Commercial Carbon Capture and Sequestration in the US
The US is home to the largest number of commercial carbon capture and sequestration (CCS) projects worldwide, with approximately 50 new projects announced in 2021, according to the Global CCS Institute. SCS contributes expertise to several ongoing and groundbreaking carbon dioxide geologic sequestration projects. These projects have highly advanced permitting and monitoring requirements.
Research published in a report by the Congressional Research Service defines three main types of sites ideal for underground CO2 injection and sequestration: depleted oil and gas reservoirs, deep saline reservoirs, and un-mineable coal seams. In each case, CO2 in a supercritical state is injected into a porous rock formation below ground that holds, or previously held, fluids. When injected at depths greater than half a mile, the pressure keeps the injected CO2 entrained within the formation fluids, where the CO2 will subsequently dissolve.
Selecting a Site
The target geological injection interval must have an overlying impermeable caprock, such as shale, so the injected CO2 doesn’t migrate into overlying formations, most specifically, the underground source of drinking water. Fortunately for geoscientists and engineers, most of the technology used to assess the subsurface was initially developed by the petroleum industry, including a variety of geophysical techniques, including seismic reflection.
Using Seismic Reflection Technology
At SCS, our team uses the same seismic reflection technology and methodology developed by the oil and gas industry to evaluate the subsurface. Seismic reflection is a powerful tool when used properly and allows us to interpret the depositional background of the system and identify permeable and impermeable units. Seismic reflection involves generating seismic waves (the source) and measuring the two-way travel time taken for the waves to travel from the source, reflect off an interface, and be detected by an array of receivers at the surface. The reflected signal is based on the density-velocity contrast at the interface. Depending upon the type of source and receivers, seismic reflection, once recorded and processed, provides 2 or 3-D imagery of stratigraphic boundaries and geologic structure –all at depths ranging from hundreds of meters to several kilometers.
In-house experts enable SCS to utilize this amazing tool, which enables teams across the organization to see where the best areas for injection are by interpreting seismic stratigraphy. We can determine the continuity of a layer and the presence (or absence) of faults and fractures. The data can also help us determine the type of fault and whether it is a sealing or a transmissive fault. For example, a fault-bound anticline (when the rocks push up from stress changes) may provide a stratigraphic trap for hydrocarbon and can potentially store CO2.
We use seismic reflection in the initial phases of a project to determine the depths and lateral extent of known lithology. We employ previously mapped lithologic units to correlate the “images” created in seismic profiles to existing formations and, in doing so, perform a “check” on the seismic interpretation.
Long Term Benefits
Seismic reflection provides significant input when choosing a reservoir or siting a well; however, its use doesn’t end with an initial site assessment. The technology provides robust methods for monitoring the CO2 plume and interpreting changes to the subsurface during and post-injection. SCS has two Class VI injection projects where seismic reflection data was employed to identify the target injection zones and seals. The next step will be using the data to look at the subsurface relative to the injection well using downhole sensors, a process known as vertical seismic profiling.
The requirements surrounding the Class VI permitting process are complicated, but SCS has in-house experts with the skills to employ seismic reflection. Teams continue to hone their skills in this area as clients value and trust partners who can demonstrate a thorough understanding of permitting carbon sequestration projects.
The Class VI permit application typically takes 18 to 24 months to receive approval. The process is laborious and expensive. Demonstrating expertise here is critical as SCS Engineers continues to play an integral role in advancing supercritical CO2 projects throughout North America.
Additional Resources and Educational Materials:
The proposed AERR rule would require nearly 130,000 facilities to report air toxics emissions directly to EPA. It would also give states the option to collect the air toxics data from industry (rather than states) and report it to EPA, provided the Agency approves their program. This proposed action would allow for EPA to annually collect (starting in 2027) hazardous air pollutant (HAP) emissions data for point sources in addition to continuing the criteria air pollutant and precursor (CAP) collection in place under the existing AERR.
Here are some key things to know about the proposed rule from the EPA website:
1. It would require air toxics (hazardous air pollutant) emissions reporting. While most states voluntarily report air toxics emissions data to EPA now, reporting is not consistent nationwide. The proposal would require many industrial facilities to report air toxics emissions data and offers states the option to report emissions on behalf of the industry sources in their states.
2. It would mean that more facilities must report emissions every year by using the same emissions thresholds every year to determine whether a facility’s detailed emissions information must be reported.
