SCS Engineers welcomes Michael Wright to the firm as Senior Project Manager in Environmental Services. Wright’s work takes underutilized or contaminated properties and returns them to productive use.
Wright comes to SCS as a licensed professional geologist, geophysicist, hydrogeologist, and licensed general contractor. He has more than 35 years of experience on national projects, including work for the Federal Department of Defense, Army Corps of Engineers, EPA, Forest Service, and Caltrans. His clients include those in commercial real estate, finance and manufacturing, and port authorities, including the Port of Los Angeles. Wright also has an extensive background in conducting environmental insurance claim investigations and providing litigation support.
Wright holds specialty certifications in OSHA Health and Safety, OSHA Hazard Recognition, and Constructions Quality Management for Contractors. Wright holds professional affiliations with the Bay Area Geophysical Society, Groundwater Resources Association, and National Ground Water Association.
Pennsylvania has a problem. A $2 billion problem.
From 2005 to 2015, I managed the plugging of nearly 1,000 wells in Pennsylvania, New York, and West Virginia. Many of the wells were old wells open to the atmosphere, leaking water, gas, or oil. My research indicated one firm had drilled tens of thousands of wells until the 1990s. Responsible companies like Shell Oil Company plugged many of the wells during my tenure after they learned they had acquired old wells through land transactions.
Many more wells were abandoned or orphaned for every responsibly plugged well.
The Pennsylvania Department of Environmental Protection (PADEP) stated there are nearly 27,000 abandoned and orphaned wells on the state and private property. PADEP estimates it will cost $1.8 billion to plug the known wells. In addition, there may be as many as 200,000 unaccounted wells. Large and smaller operators abandoned many of these wells 50-100 years ago. By 1880, 4,000 wells were producing in the Bradford Oil District alone, yielding 50,000 barrels of oil daily. Oil City had 2,000 wells along the shores of the Allegheny River. In the 1940s, the Drake property near Bradford, Pennsylvania, had over 800 wells on 1,200 acres. Many of these wells had since been abandoned or orphaned.
The abandoned/orphaned wells present several potential problems: surface water contamination, groundwater, or drinking water; methane migration to water wells or basements; hazardous air pollutants and greenhouse gas (GHG) emissions; and open holes.
Why have so many operators abandoned their wells without plugging them? And why are wells not properly plugged? The answers are multifaceted.
Inadequate plugging. In the early days, regulation of the oil and gas industry was motivated by the need to protect the oil and gas resources and not the environment. Many wells before the 1950s were either not plugged or plugged with little cement. Often tree stumps, brush, wood, and rocks, with a sack of cement thrown in, were used to plug wells. Even wells plugged in the 1950s and 1960s are not adequately plugged. When cleaning out old wells, we found junk in the hole like a deer skull, tools, brush, wireline, and trash.
Funding and Grant Programs
To address these environmental and safety issues, on November 15, 2021, the federal government enacted the Bipartisan Infrastructure Law, which allocated $4.7 billion to create a new federal program to address orphan wells. Nearly every state with documented orphaned wells submitted a Notice of Intent (NOI) indicating interest in applying for a formula grant to fund the proper closure and cleanup of orphaned wells and well sites.
Pennsylvania applied for and has received an initial grant of $25 million. The state applied for and received a Phase One Formula Grant of $79 million and is eligible for an additional $315 million Performance Grant in future years. The law also provides a separate $500 million program for the remediation of orphan wells on federal land, which the Department of the Interior (DOI) Bureau of Land Management will implement.
The DOI released draft Formula Grant Guidance to the states and the public on January 23.
Pennsylvania Act 136 of 2022 (Act of November 3, 2022, P.L. 1987, No. 136 Cl. 58 – OIL AND GAS) became effective January 3, 2023. This legislation amends Title 58 (Oil and Gas) of the Pennsylvania Consolidated Statutes to provide a mechanism for using grant money. It provides $40,000 for every eligible orphan well plugged with a depth of 3,000 feet or less or the actual cost of the qualified well plugger to plug the well, whichever is less. The Statutes also provide $70,000 for every eligible orphan well plugged at a depth greater than 3,000 feet or the actual cost of plugging, whichever is less.
In the event the qualified well plugger encounters unusual technical difficulties due to the condition of an orphan well, the department may, at its discretion, amend the grant award to cover the additional cost, with adequate documentation of those unexpected additional costs, if it doesn’t exceed the amount of the grant for a specific orphan well.
Success in managing this pressing issue requires dedicated effort and expertise from environmental professionals, in addition to government funding, who consider these factors:
Ownership due diligence. Researching ownership through title and tax records.
