Geologic Sequestration Data System (GSDS) Status of Development

Transcription

1 Geologic Sequestration Data System (GSDS) Status of Development Joe Tiago, U.S. EPA Ground Water Protection Council (GWPC) Houston, TX January 24, 2012

2 Purpose Describe the process and status of GSDS development including: Joint Requirements Planning (JRP) Alternatives Analysis (AA) U.S. Environmental Protection Agency 2

3 Outline 1. Background information on GS and the Class VI Rule 2. Overview of the GSDS A. GS data B. GSDS development process C. Joint Requirements Planning (JRP) D. Alternatives Analysis (AA) 3. Next steps U.S. Environmental Protection Agency 3

4 What is GS? How are GS projects regulated? 1. BACKGROUND ON GS AND THE CLASS VI RULE U.S. Environmental Protection Agency 4

5 1. Background GS Projects Underground injection of CO 2 for purposes such as enhanced oil or gas recovery (EOR/EGR) is a long-standing practice However, CO 2 injection specifically for GS involves: Different technical issues Potentially much larger volumes of CO 2 Potentially larger-scale projects Image: Los Alamos National Laboratory. U.S. Environmental Protection Agency 5

6 1. Background Regulating GS On December 10, 2010, EPA published: The Federal Requirements under the Underground Injection Control (UIC) Program for Carbon Dioxide Geologic Sequestration (GS) Wells ( the Class VI Rule ) These minimum requirements: Focus on USDW protection under the authority of Part C of SDWA Establish new class of underground injection wells: Class VI Are codified under 40 CFR et seq. EPA will take an adaptive approach to the Class VI requirements U.S. Environmental Protection Agency 6

7 1. Background Class VI Rule: Phases Pre-Injection Phase Injection Phase Post-Injection Phase Long-Term Care Emergency and Remedial Response Financial Responsibility U.S. Environmental Protection Agency 7

8 1. Background GS PHASES Milestones Reports/ Submittals Activities Class VI Rule: Reporting Activities PRE-INJECTION PHASE INJECTION PHASE POST-INJECTION PHASE LONG- TERM CARE Application to Construct a New Class VI Well Permit Application (146.82(a)) Waiver Report (146.95) Final submittals/updat es ( (c)) Siting/Site characterization AoR delineation and corrective action Injection well construction Logging, sampling and testing FR Demonstration Approval of Construction of Class VI Well Submittals for Injection Approval Approval of Injection 60 days 60 days 120 days 90 days Notice of Intent to Plug Semi-annual Reports Notification of Testing (30 days in advance) Reporting Test Results (within 30 days) Reporting AoR Reevaluation/Corrective Action (frequency determined in permit); Plan Updates FR Updates (Annual) Notice of Adverse Financial Condition (if needed) 24-Hour Notifications (if needed) Injection Well Operation Testing and Monitoring AoR Reevaluation/Corrective Action; Plan Updates Financial Responsibility Emergency and Remedial Response (if needed) Notice of Intent to plug Injection Well Plugging Plugging Report Plugging Report Periodic Reporting of PISC Monitoring Results Reporting AoR Reevaluation/Corrective Action (frequency determined in permit); Plan Updates FR Updates (Annual) PISC Monitoring Non-endangerment Demonstration Notice of intent for site closure Site Closure & Report Notice of Site Closure Intent for Report Site Closure U.S. Environmental Protection Agency 8

9 1. Background Class VI Rule: Reporting Requirements Requirements - 40 CFR (e) Regardless of whether a State has primary enforcement responsibility, owners or operators must submit all required reports, submittals, and notifications under subpart H of this part to EPA in an electronic format approved by EPA. Authority - SDWA 1445(a)(1) U.S. Environmental Protection Agency 9

10 1. Background Class VI Rule: UIC Program Director s Roles Access data submitted by owners or operators Evaluate and verify proposed and ongoing injection operations Submit Class VI compliance/oversight information to EPA SDWA 1445(a)(1) and 40 CFR (e) U.S. Environmental Protection Agency 10

