Using e-GGRT to Submit Your Subpart RR Project Exemption Request or MRV Plan

This page provides an overview of sub-topics that are central to Subpart RR - Geologic Sequestration of Carbon Dioxide.

If you reported for the previous reporting year, the Agency has carried some of your data from last year into the current reporting year to reduce the reporting burden. It is still your responsibility to review and ensure that all of the information in your submission is correct, but the Agency believes that most of the data that is carried forward is unlikely to change significantly from year to year. For more information about carry forward data, please see the Carry forward of data from previous submissions help content

Subpart RR - Geologic Sequestration of Carbon Dioxide reporting:

The end of this page contains links you can use for more information on these topics.

Overview

Under Subpart RR, facilities that conduct geologic sequestration by injecting a CO2 stream for long-term containment in subsurface geologic formations, including Underground Injection Control (UIC) Class VI wells, are required to:

  • Report basic information on CO2 received for injection (40 CFR 98.446).
  • Develop and implement an EPA-approved site-specific monitoring, reporting, and verification (MRV) plan (40 CFR 98.448).
  • Report the amount of CO2 geologically sequestered using a mass balance approach and annual monitoring activities (40 CFR 98.446).

Facilities that conduct enhanced oil and gas recovery are not required to report geologic sequestration under Subpart RR unless:

  • the owner or operator chooses to opt-in to Subpart RR (40 CFR 98.440(c)(1)), or
  • the facility holds a UIC Class VI permit for the well or group of wells used to enhance oil and gas recovery (40 CFR 98.440(c)(2))

R&D projects will be granted an exemption from Subpart RR provided they meet the eligibility requirements (40 CFR 98.440). EPA will consider a project eligible if it meets the Subpart RR definition of an R&D project: “a project for the purpose of investigating practices, monitoring techniques, or injection verification, or engaging in other applied research, that will enable safe and effective long-term containment of a CO2 stream in subsurface geologic formations, including research and short duration CO2 injection tests conducted as a precursor to long-term storage” (40 CFR 98.449).

Submissions Schedule:

  1. Register your facility and submit your Certificate of Representation 60 days before making a submission under Subpart RR (according to the provisions in 40 CFR 98.4).

  2. Submit a proposed MRV plan, MRV plan submission extension request (up to 180 day extension), or R&D project exemption request through e-GGRT by the following deadlines (according to the provisions in 40 CFR 98.448(b)):

    • You must submit a proposed MRV plan to EPA by June 30, 2011 if you were issued a final Underground Injection Control permit authorizing the injection of CO2 into the subsurface on or before December 31, 2010. You will be allowed to request one extension of up to an additional 180 days in which to submit your proposed MRV plan.
    • You must submit a proposed MRV plan to EPA within 180 days of receiving a final Underground Injection Control permit authorizing the injection of CO2 into the subsurface. If your facility is an offshore facility not subject to the Safe Drinking Water Act, you must submit a proposed MRV plan to EPA within 180 days of receiving authorization to begin geologic sequestration of CO2. You will be allowed to request one extension of the submittal date of up to an additional 180 days.
    • If you are injecting a CO2 stream in subsurface geologic formations to enhance the recovery of oil or natural gas and you are not permitted as Class VI under the Underground Injection Control program, you may opt to submit an MRV plan at any time.
    • If EPA determines that your proposed MRV plan is incomplete, you must submit an updated MRV plan within 45 days of EPA notification, unless otherwise specified by EPA.

  3. Submit annual reports through e-GGRT (40 CFR 98.446).

To access these features, login to e-GGRT, and select the facility from the ACCESS YOUR FACILITIES table.

Next, click on "Subpart RR (MRV): Geological Sequestration of Carbon Dioxide" link.

Click this link to expand


The Subpart RR Overview page will be displayed.

Click this link to expand

R&D Project Exemption Request

The following information is required when submitting an R&D Project Exemption Request:

  • Name of Project
  • Estimated CO2 injection Start Date
  • Estimated CO2 injection End Date
  • Class of UIC permit
  • Date of submission of the UIC permit application
  • UIC permit Start Date
  • UIC permit End Date
  • Source and type of funding
  • Research Purpose
  • Proposed CO2 injection volumes

MRV Plan Extension Request

Subpart RR allows facilities to request one extension of up to an additional 180 days in which to submit a proposed MRV plan. The following information is required when submitting an MRV Plan Extension Request:

  • Name of Project
  • Date of final UIC permit authorizing subsurface injection of CO2
  • Number of days requested for extending the MRV plan due date (180 days maximum)

Proposed MRV Plan Submission

Subpart RR requires you to develop and submit a proposed MRV plan for monitoring, reporting, and verification of geologic sequestration at the facility. Your proposed MRV plan must contain the following components:

  • Delineation of the maximum monitoring area and the active monitoring areas
  • Identification of potential surface leakage pathways for CO2 in the maximum monitoring area and the likelihood, magnitude, and timing, of surface leakage of CO2 through these pathways
  • A strategy for detecting and quantifying any surface leakage of CO2
  • A strategy for establishing the expected baselines for monitoring CO2 surface leakage
  • A summary of the considerations you intend to use to calculate site-specific variables for the mass balance equation
  • Well permitting information
  • Proposed date to begin collecting data for calculating total amount sequestered according to equation RR-11 or RR--12 of Subpart RR

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See Also

Screen Errors
Subpart RR R&D Project Exemption Request
Subpart RR MRV Plan Extension Request
Subpart RR Proposed MRV Plan Submission

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