Hydrogen is commonly produced using steam methane reforming (SMR), which requires heat, a catalyst, and feedstock such as natural gas. SMR operations generate atmospheric emissions from combustion and process vents which may require air permitting. Air permitting can be a complicated process that delays facility construction and project start-up.
Comprehensive feasibility studies include phases to facilitate pre-application meetings and submission of a complete air permit application in a timely, cost-effective manner. Based on our case studies, SCS suggests a four-phase approach.
Phase 1: Preparation and Due Diligence
To begin the evaluation, your engineer compiles all available project information, such as plot plans, process flow diagrams, equipment lists with specifications, zoning, grading, and utilities. Since project specifications are subject to change, your engineer must remain flexible and iterative in their analysis approach as new data becomes available.
Phase 2: Emissions Analysis
The next phase is to calculate the project’s potential to emit criteria pollutants and greenhouse gases (GHGs). The calculation assesses potential requirements for Best Available Control Technology (BACT), emission offsets, Title V, and climate change mitigation. Always use an engineering firm with expertise in GHG emissions inventories and third-party verification of GHG emission inventories and reduction credits. Here’s why, based on the analysis, your engineer will be looking for these factors to smooth the application process:
Project emissions complied with BACT limits based upon a comparison to other permitted SMR facilities.
Project emissions that require the purchase of carbon credits on an ongoing basis to comply with Cap and Trade regulations.
Project emissions that do not trigger the need for emission offsets or Title V.
Phase 3: Regulatory Review
Conducting a regulatory review will identify potential requirements from local regulations such as California’s South Coast Air Quality Management District (SCAQMD). Using SCAQMD as an example, the project must comply with the additional rules.
Phase 4: Results and Conclusions
The comprehensive feasibility study summarizes the potential air quality permitting thresholds, requirements, costs, and schedule for your project. It includes all conclusions and supporting data for decision-making. With a comprehensive study in hand, your project is more sustainable, and you have valuable answers during discussions leading to obtaining a complete air permit.
SCS has over 50 years of environmental experience and trusted working relations with regulatory agencies. Many local, state, and federal agencies attend our free webinars, and industry associations request our input and insight when agencies are planning new rules. We serve as expert witnesses. If you’d like to learn more about developing air permitting strategies and applications, visit our website or contact us at .
About the Author: Greg Hauser is a Project Director responsible for environmental compliance projects. Greg brings over 30 years of experience with compliance topics such as air quality permitting, emission inventories, dispersion modeling, health risk assessments, and odor impact assessments. He surveys facilities to identify sources of interest, collects field samples of odorous emissions, develops odor emission profiles based on odor concentrations and flow rates, and conducts dispersion modeling to predict odor concentrations at or beyond the facility’s property boundary. He also provides health risk assessments for aerospace, manufacturing, wastewater treatment, and oil and gas facilities.
Glenn Haave has had a close relationship with protecting our environment for years, ever since his days working on the ocean towing ships in and out of ports. He figured his deep appreciation of his natural surroundings and desire to protect them might carry into his chosen career path, especially after earning a Bachelor of Science in Geology. But when he came to SCS Engineers as a high-spirited, new graduate, he had no idea of the opportunities that would come his way— both at SCS and serving in the U.S. Coast Guard Reserves.
“Both SCS and the Coast Guard hold you accountable to rise to the occasion and get the job done. With that trust and delegation of responsibilities, I am challenged to become a leader, which gives me a sense of duty and confidence,” Haave says.
Combining Geology, Hands-On Experience, and Teamwork
Starting at SCS doing groundwater and soil sampling and helping remediate landfills for redevelopment, Haave proved to be a fast learner. Quickly building on his skills, he was presented with a unique proposition– to join one of only a few multidisciplinary teams in the country that design and install deep well injection infrastructure. EPA-approved injection wells are safe for placing fluids underground into porous geologic formations. These underground formations may range from deep sandstone or limestone to a shallow soil layer. Injected fluids may include water, wastewater, brine (salt water), or water mixed with chemicals.
Planning, permitting, and executing these projects is a multifaceted undertaking encompassing geologic consulting, reservoir engineering, and deep drilling, with environmental protections and sustainability as core goals.
“Few geologists ever get to work on this type of job. These projects require a lot of capital, time, and very specialized expertise. I was fortunate to be working at SCS’s Miami office at the right time, able, and willing,” says Haave, drawn to complex tasks calling for a razor-sharp eye for detail, focus, and discipline.
Drawing on his experience supporting the Miami-Dade Water and Sewer Department Ocean Outfall Legislation Injection Well Program, where he saw 11 wells constructed in a demanding, high-profile project, he is now on a multidisciplinary team of SCS professionals.
