16th International Conference on Greenhouse Gas Control Technologies, GHGT-16

23rd -27th October 2022, Lyon, France

Development of a Carbon Capture and Storage (CCS) risk register

and global lessons learned
Kate Thatchera, Renato Zagorščakb*, Emma Rhodesa, Louise Bruffella, Alan Paulleya,
Ton Wildenborgc, Marianne van Unenc, Lydia Rycroftc, Andrew Simsd, Philip
Copestaked
a
Quintessa Ltd, 633/635 Birchwood Boulevard, Birchwood, Warrington, WA3 7QU, UK
b
Quintessa Ltd, First Floor, West Wing, Videcom House, Newtown Road, Henley-on-Thames, Oxfordshire, RG9 1HG, UK
c
TNO, Princetonlaan 6, 3584 CB Utrecht, The Netherlands
d
Merlin Energy Resources Ltd, Newberry House, New Street Ledbury, Herefordshire, HR8 2EJ, UK

Abstract

Under all global emissions scenarios compatible with a 2°C warming, which was adopted as a goal by 196 Parties at COP 21 in
Paris in 2015, Carbon Capture and Storage (CCS) is necessary to allow a phased transition from fossil fuels. In the UK, CCS has
been recognised as a critical technology in achieving net zero emissions. The North Sea Transition Authority (NSTA) regulates
offshore carbon dioxide storage in the UK and works closely with government, industry and other stakeholders to support the drive
to achieve net zero carbon by 2050. In anticipation of increased interest in CCS projects on the UK Continental Shelf (UKCS), a
risk register has been developed to assist the NSTA in carbon storage licence stewardship. In this paper, the process of building the
register and the description of how it might be used are provided. The register incorporates the full spectrum of technical, political,
economic, commercial, environmental and organisational sources of risk, and how they relate to transportation of carbon dioxide
(CO2) offshore and storage in the subsurface.
The risk register is based on the current understanding of offshore subsurface storage of CO2 from various state-of-the-art projects
that have been carried out to date. Some of these projects are fully commercial ventures, whereas others are first of a kind
demonstration projects or designed to facilitate research. Risks apply at different stages in the storage process and are relevant over
time periods of different length, extending to thousands of years. Overall, the risk register consists of the main checklist, which
covers risk categories central to NSTA’s regulatory role; the wider factors checklist, which covers risk outside the NSTA’s
regulatory remit, but which are pertinent to ensuring the success of a CCS project; and individual risk review forms, which include
detailed project-specific risks used in the risk collation process and formation of the risk register. As experience grows from the
implementation of CCS projects on the UKCS, it is likely that improved information will become available about risks that might
occur and the preventative measures or mitigations that satisfy UK’s regulatory regime, which can then be directly incorporated
into the risk register.

Keywords: Carbon Capture and Storage (CCS); Risk Assessment; Risk Register, UK Continental Shelf (UKCS), Licence

* Corresponding author. Email address: [email protected]

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 GHGT-16 Thatcher et al. (2022) 2

