ANALYSIS OF THE COSTS ASSOCIATED WITH 

SUBPART RR (GEOLOGIC SEQUESTRATION OF 

CARBON DIOXIDE) REPORTING UNDER THE EPA 

GREENHOUSE GAS REPORTING PROGRAM

Prepared by:

Advanced Resources International, Inc.

Arlington, VA USA

Prepared for:

U.S. Environmental Protection Agency

October 2015
1

BACKGROUND AND OBJECTIVE

The primary objective of this paper is to summarize estimated burden and cost estimates for 

subpart RR of the Greenhouse Gas Reporting Program (GHGRP). It is based upon analysis 

performed for the U.S. Environmental Protection Agency (EPA) related to monitoring, reporting, 

and verification (MRV) technologies and costs, as applied to carbon dioxide enhanced oil 

recovery (CO2-EOR) operations and CO2 sequestration/storage in deep saline formations. It is 

intended that this document will provide background information to establish the basis for the 

EPA’s Greenhouse Gas Reporting Program’s (GHGRP) estimates of the costs associated with 

compliance with subpart RR of the GHGRP. 

ESTIMATION OF POTENTIAL SUBPART RR MRV COSTS

For this assessment, potential MRV activities are grouped into various categories based on 

activity type. These categories are:

• Develop MRV plans and update models

• Convert some existing wells to monitoring wells

• Install new shallow monitoring wells

• Perform soil flux/vadose zone monitoring

• Perform micro-seismic monitoring 

• Special-case plugging and abandonment (P&A) 

• Drill new deep monitoring wells

• Perform 3D seismic

• Perform vertical seismic profiling (VSP)/cross-well seismic

• Perform eddy covariance/ Color Infrared Orthoimaging (CIR) monitoring

• Conduct cased hole logging

• Replace tubulars/wellhead/packers in existing wells

• Conduct mechanical integrity testing (MIT) program 

• Monitor surface pressure, temperatures, rates, gas composition, and corrosion

• Monitor subsurface pressure and fluid sampling

Costs are sourced from previous costs and economic impact studies, industry costs for the 

injection of CO2 for CO2-EOR, and from active (or recently active) CO2 storage projects. 

Specifically, the cost estimates developed for this white paper build upon previous work, 

including EPA’s cost analyses developed as part of its final Class VI rule;1 the actual costs 

incurred with the injection of CO2 in a deep saline aquifer for two Southeast Regional Carbon 

Sequestration Partnership (SECARB) projects;

2 the U.S. Department of Energy (DOE)/National 

Energy Technology Laboratory (NETL) CO2 Saline Storage Cost Model, designed to estimate 

 1 U.S. Environmental Protection Agency, Geologic CO2 Sequestration Technology and Cost Analysis, 

EPA 816-R10-008 (November 2010), and U.S. Environmental Protection Agency, Cost Analysis for the 

Proposed Federal Requirements Under the Underground Injection Control Program for Carbon Dioxide 

Geologic Sequestration Wells (Proposed GS Rule): EPA 816-R10-013 (November 2010)

2 http://www.secarbon.org/files/anthropogenic-test.pdf
2

the costs associated with the storage of captured CO2 in a subsurface geologic reservoir;

3

 and, 

where applicable, the drilling and conversion cost algorithms for CO2-EOR developed by 

Advanced Resources for DOE/NETL.4

For this assessment, the estimated costs associated with potential MRV activities are discussed 

below.

Develop MRV Plan and Update Models

Under subpart RR, a facility will need to submit an MRV plan. For purposes of this analysis, it 

was assumed that a total of 320 hours of geologists’ and engineers’ time would be required in 

the development of this plans. Periodic updates to the simulation models used for the prediction 

of plume and pressure front migration are assumed to take place every two years during 

injection, and every four years post-injection, requiring 320 hours of geologists’/and engineers’ 

time for each update.

Convert Some Existing Wells to Monitoring Wells

This applies to both injection and production wells that may need to be converted to monitoring 

wells. This only applies to situations where wells already exist.

The estimated cost of a well conversion is based on the costs incurred as part of the 

DOE/NETL-funded SECARB Phase III research project at Citronelle, Alabama to convert an 

existing producing well into a monitoring well (to include above zone pressure monitoring and 

fluid sampling). These costs were assumed to be $299,000 per monitoring well. In addition, 16 

hours of labor of a geologist/engineer was assumed for carrying out this task. Ten monitoring 

wells were assumed in this analysis.

Install New Shallow Monitoring Wells

Shallow monitoring well costs assume newly constructed monitoring locations, consisting of one 

sampling well at each location (potentially sampling aquifers at different depths). The number of 

shallow monitoring locations for a storage field may vary depending on geochemistry and 

identification of leakage risk areas including abandoned wells. A monitoring frequency of four 

times per year is assumed, and each well installation is assumed to monitor approximately 200

acres. These wells are assumed to be 500 feet deep.

The estimated cost of drilling and equipping for a new shallow monitoring well is based on the 

costs incurred as part of the DOE research project at Citronelle. These costs were assumed to 

be $70,000 per monitoring well. In addition, 16 hours of labor of a geologist/engineer was 

assumed for carrying out this task. Four shallow monitoring wells were assumed in this analysis. 

In addition, 8 hours of labor of a geologist/engineer was assumed to be associated with the 

planning of these wells. Note that some projects may already have existing shallow monitoring 

wells.

 3 http://www.netl.doe.gov/research/energy-analysis/analytical-tools-and-data/co2-saline-storage

4 U.S. Department of Energy/National Energy Technology Laboratory, Acquisition and Development of 

Selected Cost Data for Saline Storage and Enhanced Oil Recovery (EOR) Operations, DOE/NETL2014/1658, prepared by Advanced Resources International, May 14, 2014
3

Perform Soil Flux/Vadose Zone Monitoring

Shallow subsurface monitoring may be conducted in the vadose zone (the unsaturated zone 

between the ground surface and the top of the water table). CO2 soil flux is a measurement of 

the rate of CO2 mass that is emitted from a given soil surface area. The estimated costs are 

based on the costs incurred as part of the SECARB Phase III research project at Citronelle, and 

assume the purchase of two mobile soil flux monitoring units and installation of 15 monitoring 

stations and one year of monthly background monitoring. This should cover 40-640 acres.

The equipment required was assumed to cost $38,000, $30,000 for the soil flux equipment and 

$8,000 for the vadose zone monitoring equipment. In addition, a total of 40 hours of geologists’ 

and engineers’ time was assumed to be required to install this equipment. Four stations were 

assumed, equipped for performing some combination of micro-seismic, soil flux/vadose zone 

monitoring, cross-well seismic/VSP equipment and/or eddy covariance or CIR monitoring. 

