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1、Reporting Carbon Dioxide Injection and Storage: Federal Authorities and ProgramsContentsIntroduction 1CAA and SDWA CO2 Reporting Authorities and Programs 2Clean Air Act Authorities and EPAs Greenhouse Gas Reporting Program 3General GHGRP Requirements4Safe Drinking Water Act Authorities and UIC Repor
2、ting Requirements5UIC Reporting Regulations and the GHGRP6Reporting Requirements for CO2 Injection and Sequestration Facilities6Subpart RR: Geologic Sequestration Facilities 7Reporting Requirements 8Monitoring, Reporting, and Verification Requirements 8UIC Class VI Requirements and Connection with S
3、ubpart RR 9Subpart RR Data Reported10Subpart UU: CO2 Injection (EOR) Facilities11Subpart UU Data Reported 12Internal Revenue Code Section 45Q Authorities 13CO? Measurement and Reporting Requirements14Issues for Congress19FiguresCO2 Injected for Sequestration and EOR Reported Under Subpart RR10Figure
4、 1. Subpart RR Reporting Facilities, 2016-2019 11Subpart UU Reporting Facilities, 2011-2019 13TablesTable 1. Federal CO2 Injection and Sequestration Reporting Requirements 16ContactsAuthor Information20Congressional Research Servicesummary of the considerations to be used to calculate site-specific
5、variables in the mass balance equation; UIC well number; andproposed date to begin collecting data for calculating the total amount of CO2 sequestered. 40 C.F.R. 98.448. proposed date to begin collecting data for calculating the total amount of CO2 sequestered. 40 C.F.R. 98.448.Once EPA determines t
6、hat the MRV plan meets all requirements, the agency announces its approval and issues a final MRV plan? U.S. Environmental Protection Agency, Mandatory Reporting of Greenhouse Gases: Injection and Geologic Sequestration of Carbon Dioxide; Final Rule, 75 Federal Register 75060-75089, December 1, 2010
7、, p. 75066. Facilities must submit a revised plan to EPA under certain conditions, such as if they make an unanticipated material change to the monitoring and operating procedures in the MRV plan (e.g., changes in injection volume, addition of injection wells, equipment failure, or a change in the p
8、redicted underground CO2 plume).“U.S. Environmental Protection Agency, Mandatory Reporting of Greenhouse Gases: Injection and Geologic Sequestration of Carbon Dioxide; Final Rule, 75 Federal Register 75060-75089, December 1, 2010, p. 75066. EPA also requires plan resubmission if the agency determine
9、s it is necessary following a review of the facilitys annual report, or if the UIC class of an injection well at the facility changes. U.S. Environmental Protection Agency, Mandatory Reporting of Greenhouse Gases: Injection and Geologic Sequestration of Carbon Dioxide; Final Rule, 75 Federal Registe
10、r 75060-75089, December 1, 2010, p. 75066. U.S. Environmental Protection Agency, Mandatory Reporting of Greenhouse Gases: Injection and Geologic Sequestration of Carbon Dioxide; Final Rule, 75 Federal Register 75060-75089, December 1, 2010, p. 75063.UIC Class VI Requirements and Connection with Subp
11、art RRIn the preamble to the GHGRP Subparts RR and UU rule, EPA addressed overlap with UIC requirements for injection facilities, noting that the agency designed the reporting requirements under 40 CFR part 98, subpart RR with careful overlap between the two programs.” For example, both Subpart RR a
12、nd UIC Class VI regulations require reporting of the quantity of CO2 injected. UIC Class VI regulations require owners and operators to report the quantity of CO2 injected over the annual reporting period and the total volume of CO2 injected over the life of the injection project/ 40 C.F.R. 146.91(a
13、).In the preamble to the GHGRP Subparts RR and UU rule, EPA addressed overlap with UIC requirements for injection facilities, noting that the agency designed the reporting requirements under 40 CFR part 98, subpart RR with careful overlap between the two programs.” For example, both Subpart RR and U
14、IC Class VI regulations require reporting of the quantity of CO2 injected. UIC Class VI regulations require owners and operators to report the quantity of CO2 injected over the annual reporting period and the total volume of CO2 injected over the life of the injection project/ 40 C.F.R. 146.91(a). U
15、nder Subpart RR regulations, facilities must include these data in their annual report to EPA. 40 C.F.R. 98.442.Both Subpart RR and UIC Class VI regulations also address air monitoring requirements for geologic sequestration wells. Subpart RR requires facilities to have a monitoring plan for quantif
16、ying air emissions as part of the MRV plan. 40 C.F.R. 98.448(3). Under UIC Class VI regulations, the UIC program director can require an air monitoring detection plan covering the surface overlying the injection field or CO2 plume to detect the movement of CO2 that could endanger a USDW. 40 C.F.R. 1