1. Introduction

The Paris Agreement, a legally binding international treaty on climate change adopted by 196 Parties at COP 21 in
Paris on 12 December 2015, is landmark in the multilateral climate change process as it brings all nations together to
combat climate change and adapt to its effects. The Agreement’s goal is to limit global warming to well below 2°C,
with the aim to limit the global average surface levels to 1.5°C compared to pre-industrial levels. As a party to this
Agreement, in June 2019 the United Kingdom amended the 2008 Climate Change Act to specify that the minimum
percentage by which the net UK carbon account by 2050 must be lower than 1990 baseline is 100%. In doing so, the
UK became the first major economy to put into law a commitment to achieve net zero carbon emissions.
To achieve the goal of the Paris Agreement, a range of technologies need to be fully realised, for both improving
resilience to climate change and reducing greenhouse gas emissions. The Intergovernmental Panel on Climate Change
[1] recognised Carbon Capture and Storage (CCS), or Carbon Capture, Utilisation and Storage (CCUS) if captured
CO2 is utilised prior to storage, as one of the key technologies to allow a phased transition from fossil fuels and to
reduce greenhouse gas emissions. In the UK, CCS has been recognised as a critical technology since publication of an
Energy White Paper in 2003 [2]. The most recent Energy White Paper [3], released by the UK government, outlines
plans to support the country’s net-zero climate target. The Energy White Paper is building on the UK Prime Minister’s
Ten-Point Plan which commits to support the development of four CCS hub and cluster projects across the UK by
2030.
In the UK, the North Sea Transition Authority (NSTA), formerly the Oil & Gas Authority (OGA), is the licensing
authority which approves and issues storage permits, as well as maintains the carbon storage public register. Its role is
also to consider reuse as part of the NSTA Cessation or Production processes, be a consultee to Offshore Petroleum
Regulator for Environment and Decommissioning (OPRED) on operators’ decommissioning plans, and to explore the
role of CO2 Enhanced Oil Recovery (CO2-EOR). In December 2020, a revised Strategy was presented to the UK
parliament featuring a range of new net zero obligations for the UK oil and gas industry to meet the 2050 target. The
Strategy also positions the UK Continental Shelf (UKCS) as a key enabler for the transition towards net zero.
Aligned with the Energy White Paper [3], there is an anticipation of increased interest in CCS projects on the
UKCS. The NSTA is working with government and industry on the vital role that the oil and gas industry must play
in the UK energy transition, in driving to net zero carbon emissions across the UKCS as quickly as possible. Based on
the NSTA Corporate Plan for 2022-2027 [4], NSTA’s objective is to support the development and deployment of CCS
through creation of a portfolio of carbon storage opportunities on the UKCS. Since becoming an independent regulator,
the NSTA/OGA has awarded five carbon dioxide appraisal and storage licences (CS licences) and agreed a transfer of
a sixth (Fig. 1). With the announcement of the first UKCS CCS licensing round by the NSTA in June 2022, it is likely
that there will be significantly more such CS licences awarded by the end of 2022, all requiring risk assessments in
their initial phases. A key component of the NSTA’s Carbon Storage Licence Stewardship process is an early risk
assessment that needs to be completed by the licence holder. This includes an analysis of potential threats to capacity,
injectivity and containment of CO2, assessment of the uncertainties in defining the storage system, and identification
of areas for further work and data gathering that will address any potential risks or uncertainties. In addition, each
licence holder is required to inform the requirements for a potential future CO 2 storage permit application, including
the measurement, monitoring and verification (MMV) and corrective measures (CM) plans.
Assessment of containment and storage site integrity has been a key activity in many CCS initiatives in the North
Sea and its surrounding areas to date. For instance, an assessment of CO2 storage liabilities in the North Sea concluded
that abandoned wells present the most probable source of leakage for many storage sites, while caprock leakage is
very unlikely in the UK sector of the North Sea [5]. The detailed risk management plan for the Peterhead CCS project
(cancelled) provided key information to decision-makers in selecting the correct concept, performing basic and
detailed design work and managing the project through execution [6]. Subsurface risk assessment for the Endurance
store of the White Rose project (Triassic Bunter Sandstone) provided a high level of confidence that long-term
containment of the CO2 planned to be stored would be achieved, however it identified the most important risks related
to injectivity, CO2 containment, formation fluid displacement and seabed displacement [7, 8]. The same Endurance
store has been recently revisited by the Northern Endurance Partnership (NEP) which confirmed the same major
subsurface risks and provided additional ones, such as risks associated with the monitorability of the structure in the
presence of wind farm [9]. A comprehensive containment risk assessment conduced for the Aurora site (the Northern

Electronic copy available at: https://ssrn.com/abstract=4282955

 GHGT-16 Thatcher et al. (2022) 3

Lights project) in offshore Norway demonstrated that there is no significant risk of leakage affecting human health or
the environment, but also recognised that the storage complex monitoring is an integral element of the CRA, which
enables mitigating actions in case of unexpected CO2 migration or leakage [10].
The NSTA is committed to continued regulatory excellence in this field and is therefore continuing to be
appropriately equipped to carry out its key responsibilities, including assessment of carbon dioxide storage
applications and licence stewardship. The NSTA has worked closely with Quintessa, TNO and Merlin Energy
Resources to identify and describe the risks and mitigations, building on the experience gained from planned and
operational CCS projects around the world, to assist the NSTA when reviewing and / or stewarding carbon storage
applications and licences as the NSTA is required to satisfy itself that operators of a storage licence have made an
analysis of relevant risks that is comprehensive, and which meets current best practice [11].
This paper outlines a process undertaken to describe the risks and mitigations which must be considered as part of
a CCS project on the UKCS and the creation of a risk register to assist the NSTA to carry out its key responsibilities.

Fig. 1. Carbon Dioxide Appraisal and Storage Licences, and UKCS areas offered for CS licence applications (June 2022). Reproduced with the
permission of NSTA (https://www.nstauthority.co.uk/data-centre/nsta-open-data/carbon-storage/).

