S. Carpenter - Geologic Storage Standards, Legislation and Regulation: Developments and Implications...

7/28/2019 S. Carpenter - Geologic Storage Standards, Legislation and Regulation: Developments and Implications for Commercial Deployment

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Steven M. Carpenter, VP

Advanced Resources International, Inc.

Geologic Storage Standards, Legislation and

Regulation: Developments and Implications forCommercial Deployment

RECS Monday, June 24th, 2013


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This presentation is based upon work supported by the Department of EnergyNational Energy Technology Laboratory under DE-FC26-05NT42590 and wasprepared as an account of work sponsored by an agency of the United StatesGovernment. Neither the United States Government nor any agency thereof, norany of their employees, makes any warranty, express or implied, or assumes any

legal liability or responsibility for the accuracy, completeness, or usefulness of anyinformation, apparatus, product, or process disclosed, or represents that its usewould not infringe privately owned rights. Reference herein to any specificcommercial product, process, or service by trade name, trademark, manufacturer,or otherwise does not necessarily constitute or imply its endorsement,recommendation, or favoring by the United States Government or any agency

thereof. The views and opinions of authors expressed herein do not necessarilystate or reflect those of the United States Government or any agency thereof.

Acknowledgement


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Workshop = participation Feel free to move around = be

comfortable Interrupt me when needed This is about you! Planned discussion points

Order of the Day


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Regulations: CWA, USDW, UIC (Class II, V, & VI) CAA, EPA MRR Best Available Control Technology (BACT)

Standards: Z-741: Geological storage of carbon dioxide ISO TC-265: Carbon dioxide capture, transportation, and geological

storage

Examples: What does an actual Class V permit look like?

What does an actual MRR submittal look like?

Legislation: Does EPA consider CO2 as a hazardous waste? How is permanent storage defined?

What we plan to cover


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CCS Roadmap is COMPLEX


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CWA, USDW, UIC Class II, V, & VI What does an actual Class V permit look like? Lessons learned from our permit

CAA, EPA Mandatory Greenhouse Gas ReportingRule (MRR)

Subparts A, C, W, FF, RR, & UU What does an actual MRR submittal look like?

Best Available Control Technology (BACT) analysisof CCS

Regulation = Permitting


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Clean Water Act the CWA establishes the basic structure forregulating discharges of pollutants into the waters of the US. In 1948,

the Federal Water Pollution Control Act, reorganized in 1972 tobecome CWA

Underground Source of Drinking Water (USDW) An aquifer or portion of an aquifer that supplies any public watersystem or that contains a sufficient quantity of ground water to supply

a public water system, and currently supplies drinking water forhuman consumption, or that contains fewer than 10,000 mg/l total

dissolved solids and is not an exempted aquifer.

Underground Injection Control - Is responsible forregulating the construction, operation, permitting, and closure ofinjection wells that place fluids underground for storage or disposal.Wells are regulated into one of 6 classes or categories of wells.

CWA, USDW, UIC


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UIC Class I Well Disposal

Hazardous Waste Disposal Wells under RCRA ,operating in 10 states, approximately 20% of wells

Non-Hazardous Industrial Waste Disposal Wells,

operating in 19 states, approximately 50% of wells

Municipal Wastewater Disposal Wells, with muchlarge diameter (up to 36 inches) casing and rely ongravity for injection, approximately 30% of wells.

Radioactive Waste Disposal Wells, used to injectwaste which contains radioactive material below the

lowermost formation containing a USDW. There are 0known radioactive waste disposal wells operating in theU.S.


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Enhanced Recovery Wells approximately 80% - 151,000 wells

Brine & Fluid Disposal Wells approximately 20% wells

Hydrocarbon Storage Wells inject liquidhydrocarbons in underground formations(such as salt caverns) where they arestored, generally, as part of the U.S.Strategic Petroleum Reserve. There are

over 100 liquid hydrocarbon storage wellsin operation.

UIC Class II Wells Oil & Gas


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Class III mining well - inject fluidsto dissolve and extract mineralssuch as uranium, salt, copper, andsulfur.

