on sensor data CO2(g,d) anomaly detectable? Y N Tracer-based Natural or inherent tracers Tracers detectable? CO2 attribution to reservoir not possible N Y CO2 attribution to reservoir not possible CO2 from specific reservoir CO2(g,d) anomaly LEAKAGE VERIFIED AND ATTRIBUTED QUANTIFICATION Bubble quantification from ship or AUV, passive acoustics CO2(g,d) quantification possible? N Y Quantification of CO2(g) leakage, likely high leakage flux Lab on chip gradient, benthic chamber CO2(g,d) quantification possible? Y N Computed approach based on DIC/ pH and currents Quantification of CO2(d) leakage Calculations of CO2(d) flux LEAKAGE QUANTIFIED Figure 4: Flow chart showing a potential monitoring strategy for offshore CO2 storage complexes based on the experience acquired during the STEMM-CCS release experiment (Lichtschlag et al. 2021) 28 Seabed and overburden integrity monitoring for offshore CO2 storage 3 Technical notes 3.1 Baseline methods 3.1.1 Geophysics As for the conduct of CO2 subsurface storage site qualification and baseline, it is required to assess the near-surface geological context to identify any processes witnessing natural fluid migration pathway. Existing migration pathway in the shallow overburden may be indeed preferentially re-used by CO2 in the case of CO2 migration outside the storage complex. Oil and gas exploration and production projects have shown the existence of various near surface and surface particular features related to fluid flow. These features are shallow gas, chimneys, fractures, and faults that may act as seal bypass providing fluid flow pathways to shallower depth. Pockmarks are the result of focused fluid seepages at seabed. They may be related to shallow dewatering processes due to consolidation of shallow sediments but may also be the seabed expression of fluid flow having a deeper origin. Pockmarks occur in both random (isolated) and non-random distributions; the latter, known as pockmark clusters, are generally associated with shallow overburden structures as chimneys or faults. Near-surface natural fluid flow features may have implication for migration of CO2 in the shallow overburden and to the near surface as they may act as fluid pathways. Hence, it is necessary to understand the baseline status of these natural near-surface fluid flow features to identify any preferential CO2 migration pathway in case of CO2 migration from the storage complex. Differing rates of flux from these natural fluid flows may also be early indications of deeper changes. A good understanding of these fluxes is also required to prevent their attribution to offshore CO2 storage activities, when they may be perfectly natural. Evidence of the processes of migration and rates of fluid flow through the shallow overburden and detection of these seabed features rely on high resolution geophysical methods and equipment that are described in the following guidelines and standards: • IOGP Report 373-18-1 - Guidelines for the conduct of offshore drilling hazard site surveys describes good practices for conducting geophysical and hydrographic site surveys of proposed offshore drilling locations. • IOGP Report 373-18-2 - Conduct of offshore drilling hazard Site Surveys – Technical Notes provides supporting technical information for the guidance in IOGP Report 373-18-2. • ISO 19901-8:2014, Petroleum and natural gas industries – Specific requirements for offshore structures – Part 8: Marine soil investigations Even if these guidelines and standards have been developed for oil and gas industry use, their content is fully applicable for near surface geological assessment dedicated to CO2 storage. 29 Seabed and overburden integrity monitoring for offshore CO2 storage 3.1.2 Environment Providing an absolute environmental/ecological baseline of the water column over a store is an extremely difficult task given the high levels of variability observed. This variability is discussed in Sections 2.1.4 and 2.2.4. If historical data is available, then it can be used to mitigate the difficulties caused by this variability. The use of this legacy data is covered in section 2.1.3. Table 3 covers the typical parameters that would be covered to chemically and biologically characterize the environment. This largely focuses on establishing the carbonate system of the monitored area, with sensors to determine whether anomalies may be due to leaks or biological activity. These parameters are discussed with the hydrography at Section 3.1.4. These chemical parameters have an annual wave form of variation, with smaller diurnal sub-signals. As such to characterise the system correctly the minimum data collection period would be 1 year. Additional data beyond this would prove extremely valuable in determining the natural range outside of the core signal. Chemical variation is not only temporal but could also be extremely localized constrained by the hydrodynamic conditions. As such special points of interest, such as the injection point, outcropping and the like should be individually baselined, as well as suitable control points in the vicinity of the store. This is most effectively achieved by deploying a lander at the site with a chemical detection suite. The requirement for the monitoring campaign may be so challenging, that novel approaches need to be considered. This may include the use of modelled data and monitoring methodologies reliant on rates of change in parameters rather than detection against trigger thresholds. 3.1.3 Metocean and geochemical data requirements It may be necessary to establish a baseline of metocean and geochemical data and should be based on different sets of information: • an understanding of the natural environment, the so-called baseline, which includes physical oceanographic parameters (currents, sea temperature, salinity), and geochemical parameters (DIC, pH, nutrient concentrations, total alkalinity, etc..) that provide insight into the dynamics, evolution, and interactions of CO2 (both gas and dissolved phase), • the resulting carbonate chemistry and potentially co-variables such that CO2 leakage can be reliably detected, located, and quantified, • an understanding of the biological communities, their sensitivities, dynamics and social or economic importance such that any impacts may be assessed. Figure 5 shows the actions required during each phase of a typical offshore CO2 storage project and the corresponding deliverables. Which deliverables are required, and with what level of detail, depends on the availably of existing data, the size of the project, and the risks of any CO2 leakage. More details on each deliverable will be given below. 30 Seabed and overburden integrity monitoring for offshore CO2 storage ASSESS A. Desk study of the relevant metocean and geochemical datato determine baseline SELECT DEFINE EXECUTE OPERATE B. Identify existing data and collect new water samples to determine concentration of water property and geo chemical parameters C. Current profile measurement campaign D. Apply a highresolution regional current (hydrodynamic) model E. CO2 dispersion model F. Perform model test runs and sensitivity studies of the model G. Maintain and run combined model during accidental release of CO2 H. Carry out impact assessment of CO2 leak on water properties and biological communities I. Conduct monitoring CO2 in the enviroment and maintain equipment Figure 5: Main actions during phases of offshore CO2 storage and the corresponding deliverables 3.1.3.1 Determine the baseline (desk study) The physical parameters that drive the distribution of CO2, as well as geochemical parameters, which improve reliability of CO2 detection and characterization, should be considered. Table 2 gives an example of what parameters can be considered as part of a baseline study. This could be observational data and model data, depending on what is available. 31 Seabed and overburden integrity monitoring for offshore CO2 storage Table 2: Content of a typical baseline study Obtain profiles of: Carbonate chemistry – analysis Ecosystem data • Temperature (C) • Total alkalinity vs salinity • Salinity (ppt) • DIC versus potential temperature • Calcium carbonate (CaCO3) reliant organisms • Oxygen (µmol/l) • Nitrate (µM) • Phosphate (µM) • NDIC versus NPO4 • NDIC versus NNO3 • Benthic fauna (corals, crustaceans, etc..) • Multi-cellular organisms and fish • Sediment-dwelling and benthic organisms • Silicate (µM) • Total Alkalinity (µmol/kg) • Bacteria, nanobenthos and meiobenthos • DIC (µmol/kg) • pH Cross sections (depth x distance): Leak detection indicators: Time series (multiple seasons): • Potential temperature • pCO2:O2 ratio (per season) • Current speed and direction • Temperature • Sea temperature • Salinity • Salinity • pH • pCO2 Depending on the location of the offshore CO2 storage project, some data may already be available in the public domain. There are numerous data sources that can be consulted: • British Oceanographic data centre, https://www.bodc.ac.uk/ • The surface ocean CO2 atlas, https://www.socat.info/ • Active Archive centre for Biochemical Dynamics, https://daac.ornl.gov/about/ • Pangaea, https://pangaea.de/ • European Marine Observation and data network (EMODNET) https://emodnet.ec.europa.eu/en • International Council for the Exploration of the Sea (ICES) https://www.ices.dk/Pages/default.aspx 3.1.3.2 Data collection: water property and geochemical parameters Additional data have to be collected when the desk study (deliverable A and B of Figure 4) does not result in sufficient data to determine a proper baseline, which reflects all site specific and seasonal characteristics. Costs of the data collection are largely driven by the cost of a vessel’s to service the measurement equipment. As the data needs to cover seasonal changes, multiple surveys during a year are required. Second, as concentrations of most geochemical parameters typically show a noticeable gradient in the water column, multiple samples per location are required. There are two types of sampling methods: • Discrete sampling of the water column (traditional CTD/rosette, glider) • Automated measurements of near sea-floor hydrochemistry and carbonate chemistry 32 Seabed and overburden integrity monitoring for offshore CO2 storage parameters with sensors deployed onto ROV or landers or fit for purpose AUV 3.1.3.3 Current profile measurement campaign The need for any current profile data is largely controlled by the quality of the existing measured full water column current profile data (e.g., via ADCP) and model data. Different from wind, waves, and basic water property data (temperature and salinity), which are often very well known, currents can be very complex and show a lot of spatial and temporal variability, which makes modelling them very challenging. In some areas, such as large parts of the North Sea, the level of knowledge on current profiles (both models and observational data) may be sufficient and no further data collection is needed. In many other areas, we need to collect these data. To capture the seasonal variability, it is recommended to collect at least one full year of data. Cost and schedule efficiencies can be achieved when the campaign to collect current data includes water properties data collection (deliverable C of Figure 5). 