別添 3：CO2-EOR を CO2 削減措置と位置付ける各種制度における技術的要求事項
Appendix 3: Technical requirements defined in different schemes that include CO2-EOR as a means of CO2 storage (as of December 2022)
NOTE: The American Carbon Registry (ACR) is a voluntary carbon offset program; The Clean Development Mechanism (CDM), defined in Article 12 of the Protocol, allows a country with an emission-reduction or emission-limitation commitment
under the Kyoto Protocol (Annex B Party) to implement an emission-reduction project in developing countries; EPA Class II plus Subpart RR is the requirements for CO2 enhanced oil recovery in the US in the 45Q Tax Credit1; EPA Class VI plus
Subpart RR is the requirements for CO2 geologic sequestration in the US in the 45Q Tax Credit1; the Alberta Emission Offset System (AEOS) is a regulatory program that enables facilities regulated under the Carbon Competitiveness IncentiveRegulation to purchase and retire emission offsets to meet compliance obligations.
The following table is modified after Gupta and Cumming, 2016 2 with referencing to the original documents for each rules.
ACR:

CDM:

American Carbon Registry3

CleanDevelopment

Mechanism,

Modalities and Procedures for CCS4Risk⚫

File Risk Mitigation Covenant or⚫

Perform risk and safety assessment

Assessment

similar, including ACR right to accessfor entire CCS chain (not just storage),and Mitigation

property to conduct inspections [ACR

periodically1.2].

monitoring data.

⚫

⚫

toEPA Class VI plus Subpart RR:

Protocol for AEOS:

Environmental Protection Agency (EPA)

Environmental Protection Agency (EPA)

Quantification Protocol for EOR for AEOS7

Class II5 plus Reporting via Subpart RR6Class VI5 plus Reporting via Subpart RR6(Alberta Emission Offset System)⚫

Subpart RR requires:➢reflect⚫

Delineate

themonitoringarea

maximum–thearea

Subpart RR requires the same as on⚫

the left.
⚫

UIC

Class

Establish

aassessmentVI

has

itswillallowforthorough risk management throughoutandphase CO2 plume until injectedassessment and mitigation as follows:

response plans to stop or control

CO2 is not expected to migrate in➢

5.4.1].

unintended CO2 emissions or leakage

the future in a manner likely toseismic history and a tabulation

Develop a catalog of wells penetrating(F. Participation requirement).

result in surface leakage orof all wells within the area of

Perform an environmental and socio-release [§ 98.448].

review [§ 146.82];

reviews new and existing wellbores

Identify all artificial penetrations

within 1.6 km beyond the CO2 fluid

maximumthat may penetrate the confining

plume to assess for and manage risks

monitoring area and assess thezone and either confirm thatover the life of the CO2-EOR storage

potential storage failure scenarios,

likelihood, magnitude, and timing,

those have mechanical integrity ifapproval.

considering a range of uncertainty forof

CO2

operational or have been properlyparameters and site characteristics

through[§plugged. Corrective action must

metres of a proposed injection well

[ACR 5.4.1.1].

98.448].

be performed on any artificial

may need to be abandoned as per

penetrations that could serve as

Directive 020.

leakagepathwaysandremediate

wherepossible

[ACR⚫

⚫

Developremedial

measuresmonitor wells with leakage potential

economic

impactassessment,[ACR 5.4.1.2].

periodically

updatedtoUndertake a simulation study ofmonitoring data.

reflect➢

Identify potential surface leakage
pathwaysinsurfacetheleakagetheseofpathways➢

Prepareinformation

tothatrisk

requirements

Identify

relevant

original

site-specificexpected to contain the freeat or near the injection zone; repair or⚫

updatedEPA Class II plus Subpart RR:

onrisk➢storage and remediation strategies incase of loss of containment.
⚫

⚫

⚫

A wellbore risk assessment that

Any high-risk offset wells within 100

A hazard assessment evaluating thepotential for induced seismicity within

data collected [§146.84 c];the maximum CO2 plume extent andTake into account any geologic

the applied for CO2 EOR storage

heterogeneities,scheme approval area.

othertheir possible impact on model
predictions [§146.84 c]; andConsider

potential

migration

through faults, fractures, andartificial penetrations [§146.84 c].