Innovations in Carbon Sequestration – Protecting Our Environment
Now, he takes on a new charge: working on a type of deep injection well called a Class VI well. This sophisticated infrastructure directs carbon dioxide (CO2) liquids and gases into the ground for long-term storage. A fairly new, EPA-approved carbon sequestration technique, it is proven effective at substantially reducing CO2 emissions to the atmosphere.
“Class VI wells are an exciting evolution as the world looks to decarbonize the economy. I feel like I am part of an extraordinarily innovative solution where I am using my background to support a global effort to impact our climate positively,” Haave says.
“I feel a sense of purpose in that we are helping mitigate exponential global warming. At least as important, I am comforted that what we do brings hope that my son, daughter, and their generation will grow up on a healthy, safe planet.”
Another Dimension – U.S. Coast Guard A School
As he embraces this unique opportunity to help the environment, he celebrates another milestone: graduating from U.S. Coast Guard A School and advancing in rank to Marine Science Technician Petty Officer Third Class. His calling will be responding to pollution incidents to protect U.S. waters and inspecting facilities and container vessels that transfer hazardous materials to and from land.
Getting into the Reserves is not easy, nor are the next steps. Making it into A school after boot camp is typically a two-year journey: the waiting list of accomplished graduates is long.
Haave finished three intensive months of classroom work; mock training in the field, morale-building exercises to keep spirits high while away from family and friends, and a battery of testing.
Through these rigorous trials, he took on the honorary role of Master at Arms, leading and mentoring his shipmates and serving as a liaison between the crew and captain.
“Becoming a Coast Guardsman was like a dream come true. It was something I had wanted to do since I was 19. But I needed time to mature. I did a lot of soul searching before I could fully realize what was entailed in living up to Coast Guard expectations; to truly embrace that it’s about a sense of duty to country and family, and to deliver on that conviction,” says Haave, now 37, and nominated as a most inspirational person by his shipmates and instructors.
When he shared his long-envisioned, materialized aspiration with his SCS supervisors, he was unsure what they would think; he was taking on another big commitment.
“They were not only accommodating, but they are proud. SCS Engineers is a military-friendly organization. They are always supportive, flexible, and believe in me.”
In the Coast Guard, he had a choice from a far-encompassing list of specialty areas, given his high military school entrance score. He chose marine science technology because it tied in with his civilian work – navigating and ensuring adherence to federal regulations and being a steward of the environment.
Looking Forward
Gazing back at how far he’s advanced in just the last few years, then looking forward, Haave says, “You know, I’m just 37 years old. I feel like I have a lot more in my gas tank –the amazing experiences I have been fortunate to have are just the beginning. I see more opportunities to advance as a leader and to become an even more rounded geologist, able to approach every project comprehensively and deeply.”
We thank all of our veterans and appreciate Glenn Haave for his service to the U.S. Coast Guard and his commitment to protecting our environment with SCS Engineers by advancing sustainable environmental practices and solutions.
Find out more about carbon sequestration and greenhouse gases:
Video: Building a Well
Information: Deep Well Injection and Sequestration Wells
Video: Carbon Sequestration for Landfills and GHG Tutorial
Safe engineering takes discipline and teamwork –qualities that have always served SCS and our clients with innovative, proven solutions for running operations more efficiently and greener. For a rewarding career, consider SCS Engineers, where all employee-owners have a vested interest in every solution.
The Maryland Department of the Environment (MDE) is working to develop a new regulation aimed at reducing methane emissions from municipal solid waste (MSW) landfills in the state. Methane is a potent greenhouse gas (GHG) with a global warming potential over 25 times greater than carbon dioxide. The new requirements MDE is considering are modeled after similar rules in California and Oregon and would become among the most stringent in the US. MDE anticipates publication of the draft rule in December 2022, followed by public participation and finalization of the rule in the spring of 2023.
This proposed rulemaking has been several years in development and is consistent with Maryland’s GHG Reduction Act of 2009 and the recent Climate Solutions Now Act of 2022 that requires Maryland to become “net zero” for GHG emissions by 2045, with an interim goal of achieving 60% GHG reductions by 2031 (over 2006 levels). MDE estimates that once implemented; this rule could result in up to a 50% reduction in GHG emissions from affected landfills.
MDE presented initial details about the draft regulation (aka, the state plan) at the October 24, 2022, Air Quality Control Advisory Council and stakeholder meeting. The proposed rule would apply to smaller and mid-sized landfills. It would likely impact many facilities not currently subject to the EPA’s federal landfill air regulations under NSPS & EG 40 CFR 60 Subparts Cf and XXX and NESHAP CFR 63 Subpart AAAA. MDE estimates that 32 active and closed MSW landfills in the state will be subject to the proposed regulation.
SCS Engineers is tracking the proposed rule closely, so stay tuned for additional details once the draft rule is published.
For additional information on MSW regulations and GHG emission reductions, please visit scsengineers.com or one of SCS’s nationwide offices.
