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At least 505 records · Page 28

Permitting Commercial Geologic CO 2 Storage Projects: Lessons Learned

Conference paper presented at 48th International Technical Conference on Clean Energy (Clearwater Clean Energy Conference), Clearwater, Florida, June 16–19, 2024. Carbon capture, utilization, and storage (CCUS) deployment can be a catalyst to drive investment that will extend the operational life of certain facilities and maximize oil recovery, thereby providing and retaining high-paying energy jobs that, in turn, sustain state and local economies.

01 COAL, LIGNITE, AND PEAT↗

SolarAPP+ Performance Review (2023 Data)

The Solar Automated Permit Processing Plus (SolarAPP+) platform is an online portal to facilitate and expedite rooftop solar photovoltaic (PV) and battery storage permitting processes. SolarAPP+ allows PV contractors to upload system specifications, have that information automatically reviewed for code compliance, and receive instant approval for code-compliant systems, reducing authority having jurisdiction (AHJ) staff time needed for review. SolarAPP+ also provides inspection checklists to verify installation practices and adherence to approved designs. SolarAPP+ is available to AHJs at no cost. This report is part of an ongoing series of reviews of SolarAPP+ performance. Consistent with previous performance reviews, we summarize SolarAPP+ adoption trends to date and compare various metrics for PV systems permitted through SolarAPP+ versus systems permitted through traditional AHJ permitting processes. As of the end of 2023, the National Renewable Energy Laboratory (NREL) had contacted over 1,700 AHJs with significant solar permitting volume regarding SolarAPP+. Of those, 793 AHJs had expressed interest in the platform as of the end of 2023. 161 AHJs had begun piloting the platform and 97 of these had publicly launched the platform by the end of 2023. In 2023, 668 installers submitted 18,906 permits through the SolarAPP+ platform, including 4,834 permits submitted as part of a solar plus storage program. SolarAPP+ permits accounted for around 43% of all permits issued in participating AHJs. We compare permitting timelines through SolarAPP+ to traditional AHJ permitting processes to assess the platform's performance. Consistent with previous SolarAPP+ performance reviews, we find that permitting timelines are significantly shorter for SolarAPP+ projects. Based on median timelines, a typical SolarAPP+ project is permitted and inspected 14.5 business days sooner than traditional projects. We estimate that automatic SolarAPP+ permitting saved around 7,200 hours of AHJ staff time in 2023. Finally, we estimate that SolarAPP+ eliminated over 150,000 business days in permitting-related delays in 2023.

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SolarAPP+ Performance Review (2024 Data)

The Solar Automated Permit Processing Plus (SolarAPP+) platform is an online portal to facilitate and expedite rooftop solar photovoltaic (PV) and battery storage permitting processes. SolarAPP+ allows PV contractors to upload system specifications, have that information automatically reviewed for code compliance, and receive instant approval for code-compliant systems, reducing authority having jurisdiction (AHJ) staff time needed for review. SolarAPP+ also provides inspection checklists to verify installation practices and adherence to approved designs. This report is part of an ongoing series of reviews of SolarAPP+ performance. Consistent with previous performance reviews, we summarize SolarAPP+ adoption trends to date and compare various metrics for PV systems permitted through SolarAPP+ versus systems permitted through traditional AHJ permitting processes. As of the end of 2024, 799 AHJs had expressed interest in the platform, with 264 fully adopting (215) or piloting (49) the platform. In 2024, 861 installers submitted 37,393 permits through the SolarAPP+ platform, including 27,375 permits for PV+storage systems. SolarAPP+ permits accounted for around 43% of all permits issued in all participating AHJs, and more than 60% of all permits in several participating AHJs. We compare permitting timelines through SolarAPP+ to traditional AHJ permitting processes to assess the platform's performance. Consistent with previous SolarAPP+ performance reviews, we find that permitting timelines are significantly shorter for SolarAPP+ projects. Based on median timelines, a typical SolarAPP+ project is permitted and inspected 12 business days sooner than traditional projects. We estimate that automatic SolarAPP+ permitting saved around 18,400 hours of AHJ staff time in 2024. Finally, we estimate that SolarAPP+ eliminated over 100,000 business days in permitting-related delays in 2024.