1assess the risks associated withBe based on detailed geologic

discontinuities, data quality, and➢⚫

theleakage pathways [§ 146.84 c].
➢the life of scheme approval,

別添 3：CO2-EOR を CO2 削減措置と位置付ける各種制度における技術的要求事項
Pre-Injection⚫

Characterizationand Monitoring

Operator has the option to decide if⚫

pre-injection data is needed [5.4.1.3].
⚫

⚫

Storage volume expected to contain

Performmonitoring

toestablish⚫

baseline data.
⚫

Assessall

Subpart RR requires:➢knownandinferredDefine⚫

strategyforsetting

Subpart RR requires the same as on⚫

Satisfy the following requirements as

the left.

defined in Directive 065: Containment

UIC Class VI requires to define AoR

Assurance,Safety,leakage [§ 98.448].

based on computational modeling that

Suspension&Define strategy for detecting andaccounts

Reporting.

monitoring baselines for surface

⚫

Well

CO2, plume extent and duration ofstructures within the injection and capplume migration must be assessed via

rock formations for risk of migration of

the use of a reservoir model and flow

injected CO2 via a 3D reservoir model

quantifying any CO2 surface

chemical properties of all phases

simulations [ACR 5.4.1.1].

(Appendix B).

leakage [§ 98.448].

present [§ 146.84].

project application should

UIC Class VI specify:➢Identify

leakagepathwaysand⚫

Assessinjected

CO2

fateand➢⚫

UIC Class II defines AoR by either the⚫

forthephysicalandremediate where possible. Operatormigration, with a particular focus on

Theis’s analytical equation or a fixedmust develop a detailed catalog ofvetting for risks of seepage to surface.

value greater than ¼ mile.

as defined in 146.86, which

UIC Class II requires:

includewells penetrating at or near the⚫

Developainjection zone and proceed to repair orpreparation,

monitor wells with leakage potential[ACR 5.4.1.2].

⚫

⚫

monitoring
wellplan,site⚫

therequirements

injection rates and pressures, O&M

inject into a formation separatedand cementing, and tubing andprotocols,

andfrom any USDW by a confining

packer [§ 146.86].

management of site closure based onzone that is free of known open

the results of the above fluid flow andsimulation study.

timingextensive

logging,faults or fractures within AoR withsampling,andtesting

cased and cemented (146.22).

requirements prior to injection

Appropriate logs and other tests

well operation as defined in [§matching and use the monitoring data

shall be conducted during the146.87].

to calibrate and update numerical

drilling and construction (146.22).

Describe the process for history➢

thestorage

capacity➢

develop models and execute
simulations to predict the extent
of the CO2 fluid plume,➢

predict the behaviour of thehydrocarbon-CO2 phase,

Detailed➢defineestimates and injectivity,

forgeneral well construction, casing➢

Abandonment,

In addition to the above, a CO2-EOR

Well construction requirements

Well construction designed toandconstruction,➢⚫

Integrity,➢confirm

thattheproposedscheme will perform effectively
and safely,➢establish

asite-specificrisk

assessment that will allow for

Under UIC Class VI, preparing 3D

thoroughmodels.

computational models is compulsory

throughout the life of scheme

Monitoring plan must be periodicallyto fulfil the requirements for theapproval,

updated to reflect the analysis of thedelineation of AoR and the risk

monitoring data.

assessment [§ 146.84].

⚫

➢

risk

management

establish baseline conditions todesignand

implementamonitoring program, and➢assess the risks associated withstorageandremediation

strategies in case of loss of➢During-Injection⚫

Monitoring

Use a fluid flow model to periodicallyIdentify monitoring technologies, location,compare material balances for fluids

and sampling frequency to enable:

implement an EPA-approved MRV

as observed and predicted [ACR

1. Assurance of environmental integrity

plan that includes the following five5.4.1.3].
⚫

Undertake a simulation study ofpotential storage failure scenarios,

Subpart RR requires to develop andmajor components [§ 98.448]:

and safety.
2. Detection and estimation of quantity of

1.