3.1.3.4 Apply a high-resolution regional hydrodynamic model Currents can be driven by tides, atmospheric forcing (wind), density gradient, riverine outflows, seabed/shoreline configuration and bathymetry and impacted by the Coriolis effects. In shallow water areas (water depth less than 20-25 m), currents can often be described by a certain near-constant profile shape (for tides or for winds) and a 2D model may be sufficient. However, in most cases, a 3D approach with a vertical layered grid is required to be able to model the main processes. For instance, the central North Sea is highly stratified during the summer and well mixed during the winter period, which has a major impact on the currents and vertical profiles of temperature and salinity. Only a 3D model can resolve this. A horizontal resolution of 5-10 km is typical for most current models. However, depending on the location, a finer horizontal resolution (1-3 km and even higher) may be required, particularly in areas with significant horizontal density gradients induced by, for example, an outflow of fresh water and topography changes. Increased resolution is generally achieved when a higher-resolution model is nested within a coarser model. The measured current profile data (deliverable C) should be used to validate and/ or calibrate the hydrodynamic model (deliverable D of Figure 5). There are several freely available ocean current datasets: • Copernicus Marine Environment Monitoring Service (CMEMS), https://marine. copernicus.eu/ • Plymouth Marine laboratory: data portals, https://portal.ecosystem-modelling.pml. ac.uk/ • HYCOM (consortium for data assimilative monitoring), https://www.hycom.org/ 3.1.3.5 CO2 dispersion model (biogeochemical model) The hydrodynamic model needs to be coupled with a biogeochemical model, which includes descriptions of carbonate chemistry and the bio-physical processes that influence the carbonate system. With minimal development and suitable evaluation against real-world data, these models can produce high frequency representative time series of observable parameters such as pH and pCO2, and co-variables such as O2 and nutrients, potentially at intervals of a few minutes over seasonal and decadal time scales. Model outputs of 33 Seabed and overburden integrity monitoring for offshore CO2 storage the above-mentioned parameters are typically saved at daily time intervals (for example daily mean values) per grid point (deliverable E of Figure 5). However, model time steps are usually of the order of a few minutes to sub-hourly, so high frequency data can be generated, which may be a requirement during a leakage. It should be noted that model outputs of these parameters in some cases show less small-scale variability than the real data, due to the necessary aggregation of processes, water volumes and species into functional groups. In other cases, the models are not too far short of picking up the smallscale variability. 3.1.3.6 Perform model test runs and sensitivity studies of the model Only a few marine CO2 release experiments have been undertaken. They are restricted to specific locations, limited time frames and small volumes of CO2. However, they do enable the evaluation of multiple model test runs (deliverable F of Figure 4), which provide an ability to detail spatial-temporal CO2 baselines and simulate diverse scenarios of leakage, and the variability in hydrodynamic conditions during a year (e.g., degree of stratification of the water column). The coupled models should be validated and calibrated with observational data, as much as possible. Properly evaluated model systems can provide characterization of natural chemical variability, contributing to baseline assessments and the identification of anomaly criteria in terms of changes of pH as a function of time, distance from the release point, the magnitude and duration of the CO2 release. 3.1.3.7 Maintain and run the combined (hydrodynamic and biogeochemical) model during accidental release of CO2 This deliverable (G of Figure 5) is the result of the model developed in Figure 5 under deliverables D and E and tested under deliverable F. Such simulations would help characterize the extent of impact of the CO2 release especially in parts of the area of interest not well covered by sensors. 3.1.3.8 Impact assessment of CO2 leak on water properties and biological communities Coupled marine systems models are expected to be consistent with observations for physical and chemical constituents (e.g., temperature or nitrate concentration), but they are less suitable for evaluation of biological components because such models lack detail in terms of biodiversity and the parameterization of biological impacts arising from excess CO2. In addition, small errors in physical or chemical predictions are often amplified by dependent biological process descriptions. In other words: models will not provide direct assessments of ecosystem damage but can provide indicators of impact extent and are a good tool to study various scenarios and sensitivities (deliverable H of Figure 5). An assessment of the potential ecosystem damage could comprise the following elements: • Impact on calcium carbonate (CaCO3) reliant organisms • Effects on benthic fauna (corals, crustaceans, mollusks, and echinoderms) • Effects on multi-cellular organisms and fish • Effects on sediment-dwelling and benthic (bottom dwelling) organisms • Effects on bacteria, nanobenthos, and meiobenthos 34 Seabed and overburden integrity monitoring for offshore CO2 storage 3.2 Monitoring methods Near-surface monitoring methodologies use permanent installations providing continuous monitoring in high-risk areas, such as injection sites, outcroppings, and old or abandoned infrastructure. The wide area of the store, which has a much lower risk profile, then has periodic monitoring from mobile assets. The technologies to achieve this are examined first then the concepts of operation are explored in more detail (deliverable I of Figure 5). 3.2.1 Acquisition platforms A platform should be suitably matched to its sensor payload. While there is often a great deal of interest in sensor platforms, such as AUV, they are simply a delivery mechanism for their sensors and their primary design and operational driver are the requirements of their payload. Other platform key selection criteria include: • Acquisition cost • Spatial/endurance capabilities • Safety of launch and recovery of the system This section examines the main criteria that various platforms offer to enable data collection. 3.2.1.1 Static installations The instrumentation on injection apparatus and downhole monitoring equipment will naturally form part of the continuous monitoring of the injection site. This may be supplemented using additional stationary platforms to provide permanent close observation of high-risk areas. These platforms are most likely to be in the form of landers deployed to the seabed (e.g., chemical sensors, pressure monitoring transponders, gravimeters, tiltmeters/inclinometers…). Static landers provide many advantages: • Constant presence • High in-service time – may require annual or bi-annual servicing • Can take a high battery payload to power energy intensive systems such as active sonars • If they are close to other infrastructure may be able to connect into subsea power and ability to provide live feeds via acoustic or hardwire communication networks • Power and size capacity to support large sensor arrays and onboard processing • Large size can support chemical sensors requiring the storage of reagent bags • Sensors can be accurately placed at an optimum height above the seabed • As they are static, they can integrate data over long periods to get more sensitive or accurate results Positioning is critical with static landers. As a platform for chemical sensors, they should be positioned relative to the high-risk location, so that if there is a leak, the prevailing tidal and current conditions may carry the CO2 plume towards the lander. They should then be close enough to ensure that there is a suitable concentration of detectable substance so that a problematic leak can be identified in a timely manner. 35 Seabed and overburden integrity monitoring for offshore CO2 storage A method of communicating with the lander should be established. If there is suitable nearby infrastructure, a wired solution may be possible. This gives robust and high data rate communications. If there is no suitable connection point in the vicinity, a wireless solution via a gateway buoy or USV would be required. For areas with a high amount of trawler fishing, trawl resistance should be considered. No design can be completely trawl resistant, but designs can be made more resilient to glancing blows. Static landers will also carry a high maintenance overhead. They will need periodic maintenance approximately every one to two years for sensor calibrations, cleaning, battery changes, restocking chemical agents, and changing reagent bags. Given the size of these landers will likely be greater than 500 kg, recovery will be a significant task. 3.2.1.2 Mobile platforms The diversity of mobile platforms has increased over the last decade, largely driven by the growing capability and adoption of autonomy. This section will examine the various advantages and disadvantages for the vehicles that may be considered. Payload, cost, operational range (which may tie in with sensor power requirements), and safety (during launch and recovery) are key factors to be considered. 3.2.1.2.1 Autonomous Underwater Vehicles (AUVs) Autonomous Underwater Vehicles are uncrewed submarines that are usually deployed from a larger vessel. Newer, long-range variants trade depth capability for extra battery capacity and can be deployed from shore. As they have conventional steering and propulsion, they can execute a survey plan accurately, while active depth control allows them to cruise at a height above the seabed for optimum sensor performance. The size of AUVs varies from hand portable systems to that of 10-15m long. AUVs have been used in the oil and gas industries for more than two decades, mainly for geophysical survey (with MBES, SSS,SBP profiler and more recently camera/video) or inspection survey (laser, stills camera, MBES, SSS). Such applications are fully relevant for near-surface offshore CO2 storage baseline and monitoring. In addition, under development, chemical sensors (pCO2, pH) may be deployed. 3.2.1.2.2 Autonomous Surface Vehicles (ASVs) Autonomous Surface Vehicles (also called Uncrewed (or Unmanned) Surface Vessels – USVs) are uncrewed vessels that operate on the sea surface, generally 3-10 metres long to enable easy transport. They are rarely truly autonomous and rely on a data link to shore for conduct. Their main advantages over conventional vessels are the reduction in emissions, cost, and HSE exposure. As CCUS storage sites will be relatively near shore, deployment from harbour is a practical option. The discussion around their use is similar to the AUVs with the clear differentiation that all their operations will be on the surface. Many have solar panels to supplement batteries and some of the larger ones will also have small generators. They will be suitable for mounting active sonars, but vessel self-noise and surface noise would make operation of passive sonars impractical. 36 Seabed and overburden integrity monitoring for offshore CO2 storage They have a greater energy capacity and navigational accuracy compared with AUVs, resulting in a more comprehensive sensor suite and range. On the other hand, ASVs are influenced by surface weather, wave heights and currents etc, and are thus a less stable platform than AUV’s. As the sensor suite will be at the surface, it will not have the ability to be deployed at an optimum height above the seabed for detection. Some AUVs offer the ability to deploy towed arrays, which is a useful feature, but these arrays will not be able to have the sensor payload of a AUV or towed array from a conventional vessel. Some ASVs may serve as support vessel for AUVs and ROVs. 3.2.1.2.3 Subsurface gliders Subsurface gliders (not to be confused with wave gliders) are small buoyancy-driven autonomous underwater vehicles and a widely-used modern oceanographic tool. They are, typically, about 200cm in length and weigh around fifty kilograms. Gliders cycle up and down through the water column in a saw tooth pattern. Once at surface, buoyancy tanks are filled causing them to descend through the water as wings propel them forward. At the bottom of this decent, the tanks are emptied, and the glider starts to climb with the wings again providing thrust as the glider moves upwards through the water. This is a very efficient method and very long endurances are achievable. Deployments of about a year are now possible, with deployments of 3–6months now routine, and survey tracks extending over 1,000s kilometers. If no other system is used (absence of boat or autonomous surface vehicle), the underwater positioning will rely only on the glider dead reckoning algorithm with lack of positional accuracy and optimum positioning above the seabed for sensors. The propulsion is largely unable to make headway against strong depth average currents. Glider manufacturers and users have implemented a wide range of sensors on the platform and various physical (e.g., pressure, salinity, currents) biogeochemical (e.g., pCO2, O2, pH) and acoustic parameters (e.g., hydrophones, echo sounder) can be recorded, many of them accessible in near real time. They would fit in a concept of operations where they are deployed for extended periods to collect baseline data and monitor temporal changes in parameters over long durations, or due to their low cost deploying many platforms to get suitable coverage, including leak monitoring. 