With climate change becoming a center of attention globally, much focus has pointed toward carbon capture and storage (CCS) in recent years. While USEPA has published general guidance for Class VI permitting, it is still a new permitting challenge for both scientists and regulators alike. Drawing on lessons learned from more familiar and well-developed regulatory frameworks will be beneficial.
In our Technical Bulletin, Applying Lessons Learned From Municipal Solid Waste and Coal Combustion Residuals to the Development of Testing and Monitoring Plans for CO2 Storage Projects, we focus on the testing and monitoring aspect of Class VI permitting and related complexities, including the project’s overall scale, enhanced costs, and enhanced regulatory risk. We discuss the key considerations for developing an effective CCS Testing and Monitoring Plan based on lessons learned from developed MSW and CCR monitoring programs, as well as how early planning and good judgment can help navigate the complexities associated with CCS projects and ultimately reduce those complexities and associated project costs.
Recommendations include meticulous site characterization efforts early in the CO2 storage project and tailoring the monitoring network. The latter includes placing monitoring wells based on multiphase modeling predictions, designing geochemically and geomechanically compatible monitoring wells, and using strategic statistical techniques to analyze and interpret monitoring data.
It is important to remember that for CO2 storage, groundwater monitoring is not intended to be the primary monitoring method for detecting fluid leakage and migration. It is only one of many required testing and monitoring methods. Even so, the monitoring network must be planned and established appropriately and then tightly coordinated with the other testing and monitoring methods to maximize the protection of underground sources of drinking water.
SCS Engineers will continue to post timely information, resources, and presentations to keep you well informed. These include additional guidance, industry reaction, and webinars with our teams using our website, on SCS Engineers LinkedIn, and on SCS YouTube on-demand forums.
Additional resources at your fingertips:
Green hydrogen is a clean fuel that produces only water when consumed in a fuel cell. Because it is produced from domestic resources, such as natural gas, nuclear power, biomass, and renewable power like solar and wind it is an attractive energy option for transportation and electricity generation applications.
SCS Engineers’ recent publication “Green Hydrogen – A New Frontier in Energy” evaluates the feasibility of hydrogen as green energy from production, transportation, storage, infrastructure investment, and environmental impact aspects. He discusses the technical and environmental challenges being addressed now through research, design, and development, and addressing the environmental obstacles to successful implementation of fuel cells and the corresponding hydrogen infrastructure.
Keep an eye on the Department of Energy’s Hydrogen and Fuel Technologies Office site where DOE publishes the developing and testing complete system solutions that address all elements of infrastructure and vehicle technology, integrated hydrogen and fuel cell technologies validations for transportation, infrastructure, and electric generation in systems using real-world operating conditions.
Additional Related Resources:
A couple of decades ago, industry Environmental Managers (EM) reviewed and interpreted regulations, permit requirements, and reporting obligations and educated their operations personnel on requirements from the Clean Air Act and Clean Water Act. As usual, time flies, and those major pieces of environmental legislation are more than 50 years old now, and much of the framework remains unchanged. There have also been advances in the best control technologies and great strides in automated record keeping and reporting, enabling us as environmental compliance professionals to be more efficient and offering “clear skies” regarding a manageable workload. Sure, occasional exceedances, deviations, or releases require a four-alarm fire drill as an appropriate response or the integration of the most recent ISO 14001 version release. Still, for the most part, times were good.
Sustainability changes everything.
Environmental Managers read press releases from CEOs making bold claims that their company is adopting “zero” carbon or “net neutral” goals without a real baseline carbon inventory or a roadmap for accomplishing such aggressive measures. Not to say that setting stretch targets are a “bad thing.” On the contrary, they are good targets that improve environmental stewardship for companies that may not otherwise focus on such activities. John F. Kennedy’s famous “We choose to go to the Moon” speech set a bold target for landing on the moon, stretching our space program to new limits.
Meeting the New Challenge
The challenge for you, the EM, comes into play when the responsibility of this relatively new sustainability practice is now on your desk. Larger companies are hiring Sustainability Directors at a record pace which is vital to the planning and programming of new sustainability initiatives. But even then, there are situations where EMs are responsible for implementation and retrofitting plans or projects that are conceptual in nature. And if you don’t have the luxury of a Sustainability Director to lean on, you now have the additional responsibility of developing road maps and strategies.
Where can an Environmental Manager focus on impactfully?