About the Author: Joshua Roth, PE, is a Vice President and Project Director with the Landfill Gas (LFG) Group in the SCS Reston, VA office. He has served on a number of LFG engineering projects involving LFG remediation system design, emissions inventories and air permitting, migration and odor control, ambient air sampling and reporting, LFG and CER due diligence projects, GHG emission mitigation and reporting, field sampling and assessments, and general emissions control projects.
Establishing a site-specific groundwater monitoring protocol sensitive to changes in the groundwater chemistry related to potential leakage and also sensitive to natural variability will be imperative for developing cost-effective and robust testing and monitoring plans.
In CCUS projects, a site-specific testing and monitoring plan is mandatory to ensure the protection of underground sources of drinking water (USDWs) from Class VI injection well practices. As these projects have long durations with multiple phases, it is imperative for the groundwater monitoring program to be cost-effective with a robust sensitivity to detect any leakage.
Previously demonstrated changes in pH, carbonate chemistry, and certain trace elements (i.e., those that form strong-complexing anions) are geochemical indicators of initial CO2 leakage in relatively dilute aquifers. In this case study, SCS Engineers examine the sensitivity of dilute aquifer chemistry (major and minor cations and anions) to the leakage of CO2 and brines from the injection formation. We use an inverse thermodynamic modeling approach to simulate the effect of the progressive intrusion of CO2 and brines from the injection zone on the geochemical composition of the overlying dilute aquifer waters. From this, we can infer which geochemical parameters are most likely to be affected by the potential intrusion of CO2 and brines.
To attend this live presentation of Geochemical Effects of CO2, register for the upcoming National Carbon Capture Conference on November 8-9 in Des Moines, Iowa. Visit SCS Engineers at booth 120. Meet Kacey Garber.
EPA permit requirements for Class VI injection wells explicitly include incorporating a Testing and Monitoring Plan to optimize protection of USDWs – Underground Sources of Drinking Water. The regulatory requirement is for periodic monitoring of groundwater quality above the confining zone that may result from injection fluid movement through the confining zone. Testing and monitoring plans usually implement an antidegradation strategy. Take sufficient background data to characterize the statistical distributions of groundwater quality parameters before operation. Then the same water quality parameters are sampled periodically during and after injection and compared to the background. Any statistically significant increases over the background are investigated as a possible result of injectate migration above the confining zone.
To make the detection monitoring program more robust, there is a tendency to increase the number of well/parameter pairs in the monitoring network. This is done by adding additional wells to decrease well spacing and by adding monitoring parameters to make sure that nothing gets missed. Paradoxically, this tendency decreases the statistical power of the groundwater monitoring network by increasing the sitewide false positive rate (i.e., the number of false positive detections increases, often to an unreasonable degree). Each apparent statistically significant increase involves a costly investigation with greatly increased complexity. In this talk, we examine the sitewide false positive rate for sitewide groundwater monitoring networks and its relationship to the number of well/parameter pairs and discuss how hydrologic and geochemical knowledge and characterization can be used to build a more robust and cost-effective groundwater monitoring plan that is protective of USDWs near Class VI injection wells.
To attend this live presentation, register for the upcoming National Carbon Capture Conference November 8-9 in Des Moines, Iowa. Visit SCS Engineers at booth 120. Meet Charles Hostetler.
Many landfills are still using hand-held monitoring of methane “hot spots” for compliance purposes while relying on models to estimate LFG emissions. Although technological developments in optical remote sensing and other methods offer significant improvements to measuring actual surface emissions from landfills, no single technology or method has risen to the top of the scientific hierarchy, gained universal acceptance, and achieved regulatory approval. Clearly, the technological advances provide more comprehensive methods for measuring methane concentration, identifying methane hot spots and leaks, and providing better coverage of the entire landfill surface. However, some technology falls short in their ability to provide accurate, consistent, and repeatable methane flux or emissions measurements.
As monitoring technology evolves, so have the various ways SCS takes measurements, from source level, drones, and high-altitude aircraft, to satellites. This paper presented at A&WMA by Patrick Sullivan and Raymond Huff summarises and provides details on the following methods:
• First order decay (FOD) modeling for landfills without active LFG collection systems.
• Non-FOD modeling for landfills without active LFG collection systems.
• FOD modeling with measured LFG collection.
• Non-FOD models with various site-specific data input.
• Measured LFG collection with estimated collection efficiency.
• Surface emission monitoring for compliance purposes.
• Ground-based or low-altitude imaging for concentration or hot spot measurement.
• Satellite and aerial imaging for concentration or hot spot measurement.
• Flux chamber testing.
• Ground-level plume measurement.
• Micrometeorology.
• Stationary path measurement.
• Reverse air dispersion modeling.
• Tracer studies.
• Low or high-altitude imaging.
• Hybrid methods.
