Challenge

The California Resources Corporation (CRC) was attempting to install a carbon dioxide storage project at existing facilities in their Elk Hills location. CRC had already submitted a U.S. EPA Underground Injection Control (UIC) Class VI permit application but needed assistance with submitting a Sequestration Site Certification Application under the California Air Resources Board (CARB) requirements. Many of the requirements under CARB are fairly vague, and there is little to no previous precedence (e.g. previously approved projects) to aid in interpreting their requirements.

Solutions

DBS&A drafted several reports and plans based on geologic analyses and analytical modeling. Our team began by performing a site-based risk assessment and risk management plan of the Elk Hills site to estimate the probability of occurrence over 100 years of fluid leakage and other adverse environmental impacts. Some of the modeling was collected from modeling and data analysis from the Class VI permit application, but our team also completed additional probabilistic data analysis and modeling to develop the final risk management plan. Our team then completed geological analyses on the site, including an induced seismicity evaluation, and used these findings in conjunction with existing data from the Class VI permit to draft a geologic evaluation report. Our team also submitted a Storage Complex Delineation and Corrective Action Plan, something similar to the Area of Review submitted under the Class VI permit application. However, our team completed additional monitoring to complete the more stringent requirements of CARB, including history matching of the existing pressure distribution, modeling the dissolved carbon dioxide plume, additional accounting for geologic heterogeneity, modeling the response of fluid leakage, and probabilistic modeling in support of risk assessment and monitoring plans.

Our team also completed several testing and monitoring plans that were similar to those required in the Class VI permit, but the plans required under CARB included several new requirements. Our team was able to work with CRC staff to use data from similar reports in the Class VI permit application, but we also completed additional monitoring that included soil-gas and air monitoring, surface monitoring of carbon dioxide point sources, seismicity monitoring, ecosystem stress monitoring, and monitoring of supplemental energy inputs required for operation of the project. Based on this additional monitoring, we drafted a Baseline Testing and Monitoring Plan, Pre-Injection Testing Plan, Formation Testing and Well Logging Plan, and plans for mechanical integrity testing, emissions monitoring, and monitoring, measurement, and verification of containment.

Results

Through our team’s efforts, the CARB application was approved, and CCS has been approved to open the new facility, groundbreaking of which will start in 2026. CTV I became the first facility in California to receive a Sequestration Site Certification and Class VI permits from the EPA. Our application was successful in creating a new precedence for carbon capture facilities in the state.

“We are proud of our ability to submit a successful application despite the complexity of the requirements and the lack of precedence, thus showcasing our team’s expertise in assessment and interpretation.”