Early one Saturday morning, SCSers Chuck Houser, Luke Montague, Allison O’Neal, and me, Jen Morton, headed out to Brawley in the Imperial Valley region of Southern California. That is the desert. We had been having our usual May Gray here in SoCal when the summer can feel like winter at the coast, but the desert was a balmy 100 degrees and sunny that day.
We met with Sean Wilcock of the Imperial Valley Economic Development Corporation, one of our clients for Brownfields work, at a coffee shop in Brawley. From there, we ventured north to an area between Calipatria and Niland to see the beginning workings of a lithium extraction operation.
This region lies at the southern end of the San Andreas fault, where the motion between the North American and Pacific Plates begins to switch from strike-slip to extensional or from side-by-side to pulling apart. Where extension occurs, the crust tends to be relatively thin. Imagine pulling apart a sticky bun or taffy – the middle starts to get thinner before it breaks.
With the thinning of the crust, hot magma from the earth’s interior is closer to the surface. The heat from the magma heats the groundwater, which is A LOT beneath the Imperial Valley. And in this groundwater are minerals that, until recently, have not necessarily been worth the effort to extract from the water.
For decades energy companies have been using this super-heated water to generate electricity in the Imperial Valley. The hot water is pumped up from deep within the earth, using the steam to rotate turbines. The water is then pumped back into the aquifer.
Before our trip, Chuck and I met Tracy Sizemore, director of Battery Operations for Controlled Thermal Resources (CTR), at a San Diego Association of Geologists (SDAG) meeting learning more about the mineral resources in Imperial Valley. Chuck and I were as fascinated with that as the opportunity to see the biggest drill rig we’ve ever seen, which would be drilling an 8,000-foot well for groundwater extraction. We learned about the brine’s lithium resources (another term for the super-heated, mineral-rich groundwater).
Lithium has become a highly sought-after metal with the proliferation of electric vehicles. Given this increase in value, it is now economically feasible to extract it from the brine as part of the energy generation process. Some companies have plans to conduct the extraction in addition to electricity generation at existing geothermal plants. One company will build a separate extraction facility next to an existing plant.
CTR is planning to develop a plant that will focus primarily on the extraction of lithium, with energy generation being secondary. As Geologists, we got a tour of CTR’s prototype plant. It was fascinating to see all of the equipment and the results of the extraction process – a small bottle of lithium-rich liquid worth about $10. The extraction process also creates a sludge containing other important elements, including manganese, zinc, and even gold and silver. The plan is to sell the sludge to another company to extract the additional economic elements.
The process of extracting lithium in this manner is sustainable and much cleaner than traditional mining methods. It is also considered carbon-neutral. The new plant will generate enough electricity to power it 100%, with enough left over to power a battery manufacturing facility next door after its construction.
CTR’s lithium extraction process expects to bring 1,400 jobs to the area, with another 4,000 jobs once the battery plant is up and running. With the influx of workers, the Imperial Valley needs more infrastructure, housing, and services, so it is supporting economic growth.
In the fall, we plan to return to CTR’s facility to see the enormous rig drilling the 8,000-foot well!
Meet the Author – Jen Morton, Professional Geologist and SCS Project Manager
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Dr. Hostetler will present “A Computational Modeling Approach to Critical Pressure Calculations for Class VI Area of Review Delineation” [Thursday, September 14, 10:30 – Noon, Session Class VI UIC] at the Groundwater Protection Council 2023 Annual Forum in Tampa.
Presentation Category: Carbon Capture and Underground Storage
Subsurface pressure increases as supercritical carbon dioxide is injected into a deep saline reservoir beneath a confining zone. If the pressure buildup is great enough, brine could be lifted upward from the injection zone through an inadequately plugged or abandoned well that penetrates the confining zone. This could result in the endangerment of an underground source of drinking water (USDW). A Class VI Injection Permit requires a delineation of the Area of Review (AoR). The AoR is the superposition of the area of the buoyant supercritical plume itself, together with the area over which the pressure front is large enough to potentially endanger a USDW through some conduit. The USEPA Class VI Guidance offers several approaches to calculating critical pressure. Some of these methods are based on concepts of changes in potential energy in artificial penetration and are very easy to implement. Unfortunately, they are simplified models and are also very conservative. The USEPA Guidance also allows for the computation of the critical pressure by computational modeling. We present a computational modeling approach that is more mechanistic, explicitly addresses uncertainty, can be updated as additional testing and monitoring data become available, and provides a more authentic representation of the critical pressure and hence, the AoR.
