Fact Sheet for Geologic Sequestration and Injection of Carbon Dioxide: Subparts RR and UU

Fact Sheet for Geologic Sequestration and oEPA
Injection of Carbon Dioxide: Subparts RR and UU K—
Greenhouse Gas Reporting Program
Action
• On December 1, 2010, the U.S. Environmental Protection Agency (EPA) issued a final rule that
requires facilities that conduct geologic sequestration of carbon dioxide (C02) and all other
facilities that inject C02 underground to report greenhouse gas (GHG) data to EPA annually.
• This rule amends the regulatory framework for the GHG Reporting Program. This Program
requires reporting of GHG emissions and other relevant information from certain source
categories in the United States, including suppliers of C02. Subpart RR of this rule requires
GHG reporting from facilities that inject carbon dioxide (C02) underground for geologic
sequestration, and subpart UU requires GHG reporting from all other facilities that inject C02
underground for any reason, including enhanced oil and gas recovery.
• This rule requires facilities conducting geologic sequestration of C02 to develop and implement
an EPA-approved site-specific monitoring, reporting and verification (MRV) plan, and to report
the amount of C02 sequestered using a mass balance approach. This rule is complementary to
and builds on EPA's Underground Injection Control (UIC) permit requirements.
• EPA has designed this rule so that facilities can comply with the reporting requirements without
disrupting or delaying normal operations.
• For those facilities that inject C02 for geologic sequestration (subpart RR), the estimated annual
cost of reporting for each facility is $320,000 for deep saline formation projects.
• For facilities that inject C02 underground for enhanced oil and gas recovery or any other purpose
other than for geologic sequestration (subpart UU), EPA estimates the annual cost of reporting to
be $4,000.
Background
• Geologic sequestration is the long-term containment of C02 in subsurface geologic formations
and is a key component of a set of climate change mitigation technologies known as carbon
dioxide capture and sequestration (CCS). CCS has the potential to enable large emitters of C02
such as coal fired power plants to significantly reduce GHG emissions.
• The data obtained through this rule will inform Agency policies and decisions under the Clean
Air Act related to the use of carbon dioxide capture and geologic sequestration (CCS) for
mitigating GHG emissions.
o Subpart RR information will enable EPA to monitor the growth and effectiveness of
geologic sequestration (and therefore CCS) as a GHG mitigation technology over time
and to evaluate relevant policy options.
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o Under subpart UU, EPA will be able to evaluate data obtained on C02 received for
injection in conjunction with data obtained from subpart PP on C02 supplied to the
economy.
Overview of Reporting Requirements
• Under subpart RR, facilities that conduct geologic sequestration by injecting C02 for long-term
containment in subsurface geologic formations, including UIC Class VI wells, are required to:
o Report basic information on C02 received for injection,
o Develop and implement an EPA-approved site-specific MRV plan,
o Report the amount of C02 geologically sequestered using a mass balance approach and
annual monitoring activities.
• Under subpart UU, all other facilities that inject C02 underground such as for enhanced oil and
gas recovery or any other purpose, are required to:
o Report basic information on C02 received for injection.
• Facilities that report under subpart RR for a well or group of wells are not required to report
under subpart UU for that well or group of wells.
• Facilities that conduct enhanced oil and gas recovery are not required to report geologic
sequestration under subpart RR unless (1) the owner or operator chooses to opt-in to subpart RR
or, (2) the facility holds a UIC Class VI permit for the well or group of wells used to enhance oil
and gas recovery.
• Geologic sequestration R&D projects will be granted an exemption from subpart RR. Projects
receiving a subpart RR R&D exemption are required to report basic information on C02 received
under subpart UU.
• All facilities that conduct geologic sequestration (subpart RR) are required to submit annual
reports to EPA by September 30, 2012 reporting basic information on C02 received in 2011. In
subsequent years, annual reports are due to EPA by March 31. These facilities will add data to
their annual reports on the amount of C02 that is geologically sequestered and annual monitoring
activities once their EPA-approved MRV plans are implemented.
• All other facilities that inject C02 underground (subpart UU), such as for enhanced oil and gas
recovery or any other purpose, are required to submit annual reports to EPA by September 30,
2012 reporting only basic information on C02 received in 2011. In subsequent years, annual
reports are due to EPA by March 31.
Relationship to Other Regulations
• This rulemaking does not change any of the requirements to obtain or comply with a UIC permit
for facilities that are subject to EPA's UIC program under the Safe Drinking Water Act.
• Through a separate rulemaking effort, EPA finalized federal requirements under the UIC program
for Class VI geologic sequestration wells to ensure protection of underground sources of drinking
water. For more information on the UIC Class VI rule visit:
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water.epa.gov/tvpe/groundwater/uic/wells sequestration.cfm. Subparts RR and UU fulfill a
separate but complementary goal which is to quantify the total amount of C02 sequestered and to
confirm that it remains sequestered and is not emitted to the atmosphere over the long term.
Public Involvement
• A 60-day public comment period on the proposed rule was open from April 12, 2010 to June 11,
2010. EPA also conducted a public hearing in Arlington, VA on April 19, 2010 and had an open-
door policy for discussing the proposed rule.
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 go to Rule Help Center, and then select Contact Us.
•	For background information about GHGs and climate change science and policy, please see
EPA's climate change Web site at: www.epa.gov/climatechange.
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