Appendix A - Risk Activity Table
Current through April 27, 2019
| Major Risk (Feature, Event, or Process) | |
| 1 | Mineral Rights Infringement (Trespass) |
| 1.1 | Leakage migrates into mineral zone or hydraulic front impacts recoverable mineral zone; causes may include plume migration different than modeled |
| 1.2 | Post injection discovery of recoverable minerals |
| 1.3 | New technology (or economic conditions) enables recovery of previously un-economically recoverable minerals |
| 1.4 | Act of God (egseismic event) |
| 1.5 | Formation fluid impact due to CO2 injection |
| 1.6 | Address also contributing causes 3.1, 3.2, 3.3, 3.5, 4.3, and 4.4 |
| 2 | Water Quality Contamination |
| 2.1 | Leakage of CO2 outside permitted area |
| 2.2 | Leakage of drilling fluid contaminates potable water aquifer |
| 2.3 | Rock/acid water (iegeochemistry) interaction contaminates potable water by carryover of dissolved contaminants |
| 2.4 | Act of God (egseismic event) |
| 2.5 | Formation fluid impact due to CO2 injection |
| 2.6 | See also contributing causes 3.1, 3.2, 3.3, 3.5, 4.3, and 4.4 |
| 3 | Single Large Volume CO2 Release to the Surface - Asphyxiation/Health/Ecological |
| 3.1 | Overpressurization (ieinduced) |
| 3.2 | Caprock/reservoir failure |
| 3.3 | Well blowout (egat surface or bore failure below ground), includes monitoring wells - Causes could include seal failure (egwell, drilling or injection equipment) |
| 3.4 | Major mechanical failure of distribution system or storage facilities above ground or below ground (ienear the surface) |
| 3.5 | Orphan well failure (egwell not identified prior to injection) |
| 3.6 | Sabotage/Terrorist attack (egon surface infrastructure) |
| 3.7 | Act of God (egmajor seismic event) |
| 4 | Low Level CO2 Release to Surface - Ecological damage due to low-level releases; potential asphyxiation of human or ecological receptors |
| 4.1 | Overpressurization (ieinduced) |
| 4.2 | Caprock/reservoir failure (egPlume migrates along fault line/fissure to surface) |
| 4.3 | Incomplete geological seal (eginaccurate characterization of sub-surface geology) |
| 4.4 | Well seal failure (egwell, drilling or injection equipment) including monitor wells |
| 4.5 | Mechanical failure of distribution system or storage facilities above or below ground (egnear surface) |
| 4.6 | Orphan wells (egwell not identified prior to injection) |
| 4.7 | Induced seismicity leading to leakage |
| 4.8 | Act of God (egseismic event) |
| 5 | Storage Rights Infringement (CO2 or other entrained contaminant gases) - Form of Mineral Rights Infringement |
| 5.1 | Leakage migrates into adjacent pore space; causes may include plume migrates faster than modeled |
| 5.2 | Post injection decision (egdue to new technology or changed economic conditions) to store gas in adjacent pore space |
| 5.3 | Acts of God affecting storage capacity of pore space |
| 5.4 | Formation fluid impact due to CO2 injection |
| 5.5 | Will also require primary contributing causes 3.1, 3.2, 3.3, 3.5, 4.3, and 4.4 |
| 6 | Modified Surface Topography (subsidence or uplift) Resulting in Property/Infrastructure Damage |
| 6.1 | Induced Seismicity - Pressure from geochemistry induced reactivation of historic fault or dissolution of material caused by subsidence |
| 6.2 | Formation fluid impact due to CO2 injection |
| 7 | Entrained Contaminant (Non-CO2) Releases |
| 7.1 | Change in CO2 composition/properties (egconcentration of contaminate in CO2 supply increases) |
| 7.2 | Microbial activity initiated by injection process or composition |
| Will also require primary contributing causes 3.1, 3.2, 3.3, 3.5, 4.3, and 4.4 | |
| 8 | Accidents/Unplanned Events (Typical Insurable Events) |
| 8.1 | Surface infrastructure damage |
| 8.2 | Saline water releases from surface storage impoundment |
Adopted, Eff. 7/25/2016.