The owner or operator of a Class VI injection well must
prepare, maintain, and comply with a testing and monitoring plan which will
verify that the geologic sequestration project is operating as permitted, and
that the project is not endangering USDWs. The requirement to maintain and
implement an approved testing and monitoring plan is directly enforceable,
regardless of whether the requirement is a condition of the permit. The owner
or operator must submit the testing and monitoring plan to the Agency with the
permit application, and the owner or operator must include a description of how
it will meet the requirements of this Section, including accessing sites for
all necessary monitoring and testing during the life of the project. Testing
and monitoring associated with geologic sequestration projects must, at a
minimum, include the following parameters and devices:
a) Analyses of the carbon dioxide stream with
sufficient frequency to yield data representative of the chemical and physical
characteristics of the stream;
b)
Installation and use of continuous recording devices to monitor injection
pressure, rate, and volume, except during well workovers, as such are defined
in Section
730.188(d);
the pressure on the annulus between the tubing and the long-string casing; and
the annulus fluid volume added;
c)
Corrosion monitoring of the well materials for loss of mass, thickness,
cracking, pitting, and other signs of corrosion, which must be performed on a
quarterly basis to ensure that the well components fulfill the Agency-approved
minimum standards for material strength and performance, as provided in Section
730.186(b),
by performing one of the following tests:
1)
Analyzing coupons of the well construction materials placed in contact with the
carbon dioxide stream;
2) Routing
the carbon dioxide stream through a loop constructed with the material used in
the well and inspecting the materials in the loop; or
3) Using an alternative method approved by
the Agency;
d) Periodic
monitoring of the groundwater quality and geochemical changes above the
confining zones that may be a result of carbon dioxide movement through the
confining zones or additional identified zones, including the following
information:
1) The location and number of
monitoring wells based on specific information about the geologic sequestration
project, including injection rate and volume, geology, the presence of
artificial penetrations, and other factors; and
2) The monitoring frequency and spatial
distribution of monitoring wells based on baseline geochemical data that has
been collected pursuant to Section
730.182(a)(6)
and on any modeling results in the area of review evaluation required by
Section
730.184(c).
e) The annual demonstration of
external mechanical integrity required by Section
730.189(c)
at least once per year until the injection well is plugged; and, if required by
the Agency, a casing inspection log undertaken pursuant to Section
730.189(d),
at a frequency established in the testing and monitoring plan;
f) A pressure fall-off test at least once
every five years, unless the Agency has required more frequent testing based on
site-specific information;
g)
Testing and monitoring to track the extent of the carbon dioxide plume and the
presence or absence of elevated pressure (i.e., the pressure front) by using
the following types of methods:
1) Direct
methods in the injection zones; and
2) Indirect methods (e.g., seismic,
electrical, gravity, or electromagnetic surveys or down-hole carbon dioxide
detection tools), unless the Agency has determined, based on site-specific
geology, that these methods are not appropriate;
h) The Agency must require surface air
monitoring or soil gas monitoring if the Agency determines that this monitoring
is needed to detect movement of carbon dioxide that could endanger a USDW.
1) The design of Class VI injection well
surface air or soil gas monitoring must be based on potential risks to USDWs
within the area of review;
2) The
monitoring frequency and spatial distribution of surface air monitoring or soil
gas monitoring must be decided using baseline data, and the monitoring plan
must describe how the proposed monitoring will yield useful information on the
area of review delineation or compliance with the prohibition against movement
of fluid into a USDW set forth in 35 Ill. Adm. Code
704.122;
3) If the Agency requires surface air or soil
gas monitoring, the Agency has determined that monitoring undertaken to comply
with subpart RR of 40 CFR
98 accomplishes the goals of subsections (h)(1) and
(h)(2), and the owner or operator fulfills the carbon dioxide release reporting
requirements set forth in Section
730.191(c)(5),
the Agency must approve the use of monitoring undertaken to comply with subpart
RR of 40 CFR
98. After approval by the Agency, compliance with subpart RR of 40
CFR
98 pursuant to this subsection (h)(3) is deemed a condition of the Class VI
injection well permit;
i) Any additional monitoring that the Agency
has determined is necessary to support, upgrade, and improve the computational
modeling of the area of review evaluation that is required by Section
730.184(c)
and to determine compliance with the prohibition against movement of fluid into
a USDW set forth in 35 Ill. Adm. Code
704.122;
j) The owner or operator must periodically
review the testing and monitoring plan to incorporate monitoring data collected
under this Subpart H, operational data collected pursuant to Section 730.188,
and the most recent area of review reevaluation performed pursuant to Section
730.184(e).
The owner or operator must review the testing and monitoring plan at least once
in every five-year period. Based on this review, the owner or operator must
submit an amended testing and monitoring plan or demonstrate to the Agency that
no amendment to the testing and monitoring plan is needed. Any amendments to
the testing and monitoring plan must be approved by the Agency, must be
incorporated into the permit, and are subject to the permit modification
requirements set forth in 35 Ill. Adm. Code
704.261 or
704.264, as
appropriate. The owner or operator must submit amended plans or demonstrations
to the Agency as follows:
1) Within one year
after an area of review reevaluation;
2) Following any significant changes to the
facility, such as addition of monitoring wells or newly permitted injection
wells within the area of review, on a schedule determined by the Agency;
or
3) When required by the
Agency.
k) A quality
assurance and surveillance plan for all testing and monitoring
requirements.