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Environmental Impacts of Closed-Loop Pumped Storage Hydropower

The goal of this report is to help license applicants, resource agencies, and other members of the hydropower community involved in closed-loop pumped storage hydropower permitting and licensing process, focus the scope of environmental reviews, and more quickly identify impacts with project nexus and potential mitigation measures for these impacts. Pumped storage hydropower (PSH) is an energy storage technology that uses energy to pump water up from a lower reservoir to an upper reservoir where water is stored until electricity is needed and the water is released to a lower reservoir passing through turbines. Closed-loop PSH—PSH that is not continuously connected to a naturally flowing water feature—is one of the lowest greenhouse gas emitting energy storage technologies and is therefore a critical part of the transition to renewable energy (Simon et al. 2023). Proposals for closed-loop PSH facilities in the United States currently account for more than 40% of original licenses and 99% of potential generation capacity in the Federal Energy Regulatory Commission (FERC) hydropower licensing pipeline (Johnson et al. 2023). While closed-loop PSH facilities can have lower environmental impacts than open-loop PSH facilities, no closed-loop facilities have been constructed in the United States to enable direct accounting of project impacts and efficacy of mitigations. Many proposals for closed-loop PSH submitted to FERC are abandoned early in the permitting and licensing process prior to license applications and environmental assessments, so there is little documentation describing potential project impacts and proposed mitigations. The newness of closed-loop PSH proposals in the United States may mean that tribal, federal, and state agencies with authorities for cultural and natural resources protection and management involved in the FERC licensing process may not have experience with closed-loop PSH regulation. Moreover, many proposed closed-loop PSH facilities are in areas that do not have high concentrations of conventional hydropower, so these agencies may also be unfamiliar with the FERC hydropower licensing process. The goal of this report is to help license applicants, resource agencies, and other members of the hydropower community focus the scope of environmental review for the closed-loop PSH development, licensing, and federal authorization process enabling quicker identification of potential impacts, mitigations, and situations where mitigation may not be possible. We found that environmental impacts of closed-loop PSH are highly site-specific, and generalizations about the types of environmental impacts across closed-loop PSH projects are difficult to make. Environmental impacts of closed-loop PSH are like those for open-loop PSH with a few exceptions including water sourcing, which can lead to delays and contention due to potential complexities with water rights, impacts to aquatic resources, and greenhouse gas emission potential. Cultural resource impacts were commonly reported in National Environmental Policy Act (NEPA) documents reviewed and discussed in interviews, but in many cases such impacts cannot be mitigated.

13 HYDRO ENERGY

Southwest Regional Partnership on Carbon Sequestration: Phase III (Final Scientific/Technical Report)

