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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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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The image below displays the Subpart RR Overview page:

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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

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.

This web site is maintained by a contractor to the U.S. Environmental Protection Agency (RY2019.R.01)