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Los Alamos National Laboratory Hazardous Waste Facility Permit Community Relations Plan

The requirements of the Hazardous Waste Facility Permit are fulfilled through execution of LANL's fourth strategic goal: “Enabling mission delivery through next-generation facility, infrastructure, and operational excellence.” With input from our stakeholders, we will continue to fulfill those requirements and to improve our waste operations. In 2015, the Laboratory purpose statement focused waste management efforts by directing delivery of mission success through operational effectiveness and scientific excellence. This Plan advances that purpose through community involvement. In the process of achieving our national security mission, Los Alamos National Laboratory generates some hazardous and mixed waste. Hazardous waste is solid waste that is dangerous or potentially harmful to human health or the environment. Hazardous wastes can be liquids, solids, gases, or sludges. They can be discarded as commercial products, such as cleaning fluids or pesticides, or as the byproducts of operations. Specific substances are listed in 40 Code of Federal Regulations (CFR), Part 261: 40 CFR Part 261. Hazardous waste management activities are regulated by the U. S. Environmental Protection Agency and the New Mexico Environment Department (NMED) pursuant to New Mexico Hazardous Waste Act (HWA; Chapter 74, Article 4 NMSA 1978) and regulations under the Act. In 1989, NMED issued the Hazardous Waste Facility Permit (EPA ID Number NM0890010515-1) that established standards for the Laboratory to manage, store, and treat hazardous wastes on-site and to undertake the closure, post closure care, and cleanup as necessary, of permitted waste management units. On November 30, 2010, NMED renewed the Hazardous Waste Facility Permit (the Permit). In June 2020 the Permittees submitted a permit renewal application to the NMED for their review and approval. The Hazardous Waste Facility Permit Community Relations Plan (CRP) describes the scope of public involvement in the activities of the Permit. The CRP is specifically designed to facilitate the community outreach, engagement, and relations activities concerning the Laboratory’s Hazardous Waste Facility Permit and coordinates with but does not include public involvement for other Laboratory programs, initiatives, or environmental activities.

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Joint Comments from the Department of Energy, National Nuclear Security Administration (DOE NNSA) Los Alamos Field Office and Triad National Security, LLC on the U.S. Environmental Protection Agency’s New Mexico State-Wide Municipal Separate Storm Sewer System Strawman General Permit

In December 2020 and March 2021, EPA issued two MS4 strawman permit drafts specific to the Los Alamos area. EPA made text changes in the 2 nd strawman permit based on stakeholder comments related to the initial draft. During the public meeting on the Los Alamos area designation decision held on February 13, 2024, EPA staff stated that comments from the past strawman permits would be incorporated into the new MS4 permit to be issued state-wide. However, it does not appear that any of the text changes from the 2 nd Los Alamos area strawman permit were included in this state-wide general MS4 strawman permit. For reference, the 2 nd Los Alamos area revised strawman permit is included with these comments as Attachment 2. Many of the following comments refer to or state EPA’s updated text included in the 2 nd Los Alamos area strawman permit. The updated text from this 2 nd strawman permit that are referenced in the following comments should be applicable state-wide and it is suggested that this past work be reconsidered and incorporated.

54 ENVIRONMENTAL SCIENCES↗

Direct Feed Low Activity Waste Integrated Permitting - 16642

An overall Hanford permitting strategy for the U. S. Department of Energy (DOE) Office of River Protection (ORP) is being developed to support the Direct Feed Low- Activity Waste (DFLAW) Program. The strategy identifies new permits and modifications of existing permits, as well as major regulatory approvals to support the startup and operation of nuclear systems necessary to feed low activity tank waste, pretreat the waste, operate the Waste Treatment and Immobilization Plant (WTP) Low Activity Waste (LAW) facility to treat tank waste, and dispose of waste streams. Types of permits include hazardous waste, toxic air, and radiological air licenses. Four different Contractors manage operations at Tank Farms, WTP, Utilities/Infrastructure, and Waste Disposal. Due to this complexity and the number of interfaces required, the need to have a strategic overview of all permits was evident. Approximately 25 permits and 4 major regulatory approvals are identified to implement DFLAW. The strategy will help guide integrated planning, scheduling and sequencing of permits and regulatory approvals to support DOE ORP's overall schedule for construction, commissioning and operation of DFLAW. Development of the strategy included extensive collaboration and coordination of an Integrated Permitting Team with staff and management representation from DOE, CH2M Hill Plateau Remediation Contractor (CHPRC), Washington River Protection Solutions LLC (WRPS), and Bechtel National Inc. (BNI). Information sessions and briefings have been conducted with the Washington State Department of Ecology (Ecology) and Washington State Department of Health (DOH) in the development of this overall strategy. Additionally, interface meetings are held with Ecology and DOH on specific projects early in the design phase to validate the permitting approach, identify key issues and information, and discuss requirements and assumptions. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Acquisition and Implementation of a Comprehensive Environmental Permits Linking Tool at Savannah River Site - 20234