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SolarAPP+ Performance Review (2022 Data)

The Solar Automated Permit Processing Plus (SolarAPP+) platform is an online portal to facilitate and expedite rooftop solar photovoltaic (PV) permitting processes. SolarAPP+ allows PV contractors to upload system specifications, have those specifications automatically reviewed for code compliance, and receive instant approval for code-compliant systems. SolarAPP+ also provides inspection checklists to verify installation practices and adherence to approved designs. SolarAPP+ is available to authorities having jurisdiction (AHJs) at no cost. This report is part of an ongoing series of reviews of SolarAPP+ performance. Consistent with previous performance reviews, we summarize SolarAPP+ adoption trends to date and compare various metrics for PV systems permitted through SolarAPP+ versus systems permitted through conventional AHJ permitting processes. As of the end of 2022, the National Renewable Energy Laboratory (NREL) had contacted over 1,500 AHJs with significant solar permitting volume regarding SolarAPP+. Of those, 607 AHJs had at least expressed interest in the platform. 16 AHJs had begun piloting the platform and 15 of these had publicly launched the platform by the end of 2022. In 2022, 206 installers submitted 11,092 permits through the SolarAPP+ platform, including 708 permits for solar+storage systems. SolarAPP+ permits accounted for around 37% of all permits issued in participating AHJs. We compare permitting timelines through SolarAPP+ to traditional AHJ permitting processes to assess the platform's performance. Consistent with previous SolarAPP+ performance reviews, we find that permitting timelines are significantly shorter for SolarAPP+ projects. Based on median timelines, a typical SolarAPP+ project is permitted and inspected 8 business days sooner than traditional projects. We estimate that automatic SolarAPP+ permitting saved between 3,500 and 13,900 hours of AHJ staff time in 2022. Finally, we find evidence that SolarAPP+ may improve inspection outcomes, with SolarAPP+ projects failing inspections about 28% less frequently than traditional projects.

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2017 Annual Reuse Report for the Idaho National Laboratory Site's Advanced Test Reactor Complex Cold Waste Ponds

This report describes conditions and information, as required by the state of Idaho, Department of Environmental Quality Reuse Permit I-161-02, for the Advanced Test Reactor Complex Cold Waste Ponds located at Idaho National Laboratory from November 1, 2016–October 31, 2017. The effective date of Reuse Permit I-161-02 is November 20, 2014 with an expiration date of November 19, 2019. A permit modification, I-161-02: Modification 1, became effective March 7, 2017. The modification incorporated clarification to the delivery of analytical reports and chain of custody forms. This report contains the following information: • Facility and system description • Permit required effluent monitoring data and loading rates • Permit required groundwater monitoring data • Status of compliance activities • Issues • Discussion of the facility’s environmental impacts. During the 2017 permit year, 234.05 million gallons of wastewater were discharged to the Cold Waste Ponds which is below the maximum annual permit limit of 375 million gallons. Sulfate and total dissolved solids concentrations continue to remain highest in well USGS-065, which is the closest downgradient well to the Cold Waste Ponds. As shown by the groundwater sampling data, sulfate and total dissolved solids concentrations decrease rapidly as the distance downgradient from the Cold Waste Ponds increases. The concentrations of all permit-required parameters were below their respective groundwater quality standard levels (IDAPA 58.01.11) for all six groundwater monitoring wells. There was one noncompliance with the Reuse Permit during the 2017 permit year. Approximately 600 gallons of cooling water was discharged to ground surface outside of the designated application site. DEQ was notified of the noncompliance.

