SECTION 5.305. Monitoring, Sampling, and Testing Plan  


Latest version.
  • An operator registering for certification under this subchapter must submit a monitoring, sampling, and testing plan to verify geologic storage of the anthropogenic CO2 incidental to enhanced recovery.

    (1) The monitoring, sampling, and testing plan must include the following:

    (A) an analysis of the CO2 stream at a frequency sufficient to yield data representative of its chemical and physical characteristics;

    (B) installation of continuous monitoring devices (including digital devices to capture periodic data) to monitor injection pressure, rate of injected CO2, and volume of injected CO2. The operator shall perform monitoring of daily pressure on the annulus between the tubing and the long string casing by use of either continuous monitoring device or by using a pressure gauge with a rupture disk with automated alarm to signal pressures outside of the permitted operating range. The operator may remove these devices during well workovers but must reinstall them at the completion of the workover; the Commission may approve alternative methods of monitoring the annulus between the tubing and long string casing when considering injection well construction, operating pressures, and the oil and gas reservoir;

    (C) demonstration of external mechanical integrity by one of the following, or another approved, method: oxygen-activation log survey, temperature log, noise log, or casing inspection log if the operator detects a problem, or once every five years, until the well is permanently plugged;

    (D) corrosion monitoring of the well materials that will come into contact with water for loss of mass, thickness, cracking, pitting, and other signs of corrosion. The operator shall perform corrosion monitoring at one or more designated representative test sites typical of the enhanced recovery facility initially and quarterly, and the operator shall report quarterly, but may be modified to a less frequent schedule as approved by the Commission, based on the construction materials, operating conditions, and monitoring history that show the well components meet minimum standards and performance by:

    (i) analyzing coupons of the well construction materials placed in contact with the CO2 stream; or

    (ii) routing the CO2 stream through a closed loop constructed with the material used in the well and inspecting the material in the loop; or

    (iii) using an alternative method, materials, or time period approved by the Commission;

    (E) annual monitoring of the injection zone pressure in the productive reservoir, including at a minimum, at least once every five years, a shut-down of each injection well for a time sufficient to estimate reservoir pressure at the site;

    (F) monitoring wells as needed for continuous monitoring for pressure changes in an appropriately porous and permeable formation above the confining zone. For each well installed, the operator must set forth the specified frequency of sampling the interval and analyzing the constituents as specified in the plan;

    (G) periodic monitoring of the useable quality water strata overlying the productive reservoir to monitor for changes in quality due to CO2 injection; and

    (H) the use of indirect, geophysical techniques to determine the position of the CO2 fluid front, or to provide other site-specific data.

    (2) For an operator to make a determination by mass balancing or actual system modeling of the quantities of anthropogenic CO2 permanently stored within the enhanced recovery reservoir for documentation to the Commission, the testing, monitoring, and reporting plan must:

    (A) be based upon a site-specific assessment and may include monitoring wells or other monitoring devices to ensure that the injected anthropogenic CO2 is confined to the productive reservoir; and

    (B) include a methodology for accounting for the following:

    (i) the volumes of anthropogenic CO2 injected into the productive reservoir;

    (ii) the anthropogenic CO2 separated from the enhanced recovery production;

    (iii) the anthropogenic CO2 entrained in the production;

    (iv) the volume of produced anthropogenic CO2 recycled for injection into the reservoir;

    (v) any de minimis losses of anthropogenic CO2; and

    (vi) the volume of make-up anthropogenic CO2 injected to the enhanced recovery project.

    (3) Any person registering an enhanced recovery facility under this subchapter may comply with the sampling, monitoring, and reporting requirements of this subchapter by complying with, and submitting to the Commission a copy of the information submitted to the United States Environmental Protection Agency under, Subparts RR or UU of 40 CFR Part 98, Mandatory Reporting of Greenhouse Gases: Injection and Geologic Sequestration of Carbon Dioxide.

Source Note: The provisions of this §5.305 adopted to be effective July 17, 2011, 36 TexReg 4397