Historically, Savannah River Nuclear Solutions LLC (SRNS) tracked environmental regulatory commitments and the requirements from hundreds of permits at the Savannah River Site (SRS) using several separate methods, making integrated compliance assurance cumbersome and labor-intensive. When SRNS experienced an increase in environmental issues in 2017, SRNS management and U.S. Department of Energy - Savannah River (DOE-SR) management decided a single, proactive approach was needed to capture environmental permit information (including regulations, Consent Orders, DOE Orders, and any other state or federally issued statement of requirements), track the tasks necessary to ensure compliance with these requirements, and thereby mitigate the risk of noncompliance. SRNS developed a list of mandatory objectives that the tool must meet to function as a Comprehensive Environmental Permits Linking Tool (CEPLT). A key requirement was the ability to map Site permits to their governed locations and display the associated requirements at the compliance point (e.g., outfall, stack, waste unit, etc.). Several options included modifying existing onsite resources, building a custom onsite solution, purchasing an off-the-shelf solution, and contracting an offsite developer to build a custom solution. SRNS concluded an off-the-shelf solution with configuration and customization options would provide the flexibility to fit the unique needs of Savannah River Site (SRS) while taking advantage of industry-tested software and providing a reduced deployment timeline. SRNS chose Gensuite{sup R} a, a cloud-based solution that offers numerous a la carte applications in the environmental, health, and safety arenas, as the best candidate. SRNS selected three (3) integrated applications (Compliance Calendar, Permit Manager, and Mapper) to function as the CEPLT. The Compliance Calendar module allows for creation and tracking of regulatory commitment tasks assigned to responsible environmental professionals. Permit Manager organizes permits and other requirement documents, linking the commitments in each to Compliance Calendar tasks and/or implementing procedures. Mapper provides GIS capability for mapping the data from the other two modules to their physical onsite locations. The CEPLT was configured to allow for other SRS Site Tenants to eventually utilize the applications. Additionally, DOE-SR uses the CEPLT to provide an overview of contractor environmental compliance activities and to organize DOE-specific documents and tasks. The CEPLT fulfilled the requirement of meeting current compliance needs as well as providing the ability to grow as new organizations are incorporated and functionality is expanded. SRNS now uses the CEPLT to more effectively manage permit requirements, improve knowledge transfer, and increase the Site's overall protection of the environment, the Site worker, and the public. Possible future uses of the system include integration of mobile applications for timely communication of potential non-compliant conditions and DOE complex-wide deployment allowing for enhanced DOE site and Head Quarters oversight. Implementation of CEPLT will result in cost savings, both in terms of dollars and man-hours. (authors)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Expedited desalination permitting enables adaptive planning and water system cost reduction

Seawater desalination is a drought-proof water supply for coastal cities, but widespread development of desalination plants in the U.S. has been limited by both cost and the complexity of permitting processes designed to minimize environmental impact . This work estimates the value of accelerating the permitting timeline without changing environmental or social standards. On average, faster permitting reduces the frequency of desalination plant construction and operation, the overall costs of robust water system operation, the environmental impacts of drought-tolerant water supplies due to shorter duration of plant operation. Expedited permitting allows fundamental changes in how water infrastructure is deployed, facilitating a transition from anticipatory construction and continuous operation of seawater desalination capacity as a redundant drought buffer to just-in-time (i.e. adaptive) deployment of seawater desalination capacity when critical drought thresholds are crossed. We demonstrate the value of expedited desalination permitting in enabling adaptive planning and reducing water system costs using a simple case study in Santa Barbara, CA. We discuss additional forms of adaptive water infrastructure planning as enabled by faster permitting and address their challenges and opportunities. Lastly, we identify synergies between innovation in adaptive planning, innovation in expedited permitting practices, and innovation in water technology.