Where there are challenges, there are opportunities.
The investments to plug and remediate abandoned and orphaned wells create jobs, advance economic growth, reduce hazards, and greatly reduce GHG emissions to meet carbon reduction goals.
The process requires close coordination between the state, geologists, environmental engineers, and drillers. All are benefactors, and beneficiaries, along with the general public and the environment.
A couple of decades ago, industry Environmental Managers (EM) reviewed and interpreted regulations, permit requirements, and reporting obligations and educated their operations personnel on requirements from the Clean Air Act and Clean Water Act. As usual, time flies, and those major pieces of environmental legislation are more than 50 years old now, and much of the framework remains unchanged. There have also been advances in the best control technologies and great strides in automated record keeping and reporting, enabling us as environmental compliance professionals to be more efficient and offering “clear skies” regarding a manageable workload. Sure, occasional exceedances, deviations, or releases require a four-alarm fire drill as an appropriate response or the integration of the most recent ISO 14001 version release. Still, for the most part, times were good.
Sustainability changes everything.
Environmental Managers read press releases from CEOs making bold claims that their company is adopting “zero” carbon or “net neutral” goals without a real baseline carbon inventory or a roadmap for accomplishing such aggressive measures. Not to say that setting stretch targets are a “bad thing.” On the contrary, they are good targets that improve environmental stewardship for companies that may not otherwise focus on such activities. John F. Kennedy’s famous “We choose to go to the Moon” speech set a bold target for landing on the moon, stretching our space program to new limits.
Meeting the New Challenge
The challenge for you, the EM, comes into play when the responsibility of this relatively new sustainability practice is now on your desk. Larger companies are hiring Sustainability Directors at a record pace which is vital to the planning and programming of new sustainability initiatives. But even then, there are situations where EMs are responsible for implementation and retrofitting plans or projects that are conceptual in nature. And if you don’t have the luxury of a Sustainability Director to lean on, you now have the additional responsibility of developing road maps and strategies.
Where can an Environmental Manager focus on impactfully?
After concluding your version of the Serenity Prayer, we suggest starting in these three areas:
These steps will go a long way toward planning, programming, and launching sustainability initiatives with measurable results. Environmental Managers are making a difference by collaborating with operations to convert sustainable ideas and goals into reality. SCS works with large and small public and private entities to support their actions.
About the Author: Steven D. Stewart, P.E. PMP, SCS Engineers. Project Director. LinkedIn. I look forward to hearing, ‘One small step for man, one giant leap for Environmental Managers.’ If you need help with your sustainability program, don’t hesitate to contact us at SCS Engineers. Look for Steve this week at the GreenBiz 2023.
Additional Resources:
Growing consumer demand for environmentally responsible companies that offer new carbon-neutral products and services creates competitive positioning and market value for “green” organizations. In the environmental business, we call this Sustainability.
In addition to complying with regulations and mitigating economic risks, many organizations are concerned about environmental stewardship and corporate responsibility. Our clients provide important services to society; we are pleased to assist them while also helping to minimize adverse environmental and economic impacts.
In this blog, we’d like to introduce you to Erin Quinn. Mr. Quinn has two decades of experience in environmental consulting, specializing in air quality, environmental assessments, and greenhouse gas (GHG) consulting, reporting, and verification. He has participated in over 550 GHG verification projects throughout the United States.
As a specialist in air permitting and reporting, we asked him to step us through the verification process to provide us with time and cost-saving tips while making the verification process smoother.
Erin’s Tips
Check your firm’s qualifications. Seek a firm with a successful record of GHG emissions inventories, estimating GHG reductions, and a thorough knowledge of navigating the Cap and Trade Program. If you are experiencing a gap between your plan and your actual results, they could help identify how to close the gaps depending on their certifications and background.
Go local. For example, on the west coast, look for experience with CARB and ODEQ projects from various industries such as natural gas, coal, biogas and biomass, solar electricity generation, food processing, oil and gas production, electricity and transportation fuels transactions, and paper mills.
Preparation and understanding of a reporter’s GHG emission sources, CARB designation of the facility, or EPE as described in §95101 of the regulations, and any issues the reporting entity may have had while developing its GHG emissions report will facilitate report completion. This takes experience in combination with industry and specific agency requirements.
Investigate that your third-party verification is transparent. Third-Party Verification of GHG emission inventories and reduction credits under state agencies requires an efficient, transparent, and direct methodology for verifying GHG emissions reports.