Annual monitoring costs assume monthly monitoring during injection. These costs are assumed 

to be $13,400 for the soil flux monitoring and $3,600 for the vadose zone monitoring. A total of 

16 hours of geologists’ and engineers’ time was assumed to be required to perform this 

monitoring. After injection has ceased, monitoring frequency is reduced by half.

Perform Micro-Seismic Monitoring

Micro-seismic surveys, using either surface or wellbore deployed geophones, is a technology for 

monitoring changes in in situ stress in the subsurface. For this analysis, based the experiences 

of the In Salah project, the Citronelle project, and other CCS research projects, the cost of 

installation of a single dedicated micro-seismic monitoring well was assumed at $1,000,000

along with about 80 hours of labor.5 The breakdown of these costs are roughly as follows:

• Single 500 meter, uncased borehole -- approximately $750,000

• 6-8 geophones, cable, etc. -- approximately $200,000

• Surface equipment -- approximately $20,000

• Installation costs -- approximately -- $50,000.

This assumes a dedicated micro-seismic well, like the two dedicated micro-seismic wells at the 

ADM Decatur site, separate from the other MRV wells. Four micro-seismic stations were 

assumed. The micro-seismic installation was assumed to monitor one square mile (640 acres).

Annual operating costs are for continuous micro-seismic monitoring in this single well. The costs 

associated with micro-seismic monitoring are assumed to be $20,000 per well per year, with 20 

hours of associated geologist/engineer labor. After injection has ceased, the frequency of microseismic monitoring is reduced by half.

Special-Case P&A 

For purposes of this analysis, it was assumed that the initial site characterization work for 

storage operations, as specified in the subpart RR MRV plan, could identify some wells, either 

existing or previously plugged and abandoned (P&A) that may need to be re-plugged. It was 

assumed that the costs to re-P&A these wells would be $200,000 each, and would involve 

 5 Personal communication, Tom Daley, Lawrence Berkeley National Laboratory, September 30, 2015
4

perforating uncemented casing, squeeze cementing the well, running logs, and cementing the 

inside of well to the surface. An additional 20 hours of engineer/geologist time was assumed per 

well for these activities. We assumed that 5 such wells would need to be re-plugged.

Drill New Deep Monitoring Wells

For purposes of this analysis, it was assumed that three new monitoring wells at CO2-EOR 

projects would be drilled. The costs of drilling these wells were assumed to be about 

$1,000,000, with 8 hours of associated labor for planning.

Perform 3D seismic

Three dimensional surface seismic surveys (3D seismic) are a mature technology, frequently 

used in the petroleum industry for structural imaging and reservoir characterization. 3D seismic 

surveys have been in use in the petroleum industry since the 1920s and have been successfully

deployed at CCS projects such as Sleipner and Weyburn. 

The costs assumed for 3D seismic are for the background acquisition, processing and 

interpretation of a 3D seismic survey. It was assumed that each 3D seismic survey would cost 

$1,000,000 per square mile survey (based on the 2010 EPA Economic Impact Analysis for the 

Class VI rule), along with an additional 80 hours of geologist and engineer labor to oversee. A 5 

square mile survey was assumed in this analysis.

Operational phase costs are for repeats of the 5 square mile survey, every 3 years, with timelapse interpretation to image the CO2 plume, at the same costs and labor burden as the initial 

survey. After injection has ceased, the frequency of the 3D seismic is reduced to once every 5 

years.

Perform Vertical Seismic Profiling (VSP)/Cross-Well Seismic

Where applicable, vertical seismic profiling (VSP) operates in the same fashion as surface 

seismic except that the geophones are strung vertically in a wellbore instead of deployed on the 

surface. VSP can be used to develop a local time-depth relationship, correlated with log data, to 

assist in horizon selection, and corrects for anomalies that often occur from surface seismic. 

Cross-well seismic is conducted between wells with the seismic source and receivers placed in 

those wellbores. This seismic method can be used to monitor for formation velocity changes 

due to CO2 saturation.

The costs of VSP and cross-well seismic are comparable, based on experience from the 

SECARB Phase III research project at Citronelle. Estimated costs are for the initial background 

acquisition, processing and interpretation of one seismic survey, costing $380,000 per survey, 

applied to four distinct baseline surveys (some combination of VSP and cross-well). Another 40 

hours of geologist labor is assumed for oversight per survey.

Operational phase costs are for repeats of all four surveys every three years, with time-lapse 

interpretation to image the CO2 plume, at the same costs and labor burden as the initial survey.

After injection has ceased, the frequency of the VSP/cross-well seismic is reduced to repeats of 

each survey every five years.

Perform Eddy Covariance and Color Infrared Ortho-imaging (CIR) Monitoring
5

For purposes of this analysis, two methods are assumed to be used to monitor for surface CO2

leakage.

Eddy covariance (EC) is a micrometeorological technique that allows a non-invasive 

measurement of the exchange between the atmosphere and a several hectare area of forest, 

shrub land, or grassland. Flux measurements are widely used to estimate heat, water, and CO2

exchange.

The cost estimates are for a single monitoring site, and are based on the 2010 EPA Economic 

Impact Analysis for the Class VI rule. The number of eddy covariance locations for a storage 

field may vary depending on terrain, identified leakage risk and atmospheric conditions. One 

station is assumed to be capable of monitoring approximately one injection spacing (40 to 640 

acres). Each station was estimated to cost $105,000, with 16 labor hours to install. For this 

assessment, we assumed four stations. Annual costs for monitoring were assumed to be 

$10,000, with 16 hours of associated geologist/engineer labor. After injection has ceased, 

monitoring frequency is reduced by half.

Color Infrared Ortho-imaging (CIR) monitoring utilizes color-infrared cameras on aircraft (Aerial 

CIR) to image surface vegetation where shifts in the CIR color image can indicate stressed 

vegetation. We assume that this technology would be utilized to monitor a wide area. Costs, 

which are based on the 2010 EPA Economic Impact Analysis for the Class VI rule, for initial 

aerial surveys are $10,000 per square mile. We assume five square miles are surveyed as a 

baseline with 40 hours of associated geologist/engineer labor. During the injection we repeat the 

5 square mile survey which costs $6,250 per square mile plus $5,000 for mobilization with 16

hours of associated geologist/engineer labor. After injection has ceased, monitoring frequency is 

reduced by half.

Conduct Cased-Hole Logging

Cased-hole pulsed neutron wireline logging tools were developed to characterize productive 

“behind pipe” pay zones in oil and gas fields. However the tool has demonstrated promise for 

precise CO2 saturation measurement in brine-bearing porous zones. Estimated costs are for a 

single baseline pulsed neutron log acquisition and interpretation and a single annual repeat log 

per monitoring well (13 in total). They are based on the experience from the SECARB Phase III 

research project at Citronelle, and are assumed to cost $15,000 each, with an associated four

hours of labor for each log. Logs are performed on each monitoring well once initially and 

annually during injection. After injection has ceased, cased-hole pulsed neutron logging takes 

place every other year.