Electronic copy available at: https://ssrn.com/abstract=4282955

 GHGT-16 Thatcher et al. (2022) 4

2. UKCS Geological Setting

The UKCS comprises the region of waters surrounding the United Kingdom and is bordered by Norway, Denmark,
Germany, The Netherlands, Belgium, France and the Republic of Ireland. These areas include many geological basins,
a number of which contain proven hydrocarbon resources. The known hydrocarbon reservoirs on the UKCS provide
an excellent guide to potential CCS storage units and their characterisation provides important insights into the nature
of future CCS sites, in terms of reservoir/storage unit, distribution, morphology, top seal and structure.
22 potential CO2 storage unit groups are developed in the UKCS, ranging in age from Pre Cambrian / Palaeozoic
fractured basement to Pleistocene-Holocene sandstones [11]. This categorisation is based upon known hydrocarbon
reservoir units primarily. The most volumetrically important storage unit groups are summarised in Table 1. Note that
as there are currently no active CCS projects in the operational phase in the UKCS, none of these storage units can be
regarded as proven yet (though the Permian aeolian/fluvial sandstone group has been proven in the offshore
Netherlands, via K12-B pilot project).

Table 1. The most volumetrically important storage unit groups on the UKCS. EIS = East Irish Sea; SNS = Southern North Sea; OMF = Outer
Moray Firth; WGG = With Ground Graben.
CCS Storage Unit Group Typical Lithostratigraphic Unit Intended Storage unit in known UKCS CCS Project
Permian aeolian/fluvial Zero Carbon Humber project and proven CO2 storage unit in
sandstones offshore Netherlands K12-B pilot project
Triassic aeolian/fluvial sandstones Ormskirk Sandstone (EIS), Bunter White Rose (CS001), Hynet Project (CS004, EIS), East Coast
Sandstone (SNS) Cluster (Endurance) (CS006, CS007)
Middle Jurassic deltaic/shallow Brent Group
marine sandstones
Upper Jurassic shallow marine
sandstones
Upper Jurassic deep marine
sandstones
Lower Cretaceous deep marine Captain Sandstone (OMF), Britannia Acorn CCS project, Longannet Project (expired)
sandstones Sandstone (WGG)
Paleocene deep marine sandstones Maureen Fm, Mey Sandstone Mbr, Acorn CCS Project
Forties Mbr

In addition, of the 22 known hydrocarbon storage units, 17 also have potential for storage in saline aquifers. One
of these unit groups, Oligocene to Pliocene deltaic sandstones, has potential as a CO2 storage unit in the UKCS, as the
correlative storage unit, the Utsira Formation, comprises the storage unit in the Sleipner CCS project in offshore
Norway. The distribution, volumetrics and risking on this unit was described in the North Viking Graben region, as
the Utsira – Skade Aquifer [12, 13]. The majority of the reservoirs in known fields and saline aquifers are sandstones,
representing a range of geological depositional settings and occurring across a range of basins. The choice of which
storage units are used in particular projects is based on a consideration of proximity to industrial complexes generating
significant emissions, burial depth, capacity, effectiveness of top seal (containment) and storage volume, among other
factors.
All active CS licences on the UKCS are focused on CO2 storage. However, utilisation of CO2 injection for CO2-
EOR is being considered, as has been applied in other parts of the world. Indeed, most of the large-scale commercial
CCS projects in operation worldwide are of this type [14]. A potential UKCS example of this is the Buzzard Field, in
UK block 20/6, where CO2 injection is envisaged to recover 5-15% additional oil after the application of primary and
secondary recovery techniques [15].

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3. Methodology

To cover the full spectrum of technical, political, economic, commercial, environmental and organisational sources
of risks and their relationship to transportation of CO2 offshore and storage in the subsurface, several steps were
adopted (Fig. 2).
Defining the scope of the risk register included identifying different risk categories, which are central to the NSTA’s
regulatory role, including capacity, injectivity, containment, offshore CCS infrastructure, physical impacts on other
domains, and monitorability (Table 2). Risks captured under those categories could occur in the offshore transport and
subsurface storage parts of the system, considering both internal and external threats to the system.

Table 2. Risk categories within NSTA’s remit.

Risk category Description
Capacity Volume of CO2 that can be stored in the subsurface. Risks may lead to uncertainty in capacity or changes in
capacity during the project.
Injectivity Rate at which CO2 can flow into the reservoir rock. It is a property of the rock. Risks may lead to uncertainty in
injectivity or changes in injectivity during the project.
Containment Restriction of movement of CO2 to within the store. Risks may lead to migration out of the storage site and leakage
out of the storage complex.
Offshore CCS Includes the offshore pipeline, the well head and any wells that intersect the storage complex. Risks may lead to
infrastructure damage or disturbance to the offshore infrastructure.
Physical impacts on Include geomechanical effects of induced seismicity, uplift, and displacement of in-situ fluids outside of the
other domains storage complex. Risks may lead to physical impacts outside the storage complex to both natural systems and
third-party assets.
Monitorability Ability to monitor the system to provide the required degree of assurance. Risks may impede sufficient monitoring.