50% of salt 80% of uranium Approximately 165 mining sites Approximately 18,500 wells

UIC Class III Wells - Mining


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Class IV wells are shallow wellsused to inject hazardous or

radioactive wastes into or above a

geologic formation that contains a

USDW. In 1984, EPA banned the use of

Class IV injection wells

32 waste clean-up sites with Class IVwells in the United States, as part of

EPA authorized clean up.

UIC Class IV Wells Shallow


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>20 well subtypes that fall into Class V Approximately 650,000 Class V wells

in operation nationwide

Includes storm water drainage wells,cesspools, and septic system leachfields

More complex & sophisticated wellstypically deeper and include aquiferstorage, recovery wells, geothermalelectric power, and pilot orexperimental geologic sequestration(GS) projects

UIC Class V Wells various

D 4-14 Observation Wellbore


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Used for injection of CO2 forcommercial storage

Currently NO Class VI wells Required MRV plans to address:

the relative buoyancy of CO2 mobility in the subsurface corrosivity in the presence of water large anticipated CO2 volumes

UIC Class VI Wells Com CCS


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EPA GHG MRR

Legal & Regulatory Framework

Title V of the CAA 40 CFR part 75 Acid Rain Program Any electric generation over 25 MW CEMs for NOx, SO2, and CO2If these, then EPA MRR e-GGRT

Subparts A, D, and possibly W, FF, HH, RR, & UU


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Industries affected by MRR

Electricity generation (D) Adipic acid production Aluminum production Ammonia manufacturing CCS Projects (RR, UU) Cement production HCFC-22 production HFC-23 destruction processes Industrial Waste Landfills Industrial WWTP Lime manufacturing Magnesium production Manure systems

Natural Gas Production (W) Nitric acid production Petrochemical production Petroleum refineries Phosphoric acid production Silicon carbide production Soda ash production Suppliers of NG (NN) Suppliers of Industrial GHG (OO)

Suppliers of CO2(PP) Titanium dioxide production Underground Coal Mines (FF)


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Mandatory GHG Reporting Rule


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Electric Signature and Authorization

1. ~ 1 week to process2. Snail Mail3. Maintain email


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Register facility (one per address)


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Certificate of Representation

AstheDesignated

Representa0ve(DR)

orAlternateDR,

Icer0fythat


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I certify that I was selected as the designated representative oralternate designated representative, as applicable, by an agreementbinding on the owners and operators of the facility or supplier, asapplicable.

I certify that I have all the necessary authority to carry out myduties and responsibilities under 40 CFR Part 98 on behalf of the

owners and operators of the facility or supplier, as applicable, andthat each such owner and operatorshould be fully bound by myrepresentations, actions, inactions, or submissions.

I certify that the owners and operators of the facility or supplier, asapplicable, should be bound by any order issued to me by theUSEPA Administratoror a court regarding the facility or supplier.

If there are multiple owners and operators of the facility or supplier,as applicable, I certify that I have given a written notice of myselection as the designated representative or alternate designatedrepresentative, as applicable, and of the agreement by which I wasselected to each owner and operator of the facility or supplier."

Designated Felon


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Illustrative Representation of Requirements

MRR Reporting Requirements


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MMR RR Monitoring (MRV) Plans

Required for RR projects Unclear if they are required for R&D exemption projects

(we submitted one for the SECARB Test)

Should complement Class VI UIC MVA plan Required components:

Delineation of the maximum monitoring area (MMA) Delineation of the active monitoring areas (AMA) Identification of potential surface leakage Surface leakage detection strategy Surface baseline monitoring strategy Well ID number(s) Date to begin collecting data


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MMR RR Monitoring (MRV) Plans

A list of all units, operations, processes, and activities The data used to calculate the GHG emissions Identify surface leakage pathways (EOR focus: legacy wells) Baseline measurements (pre-injection conditions) Calculation methodologies and accounting (2012 CBI rule) Continue Post Injection Monitoring Until No Leakage Risk The Annual GHG reports Retained record for any missing data Certification & QA/QC data of instrumentation 3 years of post-injection monitoring


