Toward a Law of the
Underground
Developing a regulatory framework for
geologic carbon capture and storage
Caitlin Augustin
MVA Project
DOE Award # FE0001580

GPS
◦ Measure surface
deformation with high
temporal resolution

InSAR
◦ Measure surface
deformation with high spatial
resolution

Seismology
◦ Measure Vp/Vs at selected
test site and locate
microearthquakes as
indicators of fluid migration

Geochemistry
◦ Measure key geochemical
parameters at test site
TECHNOLOGY
BACKGROUND
Definition
The capture of carbon
dioxide from a large
point source and
subsurface storage in
such a manner that it
never reaches the
atmosphere
Storage Sites
Zone Type
Average
Depth of
injection
(meters)
Count of
active
zones
Count of
potential
zones
Oil
reservoir
(EOR)
1454
1751
1,000+
Depleted
Oil/Gas
reservoir
1840
942
1,000+
1500-3000
33
unknown
1800-2300
274
355 planned
sites, count
unknown
Unmineable
coal
seams
Saline water
(brine
reservoirs)
2.
1.
Oil and Gas Journal Enhanced Recovery Survey (2010)
Current State of issues concerning Underground Natural Gas Storage
(2004)
3.
Big Sky CO2 Project
4.
CCS @ MIT (2012)
Depth measure: US Energy Information Administration
Process
Adoption


Short to mid-term emissions reduction
technology
It is estimated that geologic carbon capture
and storage (CCS) could be used to
achieve between 15% and 55% of the
carbon emission reductions necessary to
avoid dangerous levels of climate change.
(IPCC, IEA, IRGC)
DISSERTATION
PROJECT
Problem Statement
Fundamentally there is not a clear accounting of what
happens to injected carbon dioxide, and there is no
clear set of legal guidelines covering CCS
Implementation of large-scale, transboundary CCS
projects are largely unaddressed. Likely first order
scenarios that need to be considered are
1.
2.
1.
2.
3.
When CO2 injection is contained within one state, but there
is the potential for CO2 migration towards or subsurface
pressure changes in a neighboring state
Situations where the storage reservoir spans one or more
political boundaries
There exists an inadequate and incomplete
probabilistic risk assessment framework for evaluating
potential leaks and health impacts
Objectives
1.
2.
3.
4.
5.
Understand subsurface reactions in storage
reservoirs at the field-scale
Develop a probabilistic risk assessment for
future geologic sequestration scenarios
Expose the inadequacies of existing legal
frameworks governing CCS
Analyze transboundary security issues
stemming directly from CCS
Propose a framework for a Law of the
Underground
Expected Contributions
1.
2.
3.
4.
First geochemical models of Teapot
Dome, Wyoming
First Bayesian risk analysis of CCS
First Bayesian risk analysis of natural
CO2 leaks
First comprehensive Law of the
Underground
Related Research
Geology
Engineering
Policy
Caraballo AC, Rabindran P,
Winning G, et al. (2010)
Vinogradov (2011)
Bradsher, K and Barboza, D.
(2011)
Bertinelli, L., Camacho, C. and
Zou, B, (2011)
Wilkinson et al (2009)
Birkholzer (2010)
Hart (2011)
Luquot et al (2009)
Zerai et al (2006)
Chabora and Benson (2009)
Nordbotten (2008)
White et al (2005)
Class, H et al. (2009)
Xu et al (2005)
Englehardt, J.D. (1995)
Hardisty et al (2011)
Endres (2010)
De Figueiredo et al (2006, ‘07,
‘09)
Rubin, E.S., McCoy, S.T., Apt, J.
(2005)
Rissland, E. L., Ashley, K. D., &
Branting, L. K. (2005)
Policy
Methodology
Geology
Engineering
Predictive Risk
Assessment
Reactive
Transport
Modeling
Reservoir
Characterization
Case-based Legal
Research
A Law of the
Underground
Differential
Games
Modeling
DISSERTATION DATA
SOURCES
Theoretical dataset

Class, et al 2009
◦ “A Benchmark study on
problems related to
CO2 storage in geologic
formations

Parameters
◦
◦
◦
◦
◦
model domains
model input parameters,
boundary conditions
simulation times
expected model outputs
Class, H ,et al. (2009) “A benchmark study on problems related
to CO2 storage in geologic formations.” Computational
Geosciences 13.4: 409-434.
Case Study dataset

DOE Rocky
Mountain Oilfield
Testing Center
◦
◦
◦
◦
◦
◦
Injection schedule
Lithology
Injectant data
GIS maps
Well logs
Core data (porosity
and permeability)
◦ Seismic
From DOE dataset
Case Study site: Teapot Dome, WY