As the NSTA has already received and expects to continue receiving CCS applications for projects that seek to
utilise the storage potential of depleted hydrocarbon fields and of aquifers, both ‘open’ and ‘closed’, and fields of
varying lithology (e.g., carbonate, salt, sandstone), different types of candidate stores were considered to appropriately
categorise critical risks pertinent to these stores.
To cover different timeframes in which the risks may occur, several phases aligned with the EU Directive
2009/31/EC were adopted in this study. This included the exploration phase, the storage phase, the post-closure short-
term phase (pre-transfer of obligations to NSTA), and the post-closure long-term phase (post-transfer of obligations
to NSTA).
The process then included creation of the longlist of projects that could be considered for review, defining the key
criteria relevant to NSTA and shortlisting the projects based on the criteria identified (Section 4). Parallel to that, the
risk register and risk review forms were designed with the aim to fulfil the scope and to ensure that the review of
analogue projects and collation of risks is coherent, transparent and auditable (Section 5). Following those steps, the
shortlisted analogue projects were reviewed, risks collated (Section 6) and incorporated into the risk register (Section
7).
Throughout the risk register creation process, frequent discussions between the project team and different
stakeholders took place, which included:

• A kick-off meeting with the NSTA to agree on the format of the risk register and accompanying deliverables, and
agree key actions at the start of the project
• A workshop with the NSTA to ensure that the methodology proposed is aligned with the project scope and to
agree the shortlisted projects, the scope of the register, and the structure of the register
• A set of interviews with key stakeholders involved in the shortlisted analogue projects
• A review and test run of the risk register by the NSTA
• A review of the risk register by experts external to the project team which conducted the reviews of analogue
projects and collation of risks.

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 GHGT-16 Thatcher et al. (2022) 6

Fig. 2. Methodology for developing the risk register.

4. Selection of Analogue Projects for Review

Worldwide quite a few large-scale CO2 transport and storage projects have been and are still being developed, in
operation or closed down as exemplified by the CO2RE Facilities database (https://co2re.co/StorageData) and the
global CCS status report [16]. Some of these projects were cancelled in the development phase or restarted with a
different context. As many of the projects required extensive work on risk assessment to meet the requirements for
permit application, these projects were considered to be good analogue examples for the development of the risk
register presented in this paper.

4.1. Longlist of global CCS projects

In total 29 CCS projects worldwide were identified for the long list of projects, which was based on hands on
knowledge within the consortium members and external experts. 21 projects are referring to large industrial-scale

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activities and another 8 projects were at the pilot scale or experimental test scale. 7 projects are located in the UK and
9 more in other European countries. The remaining 13 projects are located in the US, Canada, Australia, Brazil,
Algeria and Japan. Most of the storage is in sandstones, 2 in carbonates and 1 partly in volcanic rocks. More than half
of the projects stored or planned to store CO2 in aquifers, sometimes in combination with storage in gas fields. 5
projects relate to EOR or enhanced gas recovery (EGR). 6 projects relate to storage in depleted gas fields or oil fields.
7 projects were in the development phase, 9 projects were in the operational phase and 8 projects ended after
operations. The remaining projects were ended or put on hold before operations would start. The conclusion was that
this long list of projects provided sufficient quality and data availability for the risk review to be performed.

4.2. Shortlist of global CCS projects selected for review

In discussion with the NSTA and external experts, the consortium selected 10 storage projects from the long list of
relevance to the UKCS, ensuring that the store types likely to be encountered are represented and the available
information is in the public domain or can be obtained with the permission of the information holder (Table 3).

Table 3. A list of 10 shortlisted projects and key characteristics.

Project name Location Store medium & type Project type Depth of Key
injection (m) references
Goldeneye North Sea, UK Sandstone – depleted Commercial-scale 2500 [6, 17-22]
(Peterhead) (offshore) hydrocarbon reservoir demonstration
Gorgon NW Australia Sandstone – saline Commercial 2300 [23-29]
(onshore) aquifer
Illinois Basin Illinois, US (onshore) Sandstone – saline Demonstration 2150 [30-33]
Decatur Project aquifer
K12-B North Sea, The Sandstone – depleted Demonstration (Enhanced Gas 3800 [34-36]
Netherlands (offshore) hydrocarbon reservoir Recovery & Storage)
Northern Lights North Sea, Norway Sandstone – saline Commercial-scale 2650 [10, 37-43]
(Aurora) (offshore) aquifer demonstration
P18 North Sea, The Sandstone - depleted Demonstration 3500 [44-52]
(ROAD project) Netherlands (offshore) hydrocarbon reservoir
Quest Alberta, Canada Sandstone – saline Commercial 2000 [53-58]
(onshore) aquifer
Sleipner North Sea, Norway Sandstone - saline Commercial 1000 [36, 59-60]
(offshore) aquifer
Snøhvit Barents Sea, Norway Sandstone - saline Commercial 2500 (initially [61-70]
(offshore) aquifer at 2650)
White Rose North Sea, UK Sandstone – saline Commercial 1500 [7, 8]
(offshore) aquifer