Replace Tubulars/Wellhead/Packers in Existing Wells

While existing wells can be converted to CO2 injection wells, some facilities may choose to 

replace the wellhead, injection tubing, and packer on each well converted. This was assumed 

to cost $195,000 per well, based on the experience from the SECARB Phase III research 

project at Citronelle. An additional 16 hours of engineer labor was also assumed per well.

Conduct Mechanical Integrity Testing (MIT) Program 
6

Mechanical Integrity Testing (MIT) involves a series of tests performed to confirm the adequacy 

of the construction of an injection well and to detect problems within the well before leaks occur. 

MITs test for both internal (casing, tubing and packer) and external (cement bond) integrity. 

Cost estimates are for a single internal and external MIT on an injection well. These costs are 

based on the experience from the SECARB Phase III research project at Citronelle, and are 

assumed to be $15,000 per test, plus four hours of labor. These MITs are assumed to be 

performed initially prior to the start of injection, and every year thereafter during injection.

Monitor Surface Pressure, Temperatures, Rates, Gas Composition, and Corrosion

Pressure, temperature and rate data at various points, including the pipeline, pump, and 

wellhead, are generally monitored and recorded during EOR operations. However these gauges 

are often analog and require wellsite visitation for recording. For this analysis, digital gauges are 

assumed to be mounted on the wellhead of the CO2 injection well to continuously monitor for 

any pressure gain or loss in the casing-injection tubing annulus and to monitor injection. 

Monitoring pressures, temperatures and rates is a method to quickly assess CO2 buildup or 

drawdown, including migration out of zone. They are performed on each well. 

The costs assumed are for the purchase and installation of a single gauge plus satellite dish for 

data transmission per injection well. Annual costs are for gauge servicing. These costs are 

based on the experience from the SECARB Phase III research project at Citronelle. Initial 

installation costs are assumed to be $16,000, plus two hours of labor. Annual costs are 

assumed to be $1,600 per well, plus two hours of labor. This activity is assumed to occur during 

the injection phase.

In addition, gas composition is monitored at the custody transfer station (pipeline outlet). The 

composition of the injected CO2 stream is assumed to be confirmed using monitoring 

equipment, and the results recorded during injection. Gas composition monitoring equipment is 

estimated to cost $40,000, including installation, with eight hours of labor for planning and 

oversight. During injection, gas composition sampling is estimated to cost $4,000 annually, with 

four hours of associated labor. This activity is assumed to occur during the injection phase.

Finally, the potential for corrosion is monitored for each well material component used in the 

field. The objective of corrosion monitoring is early detection of deterioration of injection and well 

components (casing, tubing, or packer) that may cause loss of mechanical integrity. For this 

method, a coupon for each well material, which may be exposed to CO2, is monitored for the 

rate of corrosion. This coupon is a small, carefully manufactured piece of metal (such as a strip 

or ring) placed in an appropriate location in the injection well to measure corrosion. The coupon 

is made from the same material as the well’s casing or tubing. It is weighed, subjected to the 

well environment for a period of time, and then removed and weighed again. Coupons are 

typically placed in the well using wireline equipment.

The estimated costs for this study assume one coupon installation for every 10 to 20 injection 

well sites. We assume that most of the wellbores are constructed with the same materials. The 

costs of corrosion monitoring are estimated to be $1,300 per year per well, with 16 labor hours 

for initial installation, plus four hours annually for monitoring during injection. This activity is 

assumed to occur during the injection phase.
7

Monitor Subsurface Pressure and Temperature and Fluid Sampling

Downhole pressure and temperature monitoring is a classic technique for monitoring 

performance in natural gas storage, EOR, and ground water withdrawal/recharge. Monitoring inzone pressures and temperatures is a method to quickly assess CO2 buildup or drawdown, 

including migration out of zone.

Saline reservoir fluid sampling is a direct, quantitative tool with which to assess CO2 saturation 

in the subsurface and its effect on the reservoir’s geochemistry. Cost estimates are for 

acquisition and analysis of a single background reservoir fluid sample (taken via a slickline 

pressurized fluid sampling). Operational costs are for acquisition and analysis of an annual 

reservoir fluid sample.

These costs are based on the experience from the SECARB Phase III research project at 

Citronelle. The costs are for the purchase and installation of a single downhole pressure and 

temperature gauge tandem set and for annual downhole fluid sampling (wireline). Gauge 

equipment and installation costs plus one background fluid sample and analysis are estimated 

to be $31,000 plus eight hours of associated labor. Annual costs are for a single gauge pull, 

data download, gauge servicing, and re-installation and a single fluid sample and analysis; 

costing $13,500 per year, plus eight hours of associated labor. Gauge pulls and fluid sampling 

occur every two years after injection has ceased.

SCENARIOS FOR ESTIMATING PROJECT-SPECIFIC SUBPART RR MONITORING 

AND REPORTING COSTS

Subpart RR reporting costs are estimated based on two types of potential reporting facilities: 

• Projects permitted under Class II of EPA’s Underground Injection Control (UIC) program

(carbon dioxide enhanced oil recovery (“CO2-EOR”)).

• Projects permitted under Class VI of EPA’s UIC Program (assumed to be injecting into 

deep saline formations for purposes of the analysis).

The facility assumed for this set of estimates is based on a typical CO2-EOR project in the 

Permian Basin of West Texas, where the majority of ongoing CO2-EOR operations in the U.S. 

exist. This “representative” facility is comparable to that used in previous EPA assessments.

The geology and operational characteristics of this facility was also assumed for the deep saline 

formation case, although a greater area was assumed to accommodate a larger storage 

requirement. These characteristics are summarized in Table 1.
8

Table 1. Key Characteristics of the Subpart RR Facility Assumed for Estimating 

Costs

Subpart RR Facility: Deep Saline 

Formation

Subpart RR Facility: EOR

Maximum Monitoring 

Area

28,000 acres (44 sq m) 7,000 acres (10.9 sq m)

Well Depth 5,250 feet 5,250 feet

Capacity 74 million metric tons 18.5 million metric tons

# of wells 348 injection wells, 0 production wells 87 injection wells, 87 production wells

# of above-zone 

monitoring wells

20 4 converted producers

# of in-zone monitoring 

wells

20 converted producers, 8 new 6 converted producers, 3 new

Project Life, for 

annualizing costs

20 years of injection, 50 years of postinjection monitoring20 years of injection, 10 years of postinjection monitoring 

Of the potential MRV activities described above, Table 2 summarizes those MRV items 

assumed for a subpart RR MRV plan for a Class II/CO2-EOR operation for the baseline case 

assumed in this analysis. Table 3 summarizes the unit burden and cost estimates for geologic 

CO2 storage under subpart RR for a CO2-EOR project, for this baseline case. 

