Regulatory and Social Aspects Related to Well Re-Use in CO2 Storage Operations
12 Pages Posted: 28 Nov 2022
Date Written: August 30, 2022
Abstract
Reusing hydrocarbon fields and wells for CO2 storage could mean substantial savings and a potential acceleration in the deployment of CCS (Carbon Capture and Storage) technology. In addition to the technical suitability of the wells to be re-used for CO2 injection, the existence of a coherent regulatory framework to enable well re-use and stakeholder and public acceptance are essential for the implementation of real projects. Within the REX-CO2 project, the legal, environmental and social aspects related to well re-use in CO2 storage operations have also been investigated. Following an extensive data collection of all relevant regulations, we have made a first assessment of the regulatory frameworks for well re-use in the respective project partner countries (Netherlands, Norway, US, UK, France and Romania). Our assessment indicated that in the six participating countries, with the exception of the US, very little has been regulated specifically for the re-use of existing well infrastructure for CO2 storage operations, even though specific regulations for storage exists. In the US, the Underground Injection Control (UIC) program’s Class VI well regulations identify requirements for converting an existing oil and gas well into a well suitable for use at a CO2 storage site. Based on the initial assessment of regulatory frameworks, we have also made a comparative analysis which highlighted some points of special interest to be evaluated to enable reuse in the current legislation. These refer to transition from hydrocarbon production to CO2 storage (procedure for postponing decommissioning wells, simultaneous hydrocarbon production and CO2 storage, arrangements during mothballing/hibernation), hibernation/temporary abandonment of wells for further re-use (rules for mothballing and hibernation of wells, ownership of wells and costs), specific permitting for well re-use (rules for permitting, monitoring and testing) and policies for well re-use (promoting of well re-use and incentivization). The identified points of interest and periodic consultations with regulators and industry have been used to formulate several recommendations for potential improvement of current legislation to enable well re-use in CO2 storage operations. The first key recommendation is that regulators and governments should assume the role of actively minimizing and mitigating the risk of a gap occurring between hydrocarbon and CO2 storage operations and thus maximizing the potential re-use of oil and gas infrastructure for CCS. Another recommendation is that governmental bodies should supervise and stimulate the inventories of promising options for CO2 storage (e.g. national storage atlases) in order to avoid decommissioning of key assets in these areas. Furthermore, governments should support more open access to data required to identify potentially suitable sites and conduct re-use assessments. Apart from the regulatory framework analysis, we have also made an initial, first-of the kind assessment of the stakeholder and public perception and acceptance relating to re-use of wells for CO2 storage in the partner countries. This assessment was made through a survey reaching 333 respondents; predominantly stakeholders with some knowledge of CCS and targeted groups established at national level by the REX-CO2 project team. The general perception and attitudes of the survey participants towards CCS and re-use of wells for CO2 geological storage were positive. The overall survey trends were also visible at the national level with some minor deviations highlighted in the comments received. The main concerns raised by the respondents relate to the capacity of depleted hydrocarbon reservoirs to permanently store CO2 (France), the risk of leakage (the Netherlands) and the inadequacy of old wells in CO2 injection operations (Romania). The results of the survey and the past experiences from CCS projects were used to provide some guidance on the communication strategies to be implemented for future projects involving re-use in CO2 geological storage.
Keywords: CO2 geological storage, well reuse, reglatory framework, permitting, stakeholder and public acceptance
JEL Classification: K33
Suggested Citation: Suggested Citation