Carbon Dioxide Injection
and Geologic Sequestration
United States
Environmental Protection
Proposed Rule: Subpart RR, Mandatory Reporting of Greenhouse Gases
Under the proposed subpart RR of the Mandatory Reporting of Greenhouse Gases (GHGs) rule, EPA is
proposing reporting requirements for facilities that inject carbon dioxide (CO2)for the purpose of
geologic sequestration (GS) or to enhance oil and gas recovery.
How Is This Source Category Defined?
EPA is proposing that all facilities that inject CO2 for purposes of enhanced oil and gas recovery or for
long-term geologic sequestration report basic information on CO2 injected underground. In this proposal,
"CO2 injection facilities" are defined as a well or a group of wells that inject CO2 into the subsurface or
sub-seabed geologic formations. This definition would encompass both onshore and offshore facilities.
For those facilities that inject CO2 for the purpose of long-term geologic sequestration, additional
reporting and monitoring would be required. "Geologic sequestration facilities" are a subset of CO2
injection facilities that inject CO2 specifically for the purpose of long-term containment of CO2 in
subsurface geologic formations.
Geologic sequestration research and development projects would be required to report basic data on
injected CO2, but would not be required to monitor or report the additional information required for
geologic sequestration. These projects could choose to opt-in to the geologic sequestration reporting and
monitoring requirements however. Geologic sequestration research and development projects are those
that receive federal funding for the purpose of researching the practices and monitoring techniques that
will enable safe and effective long-term sequestration of CO2 in the subsurface and that are not
commercial or demonstration projects.
This source category does not include certain facilities that store CO2 above ground; temporarily store
CO2 below ground; transport or distribute CO2; or that store CO2 in cement, precipitated calcium
carbonate, or any other application that does not involve injection of CO2 into the subsurface.
What GHGs Would Be Reported?
EPA is proposing that all facilities that inject CO2 for purposes of enhanced oil and gas recovery or long-
term geologic sequestration report basic information on CO2 injected underground.
In addition, geologic sequestration facilities that inject CO2 for the purpose of long-term containment in
subsurface geologic formations, including facilities that opt-in to the additional monitoring and reporting
requirements for these facilities, would report the amount of CO2 geologically sequestered using a mass
balance approach. Geologic sequestration facilities would develop and (after approval by EPA)
implement a monitoring, reporting, and verification (MRV) plan for determining the amount of CO2 that
is sequestered.
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What Information Would Be Reported?
All facilities that inject CO2 for purposes of enhanced oil and gas recovery or long-term geologic
sequestration would be required to report the following annually:
• The mass of CO2transferred onsite from offsite sources.
• The mass of CO2 injected into the subsurface.
• The source of the CO2, from the following categories:
o CO2 production wells
o Electric generating units
o Ethanol plants
o Pulp and paper mills
o Natural gas processing
o Other anthropogenic sources
o Unknown
In addition to the reporting requirements listed above, geologic sequestration facilities that inject CO2 for
the purpose of long-term containment in subsurface geologic formations would be required to submit an
MRV plan to EPA, implement the approved plan, and report annually the following:
• The mass of fugitive and vented CO2 emissions from surface equipment at the facility, if not
reported under the proposed Petroleum and Natural Gas Systems (subpart W) of the MRR
• The mass of CO2 produced with oil or gas, if applicable.
• The mass of CO2 emitted to the surface from the subsurface, if applicable.
• The mass of CO2 sequestered in the subsurface geologic formation.
How Would GHG Data Be Calculated?
Under the proposal, all facilities that inject CO2 for the purposes of enhanced oil and gas recovery or
geologic sequestration would calculate the following:
• The mass of CO2 transferred onsite from offsite sources using mass or volumetric flow meters
and based on the CO2 concentration in the flow.
• The mass of CO2 injected using mass or volumetric flow meters and based on the CO2
concentration in the flow.
Where flow meters are used to calculate data under this proposal, CO2 flow and concentration data would
be collected quarterly and aggregated to an annual quantity. To minimize the purchase and installation of
new equipment, facilities subject to the Underground Injection Control (UIC) program could utilize the
CO2 flow meters installed for purposes of compliance with their existing UIC permits in order to calculate
the CO2 injection data.
Each geologic sequestration facility (including facilities that opt-in to these requirements) would also
develop and implement an EPA-approved monitoring, reporting, and verification (MRV) plan which
would include:
• An assessment of the risk of CO2 leakage to the surface.
• A strategy for detecting and quantifying any CO2 leakage to the surface.
• A strategy for establishing pre-injection environmental baselines.
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• A summary of considerations made to calculate site-specific variables for the mass balance
equation.
Once its site-specific MRV plan is implemented, a geologic sequestration facility would calculate the
following:
• The mass of fugitive and vented CO2 emissions from surface equipment at the facility using
methodologies in proposed subpart W (Petroleum and Natural Gas Systems) of the MRR.
• If applicable, the mass of CO2 produced from oil or gas production wells
• If applicable, the mass of any CO2 emitted to the surface from the subsurface.
• The mass of CO2 sequestered using a mass balance approach.
For More Information
Information on the proposed amendment and supporting background information is available
electronically at www.regulations.gov. EPA's electronic public docket and comment system. The Docket
ID number is: EPA-HQ-OAR-2009-0926. Instructions on submitting comments can be found in the
preamble and on the EPA Web site at: www.epa.gov/climatechange/emissions/ghgrulemaking.html.
Information is also available at the EPA Docket Center (EPA/DC) Public Reading Room. Please call 202-
566-1744 between the hours of 8:30 A.M. and 4:30 P.M. Eastern Time for more information.
For additional information about this rulemaking, visit EPA's Web site at:
www.epa.gov/climatechange/emissions/ghgrulemaking.html. If you have questions that cannot be
answered through the Web site, please contact us by filling out the form at
www.epa.gov/climatechange/emissions/ghgrule contactus.htm.
For background information about GHGs and climate change science and policy, please see EPA's
climate change Web site at: www.epa. gov/climatechange.
This document is provided solely for informational purposes. It does not provide legal advice, have
legally binding effect, or expressly or implicitly create, expand, or limit any legal rights, obligations,
responsibilities, expectations, or benefits in regard to any person. This information is intended to assist
reporting facilities/owners in understanding key provisions of the final rule.
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