The Southwest Regional Partnership on Carbon Sequestration (SWP) is one of 7 regional partnerships formed in 2003 under the U.S. Department of Energy’s (DOE) Regional Carbon Sequestration Partnerships (RCSPs) initiative. The overall purpose of the initiative was to help determine and implement the technology, infrastructure, and regulations most appropriate to promote carbon storage in different regions of the country. Covering Arizona, Colorado, New Mexico, Oklahoma, Utah, and parts of Texas, Wyoming, and Kansas, the SWP evaluated regional carbon storage and utilization potential and focused on technologies and sites that could complement the region’s strong position in energy production. The project progressed through three phases: • Phase I (2003–2005): Characterized regional geologic formations and CO 2 sources, assessed sequestration potential, and identified pilot test sites. • Phase II (2005–2013): Conducted small-scale field tests to validate sequestration methods, including geologic and terrestrial projects. • Phase III (2008–2022): Demonstrated large-scale CO 2 injection at a commercial oil field to test monitoring, verification, and long-term storage strategies. This report covers Phase III. The final project site, the Farnsworth Unit (FWU) in Texas, provided real-world testing of reservoir characterization, monitoring, and risk evaluation tools and processes that could be used in any commercial scale carbon capture, utilization, and storage (CCUS) project. Extensive data collection and analysis helped refine best practices for reservoir characterization, injection monitoring, and storage verification. The SWP contributed to national databases, DOE best practice manuals, and regional geological assessments to support future sequestration efforts. Key lessons learned include the importance of robust data management, strategic site selection, regulatory navigation, and effective industry collaboration. The project’s findings will inform ongoing and future carbon storage initiatives. Task 1 (Regional Characterization) • The SWP continued to participate in national outreach efforts and NATCARB. • The SWP evaluated multiple potential sites before selecting the FWU as the primary field test location. Task 2 (Public Outreach and Education) • The SWP contributed to national databases, DOE best practice manuals, and regional geological assessments to support future sequestration efforts. Task 3 (Permitting and Regulatory Compliance) • The SWP ensured compliance with federal and state regulations, including National Environmental Policy Act (NEPA) requirements. • The SWP obtained all necessary permits for drilling, injection, and monitoring activities. Task 4 (Site Characterization and Planning) • The SWP developed work plans for four key activities: characterization, simulation, monitoring and verification, and risk evaluation. • The SWP collected and synthesized legacy data from multiple sources to build initial static geological models and dynamic reservoir models demonstrating project feasibility. • The SWP conducted an initial risk evaluation and developed mitigation plans. Task 5 (Field Operations and Data Collection) • The SWP drilled, logged, and cored three characterization wells to gather critical subsurface data. • The SWP conducted multiple geophysical surveys, including 3D seismic, crosswell seismic, and vertical seismic profiling, to improve reservoir characterization. Task 6 (Monitoring and Verification) • The SWP performed extensive geological characterization using data from characterization wells and seismic surveys. • The SWP established a surface monitoring network to track CO 2 flux in soil gas, groundwater chemistry, and near-surface atmospheric CO 2 levels. • The SWP built and refined reservoir models to study the effects of relative permeability on simulation behavior and improve calibration with experimental data. Task 7 (Risk Assessment and Model Refinement) • The SWP conducted multiple studies to evaluate reservoir integrity, predict CO 2 plume behavior and improve predictive modeling capabilities. • The SWP refined geological models and used them to enhance the accuracy of simulation models. • The SWP continued quantitative risk assessment of top-ranked risks and strengthened the link between qualitative and quantitative risk methodologies.

02 PETROLEUM

Establishing an Early CO 2 Storage Complex in Kemper County, Mississippi: Project ECO 2 S (Phase III) (Final Progress Report)

“Establishing an Early CO 2 Storage Complex in Kemper County, Mississippi (Project ECO 2 S)” is an early mover project within the U.S. Department of Energy (DOE) and National Energy Technology Laboratory’s Carbon Storage Assurance Facility Enterprise, or CarbonSAFE, initiative. Phase III of Project ECO2S advanced the foundational work of Phase II, which confirmed the potential for safely, permanently, and economically storing commercial volumes of carbon dioxide (CO 2 ) in the regionally significant saline reservoir system near Mississippi Power Company’s (MPC) Kemper County Energy Facility. The primary objective of Phase III was to complete detailed site characterization necessary to obtain an Underground Injection Control (UIC) Class VI Permit to Construct from the U.S. Environmental Protection Agency. This involved transitioning from regional geologic assessments to high-resolution site-specific analyses.

03 NATURAL GAS

Field Validation of MVA Technology for Offshore CCS: Novel Ultra-High-Resolution 3D Marine Seismic Technology (P-Cable) (Final Report)