adaptive planning↗

Solar Automated Permit Processing Software for Distributed PV (Cooperative Research and Development Final Report, CRADA Number CRD-19-00825)

NREL and its project partners built and commercialized the novel Solar Automated Permitting Processing Plus (SolarAPP+) software platform that delivers instant residential rooftop solar permits. The tool provides installers with a standard portal for entering permit information for residential solar systems across all Authorities Having Jurisdiction (AHJs) using SolarAPP+, thereby providing a streamlined plan review form, transparency into permitting timelines, and required specifications. The project has proven to reduce permitting timelines from as many as 20 business days to zero, delivering solar projects faster in the four participating AHJs using the platform. Streamlining permitting timelines, all else equal, results in consumers installing their systems and reducing their electricity bills faster. The continued expansion of SolarAPP+ features and adoption nationwide will expand the benefits of the SolarAPP+ beyond the current user base.

14 SOLAR ENERGY↗

Potential Air Pollutant Emissions and Permitting Classifications for Two Biorefinery Process Designs in the United States

Advanced biofuel production facilities (biorefineries), such as those envisioned by the United States (U.S.) Renewable Fuel Standard and U.S. Department of Energy's research and development programs, often lack historical air pollutant emissions data, which can pose challenges for obtaining air emission permits that are required for construction and operation. To help fill this knowledge gap, we perform a thorough regulatory analysis and use engineering process designs to assess the applicability of federal air regulations and quantify air pollutant emissions for two feasibility-level biorefinery designs. We find that without additional emission-control technologies both biorefineries would likely be required to obtain major source permits under the Clean Air Act's New Source Review program. The permitting classification (so-called 'major' or 'minor') has implications for the time and effort required for permitting and therefore affects the cost of capital and the fuel selling price. Consequently, we explore additional technically feasible emission-control technologies and process modifications that have the potential to reduce emissions to achieve a minor source permitting classification. Finally, our analysis of air pollutant emissions and controls can assist biorefinery developers with the air permitting process and inform regulatory agencies about potential permitting pathways for novel biorefinery designs.

09 BIOMASS FUELS↗

Building an EPA Class VI Permit Application

Summary To accelerate the commercialization of carbon capture and storage (CCS), the US Department of Energy (US DOE) is building on decades of characterization efforts and pilot-scale projects through their CarbonSAFE program. Administered through their National Energy Technology Laboratory, this program seeks to bring fully integrated projects to the sector that can store more than 50 million tonnes of CO2 over a 30-year period. The program, which was enacted before the enhancement of Internal Revenue Code Section 45Q, is in the capture assessment, characterization, and permitting phase. The objectives of this paper are to discuss (a) the injection permitting requirements of the CarbonSAFE projects; (b) information gathering in support of the permit; (c) the timelines of field development and permit-related activities; (d) the major technical components of the field development plan; and (e) early feedback from the regulators toward acceptance of the permit. In Mississippi, more than 30,000 acres have been characterized by six deep characterization wells, a deep groundwater well, and 92 line miles of 2D seismic as part of the CarbonSAFE Project ECO2S. During the acquisition of seismic data, all receiver lines were live, which resulted in the generation of a pseudo-3D seismic design. The incorporation of a 3D seismic survey was not included as part of this project due to logistical difficulties presented by the undulating, wooded surface terrain. A suite of openhole geophysical logs was taken from each well, allowing for a detailed interpretation of prospective storage reservoirs and confining intervals to complement the analysis carried out on the 290 ft of a whole core that was cut through the prospective confining zone and storage reservoir. The detailed geologic and reservoir data were assembled and entered into a 3D model to assess the injection capacity and the area of review (AoR). This information fed into the detailed corrective action, monitoring, testing, and postinjection site care (PISC) modeling. The results have been exceptional. The geologic assessment has revealed three primary storage targets, ranging in depth from 3,500 ft to 6,000 ft. These storage reservoirs net 1,300 ft of sandstone, with mean porosity and permeability of 29% and 3.6 darcies, respectively. Together, these reservoirs have storage capacities that may exceed 20 million tonnes per square mile, making this a gigatonne prospect. Forward modeling of the project resulted in an AoR of 16 sq miles, injecting about 8000 t/d, for 30 years, via two deep injection wells. The excellent confining characteristics of the caprock, relatively simple geologic structure, and lack of historical well drilling activity in this area provide excellent containment of the injected CO2. Based on this work, the project has proposed 20 years of PISC. To date, only two US CO2 injection permits have been granted. These projects relied on a singular capture point feeding a singular sequestration point (source to sink), and considerations have not been made to garner CO2 emissions from other industrial sources. The Kemper County Storage Complex is a first-of-its-kind storage hub concept that looks to develop an area capable of storing significant quantities of CO2 from the region. Also, this work will show how characterization efforts, geological and numerical modeling efforts, and plan development were constructed in support of permit and incentives acceptance.