Dr. Hostetler has nearly four decades of experience as a geochemist and hydrogeologist. His expertise focuses on subsurface multiphase flow modeling, groundwater flow and transport modeling, and reactive solute transport modeling. Dr. Hostetler is an SCS Engineer’s Deep Well Initiative and Class VI Permit Team member. Charles Hostetler has a BS in Geosciences and a Ph.D. in Planetary Sciences from the University of Arizona.
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The Environmental Protection Agency (EPA) is proposing to designate perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), including their salts and structural isomers, as hazardous substances. The proposed rule published in the Federal Register designates two per- and polyfluoroalkyl substances (collectively, PFAS) constituents as CERCLA Hazardous Substances. While this is a small subset of PFAS constituents, PFOA and PFOS are reportedly the most commonly used and likely to be detectable. Additional PFAS compounds are certainly on the horizon for consideration by EPA and, in fact, an Advance Notice of Proposed Rulemaking was issued by EPA in April of 2023 to seek input for seven additional compounds for hazardous substance designation.
What Could This Mean For Property Transactions and Real Estate Development?
When the CERCLA hazardous substance rule becomes final (anticipated in 2023 or 2024), it will be mandatory to consider these PFAS constituents when performing Phase I Environmental Site Assessments (ESAs) to identify Recognized Environmental Conditions (RECs) in connection with a property. Because of the ubiquitous use of PFAS, often called “forever chemicals,” in residential, commercial, and industrial products, some Environmental Professionals are concerned that PFAS-related RECs will be commonplace.
In their recent paper, “How Will EPA’S Proposed CERCLA Hazardous Substance Designation of PFOA and PFOS Impact the Environmental Due Diligence Practice?” Jeff Marshall, PE, and Mike Miller, CHMM, discuss the anticipated impacts of the PFAS rule on environmental due diligence. Depending on the former uses, the number of RECs, and ESA results, some sites are more likely to feel the impact on the potential value of a property.
As our PFAS knowledge continues to evolve, so will applying this knowledge to the environmental due diligence practice and, ultimately, real estate conditions. Read the technical paper to understand the terminology and types of properties more likely at risk.
Jeffrey D. Marshall, PE – Vice-President. Mr. Marshall is a Vice President and the practice leader for the Environmental Services Practice for SCS offices in the mid-Atlantic region. He is also the SCS National Expert for Innovative Technologies and Emerging Contaminants. His diversified background is in project engineering and management, with an emphasis on the environmental chemistry and human health aspects of hazardous materials/waste management, site investigations, waste treatment, risk-based remediation and redevelopment, and environmental compliance/permitting issues. He has over 40 years of environmental experience and directs and manages environmental due diligence projects in the mid-Atlantic. He is a chemical engineer, Professional Engineer (VA, MD, WV, NC, and SC) and meets the credentials of an Environmental Professional.
Michael J. Miller, CHMM – Vice President. Mr. Miller is a Vice President and the practice leader for the Environmental Services Practice for SCS offices in the Central region. He also serves as an SCS National Expert for Environmental Due Diligence. He supports firm operations throughout the United States related to Phase I and II Environmental Site Assessments and the completion of large portfolios and complex site assessments. A Certified Hazardous Materials Manager (CHMM) since 2009, Mike has more than 28 years of experience in environmental management and consulting with an extensive background in RCRA-related matters and industrial compliance, planning, and permitting.
Additional Real Estate Resources:
Charm Industrial’s (Charm) $53M deal with Frontier to voluntarily sequester bio-oil underground is an example of early market leadership for alternative subsurface deployment methods in the negative carbon emissions market. SCS was instrumental in developing the pilot programs, initial testing, and regulatory approvals allowing Charm to scale up its processes and deliver on this commitment.
This deal will remove 112,000 tons of carbon dioxide by 2030. Charm’s method involves converting excess organic material, like corn stover, into bio-oil and putting that oil into abandoned oil wells.
Carbon capture has been a focus for Frontier for some time now. Prior to this announcement, they partnered with early-stage startups to remove 9,000 tons of carbon. This landmark deal is a continuation of Frontier’s efforts to spark growth and bring attention to the industry and is one of the largest legally binding agreements to date. SCS is thrilled for Charm and Frontier and this huge step forward. See the recent CNBC news article below for more information on this deal and its carbon offset impact.
SCS Engineers welcomes two experienced environmental consulting professionals to our St. Louis regional office.
