Subject: Comments to the Draft Specifications for Application of UNFC-2009 to Injection Projects for the Purpose of Geological Storage: from Statoil
15 September 2015
Using and adapting the UNFC-2009 for Injection projects is a good approach and connects the different areas in a good way. It is however just beginning to set out the framework for storage. This is done in parallel to many other activities. Since this is an area under development the document should stay in “evolutionary” and “advisory” mode and recognize that the topic of regulating geological storage is maturing in numerous domains globally (EU-directive, US-EPA and other national and international efforts). Here ISO should be mentioned especially. The latter also leads to the subject of EOR mentioned in III A-20. It is a demanding task to include CO2EOR as part of a storage activity. There are lots of legal issues to be addressed, but CO2EOR can act as an enabler for the infrastructure and economic viability of a storage project and thus fit into the categories described in the document.
Reference to the footnote p3: “There is currently a lack of consensus in the Task Force on UNFC-2009 and Injection Projects for applying the term Storage Potential to all injection projects, including the most mature projects. The Task Force is continuing its work on finding an alternative term that better describes all levels of project maturity”. Since the term “storage potential” is already much debated, we are concerned that including hydrogen and gas storage in the same definition as CO2 storage potential could be tricky. Our advice would be to defer this discussion until the technology is more mature, and rather to focus on stimulating pilot and demonstration geological storage projects to promote maturation of this technology globally.
Comment from Statoil to the Draft Specifications for Application of UNFC-2009 to Injection Projects for the Purpose of Geological Storage.
15 September 2015
Using and adapting the UNFC-2009 for Injection projects is a good approach and connects the different areas in a good way. It is however just beginning to set out the framework for storage. This is done in parallel to many other activities. Since this is an area under development the document should stay in “evolutionary” and “advisory” mode and recognize that the topic of regulating geological storage is maturing in numerous domains globally (EU-directive, US-EPA and other national and international efforts). Here ISO should be mentioned especially. The latter also leads to the subject of EOR mentioned in III A-20. It is a demanding task to include CO2EOR as part of a storage activity. There are lots of legal issues to be addressed, but CO2EOR can act as an enabler for the infrastructure and economic viability of a storage project and thus fit into the categories described in the document.
Reference to the footnote p3: “There is currently a lack of consensus in the Task Force on UNFC-2009 and Injection Projects for applying the term Storage Potential to all injection projects, including the most mature projects. The Task Force is continuing its work on finding an alternative term that better describes all levels of project maturity”. Since the term “storage potential” is already much debated, we are concerned that including hydrogen and gas storage in the same definition as CO2 storage potential could be tricky. Our advice would be to defer this discussion until the technology is more mature, and rather to focus on stimulating pilot and demonstration geological storage projects to promote maturation of this technology globally.
Comment from Statoil to the Draft Specifications for Application of UNFC-2009 to Injection Projects for the Purpose of Geological Storage.