# 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 20151 

### BACKGROUND AND OBJECTIVE

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

s ubpart RR of the Greenhouse Gas Reporting Program (GHGRP). It is based upon analysis performed for the U.S. En vironmental Protection Agency ( EPA ) related to monitoring, reporting, and verification (MRV) technologies and costs, as applied to carbon di oxide enhanced oil recovery (CO 2 - EOR) operations and CO 2 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 s ubpart RR of the GH G RP.


### ESTIMATION OF POTENTIAL SUBPART RR MRV COSTS
For this assessment, potential MRV activities are grouped into various categor ies 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 mec hanical integrity testing (MIT) program

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

• Monito r subsurface pressure and fluid sampling
Costs are sourced from previous costs and economic impact studies, industry costs for the injection of CO 2 for CO 2 - EOR, and from active (or recently active) CO 2 storage projects. Specifically , the cost estimates developed for this white paper build upon previous work, including EPA’s cost analyses developed as p art of its final Class VI rule; 1 the actual costs incurred with the injection of CO 2 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 ) CO 2 Saline Storage Cost Model , designed to estimate

1 U.S. Environmental Protection Agency, Geologic CO 2 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.pdf2 the costs associated with the storage of captured CO 2 in a subsurface geologic reservoir ; 3 and, where applicable, the drilling and conversion cost algorithms for CO 2 - EOR developed by Advanced Resources for DOE/NETL. 4
For this assessment, the estimated costs associated with potential MRV activities are discussed below. Develop M RV 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 pl ace 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. T his 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 a ddition, 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 p rojects 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 Technolog y Laboratory, Acquisition and Development of Selected Cost Data for Saline Storage and Enhanced Oil Recovery (EOR) Operations , DOE/NETL

2014/1658, prepared by Advanced Resources International, May 14, 20143 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). CO 2 soil flux is a measurement of the rate of CO 2 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 so il 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 va dose 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/vados e 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, usi ng 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, e tc

. -- approximately $ 200,000

• S urface 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 sit e, separate from the other MRV wells. Four micro

- seismic stations were assumed. T he 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 micro

seismic monitoring is reduced by half. Special

- Case P&A
Fo r purposes of this analysis , it was assumed that the initial site characterization work for storage operations, as specified in the subpart RR MRV plan, c ould identify some wells, either existing or previously plugged and abandoned (P&A) that may need to b e 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 Berk eley National Laboratory, September 30, 20154 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 well s would need to be re

- plugged

. Drill New Deep Monitoring Wells
For purposes of this analysis , it was assumed that t hree new monitoring wells at CO 2 - 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 t he petroleum industry for structural imaging and reservoir characterization. 3D seismic surveys have been in use in the pe troleum industry since the 1920 s and have been successful ly deploy ed 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 time

lapse interpretation to image the CO 2 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
Wher e 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, cor related with log data, to assist in horizon selection , and correct s 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 CO 2 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 survey s every three years, with time

- lapse interpretation to image the CO 2 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) Monitoring5 For purposes of this analysis, two methods are assumed to be used to monitor for surface CO 2 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 CO 2 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 ter rain, identified leakage risk and atmospheric conditions. O ne station is assumed to be capable of monitor ing approximately one injection spacing (40 to 640 acres). Each station was estimated to cost $105,000, with 16 labor hours to install. For this

asse ssment, 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 CO 2 saturation measurement in brine

- bearing porous zones . Estim ated 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 assu med 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 y ear. Replace Tubulars/Wellhead/Packers in Existing Wells
While existing wells can be converted to CO 2 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) Program6 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 l eaks 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 res earch 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 req uire wellsite visitation for recording. For this analysis , digital g auges are assumed to be mounted on the wellhead of the CO 2 injection well to continuously monitor for any pressure gain or loss in the casing

- injection tubing annulus and to monitor inject ion. Monitoring pressures, temperatures and rates is a method to quickly assess CO 2 buildup or drawdown, in cluding migration out of zone. They are performed on each well. The costs assumed are for the purchase and installation of a single gauge plus satel lite 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 composi tion of the injected CO 2 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 plan ning and

overs ight . 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 fo r each well material
, which may be exposed to CO 2 , 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 es timated 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, 3 00 per year per wel l , with 16 labor hours for initial installation, plus four hours annual ly 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 withdraw al /recharge. Monitoring in

zone pressures and temperatures is a method to quickly assess CO 2 buildup or drawdown, including migra tion out of zone. Saline reservoir fluid sampling is a direct, quantitative tool with which to assess CO 2 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 Citrone lle. 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

e quipment 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 lab or. Gauge pulls and fluid sampling occur every two years after injection has ceased

. 