17、46.90(h). Owners and operators can satisfy the UIC Class VI monitoring requirement by demonstrating compliance with all Subpart RR requirements and the UIC Class VI regulatory requirement to report any release of CO2 into the atmosphere within 24 hours. 40 C.F.R. 146.90(h). The reporter must include
18、 additional information describing how monitoring will achieve surface detection and quantification of CO2.General MRV plan requirements are linked in the regulations. In the preamble to the GHGRP Subparts RR and UU rulemaking, EPA explained that UIC permit requirements for Class VI wells “can provi
19、de the basis for the MRV plan submitted to EPA.in other words, the Subpart RR regulations allow owners and operators to satisfy certain Subpart RR MRV plan requirements with a UIC Class VI permit. U.S. Environmental Protection Agency, Mandatory Reporting of Greenhouse Gases: Injection and Geologic S
20、equestration of Carbon Dioxide; Final Rule, 75 Federal Register 75060-75089, December 1, 2010, p. 75063. U.S. Environmental Protection Agency, Mandatory Reporting of Greenhouse Gases: Injection and Geologic Sequestration of Carbon Dioxide; Final Rule, 75 Federal Register 75060-75089, December 1, 201
21、0, p. 75063.Subpart RR Data ReportedCurrently, Subpart RR applies to one facility in the United States. This facility, located in Illinois, is operating with EPA UIC Class VI permits and is injecting CO2 from an ethanol plant into a saline aquifer. From 2016 through 2019 (the most recent year for wh
22、ich data are available), the facility reported that a total of 1,551,431 metric tons of CO2 had been sequestered at the site. EPA FLIGHT database, accessed November 16, 2020. For comparison, that facility reported emitting 17,467,428 tons of covered GHGs for that same period.Currently, Subpart RR ap
23、plies to one facility in the United States. This facility, located in Illinois, is operating with EPA UIC Class VI permits and is injecting CO2 from an ethanol plant into a saline aquifer. From 2016 through 2019 (the most recent year for which data are available), the facility reported that a total
24、of 1,551,431 metric tons of CO2 had been sequestered at the site. EPA FLIGHT database, accessed November 16, 2020. For comparison, that facility reported emitting 17,467,428 tons of covered GHGs for that same period. As of 2020, four other facilities injecting CO2 through UIC Class II wells for EOR,
25、 with some CO2 storage, have voluntarily reported under Subpart RR. EPA FLIGHT database, accessed November 16, 2020. Although it is not required for the facilities with EOR wells, all five facilities have EPA-approved MRV plans. See Figure 1 for CO2 reported under Subpart RR since 2016 and Figure 2
26、for the locations of facilities that have reported under Subpart RR to date.Figure I.CO2 Injected for Sequestration and EOR Reported Under Subpart RRCO2 injected (metric tons)5,959,38550650fl3,090,6085,452,7353,090,608CO2 injected (metric tons)5,959,38550650fl3,090,6085,452,7353,090,6088,332,419 Ann
27、ualTotalGeologic Sequestration7,812,639 EOR with Storage20162016201720182019Source: CRS, from EPA FLIGHT database, accessed November 16, 2020.Notes: EOR with Storage” amount is the amount of CO2 incidentally stored during oil production, as reported to EPA by the facilities. These volumes were repor
28、ted by four facilities conducting EOR that voluntarily reported under Subpart RR.Figure 2. Subpart RR Reporting Facilities, 2016-2019.Facility injecting C02 from industrial source for geologic sequestration Facility conducting EOR with geologic sequestrationShute Creek Facility Kemmerer, WY ODenver
29、UnitHobbs Field _Hobbs, NMDenver City, TXCore Energy Gaylord, MlArcher Daniels Midland Co. Decatur ILSource: CRS, from EPA FLIGHT database, accessed November 16, 2020.Note: Alaska and Hawaii are not shown on this map; no Subpart RR facilities are located in these states.Subpart UU: CO2 Injection (EO
30、R) FacilitiesSubpart UU applies to GHG source facilities with a well or wells used to inject CO2 during EOR operations or for any purpose other than geologic sequestration.6 As noted earlier in this report, the CO2 can be mined from natural sources or be captured from a power plant or industrial fac
31、ility. All EOR wells at Subpart UU facilities are UIC Class II wells. 40 C.F.R. 98.470.Subpart UU applies to GHG source facilities with a well or wells used to inject CO2 during EOR operations or for any purpose other than geologic sequestration.6 As noted earlier in this report, the CO2 can be mine
32、d from natural sources or be captured from a power plant or industrial facility. All EOR wells at Subpart UU facilities are UIC Class II wells. 40 C.F.R. 98.470. In states with UIC Class II primacy, Class II EOR wells are subject to state regulations and requirements. In other states, EPA directly a
33、dministers the Class II programs and associated regulations. Reporting under UIC regulations and requirements vary by state. Under the GHGRP requirements, all facilities report information directly to EPA.Under Subpart UU, there is no minimum threshold for reporting-facilities are required to report