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Schedule and Timing

January 1: Register facilit(ies)

March 31: Data reporting previous year

April 1: GHG Monitoring or QA/QC Plan:

Identification of responsibilities (i.e., job titles) for data collection Explanation of processes and methods used for data collection Describes QA/QC procedures Existing corporate documents (e.g., SOPs) Yearly revision to the Plan to reflect changes in processes Upon request make available for audit


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Submit data electronically

Submitdata


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Subpart RR Exemption Requests

To date, 4 R&D exemptions have been granted:

No RR Facilities have reported

ADM/MGSC Class I AEP/EPRI Class V Boise/BSCSP Class V Southern Co Class V


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Best Available Control Technology

All OPTIONS WITH PRACTICAL POTENTIAL


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Best Available Control Technology(BACT) 5 Step Process:

Step 1: ID all available technologies Step 2: Eliminate technically infeasible options Step 3: Rank remaining technologies Step 4: Evaluate most effective controls Step 5: Select BACTs

New Source Review, Prevention ofSignificant Deterioration & Title V:


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After January 2, 2011 BACT must address GHGs WHIJTCCS defines, and EPA considers CCS as

an available add-on technology,THEREFORE:

Must include in Step 1 Analysis: Identify May exclude in Step 4 Analysis: Evaluate In either case, CCS clearly warrants a

comprehensive consideration and a detailedcase-specific analysis needed to dismiss

Best Available Control Technology (BACT)


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What is happening to CCS under BACT

Immediately dismissed due to economicconsiderations

Immediately dismissed due to technologicalconsiderations

Immediately dismissed due to deploymentissues

Immediately dismissed due to uncertain regulatoryissues

What is happening to CCS under BACT


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What is expected under BACT is

Preliminarily evaluation of CO2 source Preliminarily evaluate of CO2 sink capacity Evaluate the regulatory status in the jurisdiction Only then, make a decision about CCS applicability

New Source Review, Prevention ofSignificant Deterioration & Title V


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CO2 under BACT

EPA CCS rule to White House (OMB) for review: EPAs rules would exclude CO2 as Hazardous Waste Proposed in August 2011, OMB has 90 days to review By announcing the proposed rule, the EPA has determined

that geological sequestration does not present a substantialrisk to people's health or the environment

EPA also says injecting carbon dioxide into the ground haslong been used for producing gas and oil in so-calledenhanced recovery techniques. Long-term undergroundstorage, however, raises a host of new issues, partlybecause it would potentially involve much larger

quantities of carbon dioxide EPA CCS rule could cap CO2 emissions at 1,000 pounds CO2/

MWh

To date EPA has received more than 3,000,000 comments onthe rule


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Integration Communication is Key!


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What are standards? Best Practices Z-741: Geological storage of

carbon dioxide

ISO TC-265: Carbon dioxidecapture, transportation, andgeological storage

Standards


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Standards, by themselves, do not have the force oflaw unless officially adopted by a regulatoryauthority.

Regulatory authorities can(should) adoptStandards with certain exceptions or additionalrequirements

recommended that the regulatory authority of therelevant jurisdiction be consulted

Where this Standard conflicts with regulatoryrequirements, the regulatory requirements will(shall) take precedence.

Standards a go-by


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reliable and consistent standards

essential forproviding the basis for a legal and regulatoryframework and encouraging widespread global CCSdeployment:

MVA

Public Outreach Geologic Storage Formation Classification Site Selection, Screening, & Characterization Risk Analysis & Simulation

Best Practices a stronger go-by


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Clean Development Mechanism, established underthe Kyoto Protocol

Managed by the United Nations FrameworkConvention on Climate Change (UNFCCC)

Primary International Offset Program for GHGreduction in developing countries

Generates Certified Emission Reductions (CER) orcarbon credits = financial mechanism for

implementation

What is a CDM?