Energy & Fuels↗

Extract useful information from building permits data to profile a city’s building retrofit history

Building retrofit is one of the key strategies for cities to reduce energy use and GHG emissions. The historical information about changes to buildings is crucial to infer the buildings’ current energy system efficiency levels and to identify candidate buildings for retrofit. In general, a building permit is required before the start of any construction activity of a building, such as changing building structure, remodeling, or installing new equipment. Moreover, many large cities provide public datasets of building permits in history. Therefore, the permits are a potentially good resource for mining information on the city’s retrofit history. In this study, we use the permit dataset from the city of San Francisco as a case study. Location and time information from the dataset is also used to depict the retrofit timeline of each building and the whole building stock. The type of work of the permit is inferred from the descriptive text by a machine learning model. At last, the limitations of the current permit dataset and potential improvements on the permit data management are discussed to better utilize the information in the future.

Zhang, Wanni↗

An Historic Perspective of NPDES Individual Permit for Storm Water Discharges from Solid Waste Management Units at Los Alamos National Laboratory - 18667

The Los Alamos National Laboratory (LANL) and the associated communities of Los Alamos and White Rock are located in Los Alamos County in north-central New Mexico approximately 60 mi north-northeast of Albuquerque and 25 mi northwest of Santa Fe. The 36-mi{sup 2} facility is situated on the Pajarito Plateau, which consists of a series of fingerlike mesas separated by deep east-to-west oriented canyons cut by predominately ephemeral and intermittent streams. The mesa tops range in elevation from approximately 7800 ft. on the flanks of the Jemez Mountains to about 6200 ft. at their eastern termination above the Rio Grande Canyon. The land surrounding the Laboratory is largely undeveloped. Public access to much of the facility is limited for safety and security reasons. Large tracts of surrounding land are held by the U.S. Forest Service (Santa Fe National Forest), the Bureau of Land Management (Bandelier National Monument), the General Services Administration and San Ildefonso Pueblo. Storm water discharges from Solid Waste Management Units (SWMUs) have been regulated at the LANL since the early 1990's and have evolved into an Individual Stormwater Permit (IP) that may be one of the most complex in the nation. Historically, storm water discharges from SWMUs at LANL were regulated under a nationwide general permit using a watershed based approach requiring a Storm Water Pollution Prevention Plan (SWPPP), monitoring at sub-watershed scale 'USGS like' gage stations, and inspection and maintenance of erosion controls. In 2001, the Cerro Grande Fire destroyed many Laboratory structures, residential homes and over 80,000 acres of forested lands in the upper watershed above Los Alamos that significantly changed the local hydrology. Several years later, a Federal Facilities Compliance Agreement (FFCA) was issued by U.S. Environmental Protection Agency (USEPA) that was followed by a Clean Water Act lawsuit filed by concerned citizens, the result of which required more focus on stormwater discharges from individual SWMUs and an IP covering over 400 Sites. The IP contains non-numeric technology-based effluent limitations, coupled with a comprehensive, coordinated inspection and monitoring program, to minimize pollutants in LANL's storm water discharges associated with historical industrial activities from specified Sites. Non-numeric technology-based effluent limitations include minimizing pollutants in discharges through erosion and sedimentation controls, management of run-on and runoff, employee training, inspection and maintenance of controls, annual reporting and public involvement. The IP establishes Target Action Levels (TALs) that are equivalent to New Mexico State water-quality criteria. These TALs are used as benchmarks to determine the effectiveness of control measures implemented under the IP. That is, storm water quality sample results from SWMU discharges are compared with applicable TALs. If one or more sample results exceed a TAL, LANL must take additional corrective action. The TAL results are also confounded by high levels of naturally occurring constituents such as aluminum and gross alpha, and urban constituents such as copper, zinc and PCBs which may not be a source from the regulated SWMU. Due to the remote rugged terrain, security access issues, number of monitoring locations, stringent TALs, reporting requirements and public involvement requirements, this permit is likely one of the most stringent and complex in the country. The Laboratory has implemented this permit in a compliant manner for the past seven years and is anticipating the issuance of a new permit in the next few months. This paper will cover permit requirements related to control measure installations, monitoring, reporting and public involvement as well as process improvements and remaining water quality initiatives such as developing studies to address issues such as discriminating between natural background levels and LANL-related contaminants during the execution of this unique permit. (author)