Similarly, Table 4 summarizes the baseline MRV items assumed for a subpart RR MRV plan for 

a deep saline formation project, which are assumed to be incremental to activities that may be 

associated with a Class VI permit. Table 5 summarizes the unit burden and cost estimates for 

geologic CO2 storage under subpart RR for a deep saline formation project based on these 

assumed activities. 
9

Table 2. CO2-EOR Operations: Subpart RR Baseline Scenario

MRV Activity EOR Operation

Develop MRV plans and update models YES

Convert some existing wells to monitoring wells YES

Perform soil flux/vadose zone monitoring YES

Special-case P&As YES

Perform eddy covariance/CIR monitoring YES

Replace tubulars/wellhead/packers YES

Conduct MIT program IN PLACE

Monitor surface pressure, temperatures, rates, 

gas composition, and corrosion YES

Monitor subsurface pressure and fluid sampling YES

YES = will be in MRV Plan

IN PLACE = already in place
10

Table 3. Baseline Unit Burden and Cost Estimates for CO2-EOR Project

Up Front Costs; Planning, Existing 

Well P&A Labor Hours Labor Dollars Capital Dollars TOTAL

 Site Characterization and Preparation 99 $8,713 $533,522 $542,235

 Convert Existing Wells to Monitoring Wells 21 $1,821 $240,953 $242,775

 Install New Shallow Monitoring Wells 0 $0 $0 $0

 Develop MRV Plans 41 $3,642 $0 $3,642

 Baseline Soil and Vadose Monitoring Installation 21 $1,821 $12,249 $14,070

 Micro-Seismic Monitoring Installation 0 $0 $0 $0

 Special-Case P&A 0 $0 $0 $0

 Drill New Monitoring Wells 3 $273 $242,444 $242,717

 Perform Baseline 3D Seismic 0 $0 $0 $0

 Perform Baseline Vertical Seismic Profiling (VSP)/Cross-Well 

Seismic 0 $0 $0 $0

 Install and Perform Baseline Eddy Covariance/CIR Monitoring 13 $1,155 $37,876 $39,031

Injection Wells 0 $0 $0 $0

 Replace Tubulars/Wellhead/Packers in Existing Wells 0 $0 $0 $0

Conduct Baseline Cased Hole Logging 0 $0 $0 $0

Conduct Baseline MIT Program 0 $0 $0 $0

Testing and Monitoring 58 $5,077 $158,288 $163,364

 Monitor Surface Pressure, Temperatures, Rates, Gas Composition, 

and Corrosion 32 $2,800 $115,819 $118,619

 Monitor Subsurface Pressure and Fluid Sampling 13 $1,184 $32,476 $33,660

 Perform Baseline Soil Flux/Vadose Zone Monitoring 12 $1,093 $9,993 $11,085

TOTAL 156 $13,790 $691,810 $705,600

Injection/Monitoring Phase (Annual) Labor Hours Labor Dollars O&M Dollars TOTAL

 RR Reporting 256 $22,600 $0 $22,600

 Update MRV Plans 256 $22,600 $0 $22,600

Conduct Cased Hole Logging 0 $0 $0 $0

Conduct MIT Program 

0 $0 $0 $0

Testing and Monitoring 755 $66,679 $524,150 $590,829 Monitor Surface Pressure, Temperatures, Rates, Gas Composition, 

and Corrosion 310 $27,402 $148,400 $175,802

 Monitor Subsurface Pressure and Fluid Sampling 166 $14,690 $175,500 $190,190

 Perform Baseline Soil Flux/Vadose Zone Monitoring 154 $13,560 $124,000 $137,560

 Perform Micro-Seismic Monitoring 0 $0 $0 $0

 Perform 3D Seismic 0 $0 $0 $0

 Perform Vertical Seismic Profiling (VSP)/Cross-Well Seismic 0 $0 $0 $0

 Perform Eddy Covariance/CIR Monitoring 125 $11,027 $76,250 $87,277

TOTAL 1011 $89,278 $524,150 $613,428

Post Injection (Annual) Labor Hours Labor Dollars O&M Dollars TOTAL

 RR Reporting 256 $22,600 $0 $11,300

 Update MRV Plans 256 $22,600 $0 $11,300

Testing and Monitoring 222 $19,638 $187,875 $207,513

Reporting 0 $0 $0 $0

 Monitor Subsurface Pressure and Fluid Sampling 83 $7,345 $87,750 $95,095

 Perform Baseline Soil Flux/Vadose Zone Monitoring 77 $6,780 $62,000 $68,780

 Perform Micro-Seismic Monitoring 0 $0 $0 $0

 Perform 3D Seismic 0 $0 $0 $0

 Perform Vertical Seismic Profiling (VSP)/Cross-Well Seismic 0 $0 $0 $0

 Perform Eddy Covariance/CIR Monitoring 62 $5,514 $38,125 $43,639

0 $0 $0 CCS P&A

Well Plugging 0 $0 $0 $0

Plug Injectors 0 $0 $0 $0

Plug Monitroing Wells 0 $0 $0 $0

Plug USDW Wells 0 $0 $0 $0

TOTAL 478 $42,238 $187,875 $218,813

Weighted Average O&M (based on years in 

category) 834 $73,598 $412,057 $481,889
11

Table 4. Deep Saline Formation: Subpart RR Baseline Scenario

MRV Activity

Deep Saline Formation

Operation

Develop MRV plans and update models YES

Convert some existing wells to monitoring wells IN PLACE

Install shallow monitoring wells IN PLACE

Perform soil flux/vadose zone monitoring IN PLACE

Perform micro-seismic monitoring IN PLACE

Special-case P&As IN PLACE

Drill new deep monitoring wells IN PLACE

Perform 3D seismic IN PLACE

Perform eddy covariance/CIR monitoring YES

Conduct cased hole logging IN PLACE

Conduct MIT program IN PLACE

Monitor surface pressure, temperatures, rates, 

gas composition, and corrosion IN PLACE

Monitor subsurface pressure and fluid sampling IN PLACE

YES = will be in MRV Plan

IN PLACE = already in place
12

Table 5. Baseline Unit Burden and Cost Estimates for Deep Saline Formation 

Projects: Subpart RR Baseline Scenario

Up Front Costs; Permitting, Existing 

Well P&A

Labor 

Hours Labor Dollars Capital Dollars TOTAL

 Site Characterization and Preparation 94 $8,295 $77,345 $85,640

 Convert Existing Wells to Monitoring Wells 0 $0 $0 $0

 Install New Shallow Monitoring Wells 0 $0 $0 $0

 Develop MRV Plans 72 $6,356 $0 $6,356

 Baseline Soil and Vadose Monitoring Installation 0 $0 $0 $0

 Micro-Seismic Monitoring Installation 0 $0 $0 $0

 Special-Case P&A 0 $0 $0 $0

 Drill New Monitoring Wells 0 $0 $0 $0

 Perform Baseline 3D Seismic 0 $0 $0 $0

 Perform Baseline Vertical Seismic Profiling (VSP)/Cross-Well Seismic 0 $0 $0 $0

 Install and Perform Baseline Eddy Covariance/CIR Monitoring 22 $1,938 $77,345 $79,283