11 How will the GSDS be developed and what will it include? 2. OVERVIEW OF THE GSDS A. Types of GS data B. GSDS development process C. Joint Requirements Planning (JRP) process D. Alternatives Analysis (AA) process U.S. Environmental Protection Agency 11

12 Overview of the GSDS: 2A. TYPES OF GS DATA U.S. Environmental Protection Agency 12

13 2A. Overview of the GSDS - Types of GS Data GS Data Data that are generated and/or collected, by owners or operators and permitting authorities, during GS operations that need to be reported, stored, and managed This includes both: Data reported by owners/operators of Class VI wells Data generated by permitting authorities for compliance and oversight purposes GS data might also include a small amount of other information that might be generated by other offices or agencies U.S. Environmental Protection Agency 13

14 2A. Overview of the GSDS - Types of GS Data Two Major Types of GS Data Reporting Data Compliance/Oversight Data Example: Data on depth, areal extent, thickness, mineralogy, porosity, permeability, and capillary pressure of the injection and confining zone(s) Examples: Last MIT date A notice of adverse financial conditions Examples: Inspection: Date; Pass or Fail Proof of Financial Responsibility: Date; Approved or Not Approved U.S. Environmental Protection Agency 14

15 2A. Overview of the GSDS - Types of GS Data GS Data Flow Owner/Operator GSDS Class VI GS Reporting Data Class VI GS Compliance/ Oversight Data States or Regions (Permitting Authority) U.S. Environmental Protection Agency 15

16 Overview of the GSDS: 2B. GSDS DEVELOPMENT PROCESS U.S. Environmental Protection Agency 16

17 2B. Overview of the GSDS - GSDS Development Process GSDS Development Process and Joint Requirements Planning (JRP) meetings completed Alternatives Analysis (AA) completed: JRP outcomes were used to inform development of data system alternatives Status JRP AA DECISION GSDS Identify user and data system requirements. June 2011 September 2011 Develop data system alternatives based on input from JRP process and conduct cost/benefit analysis. August 2011 December 2011 Obtain EPA management decision on the selected alternative for the GS Data System. February 2012 Design the GS Data System U.S. Environmental Protection Agency 17

18 Overview of the GSDS: 2C. JOINT REQUIREMENTS PLANNING (JRP) PROCESS U.S. Environmental Protection Agency 18

19 2C. Overview of the GSDS - JRP Process Definition of JRP Process Structured meetings in which a carefully selected group of stakeholders and content experts work together to identify, define, create, and refine user requirements EPA held two JRP meetings: JRP1: August 2 3, Focused on needs of EPA users, especially Regions JRP2: August 15 16, Focused on needs of state and owner/operator users U.S. Environmental Protection Agency 19

20 2C. Overview of the GSDS - JRP Process Purpose of JRP Process for GSDS Development To inform the development of alternatives for the Alternatives Analysis process To identify/collect input (e.g., formats) on data elements reported/generated to comply with the requirements of the Class VI Rule To identify users of the system and potential use cases To identify data system functionalities and functional areas U.S. Environmental Protection Agency 20

21 2C. Overview of the GSDS - JRP Process JRP Outcome: GSDS Conceptual Model Functional Areas for Users Users of the Functional Area Operations Reporting/Communication Environment Owners/ Operators Submitting: Permit Applications Periodic Reports Class VI GS Data System Permitting Authority (UIC Program Director) Providing: Official Communication Responses Collaboration, Transparency, and Oversight Environment All other users (EPA HQ, Permitting Authorities, Public, OECA/ICIS, etc.) Collaborations per well/aor limitations can be placed on different users for different level of access A subset of information could be made public Data Evaluation Environment EPA HQ/Permitting Authorities GS Project Data Quality Evaluation/ Confirmation Regulatory Evaluation. Technical Requirements/Notes Functional Areas for Data Requires: Use of CDX CROMERR compliance Records Management Environment No need for CROMERR compliance Data Storage U.S. Environmental Protection Agency 21

