Review of project permits under the London Protocol – An assessment of the proposed P18-4 CO2 storage site

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By Tim Dixon

7 June 2016

 The London Convention and Protocol promotes the protection of the marine environment by prohibiting the dumping of wastes and other matter into the sea. Under the Protocol all dumping is prohibited, with the exception of a limited number of selected substances. In 2007, an amendment entered into force which permitted CO2 streams for geological storage beneath the seabed to be considered under the London Protocol. The amendment was supported with a set of “Specific Guidelines for Assessment of Carbon Dioxide Streams for Disposal into Sub-seabed Geological Formations”, developed to support the National Authorities of Contracting Parties in evaluating permit applications for CO2 disposal activities in their marine territories.

The P18-4 field, originally part of the ROAD CCS Project, is a near-depleted gas field at a depth of 3.5 km under the seabed, located approximately 20 km off the Dutch coast in the North Sea. The operator of the gas field applied for a CO2 storage permit to the Dutch authorities in 2011. The objective of this report is to assess to what extent the proposed P18-4 storage site complies with the London Protocol’s 2012 Specific Guidelines for Assessment of Carbon Dioxide Streams for Disposal into Sub-seabed Geological Formations, and therefore the 1996 London Protocol itself. The assessment has been achieved through a simple, but systematic, cross-check of the requirements of the Specific Guidelines against the contents of the application material provided by the operator to the National Authority.

It was found that the material submitted to the National Authority is broadly sufficient to allow an evaluation of the planned CO2storage activities in a manner consistent with the provisions of the 1996 London Protocol. This compliance assessment indicates overall technical compliance with the CO2 Specific Guidelines, no information was sufficiently absent that would indicate clear non-compliance with the CO2 Specific Guidelines.

A number of recommendations are provided to address some areas that would benefit from further clarification. The recommendations are relevant both for this specific case study, but also for future CO2 storage permits in marine territories of contracting parties.

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