Injection Wells 0 $0 $0 $0

 Replace Tubulars/Wellhead/Packers in Existing Wells 0 $0 $0 $0

Conduct Baseline Cased Hole Logging

0 $0 $0 $0

Conduct Baseline MIT Program 0 $0 $0 $0

Testing and Monitoring 4 $318 $11,250 $11,568 Monitor Surface Pressure, Temperatures, Rates, Gas Composition, and 

Corrosion 4 $318 $11,250 $11,568

 Monitor Subsurface Pressure and Fluid Sampling 0 $0 $0 $0

 Perform Baseline Soil Flux/Vadose Zone Monitoring 0 $0 $0 $0

 Perform Micro-Seismic Monitoring 0 $0 $0 $0

 Perform Baseline 3D Seismic 0 $0 $0 $0

 Perform Vertical Seismic Profiling (VSP)/Cross-Well Seismic 0 $0 $0 $0

 Install and Perform Baseline Eddy Covariance/CIR Monitoring 0 $0 $0 $0

TOTAL 98 $8,612 $88,595 $97,208

Injection/Monitoring Phase (Annual) 

Labor 

Hours Labor Dollars O&M Dollars TOTAL

 RR Reporting 1,024 $90,398 $0 $90,398

 Update MRV Plans 1,024 $90,398 $0 $90,398

Conduct Cased Hole Logging 0 $0 $0 $0

Conduct MIT Program 

0 $0 $0 $0

Testing and Monitoring 300 $26,520 $152,250 $178,770

 Monitor Surface Pressure, Temperatures, Rates, Gas Composition, and 

Corrosion 26 $2,260 $16,000 $18,260

 Monitor Subsurface Pressure and Fluid Sampling 0 $0 $0 $0

 Perform Baseline Soil Flux/Vadose Zone Monitoring 0 $0 $0 $0

 Perform Micro-Seismic Monitoring 0 $0 $0 $0

 Perform Baseline 3D Seismic 0 $0 $0 $0

 Perform Vertical Seismic Profiling (VSP)/Cross-Well Seismic 0 $0 $0 $0

 Install and Perform Baseline Eddy Covariance/CIR Monitoring 275 $24,260 $136,250 $160,510

TOTAL 1,324 $116,918 $152,250 $269,168

Post Injection (Annual)

Labor 

Hours Labor Dollars O&M Dollars TOTAL

 RR Reporting 512 $45,199 $0 $45,199

 Update MRV Plans 512 $45,199 $0 $45,199

Conduct Cased Hole Logging 0 $0 $0 $0

Conduct MIT Program 

137 $12,130 $68,125 $80,255

Reporting 0 $0 $0 $0

 Monitor Subsurface Pressure and Fluid Sampling 0 $0 $0 $0

 Perform Baseline Soil Flux/Vadose Zone Monitoring 0 $0 $0 $0

 Perform Micro-Seismic Monitoring 0 $0 $0 $0

 Perform 3D Seismic 0 $0 $0 $0

 Perform Vertical Seismic Profiling (VSP)/Cross-Well Seismic 0 $0 $0 $0

 Perform Eddy Covariance/CIR Monitoring 137 $12,130 $68,125 $80,255

TOTAL 649 $57,329 $68,125 $125,454

Weighted Average O&M (based on years in 

category) 987 $87,124 $110,188 $197,311
13

ESTIMATION OF THE NUMBER OF AFFECTED FACILITIES FOR SUBPART RR 

The Global CCS Institute publishes a database of large scale integrated projects (LSIPs).6

LSIPs are defined by the Global CCS Institute as projects which involve the capture, transport, 

and storage of CO2 at a scale of not less than 800,000 tonnes of CO2 annually for a coal-based 

power plant; and not less than 400,000 tonnes of CO2 annually for other emissions-intensive 

industrial facilities (including natural gas-based power generation). The Global CCS Institute 

defines its projects to be in one of five phases. From initial consideration to actual operation 

these categories are: Identify, Evaluate, Define, Execute, and Operate. A final investment 

decision is made on a project at the end of the Define phase, moving it into the Execute phase. 

According to this database, there is one LSIP in the U.S. that plans to store CO2 in a deep 

saline aquifer. Seventeen LSIPs listed in the Global CCS Institute database as of 2014 use or 

intend to use captured CO2 for CO2-EOR. Of these, seven are currently in operation (Operate 

phase), two are under construction (Execute phase), four are in the Evaluate phase, and four

are in the Define phase. 

For purposes of the analysis, it was assumed that the one current VI saline sequestration 

project would report under subpart RR. It was also assumed that six CO2-EOR projects would

opt in to subpart RR reporting, with two in year 1, four in year 2, and six in year 3. 

ESTIMATION OF TOTAL SUBPART RR MONITORING AND REPORTING BURDEN AND 

COSTS

Taking into consideration the unit cost and burden estimates for CO2-EOR facilities (Table 3)

and for deep saline formation facilities (Table 5), and the estimated number of impacted facilities 

stated above, estimates for the total burden and costs for geologic CO2 storage/sequestration

under subpart RR are presented in Table 6. 

 6 Global CCS Institute. Global Status of CCS update: November 2014. Global CCS Institute. [Online] 

2014. [Cited: April 3, 2015.] http://www.globalccsinstitute.com/projects/large-scale-ccs-projects.
14

Table 6. Total Burden and Cost Estimates for Subpart RR

No. of 

Respondents

Responses/R

espondent

Total 

Responses

Burden - 

Technical

(hrs)

Burden - 

Managerial

(hrs)

Burden - 

Clerical 

(hrs)

Burden - 

Legal (hrs)

Total 

Burden 

(hours)

Total 

Labor Cost 

($)

Capital Cost 

($)

O&M Cost 

($) Total Cost ($)

Subpart RR

Deep Saline 

Formation (Class VI) 1 varies varies 700 30 247 10 987 $87,120 $88,595 $110,188 $285,903

EOR (Class II) 2 varies varies 1,183 50 417 17 1,667 $147,192 $1,383,620 $824,115 $2,354,926

Total 3 1,883 80 664 27 2,654 $234,311 $1,472,215 $934,302 $2,640,829

No. of 

Respondents

Responses/R

espondent

Total 

Responses

Burden - 

Technical

(hrs)

Burden - 

Managerial

(hrs)

Burden - 

Clerical 

(hrs)

Burden - 

Legal (hrs)

Total 

Burden 

(hours)

Total 

Labor Cost 

($)

Capital Cost 

($)

O&M Cost 

($) Total Cost ($)

Subpart RR

Deep Saline 

Formation (Class VI) 1 varies varies 700 30 247 10 987 $87,120 $88,595 $110,188 $285,903