3.2.1.2.4 Remotely Operated Vehicles (ROVs) Remotely Operated Vehicles are platforms deployed from a crewed or more recently, uncrewed vessel, able to move in high degrees of accuracy in three dimensions. They are controlled by an operator onboard the support vessel (crewed) or remote-control centre (uncrewed). They vary in size from hand portable nearshore and shallow water ROVs to very large offshore deep-water intervention (work class) ROVs, with dedicated launch and recovery system and and high payload capability. For CCUS applications, typically they will be towards the larger end of this range, capable of carrying all required equipment. An ROV has a continuous power supply from the vessel and can carry power intensive payloads. Due to the tether to a large vessel and slow transit speeds, typically these would not be for monitoring a large area, but for more detailed inspection and intervention. 37 Seabed and overburden integrity monitoring for offshore CO2 storage As ROVs can be positioned with a high degree of accuracy, they are excellent platforms for collecting visual data and very precise chemical sampling. The use of ROVs is most likely to be part of a follow-up investigation in which precise location, measurement, and investigation over a tightly defined area is required, such as anomaly detection. 3.2.1.2.5 Conventional vessels Crewed service vessels are still the main delivery mechanism for offshore services globally. Their practices are well established, and generally they are widely available. To carry a suitable sensor payload, to the areas we would expect CCUS to be undertaken, for several days at sea, vessels will likely by longer than 30 meters. They combine the advantages of many of the other platforms and provide some additional advantages: • High positioning accuracy • Large size and power capacity for complex sensor suits • Ability to deploy towed arrays to place sensors at optimum depths • Onboard ROVS for searching large areas Onboard staff for rapid data interpretation, sample management, time-critical testing, and programme decision making Activities for CCUS monitoring are not high risk and the actual exposure is not likely to be significantly more than the cranage and deployment of unmanned vessels from shore. Conventional vessels primary limitation is cost, and increasingly, carbon footprint. They are expensive, with relatively high day rates compared with uncrewed vehicles, higher mobilisation rates and more shoreside support overheads. There can also be savings found in mobilising them for multiple tasks at once, as they can carry several mission payloads simultaneously – if a suitable vessel asset is in area, then large common costs (such as mobilisation, transit, weather time) can be spread between projects. 3.2.1.2.6 Ships of Opportunity (SOO) Ships of opportunity are vessels that are not primarily tasked with monitoring operations. For example, field support vessels’ (FSVs) or Platform Supply Vessels (PSVs) for O&G field operations. There are systems that can be fitted to monitor oceanographic parameters, including seawater composition, along the route. This would not provide sufficient data or methodology for core monitoring activities, so they are not included in that discussion, but may for part of a consideration for monitoring baseline drift. 3.2.1.2.7 Acquisition platform comparison While the above sections have given some indication of the likely employment of different platforms, mobile platforms are subject to different sensor requirements, evolving technology, site specific factors and changeable cost models. Table 3 provides a comparison of these factors. Scores assigned are relative to each other and do not account for project specific requirements or weighted operator preferences. 38 Seabed and overburden integrity monitoring for offshore CO2 storage Range Mission Payload Onboard processing Navigation - Accuracy Navigation - Positioning Sensor position (depth) Cost Re-tasking* Criteria AUVs 3 3 3 3 3 5 4 4 ASVs – active power 4 4 3 5 4 3 4 4 ASVs – passive power 5 3 2 5 2 2 4 2 Criteria Platform Subsurface gliders 5 2 1 3 1 2 5 0 ROVs 1 4 1 5 5 5 2 5 Conventional Vessels 4 5 5 5 5 4 2 5 Table 3: Acquisition platform selection matrix. 0 – No capability, 1 – Low, 2 – Below average, 3 – Satisfactory, 4 – Good, 5 - Excellent Both AUVs and ASVs can revisit areas of interest if an anomaly is detected to collect more data, conventional vessels can carry a large mission payload, such as an ROV to conduct more in depth investigations. 3.2.2 Acquisition sensors (geophysics, hydroacoustic, geochemistry, biological) The sensor suite deployed to provide monitoring is part of a complex trade-off between the legislative requirements, what is technically possible from both the performance of the sensors and platform, and cost. These interactions will be highly project specific. This section gives an overview of the capabilities that different sensors provide, some of the key factors to consider for use, and matching with platforms. 3.2.2.1 Chemical sensors Chemical sensors can be mounted to static and mobile platforms. When mounting to mobile platforms, the first aspect to consider is the sampling and processing time of the sensor. This needs to be suitably fast so that the sensor can sample at a suitable frequency relative to the vehicles speed through the water. Chemical sensors then need to be matched to the available power and space on a mobile platform. Considerations for space may also include the requirement to store reagent bags which cannot be released to the environment. These concerns are much simpler on static and mobile crewed platforms, with far less complexity over movement and, in comparison to autonomous vehicles, more space and power. Part of the discussion around chemical sensors for a project should also examine the use of sediment sampling. This is unlikely to be for in-situ analysis or uncrewed vessel systems 39 Seabed and overburden integrity monitoring for offshore CO2 storage but sampling for laboratory assessment. This methodology may go some way to mitigating the complexities caused by the environmental and hydrodynamic effects. Research and development projects did show a marked increase in concentration at the sediment-water interface (as opposed to higher in the water column), which would improve detectability. Carbonate system The carbonate system, to indicate the presence of CO2, of the water column can be measured on factors of Dissolved Inorganic Carbon (DIC), dissolved CO2 (ρCO2), Total Alkalinity (TA) and pH. Measuring DIC and ρCO2 is currently considered impractical due to the very low chemical signal that both these parameters will give in a hydrodynamic environment and hence very short detection ranges. For this reason, pH is often the most practical to measure. It offers the best likelihood of detection and there are readily available seawater pH sensors. Commercially available sensors have an accuracy of 0.01pH, which is sufficient for detection. For leak rates of less than 1 tonne per day, then the dominant effect is limited to less than 3m from the seabed and may not be suitable for AUV deployment due to flight height restrictions. Figure 6: Estimated detection length scales for the range of leakage scenarios (Blackford et al, 2020) Due to the damaging nature of release experiments at representative rates, detection range research has been largely limited to modelled examples. Figure 6 indicates that a leak of 1Kg/d would require a sensor within a one meter radius, a one tonne per day (T/d) leak could be detectable at around 60 m distant, and a one metric tonne per day (M T/d) leak at 7.8 km distance. As no more than 1% of stored CO2 can be released to maintain an acceptable degree of storage integrity (IPCC, 2005) and using the Sleipner injection rate as an example, then a release of 30 T/d would be detectable at approximately 660 m distance.13 Caution should be applied to these modelled results. Due to the impracticality of conducting such large-scale releases of CO2, there is no experimental evidence to support the top end of this scale. 13 Blackford J et al, 2020 40 Seabed and overburden integrity monitoring for offshore CO2 storage Release experiments that have simulated approximately 100 kg per day have shown far more modest performance than modelling suggests, with detections only made very close to the source. pH sensors are not energy intensive and lend themselves well to deployment on batteries. They do suffer from drift, so for protracted deployments, such as on a lander a method of correcting or calibrating this drift should be considered. To correct pH (and DO) both temperature and salinity should both be measured, as they are dependent variables. Verification and attribution Chemical sensors for verifying and attributing the source of any anomalies fall into two broad categories: • Ensuring that perturbations in chemical profiles are not due to biological activity • Detecting tracer elements that will indicate the operator of the leaking store, which can aid initial detection To determine the impact of biological activity, refer to the sensors proposed in Table 3: Content of a typical baseline study, where dissolved oxygen (DO), nitrates, and phosphates are measured. While only one of these parameters needs to be measured to determine whether a pH anomaly is biogenic, it may be desirable to include all three on a platform such as lander. This gives increased data and redundancy where there is platform capacity, for little increase in cost. Sensors for these parameters are commercially available, but not as widely as pH sensors. Many research institutions have their own sensors developed in-house for these parameters, which may not be at a commercial Technology Readiness Level, but may be worth exploring as high accuracy alternatives. The inclusion of tracer elements into the sequestered CO2 is not yet confirmed as standard practice. Suitable tracer elements that have been identified are helium and xenon isotopes (particularly 124,129Xe), and artificial tracers such as perfluorochemicals (PFCs) and deuterated methane14. Studies into this methodology have reservations about the performance of tracer elements as they migrate through the shallow overburden and potency over time. Given the uncertainties of this approach, development of suitable sensors has been limited. 3.2.2.2 Acoustic sensors Acoustic sensors fall into two main categories. Active acoustic, which transmits soundwaves and builds a picture from the reflected energy and passive acoustic, which does not transmit but ‘listens’ to determine what is happening in its vicinity. In offshore CO2 storage applications, acoustic sensors can be used to provide near photorealistic imagery of the seabed, which can be used to visually identify gaseous leaks. This imaging can also be used to identify leak features in the sediment, such as pockmarks. They can also take highly accurate bathymetric readings to monitor changes and anomalies in the seabed indicative of leaks or containment issues lower in the shallow overburden. Passive acoustic sensors are overall less capable but come with advantages that will be discussed later in this section. Their primary application is to ‘listen’ out for the frequencies that would indicate a leak or other anomalous event. 