In particular, the following selection criteria were used:

• Similarity to potential CCS projects on the UKCS – 6 out of the 10 selected projects are located in the North Sea
region. Projects that are currently being developed on the UKCS are excluded so that they do not interfere with the
regulatory role of the NSTA
• Preference for commercial scale projects – the risk register to be developed should represent the relevant scale of
injection rates and integration with other parts of the CCS value chain. Pilots and field scale tests of novel
techniques do not necessarily represent the needs for cost-effective monitoring and subsurface operations of
commercial scale projects
• Accessibility of information – the project team already had appropriate understanding and good access to a number
of projects which are all located in the North Sea region. The team then used their wider network of contacts from

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a range of projects to obtain further information. Several projects had to be excluded because of restrictions in the
accessibility of the risk-related information.

Four projects were chosen from regions outside the North Sea area. The Snøhvit project in the Barents Sea and
Gorgon project below Barrow Island on the eastern coast of Australia provide unique insights in managing injectivity
and brine production, respectively. The Quest project in Canada and the Illinois Basin Decatur Project (IBDP) in the
US have performed very thorough risk assessment work. For the IBDP, Northern Lights, K12-B and P18 in the
Netherlands and White Rose in the UK, the team had close exchange of information with people engaged on these
projects. Regular communication with the NSTA enabled adequate steering of the selection process and provision of
confidential information on previous projects in the UK, e.g., the Goldeneye store. Finally, all of this allowed the
selection of 10 global CCS projects (Table 3).

5. Design of Risk Register and Review Forms

In designing the risk register, a number of workshops and discussions were held which aimed at discussing the
risks that are within the remit of NSTA. As result of those discussions, the risk register was designed to consist of two
individual risk checklists. Risks that are central to the NSTA’s regulatory role were captured in detail onto a main risk
checklist (Fig. 3), while other risks relevant to a CCS project were captured in less detail on a wider factors checklist
(Fig. 4). Each review form also contained a storage project summary sheet, which includes primary details about the
analogue project reviewed (Fig. 5).
The structure of the main risk checklist was designed to broadly align with the Bowtie methodology [17], which is
commonly used in the oil and gas industry for communicating risk. Such approach enables understandable
representation of the impacts of a hazard, the risk it presents, the controls preventing the event from occurring and the
mitigation measures in place to limit the consequences.
The structure of the main checklist includes (Fig. 3):

• Risk number, which is used to aid cross referencing between different risks
• Risk title, which is inspired by a risk identified in the analogue projects
• Risk description, which gives more detailed information about the risk
• Relevant risk categories, which serve to group the risks of interest based on risk categories central to the NSTA’s
regulatory role. Those categories include: capacity; injectivity; containment; offshore CCS infrastructure;
physical impacts on other domains; and monitorability
• Store types of relevance, which serve to extract relevant risks based on store type criteria. Those include:
aquifers; depleted hydrocarbon reservoirs; sandstones; carbonates; salt; open reservoirs; and closed reservoirs
• Relevant timeframe(s), which serve to group the risks of interest based on different timeframes aligned with the
CCS Directive. Those include: Assessment, Characterisation and Development (ACD) stage; Operational (O)
stage, Post-closure pre-transfer (PCPT) stage; and Post-closure long-term (post-transfer) (PCLT) stage
• Typical preventative measures, which could be put in place to prevent the risk occurring
• Typical mitigations, which could be put in place to limit or stop the potential consequences of the risk arising
• Potential impact(s), which could arise if the risk occurs
• Example Case studies, which are the key references within an analogue project under which the risk was
identified
• Comments, which include useful information (e.g. key aspects relevant to the context).

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Relevant Time-
Relevant Risk Categories Store Types of Relevance
frame(s)

Physical Impact on
Risk Related Typical Preventative Typical Potential Example Case

other domains

Monitorability
infrastructure

Depleated gas
Off-shore CCS
Risk Number and Title

Containment
Comments

Carbondate
Sandstone
Desciption Risks Measures Mitigations Impact(s) Studies

Injectivity
Capacity

Aquifer

Closed
Open

PCPT

PCLT
ACD
Salt

O
1 Physical uplift of sea-bed ✓ ✓ ✓ ✓ ✓ ✓

Fig. 3. Main risk checklist structure.

