USEPA Proposes Mandatory GHG Reporting for Facilities that Inject CO2 Underground
This post was written by Jennifer Smokelin.
On March 22, 2010, USEPA signed a proposed rule for the mandatory reporting of greenhouse gases (GHGs) from facilities that inject carbon dioxide underground for the purposes of geologic sequestration or enhanced oil and gas recovery. Geologic sequestration is the long-term containment of carbon dioxide in subsurface geologic formations.
USEPA is proposing that all facilities that inject CO2 for the purpose of long-term geologic sequestration or to enhance oil and gas recovery report basic information on CO2 injected underground. In addition, geologic sequestration facilities that inject CO2 specifically for the purpose of long-term containment in subsurface geologic formations would also be required to:
- Develop and implement an USEPA approved site-specific monitoring, reporting, and verification (MRV) plan.
- Report the amount of CO2 geologically sequestered using a mass balance approach.
Geologic sequestration research and development (R&D) projects (projects that receive federal funding for researching monitoring techniques and practices) would not be required to develop MRV plans or report the additional information required for geologic sequestration, but could choose to opt-in to these requirements.
For those facilities that inject CO2 for the purposes of enhanced oil and gas recovery and only report injection data, USEPA estimates the annualized cost of reporting for each facility to be $4,000. For those facilities that inject CO2 for the purposes of long-term geologic sequestration, additional reporting and monitoring would be required as indicated above and the estimated annualized cost of reporting for each facility required to report geologic sequestration is $300,000.
Most facilities that inject CO2 underground hold permits through USEPA’s Underground Injection Control (UIC) permitting program under the Safe Drinking Water Act. This rulemaking does not change any of the requirements to obtain or comply with a UIC permit. Through a separate rulemaking effort USEPA has proposed federal requirements under the UIC program for the underground injection of carbon dioxide to ensure protection of underground sources of drinking water. This action fulfills a separate but complementary goal which is to track the total amount of CO2 sequestered and to confirm that it remains sequestered and is not emitted to the atmosphere over the long term.
The first annual reports of CO2 injection amounts would be due to USEPA by March 31, 2012 for injection that occurs in 2011. The public comment period for this proposed rulemaking will be open for 60 days after publication in the Federal Register. In addition, a public hearing on this proposal will be held on April 19, 2010, in Arlington, VA.