14 Roberts et al, 2017 41 Seabed and overburden integrity monitoring for offshore CO2 storage Active leak detection sonars can be mounted on static landers around high-risk areas of leakage. These function by inducing vibration in the individual bubbles of gaseous phase bubble plumes, increasing the return signal over that which may not have been detectable via passive methods. These sonars can also be used in noisy environments, such as near the injection site where there will be lots of plant noise, where passive sonars would be unable to discern events. Active sonars in the forms of Side Scan Sonar (SSS) and Multi-Beam Echo Sounder (MBES) provide high resolution imagery of the seabed and objects in the water column, such as bubble plumes. This can be coupled with an automatic target recognition algorithm, which can highlight bubble plumes from seabed seeps to improve detection capability. It should be noted that both systems need a stable platform, such as a submerged AUV, ROV, or actively stabilized surface vessel. Imagery from them can be smoothed via processing although this may lead to the omission of important data. MBES are slightly more robust to this movement. All these forms of active sonars are in widespread operational use and would require minimal platform integration. Passive sonars are at a lower technology readiness level with less demonstrable operation. They however provide a lower power monitoring solution than active sonars for high-risk locations of a CO2 storage that could be located some way from the injection point, such as legacy wells. They have a higher sensitivity than active sonars, as they can integrate data over a time period, but this also heightens their susceptibility to noise. 3.2.2.3 Deployment of sensors In the preceding sections the capabilities of the platforms and the sensors have been examined. This needs to be applied to the MMV principles discussed at the start of Section 1, and considered with both engineering and operational judgement. The MMV principles from Section 1.1.1 provide containment, conformance, and confidence for shallow-focused monitoring, capable of detecting and quantifying near-surface emissions likely to pose a health and safety threat or environmental impact. Shallowfocused monitoring relies upon near surface monitoring technologies generally developed and implemented by marine geoscientists, oceanographers, and environmental scientists. Conformance with modelled behaviour is the domain of deep monitoring to ensure that the injected gas is migrating through the storage complex as expected. Deep monitoring can also assure containment and provide confidence of the deep containment mechanisms, with shallow monitoring providing measurable indications that deep monitoring is indeed correct and the environment is not suffering any damage. Acoustic detection of gaseous phase bubbles is the most obvious indication of leakages. The supercritical CO2 of the store will go through complex phase changes to reach the seabed. While this is happening, it will be translating laterally, diffusing and eventually dissolving with saturated sediment. Suitable site characterization should identify any pathways, but that is not to say one may not have been found or some fault may develop in either the natural containment or sealing of old wells. Pockmark detection should in some way mitigate this uncertainty as it can detect fluxes in both different phases, which may include precursor brine. 42 Seabed and overburden integrity monitoring for offshore CO2 storage Chemical detection also has a high degree of uncertainty. The natural variability and reactions to the introduction of CO2 mask emissions. While modelled results provide encouraging theoretical detection ranges, experimental findings are more modest. Chemical detection relies on a leak establishing itself for a period to get the necessary detectable concentrations, which does not lend itself to rapid responses. Shallow monitoring techniques, especially over a wide area, are not in themselves a full solution for containment or confidence. It is not the intent to suggest that shallow monitoring may be unfit for purpose; however, incorrectly delivered shallow monitoring could provide no meaningful results, including false positives or negatives, and as such affect the environment, reputation, cost, and timelines. An integrated deep and shallow monitoring strategy across development phases, where context and layered data is analysed to provide a true picture, provides the best opportunity for success. Shallow monitoring techniques should be considered to have quantification capability, as in the event of a leak, this techniques could support leak volume assessments. 3.2.3 Example missions and surveys 3.2.3.1 Capability matrix The matrices describe the capabilities examined in this document. There will be other monitoring methods (such as downhole monitoring) but the purpose of this section is to examine interaction between deep and shallow monitoring and the potential for overlapping capabilities. The project phases are: Phase 1 – Assessment, Phase 2 – Characterization, Phase 3 – Development, Phase 4 – Operation, Phase 5 - Post-Closure/Pre-Transfer, Phase 6 - Post Transfer. The activities for Phases 5 and 6 are similar to previous phases in terms of methodology. The periodicity may change to reflect the decreased risk and the objective would be more focussed on confidence with the intention to transfer liabilities. Table 7: Phase 2, 3, and 4 (characterization, development and operation) monitoring techniques Objective Objective description Deep/ shallow Output Sensor requirements Platform Discussion Phase 2 and 3 - Characterization and Development Containment Integrity of complex containment mechanisms Deep Seismic data, identification of routes to surface from storage complex Seismic towed array Large Vessel Confidence Identification of natural fluxes to avoid confusion with induced fluxes Shallow Geomorphology, bathymetry, water column imaging (gas plumes), near surface geology SSS/MBES/ SBP/UHRS Surface vessel AUV,ASV, ROV 43 Wide area coverage of primary flux identification indicators Baseline bathymetry to detect anomalous movement Seabed and overburden integrity monitoring for offshore CO2 storage Objective Objective description Deep/ shallow Output Sensor requirements Platform Discussion Confidence Identification of chemical baseline to monitor and measure anomalies against Shallow Annual profile of key measurement parameters, several years of data would also give range Carbonate system Lander Monitoring of the key points of the storage complex in order to identify anomalies and baseline conditions in order to detect and quantify leaks. Understand the hydrodynamic environment and how the dispersal of leaked hydrogen may evolve Shallow Tidal and current conditions at site ADCP Lander Seismic array Large Vessel Conformance Attribution parameters Phase 4, Operation Containment Conformance Identify breaches of primary (or later) containment mechanisms Deep Identify extent of CO2 migration through the storage complex to confirm modelled behaviours Deep Seismic data OBNs Seismic data 44 Seismic array Large Vessel OBNs A study would need to be made as to the preference of towed arrays over OBNs, noting the potential interference of other users, such as windfarms. Same data as previous item with different objective Seabed and overburden integrity monitoring for offshore CO2 storage Objective Objective description Deep/ shallow Output Sensor requirements Platform Discussion Confidence Identify extent of CO2 migration through the storage complex to confirm stored volume Deep Seismic data Seismic array Large Vessel OBNs Same data as previous item with different objective Containment Provide monitoring at high-risk locations Shallow Alarm if there is a detection of trigger factors Leak detection sonar Chemical monitoring of conditions Lander Constant presence at high-risk locations Shallow Alarm if there is a detection of trigger factors SSS/MBES Chemical suite Surface vessel This methodology may also include sediment sampling Improve understanding of environmental trends Containment Monitor areal store AUV ASV Containment Monitor areal store Shallow Bathymetric data to confirm overburden performance and integrity MBES Seafloor deformation monitoring instruments (pressure sensors) Surface vessel AUV SUV This methodology is used at Sleipner and Machar Lander 3.2.3.2 Concepts of operation All monitoring concepts for offshore storage complexes provide a risk-based approach. While it is technically feasible to have static landers providing constant shallow monitoring over the entire storage complex, this would not be cost effective, nor is it required. From the approaches examined in Section 3.2.3.1, there are overlapping capabilities which can be traded-off against each other, combined with the likelihood of areal leakage from the primary containment being extremely small. While this does intuitively push for a minimalist approach to monitoring, the strategy should be suitable for the risk profile of the store and provide meaningful evidence of absence of any leaks. These design factors will be examined more fully, with other requirement drivers such as regulatory requirements, in Section 3.4. 45 Seabed and overburden integrity monitoring for offshore CO2 storage Using these broad principles, an outline concept of operation would be: Phase 1 – Assessment: This is a desk study phase where the monitoring philosophy should be established, and major characteristics identified from extant information. These characteristics can then have an outline monitoring strategy defined, or they may preclude the suitability of the site for CO2 storage. Phase 2 – Characterization: The characterization phase is to develop the outline of the storage feasibility put forward in the assessment without committing to the full-scale development phase costs. This would likely focus on deep monitoring with the aim of identifying of yet unfound leakage routes. Given the range of natural variability in chemical parameters and the relative cost of a measurement campaign, it would be prudent at this time to deploy landers to understand the marine and hydrodynamic environment. Phase 3 – Development: Once the development phase is underway, there is greater certainty over future investment. At this stage if it has not already been started, the chemical environmental baseline campaign should be started. The areal extent of the store should then be baselined for shallow leak identifiers, such as pockmarks, and to establish the baseline bathymetry. Phase 4 – Operation: During the operational phase, the site operator should comply fully with the regulatory requirements, which will likely be the primary requirement driver. The risk-based approach to this will be constant surveillance at the high-risk areas using landers, with periodic wide area surveys using the methods discussed in section 3.2. Landers will then relay their data in real time to an operations centre. In most cases these wide area surveys would be cheapest utilising suitably instrumented AUVs. Data from surveys can then be transmitted live for preliminary analysis (on board, in the case of large vessels), or stored onboard for later analysis. This latter approach caries risk of slowing a reaction to anomalies detected and prevents re-tasking (see Section 3.2.4). The periodicity of the wide area surveys will be driven by the risk profile of the store and regulatory requirements for complex wide water column monitoring. When examining overlapping capabilities, we can see there are multiple ways of demonstrating containment. It will be a trade-off on cost effective and compliant methodologies adopted by the operator. Phase 5 - Post-closure/pre-transfer: Following the end of injection operations, the monitoring regime will be defined by the jurisdiction’s regulatory requirements. It logically follows that the monitoring regime will be the same as that employed during the Operational phase but at a reduced periodicity to recognise the reduced risk as there is no active injection. Phase 6 – Post-transfer: With the liabilities transferred to the national body, shallow monitoring will be driven by the risk profile of the store and may not be required. Deep monitoring would need to continue if the CO2 plume has not yet stabilised and continues to migrate in a way that may be problematic. Shallow monitoring may be combined into an academic exercise in the local ecology. 