The wider factors checklist was formed to enhance the value of the project, however consistent with the NSTA’s
regulatory role, its structure reflects lower level of detail compared with the main checklist, which includes (Fig. 4):

• Wider factor risk categories, which provides a title for a risk category
• Generic category description, which provides a description of the risk category
• Wider factor risk number, which is used to aid cross referencing between the risks on the main risk checklist
• Key risks, which outline potential threats and causes that would lead to unwanted events
• Comments including key references, which include useful aspects of context and key references.

Wider Factor
Wider Factor Risk Categories Generic Category Description Key Risks Comments inc. Key References
Risk Number

Human safety

Fig. 4. Wider factors checklist structure.

Primary Details

Store name:

Operator:

Nature of project (demonstrator, full-scale application, EOR/EGR, analogue etc):

Current status (planned / live / completed etc):

Regulatory / legal status (nature or permits / licenses issued etc):

Store type (aquifer, depleted gas reservoir, carbonate etc):

Main Features / Comments (including: trap type; seal type; any key potential leakage pathways such as faults, fractures, old wells; open or closed aquifer;
depth of injection; lithology of reservoir and seal; any other key features):

Key References:

Fig. 5. Storage project summary sheet.

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6. Risk Review and Collation Process

To conduct a detailed review of the analogue projects outlined in Table 3, a range of data sources were considered:

• Publicly available literature, which can be used for commercial purposes

• Non-publicly available literature for which a permission to use was granted
• Information provided by NSTA
• Information obtained through a dialogue with stakeholders involved in the shortlisted projects.

The analogue projects were reviewed with information recorded in the review forms, with one form for each project
reviewed. Once all the reviews have been completed, the risks were transposed into a risk register and merged based
on similar characteristics. The risk register was then comprehensively edited, using expert judgement, to merge risks
into a single set that can be applied to any CCS project. For instance, while the preventative measures were collated
during the reviews of analogue projects, the measures reported in the main risk checklist were generalized to be at an
appropriate level of detail for the generic checklist. Furthermore, as all analogue projects that were reviewed
considered sandstones with a mixture of saline aquifers and depleted gas reservoirs (see Table 3), the expert judgement
was used to fill in the remaining store types of relevance. Consistent with the risk register structure, the risks were
divided into the main risk checklist and the wider factors risk checklist.
To ensure the comprehensiveness of the risk register, two documents provided by the NSTA, which specify hazards
and risks associated with depleted fields and the risks associated with interactions between offshore windfarms and
CCUS projects, were used as an auditing tool.

7. Completion of Risk Register

7.1. Introduction to the Risk Register

As an introduction to the risk register, an overview of risks contained on the main checklist, projects reviewed and
corresponding reference codes used in the risk register, description of risk categories, identifiers associated with the
related risks, and descriptions of risk timeframes were provided. The introduction also provided a reference to the
accompanying report [11], which provided NSTA with a background on the risk register creation process and
instructions on how to use the risk checklist.

7.2. Main Risk Checklist

The risks captured in the main risk checklist, which are central to the NSTA’s regulatory role, were organised and
grouped under differed headings. For that purpose, Quintessa’s online database of Features, Events and Processes
(FEPs) was used as a basis. The CO2 FEP database (https://www.quintessa.org/co2fepdb/v2.0.0/) provides a tool to
support the assessment of long-term safety and performance of geological CO2 storage. The database includes around
200 FEPs in a hierarchical structure, with individual FEPs grouped into several categories. Similar categories were
adopted in this work, consisting of:

• External factors – Geological (2 risks)

• External factors – Human actions (5 risks)
• CO2 storage project – Operation and Monitoring (7 risks)
• CO2 properties & interactions – Subsurface processes (7 risks)
• Subsurface migration of CO2 (8 risks)
• Geosphere – Characterisation and uncertainty (5 risks)
• Infrastructure – Boreholes and pipelines (8 risks).

A total of 42 risks were captured in the main risk checklist and then grouped accordingly under those categories.
To maintain the functionality and comprehensiveness of the main risk checklist, only key examples of risk

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descriptions, preventative measures, and mitigation strategies were outlined. In addition to the main risk checklist
structure shown in Fig. 3, which was used for the review of the analogue projects, the risk register includes additional
columns which show the relationships with the risks on the main risk checklist, the risks in the wider factors checklist
and the risks in each individual risk review form populated as a part of the review process. This mutual correlation
reflects on the fact that a risk can cause another risk or be caused by it, and allows the user of the risk register to obtain
further information on risks that actually arose for the reviewed analogue project, their importance, site/project specific
mitigation strategies and other key aspects relevant to the context and for understanding the risk. To enable easy
referencing from the main risk checklist to the individual risk review forms, a set of reference codes were assigned to
each analogue project and the risk captured (Table 4). For instance, ‘WR10’ refers to risk number 10 on the individual
risk review form for the White Rose project.