EOR (Class II) 4 varies varies 2,368 100 834 33 3,335 $294,374 $2,767,240 $1,648,229 $4,709,843

Total 5 3,068 130 1,081 43 4,322 $381,494 $2,855,835 $1,758,417 $4,995,745

No. of 

Respondents

Responses/R

espondent

Total 

Responses

Burden - 

Technical

(hrs)

Burden - 

Managerial

(hrs)

Burden - 

Clerical 

(hrs)

Burden - 

Legal (hrs)

Total 

Burden 

(hours)

Total 

Labor Cost 

($)

Capital Cost 

($)

O&M Cost 

($) Total Cost ($)

Subpart RR

Deep Saline 

Formation (Class VI) 1 varies varies 700 30 247 10 987 $87,120 $88,595 $110,188 $285,903

EOR (Class II) 6 varies varies 3,551 150 1,251 50 5,002 $441,565 $4,150,859 $2,472,344 $7,064,769

Total 7 4,251 180 1,498 60 5,989 $528,685 $4,239,454 $2,582,532 $7,350,671

No. of 

Respondents

Responses/R

espondent

Total 

Responses

Burden - 

Technical

(hrs)

Burden - 

Managerial

(hrs)

Burden - 

Clerical 

(hrs)

Burden - 

Legal (hrs)

Total 

Burden 

(hours)

Total 

Labor Cost 

($)

Capital Cost 

($)

O&M Cost 

($) Total Cost ($)

Subpart RR

Deep Saline 

Formation (Class VI) 1 varies varies 700 30 247 10 987 $87,120 $88,595 $110,188 $285,903

EOR (Class II) 4 varies varies 2,367 100 834 33 3,335 $294,377 $2,767,240 $1,648,229 $4,709,846

Total 5 3,067 130 1,081 43 4,322 $381,497 $2,855,835 $1,758,417 $4,995,748

Rate Assumptions: Technical = Engineer = $99.18 /hour

Managerial = Middle Mgr = $118.86 /hour

Clerical = Technician= $52.84 /hour

Legal = $108.61 /hour

Source Category

Annual Average (3-year ICR Period)

Source Category

Year 1

Source Category

Year 2 

Source Category

Year 3
15

SENSITIVITY ANALYSES

Several sensitivity analyses were considered as part of this assessment. Items considered 

included both the extent of MRV activities that would be associated with a subpart RR MRV plan 

(for both CO2-EOR operations and deep saline formation projects) and, for CO2-EOR 

operations, the extent of MRV activities already being conducted.

Table 7 summarizes sensitivity analysis 1 for a subpart RR MRV plan for a CO2-EOR operation.

Table 7. CO2-EOR Operation: Sensitivity Analysis 1

MRV Activity EOR Operation

Develop MRV plans and update models YES

Convert some existing wells to monitoring wells YES

Install shallow monitoring wells YES

Perform soil flux/vadose zone monitoring YES

Perform micro-seismic monitoring YES

Special-case P&As YES

Drill new deep monitoring wells YES

Perform 3D seismic YES

Perform VSP/cross-well seismic YES

Perform eddy covariance/CIR monitoring YES

Conduct cased hole logging YES

Replace tubulars/wellhead/packers YES

Conduct MIT program IN PLACE

Monitor surface pressure, temperatures, rates, 

gas composition, and corrosion YES

Monitor subsurface pressure and fluid sampling YES

YES = will be in MRV Plan

IN PLACE = already in place

Table 8 summarizes the unit burden and cost estimates for geologic CO2 storage under subpart 

RR for a typical operating CO2-EOR project under this sensitivity analysis. 
16

Table 8. Unit Burden and Cost Estimates for CO2-EOR Project: Sensitivity

Analysis 1

Up Front Costs; Planning, Existing 

well P&A

Labor 

Hours Labor Dollars

Capital/O&M 

Dollars TOTAL

 Site Characterization and Preparation 227 $20,079 $1,484,442 $1,504,520

 Convert Existing Wells to Monitoring Wells 21 $1,821 $240,953 $242,775

 Install New Shallow Monitoring Wells 4 $364 $22,564 $22,928

 Develop MRV Plans 41 $3,642 $0 $3,642

 Baseline Soil and Vadose Monitoring Installation 21 $1,821 $12,249 $14,070

 Micro-Seismic Monitoring Installation 41 $3,642 $322,346 $325,988

 Special-Case P&A 13 $1,138 $80,586 $81,725

 Drill New Monitoring Wells 3 $273 $242,444 $242,717

 Perform Baseline 3D Seismic 50 $4,443 $402,932 $407,375

 Perform Baseline Vertical Seismic Profiling (VSP)/Cross-Well Seismic 20 $1,777 $122,491 $124,269

 Install and Perform Baseline Eddy Covariance/CIR Monitoring 13 $1,155 $37,876 $39,031

Injection Wells 144 $12,749 $1,100,004 $1,112,753

 Replace Tubulars/Wellhead/Packers in Existing Wells 144 $12,749 $1,100,004 $1,112,753

Conduct Baseline Cased Hole Logging 7 $592 $15,122 $15,714

Conduct Baseline MIT Program 90 $7,922 $210,331 $218,253

Testing and Monitoring 66 $5,805 $176,339 $182,144 Monitor Surface Pressure, Temperatures, Rates, Gas Composition, and 

Corrosion 32 $2,800 $115,819 $118,619

 Monitor Subsurface Pressure and Fluid Sampling 13 $1,184 $32,476 $33,660

 Perform Baseline Soil Flux/Vadose Zone Monitoring 21 $1,821 $28,044 $29,865

 Micro-Seismic Monitoring 0 $0 $0 $0

 Perform Baseline 3D Seismic 0 $0 $0 $0

 Perform Baseline Vertical Seismic Profiling (VSP)/Cross-Well Seismic 0 $0 $0 $0

 Perform Baseline Eddy Covariance/CIR Monitoring 0 $0 $0 $0

TOTAL 534 $47,147 $2,986,238 $3,033,385

Injection/Monitoring Phase (Annual) 

Labor 

Hours Labor Dollars

Capital/O&M 

Dollars TOTAL

 RR Reporting 256 $22,600 $0 $22,600

 Update MRV Plans 256 $22,600 $0 $22,600

Conduct Cased Hole Logging 83 $7,345 $187,655 $195,000

Conduct MIT Program 557 $49,154 $1,305,000 $1,354,154

Testing and Monitoring 1,277 $112,723 $2,999,310 $3,112,033 Monitor Surface Pressure, Temperatures, Rates, Gas Composition, and 

Corrosion 310 $27,402 $148,400 $175,802

 Monitor Subsurface Pressure and Fluid Sampling 166 $14,690 $175,500 $190,190

 Perform Baseline Soil Flux/Vadose Zone Monitoring 256 $22,600 $348,000 $370,600

 Perform Micro-Seismic Monitoring 128 $11,300 $80,000 $91,300

 Perform 3D Seismic 208 $18,360 $1,665,000 $1,683,360

 Perform Vertical Seismic Profiling (VSP)/Cross-Well Seismic 83 $7,344 $506,160 $513,504