### SCENARIOS FOR ESTIMATI N G 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 (c arbon dioxide enhanced oil recovery ( “ CO 2 - EOR ” ) )

.

• P rojects permitted under Class VI of EPA’s UIC Program (assumed to be injecting into deep saline formati ons for purposes of the analysis). The facility assumed for this set of estimates is based on a typical CO 2 - EOR project in the Permian Basin of West Texas, where the majority of ongoing CO 2 - EOR operations in the U.S. exist. This “representative” facility is comparable to that used in previous EPA assessments. Th e 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. Thes e 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 produc tion wells 87 injection wells , 87 p roduc tion 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 post

injection monitoring 20 years of injection, 10 years of post

injection monitoring

Of the potential MRV activities described above, Table 2 summarizes those M RV items assumed for a subpart RR MRV plan for a Class II/CO 2 - EOR operation for the baseline case assumed in this analysis. Table 3 summarizes the unit burden and cost estimates for geologic CO 2 storage under subpart RR for a CO 2 - EOR project, for th is baseline case

. Similarly, Table 4 summarizes the baseline MRV items assumed fo r 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 CO 2 storage under subpart RR for a deep saline formation project based on these assumed activities

.9 

### Table 2 . CO 2 

### - 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 place10 

### Table 3

. Baseline Unit Burden and Cost Estimates for CO 2 

### - 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 $481,88911 

### 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 place12 

### 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 $197,31113 ESTIMATION OF THE NUMBER OF AFFECTED FACILITIES FOR SUBPART RR
The Global CCS Institute publishes a database of large scale integrated projects (LSIPs). 6 LSI Ps are defined by the Global CCS Institute as projects which involve the capture, transport, and storage of CO 2 at a scale of not less than 800,000 tonnes of CO 2 annually for a coal

- based power plant; and not less than 400,000 tonnes of CO 2 annually for ot her 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 CO 2 in a deep saline aquifer. Seventeen LSIPs listed in the Global CCS Institute database as of 2014 use or intend to use captured CO 2 for CO 2 - EOR. Of these, seven are currently in operation (Operate phase), two are under construction (Execute phase), four are in the Evaluate phase, a nd four are in the Define phase.
F or 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 CO 2 - 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 CO 2 - EOR facilities (Table 3) and for deep saline formation facilities (Table 5 ), and the estimated number of impacted facilities stated above, estimate s for the total b urden and costs for g eologic CO 2 s torage / sequestration under s ubpart 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 315 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 CO 2 - EOR operation s and deep saline formation project s) and, for CO 2 - EOR operation s , the extent of MRV activities already being conducted

. Table 7 summarizes sensitivity analysis 1 for a subpart RR MRV plan for a CO 2 - EOR operation

. 

### Table 7 . CO 2 

### - 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 CO 2 storage under subpart RR for a typical operating CO 2 - EOR project under this sensitivity analysis

.16 

### Table 8 . Unit Burden and Cost Estimates for CO 2 

### - 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 $3,721,82217 Table 9 summarizes sensitivity analysis 2 for a CO 2 - EOR operation

. 

### Table 9 . CO 2 

### - EOR Operation s : 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 CO 2 storage under subpart RR for this sensitivity analysis

.18 

### Table 10 . Unit Burden and Cost Estimates for CO 2 

### - 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 $1,570,52319 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 place20 

### 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 $1,224,70521 Table 13 summarizes the total annualized costs per tonne CO 2 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 CO 2 injected, or less.

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

Scenario Total Annualized Cost $/tonne

- CO 2 /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