3. It would fill reporting gaps for some portions of Indian country and federal waters. The AERR proposal would require industry to report emissions for certain facilities that operate in those areas and that currently are not reported.
4. It includes provisions to limit the burden on small businesses. The proposal includes flexibilities such as allowing certain small businesses to report a facility’s total air toxics emissions instead of detailed data and exempting many collision repair shops from air toxics reporting requirements.
5. It would provide EPA information that would help the Agency improve its estimates of emissions from prescribed fires. EPA is committed to helping communities and our federal, state, local, and tribal partners manage the health impacts of smoke from wildland fires, including prescribed fires. Prescribed fire is a land management tool that can reduce the likelihood of catastrophic wildfires by reducing the buildup of unwanted fuels.
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Class VI Underground Injection Control Well Permitting is Part III of our video series on Carbon Capture and Storage. Cutting through red tape and regulatory barriers is key to keeping the permitting process on track for your Class VI UIC well. There are steps you can take to prevent delays and meet key regulatory requirements.
Watch the SCS’s Carbon Capture and Storage webinar to learn more about each phase of the permitting process and how to keep each running smoothly. Carbon capture and storage is an EPA-approved technology companies are exploring to help them reduce their greenhouse gas emissions, and understanding the permitting process is key as you plan your project. In this chapter you’ll get answers to these questions:
Your business does not have to be in Illinois to learn from these educational webinars. If you’re ready to explore the benefits of carbon capture and storage but concerned you’ll get delayed by the ins and outs of the Class VI UIC well permitting process, watch Patty Herman’s video to learn more, or contact your local SCS office for a consultation.
Patty Herman graduated from Southern Illinois University Edwardsville with a Master of Science in Biological Sciences. Working in diverse and unique habitats enhances her awareness of the ecosystem’s fragility and the need to protect it, especially for agencies during the permitting process. During graduate school, she was selected by the Illinois Department of Natural Resources for the Natural Heritage Residency program. The residency provided exposure to resource management in both public and private sectors, interacting with many federal, state, and local agencies, as well as NGOs and landowners. She writes and executes management plans and permits using her intensive experience in land management techniques. She has the unique ability to find common ground with stakeholders, agencies, and the public in safe land management for industrial and manufacturing.
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Carbon capture and storage (CCS) enables industry and manufacturing to reduce greenhouse gas footprints by up to 2 million metric tons annually, for decades. It’s a great time to learn how this technology works, how it can help you, and what the overall lifecycle of a CCS project looks like. In this chapter, Kacey Garber and Candy Elliot step through best practices based on project experience, regulations (in this example Illinois), and the compilation and submittal of permit applications. You’ll learn about:
Your business does not have to be in Illinois to learn from these educational, non-commercial webinars. Transform how industry leaders like you manage greenhouse gas as a byproduct of modern life.
Helpful Basic Tips:
Early planning and mindful project scoping are critical for a CCS project to understand and communicate the project’s needs, objectives, goals, and conceptualized design. Use site characterization data and have a good handle on the operational parameters to develop a good first model and initial area of review delineation. The monitoring system design should then be tailored based on those data. Use the baseline and operational monitoring data to calibrate the model and refine your area of review delineation.
Early financial planning is also important and should include long-term operations and monitoring. Spend rates will be variable throughout these projects and highly dependent on the project’s phase.
The site geology is a key factor — we highly recommend conducting a feasibility study before beginning a project to assess the suitability of Class 6 injection at the proposed location. In addition, when the permit process begins, it’s important to front-load the site characterization efforts to minimize the uncertainty surrounding your site suitability.
Proactive stakeholder engagement surrounding your project is more likely to help lead your project to success. Developing outreach plans help open and facilitate lines of communication with stakeholders, regulatory officials, and public and environmental advocate groups.
Use an iterative project approach – permitting is not a cookie-cutter but a site-specific process. Your early and thorough planning steps help create a feedback loop that will go on throughout the project’s life. It enables flexibility in implementing your approach.
Kacey Garber is an experienced groundwater project manager for active and closed industrial clients, including routine groundwater monitoring and statistical analyses; reports and permit applications; designing sampling and analysis plans; special groundwater studies; and conducting groundwater well construction planning and design. She has also been involved in PFAS work groups and publishes on the topics of UIC and geologic sequestration. Ms. Garber has a Masters degree in Geoscience.