After concluding your version of the Serenity Prayer, we suggest starting in these three areas:
These steps will go a long way toward planning, programming, and launching sustainability initiatives with measurable results. Environmental Managers are making a difference by collaborating with operations to convert sustainable ideas and goals into reality. SCS works with large and small public and private entities to support their actions.
About the Author: Steven D. Stewart, P.E. PMP, SCS Engineers. Project Director. LinkedIn. I look forward to hearing, ‘One small step for man, one giant leap for Environmental Managers.’ If you need help with your sustainability program, don’t hesitate to contact us at SCS Engineers. Look for Steve this week at the GreenBiz 2023.
Additional Resources:
Abdul Mulla-Saleh, PhD, PE, BCEE, joins SCS Engineers as a Project Director specializing in civil and environmental services for solid waste management and master planning, landfill permitting, site development, landfill expansions and closures.
“Abdul brings superior credentials to serve SCS’s clients. Our Southeastern engineering teams bring a holistic approach to solid waste management by combining field skills, advanced technology, and engineering experts to focus on sustainable solutions,” states Vice President Shane Fischer.
Dr. Mulla-Saleh is a licensed Professional Engineer in Alabama, Florida, Georgia, and South Carolina and a Board Certified Environmental Engineer who has supported large civil and environmental projects globally. His portfolio includes new site development and infrastructure projects, master plans for drainage and wastewater, solid waste management, hydrologic and hydraulic studies, flood control structures, pump stations, and roadways.
His successful track record includes projects in the US, where he completed environmental projects, including landfill engineering and solid waste management facilities design, sustainable waste management, including zero waste and carbon neutral concepts, and technical quality assurance.
Abdul is a published author and presents at industry and association educational events. He is a member of the American Academy of Environmental Engineers, the American Society of Civil Engineers, the International Solid Waste Association, and the Solid Waste Association of North America. He earned his PhD in Civil Engineering at the University of South Florida; his MS in Environmental Engineering also at the University of South Florida; and his BS in Civil Engineering at the University of South Alabama.
There is a demand for qualified professionals such as Abdul, and opportunities for those just beginning their careers at SCS Engineers. Each and every team at SCS has opportunities to help protect our water, air, and land for those interested in gaining experience or sharing their expertise with industries responsible for safeguarding the environment as they deliver essential services and products.
For more information about us, please watch our video to see what you can do for your business and community. If you prefer working outdoors as part of a talented, unique team please watch this short video. No matter your job at SCS, you will make a difference!
From the USEPA to headlines in the media, coverage of PFAS moving from wastewater to drinking water is a major concern. Furthermore, there are growing concerns about how much PFAS is in by-products that are recycled or reused from waste products. Topping that list is fertilizer.
Retail fertilizer products made from at least 50% biosolids commonly sold to the general public and used in farming contain PFAS, which could get into crops and stock, eating those crops. The Environmental Protection departments in some states are beginning to consider or pass state-level specific regulations on the content of PFAS in biosolids.
The December 2022 USEPA memo to states (pages 4-5) made these recommendations on biosolids as follows:
Tony Kollasch, an environmental consultant specializing in remediation, tells us to use precaution and learn more about what plans are underway in your state. In his Wisconsin Agri-Business article, BIOSOLIDS and PFAS – NUTRIENTS with a SIDE OF CONCERN, he walks readers through the most recent reports and studies using plain language.
The issues and questions that come up are solvable. There are treatments for removing PFAS, and as an environmental engineering and consulting firm, we solve these types of challenges. We encourage the safe use of by-products and urge you to learn more about specific products by joining associations where you can educate yourself – it’s good for business and for understanding pending regulations that may impact your operations. It will help you run your business sustainably by making sound decisions based on human health, the environment, and economic demand.
Additional Resources:
Air permitting compliance is a crucial aspect of operating a facility that generates air emissions. The process involves obtaining permits from regulatory agencies that establish requirements to demonstrate that the facility operates within limits set by air quality regulations.
Air permitting is not just for industrial operations but impacts many businesses.
In Miami-Dade County, Florida, the agency responsible for issuing air permits is the Department of Environmental Resources Management (DERM). Businesses that emit air pollutants, such as fine particulate matter (dust), volatile organic compounds, and hazardous air pollutants, or which operate combustion equipment such as ovens, furnaces, boilers, and backup power generators must obtain air permits to operate legally. The Florida Department of Environmental Quality provides state guidance here. These permits are required to ensure that the facility’s emissions are within limits set by air quality regulations and that the facility is taking the necessary steps to control and reduce emissions.