Steps in the GHG Verification Process
SCS submits a conflict of interest (COI) and notice of verification services (NOVS) to CARB for their approval as soon as an agreement for verification services has been reached. A simple thing, but one that allows us to begin verification service as soon as the reporting entity submits its verification report to the agency, thus streamlining the process.
Next, we set up a kickoff meeting with the reporting entity and a consultant if you’re using one. At the meeting, we discuss the data that will or may, be required for a transparent verification process and documentation. The meeting helps clients understand all the data used in calculating and reporting their emissions, making the data review process seamless. Immediately following, we provide a formal initial data request.
Now we get to work. We begin by reviewing the provided data to develop a verification plan, a sampling plan, and an issues log. We share this with our client and provide any further explanation within the regulatory framework. During this phase, we often communicate with our client as a part of our quality management methodology.
After reviewing and addressing any issues, SCS completes the verification report and has a final meeting with our client within days of receipt so that SCS can submit it to the agency. The end result is a cost-effective, timely, and defendable verification that meets client and agency expectations and all requirements.
GHG Services at SCS Engineers
Our diligence has helped SCS develop excellent working relations with clients, various regulatory agencies, and voluntary registry. Our long experience enables us to understand your needs and how a regulatory agency or registry will interpret an unusual situation.
The firm has delivered verifications for over a decade and has 52 years of environmental compliance expertise for municipalities and industries. Our GHG verification team has completed hundreds of validation and verification projects, from mandatory GHG reporting in California and Oregon; LCFS validation and verification and offset verifications throughout the U.S.
To learn more about the process or to speak with Erin or another team member, please contact us at .
Additional Resources
From the USEPA to headlines in the media, coverage of PFAS moving from wastewater to drinking water is a major concern. Furthermore, there are growing concerns about how much PFAS is in by-products that are recycled or reused from waste products. Topping that list is fertilizer.
Retail fertilizer products made from at least 50% biosolids commonly sold to the general public and used in farming contain PFAS, which could get into crops and stock, eating those crops. The Environmental Protection departments in some states are beginning to consider or pass state-level specific regulations on the content of PFAS in biosolids.
The December 2022 USEPA memo to states (pages 4-5) made these recommendations on biosolids as follows:
Tony Kollasch, an environmental consultant specializing in remediation, tells us to use precaution and learn more about what plans are underway in your state. In his Wisconsin Agri-Business article, BIOSOLIDS and PFAS – NUTRIENTS with a SIDE OF CONCERN, he walks readers through the most recent reports and studies using plain language.
The issues and questions that come up are solvable. There are treatments for removing PFAS, and as an environmental engineering and consulting firm, we solve these types of challenges. We encourage the safe use of by-products and urge you to learn more about specific products by joining associations where you can educate yourself – it’s good for business and for understanding pending regulations that may impact your operations. It will help you run your business sustainably by making sound decisions based on human health, the environment, and economic demand.
Additional Resources:
On January 11, 2023, the Illinois Environmental Protection Agency posted the General NPDES Permit for Industrial Storm Water Discharges (NPDES Permit No. ILR00) for public review and comment.
Please note that numerous modifications and additions are proposed for Attachment 1 of the NPDES Permit No. ILR00. The Attachment was just made public by the Illinois Environmental Protection Agency. We are preparing a summary of the changes associated with each subsector.
Modifications and added parts or sections are summarized below:
All comments on the draft permit and requests for a public hearing must be received by the IEPA no later than February 11, 2023.
Our team of Storm Water professionals in Illinois includes Spencer LaBelle and Scott Knoepke, who are ready to answer your NPDES Permit questions and discuss how the proposed modifications to the permit may impact your operation.
On January 11, 2023, the Illinois Environmental Protection Agency posted the General NPDES Permit for Industrial Storm Water Discharges (NPDES Permit No. ILR00) for public review and comment.
Please note that numerous modifications and additions are proposed for Attachment 1 of the NPDES Permit No. ILR00. At the time of authoring this blog, Attachment 1 has not been made public by the Illinois Environmental Protection Agency. Once this document is made available, a follow-up post will be prepared to summarize the changes associated with each subsector.
Modifications and added parts or sections are summarized below:
All comments on the draft permit and requests for a public hearing must be received by the IEPA no later than February 11, 2023.
Our team of Storm Water professionals in Illinois includes Spencer LaBelle and Scott Knoepke, who are ready to answer your NPDES Permit questions and discuss how the proposed modifications to the permit may impact your operation.
Join SCS Engineers at Oklahoma State University’s STEM Career Fair on March 2, 2023.