The objectives of the proposed study were to deploy and validate a specific monitoring technology, high-resolution 3D marine seismic (HR3D), appropriate for large-demonstration and commercial-scale offshore CCS sites. The project accomplished successful acquisition two HR3D seismic surveys. The first HR3D dataset was over the offshore injection site of the Tomakomai, Japan integrated pilot CCS project, which at the time of survey acquisition was actively injecting CO 2 . The first survey also represented a successful international collaboration between the DOE NETL program and Japan’s national CCS program and was the first successful acquisition and use of HR3D over an active CO 2 injection site (Meckel, Feng et al. 2019). The Tomakomai HR3D survey successfully tested a novel 4-streamer HR3D system array in which, for the first time, no cross-cable (aka “P-Cable”) was utilized and only four GeoEel streamers were used instead of the standard 12-streamer configuration. Consequently, this was not, strictly speaking, a deployment of the “P-Cable” system of (Planke and Berndt 2004) but rather a modified version, thereof, and it is the first known demonstration of the modified system configuration. One very positive outcome from the Japanese collaboration earlier in the project was the ability to learn from the Japanese how they used tail buoys with GPS to determine the position of the seismic source and receivers in time and space. Based on that experience, GCCC designed and built six GPS receivers that could be used to position the streamer receivers and the seismic source via tail buoys. A fundamental advance that was made on the original design, was the ability to directly power the tail buoy GPS units and transfer data through the streamers (i.e., vs. the batteries used at Tomakomai). The bulkiness of the GPS batteries caused drag and episodic surging of the buoys, which affected data quality by lifting up the tail end of the streamers so the receivers were not at the same depth. The units were tested onshore for accuracy and functionality, and the design was subsequently and successfully tested in marine acquisition mode during the SLP survey acquisition. The marine acquisition test and survey satisfied Subtasks 2.2.2, Novel Positioning Technology Selection and Subtask 2.2.3, Novel Positioning Technology Deployment. Results of the novel positioning technology selection (Subtask 2.2.2) were considered successful and will be incorporated in future HR3D seismic acquisition projects to reduce costs, improve deployment safety at sea, and integrate both seismic and data recording via a single data transfer through the streamers to the recording system. The project also established a permitting process through NETL NEPA compliance, which included an Environmental Assessment in a marine setting and is required for conducting these types of surveys using Federal funding. The permitting process charted a “boilerplate,” which can allow future surveys related to other funded projects to move forward more expeditiously. Future improvements that could be considered are more robust seals on the GPS module and stronger materials (especially joints) on tail buoy fabrication. These would increase fixed costs, but would be advisable and probably more economic long-term if multiple HR3D surveys are planned. Project Accomplishments include: • Pre-survey Sensitivity Study • Marine geochemistry methods and data analysis • Successful HR3D seismic dataset acquired @ Tomakomai active CO 2 injection marine site • Developed advanced seismic processing techniques • No NRMS anomalies detected in overburden; Demonstration of containment • Repeatability study • Second survey collected @ San Luis Pass, TX • 4D application using positioning techniques developed in the project for monitoring were successful

3D seismic GPS positioning

PCOR partnership initiative to accelerate CCCUS deployment

The Plains CO 2 Reduction (PCOR) Partnership Initiative, led by the Energy & Environmental Research Center (EERC), was a 5-year collaborative effort under the U.S. Department of Energy’s Regional Initiative to Accelerate CCUS (carbon capture, utilization, and storage). With support from the University of Wyoming School of Energy Resources (UW SER), the University of Alaska Fairbanks Institute of Northern Engineering (UAF INE), and a broad network of public and private stakeholders, the program focused on overcoming regional challenges to CCUS across ten U.S. states and four Canadian provinces. This report summarizes the notable findings of the EERC and its collaborators through the 5-year PCOR Partnership Initiative phase. The EERC developed and demonstrated a risk-based area of review (AOR) workflow for U.S. Environmental Protection Agency Class VI carbon dioxide (CO 2 ) storage permitting.

01 COAL, LIGNITE, AND PEAT

NEPATEC2.0: NEPA Text Corpus v2.0

The National Environmental Policy Act of 1969, as amended (NEPA), is a major environmental law in the United States, requiring Federal agencies to consider and document potential environmental impacts before deciding on a proposed action. Modernization of NEPA and permitting processes faces significant challenges due to the lack of standardized formats and interoperable systems for organizing and sharing NEPA-related information across agencies. Much of the information gathered during NEPA reviews is written into documents such as categorical exclusions, environmental assessments, and environmental impact statements, then filed in predominately independent agency file stores that may or may not be publicly accessible. The application of metadata and data standards, such as those recommended by the Council on Environmental Quality (CEQ), to NEPA documents offers a shared vocabulary and structure for key entities like projects, processes, and documents that can streamline information exchange and enhance collaboration across systems. In this work, we publicly release NEPATEC2.0, an expanded corpus of NEPA documents with associated metadata. NEPATEC2.0 encompasses approximately 120,000 documents from 60,000 projects prepared by more than 60 different agencies. Modeled to align with CEQ metadata standards, NEPATEC2.0 promotes consistency in environmental reviews and supports the ongoing effort to modernize permitting technologies by facilitating more transparent, efficient, and data-driven decision-making. Importantly, NEPATEC2.0 demonstrates the possibilities and limitations of large language model-based prompting to extract information from NEPA documents at scale.