 Perform Eddy Covariance/CIR Monitoring 125 $11,027 $76,250 $87,277

TOTAL 2,173 $191,821 $4,491,965 $4,683,787

Post Injection (Annual)

Labor 

Hours Labor Dollars

Capital/O&M 

Dollars TOTAL

 RR Reporting 128 $11,300 $0 $11,300

 Reporting and Update MVA and Montioring Area Plans 128 $11,300 $0 $11,300

Conduct Cased Hole Logging 42 $3,672 $93,828 $97,500

Testing and Monitoring

513 $45,246 $1,643,875 $1,689,121

Reporting 0 $0 $0 $0

 Monitor Subsurface Pressure and Fluid Sampling 83 $7,345 $87,750 $95,095

 Perform Baseline Soil Flux/Vadose Zone Monitoring 128 $11,300 $174,000 $185,300

 Perform Micro-Seismic Monitoring 64 $5,650 $40,000 $45,650

 Perform 3D Seismic 125 $11,027 $1,000,000 $1,011,027

 Perform Vertical Seismic Profiling (VSP)/Cross-Well Seismic 50 $4,411 $304,000 $308,411

 Perform Eddy Covariance/CIR Monitoring 62 $5,514 $38,125 $43,639

682 $60,218 $1,737,703 $1,797,921

Weighted Average O&M (based on years in 

category) 1,676 $147,953 $3,573,869 $3,721,822
17

Table 9 summarizes sensitivity analysis 2 for a CO2-EOR operation.

Table 9. CO2-EOR Operations: Sensitivity Analysis 2

MRV Activity EOR Operation

Develop MRV plans and update models YES

Convert some existing wells to monitoring wells YES

Install shallow monitoring wells YES

Perform soil flux/vadose zone monitoring YES

Perform micro-seismic monitoring YES

Special-case P&As YES

Drill new deep monitoring wells YES

Perform 3D seismic IN PLACE

Perform eddy covariance/CIR monitoring YES

Conduct cased hole logging YES

Replace tubulars/wellhead/packers in existing 

wells IN PLACE

Conduct MIT program IN PLACE

Monitor surface pressure, temperatures, rates, 

gas composition, and corrosion YES

Monitor subsurface pressure and fluid sampling IN PLACE

YES = will be in MRV Plan

IN PLACE = already in place

Table 10 summarizes the unit burden and cost estimates for geologic CO2 storage under 

subpart RR for this sensitivity analysis. 
18

Table 10. Unit Burden and Cost Estimates for CO2-EOR Projects: Sensitivity 

Analysis 2

Up Front Costs; Planning, Existing 

well P&A

Labor 

Hours Labor Dollars

Capital/O&M 

Dollars TOTAL

 Site Characterization and Preparation 136 $12,037 $718,065 $730,102

 Convert Existing Wells to Monitoring Wells 0 $0 $0 $0

 Install New Shallow Monitoring Wells 4 $364 $22,564 $22,928

 Develop MRV Plans 41 $3,642 $0 $3,642

 Baseline Soil and Vadose Monitoring Installation 21 $1,821 $12,249 $14,070

 Micro-Seismic Monitoring Installation 41 $3,642 $322,346 $325,988

 Special-Case P&A 13 $1,138 $80,586 $81,725

 Drill New Monitoring Wells 3 $273 $242,444 $242,717

 Perform Baseline 3D Seismic 0 $0 $0 $0

 Perform Baseline Vertical Seismic Profiling (VSP)/Cross-Well Seismic 0 $0 $0 $0

 Install and Perform Baseline Eddy Covariance/CIR Monitoring 13 $1,155 $37,876 $39,031

Injection Wells 179 $15,845 $1,367,148 $1,382,993

 Replace Tubulars/Wellhead/Packers in Existing Wells 179 $15,845 $1,367,148 $1,382,993

Conduct Baseline Cased Hole Logging

2 $137 $3,490 $3,626

Conduct Baseline MIT Program 90 $7,922 $210,331 $218,253

Testing and Monitoring 55 $4,895 $151,357 $156,252 Monitor Surface Pressure, Temperatures, Rates, Gas Composition, and 

Corrosion 32 $2,800 $115,819 $118,619

 Monitor Subsurface Pressure and Fluid Sampling 3 $273 $7,495 $7,768

 Perform Baseline Soil Flux/Vadose Zone Monitoring 21 $1,821 $28,044 $29,865

 Micro-Seismic Monitoring 0 $0 $0 $0

 Perform Baseline 3D Seismic 0 $0 $0 $0

 Perform Baseline Vertical Seismic Profiling (VSP)/Cross-Well Seismic 0 $0 $0 $0

 Perform Baseline Eddy Covariance/CIR Monitoring 0 $0 $0 $0

TOTAL 463 $40,835 $2,450,391 $2,491,226

Injection/Monitoring Phase (Annual) 

Labor 

Hours Labor Dollars

Capital/O&M 

Dollars TOTAL

 RR Reporting 256 $22,600 $0 $22,600

 Update MRV Plans 256 $22,600 $0 $22,600

Conduct Cased Hole Logging 19 $1,695 $43,305 $45,000

Conduct MIT Program 557 $49,154 $1,305,000 $1,354,154

Testing and Monitoring 858 $75,719 $693,150 $768,869 Monitor Surface Pressure, Temperatures, Rates, Gas Composition, and 

Corrosion 310 $27,402 $148,400 $175,802

 Monitor Subsurface Pressure and Fluid Sampling 38 $3,390 $40,500 $43,890

 Perform Baseline Soil Flux/Vadose Zone Monitoring 256 $22,600 $348,000 $370,600

 Perform Micro-Seismic Monitoring 128 $11,300 $80,000 $91,300

 Perform 3D Seismic 0 $0 $0 $0

 Perform Vertical Seismic Profiling (VSP)/Cross-Well Seismic 0 $0 $0 $0

 Perform Eddy Covariance/CIR Monitoring 125 $11,027 $76,250 $87,277

TOTAL 1,690 $149,167 $2,041,455 $2,190,622

Post Injection (Annual)

Labor 

Hours Labor Dollars

Capital/O&M 

Dollars TOTAL

 RR Reporting 128 $11,300 $0 $11,300

 Update MRV Plans 128 $11,300 $0 $11,300

Conduct Cased Hole Logging 10 $847 $21,653 $22,500

Conduct MIT Program 

274 $24,158 $272,375 $296,533

Testing and Monitoring

Reporting 0 $0 $0 $0

 Monitor Subsurface Pressure and Fluid Sampling 19 $1,695 $20,250 $21,945

 Perform Baseline Soil Flux/Vadose Zone Monitoring 128 $11,300 $174,000 $185,300

 Perform Micro-Seismic Monitoring 64 $5,650 $40,000 $45,650

 Perform 3D Seismic 0 $0 $0 $0

 Perform Vertical Seismic Profiling (VSP)/Cross-Well Seismic 0 $0 $0 $0

 Perform Eddy Covariance/CIR Monitoring 62 $5,514 $38,125 $43,639

TOTAL 411 $36,306 $294,028 $330,333

Weighted Average O&M (based on years in 

category) 1,264 $111,546 $1,458,977 $1,570,523
19

Finally, Table 11 summarizes the sensitivity analysis for a deep saline formation project; again, 

with costs assumed to be incremental to those associated with a Class VI permit. Table 12

summarizes the unit burden and cost estimates for this sensitivity analysis.