46 Seabed and overburden integrity monitoring for offshore CO2 storage 3.2.3.3 Example missions For the key technologies (landers and AUVs) discussed for Phase 4 operational monitoring, it is possible to give example missions. The shallow monitoring discussion is not weighted towards any specific technologies and/or parameters, because many variables play a part in defining the correct solution for a particular site. However, the combination of landers and AUVs is widely considered as a recommended solution. Landers will be deployed in the vicinity of high-risk features, such as the injection site, old and abandoned infrastructure, and natural leakage pathways. The sensor outfit for a lander will likely consist of a leak detection sonar and chemical suit. They should be situated so that the hydrodynamic conditions move chemical leakage effects towards them. There should be continuity throughout Phases 3-5 over the lander siting and measured parameters. From deployment, there will be a regular maintenance regime to ensure the lander’s continued effectiveness. This will consist of cleaning to remove marine growth and debris, replacing batteries, calibrating and maintaining instruments, and replacing reagent bags. Using a standard maintenance cycle for marine deployed instruments would put this activity as every one to two years. It may seem an attractive solution to try and increase the endurance of a lander by supplying surface power, which may be possible with fixed cabling in the vicinity of infrastructure but has a poor reliability record when flexible cabling is used from a buoy. Landers will need a form of gateway to return their data. As with power in the vicinity of fixed infrastructure, a cabled link may be possible, which would enable very high data rates. If this is not possible, there will need to be a surface gateway, either in the form of an ASV or buoy. The wireless communications between the lander and buoy will have less bandwidth than a wired link and may lead to the requirement for onboard processing for data compression. In addition to the permanent but localized monitoring provided by the landers, AUVs will provide a periodic and spatial assessment of the CO2 storage area and aa prudent estimate would put this periodicity at every three to five years. AUVs would be equipped with a SSS and/or MBES and/or SBP and a light chemical suit capable of rapid processing sampled water as the AUV moves. The flight height of the AUV would need to be tailored to allow greatest coverage of the SSS/MBES but may also be adapted to sample gas bubble close to the seafloor. The AUV would run reciprocating adjacent survey lines over the storage complex, this is most efficiently done moving with and against prevailing tidal and current conditions. 3.2.4 Data management, processing Large amounts of data will be produced by the monitoring operation from disparate sources and will require careful integration. Handling of the data will be crucial to leading effective decision making. For this to be the case there will always be a human involved, but their efficiency and error rate can be improved with the aid of automation and userfriendly displays. Data displays have been discussed at length in the section on GIS in this document. (Section 3.1.1) Where automation can greatly assist is in highlighting areas of concern to a human operator. This at first happens in bandwidth restricted areas. Examples of this would be on a wide area survey. When surfacing, an AUV has a limited amount of time to transmit its data. By identifying data of interest through an Automatic Target Recognition (ATR) algorithm from onboard processing, in both chemical and sonar, it allows shorter and 47 Seabed and overburden integrity monitoring for offshore CO2 storage hence cheaper data transmission. For the shoreside operator it then allows a more efficient data sift where ATR false positives can be quickly discarded. If a conventional surface vessel is used and data is being manually examined as it is collected an effective ATR also reduces operator fatigue, and hence, likelihood of error. For static landers the constant data stream will need an alarm feature as constant monitoring of sufficient vigilance is simply not possible. As discussed in Section 2.2.7, absolute thresholds to detect anomalies in the carbonate system are not sufficient due to the variability and range pH, which is the most likely parameter monitored. Using the performance of chemical sensors and modelled detections examined in Section 3.2.2.1, a change in the data of 0.01pH would be a flag for further investigation. Data may need to be re-examined for several reasons including missed detections. For liability and good practice, the full set of data should be retained in line with regulatory and company policy. This data archive may also prove useful in developing machine learning to identify leaks more effectively. 3.3 Value of information Shallow monitoring data will be of low value without context. This puts a significant burden on the need to have good store characterization. A shallow monitoring anomaly detection will be of low value, in the sense it will be a high probability of false-positive or unattributable to a leak mechanism, unless is correlates with a suitable geological feature. This weights early data collection in favour of deep monitoring techniques. Shallow monitoring is of far greater importance during operation as the ability to meaningfully quantify any emissions and qualify their environmental impact will be a key capability that regulatory bodies will require. This extends the requirement for robust near-surface baselining in development phases. It is extremely difficult to attribute a weighting to any shallow monitoring technique, that chemical detections may be better than acoustic or vice-versa. Data will have far more cumulative value when considered together and as such handling and display systems should consider this layering feature as a high priority requirement. 3.4 Workflow decision diagram (to help operators make appropriate choices) This section examines the major processes in the workflow of through-life monitoring of a CO2 storage site. These are aligned with the major operational steps and common regulatory requirements in a site development, but regional and operator variations will apply. Phase 3, development, presents complexities as until this point there is limited certainty over the project and major investment will not be released prior to this. Expensive activities, like seismic acquisition, will need to be initiated and the results implemented within this phase. As such the workflow diagram here shows the major process of this phase as a two stage activity. Savings in time and cost may be made where there will legacy data available for depleted oil and gas fields, which may slightly influence the order and content of this process. 48 Seabed and overburden integrity monitoring for offshore CO2 storage Phase 1: Assessment Site characteristics/Risk identification from extant information Regulatory monitoring requirements Licensing requirements Identify general monitorability of storage site and complex. Identify project feasibility. Concept - License Feasibility of store Outline monitoring plan Phase 2: Characterization FEED CO2 migration modelling Corporate safety guidelines Concept study Perform storage containment/IS risk assessment. Based on this assessment, design MMV plan and corrective measures plan Baseline campaign plan (may even initiate) Through life MMV plan for development and operation and supply chain EIA proposal Identify relevant background data Report on major hazards Phase 3: Development Technology trade-off study FEED study Storage Characterization Background data Acquire baseline monitoring data Initiate EIA Initiate shallow baseline measurements Finalise storage technology feasibility studies Acquire seismic data Internal emergency response plan Finalised MMV plan 49 Seabed and overburden integrity monitoring for offshore CO2 storage Phase 4: Operation Finalized MMV Plan Monitoring plan revisions Store characterization Monitoring results Anomaly response Regulatory required reporting Operational MMV. Acquire planned monitoring data (base monitoring plan) and history match dynamic models; update as necessary. Internal safety reporting Finalized closure MMV plan Phase 5: Post-closure/pre-transfer Closure MMV Plan Risk assessment updates and additional monitoring as required to prepare handover to government. Demonstrate long-term containment and conformance with subsurface models. Acquire seismic data, demonstrate stability in plume Final shallow monitoring results, demonstrate EIA compliance Handover documentation Phase 6: Post-transfer Handover documentation Jurisdiction continued monitoring plan Monitoring as indicated by updated risk profile of storage site containment and conformance with subsurface models required. Release of public domain data Figure 7: Workflow decision diagram 50 Data acquisition as required Seabed and overburden integrity monitoring for offshore CO2 storage Appendix A: Review of regulatory frameworks and standards relevant to seabed and overburden integrity There are several regulatory requirements relevant to seabed and overburden integrity which are addressed in international, regional, and country-specific regulations. Examples of these regulations and extracts from them relating to seabed and overburden integrity are provided in this Appendix. A.1. International Regulations A.1.1 The London Protocol The London Protocol (1996), under the London Convention (Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter, 1972), regulates the disposal of wastes and other matter at sea. Under the Protocol all dumping is prohibited, apart from eight types of wastes listed in Annex I of the Protocol and for which a permit way be delivered by the National Authority. In 2006, the London Protocol was amended to add subseabed geological storage of CO2 in Annex I. London Protocol Risk Assessment and Management Framework for CS-SSGS (RAMF) and associated Specific Guidelines for the Assessment of Carbon Dioxide for Disposal into Subseabed Geological Formations (the 2012 Guidelines) recommend: • Environmental baseline data is required to assess the pre-existing level of exposures of organisms to natural hazardous substances and ubiquitous contaminants that may be released due to the injection and the effect of additional exposure (Article 7.4). • Environmental baseline data is required to identify sensitive ecosystems or species, sensitive areas and habitats, other amenities or uses of the sea (Article 7.5). • Near-surface baseline data is required such that changes that arise due to sequestration of carbon dioxide streams can be monitored (Article 8.4). • Monitoring of the seafloor and marine communities may be included in the monitoring program (Article 8.9), but this monitoring could be part of the contingency plan (RAMF, s.6.22). A.1.2 The OSPAR convention: The OSPAR Convention (Convention for the Protection of the Marine Environment of the North-East Atlantic, 1992) is the main legal framework governing the protection of the marine environment in the Northeast Atlantic and North Sea. The EU (initially as the European Community) and 15 individual states (mainly EU Member States) are Contracting Parties to the Convention. Since 2007, OSPAR member countries have been allowing subseabed geological storage of CO2, provided the contracting parties apply the OSPAR FRAM Guidelines when granting permits or approvals by the competent authorities. In details for CO2 subsea storage, the following documents should be considered: • Decision 2007/2 on the Storage of Carbon Dioxide Streams in Geological Formations. • Framework for Risk Assessment and Management of Storage of CO2 Streams in Geological Formations (OSPAR FRAM). 