Engaging With Your Stakeholders and Public Outreach is Part II of our four part video series.
Geologic sequestration can be seen as an incredible public good that reduces greenhouse gas and protects the health and wellness of generations to come, or a local risk. It’s likely you will receive questions and concerns from the public and other stakeholders during your project’s lifecycle. You can use an effective stakeholder engagement plan to help you anticipate and respond to those questions and concerns.
Watch the Geologic Sequestration webinar to learn how to engage your key stakeholders in a supportive, consistent way that demonstrates your commitment to the community and builds trust. Geologic sequestration is an EPA-approved technology companies are exploring to help them reduce their greenhouse gas emissions. In this chapter you’ll learn:
If you’re ready to explore the benefits of geologic sequestration and want to educate the public and stakeholders about the safety and sustainability of Class VI underground injection control wells, watch Richard Southorn’s video to learn more, or contact your local SCS office for a consultation.
Richard Southorn, PE, PG, serves as Project Director in our Chicagoland office. He manages coal combustion residual (CCR) and municipal solid waste projects, ranging from construction plan development to full-scale design services. He is a licensed Professional Engineer in Illinois, New York, Pennsylvania, Maryland, Delaware, Alabama, South Carolina, Kansas, Michigan, Indiana, Hawaii, Oregon, and Georgia; and a licensed Professional Geologist in Illinois and Delaware.
Additional Resources:
What if you could reduce your company’s greenhouse gas (GHG) emissions by 1.5 to 2 million metric tons per year for the next 20 years?
Now you can, with carbon capture and storage technology. Watch the Illinois Basin Carbon Capture and Storage webinar to learn more. Carbon capture and storage is an EPA-approved technology companies are exploring to help reduce GHG emissions.
In Illinois and many other states, leading firms are submitting permit applications for Class VI underground injection control wells. It’s a great time to review the state of the practice and learn how this technology works and how it can help you meet your carbon reduction goals. In this video chapter, SCS answers these questions:
This technology is on track to transform how industry leaders like you manage greenhouse gas as a byproduct of modern life. Watch Charles Hostetler’s short video to learn more, or contact your local SCS Engineers’ office for a consultation.
Dr. Charles Hostetler has nearly four decades of experience as an engineer and hydrogeologist. He has diverse experience in coal combustion residue (CCR) and solid waste management permitting, design, and construction projects. His areas of expertise focus on supporting electric utilities, property owners and developers, solid waste facility owners and operators to meet demands for addressing environmental changes and impacts on their operations.
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USEPA recently issued Effluent Guidelines Program Plan 15, which includes a focus on PFAS discharges from multiple categories. In conjunction with Plan 15, EPA has determined that revisions to the effluent guidelines and standards for the Landfills Category (40 CFR part 445) are warranted. See Section 6.3.3 of the Plan. Here are a few excerpts regarding landfill leachate:
Landfill leachate and wastewater treatment planning and resource information are available here.
(l) Liquids addition. The owner or operator of a designated facility with a design capacity equal to or greater than 2.5 million megagrams and 2.5 million cubic meters that has employed leachate recirculation or added liquids based on a Research, Development, and Demonstration permit (issued through Resource Conservation and Recovery Act (RCRA), subtitle D, part 258) within the last 10 years must submit to the Administrator, annually, following the procedure specified in paragraph (j)(2) of this section, the following information:
(1) Volume of leachate recirculated (gallons per year) and the reported basis of those estimates (records or engineering estimates).
(2) Total volume of all other liquids added (gallons per year) and the reported basis of those estimates (records or engineering estimates).
(3) Surface area (acres) over which the leachate is recirculated (or otherwise applied).
(4) Surface area (acres) over which any other liquids are applied.
(5) The total waste disposed (megagrams) in the areas with recirculated leachate and/or added liquids based on on-site records to the extent data are available, or engineering estimates and the reported basis of those estimates.
(6) The annual waste acceptance rates (megagrams per year) in the areas with recirculated leachate and/or added liquids, based on on-site records to the extent data are available, or engineering estimates.
(7) The initial report must contain items in paragraph (l)(1) through (6) of this section per year for the most recent 365 days as well as for each of the previous 10 years, to the extent historical data are available in on-site records, and the report must be submitted no later than June 21, 2022.
