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This report summarizes the policy, regulatory, legal, and permitting requirements to-date for the siting of a CO 2 injection and storage project in the CarbonSAFE Illinois East Sub-Basin pre-feasibility study area. Where applicable, the East Sub-Basin case study focuses on a proposed carbon capture and storage (CCS) site location in West Terre Haute, Indiana. Indiana has established the legal mechanisms to obtain rights to the subsurface mineral estate with the expectation to apply to reservoir pore space for CO 2 storage in an analogous manner to storage of natural gas, which is a common practice in Indiana. There is, however, no precedent in Indiana to take liability for stored CO 2 . There are currently no Indiana State incentives for CCS, but at the Federal level, tax credits for carbon capture and storage under 26. U.S. Code § 45Q constitute the greatest incentive targeted at CCS projects. The amendment to these credits put forth in the Bipartisan Budget Act (the FUTURE Act) of 2018 substantially increases the per-ton incentive for CCS—from $22.66 per ton in tax year 2017 up to $50 per ton in tax year 2027, for CO 2 not used as an injectant (i.e. saline storage). Additional economic opportunities may exist for the provision of CO 2 for potential EOR in the Illinois Basin. Policies that may support the development of CO 2 pipelines and/or CCS projects in Indiana include: 1) Title 41 of the FAST Act (2015), which created a new governance structure, procedures, and funding authorities in order to improve and expedite Federal review and authorization of covered infrastructure projects, including pipelines, and 2) the Eminent Domain for Transportation of Carbon Dioxide by Pipeline (IC 14-39, Indiana State, 2011), which declares pipeline transportation of CO 2 exclusively to a carbon management application, including sequestration, enhanced oil recovery, and deep saline injection as a benefit to the welfare of Indiana and the people. The US Environmental Protection Agency’s (EPA) Underground Injection Control (UIC) Program Class VI rule and permit requirements address all components pertaining to CO 2 injection and monitoring for long-term storage, and outline the minimum technical criteria to protect underground sources of drinking water at, and surrounding, injection well sites. The Class VI requirements also address financial responsibility for corrective action, post-injection site care, and site closure. In addition, UIC Program public notice requirements include that the EPA issue notice of the draft permit preparation to key stakeholders, and open a public comment period of not less than 30 days. A public hearing about the permit would also be held, if specifically requested by the public. A potential Class VI CO 2 injection well permit for the East Sub-Basin case study site would be obtained through the US EPA Region 5, because the State of Indiana does not have UIC Class VI primacy. Although no CO 2 injection wells have been permitted in Indiana, the US EPA Region 5 (which covers Illinois and Indiana) and the East Sub-Basin CarbonSAFE team (via the Midwest Geological Sequestration Consortium [MGSC]) have Class VI permitting experience from several projects located in Illinois. Based on our experience, applying for a Class VI permit can be an intensive and iterative process requiring clear communication and numerous interactions with EPA staff. In addition to gathering and preparing the data/models and documentation necessary for a permit application’s initial submittal, the subsequent public comments, EPA response and review, and answering of any follow-up questions/requests by the EPA could significantly increase the timeframe of draft permit issuance. The US EPA offers guidance documents regarding the specific Class VI permit requirements, and shows a general permitting timeline example from the FutureGen Alliance 2.0 covering one-and-a-half years from permit submittal to issuance. However, the overall permitting process to-date has a high degree of variability, and in MGSC’s project experience we observed a more extended timeline to receive Class VI permits for each of two CO 2 injection wells.
State and local permitting challenges could impede the ability of large-scale solar (LSS) to meet growing electricity demand in the United States. Here, we review research that explores LSS permitting and its impacts on the pace and scale of LSS project development. Research on LSS permitting is relatively scarce, such that we support our review with research in the context of wind permitting, where appropriate. Further, few studies attempt to rigorously quantify the effects of permitting on the pace and scale of LSS project development. The available evidence allows us to identify various hypotheses and identify gaps for further research. Our review suggests that differences in permitting policies, regulations, and ordinances explain relatively little variation in LSS permitting and development outcomes across jurisdictions, except where jurisdictions implement rules designed to impede LSS. The evidence suggests LSS permitting challenges largely accrue during the implementation of permitting processes. Recent research suggests that community opposition to project development is a key driver of LSS permitting challenges, given that project opponents often use permitting processes to translate opposition into legal action. We call on future researchers to more concretely describe the LSS permitting challenge and to identify the specific actors responsible for implementing solutions.