Local business example
In the case of one apparel printing facility in Miami-Dade County, SCS Engineers (SCS) was hired to assist with obtaining the necessary air permits from DERM. The scope of services included reviewing current and proposed operations information, calculating air emission estimates, and preparing the narrative and application forms. SCS also prepared a Request for Information (RFI) to confirm the necessary background information, such as equipment specifications, facility layout, projected usage, and operating records. The deliverables included an Air Construction Permit Application and an Air Operating Permit Application. In this case, SCS could prove that the client did not need a permit even though the regulatory agency thought they might.
What are the steps?
The process of obtaining an air permit can be complex and time-consuming, which is why businesses often hire specialized environmental engineering firms to assist them. In this example, SCS provided DERM with a detailed report and application package, including a process flow diagram, equipment specifications, and actual and potential emissions calculations.
It’s important for businesses operating in Miami-Dade, or any county, to understand the air permitting process and the regulations set by local authorities. Environmental engineering firms can provide more accurate and detailed information, so management understands the specific air quality regulations that apply to their business.
The value is in implementing the practices necessary to maintain compliance with air quality regulations and keeps your reputation with workers and the community stellar. Businesses continuing to operate illegally face administrative and civil violations, court actions, and potential environmental insurance challenges. Another consideration is that the same engineering firm can likely advise you on stormwater and groundwater permits and compliance for your facility.
About the Author: Troy Schick, PE, is a Project Manager based in our Miami, Florida, office. He is a Professional Engineer licensed in Florida and a Qualified Stormwater Management Inspector.
Stormwater and Air Permitting Compliance Resources for Businesses:
Compounded by rising labor and regulatory costs, landfill operations challenges for owners and operators are liquids and greenhouse gases. Gas collection and control systems, leachate management strategies, and treatment technologies all help create efficiencies. But so does new technology.
In our two-part educational series, we use case studies to demonstrate combinations of integrated SCADA, IIoT, drones, satellites, and Geographical information systems (GIS) technologies. Using clear, straightforward language, our panelists explain which technology is best for what and when integrating these technologies better serves your landfill’s and composting operation’s challenges and budget.
Recorded in front of a live audience who send questions to our panelists specific to their operational needs we cover monitoring, liquids, and labor challenges – with an aim to introduce new technologies that solve some of your most expensive challenges. SCS’s forums are educational, non-commercial webinars with a Q&A forum throughout; they are free and open to all who want to learn more about landfill and composting technology. We recommend these discussions for landfill and organics management facility owners/operators, technicians, environmental engineers, municipalities, and environmental agency staff.
View Part I focused on drones, satellites, and GIS technologies which are valuable for landfill permitting, design, and monitoring liquids and gas well conditions.
View Part II focused on SCADA and remote monitoring & control systems – when and why using real-time data can create efficiencies and reduce risk at your landfill and are useful for compost operations, and anaerobic digestors.
If you would like to join our mailing list for these monthly forums, please contact us at – SCS never shares or sells your contact information.
Executing Brownfield Redevelopment
Green spaces are dwindling rapidly as real estate development forges ahead; meanwhile, a plentiful inventory of brownfields lie idle or underused that have great potential to become vibrant, revenue-generating resources.
Well-executed brownfield redevelopment projects make the most of existing infrastructure, leaving green spaces green. They create jobs and increase property values. They improve the health and safety of the environment and people. And turning former liabilities into neighborhood jewels cultivates a spirit of goodwill among residents.
As developers and governments realize the benefits, old gas stations, defunct factories, and closed landfills are among the properties redeveloped into community parks, retail, industrial, or mixed-use properties to become productive assets.
But while communities and private investors can reap tremendous payoffs, successfully repurposing brownfields can be complicated. They may be laden with hazardous substances and other contaminants from past uses, calling for specialized technical expertise to ensure sustainable environmental and financial outcomes.
Meet Amy Guilfoyle
SCS Engineers’ Amy Guilfoyle has been deeply rooted in brownfield redevelopment work for 20 years, supporting plans to ensure projects are technically sound, on time, and on budget.
Groundwater and soil assessment and remediation are her primary focus. Her job involves more than these essential tasks—from helping local governments apply for U.S. EPA Brownfield assessment and cleanup grants and voluntary cleanup state tax credits to ensuring and documenting regulatory compliance.
When Amy was a new biology graduate, she was not sure exactly what career direction she would choose until she got a full taste of fieldwork with an environmental focus.
“I like working on practical solutions to our clients’ day-to-day problems. And I like the creativity involved in finding and developing the best options in each case. Every scenario is unique, challenging you to keep the wheels in your mind turning,” she says.