SCS is an employee-owned, award-winning environmental engineering, consulting, and construction firm with offices nationwide. We are seeking a wide variety of dedicated, hard-working professionals with Science, Technology, Engineering, and Mathematics (STEM) backgrounds.
The fair is FREE to students.
Click for more information and registration
Success in such projects helps municipalities move closer to achieving their sustainability goals. These two Maryland projects provide value to their communities by lowering greenhouse gas emissions, providing renewable energy and environmental integrity, and creating jobs and savings for taxpayers. That’s a win for Maryland and its citizens.
Closed landfills require significant maintenance and environmental compliance expenditures for many years, more often decades. Recent changes in federal tax law under the Inflation Reduction Act have dramatically improved opportunities for public and private sector landfills to convert a liability to an income-producing asset. The Inflation Reduction Act includes provisions for a 30% investment tax credit for solar projects with other provisions that can increase this incentive to as much as 50%. There are also equivalent provisions for direct payment to non-taxpaying entities such as cities and counties. An excellent summary has been prepared by the law firm of Holland & Knight and is available here.”
Two Maryland counties are among recent SCS Engineers’ clients who are converting their idle properties into revenue-generators that serve their communities—they are installing solar farms, a growing trend on closed landfills. The Oaks Landfill in Montgomery County, MD, is one.
The Oaks Landfill Photovoltaic Array project will be a 6-megawatt (MW) system on 170 acres of the closed landfill, the largest solar project on county property. Governed through a power purchase agreement, two MWs are allocated for the County. The other four MWs are for a community solar project, with 100% of the electricity generated, provided to low and moderate-income subscribers. In total the solar energy system is expected to generate 11.4 million kilowatt hours of electricity each year – enough to power 930 homes. The solar power is expected to reduce greenhouse gas emissions as much as taking 1,740 cars off the road.
It will be one of the largest solar farms nationwide to allocate all power to disadvantaged communities. The array is on schedule to operate in 2023.
Siting solar energy installations
Ideal sites for these facilities are fairly flat (preferably less than 15% slope) with open spaces conducive to photovoltaic system installation. Favorable sites are also in close proximity to utility connection points providing developers a viable means to bring their product to market and consumers. While properties like closed landfills provide ideal locations, the projects command a robust multidisciplinary redevelopment approach. Important skills for successfully engineering and permitting these projects include landfill engineering expertise and experience with state and local permitting processes.
You can learn more about renewable energy solutions here.
Donald Barfield (Don) joins SCS Engineers as a Project Director specializing in environmental assessment and brownfield remediation, the first step in returning damaged sites and property to productive use. Barfield brings AAI expertise developed at over 2,000 assessments and brownfield projects throughout the United States and globally, keeping them on schedule and budget.
“Don’s proven track record fits our aim to create sustainable environmental solutions. Our consulting engineer teams include members with field and financial experience to create solutions that meet and remain compliant with local, state, and federal policies while economically and socially practical, states Senior Vice President and Southeast Business Director Carlo Lebron.
All Appropriate Inquiries (AAI) is a process of evaluating the environmental condition of a property and assessing the likelihood of contamination. Parties must comply with the requirements of the AAI Rule or follow the standards set forth in the ASTM E1527-13 or E1527-21 Standard Practice for Phase I Environmental Site Assessments to satisfy the statutory requirements for conducting all appropriate inquiries.
Today’s commercial property transactions take environmental issues into consideration. Complex laws can impose significant environmental liabilities on purchasers, sellers, and lenders, whether or not they caused the problem and whether or not they still own the property.
Don brings years of experience helping municipalities, developers, and industrial clients prepare and submit EPA Brownfield Assessment and Cleanup Grants, including the compliance reporting and due diligence associated with making these projects successful for communities and businesses. His project experience includes due diligence and risk reviews for large acquisitions or mergers and the assessment and development of closure plans for RCRA Regulated Units.
“Sustainability and environmental compliance are important factors in moving projects forward while protecting communities,” says Don. “There are funding, grants, tax credits, and incentives available now. In Florida, the Voluntary Cleanup Tax Credit Program could support mixed-use developments and potential partnerships right now.”
Barfield is an LEED® Accredited Professional, HAZWOPER Certified, and an ASTM Environmental Professional. He earned his MBA at the University of North Florida and a BS in Biology at Jacksonville University.
SCS Engineers’ environmental solutions and technology directly result from our experience and dedication to industries responsible for safeguarding the environment as they deliver essential services and products. For more information about joining us, please visit the SCS Engineers website, or watch our video to see what we can do for your business and community.
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