CO2 stored in site.

considering a range of uncertainty for3. Confirmation that injected CO2 isparameters and site characteristics

contained and behaving as predicted.

[ACR 5.4.1.3].

⚫

4. Detection

andestimationoftheDelineationofthemonitoringarea,⚫
⚫

Subpart RR requires the same as on

Conduct monitoring to:

the left.

⚫

UIC Class VI specifies:➢maximumandactive

Identificationofthepotential

surface leakage pathways and an2➢

Demonstratelegislation

The requirements for operational

directives),

injection pressure which shall notapprovals.

exceed 90 percent of the fracture

monitoring areas;2.

containment.

⚫

compliance(regulations,withstandards,applications

andMonitor for trigger events and, if

pressure of the injection zone(s)detected,[§ 146.88].

operating procedures in response.

The requirements for mechanicalemployassociated別添 3：CO2-EOR を CO2 削減措置と位置付ける各種制度における技術的要求事項⚫

Perform monitoring for the mostrate/mass of CO2 seepage either via

assessment of the likelihood,integrity of wells including theMonitoring technologies are evaluated on asensitive parameters as identified

cap rock, overburden and surrounding

magnitude, and timing of surface

demonstration of the absence ofregular basis

from the above study. Tools selecteddomains or via wells with potential forleakage of CO2 through thesesignificant

and sampling frequency must beleakage.

pathways;temperature or noise logging at

The MMV plan is periodically renewed andleast once per year [§ 146.89].

ongoing dialogue is held with the regulator

specified (justified) [5.4.1.3].
⚫

5. Monitoringmeasurementof

Select and locate (other) monitoring

relevant parameters of groundwaterequipment in a manner that provide

properties, soil and surface CO2

confidence

concentrations measurements, etc.

in

CO2

storageandidentify leakage. Establish reasonable[ACR 5.4.1.3].

3.

4.

5.

CO2 seepage.

Require the project-specific MRV planandbe developed by a professional [ACRobservation wells.

5.4.2].

fordetection

and➢through

The detailed requirements for

Approach for establishing thetesting and monitoring in [§expected baselines; and146.90].

Considerations made to calculate
site-specific variables for the

7. Measurement of temperature at the top
bottomStrategyquantification of surface leakage;

6. Timely remedial action in the event ofdetection thresholds for the equipment⚫

andleaksofinjection

andmass balance equation.
⚫

UIC Class II requires:➢8. Detection of corrosion or degradation

Operational injection pressure
whichof transport and injection facilities.

shallnotexceed

amaximum that does not initiate
newfractures

orpropagate

existing fractures (146.23).
➢

Monitoringofthenatureofinjected fluids and observation ofinjection pressure, flow rate, andcumulative volume at a minimum(146.23).
Post-Injection
Monitoring⚫

Minimum of 5 years of Post-⚫

Minimum of 20 years of Post-⚫

Subpart RR requires to develop andInjection. If no migration of theInjection. If no migration of theimplement an EPA-approved MRV

injected CO2 is detected and theinjected CO2 is detected and theplan as described above [§ 98.447].

modelled failure scenarios indicate

modelled failure scenarios indicatethat CO2 remains contained within thethat CO2 remains contained within thestorage volume, then it is consideredstorage volume, then it is consideredadequate

adequate

assurancethatnoassurance

that

⚫

⚫

Subpart RR requires the same as on⚫

the project operator to develop athe left.

termination plan for the CO2-EORUIC Class VI requires the default

project

UIC Class II has no description onvalue of 50 years of Post-Injection

termination.

