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• Delineation of the maximum monitoring area and the active monitoring areas. The first period for your active monitoring area will begin from the date determined in your MRV plan through the date at which the plan calls for the first expansion of the monitoring area. The length of each monitoring period can be any time interval chosen by you that is greater than 1 year.
• 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. This includes, but is not limited to, considerations for calculating equipment leakage and vented emissions between the injection flow meter and injection well and/or the production flow meter and production well, and considerations for calculating CO₂ in produced fluids.
• Permitting information:
  • If a well is permitted under the Underground Injection Control program, for each injection well, report the well identification number used for the Underground Injection Control permit and the Underground Injection Control permit class.
  • If the well is not yet permitted, and you have applied for an Underground Injection Control permit, report the well identification numbers in the permit application. If you are submitting your Underground Injection Control permit application as part of your proposed MRV plan, you must notify EPA when the permit has been approved.
  • If an offshore well is not subject to the Safe Drinking Water Act, for each injection well, report any well identification number and any identification number used for the legal instrument authorizing geologic sequestration.
  • If you are an offshore facility not subject to the Safe Drinking Water Act, and are submitting your application for the legal instrument authorizing geologic sequestration as part of your proposed MRV plan, you must notify EPA when the legal instrument authorizing geologic sequestration has been approved.
• Proposed date to begin collecting data for calculating total amount sequestered according to equation RR-11 or RR-12 of Subpart RR. This date must be after expected baselines as required by 40 CFR 98.448(a)(4) of this section are established and the leakage detection and quantification strategy as required by 40 CFR 98.448(a)(3) of this section is implemented in the initial active monitoring area.
• EPA has provided information in the Subpart RR General Technical Support Document on the technical evaluation of MRV plans, including illustrative examples describing the types of information that may be included in the MRV plan to fulfill the regulatory requirements at 40 CFR 98.448. This includes delineating the monitoring area, both the maximum area that the CO₂ plume is predicted to cover and how monitoring can be phased in over this area; selecting leakage detection systems that are suitable for the site; determining and verifying that a leak has occurred; identifying baseline conditions; and quantifying a CO₂ leak once a leak has been verified. The Subpart RR General Technical Support Document is available at: http://www.epa.gov/climatechangeghgreporting/documents/emissionspdf/downloads102010/Subpart-RR-UU_TSD.pdfEPA has decided to undertake an action to determine the confidentiality status for data elements reported under Subpart RR. Since Subpart RR proposed MRV plans and R&D Project Exemption Requests likely will be submitted before the final confidentiality determinations for Subpart RR are made, EPA will evaluate individual confidential business information (CBI) claims regarding these submissions on a case-by-case basis. The reporter should indicate any CBI claims in the submission.

Submitting an MRV Plan Proposal

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