(8) Subsequent annual reports must contain items in paragraph (l)(1) through (6) of this section for the 365-day period following the 365-day period included in the previous annual report, and the report must be submitted no later than 365 days after the date the previous report was submitted.
(9) Landfills in the closed landfill subcategory are exempt from reporting requirements contained in paragraphs (l)(1) through (7) of this section.
(10) Landfills may cease annual reporting of items in paragraphs (l)(1) through (6) of this section once they have submitted the closure report in § 62.16724(f).
If you need assitance meeting the regulations, please contact your project manager or send a request to
Recent changes to regulatory guidance in California are arguably making obtaining closure on sites with vapor intrusion health risk concerns more difficult to achieve. The Draft Cal-EPA Supplemental Vapor Intrusion Guidance (DSVIG) suggests changes to the methods in which vapor phase transport and potential health risks are modeled and calculated for occupants of buildings with known soil or groundwater contamination beneath them. These changes, which result from a multi-year working group collaboration, recommend a more extensive and site-specific data collection effort. They include indoor air quality calculation methods relying on EPA work and guidance and empirically derived attenuation factors (AFs) which some would argue lead to overestimating potential health risks.
The consequences of the DSVIG are potentially significant if adopted as is and appear likely to result in more sites being “screened in” with vapor intrusion issues and more sites requiring mitigation. The impact, resultant costs, and possibly detrimental secondary effects include decreases in affordable housing production, particularly in urban infill areas. And while none would argue with appropriate protection of health risk, the question is whether the studies and empirical data used to support the DSVIG represents the best available science and is truly representative and predictive of risk.
The DSVIG adopts an attenuation rate of 0.03 for the flux of both soil and sub-slab vapor to indoor air based on a previous 2012 EPA Study comprised of empirical data collected from buildings arguably not representative of modern construction in California. The development of a reliable screening level attenuation factor for California based on high-quality, recent, California-specific data:
1) Will be protective of human health, as no toxicological imperative or basis supports a call for accelerated or immediate action (as evidenced by the fact that the DSVIG workgroup commenced its work in 2014 and issued the review draft in 2020).
2) Will ensure California’s environmental policy satisfies the gold standard for data quality and insightful analysis in which the state once took pride.
3) Will not unnecessarily decimate the California housing development market. The empirically derived screening level AF in the DSVIG is overly conservative based on the available data. More accurate empirical data and measurement methods for site-specific measurement are available.
Oversimplifying the VI health risk assessment methods has constrained the environmental community’s ability to apply science-based health risk screenings, often resulting in costs associated with additional environmental assessment and mitigation. An additional revision to the DSVIG to utilize a screening level AF more reflective of the current California data and building specifications could save state resources, increase infill development by reducing urban sprawl, promote housing development, all while protecting human health.
Take a deeper dive into this topic in the Daily Transcript article Vapor intrusion rules hamper infill projects.
Approved
The EPA issued a newly approved alternative test method (ALT-143) for compliance with the enhanced monitoring provisions in the National Emission Standards for Hazardous Air Pollutants (NESHAPs) for MSW Landfills (40 CFR 63 Subpart AAAA updated March 26, 2020). The approved alternative method instead of Method 10 allows for direct monitoring of CO at a landfill gas well using a portable gas analyzer. The NESHAP requires weekly monitoring of CO at the landfill gas well if the gas temperature is over 145F and the regulatory agency has approved no higher operating value under the NSPS/EG rules or NESHAPs. The Solid Waste Working Group (SWWG) coordinated with landfill gas meter manufacturers (QED, Elkins Earthworks) to prepare this method.
EIL approved sharing a flow chart and Excel file that can be used for monitoring/documentation purposes when using this approved alternative “field instrument method.” Don’t hesitate to get in touch with your SCS air emissions/compliance expert or contact us at for details.
EPA will post the alternative test method to the Broadly Applicable Approved Alternative Test Methods | US EPA website page. Take note that the hyperlink in EPA’s letter is out of date.
Pending Approval
The Solid Waste Working Group (SWWG) also submitted two alternative methods in lieu of Method 10 to EPA for approval using grab sample (canister, foil bag) and laboratory analysis, one with GC/FID and the other GC/TCD instrumentation. The SWWG coordinated with several national laboratories on the methods. EPA is completing its review of the two proposed methods, anticipating EPA approval before September 27, 2021, the effective date of the enhanced monitoring provisions.
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