Thispost-injection site care.

site care.

developedanyinjectionbegins,

⚫

➢

noThe

post-injection

sitecarethatspecifies
plantime
butcriteria

for

shall

beaftermust

CO2beperiod can be reduced upon adeveloped prior to the termination of
CO2 injection at the scheme.

atmospheric leakage has occurred.

atmospheric leakage has occurred.

showing

Otherwise, monitoring requirements

Otherwise, monitoring requirements

monitoring and other site- specificwill be extended in 2 year increments

will have to be extended in 10 year

data,

until no leakage is assured [ACRincrements

sequestration project no longer

5.4.1.4].

assured.

poses

Monitoring is for the same parameters

USDWs," and the period will befacilities and perform all closure

described for “During Injection”.

extended if that demonstration

activities in accordance with theAn evaluation must be performed incannot be made even at the end

regulations.

the event of seepage to determine theof 50 years [§ 146.93].

⚫
⚫

until

noleakage

is3

that
that
an"based
theon⚫

geologicendangerment

toRegulatory

Framework

Assessment recommend minimum
10 years8⚫

⚫

Continue to monitor all wells andArrangements are made between the別添 3：CO2-EOR を CO2 削減措置と位置付ける各種制度における技術的要求事項
quantity of seepage for compensation➢purposes.

Specific monitoring methods andregulator and project operator for thetools should be site specific andtransfer of any MMV monitoring

designedfollowing

equipment that the regulator requests

objectives: 1) verify plume is

to be left in place at the point of closurestabilizing and pressures arethat will not compromise long-term

equilibrating and 2) detecting

integrity of well abandonments.

forthepotential leakage [§ 146.93].
Reporting/⚫

Accounting

ACRdetails

toSubpart RR requires facilities to collectbaseline

include an accounting for all GHG

quarterly data and submit annual reports

emissions, project emissions, andemissions as a part of the baselineon the annual amount of CO2 sequestered.

Documentation for the Baseline condition

emission reductions in Equations 4.1

assessment

monitoring.

The mass balance equations RR-11 or RR-requires

to 4.3 [ACR, 4.1~4.3].

Verification will be achieved by history

12 (EPA, 2010) are used to calculate theDocumentation for the Project condition

Require the project-specific MRV planmatching

necessary,amount of CO2 that is reported as

be developed by a professional [ACR

updating the numerical models usedsequestered and accounts for quantity of5.4.2].

to characterize the geological storage.

CO2 in emissions, the produced gas, theThe numerical models will be adjusted

quantity remaining in the oil and gas, andtofinally the total quantity sequesteredequations⚫

tothemethods

quantifyand⚫

Determine

project

betweenandand,address

boundaries

wheresignificantobservedanddeviations⚫

Subpart RR requires the same as onDocumentation

requirements

the left.

emission offset project

predicted

behavior

References1.

Congressional Research Service (CRS). Carbon Storage Requirements in the 45Q Tax Credit. (2021).

2.

Gupta, N. & Cumming, L. United Mexican States MX TF Carbon Capture, Utilization and Storage Development in Mexico: Combining CO2 Enhanced Oil Recovery with Permanent Storage in Mexico. 89 (2016).

3.

American Carbon Registry. Methodology for the quantification, monitoring, reporting and verification of greenhouse gas emissions reductions and removal from carbon capture and storage projects. Version 1.1. 1–75 (2021).

4.

UNFCCC, FCCC/KP/CMP/2011/10/Add.2, Decision 10/CMP.7, Modalities and procedures for carbon dioxide capture and storage in geological formations as clean development mechanism project activities (2011).

5.

Environmental Protection Agency. 40 CFR Part 146 Underground Injection Control Program: Criteria and Standards. https://www.ecfr.gov/current/title-40/chapter-I/subchapter-D/part-146?toc=1 (2022).

6.

Environmental Protection Agency. 40 CFR Part 98 Subpart RR Geologic Sequestration of Carbon Dioxide. https://www.ecfr.gov/current/title-40/chapter-I/subchapter-C/part-98?toc=1 (2022).

7.

Alberta Energy. Quantification Protocol for Enhanced Oil Recovery. Version 2.0. (2022).

8.

Alberta. Alberta Energy. Summary Report of the Regulatory Framework Assessment. 36th Annual International Pittsburgh Coal Conference: Clean Coal-Based Energy/Fuels and the Environment, PCC 2019 (2012).

4forthe