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.
Candy Elliott has 14 years of experience in assessment and remediation, including comprehensive geologic and hydrogeologic site assessments in several states. Her projects include site characterization, site assessment and remediation, brownfields, groundwater monitoring and reporting, groundwater corrective action, mining, and other industrial facility or site development projects. She also supports new and existing geologic permitting assignments for waste clients and facilities. Ms. Elliott is a licensed Professional Geologist.
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.
Additional Resources:
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.
The EPA and, in some cases, states are rolling out new emissions guidelines at least as stringent. The EPA estimates that the plans could cover about 1,600 landfills. These landfills are in 41 states, tribal entities, and the U.S. territories of Puerto Rico and the Virgin Islands.
MSW landfills without Gas Collection and Control Systems (GCCS) that reach a specific threshold will need to add these systems and have 30 months to install or update control systems to meet new standards. As you’ve noticed by now, we’ve greatly oversimplified what is happening.
The new regulations and timetables are difficult to understand and untangle. SCS Engineers, in concert with SCS Field Services, have prepared resources to help during the transition period and afterward when landfills are likely to need more monitoring and measurement, thus creating millions of more bits of data to store, analyze, and report.
We hope you find these resources useful. We will be publishing more soon.
These resources may help you with future monitoring and maintenance:
Thank you to the many folks attending SCS’s live webinar on July 15th about managing the NESHAP, NSPS/EG transition period. As promised, we’ve created a library of resources for you to use and share with your colleagues.
These resources may help you with future monitoring and maintenance:
We’re here to help. Please find an expert or contact us at .
May 27, 2021, from two separate U.S. Environmental Protection Agency (EPA) announcements:
EPA intends to reconsider and revise the 2020 CWA Section 401 Certification Rule
Congress provided authority to states and Tribes under CWA Section 401 to protect the quality of their waters from adverse impacts resulting from federally licensed or permitted projects. Under Section 401, a federal agency may not issue a license or permit to conduct any activity that may result in any discharge into navigable waters unless the affected state or Tribe certifies that the discharge is in compliance with the Clean Water Act and state law, or waives certification.
EPA intends to reconsider and revise the 2020 CWA Section 401 Certification Rule to restore the balance of state, Tribal, and federal authorities while retaining elements that support efficient and effective implementation of Section 401. While EPA engages with stakeholders and develops a revised rule, the 2020 rule will remain in place. The agency will continue listening to states and Tribes about their concerns with implementing the 2020 rule to evaluate potential administrative approaches to help address these near-term challenges.
The agency’s process of reconsidering and revising the 2020 CWA Section 401 Certification Rule will provide an opportunity for public and stakeholder input to inform the development of a proposed regulation, and will include sustained dialogue with state and Tribal co-regulator partners and local governments around these issues. EPA will begin a stakeholder engagement process in June to hear perspectives on this topic and how to move forward. More information will be available at: www.epa.gov/cwa-401.
EPA, Region 7, public listening sessions on the RMP Rule
Section 112(r) of the Clean Air Act Amendments requires EPA to publish regulations and guidance for chemical accident prevention at facilities that use certain hazardous substances. These regulations and guidance are in the Risk Management Plan (RMP) rule, which requires facilities using extremely hazardous substances to develop a Risk Management Plan that:
These plans provide information to local fire, police, and emergency response personnel to prepare for and respond to chemical emergencies in their community.
The Region 7 EPA announced two upcoming virtual public listening sessions on the Agency’s Risk Management Plan (RMP) rule. The RMP rule has been identified as an action for review under Executive Order 13990: Protecting Public Health and the Environment and Restoring Science To Tackle the Climate Crisis.
The listening sessions will give people the opportunity to present information, and provide comments or views pertaining to revisions made to the RMP rule since 2017. The Occupational Safety and Health Administration (OSHA) will also participate in the listening sessions and receive comments on their Process Safety Management (PSM) standard, which contains similar requirements to the RMP rule.
Virtual public listening sessions will be held on:
For more information on the public listening sessions:
https://www.epa.gov/rmp/forms/virtual-public-listening-sessions-risk-management-program-rule.
Submit written comments via the docket at: http://www.regulations.gov, Docket ID: EPA-HQ-OLEM-2021-0312 until July 15, 2021.
EPA Region 7 serves Iowa, Kansas, Missouri, Nebraska, and Nine Tribal Nations.