CO2 injection
into three
unique
formations
(Tensleep,
Shannon, 1st
Wall Creek)
Situated near
major
metropolitan
area
Reservoir
borders Native
American
territorial lands
Map of NPR-3 Injection Site
Natural CO2 Leaks dataset

290 point dataset
compiled dataset from
◦ Googas Database
◦ USGS Volcanics
◦ EPA

Data contains
◦ Volume (metric tons)
leaked per 24 hours
◦ Type of leak
◦ Human fatalities
◦ Human injuries
◦ Animal fatalities
◦ Latitude/longitude
Map of Googas database leak locations
Commercial Leaks dataset

18 point dataset
compiled from
◦ News sources
◦ Literature review

Data contains
◦ Volume (metric tons)
leaked per 24 hours
◦ Type of leak
◦ Latitude/longitude
◦ Human fatalities*
*not available for all sites
Leak at Weyburn, Canada injection site
DISSERTATION
CHAPTERS
Ch 1: Introduction

Motivation for the Study
◦ CCS is performed by public and private actors
across local, national and international
governments
◦ The cross-cutting nature of CCS means law has
been created without scientific basis, leading to
unrealistic monitoring standards and arbitrary
injection frameworks
◦ Law is proposed and interpreted at all levels,
from the local to federal to international, leading
to overlapping and conflicting regulatory regimes
Ch 1: Introduction

Description of the Knowledge Gaps
◦ Subsurface interactions: There is a need for a better understanding
of long-term storage, migration and leakage processes.
◦ Probabilistic Risk Profiles: To date, there have been no few at
quantifying risk on a site by site basis using probabilistic methods, and
no attempts at quantifying on a larger scale. Furthermore, no research
has been undertaken to do predictive Bayesian modeling on GCCS site
information and use these techniques to develop a risk profile for future
injection scenarios.
◦ Regulation: Current knowledge about the legal and regulatory
requirements for implementing GCCS remains inadequate. There exists
no appropriate framework to facilitate the implementation of GCCS
and manage the associated long-term liabilities. Clarification is needed
regarding potential legal constraints on geological storage (either
terrestrial or sub-seabed.)
Ch 1I: 3-D Reservoir
Characterization—Chapter Overview

This chapter will focus on the
development field-scale reservoir models
of potential injection sites. These models
are intended to form the basis of the
reactive-transport models of
CO2 injection in Ch II

Potential fields must be characterized on
reservoir architecture and lithology
◦ This characterization can highlight potential injection
hazards such as groundwater contamination, pressure
build up, and fracture/fault presence.
Software
◦ PetraSim
◦ Trinity
5,000 and 10,000
point grids
 Data

◦ Class, et al
◦ Teapot Dome
Petrasim benchmark
problem(reservoir is stratified
based on lithology)

Petrasim problem (reservoir is
inverted, stratified based on
teperature)
Ch 1I: 3-D Reservoir
Characterization—Chapter Approach
Ch 1I: 3-D Reservoir Characterization—
Preliminary Results/Next Steps

Tough 2 has no
visualizer and is
cumbersome to work
with
◦ PetraSim is a far easier
tool

Tough 2 cannot handle
oil as a fluid
◦ Use basin modeling
techniques from
petroleum geology
which allow oil to
behave as a fluid

Trinity software
Zetaware Trinity © Basin Model of
an unnamed oil field
Ch III: 2-D and 3-D Reactive Transport
Modeling—Chapter Overview

This chapter will present the results of modeling
of CO2–brine–mineral reactions in sandstone,
carbonate, and mixed mineral assemblage
reservoirs

The 2-D reactive transport models should
demonstrate mineral-trapping and solubilitytrapping of CO2 over specified time scales

The 3-D models should show the evolving
pressure field over an injection site, the migration
of the CO2 plume over time, and the reservoir
deformation resulting from injection
Software
◦ PetraSim
◦ Geochemist’s
Workbench
5,000 and 10,000
point grids
 20, 50, 100 year
reaction periods
 Data

◦ Class, et al
◦ Teapot Dome
Precipitation of dawsonite e from a
sandstone reservoir

Precipitation of siderite from a
sandstone reservoir
Ch III: 2-D and 3-D Reactive Transport
Modeling—Chapter Approach
Ch III: 2-D and 3-D Reactive Transport Modeling—
Preliminary Results and Next Steps
We discovered a
glitch in GWB
models where more
carbonates were
precipitating than
possible
 Attending a summer
2013 GWB training
workshop

Reaction path modeling from
Zerai, et al (2005)
Chapter IV: Predictive Risk
Assessment —Chapter Overview

With GCCS, it will be impractical and impossible
to collect comprehensive empirical data regarding
geologic reservoir leaks. For these reasons,
together with the expense of field data collection,
there is a need for a statistical technique
integrating limited data collection with stochastic
modeling.