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Afforestation Electric generation fuel switching SF6 emission reductions Landfill methane (CH4) collection CMM & VAM Manure management CCS (recently added)

Types of CDM Projects


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Z-741 Kills 2 Birds with 1 Stone


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World's first formally recognizedCCS standard Geologic Storage

International Standards Organization - 31000,17024, 14064, 14065

International Performance Assessment Centrefor Geologic Storage of CO2 Seed document

Canadian Standards Association - ISOSecretariat, standards developer

Bi-national agreement between USA & Canada


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Brings together 2 nations, multiplestakeholders


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Reference Publications Management Systems Site Screening, Selection &

Characterization Risk Management Site & Well Development Monitoring & Verification (MVA) Closure

TOC and Working Groups


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Must INCLUDE any and all

UNFCCC - IPCC ISO EU European Directives CSA DOE WRI IPAC-CO2 Federal, Provincial, State regulations Future expected directives


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40 people, beer, pizza & hockey

40 = 52 = 47

Game 7 Boston (US) v.Vancouver (CAN) in a bar


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International Organization for Standardization(ISO) Technical Committee TC-265

Title: Carbon dioxide capture, transportation,and geological storage

Acceptance of Z-741 by Standards Council ofCanada and American National StandardsInstitute (ANSI) is seed document for

TC-265 26 countries participating and NGOs

Why not take on the World?


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Twined Secretariat: Canada & China

Participating Countries: Observing Countries:

o Australiao Canadao Chinao Franceo Germanyo Italyo Japano South Koreao Netherlandso Norwayo

South Africao Spaino Switzerlando United Kingdomo United States

o Argentinao Brazilo Czech Republico Egypto

Finlando Indiao Irano New Zealando Serbiao Swedeno United StatesNGO/Liaison:o GCCSIo IEAGHGo WRIo others

No in 2012

Yes in 2013


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CSA is the Mirror Committee


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Capture: led by Japan, will focus largely on post-, pre-and oxyfuel combustion capture processes

Transportation: let by Germany, will focus onpipelines not currently covered by existing ISO/TC-67

standards Storage: split leadership with Canada focusing on

onshore and Japan focusing on offshore.

Quantification and verification: split leadership withChina leading the group and support provided byFrance

Cross-cutting issues: has split leadership withFrance leading the group supported by China

5 Working Groups


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Select US Head of Delegation (HoD) for USTechnical Advisory Group (TAG) TC-265

General call for technical and subject matter expertsto join the five working groups

Select Working Group Leaders for the 5 WG Countries that are voting or P-member nations may

identify and add technical experts to all committees

Populate Capture, Transportation, Storage,Quantification and Verification, and Cross-cuttingworking group to address issues

Next Steps


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Perpetual Event Horizon

Sequestration to Storage; CCS to CCUS MMV to MRV to MVA Perpetual Event (Time) Horizon

Sequestration requires 00s & 000s years monitoring, verification and reporting

Perpetual Event Horizon WILL outlast: Risk & Financial models Companies who placed the CO2 Companies who manage the CO2


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Carbon Pricing 10 to $80 Liability: Price-Anderson Act Indemnification Insurance products Preemption state & local v. federal Lack of success

Other Wild Cards


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AEP Mountaineer

Poster-child for success; CCPI, RCSP funded Pilot successful NO LONGER IN OPERATION


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Dominion VCHEC

CCPI, RCSP not funded

NO CCS


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Office Locations

Washington, DC

4501 Fairfax Drive, Suite 910Arlington, VA 22203Phone: (703) 528-8420

Fax: (703) 528-0439

Houston, TX11931 Wickchester Ln., Suite 200Houston, TX 77043

Phone: (281) 558-9200Fax: (281) 558-9202

Knoxville, TN603 W. Main Street, Suite 906

Knoxville, TN 37902Phone: (865) 541-4690Fax: (865) 541-4688

Cincinnati, OH

1282 Secretariat CourtBatavia, OH 45103Phone: (513) 460-0360

Email: [email protected]

http://adv-res.com/

Thank you!