12 MANAGEMENT OF RADIOACTIVE AND NON-RADIOACTIVE W↗

Marine Energy Environmental Permitting and Compliance Costs

Costs to permit Marine Energy projects are poorly understood. In this paper we examine environmental compliance and permitting costs for 19 projects in the U.S., covering the last 2 decades. Guided discussions were conducted with developers over a 3-year period to obtain historical and ongoing project cost data relative to environmental studies (e.g., baseline or pre-project site characterization as well as post-installation effects monitoring), stakeholder outreach, and mitigation, as well as qualitative experience of the permitting process. Data are organized in categories of technology type, permitted capacity, pre- and post-installation, geographic location, and funding types. We also compare our findings with earlier logic models created for the Department of Energy (i.e., Reference Models). Environmental studies most commonly performed were for Fish and Fisheries, Noise, Marine Habitat/Benthic Studies and Marine Mammals. Studies for tidal projects were more expensive than those performed for wave projects and the range of reported project costs tended to be wider than ranges predicted by logic models. For eight projects reporting full project costs, from project start to FERC or USACE permit, the average amount for environmental permitting compliance was 14.6%.

16 TIDAL AND WAVE POWER↗

HWMA RCRA Storage and Treatment Permit for the Material and Fuels Complex on the Idaho National Laboratory

Owners and operators of facilities that treat, store, and dispose of hazardous waste must obtain an operating permit required by Subtitle C of the Resource Conservation and Recovery Act (RCRA). The operating permit for the Materials and Fuels Complex is the Hazardous Waste Management Act (HWMA)/RCRA Storage and Treatment Permit. The permit defines the conditions and requirements that apply to the treatment and storage of hazardous waste managed at the treatment, storage and disposal facilities (TSDF). The regulations governing the permitting process are found at 40 CFR Pa 124 and 270.