Table 4. A list of 10 shortlisted projects and key characteristics.

Project name Reference Code Number of risks on the
individual risk review form
Goldeneye (Peterhead) GE 1-29
Gorgon GO 1-11
Illinois Basin Decatur Project (IBDP) IBDP 1-25
K12-B KB 1-9
Northern Lights (Aurora) AU 1-13
P18 – pipeline PP 1-9
P18 – subsurface PS 1-17
Quest QU 1-23
Sleipner SL 1-10
Snøhvit SN 1-17
White Rose WR 1-20

7.3. Wider Factors Checklist

The risks that are outside NSTA’s regulatory remit, but which are nevertheless pertinent to ensuring the success
of a CCS project were captured in the wider factors checklist. There were 104 risks outlined in the wider factors
checklist, grouped under eight different headings, each serving to group a number of risks:

• Interactions with surface operations (9 risks)

• Impacts to workers or members of the public (5 risks)
• Interactions with environmental receptors (6 risks)
• Non-technical financial / economic / commercial risk categories (22 risks)
• Non-technical reputation risk categories (11 risks)
• Non-technical perception risk categories (12 risks)
• Non-technical legal / regulatory risk categories (24 risks)
• Non-technical organisational risk categories (15 risks).

7.4. Individual Risk Review Forms

The individual risk review forms were provided as supporting documents to the main risk checklist and the wider
factors checklist to allow the NSTA to obtain more detailed information on risk descriptions, preventative measures,
mitigations strategies and any other project-specific information. In total, there were more than 180 risks captured on
individual main checklists and more than 140 risks captured on the individual wider factor risk categories checklists

Electronic copy available at: https://ssrn.com/abstract=4282955

 GHGT-16 Thatcher et al. (2022) 12

through the expert review of ten analogue projects. The projects reviewed all had information at different levels of
detail, with some projects focusing on specific aspects of risk.

8. Conclusions

This paper presented the methodology developed for building a risk register to assist the NSTA in carbon dioxide
storage licence stewardship. A number of risks were considered in building the risk register, which cover the full
spectrum of technical, political, economic, commercial, environmental and organisational sources of risk, and how
they relate to transportation of carbon dioxide offshore and storage in the subsurface. The work presented in this paper
is built on the current understanding of offshore subsurface storage of CO 2, based on selected state-of-the-art
international projects that have been carried out to date. While some projects reviewed in this work are fully
commercial ventures, others are first of a kind demonstration projects or designed to facilitate research, which affects
the level of detail of the risk assessment and the preventative measures or mitigations that might be appropriate. The
risk register created as a result of work described in this paper outlines 42 key risks that are central to the NSTA’s
regulatory role, and 104 risks that are outside of it. As such, the risk register has been kept at an appropriately generic
level ensuring that all key topics are covered without being obscured by details. As experience grows from the
implementation of CCS projects on the UKCS, it is likely that improved information will become available about risks
that might occur and the preventative measures or mitigations that satisfy UK’s regulatory regime. The flexible
framework under which the risk register has been created allows for direct incorporation of newly identified risks,
measures, and mitigations.

Acknowledgements

The work described in this paper was funded by the North Sea Transition Authority. Permission by the North Sea
Transition Authority to publish this work is thankfully acknowledged. The authors acknowledge the support of the
experts who contributed to this project by providing expert review: Iain Wright, Stuart Haszeldine, Klaas van Alphen,
and Graham Wadelin. The authors also acknowledge the support provided by Sallie Greenberg (Illionis State
Geological Survey), Kjersti Vebenstad (Equinor ASA) and Maarten Slijkhuis (Energie Beheer Nederland) in
providing information to be used in this work. Philip Copestake and Andy Sims are grateful to Merlin Energy
Resources Ltd for permission to publish.

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Electronic copy available at: https://ssrn.com/abstract=4282955

 DEVELOPMENT OF A CARBON CAPTURE AND STORAGE (CCS)
RISK REGISTER AND GLOBAL LESSONS LEARNED
Kate Thatchera, Renato Zagorščakb*, Emma Rhodesa, Louise Bruffella, Alan Paulleya, Ton Wildenborgc, Marianne van
Unenc, Lydia Rycroftc, Andrew Simsd, Philip Copestaked
aQuintessa Ltd, 633/635 Birchwood Boulevard, Birchwood, Warrington, WA3 7QU, UK
bQuintessa Ltd, First Floor, West Wing, Videcom House, Newtown Road, Henley-on-Thames, Oxfordshire, RG9 1HG, UK
cTNO, Princetonlaan 6, 3584 CB Utrecht, The Netherlands
dMerlin Energy Resources Ltd, Newberry House, New Street Ledbury, Herefordshire, HR8 2EJ, UK