environmental review

NEPATEC v2.0: Standardized Metadata and Text Corpus of National Environmental Policy Act Documents

The National Environmental Policy Act of 1969, as amended (NEPA), is a major environmental law in the United States, requiring Federal agencies to consider and document potential environmental impacts before deciding on a proposed action. Modernization of NEPA and permitting processes faces significant challenges due to the lack of standardized formats and interoperable systems for organizing and sharing NEPA-related information across agencies. Much of the information gathered during NEPA reviews is written into documents such as categorical exclusions, environmental assessments, and environmental impact statements, then filed in predominately independent agency file stores that may or may not be publicly accessible. The application of metadata and data standards, such as those recommended by the Council on Environmental Quality (CEQ), to NEPA documents offers a shared vocabulary and structure for key entities like projects, processes, and documents that can streamline information exchange and enhance collaboration across systems. In this work, we publicly release NEPATEC2.0, an expanded corpus of NEPA documents with associated metadata. NEPATEC2.0 encompasses approximately 120,000 documents from 60,000 projects prepared by more than 60 different agencies. Modeled to align with CEQ metadata standards, NEPATEC2.0 promotes consistency in environmental reviews and supports the ongoing effort to modernize permitting technologies by facilitating more transparent, efficient, and data-driven decision-making. Importantly, NEPATEC2.0 demonstrates the possibilities and limitations of large language model-based prompting to extract information from NEPA documents at scale.

54 ENVIRONMENTAL SCIENCES

Development and application of an environmental risk register for marine energy device and project developers

The marine energy industry is steadily advancing as more devices are deployed worldwide. However, several challenges and barriers remain, such as lingering uncertainty regarding the potential environmental effects of marine energy devices on marine animals, habitats, and ecosystems. Concerns have led to difficulty navigating permitting and consenting processes and receiving authorization to deploy devices in the marine environment, including extended timelines and costs. Based on existing risk registers, a novel marine energy environmental risk register was created to help the marine energy industry move beyond these barriers. This risk register aims to aid marine energy device and project developers identify and assess potential environmental risks early in device design or project planning, document and track potential environmental interactions, prioritize risks and determine risk responses, and make decisions throughout device or project development. It can also be used as a tool to assist in communicating with regulators and advisors during permitting processes and to inform stakeholder and community engagement efforts. This paper details the methods and process to develop a risk register specific to environmental effects of marine energy and describes two use cases (one for wave energy and another for tidal energy) to highlight example results. Due to the tool's novelty, the paper showcases its application for the marine energy industry and acknowledges limitations and possible future improvements. Overall, the environmental risk register shows promise to support marine energy developers when identifying, tracking, and addressing potential environmental risks and to help successfully navigate permitting and deploy marine energy devices responsibly.

Environmental effects

Polk Carbon Storage Complex CarbonSAFE Phase 3 (Final Scientific/Technical Report)

This report summarizes the workplan, technical progress, and high-level findings for the Polk Carbon Storage Complex (PCSC) CarbonSAFE Phase III project. The project was designed to advance a commercial-scale geologic CO 2 storage by drilling and completing two characterization wells to strengthen an already-submitted Underground Injection Control (UIC) Class VI permit application, acquiring new subsurface data, advancing National Environmental Policy Act (NEPA) requirements, progressing CO 2 transportation engineering, and developing commercial and community engagement frameworks.

54 ENVIRONMENTAL SCIENCES

Battery Energy Storage System (BESS) Licensing and Permitting [Slides]

This presentation provides an overview of the licensing, permitting, and regulatory frameworks governing Battery Energy Storage Systems (BESS) across multiple international contexts. It outlines foundational permitting considerations - including safety standards, siting requirements, regulatory and environmental obligations, and interconnection processes - alongside typical pathways for installation, approval, and inspection. The presentation summarizes key technical standards such as NFPA 855 and IEEE guidelines, and emphasizes best practices for safe and effective deployment. A series of detailed case studies from South Africa, Chile, Mexico, Brazil, Costa Rica, Honduras, and the Dominican Republic illustrates how different countries structure approval authority, evaluate environmental impacts, and integrate BESS into national grid systems. The deck concludes with insights on emerging challenges, including evolving regulatory frameworks, financial viability, and the need for pricing mechanisms that accurately value storage services.