Engineering News Report’s Top 500 Environmental Sourcebook was published today. SCS continues to rank #1 in Solid Waste services and top-tier rankings in Sewer & Waste, Hazardous Waste, Chemical & Soil Remediation, and Site Assessment & Compliance.
ENR is one of the premier companies tracking the A&E industry, and these rankings are closely followed as they publish throughout the year. The ENR Top 500 Design Sourcebook, which publishes annually in April, also ranks SCS Engineers among the top 100 of 500 global design-engineering firms at #59.
Climate change and reducing our nation’s carbon footprint are important challenges facing our planet. SCS Engineers remains a leader in recovering and utilizing methane from landfills, a potent greenhouse gas. In the last two decades, we’ve expanded our role to include the utilization of biogas from agriculture, carbon sequestration, management of other greenhouse gas, and environmental impacts for multiple sectors while reducing methane production in landfills by diverting organics.
SCS designs and supports innovative environmental solutions with our in-house award-winning technologies to help our clients. With more data and control available 24/7, our clients can make more informed decisions, operate more efficiently, running cleaner and safer while delivering essential services, products, and properties. As employee-owners, we aim to seek the most efficient and clean operations for our clients, who are responsible for delivering essential services and supporting our nation’s economy.
Our environmental work is ongoing with many new exciting ways to support our clients and communities; it’s rewarding to share this recognition with our thanks to you.
Did you miss the 2022 Annual GWPC & UIC Conference in Salt Lake City? We welcome you to view SCS Engineers’ presentation by Kacey Garber entitled “Sensitivity of Aquifer Chemistry to Changes in Carbon Dioxide Partial Pressure: Implications for Design of Groundwater Monitoring Protocols,” where Kacey discusses permitting requirements for groundwater monitoring for carbon sequestration and storage sites.
In her technical presentation, Kacey Garber of SCS Engineers discusses the great care taken in the design and operation of the injection of carbon compounds to ensure that the sequestration is effective and permanent. Each injection site also has permitting requirements for groundwater monitoring in any overlying aquifer as a protective measure. Because the injection and sequestration periods are long, CSS solutions need a cost-effective groundwater monitoring program with a robust sensitivity to detect any leakage. By establishing a groundwater monitoring protocol specific to the site, sensitive to changes in the partial pressure of carbon dioxide, and relatively insensitive to natural variability and hydrochemical facies changes, implementing optimal and cost-effective groundwater protection is possible. Using a case study, Kacey tells us how her team did this in detail.
Kacey Garber is an experienced groundwater project manager for active and closed landfills, including routine groundwater monitoring and statistical analyses; reports and permit applications; designing sampling and analysis plans; special groundwater studies; and conducting groundwater well construction planning and design.
SCS Engineers is providing landfill gas (LFG) systems operations, monitoring, design, and management for the Yolo County Central Landfill (YCCL). SCS Field Services is SCS’s specialized landfill practice, providing operations, maintenance, and monitoring (Landfill OM&M) for Yolo County and over 600 landfills across the nation.
SCS Field Services identifies practical strategies to optimize the performance of landfill gas (LFG) systems and equipment while working on site. Optimized systems capture more gas.
Project Manager Mike Calmes leads the comprehensive team at YCCL, which has five closed waste management units, five active waste management units, and one under construction. Closed landfills continue generating gas, so active or closed, they all require oversight by these landfill specialists.
“The County understands the importance of preventative strategies using captured landfill data to create sustainable environmental controls. These keep landfills running as efficiently as possible and safely within regulatory compliance,” said Anton Z. Svorinich Jr., SCS Engineers Vice President, Regional OM&M Manager.
To learn more about landfill operations and engineering, visit SCS Engineers.
Scrap facilities’ stormwater permits incorporate strict sampling requirements, numeric limits (generally referred to as benchmarks, numeric action levels, or numeric effluent limits), and mandated corrective actions. Furthermore, facilities face emerging challenges with increased regulatory scrutiny within environmental justice communities and communities implementing new stormwater utilities. Good planning can ease the operational, maintenance, and reporting requirements and provide positive results for your facility’s relationship with local communities and regulators.
If your facility is facing scrutiny or requires additional best management practices (BMPs) to meet stormwater permit requirements, follow this simple stepped approach:
Good planning and design create effective conveyance and treatment systems that improve stormwater quality and help you meet benchmark requirements. Proactive measures to plan for stormwater treatment systems will help existing scrap metal recycling facilities address corrective action and avoid Additional Implementation Measure (AIM) levels based on their benchmark monitoring results.
Need assistance with managing stormwater runoff at your scrap facility? Contact our Author, Scott Knoepke, to set up a meeting at the Institute of Scrap Recycling Industries’ 2022 Safety and Environmental Conference. Or reach out anytime; SCS’s environmental professionals are nationwide.