Predictive Bayesian modeling techniques have
been developed and demonstrated for exploiting
limited information for decision support in many
other situation, this chapter will adapt and apply
them to CCS.
Chapter IV: Predictive Risk
Modeling—Chapter Approach
Develop a probabilistic
risk profile using a
compound Poisson
model
◦ Incident frequency
modeled using the
predictive Bayesian form of
the Poisson distribution
◦ Incident size modeled using
the predictive Bayesian
form of the truncated
Pareto I distribution

Run a 1,000,000 point
Monte Carlo simulation
with 100,000 sampled
for replacement
1000
100
10
1
0
0.1
0
log (probability density)

10
1000
100000 10000000
0.01
0.001
0.0001
0.00001
0.000001
0.0000001
1E-08
1E-09
1E-10
log (incident sizes)
Empirical PDF for natural leaks
historic data
Chapter IV: Predictive Risk
Modeling—Preliminary Results

◦ (Robers , 2011) “more likely to be struck by
lightening than die from CCS leak”
1000
10000
100000
0.0001
0.00001
0.000001
0.0000001
1E-08
log (n*z total incident size) metric tons
Resulting compound distribution
over a 20 year planning period
This first application of Bayesian
methods to the carbon capture and
storage problem corroborates recent
research results from other schools
100
0.001
0.7000
0.6000
0.5000
0.4000
0.3000
0.2000
0.1000
0.0000
0
20000
40000
60000
80000
total leakage volume
100000
Resulting probability distribution
over a 20 year planning period
◦ results of this simulation show that the
probability of large volume leakage is so
small that the risk would actually be
classified as “low”
0.01
log (probibility density)
In risk analysis, the formula
“Risk = Probability × Consequence”
is applied as a way to categorize high,
medium, and low risk scenarios
probability

Chapter IV: Predictive Risk
Modeling—Next Steps
Build model based on known commercial
leak data
 Compare commercial leak profile and
natural leak profile

Chapter V: Legal analysis—Chapter
Overview

Intergovernmental agencies have focused on regulating
isolated components of CCS rather than the process as a
whole.

CCS does not fall easily within the regulation of international
legislation, as existing laws were designed prior to this
technology being developed. Very few countries have
developed the necessary frameworks for sequestration
regulations and in many cases haven’t even determined which
regulatory authorities have jurisdiction.

Intergovernmental laws, national laws from the 50+ countries
adopting GCCS, and regional laws from major adopters (such
as the United States) will be analyzed.
Chapter V: Legal analysis—Chapter
Approach

“case-based” approach
◦ Simply put, the present
problem of interpretation
must be solved based on
the solutions to similar
past problems.
◦ In particular, one tries to
resolve interpretation
problems by considering
past applications of the
rules and terms in
question: by examining
precedent cases,
comparing and contrasting
these with the instant
case, and arguing why a
previous interpretation
can (or cannot) be applied
to the new case.,
Chapter V: Legal analysis—
Preliminary Results and Next Steps

Categorized all property law regimes in
relation to subsurface ownership

Identified all laws governing (or potentially
governing) carbon dioxide

Identified international laws governing (or
potentially governing) CCS
Chapter VI: Transboundary Security
Situations—Chapter Overview
Chapter VI: Transboundary Security
Situations—Chapter Approach

◦
◦
◦
◦

◦

◦

Game theory will be applied to a transboundary
injection model with two actors
Countries commit to an emissions reduction target
Emissions potential stays constant
Cost of reduction of one emissions unit
Penalty cost of not reducing one emissions unit
Noncooperative model
Individual economic success optimized
Cooperative model
Joint economic success optimized
Based on Olli Tahvonen (1994) “Carbon dioxide
abatement as a differential game”
Chapter VII: Law of the
Underground
Subsurface ownership
 Treatment of carbon dioxide
 Liability regimes
 Disaster mitigation

Timeline
Percentage
completed/ topic
Bayesian Models:
natural leaks
Bayesian Models:
commercial leaks
Legal Analysis
3-D Reservoir
Characterization
(Trinity)
3-D Reservoir
Characterization
(PetraSim)
2-D Reactive
Transport Modeling
3-D Flow Modeling
Differential Games
Modeling
Policy
Recommendations
10%
20%
30%
Problem designed
and model built
40%
50%
60%
Data collected
70%
80% 90%
Analysis run and
refined
100%
Writing
chapter
Spring
2013
Spring
2013
Spring
2013
Summer
2013
Fall
2013
Fall
2013
Spring
2014
Summer
2014
Fall
2014