34、 CO2 data if they inject any amount of CO2. 40 C.F.R. 98.471. These facilities are required to report the quantity of CO2 received for injection and its origin, if known. 40 C.F.R. 98.472. The CO2 received includes CO2 streams from the facilitys own production processes and any CO2 transferred from
35、another facility for injection.Subpart UU regulations specify how facilities must calculate the mass of CO2 received for injection. 40 C.F.R. 98.473. The regulations also require that owners and operators use certain procedures to measure the CO2 flow rate and follow quality assurance/quality contro
36、l procedures for measurement devices, including continuous operation of flow meters. 40 C.F.R. 98.474. Subpart UU facilities must complete the monitoring plans required under general GHGRP requirements. U.S. Environmental Protection Agency, Mandatory Reporting of Greenhouse Gases: Injection and Geol
37、ogicSequestration of Carbon Dioxide; Final Rule, 75 Federal Register 75060-75089, December 1, 2010, p. 75088. These must be retained for EPA review, but do not have to be submitted to EPA. In addition to general GHGRP recordkeeping requirements, Subpart UU facilities are required to keep quarterly r
38、ecords of the quantity of CO2 received. 40 C.F.R. 98.477. An MRV plan is not required, but facilities may choose to submit a plan. Unlike Subpart RR, Subpart UU facilities are not required to measure or report the amount of CO2 injected or sequestered as part of GHGRP reporting. Facilities typically
39、 conduct measurements for their own business purposes. Some CO2 tracking and reporting is required by EPA for well owners and operators in states where EPA directly administers the UIC Class II program and in states granted enforcement authority under SDWA 1422. In other states, reporting requiremen
40、ts may vary, depending on state UIC regulations and requirements.Subpart UU facilities report CO2 information at a facility level, which includes the total amount of CO2 received for injection. The facilities do not report data associated with individual EOR (UIC Class II) wells-the CO? received may
41、 be injected through one or more wells located within the facility.Subpart UU Data ReportedSince 2012 (the first year of required reporting) through 2019, 125 facilities in 15 states have reported quantities of CO2 received (see Figure 3). EPA FLIGHT database, accessed November 16, 2020.Since 2012 (
42、the first year of required reporting) through 2019, 125 facilities in 15 states have reported quantities of CO2 received (see Figure 3). EPA FLIGHT database, accessed November 16, 2020. EPA treats the quantity reported as confidential business information and does not make this information publicly
43、available. In 2012, EPA published a final rule that included CBI determinations for Subpart RR and UU data (U.S. Environmental Protection Agency, Final Confidentiality Determinations for Regulations under the Mandatory Reporting of Greenhouse Gases Rule, 77 Federal Register 48072-48089, August 13, 2
44、012). Three of the reporting facilities have received research and development exemptions from Subpart RR and have reported under Subpart UU. EPA FLIGHT database, accessed November 16, 2020. Combined, these three facilities reported a total of 1,443,517 tons of CO2 received for injection through 201
45、9. EPA FLIGHT database, accessed November 16, 2020.Figure 3. Subpart UU Reporting Facilities, 201 I -2019 Subpart UU Reporting FacilitySource: CRS, from EPA FLIGHT database, accessed November 16, 2020.Note: Alaska and Hawaii are not shown on this map; no Subpart UU facilities are located in these st
46、ates.Internal Revenue Code Section 45Q AuthoritiesSection 45Q of the Internal Revenue Code, enacted as part of the Energy Improvement and Extension Act of 2008 (P.L. 110-343, Division B), requires facility owners or operators to report CO2 data in order to claim the federal tax credit for carbon seq
47、uestration. Under Section 45Q, taxpayers can claim the tax credit for the disposal or utilization of CO2 and other carbon oxides, providing they meet thresholds for the amount of CO2 captured or sequestered and begin construction before January 1, 2026. 26 U.S.C 45Q. Carbon oxide refers to any of th
48、e three oxides of carbon: carbon dioxide, carbon monoxide, and carbon suboxide.Section 45Q of the Internal Revenue Code, enacted as part of the Energy Improvement and Extension Act of 2008 (P.L. 110-343, Division B), requires facility owners or operators to report CO2 data in order to claim the fede
49、ral tax credit for carbon sequestration. Under Section 45Q, taxpayers can claim the tax credit for the disposal or utilization of CO2 and other carbon oxides, providing they meet thresholds for the amount of CO2 captured or sequestered and begin construction before January 1, 2026. 26 U.S.C 45Q. Carbon oxide