Carbon Capture and Sequestration: Pathway Validation

Carbon Capture and Sequestration continues to pick up speed with more interest than ever before in the race to decarbonize. The United Nations reports that more than 1200 companies and more than 70 countries have committed to net-zero carbon emissions targets. Helping to fuel some of these efforts in the United States, in July the Department of Energy announced a Bipartisan Infrastructure Bill with $2.6 Billion in funding to support additional carbon capture projects and decarbonize power generation. As climate tech rapidly evolves with new carbon removal investments frequently being announced, we see firsthand the growing demand for effective carbon reduction strategies. At Christianson, we are thrilled to be on the frontlines helping clients tackle many of the new challenges that face our evolving energy industry.

Filling in the Gaps to Ensure Your Project’s Success Part 2

In part two of this Carbon Capture and Sequestration series we will take a closer look at the pathway validation process to prepare you for a successful validation under the California Air Resources Board’s (CARB) Low Carbon Fuel Standard (LCFS). If you missed the first part of this series where we discussed what you need to know to prepare for the Permanence Certification portion of your CCS Pathway, you can find part one here.

The Carbon Capture and Sequestration Protocol is a document drafted by CARB that carries the weight of the LCFS regulation. The protocol applies to CCS projects that capture carbon dioxide and sequester it onshore, in either saline or depleted oil and gas reservoirs, or oil and gas reservoirs used for CO2-enhanced oil recovery. The CCS protocol applies to both new CCS projects as well as any that are already existing, as long as the project meets the protocol’s permanence requirements. Now let’s dive into what you should know for your Pathway Validation!

Experts Needed to Guide your CCS Pathway/Project Validation

To generate credits under the LCFS for your Carbon Capture & Sequestration project, you are required to apply and be approved for a CCS pathway under CARB’s CCS Protocol. CARB will only issue credits after your pathway verification has been completed for the project and the permanence certification has approval. In addition to completing 3^rd Party Independent Reviews for the permanence certification (see part one for further details), there are additional experts that you need to work with for the CCS Pathway Validation portion of your project:

1. Your trusted verification body – the Christianson PLLP Compliance team. Only half of the registered verification bodies are approved to complete CCS verification projects.
2. A CARB-accredited oil and gas systems specialist pursuant to the Regulation for the Mandatory Reporting of Greenhouse Gas Emissions – partnered with our staff
3. An accredited Professional Geologist licensed under California or equivalent as approved by CARB – partnered with our staff

It is important to note that the oil and gas specialist as well as the accredited Professional Geologist that is engaged on your validation must be a professional who was not involved in your 3^rd party review or any related work leading up to the construction or commissioning of your CCS project.

Wondering how to assemble this team of specialists to support your CCS project? Christianson has a team of experts ready to support you when you reach this point in your CCS Pathway development. Keep in mind that  Christianson can  begin the validation of your pathway as soon as you have 3 months of injection data available for reporting and review.  The pathway validation can be completed simultaneous to the reviews of your permanence certification, but credits cannot be claimed until you have both approvals.

Pathway Validation Documentation Process

If your company  currently holds an LCFS pathway and has engaged in annual LCFS pathway verifications, this process will mirror those engagements.  The same pathway verification procedures will be completed with the addition of procedures for review of the CCS project data as required in the CCS Protocol. The CCS verification will include a detailed review of all the following:

1. Documentation and maps to verify the boundaries of the CCS project, including location of monitoring requirements, procedures for data quality assurance and quality control
2. The operator’s CCS project’s risk rating for determining its contribution to the LCFS Buffer Account as calculated under Appendix G of the CCS Protocol
3. All plans, assessments, and reports for conformance with LCFS Regulation and the requirements of the CCS Protocol

Some of the plans, assessments, and reports that are under review during validation will include:

1. Internal and external mechanical integrity of the CCS project
2. CO2 emissions analysis and continuous monitoring of injection rate and volume
3. Plans for CO2 leakage event from storage complex
4. Detailed review of required materials submitted to CARB with your application

After completing the first pathway validation, there will be annual verifications of your pathways, just as reporting entities are currently doing for any existing LCFS pathways.

What if our company currently has a Carbon Intensity (CI) Score and maintains an LCFS Pathway? Does this change how we approach our CCS validation?

Regardless of the type of pathway your company currently holds, your CCS project/pathway will be a new and separately validated CI score. Whether your facility currently has a pathway with Starch or Fiber Ethanol, Biodiesel or Renewable Diesel, LNG or L-CNG, or Biomethane etc., or is applying for its first pathway, every CCS Project will need to apply for new pathways when adding a CCS project to the mix.  For plants with existing pathways, the CCS project will double the number of pathways that the entity holds.  You will maintain a non-CCS pathway set and have a mirrored set of pathways with CCS.

What do we do if we are planning to work with one of the CCS pipeline projects?

Christianson has recently received inquiries regarding how CCS pipeline projects affect the CCS Pathway application process. It is expected that  the CCS injection site would register as a Joint Applicant and be responsible for the permanence certification approval.  The participating production  facilities would still need to  apply for updated CI score that include the CCS project in its pathways. This would mean that any facility attached to the pipeline would register with the injection site as a Joint Applicant for their specific pathway.

Are there other ways that you can help support us on our CCS pathway/project?

Our team is always happy to help answer questions about the validation process regardless of where you are with your CCS pathway or project. Additionally, federal and state government agencies continue to announce funding opportunities to support development and commercialization of carbon capture projects, and Christianson’s Business Advisory Services team is ready to assist clients with the identification of new funding opportunities for your CCS project development.