24 POWER TRANSMISSION AND DISTRIBUTION

Influence of Soil Moisture on the Development of Organized Convective Systems in South America

Abstract This study investigates the role of soil moisture (SM) on the initiation and organization of convective systems using the convection‐permitting ICOsahedral Non‐hydrostatic (ICON) model. We conduct two sets of experiments: a Control experiment with interactive SM and a fixed SM experiment (FixedSM) with invariable SM conditions. We focus on two regions in South America: the Amazon and southeastern South America (SESA). Larger organized convective systems are associated with greater SM heterogeneity in both regions, though other large‐scale synoptic influences affect the robustness of this relationship in SESA. These results remain largely unaffected by disabling the effects of precipitation on SM in the FixedSM experiment, and complementary analyses using satellite‐based estimates of SM and precipitation support these findings. Spatial compositing of mesoscale environments in the Amazon shows the presence of well‐defined SM gradients, at a length scale of a few hundred kilometers, many hours before convective system detection. Larger SM gradients correspond to larger gradients in thermodynamic variables, particularly surface temperature and sensible heat flux, and are associated with larger convective systems. Overall, our findings suggest that surface heterogeneities such as SM gradients not only affect deep convection initiation, as previously suggested, but they can also encourage the growth and organization of convective systems into larger clusters, particularly in the absence of significant synoptic influences.

54 ENVIRONMENTAL SCIENCES

Air Dispersion Modeling for the Idaho National Laboratory Permit to Construct P-2020.0045 Facility Emission Cap Revision Request

The U.S. Department of Energy Idaho Operations Office (DOE-ID) is seeking to modify permit to construct (PTC) P-2020.0045 issued to U S Dept. of Energy – Idaho National Laboratory (INL) on January 29, 2021 by the Idaho Department of Environmental Quality (DEQ). This PTC allowed the INL to become a synthetic minor source of air pollutants using a facility emission cap (FEC). Air dispersion modeling was performed as part of the permit revision application process to demonstrate that the modifications will comply with the National Ambient Air Quality Standards (NAAQS). This report documents the modeling methodology and complete results for the air dispersion impact analysis and is supplied as an appendix to the permit revision request, Idaho National Laboratory Permit to Construct P-2020.0045 (INL 2025). All criteria air pollutants (CAPs) regulated under Section 109 of the Clean Air Act were modeled with the exception of lead (Pb) and ozone which are not required to be modeled by DEQ. Consistent with the original permit application, modeling was not performed for toxic air pollutants (TAPs) as uncontrolled emissions did not exceed screening emission levels for carcinogenic and non-carcinogenic TAPs. Acceptable model design values (concentrations) for each CAP and averaging period were summed with average background concentrations and compared to NAAQS. The results demonstrate the impacts of requested FEC limits for CAPs are less than applicable standards and demonstrate emissions up to FEC limits will not cause a violation of ambient air quality standards.

54 ENVIRONMENTAL SCIENCES

Site Identification framework and environmental compliance for floating ocean turbines in US Waters (Abstract)

Like all potential marine energy deployment sites, characterizing the site, understanding the environmental interactions with floating tidal technology, and mapping a pathway towards regulatory acceptance will be needed to site and permit ocean current development within the Florida Current. The proposed work will be based on a modeling analysis, a desk-top review and analysis, focusing on the characteristics of the ocean current technology and environmental monitoring information on the marine animals and habitats that are specific to the appropriate latitude, particularly those that are endemic to the offshore Florida area. The analysis will also describe the state and federal authorizations required for deploying a floating tidal energy technology, with an emphasis on how they differ from those in Washington, Alaska, and Maine. Environmentally compliant sites within Florida Current will be selected based on environmental, logistical, and regulatory criteria. Recommendations on monitoring needs and adaptive management practices will be provided. The need to acquire social acceptance for the Orbital Marine Power technology will also be explored and general recommendations prepared to encourage the best acceptance in the communities of interest.