Susan Robertson, MBA, is Senior Project Manager. Robertson’s comprehensive environmental due diligence and remedial work rejuvenates prime commercial properties back to health while supporting municipal and private industries’ plans for economic redevelopment.
In the environmental industry for nearly 20 years, Susan has worked on a wide range of consulting projects, including environmental due diligence Phase I and Phase II Environmental Site Assessments. She performs Indoor Air Quality and radon assessments, lead-based paint, and asbestos inspections.
Susan is known for her Brownfield-Voluntary Cleanup Program work under the Missouri Department of Natural Resources¹, Illinois EPA Tiered Approach to Corrective Action, and Missouri Risk-Based Corrective Action risk assessments and historic preservation projects under the Missouri Department of Economic Development².
Julia Hunter is an SCS Project Professional. Julia has five years of experience in environmental consulting, primarily performing environmental due diligence for commercial and telecommunications clients nationwide. She has a Master of Science in Environmental Geoscience from St. Louis University.
Hunter uses the highest standards of care in her due diligence and building sciences investigations, analyzing the data to determine if a property is feasible for its proposed use and future requirements to speed the closure process and ensure no surprises.
“The service these two women perform for our clients is strategic and comprehensive,” states Rachel McShane, SCS – St. Louis project director. “The results of their work help determine the true value of a property before purchase, and if there are any environmental or health concerns, how to remediate them.”
Additional Resources:
SCS Engineers welcomes Melissa Schick to the environmental firm’s Brownfields and Voluntary Remediation practice, which works nationwide, supporting municipal and public/private sector ventures to remediate previously thought unusable properties back to life.
These properties are not exclusively but often found in urban areas with existing supporting infrastructure. New technologies and environmental processes can turn these well-situated properties safe again for almost any redevelopment purpose, whether housing, recreational facilities, retail/office, or logistics centers.
Schick brings her knowledge of state and federal brownfield redevelopment and voluntary remediation cleanup program regulations. She specializes in U.S. Environmental Protection Agency (USEPA) Regions 3, 4, and 6, supporting the grant application process or overseeing the implementation of USEPA assessment and cleanup grants which provide funds for municipalities to redevelop sites.
Since brownfields and voluntary remediation create valuable economic and natural resources for communities, clients find her experience coordinating communications, outreach, and educational events helpful. As this work demands, Schick often focuses on improving the communications between private developers, regulatory agencies, community leaders, and other partners to smooth project implementation, keeping projects on track and within budget.
“Importantly, Melissa is an ethical and caring person whose work in communities matters to her,” states Kirk Blevins, SCS Project Director. “As a local environmental engineering and consulting firm, she enhances our national practice as a detail-oriented resource to augment communications, outreach, and reporting for comprehensive and cohesive project success.”
Schick has professional affiliations with the Florida Brownfield Association – Board of Directors, the Society of American Military Engineers, and the Florida Association of Environmental Professionals.
We welcome you to learn more about Melissa Schick’s work, background, and education in land remediation services on the SCS website.
Additional Resources:
Municipal Solid Waste Facilities (MSWFs) are subject to a wide range of federal, state, and local regulations that govern their operations. Regulatory compliance is essential to ensure the facility operates safely, protects the environment, and meets its legal obligations. The regulatory priorities for a solid waste facility can vary depending on the specific facility and its location. Waste management, air quality permitting, leachate management, and landfill gas management are top regulatory priorities for most solid waste facilities. It is equally important for facility owners and operators to plan for oil spill prevention, but this can be a blind spot. The Federal Spill Prevention, Control, and Countermeasure Rule (SPCC) primarily governs oil spill prevention planning.
The Federal Spill Prevention, Control, and Countermeasure Rule (SPCC) (40 CFR 112.1-112.12) applies to solid waste landfills and transfer stations. The U.S. Environmental Protection Agency (USEPA) requires an SPCC Plan for any non-transportation-related facility with an aboveground storage capacity of 1,320 gallons or more and if it could potentially discharge oil to navigable waters or adjoining shorelines. The SPCC rule aims to prevent oil spills and limit significant environmental and economic impacts.
The SPCC regulations require solid waste facilities to implement spill prevention measures to reduce the likelihood of spills, including providing adequate secondary containment systems for all oil storage containers and spill prevention controls such as automatic shut-off valves or overfill prevention devices.
The regulation also requires an SPCC Plan that includes emergency response procedures in the event of a spill and contact information for assigned emergency personnel. Facilities must document annual and ongoing SPCC training for all personnel who handle petroleum products.
