U.S. EPA’s Proposed GreenhouseGas Reporting Rule for CarbonDioxide Injection and GeologicSequestration6thIEA GHG Monitoring Network WorkshopMay 7, 2010Barbora Master, Office of Air and Radiation, EPAAny communication on the greenhouse gas reporting program is intended to provide general andadministrative information. This communicationdoes not provide legal advice, and responses toquestions received do not have legally binding effect.Presentation Outline• Introduction• EPA’s GHG Reporting Program• EPA’s UIC Program• EPA’s proposal for CO2Injection and GSReporting5/17/2010Introduction: EPA Role• Evaluating and developing appropriate regulatoryframeworks• Evaluating risks to human health and theenvironment• Working to understand and address CCS publicacceptance issues• Designing inventory and accounting methodologies• Improving cost estimates4• EPA is proposing reporting mechanisms for facilities that injectcarbon dioxide (CO2) underground, such as for enhanced oil andgas recovery (ER) or for long-term geologic sequestration (GS).– 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 Programpromulgated under the authority of the Clean Air Act– The proposal is complementary toand builds on EPA’s proposedUnderground Injection Control (UIC) Class VI requirements forgeologic sequestration wells promulgated under the authority of theSafe Drinking Water Act.EPA’s Proposal for CO2Injection andGS Reporting: Introduction5/17/2010Background on EPA GreenhouseGas (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 under theClean Air Act• The rule provides for reporting of GHG data from allsectors of economy above appropriate thresholds toinform future climate change policies and programs– Covers all six GHGs– 25 source categories– 5 types of suppliers of fueland industrial GHG – including CO2suppliers– Motor vehicle and engine suppliers (except light duty sector)– Does not require control of GHGsBackground on EPA GHGReporting Program• Subpart A: General Provisions– Applicability provisions– Schedule– Reporting and recordkeeping requirements common to all reporters– 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 CO2– In the final package, EPA committed todeveloping a mechanism in the nearfuture for industry to report the CO2supply that is permanently sequesteredBackground on EPA UIC Program• The Safe Drinking Water Act (SDWA) created Federalregulations for protection of Underground Sources ofDrinking Water (USDWs)• SDWA requires EPA to develop requirements for underground injectionof all fluids – Underground Injection Control (UIC) program• In July 2008, EPA proposed a rulefor the GeologicSequestration of CO2using Safe Drinking Water Act authoritiesand the UIC Program•Priority placed on avoiding endangerment of underground sources ofdrinking water• Existing UIC program provides aregulatory framework (baseline)• UIC Class VI proposal• The proposal creates a new well class for injection of CO2forGS and builds on UIC program elements (e.g. SiteCharacterization, Area of Review, Well Construction, WellOperation, Site Monitoring, Post-Injection Site Care, etc)8• The proposal takes a measured, tiered approach:– EPA is proposing that all facilities that inject CO2undergroundwould report basic information:• Amount of CO2received onsite from offsite sources• Amount of CO2injected into the subsurface• Source of the CO2if known– In addition to the reporting requirements listed above, facilitiesthat conduct geologic sequestration would also:• Develop and implement an EPA approved site-specificmonitoring, reporting, and verification (MRV) plan• Report the amount of CO2geologically sequestered usinga mass balance approachEPA’s Proposal for CO2Injection andGS Reporting: Overview9• Data collected under this proposal would:– Enable EPA to track the flow of CO2across the CCSsystem and to better understand the quantity of CO2supplied to emissive and non-emissive end-uses.– Enable EPA and others to track growth and efficacy of GS(and therefore CCS) as a mitigation technology over timeand to evaluate relevant policy options.• EPA has designed this proposal so that facilities cancomply without disrupting or delaying normaloperations.EPA’s Proposal for CO2Injection andGS Reporting: Overview (cont’d)10• GS defined as the long-term containment of a gaseous,liquid, or supercritical CO2stream in subsurface geologicformations.• Facilities that inject CO2for ER would be required to reportbasic CO2injection data but would not be required to developMRV plans or report the additional information required forGS. However, they could choose to opt-in to theserequirements.• Geologic sequestration R&D projects would be required toreport basic CO2injection data, but would not be required todevelop MRV plans or report the additional informationrequired for other GS facilities. However, they could chooseto opt-in to these requirements.EPA’s Proposal for Reporting:Who reports GSEPA’s Proposal for Reporting:MRV Plans• EPA is not prescribing specific monitoringtechnologies• GS facilities would develop and implement a sitespecific MRV plan which would include:1. Assessment of Risk of Leakage2. Strategy to Detect and Quantify CO2Leakage to Surface3. Strategy for Establishing Pre-Injection EnvironmentalBaselines at Surface4. Tailor Mass Balance Equation• Once MRV plan is approved by EPA, GS facilitywould implement it and begin collecting data forreporting to EPA12• Information on the proposal and supporting background information isavailable electronically atwww.regulations.gov, EPA’s electronic publicdocket and comment system. The Docket ID number is: EPA-HQ-OAR2009-0926.• For additional information about this rulemaking, visit EPA’s Web siteat:www.epa.gov/climatechange/emissions/subpart/rr.html. If you havequestions that cannot be answeredthrough the Web site, please contactus by filling out a form atwww.epa.gov/climatechange/emissions/ghgrule_contactus.htm.• Comment period open until June 11, 2010• EPA has open door policy duringcomment period to hear fromstakeholdersFor More Information