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Back up and Supporting Slides


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Advanced MRV Technology:CCP Modular Borehole Monitoring

Cintronelle / Plant Barry project CCP, EPRI Southern Co, SECARB cooperators Goal: a "rugged" modular multi sensor CO2

monitoring system in small diameter but deepwells.

Semi-permanent flat sensor string including fiberoptic cable and sample tubing down the annulusbetween the long string casing and injectiontubing and right through the packer into theinjection zone.

Can determine plume location with geophonearray; Crosswell, offset VSP, walk-away VSP.

Reservoir pressure & T using quartz P/T sensors Heat-pulse monitoring =/- 0.1 deg C

sensitivity leak detection / flow monitoring Fluid sampling via U-tube.

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EXAMPLE APPLICATIONS

Coal vs. NG Water cooling vs. air cooling Simple cycle vs. combined cycle California Renewable Portfolio Standards CCS and international standards


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Proposed NG Gas Plant May SetTighter GHG BACT Permit Precedent

The BACT for GHG emissions for the AESproject is a rate of 1,082 pounds of carbondioxide per megawatt hour (CO2/MWhr) of grossenergy output, and a total annual CO2 emissions

limit of 3,161,785 metric tons per year.

By comparison the average emission rate forNG fired power is 1,135 lbs of CO2/MWh

By comparison the average emission rates forcoal fired power 2,249 lbs of CO2/MWh


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A simple-cycle plant, which does not include theheat-recovery steam generators, would result inmore GHG emissions

Simple-cycle vs. combined-cycle turbinesystems has emerged as a key issue in GHGpermits

Wisconsin officials rejected a request by EPARegion V to consider mandating more efficientcombined-cycle gas turbines in a final GHGpermit due to space (air cooled) issues


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EPA Region IX approved a simple-cycle system forthe Pio Pico Energy Center "peaking" power plant inCA

AES Huntington Beach project, planned at two moreAES facilities in the coming months, could set a newGHG emissions or energy efficiency threshold EPAor local regulators must follow for future proposals

AES PSD permit application with the South CoastAir District ALSO must contain renewable power at a

significantly higher energy efficiency rate, helpingutilities achieve Californias stringent renewableportfolio standard (RPS) with fewer GHG emissions


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This may mean that ALL future BACTconsiderations:

Be required to meet enlarged size (footprint)restrictions of air cooled turbines

Be required to meet non-peaker GHGemission rate for peaker designed plants(fast-ramp, fast-start, and ramp-down)

Be required to meet California's RenewablePortfolio Standards (RPS)


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CPUC denies PPA to Pio Pico

CaliforniaCommissionQuashes2SanDiegoGasPlantsbyChrisClarkeonMarch21,2134:9PM,KCET.org

TheCaliforniaPublicU0li0esCommission(CPUC)haslikelymadesomeSanDiegoCountyresidentsveryhappytodaywithadecisionnottoallowSanDiegoGas&Electric(SDG&E)tobuypowerfromthecontroversialproposedPioPicoEnergyCenterandQuailBrushPowergas-firedpowerplants.

TheplantswereslammedearlierthismonthbytheSierraClub,whichratedthepairofproposalsasthesecond-mostwastefulu0lityprojectsinthestate.Ifbothhadbeenbuilt,accordingtotheSierraClub,thestate'sratepayerswouldhaveseenacumula0ve$2billionaddedtotheirpowerbills.

S0ll,it'sgottobegra:fyingtothosewhoopposedtheplantstohearthe

CPUCdenythepowerpurchaseagreementsinlanguageremarkablysimilartothatopponentshadused.

UnderBACTwithinclusionofCCScostswillincrease Giventhisscenario,permitapprovaldoesnotlooklikely


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Injecting Tracer for Monitoring

500 milliliters ofperfluoro-trimethylcylclohexane(CF

3)3C

6F

9 Injected over a

12-hour period byDOE

1-week afterstarting the CO2injection

S. Carpenter - Geologic Storage Standards, Legislation and Regulation: Developments and Implications...

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