51 Seabed and overburden integrity monitoring for offshore CO2 storage • OSPAR Recommendation 2012/5 for a risk-based approach to the Management of Produced Water Discharges from Offshore Installations (especially relevant if produced water is to be discharged at sea) • OSPAR Recommendation 2003/5 related to the Use and Implementation of Environmental Management Systems that recommends oil and gas operators to set clear environmental objectives and targets. The Provisions of the OSPAR FRAM are consistent with those of the EU CCS Directive and the LP, but further guidance is provided on the information and parameters to describe the baseline environment and the risk assessment. A.2 European Regulations In addition to international regulations, several European directives may impact the member states’ legislation for CO2 subsea storage, in particular regarding environmental baseline and near-surface site assessment. A.2.1 Directive 2009/31/EC (CCS Directive) This directive of the European Parliament and of the Council of 23 April 2009 on the geological storage of carbon dioxide sets out a regulatory regime for permitting of exploration of potential CO2 storage sites, storage operations and post closure obligations. • Near-surface baseline data is explicitly required to describe the storage context (Annex I.1.b, and h to k). • Near-surface baseline data is implicitly required to conduct the risk assessment (Annex II: hazard characterization, exposure assessment and effects assessment). • Monitoring of fugitive emissions of CO2 at the injection site is explicitly required in the monitoring plan (Annex II.1.1.e). • Environmental monitoring is explicitly required to detect significant adverse effects on the surrounding environment (Article 13.1.e), but this does not mean that it should be included in the core monitoring program. • Annual reporting, or more frequently if required by the competent authority, of monitoring results and methodology (Article 14) • The associated Guidance Document #2 (Characterisation of the Storage Complex, CO2 Stream Composition, Monitoring and Corrective Measures) makes general recommendations regarding baseline measurements: • Formation gas and fluid characteristics in the storage reservoir, surrounding complex and formations that might be affected by potential leakage, including aquifers • Background CO2 emissions at surface or sea floor • Surface and near surface environmental surveys • Seabed, surface or near surface baseline surveys to define any pre-existing leakage indicators such as pockmarks • Ground surface surveying, e.g. where ground movement monitoring is expected to be beneficial and/or in areas of ground movement risk. 52 Seabed and overburden integrity monitoring for offshore CO2 storage A.2.2 Directive 85/337/EEC (EIA Directive) This directive on the assessment of the effects of certain public and private projects on the environment (as amended by Directive 2011/92/EU and Directive 2014/52/EU) sets out legal requirements for member states to ensure that projects that could have a significant impact on the environment because of their nature, size or location should receive development consent and comprehensive prior assessment. • Environmental baseline data is required to describe the “aspects of the environment likely to be significantly affected by the project, including, in particular, population, fauna, flora, soil, water, air, climatic factors, material assets, including the architectural and archaeological heritage, landscape and the interrelationship between the above factors” (Annex IV.3). • Assessment of the environmental impacts is to be assessed on the basis of the availability of environmental information and scientific knowledge. • An environmental monitoring program may be part of the preventive measures proposed by the operator to prevent significant adverse effects on the environment (Annex IV.4). • Additional monitoring may be granted if knowledge gaps were identified during the EIA (Annex IV.8). A.2.3 Directive 92/43/EEC (Habitats Directive) This directive on the conservation of natural habitats and of wild fauna and flora requires the following: • Habitats listed in the Annex I of the Habitats Directive (“Annex I habitats”) and species listed in the Annex II of the same Directive (“Annex II species”) require the designation of special areas of interest, called Special Areas of Conservation (SACs). • SACs are sites that have been adopted by the European Commission and formally designated by the government of each country in whose territory that site lies. Sites that are in the process of being qualified as SAC are equally considered (SCI, cSAC, pSAC and dSAC). • SCAs and SPAs form the Natura 2000 network of protected areas in the EU. Baseline data is required to identify such areas (Annex I) and species (Annex II). A.2.4 Directive 2003/87/EC (ETS Directive) This directive on the EU emissions trading system requires the following: • Installations are required to monitor and report their emission (planned and unplanned). Allowances should be purchased and surrendered to cover the release of emissions. – ­Baseline data are not explicitly required – Monitoring ­ activities as part of the MMV plan need to provide the input data for emissions calculations and reporting. A combination of methods is proposed (geophysical/acoustic method, then targeted point-based sampling) 53 Seabed and overburden integrity monitoring for offshore CO2 storage A.2.5 Directive 2004/35 (Environmental Liability Directive) This directive on liability for environmental damages requires the following: • Enforces strict liability for prevention and remediation of environmental damage to ‘biodiversity’, water and land from specified activities and remediation of environmental damage for all other activities through fault or negligence (“polluter pays” principle). The Directive requires setting preventive actions (Article 5) and remedial actions (Article 6), but baseline conditions are based on “best information available”. • Baseline data is not required but (environmental baseline) data collected by the operator would be used to describe the status of the environment prior to any pollution. A.2.6 Directive 2008/56/EC (Marine Strategy Framework Directive) This directive establishes a framework for community action in the field of marine environmental policy aiming at achieving and maintaining good environmental status in the marine environment by the year 2020 (article 1.1). This framework is underpinned by ecosystem-based approach (article 1.3) and requires Member States to define indicators, associated targets (article 10) and monitoring programmes (article 11). • This Directive is not directly applicable to subsea CO2 storage project but may provide guidance regarding parameters and indicators that the regulator may want to see in an environmental monitoring program. These European Directives do not provide explicit requirements (i.e., are not prescriptive) in terms of monitoring strategy and parameters. One should look at how the directive has been transposed in the national legislation of each member state. A.2.8 Regulatory context in the UK The Storage of Carbon Dioxide (Licensing etc.) Regulations 2010 is the prime legislative instrument governing CCUS in the UK. Schedule 2.2 specifically addresses monitoring and will be fundamental to the design of store monitoring strategies. The North Sea Transition Authority (NSTA – previously Oil & Gas Authority, or OGA) regulates offshore carbon dioxide storage. The NSTA is the licensing authority for offshore storage except within the territorial sea adjacent to Scotland, which Scottish ministers authorise. Requirements of the EU EIA Directive for CGS projects are transposed into the UK legislation in the Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (“the EIA Regulations”). Data expected for the EIA are compiled in the guidance document issued by the UK Environment Agency for the scoping of EIA of full-chain CCS project. The EIA needs to be supported by generic and regional data, and supplemented by site-specific data, unless it can be demonstrated that such information is not relevant for the site in question. The need for new surveys will be discussed with the regulators and the stakeholders during the scoping phase of the EIA. 54 Seabed and overburden integrity monitoring for offshore CO2 storage The BEIS defines three types of monitoring: baseline surveys, site-specific surveys and intelligent surveys. Intelligent survey means a phased approach during which information is first collected using non-invasive geophysical techniques (such as multi-beam echosounder and side-scan sonar) and the collected data is used to design the additional survey requirements. A.2.7 Regulatory context in Netherlands Provisions of the EU CCS Directive have been transposed into Dutch legislation without any additional technical requirement. They are addressed by The Mining Act (Ministerie van Economische Zaken, 2011a), Decree (Ministerie van Economische Zaken, 2011b) and Regulation (Ministerie van Economische Zaken, 2011c). A.2.8 Regulatory context in Norway Requirements of the EU CCS Directive have been integrally transposed into Norwegian legislation without any additional technical requirement. Additional provisions are resent in: • The Royal Decree ”Forskrift om lagring og transport av CO2 på sokkelen” (Regulations relating to exploitation of subsea reservoirs on the continental shelf for storage of CO₂ and relating to transportation of CO₂ on the continental shelf) pursuant to the Continental Shelf Act of 21 June 1963, managed by the Ministry of Petroleum & Energy/Labour & Social Affairs, and • The Pollution control regulation Part 7A., chap. 35 pursuant to the Pollution and Waste Act of 13 March 1981, managed by the Ministry of Environment and Climate. Table A.1, Table A.2, and Table A.3 summarize near surface data requirements in the Netherlands, Norwegian, and UK contexts associated to the relevant permitting milestones. Depending on the applicable framework, monitoring data may be required at different steps of the project to: • Describe the context of the CGS and the “baseline scenario” based on existing data (initial near-surface data compilation phase). • Characterize the near-surface of a site and fill knowledge gaps (near-surface site characterization phase). • Provide a reference basis against which changes will be measured (near-surface preinjection monitoring phase): note that this reference basis may be time dependent (natural or anthropogenic variability, long-term trend). • Support the MMV plan during injection or post-injection phase (outside of the scope of this report). 