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PNNL Review of Federal and State Agency Regulatory Streamlining Practices

All major federal actions that have the potential to significantly affect the environment (e.g., land purchases and/or issuing grants, permits, leases, or licenses) are subject to multiple statutes including the following: • an environmental analysis under the National Environmental Policy Act (NEPA) • potential consultations with the U.S. Fish and Wildlife Service (USFWS) and/or National Marine Fisheries Service (NMFS) under the Endangered Species Act of 1973, as amended (ESA) • potential consultations with State Historical Preservation Officers (SHPOs) and/or tribal nations [often Tribal Historic Preservation Officers (THPOs)] under the National Historic Preservation Act of 1966 (NHPA). Given the size of the federal government and the corresponding variability and complexity in its missions, different branches within the federal government have a fairly wide range of approaches to fulfill their NEPA and consultation requitements. Many of these approaches are founded on the desire to streamline their NEPA and consultation processes while meeting the spirit and letter of the regulations. Some federal and state environmental/engineering agencies have developed web-based dashboards that provide a single web location for permit application submittals. They also use general permits in their various permitting processes. General permits can streamline the permitting process by establishing identical requirements for all eligible applicants. This reduces the time these agencies need to spend reviewing individual permits and setting specific requirements. In addition, general permits do not require a case-specific permit application. This paper presents a sampling of effective agency examples of streamlining the NEPA process and associated agency consultations. It also includes several examples of federal and state agency web portals, online application systems, and general permits that make application processes more efficient and accessible.

54 ENVIRONMENTAL SCIENCES↗

Closure Plan for the Idaho National Laboratory Site's Materials and Fuels Complex Industrial Waste Ditch

The Materials and Fuels Complex industrial waste system currently consists of the Industrial Waste Pond and Industrial Waste Ditch, associated piping, lift station, and flow meter. The Industrial Waste Pond and Industrial Waste Ditch, are land application sites permitted under Idaho Department of Environmental Quality Reuse Permit I-160-02, Modification 1. The Reuse Permit allows for 17 million gallons of industrial wastewater to be discharged to the land application sites. For Reuse Permit year 2017, approximately 7.569 million gallons were discharged to the land application sites, of which 1.649 million gallons were discharged to the Industrial Waste Ditch. A project (MFC West Campus Utility Corridor project) is proposed to begin in the summer of 2018. The project will install a new utility corridor along the west and north sides of the Materials and Fuels Complex. As part of the design, it is proposed to reroute the wastewater currently discharged to the Industrial Waste Ditch into an underground pipe that would connect into the existing Industrial Waste Pipeline. The Industrial Waste Ditch pipe would enter the existing Industrial Waste Pipeline upstream of the existing flow meter and sampling location. This would allow for the combined wastewater streams to be monitored for flow and sampled for parameters required by the Reuse Permit. In accordance with the Reuse Permit, this closure plan is being submitted to the Idaho Department of Environmental Quality for review and approval. Once the closure plan is approved, the Reuse Permit will be modified to remove the Industrial Waste Ditch from the permit. The closure plan includes: • Brief background of the Materials and Fuels Complex. • Reuse Permit history. • Site characteristics. • Description of the Industrial Wastewater System. • History of discharges to the Industrial Waste Ditch. • Summary of the Comprehensive Environmental Response, Compensation, and Liability Act characterization, evaluation, and remediation of the Industrial Waste Ditch. • Contaminant concentrations in the effluent discharged to the Industrial Waste Ditch. • Contaminant concentrations in cross gradient, downgradient, and background monitoring wells. Based on the Comprehensive Environmental Response, Compensation, and Liability Act characterization and remediation of the Industrial Waste Ditch, low volumes and contaminant concentrations in the effluent subsequently discharged to the Industrial Waste Ditch, and contaminant concentrations at or near background levels in the monitoring wells, it is recommended that the Industrial Waste Ditch should be closed without further characterization.

99 GENERAL AND MISCELLANEOUS↗

Addendum 2 to the Closure Report for CAU 577 Area 5 Chromium Containing Waste Disposal Cells, NNSS, Nevada