99 GENERAL AND MISCELLANEOUS↗

NORTH DAKOTA CARBONSAFE PHASE III: SITE CHARACTERIZATION AND PERMITTING OF GEOLOGIC STORAGE OF CARBON DIOXIDE

The Energy & Environmental Research Center (EERC), in partnership with Minnkota Power Cooperative Inc. (Minnkota), SLB, and Computer Modelling Group Ltd. (CMG), supported wide-scale deployment of carbon capture and storage (CCS) as part of the U.S. Department of Energy (DOE) National Energy Technology Laboratory Carbon Storage Assurance Facility Enterprise (CarbonSAFE) Initiative Phase III. This phase included the acquisition, analysis, and development of information to fully characterize two storage complexes to demonstrate viable storage resources for commercial volumes of CO2 (defined by DOE as a minimum of 50 million tonnes [MMt] of CO2 within a 30-year period) (National Energy Technology Laboratory, 2024). Phase III also involved the preparation, submission, and approval of North Dakota underground injection control (UIC) Class VI storage facility permits (SFPs)—required precursors to applications for Class VI injection well permits. The presumed viability of commercial-scale CCS, situated adjacent to Minnkota’s Milton R. Young Station (MRYS), is validated by Minnkota’s continued pursuit of Project Tundra—an initiative to build the world’s largest lignite-based CCS project in central North Dakota (www.projecttundrand.com). Project Tundra comprises two scopes of work, Tundra Capture (installation of postcombustion CO2 capture at MRYS) and Tundra SGS (secure geologic storage). The efforts of North Dakota CarbonSAFE Phase III, Site Characterization and Permitting, supported Tundra SGS. Extensive site-specific characterization activities included a successful multimeasurement geophysical approach and drilling a stratigraphic test well (J-ROC 1, subsequently renamed Liberty-1) adjacent to MRYS. Core collection and analyses, downhole testing and fluid sampling, and geophysical logging were performed on J-ROC 1 and on a nearby stratigraphic test well (known as J-LOC 1), which was drilled, cored, and tested under a complementary project funded by the North Dakota Lignite Research Program. The injection tests performed on J-LOC 1 positively impacted the CarbonSAFE project, resulting in fewer proposed injection wells and significant construction, operations, and monitoring cost savings. The characterization data collected and analyses performed were integrated into geologic models, and successive numerical simulations were run to determine CO2 plume extent and subsurface pressure buildup associated with the planned CO2 injection rate of nearly 4 MMt per year. The latter doubles the CarbonSAFE Initiative goal with an estimated 100 MMt of CO2 stored in 20 years. Application of the U.S. Environmental Protection Agency’s (EPA’s) method for estimating the Class VI Rule area of review (AOR) to the overpressurized Broom Creek Formation inspired an alternative method of calculation, called risk-based AOR delineation. This peer-reviewed method was applied for the first time during the storage facility-permitting process. The two SFP applications submitted in 2021 successfully resulted in North Dakota Industrial Commission (NDIC) orders in 2022 authorizing the creation of the storage facility areas and amalgamation of pore space as well as establishing financial responsibility requirements. After approval of the SFPs, Minnkota filed in 2022 applications for permits to reenter the J-ROC 1 well and to drill two new wells—all with the intended purpose to become Class VI injection wells. To establish eligibility under the Internal Revenue Code for Section 45Q tax incentives, a monitoring, reporting, and verification (MRV) plan was prepared and submitted by Minnkota to EPA in 2022, resulting in the first such plan approved in North Dakota. Also in 2022, under the National Environmental Policy Act (NEPA), Minnkota prepared and submitted an environmental information volume (EIV) describing the proposed CCS project and associated potential environmental impacts. Based on the EIV, DOE determined that the proposed construction project required an environmental assessment, and Minnkota submitted the first draft in 2023 and a revised draft in 2024. Both submissions were followed by a public comment period. Subsequently, DOE issued a finding of no significant impact (FONSI) on September 13, 2024. A successful outreach program, strongly based in the production, presentation, and dissemination of informational material, fostered an environment to aid stakeholders in making informed decisions regarding the planned project. Opportunities for public input were provided at various steps along the way, including at county planning and zoning meetings, before and during the SFP administrative hearing, and during environmental assessment public comment periods. In addition, land/pore space owners and mineral owners had various points of contact, including granting access rights, securing pore space leasing, and mineral owner notifications. Based upon the successful storage facility permitting issued by NDIC, approval of the MRV plan by EPA, and receipt of a FONSI under the NEPA, Minnkota is continuing its pursuit of Project Tundra. In December 2023, the Office of Clean Energy Demonstrations under its Carbon Capture Demonstrations Projects Program announced funding for the capture system (Office of Clean Energy Demonstrations, 2023) and a proposal for CarbonSAFE Phase IV: Construction funding was submitted in March 2024 for the storage project. A go/no-go decision to proceed with construction and operations in the Broom Creek Formation is anticipated in 2024. References National Energy Technology Laboratory, CarbonSafe Initiative, https://netl.doe.gov/carbon-management/carbon-storage/carbonsafe (accessed August 2024). Office of Clean Energy Demonstrations, 2023, OCED selects three projects in CA, ND, and TX to reduce harmful carbon pollution, create new economic opportunities, and advance carbon reducing technologies, December, www.energy.gov/oced/articles/oced-selects-three-projects-ca-nd-and-tx-reduce-harmful-carbon-pollution-create-new (accessed August 2024).