55 Seabed and overburden integrity monitoring for offshore CO2 storage Table A.1: Subsea CO2 storage near-surface data requirements in the Netherlands Permitting milestone Activity & Deliverable Environmental data requirements EIA – Scoping Notice of Scope and Level of Detail Preliminary impact of projects and project alternatives on: Reference/ Guidelines • Population • Biodiversity, seabed, water, air and climate, cultural heritage EIA – realization Pipeline Licence EIA reports (storage and pipeline) • Baseline data (see above) Pipeline route survey • profile of the bottom of the sea • Identification of information gaps Article 1.7.1 of Mining Decree • obstacles present • location of existing pipelines and cables • soil mechanic characteristics • stratigraphy of the bottom of the sea • the analysis and quality of soil samples and probes. Storage Licence/permit Site characterization • Description of the domains surrounding the storage complex Annex I of the EU CCS Directive • Population distribution • Proximity to valuable natural resources • Activities around the storage complex • Proximity to the potential CO2 source(s) • Sensitivity to CO2 of receptors Risk assessment • Potential leakage routes and leakage magnitude • Exposure assessment based on characteristics of the environment and activities • Effect assessments based on the sensitivity of special species or habitats 56 Annex II of the EU CCS Directive Seabed and overburden integrity monitoring for offshore CO2 storage Permitting milestone Activity & Deliverable Environmental data requirements Reference/ Guidelines Monitoring plan • Detecting significant adverse effects for the surrounding environment Annex II of the EU CCS Directive • Fugitive emissions of CO2 at the injection facility • Pre-injection baseline, as required Table A.2: Subsea CO2 storage near-surface data requirements in Norway Permitting milestone Activity & Deliverable Environmental data requirements Reference/Guidelines Proposed study programme Propose study programme for Impact Assessment to the MPE • Preliminary assessment of the impact of the project on the environment, including cultural monuments and cultural environment, any transboundary environmental effects, natural resources, fisheries and society in general Guidelines for PDO and PIO • Result of consultation of existing RIAs3 and individual IAs should be consulted • Identification of knowledge gaps and need for documentation and updates • Preliminary remedial measures • Identification of applicable provisions under the Nature Diversity Act 57 Regulations on CO2 storage (s.4-7) Seabed and overburden integrity monitoring for offshore CO2 storage Permitting milestone Activity & Deliverable Environmental data requirements Reference/Guidelines Impact Assessment (EIA) EIA process and report • Alternative development solutions Regulations on CO2 storage (s.4-8) • Environment that may Guidelines for PDO and be significantly affected PIO1 • Consequences of regular and acute discharges on plant and animal life Plan for development and operation Proposed plans • Description of technical measures for preparedness relating to health, safety and the environment in the petroleum activities Regulations on CO2 storage (s.1-10, s.4-6 , Appendix II) Guidelines for PDO and PIO1 • Proposed monitoring plan • Proposed plan for corrective measures • Proposed preliminary plan for post-operation Storage Permit Characterization of the storage Same requirements as CCS Directive Appendix I of the Regulations for CO2 storage2 Risk assessment Same requirements as CCS Directive Appendix I of the Regulations for CO2 storage2 Site characterization Same requirements as CCS Directive Pollution control regulation (Appendix I of Chapter 35) Risk assessment Same requirements as CCS Directive Idem Monitoring plan Same requirements as CCS Directive Pollution control regulation (s.35-9 and Appendix II) Environmental monitoring • Water column monitoring (Oceanographic parameters, chemical parameters, biological parameters) Guidelines for environmental monitoring of petroleum activities on the Norwegian continental shelf • Monitoring of benthic habitats (grab sampling and video surveys) 58 Seabed and overburden integrity monitoring for offshore CO2 storage Table A.3: Subsea CO2 storage near-surface data requirements in UK Permitting milestone Activity & Deliverable Environmental data requirements Reference/Guidelines Storage Licence High-level EIA 10-20 pages to demonstrate that the Company is aware of the sensitivities in the area within, and immediately adjacent to, the block(s) of interest, and is aware of the potential impacts that would have to be managed during the execution of the proposed work programme Guidance on an application for an offshore carbon storage licence Survey Licence Licence application Identify any areas designated for protection under the Habitats Directive or Wild Birds Directive (or that could qualify) The Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (as amended) – A Guide Identification of Annex I habitats Storage Permit Site characterization • Identification of environmentally sensitive areas • Description of the domains surrounding the storage complex Environmentally sensitive areas Annex I to CCS Directive • Population distribution • Proximity to valuable natural resources • Activities around the storage complex • Proximity to the potential CO2 source(s) • Sensitivity to CO2 of receptors Risk assessment • Review of existing well data • Hydraulic communication between geological units • Demonstration of no significant risk of leakage or of harm to the environment or human health 59 Guidance on Carbon dioxide storage permit application Seabed and overburden integrity monitoring for offshore CO2 storage Permitting milestone Activity & Deliverable Environmental data requirements Reference/Guidelines Monitoring plan Monitoring plan to include as a minimum: Guidance on Carbon dioxide storage permit application • Seabed monitoring: monitoring of the seabed above the storage site to identify CO2 leakage (no parameter specified). Annex II to CCS Directive • Fugitive emissions of CO2 at the injection facility. Pre-injection baseline as required Pipeline Works Authorization Pipeline route survey Environmental consent Scoping of the EIA Review of existing environmental data: • Population • Biodiversity, seabed, water, air and climate, cultural heritage • Seasonal variability • Focus on environmental aspects likely to be significantly impacted by the project scoping guidance document for CCS projects The Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (as amended) – A Guide • Identification information gaps and need for new surveys EIA report (EIS) • Baseline surveys • Site-specific surveys (less than 5 years) • Intelligent surveys 60 The Offshore Petroleum Production and Pipelines (Assessment of Environmental Effects) Regulations 1999 (as amended) – A Guide Seabed and overburden integrity monitoring for offshore CO2 storage A.3. Examples of regulations from other countries A.3.1 Australian regulations and guidelines Currently, there is no single reference or guideline that sets out a standard for all of Australia. It is multi-jurisdictional, with significant dependence on the Planning Approval process. The legal framework for encouraging and regulating carbon capture and storage (CCS) in Australia is divided among the Commonwealth and the states and territories. The Commonwealth and some states have established CCS-specific regulations. Commonwealth CCS legislation only applies to offshore areas that are beyond state jurisdictions, which generally extend three miles offshore. State CCS-specific legislation applies onshore and offshore within their respective jurisdictions. However, there is significant variation across states and territories and though the relevant frameworks are comprehensive in some parts of the country, they are much less so in other parts. Details of these regulations can be found in an online article by White & Case (Power, 2021). The Environmental Guidelines for Carbon Dioxide Capture and Geological Storage are intended to build on the Carbon Dioxide Capture and Geological Storage – Australian Regulatory Guiding Principles endorsed by the Ministerial Council on Mineral and Petroleum Resources in 2005. They provide regulators, proponents, and the public with an understanding of the application of existing environmental laws to proposed carbon dioxide capture and geological storage projects. They are intended to demonstrate best practice and do not seek to place additional burden on existing state and territory government requirements. The guidelines provide steer for the environmental assessment, monitoring, site closure, and coordination. Appropriate monitoring is considered an essential element in the conditions for approvals for all CCS projects. A.3.2 Japanese regulations In Japan, several technical verification and demonstration CCS projects have been conducted for saline aquifer due to lack of hydrocarbon fields which were ready to accept CO2. At the time of this writing, there are no commercial scale CCS/CCUS projects nor specific legislation to administer them. The Mining Act and Mining Safety Act covers onshore geological storage, while the offshore capture and storage activities are governed by Act on the Prevention of Marine Pollution and Maritime Disaster. According to the Act, project practitioners need to obtain an approval from Minister of the Environment (MOE) by submitting monitoring plans prior to implementation. Monitoring plans consists of three parts: monitoring plan for steady-state operation, monitoring plan for needs care, and monitoring plan for emergency (Table 4). In steady state operation phase, even if the pressure data and temperature at injection facilities and in storage layers appear normal, if there are some exceedances found in water sampling survey, a follow-up survey to re-confirm the pressure and temperature data will be carried out. Based on the results of that survey, the monitoring level may need to be increased. This three-step monitoring scheme makes it possible to elevate monitoring levels quickly and maintain a detailed investigation over a long period. 61 Seabed and overburden integrity monitoring for offshore CO2 storage The Act on the Prevention of Marine Pollution and Maritime Disaster imposes appropriate requirements during injection completion and short time after completion on operator, however there are no regulations that can consider long-term management after CCS completion. Under the current act, project practitioner has a responsibility to renew the approval license every five years as long as CO2 is stored. That puts operator under an obligation to monitor CCS storage areas permanently. In addition to the above Acts to control offshore activities, there are multiple safety laws governing onshore facilities: • Gas Business Act for Inlet gas line, CO2 Capture Facility (Absorption Unit), and separated flammable gas line. • High Pressure Gas Safety Act for CO2 lines, Capture Facility (Flash etc.) and compressors toward the wellheads. Monitoring plans for CCS operations has to be developed according to the relevant Acts mentioned previously, and the operator is required to conduct monitoring and report to the Ministry of Environment (MOE) Japan. 