The storage operator shall prepare, maintain, and comply with a testing and monitoring plan to verify that the geologic sequestration project is operating as approved and is not endangering underground sources of drinking water or natural resources. The plan must be submitted with the petition to approve the storage facility and must include a description of how the storage operator will meet the requirements of this section, including accessing sites for all necessary monitoring and testing during the life of the project.

1. 1. The testing and monitoring plan must include:

   1. a. Analysis of the carbon dioxide stream in compliance with applicable analytical methods and standards generally accepted by industry and with sufficient frequency to yield data representative of its chemical and physical characteristics;
      b. Installation and use, except during well workovers, of continuous recording devices to monitor injection pressure, rate, and volume; the pressure on the annulus between the tubing and the long string casing; and the annulus fluid volume added;
      c. Corrosion monitoring of the well materials for loss of mass, thickness, cracking, pitting, and other signs of corrosion, which must be performed on a quarterly basis to ensure that the well components meet the minimum standards for material strength and performance by:

      1. i. Analyzing coupons of the well construction materials placed in contact with the carbon dioxide stream;
         ii. Routing the carbon dioxide stream through a loop constructed with the material used in the well and inspecting the materials in the loop; or
         iii. Using an alternative method approved by the Board;

   2. d. Periodic monitoring of the ground water quality and geochemical changes above the confining zone that may be a result of carbon dioxide movement through the confining zone or additional identified zones, including:

      1. i. The location and number of subsurface observation wells based on specific information about the geologic sequestration project, including injection rate and volume, geology, the presence of artificial penetrations, and other factors; and
         ii. The monitoring frequency and spatial distribution of subsurface observation wells based on baseline geochemical data and on any modeling results in the area of review evaluation.

   3. e. A demonstration of external mechanical integrity at least once per year until the injection well is plugged; and, if required by the Board, a casing inspection log at a frequency established in the testing and monitoring plan;
      f. A pressure fall-off test at least once every five years unless more frequent testing is required by the Board based on site-specific information;
      g. Testing and monitoring to track the extent of the carbon dioxide plume and the presence or absence of elevated pressure (e.g., the pressure front) by using:

      1. i. Direct methods in the injection zone; and
         ii. Indirect methods (e.g., seismic, electrical, gravity, interferometric synthetic aperture radar or electromagnetic surveys and down-hole carbon dioxide detection tools), unless the Board determines, based on site­ specific geology, that such methods are not appropriate;

   4. h. The Board may require surface air monitoring and soil gas monitoring to detect movement of carbon dioxide that could endanger an underground source of drinking water. Regarding these requirements:

      1. i. Design of surface air and soil gas monitoring must be based on potential risks to underground sources of drinking water within the area of review;
         ii. The monitoring frequency and spatial distribution of surface air monitoring and soil gas monitoring must be based on using baseline data, and the monitoring plan must describe how the proposed monitoring will yield useful information on the area of review; and
         iii. Surface air monitoring and soil gas monitoring methods are subject to the Board's approval;

   5. i. Any additional monitoring, as required by the Board, necessary to support, upgrade, and improve computational modeling of the area of review evaluation;
      j. Periodic reviews of the testing and monitoring plan by the storage operator to incorporate monitoring data collected, operational data collected, and the most recent area of review reevaluation performed. The storage operator shall review the testing and monitoring plan at least once every five years. Based on this review, the storage operator shall submit an amended testing and monitoring plan or demonstrate to the Board that no amendment to the testing and monitoring plan is needed. Any amendments to the testing and monitoring plan are subject to the Board's approval, must be incorporated into the permit, and are subject to the permit modification requirements. Amended plans or demonstrations must be submitted to the Board as follows:

      1. i. Within one (1) year of the reevaluation;
         ii. Following any significant changes to the facility, such as addition of subsurface observation wells or newly permitted injection wells within the storage facility area or the area of review, on a schedule determined by the Board; or
         iii. When required by the Board; and
   6. k. A quality assurance and surveillance plan for all testing and monitoring requirements.

2. 2. Samples and measurements taken for the purpose of monitoring shall be representative of the monitored activity.
   3. Records of monitoring information shall include:

   1. a. The date, exact place, and time of sampling or measurements;
      b. The individual who performed the sampling or measurements;
      c. The date analyses were performed;
      d. The individual who performed the analyses;
      e. The analytical techniques or methods used; and
      f. The results of such analyses.

3. 4. All well permits issued by the Board shall specify:

   1. a. Requirements concerning the proper use, maintenance, and installation, when appropriate, of monitoring equipment or methods, including biological monitoring methods when appropriate;
      b. Required monitoring, including type, intervals, and frequency sufficient to yield data, which are representative of the monitored activity, including when appropriate, continuous monitoring; and
      c. Applicable reporting requirements based upon the impact of the regulated activity and as specified throughout this chapter.

Author: S. Marvin Rogers

Statutory Authority: 9-17-150 et seq. of the Code of Alabama (1975)

History: New Rule: Published November 27, 2024; effective January 11, 2025.