Using e-GGRT to Prepare Your Subpart RR Report

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

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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:

  • 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)):

    • If you were issued a final UIC permit authorizing the injection of CO2 into the subsurface on or before December 31, 2011, you must submit a proposed MRV plan, MRV plan extension request, or R&D project exemption request by June 30, 2012
    • If you were issued a final UIC permit authorizing the injection of CO2 into the subsurface on or after January 1, 2012, you must submit a proposed MRV plan, MRV plan extension request, or R&D project exemption request within 180 days of receiving a final UIC permit
    • 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 UIC Program, you may opt to submit an MRV plan at any time

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

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

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