U.S. EPA’s Proposed Greenhous

Gas Reporting Rule for Carbon Dioxide Injection and Geologic Sequestration

6th IEA GHG Monitoring Network Workshop

May 7, 2010Barbora Master, Office of Air and Radiation, EPA

Any communication on the greenhouse gas reporting program is intended to prov

administrative information. This communication does not provide legal advice, a

questions received do not have legally binding effect. 
Presentation Outline

• Introduction • EPA’s GHG Reporting Program• EPA’s UIC Program• EPA’s proposal for CO

2 Injection and GS 

Reporting
5/17/2010

Introduction: EPA Role

• Evaluating and developing appropriate regulato

frameworks

• Evaluating risks to human health and the 

environment

• Working to understand and address CCS public 

acceptance issues

• Designing inventory and accounting methodolo• Improving cost estimates
• EPA is proposing reporting mechanisms for facilities tha

carbon dioxide (CO

2) underground, such as for enhanced 

gas recovery (ER) or for long-term geologic sequestratio

– Proposal published in FR April 12, 2010 – 60 day comment period ends June 11, 2010

• Relationship to other EPA rulemakings:

– The proposal amends EPA’s Greenhouse Gas Reporting Pr

promulgated under the authority of the Clean Air Act

– The proposal is complementary to and builds on EPA’s pro

Underground Injection Control (UIC) Class VI requiremengeologic sequestration wells promulgated under the autho

Safe Drinking Water Act.

EPA’s Proposal for CO

2 Injection and 

GS Reporting: Introduction
5/17/2010

Background on EPA Greenhouse Gas (GHG) Reporting Program

• Directed by Congress in 2008 Appropriations Act

– Final rule signed September 22, 2009– Went into effect January 1, 2010

• EPA issued the rule pursuant to its authority und

Clean Air Act

• The rule provides for reporting of GHG data from 

sectors of economy above appropriate thresholds inform future climate change policies and program

– Covers all six GHGs– 25 source categories– 5 types of suppliers of fuel and industrial GHG – includ

suppliers 

– Motor vehicle and engine suppliers (except light duty se

– Does not require control of GHGs
Background on EPA GHG 

Reporting Program

• Subpart A: General Provisions

– Applicability provisions– Schedule– Reporting and recordkeeping requirements common to all reporter– Definitions– Report submission procedures– Other (e.g., calibration procedures, monitoring plan)

• Subparts C-PP: Source-Specific Requirements

– Definition of source category– GHG to report– Calculation methods– Monitoring and QA/QC– Missing data procedures– Reporting and recordkeeping elements unique to each subpart

• Subpart PP: Suppliers of CO

2

– In the final package, EPA committed to developing a mechanism in 

future for industry to report the CO

2 supply that is permanently seq
Background on EPA UIC Program

• The Safe Drinking Water Act (SDWA) created Fede

regulations for protection of Underground Sources Drinking Water (USDWs)

• SDWA requires EPA to develop requirements for undergrou

of all fluids – Underground Injection Control (UIC) program

• In July 2008, EPA proposed a rule for the Geologic 

Sequestration of CO2 using Safe Drinking Water Act a

and the UIC Program

• Priority placed on avoiding endangerment of underground s

drinking water

• Existing UIC program provides a regulatory framework (bas• UIC Class VI proposal

• The proposal creates a new well class for injection 

GS and builds on UIC program elements (e.g. Site Characterization, Area of Review, Well ConstructioOperation, Site Monitoring, Post-Injection Site Ca
• The proposal takes a measured, tiered approach

– EPA is proposing that all facilities that inject CO

2 und

would report basic information: 

• Amount of CO

2 received onsite from offsite sour

• Amount of CO

2 injected into the subsurface

• Source of the CO

2 if known

– In addition to the reporting requirements listed abov

that conduct geologic sequestration would also:

• Develop and implement an EPA approved site-s

monitoring, reporting, and verification (MRV) p

• Report the amount of CO

2 geologically sequeste

a mass balance approach

EPA’s Proposal for CO

2 Injection and 

GS Reporting: Overview
• Data collected under this proposal would:

– Enable EPA to track the flow of CO

2 across the C

system and to better understand the quantity of C

supplied to emissive and non-emissive end-uses.

– Enable EPA and others to track growth and effica

(and therefore CCS) as a mitigation technology oand to evaluate relevant policy options.

• EPA has designed this proposal so that facili

comply without disrupting or delaying normoperations.

EPA’s Proposal for CO

2 Injection and 

GS Reporting: Overview (cont’d)
• GS defined as the long-term containment of a gaseo

liquid, or supercritical CO

2 stream in subsurface geo

formations.

• Facilities that inject CO

2 for ER would be required t

basic CO

2 injection data but would not be required t

MRV plans or report the additional information reqGS. However, they could choose to opt-in to these requirements.

• Geologic sequestration R&D projects would be requ

report basic CO

2 injection data, but would not be re

develop MRV plans or report the additional informarequired for other GS facilities. However, they could to opt-in to these requirements. 

EPA’s Proposal for Reporting: Who reports GS
EPA’s Proposal for Reporting: 

MRV Plans

• EPA is not prescribing specific monitoring 

technologies

• GS facilities would develop and implemen

specific MRV plan which would include:

1. Assessment of Risk of Leakage2. Strategy to Detect and Quantify CO

2 Leakage t

3. Strategy for Establishing Pre-Injection Enviro

Baselines at Surface

4. Tailor Mass Balance Equation

• Once MRV plan is approved by EPA, GS fa

would implement it and begin collecting dreporting to EPA
• Information on the proposal and supporting background infor

available electronically at www.regulations.gov, EPA’s electron

docket and comment system. The Docket ID number is: EPA-2009-0926. 

• For additional information about this rulemaking, visit EPA’s 

at: www.epa.gov/climatechange/emissions/subpart/rr.html. 

questions that cannot be answered through the Web site, pleaus by filling out a form at www.epa.gov/climatechange/emissions/ghgrule_contactus.h

• Comment period open until June 11, 2010• EPA has open door policy during comment period to hear from 

stakeholders

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