Corrective Action Unit (CAU) 577, “Area 5 Chromium Containing Waste Disposal Cells,” includes five low-level waste cells at the Nevada National Security Site Area 5 Radioactive Waste Management Site where buried waste received from Nuclear Fuel Services, Inc., was subsequently determined to contain chromium that exceeded the toxicity characteristic leaching procedure regulatory limit, which would require the waste to carry hazardous waste code D007. CAU 577 was created to satisfy the requirements of the Settlement Agreement (SA) executed between the Nevada Division of Environmental Protection (NDEP) and the U.S. Department of Energy, National Nuclear Security Administration Nevada Field Office (NNSA/NFO) on April 25, 2019 (NDEP 2019). The SA required that the chromium-containing waste received from NFS would be addressed following the closure process laid out in the Federal Facility Agreement and Consent Order (FFACO). The FFACO process ensures proper closure of the chromium-containing waste and documentation of that closure through FFACO-type documents. The following three Corrective Action Sites (CASs) were closed, and their closure was documented in the Closure Report for Corrective Action Unit 577: Area 5 Chromium Containing Waste Disposal Cells, Nevada National Security Site, Nevada, DOE/EMNV--0030, dated September 2021 (U.S. Department of Energy [DOE] Environmental Management [EM] Nevada Program 2021a): • CAS 05-21-02, Waste Disposal Cell 12 • CAS 05-21-03, Waste Disposal Cell 15 • CAS 05-21-04, Waste Disposal Cell 17 Closure of the following CAS was previously documented in the Addendum to the Closure Report for Corrective Action Unit 577: Area 5 Chromium Containing Waste Disposal Cells, Nevada National Security Site, Nevada, DOE/EMNV--0030-ADD, dated September 2022 (DOE EM Nevada Program 2022): • CAS 05-21-05, Waste Disposal Cell 20 This second addendum to the Closure Report documents the closure activities that have occurred for CAS 05-21-06, Waste Disposal Cell 21. This is the last CAS in CAU 577. The final waste shipment was placed in the waste disposal cell on November 21, 2022. Following this, closure activities began on November 28, 2022, and were conducted according to the Corrective Action Decision Document/Corrective Action Plan (CADD/CAP) for CAU 577 (DOE EM Nevada Program 2021b). The following closure activities were performed: • Constructing an engineered evapotranspiration cover • Installing two subsidence monuments and vadose zone monitoring equipment • Seeding the cover with a mixture of native plant species • Installing four concrete monuments on the corners of the cover and placing two use restriction (UR) warning signs on each monument These activities fulfill applicable federal and state regulations for closure of CAS 05-21-06 and minimize potential future exposure pathways to buried waste. Completed closure activities are also consistent with closure of the nine historical Resource Conservation and Recovery Act (RCRA) units included in Section 10.2.2 of the RCRA Permit that governs hazardous waste management activities at the Nevada National Security Site (Permit NEV HW0101) (NDEP 2023). UR documentation for this CAS is included in Appendix B of this report. The post-closure plan is presented in detail in the CADD/CAP for CAU 577 (DOE EM Nevada Program 2021b), and the requirements are summarized in Section 5.2 of this document. In accordance with paragraph 5D of the SA, a request to incorporate the requirements for post-closure monitoring of CAU 577 was included with the permit application for RCRA Permit NEV HW0101 that was submitted in January 2022 (NNSA/NFO 2022). The request included the post-closure requirements for the three CASs that had been closed at the time of submittal of the application as well as requirements that would be implemented upon future approval of closure of the remaining two CASs. All CAU 577 post-closure monitoring requirements have been captured in the April 4, 2023, Revision 7 of the RCRA Permit (NDEP 2023). As the RCRA Permit NEV HW0101 has been revised since the submittal of the original CAU 577 Closure Report (DOE EM Nevada Program 2021a) and Addendum 1 (DOE EM Nevada Program 2022), the post-closure requirements in this Addendum 2 report do not align with the previous documents. Specific changes resulting from the issuance of Revision 7 of the RCRA Permit are discussed in Section 5.2 of this report. The requirements in this report are consistent with the current permit (NDEP 2023) and supersede all requirements listed in the CAU 577 Closure Report and Addendum 1. All CAU 577 post-closure requirements should be conducted in accordance with the version of the RCRA Permit that is current at the time of the activities being performed. The DOE EM Nevada Program is requesting a Notice of Completion from NDEP for closure of CAU 577. Although CAU 577 is not a legacy site, the FFACO process is being followed to ensure proper closure of the chromium-containing waste. Therefore, transfer of CAU 577 from Appendix III of the FFACO to Appendix IV, Closed Corrective Action Units, is requested, as all closure activities have been completed.

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