16 TIDAL AND WAVE POWER

Carbon Management Projects (CONNECT) Database and Explorer

Overview The Carbon Management Projects (CONNECT) Toolkit is an online exploratory visualization tool developed by the U.S. Department of Energy's (DOE) Office of Fossil Energy and Carbon Management (FECM) with support from other federal agencies such as the U.S. Environmental Protection Agency (EPA) and the U.S. Department of Transportation (DOT). It provides a single point of access to authoritative information on federal agency investment in a portfolio of research, development, and demonstration (RD&D) projects that have been publicly announced to advance technologies for point source carbon capture, carbon dioxide removal, transport, storage, and conversion, collectively referred to as carbon management. The RD&D programs covered in this tool are authorized by annual congressional appropriations ("Base Program") and the 2021 Infrastructure Investment and Jobs Act (IIJA). The tool also incorporates public information on other federal initiatives, such as the Regional Clean Hydrogen Hubs, and public information released by other government agencies, such as the Environmental Protection Agency's (EPA) and Primacy States’ Underground Injection Control Class VI permits and EPA’s facility level greenhouse gas (GHG) emissions. Developed in a geographic information system, the tool organizes carbon management projects into five groups based on the primary technology that a project aims to advance, each visually represented as a digital layer ("carbon management project layer"). Only federally funded projects are included, which can be awarded projects that are completed or ongoing, or projects that have been selected but are currently under negotiation. Project information can be viewed in the map or in the attribute table below it when turned on. In the map view, each project is displayed at either its host site (for field work), where available, or its performer site (project lead's location, further explained in the table below). Host sites and performer sites are represented in distinct icons. Several reference layers offer additional public information on infrastructural and natural resource environment for carbon management. These reference layers, combined with multiple geographical basemaps, enable users to visualize the carbon management project layers in context. Carbon management project information will be updated monthly based on feedback and information availability. Carbon management project layers Point Source Carbon Capture (PSC) This layer contains DOE-funded projects focused on capturing carbon dioxide (CO2) from power plants or industrial facilities. Carbon Dioxide Removal (CDR) This layer contains DOE-funded projects focused on capturing CO2 from the atmosphere, including direct air capture (DAC) and DAC hubs, direct ocean capture, enhanced mineralization, and biomass carbon removal and storage. For projects with multiple host sites, each of the sites are displayed individually with the project cost and cost sharing information representing the total for the entire project. Carbon Transport This layer contains DOE- and DOT-funded projects focused on CO2 transport. The Transport Research and Development sublayer contains projects that do not involve physical infrastructure; the Proposed Transport Corridor sublayer contains projects for which either a route for the transport infrastructure has been proposed or a general area for the transport infrastructure has been identified. Carbon Storage This layer contains DOE-funded key projects focused on CO2 storage. For projects with multiple field-work sites, each of the sites are displayed individually on the map with the project cost and cost sharing information representing the overall total for the entire project. Carbon Conversion This layer contains DOE-funded projects focused on converting CO2 into economically valuable products. Reference layers The following layers provide additional information in the geographic proximity of carbon management projects. Users should reference the original sources for more details (weblinks provided below and in pop-up windows on the map). Regional Clean Hydrogen Hub and Facility These layers illustrate the approximate areas of the Regional Clean Hydrogen Hubs announced by DOE's Office of Clean Energy Demonstrations (OCED) and the approximate locations of individual facilities that constitute the hubs (see "Where are the H2Hubs located?" on the webpage linked above). EPA Facility Level GHG Emissions (direct emitter) This layer shows direct CO2 emissions from stationary sources in 2022, using data extracted from EPA's Facility Level Information on GreenHouse gases Tool (FLIGHT). Captured and injected CO2 are not deducted from direct emitters’ total emissions. Contact EPA for additional details. Underground Injection Control Class VI permit/permit application This layer shows the locations of CO2 injection wells that are granted or in the process of applying for an Underground Injection Control Class VI permit by EPA or a Primacy State (currently Louisiana, North Dakota, and Wyoming). The URLs for the permits or permit applications are provided in the pop-up windows associated with the well locations. Contact EPA for additional details. Carbon Storage Resource This layer contains information on prospective CO2 storage resources in saline formations and oil and gas reservoirs provided by the National Carbon Sequestration Database and Geographic Information System (NATCARB) spatial database. Contact NETL for additional details. Existing CO2 pipeline This layer shows active CO2 pipelines based on information digitized from the map issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA). Contact PHMSA for additional details.