Developers have identified many non-technical barriers to geothermal power development, including permitting. Activities required for permitting, such as the associated environmental reviews, can take a considerable amount of time and delay project development. This paper discusses the impacts to geothermal development timelines due to the permitting challenges, including the regulatory framework, environmental review process, and ancillary permits. We identified barriers that have the potential to prevent geothermal development or delay timelines and defined improvement scenarios that could assist in expediting geothermal development and permitting timelines and lead to the deployment of additional geothermal resources by 2030 and 2050: (1) the creation of a centralized federal geothermal permitting office and utilization of state permit coordination offices as well as (2) an expansion of existing categorical exclusions applicable to geothermal development on Bureau of Land Management public lands to include the oil and gas categorical exclusions passed as part of the Energy Policy Act of 2005. We utilized the Regional Energy Deployment System (ReEDS) and the Geothermal Electricity Technology Evaluation Model (GETEM) to forecast baseline geothermal deployment based on previous analysis of geothermal project development and permitting timelines. The model results forecast that reductions in geothermal project timelines can have a significant impact on geothermal deployment. For example, using the ReEDS model, we estimated that reducing timelines by two years, perhaps due to the creation of a centralized federal geothermal permitting office and utilization of state permit coordination offices, could result in deployment of an additional 204 MW by 2030 and 768 MW by 2050 - a 13% improvement when compared to the business as usual scenario. The model results forecast that a timeline improvement of four years - for example with an expansion of existing categorical exclusions coupled with the creation of a centralized federal geothermal permitting office and utilization of state permit coordination offices - could result in deployment of an additional 2,529 MW of geothermal capacity by 2030 and 6,917 MW of geothermal capacity by 2050 - an improvement of 116% when compared to the business as usual scenario. These results suggest that reducing development timelines could be a large driver in the deployment of geothermal resources.
The National Renewable Energy Laboratory (NREL) led a collaborative effort to develop the Solar Automated Permit Processing Plus (SolarAPP+), a no-cost solar permitting software solution to address residential solar photovoltaic (PV) permitting resource constraints and streamline solar adoption processes among authorities having jurisdiction (AHJs). The SolarAPP+ is an online portal that automates permit plan review, enabling an instant permit approval process for code-compliant residential PV systems. Based on national model building, electrical, and fire codes, the SolarAPP+ automatically performs a compliance check of permit inputs against code requirements and produces an inspection checklist that can be used to verify installation practices, workmanship, and adherence to the approved design. NREL conducted a two-phase pilot with five participating AHJs and 16 solar contractors, spanning from November 2020 through December 2021, evaluating the ability of SolarAPP+ to deliver instant permits and its impact on four critical areas within each AHJ: permit review timelines; solar adoption timelines; AHJ time saved; and inspection results. The pilot confirmed that SolarAPP+ reduced permit review times to less than one day, reduced solar adoption timelines by an average of 12 days, saved an estimated 2,067 staff hours, and had comparable inspection results to those found in traditional permitting. The pilot further identified key lessons for improving SolarAPP+, including ways to streamline SolarAPP+ adoption, development of training resources, and expansion of supported products.
