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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)

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Coordinating Permit Offices and the Development of Utility-Scale Geothermal Energy (Presentation)

Permitting is a major component of the geothermal development process. Better coordination across government agencies could reduce uncertainty of the process and the actual time of permitting. This presentation highlights various forms of coordinating permit offices at the state and federal level in the western United States, discusses inefficiencies and mitigation techniques for permitting natural resource projects, analyzes whether various approaches are easily adaptable to utility-scale geothermal development, and addresses advantages and challenges for coordinating permit offices. Key successful strategies identified include: 1. Flexibility in implementing the approach (i.e. less statutory requirements for the approach); 2. Less dependence on a final environmental review for information sharing and permit coordination; 3. State and federal partnerships developed through memorandum of understanding to define roles and share data and/or developer information. A few of the most helpful techniques include: 1. A central point of contact for the developer to ask questions surrounding the project; 2. Pre-application meetings to assist the developer in identifying all of the permits, regulatory approvals, and associated information or data required; 3. A permit schedule or timeline to set expectations for the developer and agencies; 4. Consolidating the public notice, comment, and hearing period into fewer hearings held concurrently.

15 GEOTHERMAL ENERGY↗

Los Alamos National Laboratory Permit Modification Request for Technical Area 63 Transuranic Waste Facility Hazardous Waste Container Storage Unit (Rev. 3)

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.

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)

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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↗

Hanford site excavation permit application automation project - 15187

Mission Support Alliance, LLC (MSA), on behalf of the Department of Energy's Richland Operations Office (DOE-RL), recently implemented the Site Excavation Permit Application (SEPA) at Hanford. The SEPA automation replaced a 20-year-old manual excavation permit process that governed all Hanford Site excavation activities. The manual process required time consuming interaction between numerous resources for submitting an excavation permit to 15 separate permit organizations for approvals and signature. The process involved numerous information exchanges - usually by phone or E-mails, and substantial vehicle travel. It also generated large amounts of paper, lengthy wait periods and the need for continual status updates to permit reviewers until all approvals were obtained. The new SEPA automated system is an entirely paperless application that streamlines over 25 separate manual permit activities into five Web-based processes. The new application provides sizable environmental sustainability benefits in terms of avoiding: paper waste, air pollution and bio-fuel consumption. SEPA also deploys automated innovations that produce an approximate 50 percent operational cost reduction when compared to the manual permit process. (authors)

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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)

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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↗

Funding Mechanisms for Federal Geothermal Permitting

The Department of Energy's (DOE) Geothermal Technologies Office (GTO) initiated a Geothermal Regulatory Roadmap (GRR) in March 2012 to facilitate the development of utility-scale geothermal power. The GRR team conducted a series of workshops during the summer of 2012, which included key representatives from federal and state agencies, as well as industry and other stakeholders involved in the permitting and development of utility-scale geothermal projects. In many of the GRR meetings held with agencies, industry, and other stakeholders, a recurring issue was competing priorities for agency staff's time, which result in permit processing delays. Some agency personnel explained how only a percentage of their weekly or monthly time is allocated to geothermal due to geothermal budget allocations. Others described how their time allocation was determined by agency priorities, and not by specific geothermal budget allocations. In these cases, geothermal may not be a priority at all. One suggestion that was to increase geothermal permit fees or to develop some other mechanisms of cost recovery to fund additional geothermal positions or contractors to process permits more quickly. Because much of the geothermal resource available in the western U.S. is on federal lands, analysis of cost recovery programs could identify opportunities for additional funding mechanisms to support federal agency personnel and processing permits for geothermal projects. This paper discusses: federal agency revenues received for geothermal projects, including: (1) lease revenues, (2) fixed fees, and (3) cost recovery fees; and potential federal agency budget sources for processing geothermal applications, including: (1) cost-recovery fees for services rendered, (2) set-aside funds (such as those employed by EPAct2005), and (3) the appropriations process. This paper then analyzes the three budget sources as mechanisms for increasing funds available to federal agencies for processing geothermal permits and approvals. This paper concludes that both set-asides and cost-recovery fees for services rendered were effective ways of ensuring sufficient funding for processing geothermal authorizations on federally-managed public lands in a timely manner.

15 GEOTHERMAL ENERGY↗

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↗

The National Solar Permitting Database

"The soft costs of solar — costs not associated with hardware — remain stubbornly high. Among the biggest soft costs are those associated with inefficiencies in local permitting and inspection. A study by the National Renewable Energy Laboratory and Lawrence Berkeley National Laboratory estimates that these costs add an average of $0.22/W per residential installation. This project helps reduce non-hardware/balance of system (BOS) costs by creating and maintaining a free and available site of permitting requirements and solar system verification software that installers can use to reduce time, capital, and resource investments in tracking permitting requirements. Software tools to identify best permitting practices can enable government stakeholders to optimize their permitting process and remove superfluous costs and requirements. Like ""a Wikipedia for solar permitting"", users can add, edit, delete, and update information for a given jurisdiction. We incentivize this crowdsourcing approach by recognizing users for their contributions in the form of SEO benefits to their company or organization by linking back to users' websites."

Gunderson, Renic↗

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↗