Carbon Conversion

Voucher Opportunity 5-15: Independent Assessment of Monitoring, Reporting, and Verification (MRV) Technologies and Practices for Enhanced Rock Weathering (CRADA 718) Abstract

Development of robust, transparent, and precise monitoring, reporting, and verification (MRV) technologies and practices is critical for carbon dioxide removal (CDR) project developers to comply with regulatory and permitting requirements, voluntary carbon market (VCM) protocols, and to ensure safety while reducing environmental impacts. Enhanced rock weathering (ERW)-based CDR technologies focus on removing atmospheric carbon through conversion into thermodynamically stable solid or aqueous carbonate forms for permanent storage (i.e., mineralization). This highly durable form of CDR enhances naturally occurring silicate rock weathering cycles by optimizing application of finely-ground silicate rock particles (i.e., from basalt) on terrestrial agricultural lands to accelerate natural silicate rock weathering and mineralization. Enhanced rock weathering may also provide improved crop yields and enhance soil health. A critical aspect for commercialization of these technologies is the development of MRV to quantify the net removal and durable storage of atmospheric CO 2 . For ERW systems, it is essential to accurately characterize the mineral feedstock selected for application to establish the baseline geochemical composition, mineral dissolution rates, and carbon removal potential of the feedstocks to estimate overall net removal. Given the difficulty with conducting MRV for ERW in diverse soil/environment types, over large application areas, and due to complex chemical reaction networks, this project will accelerate understanding towards consensus on best practices for MRV. The overall objectives of the proposed voucher project are to: 1) Characterize and analyze feedstock(s) intended for ERW field application by Lithos Carbon (“Voucher Recipient”/ “CRADA Participant”) to determine overall mineralization potential; 2) Facilitate knowledge transfer and documentation of experimental protocols, instrumentation, and other relevant best practices; and 3) Support the Voucher Recipient’s broader technology commercialization and ERW Research Facility development plans. This work will align with the Voucher Recipient’s MRV plans for field sites and build upon complementary efforts conducted by PNNL on mineralization MRV.

37 INORGANIC, ORGANIC, PHYSICAL, AND ANALYTICAL CH

Illinois Storage Corridor - CarbonSAFE Phase III: Policy, Regulatory, Legal and Permitting Characteristics; Subtask 5.5

The Illinois Storage Corridor (ISC) project aims to advance the commercial development and implementation of carbon capture and storage (CCS) technologies within a region in Illinois of suitable geology for carbon dioxide (CO 2 ) storage in deep saline aquifers. The project partners have annual emissions greater than 6.5 million tonnes per year; storage hubs are being explored at two sites—one near the One Earth Energy facility in east-central Illinois, and one near the Prairie State Generating Company campus in southwest Illinois. To implement the technology, legal, policy, and economic considerations must be explored. The United States Environmental Protection Agency (US EPA) administers the Underground Injection Control (UIC) program and is responsible for issuing Class VI permits to construct and operate CO 2 injection wells, i.e., a UIC Class VI well permit is required to inject CO 2 into the subsurface for geologic sequestration. The largest consideration of the Class VI well requirements is to protect underground sources of drinking water (USDWs). Additionally discussed are considerations for Class VI permits relating to public engagement. Besides permitting, property rights to storage sites, subsurface pore spaces, and areas for pipeline transportation must be secured. Pore space rights is still a novel concept being explored and not yet addressed by the Illinois legislature. It is believed that surface property rights are required for the subsurface pore space below, so long as there is not a separated mineral estate in the subsurface. Illinois legislature has addressed securing rights-of-way for CO 2 transportation, allowing for easements and the exercise of eminent domain to secure such rights. Economically, the incentives for CCS are ever-expanding. Recently, the federal government broadened the availability and increased the dollar-amounts for the § 45Q tax credits for geological storage of carbon oxides. Congress has also authorized the Advanced Industrial Facilities Development Program which allocates billions of dollars in funds to installing technology at industrial facilities to reduce greenhouse gas emissions. On the state level, Illinois has had its own incentives for CCS projects since 2009 and expanded its emission-related goals again in 2021. The law enacted in 2021 specifically creates a commission to explore implementing CCS at Prairie State Generating Company, a partner on the Illinois Storage Corridor project.

54 ENVIRONMENTAL SCIENCES