22 What are the alternatives? What are the methodologies used for the analysis? 2D. ALTERNATIVES ANALYSIS (AA) PROCESS U.S. Environmental Protection Agency 22

23 2D. Overview of the GSDS - AA Process Alternatives Analysis (AA) A structured process for evaluating and comparing Project Management options. The Alternatives Analysis: Identifies different options that are consistent with the conceptual model and based on information received during the JRP process; Analyzes the costs, benefits, and technical feasibility of each option; Distinguishes the option that generates the most benefits to the organization as a whole; and Facilitates and documents a better decision making process U.S. Environmental Protection Agency 23

24 2D. Overview of the GSDS - AA Process Alternative Analysis Process The AA process includes the following steps: 1) Determine and define the objectives of the system 2) Document the solution requirements 3) Choose at least three alternatives 4) Estimate costs for each alternative 5) Estimate benefits for each alternative 6) Document assumptions 7) Adjust costs based on risk assessment 8) Calculate return on investment (ROI) for each alternative 9) Evaluate and select alternative with the greatest net benefit U.S. Environmental Protection Agency 24

25 2D. Overview of the GSDS - AA Process Alternative Analysis: Cost/Benefit Methodology Costing Methodology Mandate: An analysis of comparative costs Our Approach - Costs in ICRs where applicable - Costs for elements of each alternative from sources with prior experience (e.g., UIC DB) - Some costs are relatively constant across all alternatives, such as: Modifications of primacy data systems Data validation (ensuring that data submitted meet the rule and data system requirements) - Costs categories include: Hardware, software, development (e.g., personnel) Program (e.g. personnel to run the system and related processes) O&M (e.g., ongoing costs after initial purchase, including training fees) Benefit Assessment Methodology Mandate: An analysis of benefits - Quantitative: financial benefits - Qualitative: non-financial benefits Our Approach - Developing a qualitative assessment of benefits based on input from JRP participants (HQ, owners/operators, and states) - Benefit categories include: Extent to which alternative meets Program requirements (e.g., adaptive rulemaking, permit processing) Ease of use & integration with existing data systems Technological confidence U.S. Environmental Protection Agency 25

26 2D. Overview of the GSDS - AA Process Alternatives Alternative 1 Alternative 2 GSDS Alternatives Reporting/ Communication GSDS Conceptual Model Environments Collaboration Status Quo Data Evaluation GS Extension of UIC National Database (New Collaboration Platform and Data Evaluation Environment) Data Storage UIC National DB/Documentum GS Extension of UIC National DB/Documentum Alternative 3 GS 3 (Customized for Class VI Support) GS 3 / UIC National DB/Documentum Alternative 4 New Class VI Drupal Collaboration Platform GS 3 GS 3 /UIC National DB/Documentum Alternative 5 New modified-rbdms Collaboration/Data Evaluation/Storage Option RBDMS/ Documentum/ UIC National DB U.S. Environmental Protection Agency 26

27 2D. Overview of the GSDS - AA Process Alternative #1 (Status Quo) Communications Collaboration Data Evaluation/ Analytical Toolset Data will directly be sent to permitting authorities No collaboration or data evaluation solutions Data Storage: Existing UIC National Database for limited GS Class VI structured data Documentum for unstructured data GSDS Node User Interface Exchange Network Data Storage Integration processes BPA/EAI/ESB Enterprise Service Bus/ SOA Service Bus Documentum UIC National Database (Existing) U.S. Environmental Protection Agency 27

