Transfer of responsibility of CO2 storage sites by Manuel Dr. Nepveu

In this report a number of issues are put forward associated with the Transfer of Responsibility as defined in art. 18 of the EU Directive on the geological storage of carbon dioxide (2009/31/EC). The most important conclusion is that the added value of a post-closure delay, for example 20 years, until the responsibility take-over by the Competent Authorities is basically nil. The work done in risk assessment and characterization before a storage permit is requested must already have been convincing on health, safety and environmental (HSE) issues before a CO2 storage permit is issued. In the subsequent injection phase ongoing modeling and monitoring have added to the conviction that the storage takes place in accordance with the requirements of the Directive. Furthermore, the injection phase presents the most severe test on the storage container, whereas post-closure the subsurface system approaches equilibrium.