Peck, Wesley↗

Illinois Storage Corridor, CarbonSAFE Phase III: UIC Class VI Permitting Plan

The Illinois Storage Corridor (ISC) project evaluated two distinct sites to determine the feasibility of commercial-scale CO₂ storage at each. The project leveraged the region's exceptional geological characteristics, particularly the well-characterized Cambro-Ordovician Storage Complex, to enable permanent geological storage of more than 50 million tonnes of CO₂ over 30 years. The two storage sites are located at One Earth Energy (OEE) facility in northcentral Illinois and Prairie State Generating Company (PSGC) in southcentral Illinois. Once operational, these facilities will combine to capture and store more than 6.5 million tonnes of CO₂ per year, positioning the ISC among the largest carbon storage regions globally. Preliminary homogeneous dynamic modeling based on regional and site-specific reservoir characteristics indicates promising injection capabilities at both locations. For the OEE site, modeling predicts a maximum allowable injection rate of 3.7 MTPA, with a baseline scenario of 1.7 MTPA over 30 years producing a CO₂ plume radius of 1.4 miles at end of injection. For the PSGC site, incorporating recent well data, modeling indicates a single-well maximum injection rate of 2.1 MTPA, with a plume radius of 4.2 miles at end of injection for the 60 MT over 30 years scenario. The primary objective of this CarbonSAFE Phase III project is to develop and submit Class VI Underground Injection Control (UIC) permit applications to the U.S. Environmental Protection Agency Region 5. The permitting plan outlines comprehensive site characterization, Area of Review delineation, monitoring programs, well construction designs, financial responsibility provisions, and post-injection site care procedures necessary to demonstrate safe, permanent CO₂ storage protective of underground sources of drinking water. Three UIC Class VI permit applications for the OEE site were submitted to EPA in October 2022 and are progressing through technical review, with final permit decision projected by June 2026. Through five rounds of Requests for Additional Information and responses, the applications have been refined to address computational modeling, area of review delineation, well integrity, monitoring protocols, and financial assurance requirements. For the PSGC site, finalized characterization and permitting documentation was delivered directly to the facility in July 2023 due to business constraints precluding formal federal regulatory submission. This comprehensive permitting effort builds upon extensive prior subsurface evaluations and demonstration projects that have confirmed the feasibility of widespread commercial-scale carbon storage in the region.

01 COAL, LIGNITE, AND PEAT↗

Air Permitting Implications of a Biorefinery Producing Raw Bio-Oil in Comparison with Producing Gasoline and Diesel Blendstocks

A biorefinery, considered a chemical process plant under the Clean Air Act permitting program, could be classified as a major or minor source based on the size of the facility and magnitude of regulated pollutants emitted. Our previous analysis indicates that a biorefinery using fast pyrolysis conversion process to produce finished gasoline and diesel blendstocks with a capacity of processing 2,000 dry metric tons of biomass per day would likely be classified as a major source because several regulated pollutants (such as particulate matter, sulfur dioxide, nitrogen oxide) are estimated to exceed the 100 tons per year (tpy) major source threshold, applicable to chemical process plants. Being subject to a major source classification could pose additional challenges associated with obtaining an air permit in a timely manner before the biorefinery can start its construction. Recent developments propose an alternative approach to utilize bio-oil produced via the fast pyrolysis conversion process by shipping it to an existing petroleum refinery, where the raw bio-oil can be blended with petroleum-based feedstocks (e.g., vacuum gas oil) to produce gasoline and diesel blendstocks with renewable content. Without having to hydro-treat raw bio-oil, a biorefinery is likely to reduce its potential-to-emit to below the 100 tpy major source threshold, and therefore expedite its permitting process. We compare the PTE estimates for the two biorefinery designs with and without hydrotreating of bio-oils and examine the air permitting implications on potential air permit classification and discuss the best available control technology requirements for the major source biorefinery utilizing hydrotreating operation. Our analysis is expected to provide useful information to new biofuel project developers to identify opportunities to overcome challenges associated with air permitting.

09 BIOMASS FUELS↗

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↗

Air Dispersion Modeling for the Idaho National Laboratory Permit to Construct P-2015.0023 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-2015.0023 issued to U S Dept. of Energy – Idaho National Laboratory (INL) on January 11, 2018 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-2015.0023 Facility Emission Cap Revision Request (DOE-ID 2020). All 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.

99 GENERAL AND MISCELLANEOUS↗

Environmental Permitting and Compliance Cost Reduction Strategies for the MHK Industry: Lessons Learned from Other Industries

The marine and hydrokinetic (MHK) industry plays a vital role in the U.S. clean energy strategy by providing a renewable, domestic energy source that may offset the need for traditional energy sources. The first MHK deployments in the U.S. have incurred very high permitting costs and long timelines for deploying projects, which increases project risk and discourages investment. A key challenge to advancing an economically competitive U.S. MHK industry is reducing the time and cost required for environmental permitting and compliance with government regulations. Other industries such as offshore oil and gas, offshore wind energy, subsea power and data cables, onshore wind energy, and solar energy facilities have all developed more robust permitting and compliance pathways that provide lessons for the MHK industry in the U.S. and may help inform the global consenting process. Based on in-depth review and research into each of the other industries, we describe the environmental permitting pathways, the main environmental concerns and types of monitoring typically associated with them, and factors that appear to have eased environmental permitting and compliance issues.

other industries↗