28 2D. Overview of the GSDS - AA Process Alternative #2 A new GS Extension of UIC National Database will be created to include: A content management system for the collaboration environment An HPC platform for the data evaluation environment Data Storage: GS Extension UIC National Database for GS Class VI structured data Documentum for unstructured data Communications GSDS Node User Interface Exchange Network Data Storage Collaboration A Drupal (Open Source Content Management Platform) Integration processes BPA/EAI/ESB Documentum Data Evaluation/ Analytical Toolset A Cloud-based High-Performance Computing (HPC) Platform Enterprise Service Bus/ SOA Service Bus GS Extension of UIC National Database U.S. Environmental Protection Agency 28

29 2D. Overview of the GSDS - AA Process Alternative #3 Comprehensive use of GS 3 configured and customized for Class VI support in: Collaboration environment Data evaluation environment Data Storage: Existing UIC National Database for limited GS Class VI structured data Documentum for unstructured data GS 3 for the remainder of GS Class VI structured data Communications GSDS Node User Interface Exchange Network Data Storage Collaboration Integration processes BPA/EAI/ESB UIC National Database (Existing) Data Evaluation/ Analytical Toolset Enterprise Service Bus/ SOA Service Bus U.S. Environmental Protection Agency 29 GS3 GS3 GS3

30 2D. Overview of the GSDS - AA Process Alternative #4 A new Drupal collaboration platform GS 3 platform for data evaluation environment Data Storage: Existing UIC National Database for limited GS Class VI structured data Documentum for unstructured data GS 3 for the remainder of GS Class VI structured data Communications GSDS Node User Interface Exchange Network Data Storage Collaboration Drupal (Open Source Content Management Platform) Integration processes BPA/EAI/ESB UIC National Database (Existing) Data Evaluation/ Analytical Toolset Enterprise Service Bus/ SOA Service Bus U.S. Environmental Protection Agency 30 GS3 GS3

31 2D. Overview of the GSDS - AA Process Alternative #5 A new modified-rbdms collaboration/data evaluation/storage option Data Storage: Existing UIC National Database for limited GS Class VI structured data Documentum for unstructured data RBDMS for the remainder of GS Class VI structured data Communications GSDS Node User Interface Exchange Network Data Storage Collaboration RBDMS Integration processes BPA/EAI/ESB Data Evaluation/ Analytical Toolset RBDMS Enterprise Service Bus/ SOA Service Bus UIC National Database (Existing) RBDMS U.S. Environmental Protection Agency 31

32 2D. Overview of the GSDS - AA Process Alternatives 1. Status Quo GSDS: Assessment of Alternatives Capabilities O/Os submit electronically, but no electronic storage or modeling capabilities. Alternatives Analysis Assessment Benefits Assessment Low investment, but no support for permit processing or adaptive approach. Does not comply with JRP req s. 2. GS Extension of UIC DB 3. PNNL s GS 3 for UIC 4. Drupal + GS 3 5. Modified RBDMS (GWPC) Would store structured Class VI data, unclear how it would integrate with modeling & collaboration tools. Would store Class VI data & integrate a robust modeling tool (e.g., for evaluating AoRs, etc.). Similar to #3, with enhanced and tailored collaboration platform. Currently used by 22 state Class II / O&G programs. Modifications would add Class VI, modeling, and storage. Oversight support, but support for permit processing/data eval. & adaptive rulemaking unclear. Compliance w/ JRP req s unclear. Supports permit processing & adapt. approach, but relies heavily on PNNL. High learning curve. Similar to #3, but the new collaboration platform needs to be developed and integrated & more EPA oversight time needed. Already used by states, but extensive modifications needed. Support of system req s is moderate. U.S. Environmental Protection Agency 32

33 What are the next steps for GSDS AA development? 3. NEXT STEPS U.S. Environmental Protection Agency 33

34 3. Next Steps Next Steps EPA management decision on the selected alternative for the GS Data System Design the GS Data System (2012) U.S. Environmental Protection Agency 34

35 Questions??? U.S. Environmental Protection Agency 35