Recommendations include meticulous site characterization efforts early in the CO2 storage project and tailoring the monitoring network. We discuss the key considerations for developing an effective CCS Testing and Monitoring Plan based on lessons learned from developed MSW and CCR monitoring programs, as well as how early planning and good judgment can help navigate the complexities associated with CCS projects and ultimately reduce those complexities and associated project costs. In our Technical Bulletin, Applying Lessons Learned From Municipal Solid Waste and Coal Combustion Residuals to the Development of Testing and Monitoring Plans for CO2 Storage Projects, we focus on the testing and monitoring aspect of Class VI permitting and related complexities, including the project’s overall scale, enhanced costs, and enhanced regulatory risk. Drawing on lessons learned from more familiar and well-developed regulatory frameworks will be beneficial. While USEPA has published general guidance for Class VI permitting, it is still a new permitting challenge for both scientists and regulators alike. With climate change becoming a center of attention globally, much focus has pointed toward carbon capture and storage (CCS) in recent years.
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