Facilities must regularly inspect their oil storage containers and secondary containment systems to ensure they are in good condition and leak-free. Each facility must maintain inspection records for potential EPA review.
SPCC Plans must be updated and re-certified by a professional engineer (PE) every five years. Additionally, amendments to SPCC Plans must be PE certified within six months of any change in the facility design, construction, operation, or maintenance materially affecting the facility’s oil spill potential.
MSWFs use a variety of petroleum products for their ongoing operations. Here are some examples:
Solid waste facilities and landfills are responsible for preventing environmental impacts and complying with regulations. Implementing an effective SPCC program can help to prevent petroleum leaks and spills from entering natural waterways. In addition to the Federal SPCC requirements, some States have more stringent oil spill planning requirements, so facility owners need to seek guidance when developing their oil spill prevention program. With the proper risk management measures, solid waste facilities and landfills can do their part in protecting the environment while maintaining their essential operating budget.
SCS has prepared and updated thousands of SPCC Plans for clients across the U.S. and in various industries, including MSWFs, bulk petroleum storage terminals, chemical storage facilities, and animal fat and vegetable oil storage facilities.
Find out more about SPCC Planning and Spill Prevention
Meet our Author, Michael Morawski, Project Manager
EPA will hold three complementary competitions to strategically distribute grant funding under the $27 billion Greenhouse Gas Reduction Fund program. EPA will implement these programs in alignment with the President’s Justice40 Initiative and expects to open competitions for funding under the Greenhouse Gas Reduction Fund by the summer of 2023.
The goal is to ensure that households, small businesses, schools, and community institutions in low-income and disadvantaged communities have access to financing for cost-saving and pollution-reducing clean technology projects. EPA aims to deliver tangible benefits, including lower energy costs, good-paying jobs, and improved public health outcomes to households, businesses, and communities. The three competitions will be:
EPA Feedback and Listening Sessions
EPA invites written technical feedback and comments on the competition descriptions as the Agency prepares the program for release as early as June 2023. Stakeholders may send their written feedback to by 11:59 pm ET on May 12. Over the next two weeks, EPA will convene six public listening sessions on this implementation framework. Listening session details and other information about the program are on the GGRF website.
Additional Greenhouse Gas Reduction Resources
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Play with ReFED’s interactive, fun, and educational tool!
Earth Day is a great time to remind you that food waste reduction is a top climate change strategy! As you’ll see in this addicting, educational, and fun ReFED tool – everyone helps make a difference. Every small change citizens and businesses make has a major impact on our planet’s health and well-being. Try it out and see how we are building solutions to reduce the 91 million tons of surplus food annually in the U.S.
The ReFED Insights Engine offers the most comprehensive examination of food waste in the United States by incorporating current data from a variety of sources, including public and proprietary datasets, expert interviews, case studies, and industry research. This powerful engine has several components, including:
Food Waste Monitor – A centralized repository of information built with data from more than 50 public and proprietary datasets and providing granular estimates of how much food goes uneaten in the U.S., why it’s happening, and where it goes.
Solutions Database – A stakeholder-specific, comprehensive cost-benefit analysis of 40+ food waste reduction solutions based on a range of impact goals, plus detailed fact sheets on each.
Impact Calculator – An interactive resource that quantifies the greenhouse gas emissions reduction, water savings, and donated meal recovery potential of different food surplus management scenarios in the U.S. by sector and food type.
Capital Tracker – A dashboard to monitor the flow of capital into food waste innovation, allowing users to understand the landscape, identify key players, and plan out future funding strategies.
Use a reusable water bottle, drinking straws, and shopping bags.
Around 380 million metric tons of plastic are being produced yearly; that’s roughly the same as the entire weight of humanity. Approximately 91% of plastic is not recycled. Roughly half of our global annual plastic production is destined for a single-use product.
The average per person use is astounding; some can take 1,000 years to disintegrate.
Think of the money you’ll save along with planet Earth!
Landfill owners, operators, and engineers have long dreamed of using landfill acreage for more than disposal, and that’s just what the Lanchester Landfill in Pennsylvania is doing. Many disposal companies and municipalities are already controlling waste rather than seeing it go into landfills, take a moment to see the innovative Republic Inc. solutions.
Sustainability in the waste industry is becoming a reality with new recycling and reuse technologies, renewable energy, public/private and organizational coordination, and the backing of industry associations.