Guilfoyle’s work typically begins with a Phase I Environmental Assessment, entailing an inspection of the property and a review of documents to evaluate for potentially hazardous pollutants and contamination. She will move on to a Phase II Environmental Assessment, depending on her findings, collecting and analyzing soil and groundwater samples to determine concentrations, locations, and other details to inform what may become her next course. The results help lead her team in developing and executing a rigorous cleanup strategy to meet regulatory standards.
The practiced brownfields veteran has her work cut out for her, especially on her dedicated turf; the state of Florida, whose groundwater and soil quality standards are even more rigorous than the U.S. EPA’s. Guilfoyle must not only stay on top of stringent regulatory demands but know how to strategically approach complex challenges tied to the region’s unique physical conditions.
“For one, as we monitor and plan remediation, we consider soil characteristics. Like much of the Southeast part of the country, Florida is sandy, making it easier for contaminated water and materials to move through the ground than in rocky areas,” she explains.
“Additionally, we give careful thought to the fact that the water table is shallow, which means saturated soil is close to the land surface, increasing the risk for groundwater contamination.”
Protecting groundwater is the most meaningful work she can do in her eyes.
“Keeping groundwater clean is so important to our public health and safety, as it is the major source of drinking water,” Guilfoyle says.
Sizing up cleanup options
In determining the best method to tackle soil and water impacts, she considers multiple variables: regional standards, the proposed use of the property, and clients’ overall goals.
Every success story hinges on protecting human health and the environment while keeping an eye on the bottom line—economics.
“Our clients are taking on huge projects that can have substantial cleanup costs. Our priority is to develop solutions that limit their out-of-pocket costs and liability. But doing it more effectively, so the outcome is a rich resource that serves communities well into the future,” Guilfoyle says.
A solid understanding of regulations is key to delivering sound technical and financially feasible outcomes.
She exemplifies this, beginning with a recent approach involving removing contaminated soil and using the nonimpacted soil as part of a pond construction to expand stormwater holding capacity.
“In this scenario, you save on the cost to transport hundreds of tons of soil and put it to use to build out existing infrastructure. Also, fewer trucks are coming in and out of the site, mitigating a nuisance and greenhouse gases.
“In other scenarios, we have been able to negotiate cleanup levels above the standard by providing documentation to show they are sufficient for full compliance.”
Forging industry relationships through professional engagements
Guilfoyle knows the agencies well through her work at SCS and professional engagements beyond.
Among her involvement, she’s a board member of the Florida Brownfields Association (FBA), supporting educational and outreach efforts and legislative initiatives to secure funding for cleanup projects.
She serves on the Florida Association of Environmental Professionals (FAEP) board, reporting business activity to local chapter members.
She lends her expertise as a board member for Metropolitan Environmental Training Alliance (METRA), promoting free and low-cost training on hazardous waste management requirements and other environmental regulations.
Outside her leadership roles in industry organizations, she finds time for her passion—telling others about the environmental industry. She has been involved with teaching Boy Scouts and Girl Scouts at Science, Technology, Engineering, and Mathematics (STEM) events and introducing college students to job opportunities in these disciplines.
“It’s important to provide a real role model in science and introduce youth to the wide range of job opportunities. We need more sharp young minds. And we especially need more women in environmental sciences,” Guilfoyle says.
“We have done good work. But we have more ahead of us. We will continue making progress by increasing youths’ awareness of what we do and why we do it–and by educating and supporting industry organizations.”
Brownfield Redevelopment Resources, Funding, Careers:
Join SCS Engineers at Oklahoma State University’s STEM Career Fair on March 2, 2023.
SCS is an employee-owned, award-winning environmental engineering, consulting, and construction firm with offices nationwide. We are seeking a wide variety of dedicated, hard-working professionals with Science, Technology, Engineering, and Mathematics (STEM) backgrounds.
The fair is FREE to students.
Click for more information and registration
Join SCS Engineers at California State University at Fullerton’s Engineering and Computer Career Fair, February 23, 2023.
SCS is an employee-owned, award-winning environmental engineering, consulting, and construction firm with offices nationwide. We are seeking a wide variety of dedicated, hard-working professionals with STEM backgrounds.
CSUF’s career fair is a great opportunity for undergraduate and graduate students from the College of Engineering & Computer Science to meet potential employers, step-up your job or internship search, and network with employers who can answer your questions. If you are looking to hire for professional or internship opportunities in one of the many focus areas, this is an event you do not want to miss!