62 Table A.4: Overview of monitoring plan and monitoring report in Japan Report Same time as chemical property of sea water Continuous Continuous Annually Frequency Annually Continuous Pressure and temperature at injection well Same time as chemical property of sea water Continuous Same time as chemical property of sea water Continuous Annually Continuous Pressure and temperature at observation well Condition of geological formations and geological features such as pressure and temperature change Same time as chemical property of sea water Injection activities suspended Injection activities suspended Annually Continuous Injection pressure, velocity and temperature Injection condition Report Frequency Annually Report Regular analysis Alkali absorption and Gas chromatography Flow meter Continuous Density Disposal volume Frequency Monitoring method Monitoring item Steady state monitoring Needs care 63 Emergency 1. Condition of CO2 gas Same time as chemical property of sea water immediately Two times in permit validate period Annually Seismic Same time as chemical property of sea water Continuous Same time as chemical property of sea water Continuous Annually Continuous Pressure and temperature at observation well Location and extent of CO2 Immediately As needed Immediately As needed Quarterly, Immediately in case of follow-up survey Quarterly, Follow-up survey as needed Oceanic environmental survey Chemical property of sea water 2. Condition of maritime area Immediately As needed Quarterly Quarterly Oceanic environmental survey Condition of marine species Immediately As needed Permit expired year Once in the previous year of permit expiration Desktop study and hearing survey Condition of usage of biology and ocean Seabed and overburden integrity monitoring for offshore CO2 storage Seabed and overburden integrity monitoring for offshore CO2 storage A.4 Standards and recommended practices Apart from regulatory requirements, there are also standards and recommended practices relevant to seabed and overburden integrity and the examples are referenced below. A.4.1 ISO 27924:2017 Carbon dioxide capture, transportation, and geological storage — Geological storage ISO 27914 focuses on the storage complex and there are only a few recommendations regarding near-surface data. The following sections of ISO 27914 should be considered: Section 5.5.4, Baseline geochemical characterization; Section 6.7.2.2, Process (Table 1, Criteria number 6); and Sections 9.3.a and 9.3.b, M&V program objectives. A.4.2 ISO/FDIS 19901-10 Marine Geophysical Investigations and ISO/FDIS 19901-08 Marine Soil Investigations These standards are the requirements and guidelines for marine geophysical investigations. It is applicable to operators/end users, contractors and public and regulatory authorities concerned with marine site investigations for offshore structures for petroleum and natural gas industries. As there are many areas of CCUS storage as yet undefined utilizing methods from adjacent industries will be useful for defining best practice. A.4.3 DNV-RP-J203: Geological Storage of Carbon Dioxide This Recommended Practice specifies: • Near-surface baseline is required for describing the ‘context’ for site screening, site selection, permitting, and risk management. The type of information required is in line with the provisions of the EIA and CCS directives. • Near-surface monitoring is required to demonstrate performance of the storage in terms of health, safety and the environment • Baseline monitoring prior to injection is required to define baseline against which monitoring measurements will be compared (including temporal trends and fluctuations) The following section of DNV-RP-J203 should be considered: Section 5.4.4, Environmental statement. A.4.4 DNVGL-RP-F104: Design and operation of carbon dioxide pipelines The following sections of DNV-RP-F104 should be considered: Section 3.2.7, Health, safety and environment; and Section 3.4.5, Environmental impact. 64 Seabed and overburden integrity monitoring for offshore CO2 storage Appendix B: Case studies Marine environmental monitoring in Japan Under the Act for the Prevention of Marine Pollution and Maritime Disaster, administered by the Ministry of the Environment (“MOE”), operators who will work for offshore geological storage in Japan need to establish a Monitoring Plan and then conduct monitoring during predefined three stages (before injection – baseline surveys, during injection, and postinjection) to ensure site integrity. The Operator for a Japanese CCS demonstration project, under the commission of the New Energy and Industrial Technology Development Organization (“NEDO”) with funding from the Ministry of Economy, Trade and Industry (“METI”) along with continuous monitoring of seismicity and reservoir fluid dynamics, has carried out seasonal marine environmental surveys including chemical measurements of seawater and sea bottom sediments at 12 selected locations. To monitor CO2 behaviour and seismicity in and around the storage complex, downhole pressure and temperature were continuously monitored in the injection wells and three observation wells, and these observation wells were also equipped with downhole seismic sensors. OBC (Ocean Bottom Cable), four OBS (Ocean Bottom Seismometers), and an onshore seismic station have been deployed, being an integral part of spatio-temporal monitoring of micro-seismicity and natural earthquakes, including periodical 2D and 3D surveys. Four marine environmental surveys (seasonal baseline surveys) were conducted between August 2013 and May 2014, to cover all four seasons. From these measurements, an initial threshold line (upper limit of 95% prediction interval) based on the relationship between partial pressure of CO2 (pCO2) and dissolved oxygen (DO) of sea water was drawn. Injection of CO2 commenced in April 2016 and temporally suspended in late May for a planned maintenance. The reservoir received 7,163 t of CO2 during this period. Original plan was to resume injection in August, but the June marine survey reported some points exceeded the initial threshold line, which triggered a “follow-up” survey of chemical remeasurements of sea water (round purple markers on ). Side-scan sonar survey for bubble detection and a pH sensor survey were conducted along with the chemical measurements at the points of exceedance. METI and MOE concluded the high values were false-positives caused by natural variations and updated the threshold line (a solid red line on ), adding the data from February 2017 to February 2018 surveys. They also recognized and reported the difficulty in effectively surveying the sea-bottom soil and condition of marine organisms as a method of detecting CO2 leakage. Therefore, operator proposed MOE to reduce the frequency of this survey by once in a permit validity period for future projects. There are no huge gaps between marine survey results after CO2 injection commencement and baseline survey results. Also there are no event that may relate to CO2 leakage. From these points, it is confirmed that CO2 is safely captured in the layers. The project is currently in post injection monitoring period. 65 Seabed and overburden integrity monitoring for offshore CO2 storage Experience from projects offshore Norway One Norwegian project offers a valuable case study in offshore monitoring. The project was initially permitted under Norwegian Petroleum Law. Subsequently, in 2015, after the Norwegian legal framework was updated to be consistent with the 2009 EU directive on CO2 storage, the CO2 storage operation at the site was re-permitted to be consistent with the new directive. In the initial years, the project was used to inform the terms of the EU directive on CO2 storage, including research on marine environmental monitoring. Various research cruises to measure the chemistry of sediments and water column were conducted to search for potential increased CO2 levels. No indications of leakage from the site have been identified.15 However, concerns about possible leakage are often raised by various stakeholders and members of the public, such that confirmation of ‘absence of leakage’ continues to be a question the operator may need to address as part of ongoing compliance with the regulations. 15 Furre AK et al, 2017 66 Seabed and overburden integrity monitoring for offshore CO2 storage References IOGP Report 373-01 - Geodetic awareness guidance notes IOGP Report 373-21 - Grid Convergence – Geomatics guidance note 21 IOGP Report 373-24 - Geomatics Guidance Note 24 – Vertical data in oil and gas applications IOGP Report 373-16 - Guidelines for the quality control of proposed well coordinates IOGP Report 373-18-1 - Guidelines for the conduct of offshore drilling hazard site surveys IOGP Report 373-18-2 - Offshore Drilling Hazard Site Surveys – Technical Notes IOGP Report 462-1 - Guidelines for the use of the Seabed Survey Data Model IOGP Report 462-02 - Guideline for the delivery of the Seabed Survey Data Model IOGP Report 483-7 - P7/17 Wellbore Positioning Data Exchange Format (and User Guide) IOGP Report 483-1u - IOGP P1/11 Geophysical position data exchange format – User Guide IOGP Report 483-6u - IOGP P6/11 Seismic Bin Grid Data Exchange Format - User Guide IOGP Report 483-6g - Guidelines for the use of the P6 Bin Grid Data Model IOGP Report 629 - Application of Remote Sensing Technologies for Environmental Monitoring IOGP Report 652 - Recommended practices for measurement, monitoring, and verification plans associated with geologic storage of carbon dioxide Birchenough S, Williamson P, and Turley C. “Future of the Sea: Ocean Acidification.” United Kingdom Government Office for Science. 2017. Blackford, J., et al. “Marine baseline and monitoring strategies for carbon dioxide capture and storage (CCS). .” International Journal of Greenhouse Gas Control 38. 2015. Blackford J et al. “Impact and detectability of hypothetical CCS offshore seep scenarios as an aid to storage assurance and risk assessment.” International Journal of Greenhouse Gas Control 95. 2020. Bourne S, Crouch S, and Smith M. “A risk-based framework for measurement, monitoring and verification of the Quest CCS Project, Alberta, Canada.” International Journal of Greenhouse Gas Control 26. 2014. p. 109-126. Daiji T et al. “Progress of CO2 injection and monitoring of the Tomakomai CCS Demonstration Project.” Proceedings of the 15th Greenhouse Gas Control Technologies Conference 15-18 March 2021. Abu Dhabi. 1 April 2021. Dean M et al. “Insights and guidance for offshore CO2 storage monitoring based on the QICS, ETI MMV, and STEMM-CCS projects.” International Journal of Greenhouse Gas Control 100. 2020. 67 Seabed and overburden integrity monitoring for offshore CO2 storage Dean M and Tucker O. “A risk-based framework for Measurement, Monitoring and Verification (MMV) of the Goldeneye storage complex for the Peterhead CCS project, UK.” International Journal of Greenhouse Gas Control 61. 2017. p.1-15. Furre AK et al. “20 years of monitoring CO2-injection at Sleipner”. Energy Procedia 114. 2017. p.3916-3926. Directive 2004/35/CE of the European Parliament and of the Council of 21 April 2004 on environmental liability with regard to the prevention and remedying of environmental damage, Articles 5 and 6 for EU/UK regulations Government of Japan, Ministry of Economy, Trade and Industry (METI), New Energy and Industrial Technology. “Development Organization (NEDO), and Japan CCS Co., Ltd. (JCCS), Report of Tomakomai CCS Demonstration Project at 300 thousand tonnes cumulative injection (“Summary Report”).” 2020. Available at: https://www.meti.go.jp/english/press/2020/pdf/0515_004a.pdf. Government of Japan, Ministry of Environment (MOE). “Appropriate state of monitoring plan of offshore CCS projects.” 2016. Available at: https://www.env.go.jp/water/kaiyo/ccs2/kanshinoarikata. pdf. Jones et al. “Developments since 2005 in understanding potential environmental impacts of CO2 leakage from geological storage.” International Journal of Greenhouse Gas Control 40. 2015. p.350377. Lichtschlag et al. “Suitability analysis and revised strategies for marine environmental carbon capture and storage (CCS) monitoring.” International Journal of Greenhouse Gas Control 40. 2021. Roberts et al. “Geochemical tracers for monitoring offshore CO2 stores.” International Journal of Greenhouse Gas Control 65. 2017. p.218-234. United Kingdom Department for Environment, Food, and Rural Affairs, Marine Online Assessment Tool. “pH and ocean acidification”. https://moat.cefas.co.uk/ocean-processes-and-climate/oceanacidification/ (Accessed 15 June 2023) 68 Seabed and overburden integrity monitoring for offshore CO2 storage This page is intentionally blank 69 The Report provides a set of common industry good practices for demonstrating the ongoing integrity of an offshore CO2 storage project and to provide assurance to the operator(s), local regulatory bodies, or public stakeholders that the injected CO2 remains in the storage unit over the full project lifecycle. Using these guidelines, the operator should be able to demonstrate that, in the case of anomalies or unexpected leakage detected in the overburden and/or at seabed, the necessary mitigation measures are in place to identify the issue promptly and thus reduce the impact of the leak to a minimum level. The scope and focus of this Report are on the marine environment, seabed, and shallow overburden, limited to the units above the storage complex. www.iogp.org IOGP Headquarters City Tower, 40 Basinghall Street, London EC2V 5DE, United Kingdom T: +44 (0)20 3763 9700 E: reception@iogp.org IOGP Americas IOGP Asia Pacific IOGP Europe IOGP Middle East & Africa T: +1 713 261 0411 E: reception-americas@iogp.org T: +60 3-3099 2286 E: reception-asiapacific@iogp.org T: +32 (0)2 790 7762 E. reception-europe@iogp.org T: +20 120 882 7784 E: reception-mea@iogp.org