The United States has great geothermal power potential; however, only a small fraction of this resource has been utilized for power generation. Various barriers, including technical, financial, and regulatory permit delays, are attributed to the lower penetration of geothermal energy into the national grid. Unpredictable environmental reviews and permitting timelines are some of the non-technical barriers that can cause delays in geothermal exploration and utilization plans. This document provides an assessment of the potential economic impact of permitting costs and timelines on geothermal power in California, Nevada, and Utah. Development of geothermal resources requires multi-layered regulatory permitting by local, state, and federal agencies. In this study, we collected and reviewed permit timelines and associated cost data for several existing geothermal power plants as well as for geothermal projects currently undergoing permitting processes for exploration and development activities in California, Nevada, and Utah. We interviewed several geothermal developers and staff from multiple permitting agencies to obtain insight from both sides (i.e., people applying for permits and people processing those applications for California Environmental Quality Act [CEQA] and National Environmental Policy Act [NEPA] reviews and other regulatory compliance). The intent of this project was also to identify informative pathways for the geothermal stakeholder community by which the permitting process could be streamlined.
This report summarizes the EMPOWERED Distributed Energy Resources (DER) Permit Accelerator Pilot project. Its primary objective was to streamline the design, installation, permitting, and inspections of targeted Distributed Energy Resource (DER) solutions. Streamlining these processes is critical to strengthening and accelerating the adoption of DER solutions nationwide. Moreover, streamlined processes help expedite the clean energy transition and expand energy resilience by improving understanding and capability among key stakeholders like property owners, code officials, and the general workforce. The project team accomplished this by developing and deploying a set of design and permitting guides for simple DER solutions, which they rolled out via a permitting pilot program. The project team developed nine permitting and inspection guides for simple DER solutions, as follows: 1. Single-Family and Duplex: Electric Vehicle Service Equipment (EVSE), and Storage, Solar + Storage (each in two code cycles) 2. Multi-family and Office: EVSE, Storage, Solar + Storage (each in two code cycles) 3. A permitting process guide to support the implementation of the permitting guides. The guides cover key code requirements via plan review and field inspection checklists for code officials and building owners to follow to streamline the permitting and inspections process for DER solutions. Following the development of the initial set of guides, the project team formed two cohorts, each made up of four jurisdictions, to participate in the Permit Accelerator Pilot. Each cohort received training and technical assistance to support them in incorporating the guides into use. The project successfully engaged jurisdictions in two disparate US regions: Chelsea, Somerville, Natick, and Norwood in metro Boston; and Pima County, Town of Gilbert, Flagstaff, and Sedona in Arizona. Feedback gathered from the project was valuable in refining the guides to better address jurisdictional needs. After the pilot period, the project team developed final versions of the guides based on extensive feedback from the cohorts and from external technical peer review. Feedback included needs and barriers related to implementation, as well as detailed technical improvements from external peer review. The final guides were presented in a series of webinars with a national reach, with 192 attendees from 35 states in the live session of the final webinar, and the final guides are posted online and available for use nationwide. Key findings: • The most receptive jurisdictions were those adjacent to other jurisdictions that had already adopted similar initiatives. The least receptive jurisdictions were those in the midst of adopting new code cycles. • The most common barrier to jurisdictional adoption of new guidelines were internal administrative and process delays, more so than technical barriers. • The main technical barrier to adoption proved to be the concern of fire hazard risks posed by energy storage systems. There is some apprehension in the code enforcement community about the safety of the batteries. Education coordinated with fire and safety services will help alleviate concerns and increase confidence in the acceptance of innovative technologies. • Opportunities to further leverage and advance the guides and related resources include outreach, education, and jurisdictional support; updates to the resources to align with code cycle changes and local requirements; and advancements supporting emerging technologies.
