Using e-GGRT to Prepare Your Subpart RR Report

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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 of Subpart RR

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:

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Facilities that conduct geologic sequestration of carbon dioxide (CO2) must report basic information on the amount of CO2 received for injection; develop and implement an EPA-approved

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monitoring, reporting, and verification (MRV) plan

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; and report the amount of

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CO2 sequestered using a mass balance approach and annual monitoring activities

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.

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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).

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Submissions Schedule:

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Major elements of the MRV Plan include:

  • Delineation of the monitoring areas
  • Identification of potential surface leakage pathways for CO2
  • Strategy for detecting and quantifying surface leakage of CO2
  • Strategy for establishing the expected baseline for monitoring CO2 surface leakage
  • Site-specific variables

Once the facility has an approved MRV Plan, data that are required to be reported annually include:

  • Amount of CO2 received, data used to calculate the amount, and the source of the received CO2 (if known)
  • Mass balance equation inputs (amounts of CO2 injected, CO2 produced, CO2 emitted by surface leakage, CO2 emitted from equipment leaks and vented CO2 emissions) and the amount of CO2 sequestered
  • An annual monitoring report (including a narrative history of the monitoring efforts conducted over the previous calendar year, a description of any changes to the monitoring program, a narrative history of any monitoring anomalies, and a description of any surface leakage of CO2)

These data should be reported using the Subpart RR reporting module of e-GGRT.

For further detail on reporting Subpart RR data in e-GGRT, you should review the Subpart RR RY16 Webinar.

Please contact the GHGRP Help Desk if you have questions which are not addressed by the above training content.

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R&D Project Exemption Request

The following information is required when submitting an R&D 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

The following information is required when submitting an MRV Plan Extension Request:

  • Name of Project
  • Date of final UIC permit (or legal instrument for an offshore facility not subject to the Safe Drinking Water Act) 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
  • 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

This web site is maintained by a contractor to the U.S. Environmental Protection Agency (RY2023.R.01)