Table 11. Deep Saline Formation: Sensitivity Analysis

MRV Activity

Deep Saline Formation

Operation

Develop MRV plans and update models YES

Convert some existing wells to monitoring wells IN PLACE

Install shallow monitoring wells IN PLACE

Perform soil flux/vadose zone monitoring IN PLACE

Perform micro-seismic monitoring IN PLACE

Special-case P&As IN PLACE

Drill new deep monitoring wells IN PLACE

Perform 3D seismic IN PLACE

Perform VSP/cross-well seismic YES

Perform eddy covariance/CIR monitoring YES

Conduct cased hole logging IN PLACE

Conduct MIT program IN PLACE

Monitor surface pressure, temperatures, rates, 

gas composition, and corrosion IN PLACE

Monitor subsurface pressure and fluid sampling IN PLACE

YES = will be in MRV Plan

IN PLACE = already in place
20

Table 12. Unit Burden and Cost Estimates for Deep Saline Formation Projects: 

Sensitivity Analysis

Up Front Costs; Planning, Existing Well 

P&A

Labor 

Hours Labor Dollars Capital Dollars TOTAL

 Site Characterization and Preparation 211 $18,608 $346,036 $364,644

 Convert Existing Wells to Monitoring Wells 0 $0 $0 $0

 Install New Shallow Monitoring Wells 0 $0 $0 $0

 Develop MRV Plans 145 $12,768 $0 $12,768

 Baseline Soil and Vadose Monitoring Installation 0 $0 $0 $0

 Micro-Seismic Monitoring Installation 0 $0 $0 $0

 Special-Case P&A 0 $0 $0 $0

 Drill New Monitoring Wells 0 $0 $0 $0

 Perform Baseline 3D Seismic 0 $0 $0 $0

 Perform Baseline Vertical Seismic Profiling (VSP)/Cross-Well Seismic 44 $3,894 $268,354 $272,248

 Install and Perform Baseline Eddy Covariance/CIR Monitoring 22 $1,947 $77,681 $79,628

Injection Wells 0 $0 $0 $0

 Replace Tubulars/Wellhead/Packers in Existing Wells 0 $0 $0 $0

Conduct Baseline Cased Hole Logging

0 $0 $0 $0

Conduct Baseline MIT Program 0 $0 $0 $0

Testing and Monitoring 4 $319 $11,299 $11,618 Monitor Surface Pressure, Temperatures, Rates, Gas Composition, and 

Corrosion 4 $319 $11,299 $11,618

 Monitor Subsurface Pressure and Fluid Sampling 0 $0 $0 $0

 Perform Baseline Soil Flux/Vadose Zone Monitoring 0 $0 $0 $0

 Perform Micro-Seismic Monitoring 0 $0 $0 $0

 Perform Baseline 3D Seismic 0 $0 $0 $0

 Perform Vertical Seismic Profiling (VSP)/Cross-Well Seismic 0 $0 $0 $0

 Install and Perform Baseline Eddy Covariance/CIR Monitoring 0 $0 $0 $0

TOTAL 214 $18,927 $357,335 $376,262

Injection/Monitoring Phase (Annual) 

Labor 

Hours Labor Dollars O&M Dollars TOTAL

 RR Reporting 1,024 $90,398 $0 $90,398

 Update MRV Plans 1,024 $90,398 $0 $90,398

Conduct Cased Hole Logging 0 $0 $0 $0

Conduct MIT Program 

0 $0 $0 $0

Testing and Monitoring 508 $44,880 $1,417,650 $1,462,530

 Monitor Surface Pressure, Temperatures, Rates, Gas Composition, and 

Corrosion 26 $2,260 $16,000 $18,260

 Monitor Subsurface Pressure and Fluid Sampling 0 $0 $0 $0

 Perform Baseline Soil Flux/Vadose Zone Monitoring 0 $0 $0 $0

 Perform Micro-Seismic Monitoring 0 $0 $0 $0

 Perform Baseline 3D Seismic 0 $0 $0 $0

 Perform Vertical Seismic Profiling (VSP)/Cross-Well Seismic 208 $18,360 $1,265,400 $1,283,760

 Install and Perform Baseline Eddy Covariance/CIR Monitoring 275 $24,260 $136,250 $160,510

TOTAL 1,532 $135,279 $1,417,650 $1,552,929

Post Injection (Annual)

Labor 

Hours Labor Dollars O&M Dollars TOTAL

 RR Reporting 512 $45,199 $0 $45,199

 Update MRV Plans 512 $45,199 $0 $45,199

Conduct Cased Hole Logging 0 $0 $0 $0

Conduct MIT Program 

262 $23,157 $828,125 $851,282

Reporting 0 $0 $0 $0

 Monitor Subsurface Pressure and Fluid Sampling 0 $0 $0 $0

 Perform Baseline Soil Flux/Vadose Zone Monitoring 0 $0 $0 $0

 Perform Micro-Seismic Monitoring 0 $0 $0 $0

 Perform 3D Seismic 0 $0 $0 $0

 Perform Vertical Seismic Profiling (VSP)/Cross-Well Seismic 125 $11,027 $760,000 $771,027

 Perform Eddy Covariance/CIR Monitoring 137 $12,130 $68,125 $80,255

TOTAL 774 $68,356 $828,125 $896,481

Weighted Average O&M (based on years in 

category) 1,153 $101,817 $1,122,888 $1,224,705
21

Table 13 summarizes the total annualized costs per tonne CO2 injected for each of the 5 

scenarios considered. As shown, in all scenarios considered, the total cost of subpart RR MRV 

and reporting amounts to about $1.00 per tonne of CO2 injected, or less.

Table 13. Estimates of Annualized Costs per Tonne Injected for the Five Scenarios 

Considered

Scenario

Total 

Annualized 

Cost

$/tonne-CO2/year 

Injected

EOR $481,889 $0.13

EOR Sensitivity Analysis 1 $3,721,882 $1.01

EOR Sensitivity Analysis 2 $1,570,523 $0.43

Deep Saline Formation $197,311 $0.05

Deep Saline Formation 

Sensitivity Analysis $1,224,705 $0.33