The demand for new energy infrastructure is increasing across the United States, but heterogenous permitting processes and embedded requirements across different local jurisdictions can cause project delays, increase “soft costs,” and hinder developer expansion. This study analyzes the variability in local permitting requirements across the U.S. and develops a quantitative approach to describe their clarity and effectiveness in enabling infrastructure project development. By using an Energy Language Model (ELM), a large language model (LLM) for energy technologies, we systematically gathered permitting information from nearly 300 state-, county-, and city-level documents, creating a structured dataset of requirements and procedures on an unprecedented scale and speed. Our analysis revealed that local (city and county) permitting requirement documents are underrepresented compared to state-level guidance documents, which can impede timely and cost-effective installation of new electric infrastructure. Our validation process showed that the final database has an accuracy of approximately 95%. We, further, created a new quantitative method to score permitting requirements for clarity and efficiency, with electric vehicle supply equipment as an initial use case. The average local permitting document scored a 1.8 out of 5, which we interpret as meaning that half of the requirements developers face when installing electric infrastructure are ambiguous, increasing both cost and time. We also created a “Generalized Permit Process”, highlighting common procedural steps and identifying specific opportunities for municipalities to improve their documentation. This research establishes a systematic and scalable framework for evaluating the complexities of local infrastructure permitting processes by combining LLM-powered data collection and quantitative scoring. The framework enables policymakers and developers to identify and mitigate procedural bottlenecks, with the expectation that these improvements can accelerate application review and approval, reduce project costs, and expedite connection to utility distribution grids. As a foundational approach for streamlining local project development processes, this study’s methods are intended to be extended to a wide range of energy applications.
Despite having a large geothermal power potential in the United States, only a small fraction has been developed for power generation. Various barriers, including technical, financial, and regulatory permit delays, are attributed to lower contribution of geothermal energy in the national grid. Unpredictable environmental reviews and permitting timelines are some of the non-technical barriers that can cause delays in geothermal exploration and utilization plans. Our study shows that the geothermal permitting timelines can vary from six months to several years, depending on the presence or absence of biological resources, cultural resources, and sensitive environmental issues at the project site. The potential impacts of these permit barriers can range from investors abandoning geothermal development to making the product (i.e., electricity) more expensive and uncompetitive. In this study, we conducted economic analysis to assess the impact of permitting timelines on cost of produced electricity from geothermal resources using data from existing geothermal plants as well as prospective sites. In this paper, we present collected timelines data, approach, and results of economic impact of permitting timelines on geothermal power. We evaluated the various environmental management and permit review processes by considering a hypothetical geothermal project in the Salton Sea Known Geothermal Resource Area. Because of the variety of the biological and environmental issues and the involvement of local, state, and federal agencies with overlapping jurisdictions, this project could go through one of the many California Environmental Quality Act (CEQA) and National Environmental Policy Act (NEPA) review scenarios that range from the least to the most complex in its circumstances. The fastest CEQA/NEPA review timelines would have the project completed in six years. In contrast, the project would substantially need longer time to complete if it were located in an area with significant environmental resources or cultural issues that required permitting from various agencies. With increasing project completion timelines, the simplified levelized cost of electricity (sLCOE) can be 4 to 11% higher with longer CEQA/NEPA review timelines than the sLCOE value with the fastest CEQA/NEPA review timeline. Lengthier CEQA/NEPA review timelines could also result in loss of $64 million to $227 million in potential revenue. Such significant economic impacts could determine the success of a geothermal project.
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.
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.
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)
This Class 3 permit modification requests the addition of a hazardous waste management unit, the Transuranic Waste Facility (TWF), to the Los Alamos National Laboratory Hazardous Waste Facility Permit (November 2010), (hereinafter referred to as “the Permit”). The Permit was issued by the New Mexico Environment Department (NMED) in November, 1989 and renewed in 2010 (NMED 2010). The Los Alamos National Laboratory (LANL) Environmental Protection Agency (EPA) Identification Number is NM0890010515. The facility is owned by the National Nuclear Security Administration (NNSA) of the Department of Energy (DOE), and is operated jointly by NNSA-DOE and by Los Alamos National Security, LLC (LANS). This permit modification request has been prepared to address requirements in the New Mexico Administrative Code, Title 20, Chapter 4, Part 1 (20.4.1 NMAC), as revised October 2009, that are specific for the proposed new hazardous waste storage operations at the TWF. The renewed Permit contains many of the conditions addressing the requirements of the New Mexico Hazardous Waste Act (NMHWA) and implementing regulations, specifically 40 CFR, that are common to all LANL hazardous waste management units. The relevant sections of the Permit are referenced throughout this document. Together, information provided in this document and in the Permit will meet the applicable requirements specified in 40 CFR Parts 264 and 270 for the proposed unit.
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)
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.
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.
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.
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.