* Corresponding author. Email address: [email protected]

1. Introduction 3. Risk Review and Collation

 There is an anticipation of increased interest in Carbon Capture and  A synthesis of the characterisation of the known hydrocarbon fields and
Storage (CCS) projects on the UK Continental Shelf (UKCS). saline aquifer units on the UKCS was carried out, allowing the selection of
 The North Sea Transition Authority (NSTA) is the licensing authority which 10 analogue projects (Table 1) for evaluation by the project team from a
approves and issues storage permits, and maintains the carbon storage list of global CCS projects.
public register. Its objective is to support the development and  The risk register was designed to consist of:
deployment of CCS through creation of portfolio of CCS opportunities on • Risks that are central to the NSTA’s regulatory role
the UKCS. • Risks outside the NSTA’s regulatory remit, but which are pertinent to
 The NSTA has issued six CO2 appraisal and storage (CS) licences up to date, ensuring the success of a CCS project.
and in June 2022 invited bids in the UK’s first ever carbon storage licensing  The structure of the main risk checklist was designed to broadly align with
round (Fig. 1). the Bowtie methodology, as it enables representation of the impacts of a
 A key component of the NSTA’s CS Licence hazard, the risk it presents, the controls preventing the event from
stewardship process is an early risk occurring and the mitigation measures in place to limit the consequences.
assessment that needs to be completed  A detailed review of analogue projects was conducted using a range of
by the licence holder. sources (e.g., publicly available literature, interviews, NSTA, etc.)
 The NSTA is committed to regulatory Table 1: The list of 10 shortlisted analogue projects and key characteristics
excellence in this field and has been
Project name Location Store medium & type
working closely with Quintessa, TNO and Goldeneye (Peterhead) North Sea, UK (offshore) Sandstone – depleted HC* reservoir
Merlin Energy Resources to identify and Gorgon NW Australia (onshore) Sandstone – saline aquifer
describe the key risks and mitigations, Illinois Basin Decatur Project Illinois, US (onshore) Sandstone – saline aquifer

building on the experience gained from K12-B North Sea, The Netherlands (offshore) Sandstone – depleted HC reservoir
Northern Lights (Aurora) North Sea, Norway (offshore) Sandstone – saline aquifer
planned and operational CCS projects P18 (ROAD project) North Sea, The Netherlands (offshore) Sandstone – depleted HC reservoir
around the world. Quest Alberta, Canada (onshore) Sandstone – saline aquifer
 As a result, a risk register has been Sleipner North Sea, Norway (offshore) Sandstone – saline aquifer
developed to assist the NSTA in CS licence Snøhvit Barents Sea, Norway (offshore) Sandstone – saline aquifer
White Rose North Sea, UK (offshore) Sandstone – saline aquifer
stewardship. Fig. 1: UKCS areas offered for CS applications
*HC = hydrocarbon
(NSTA, 2022)

2. Methodology 4. Completion of Risk Register

 To cover the full spectrum of technical, political, economic, commercial, Introduction to the Risk Register
environmental, and organisational sources of risks and their relationship  Includes an overview of risks, projects reviewed and relevant guidance
to transportation of CO2 offshore and storage in the subsurface, several
steps were adopted (Fig. 2) Main Risk Checklist
 Different risk categories were  Contains 42 risks, organised and grouped under different headings:
included: • External factors – Geological • Subsurface migration of CO2
• Capacity • External factors – Human actions • Geosphere – Characterisation and
• Injectivity • CO2 storage project – Operation and Uncertainty
• Containment Monitoring • Infrastructure – Boreholes and
• Offshore CCS infrastructure • CO2 properties & interactions – Pipelines
• Physical impacts on other Subsurface processes
domains
• Monitorability Wider Factors Checklist
 Different types of candidate  Contains 104 risks, grouped under different headings:
stores were considered: • Interactions with surface operations • Non-technical perception risk
• Hydrocarbon fields • Impacts to workers or members of the categories
• Saline aquifers public • Non-technical legal / regulatory risk
• ‘open’ and ‘closed’ reservoirs • Interactions with environmental categories
• Fields of varying lithology (e.g., receptors • Non-technical organisational risk
carbonate, salt, sandstone) • Non-technical financial / economic / categories
 Different timeframes in which commercial risk categories
risks may occur were covered: • Non-technical reputation risk
• Exploration stage categories
• Storage stage
• Post-closure short-term stage Individual Risk Review Forms
• Post-closure long-term stage  Include detailed analogue projects’ specific risks used in the risk collation
Fig. 2: Methodology for developing the risk register process and formation of the risk register
Electronic copy available at: https://ssrn.com/abstract=4282955