Permitting & Consulting

Regulatory Basis Development

Understanding Air and Water Pollution permits is important to maintaining a compliant facility. CleanCap can provide site support by analyzing operational practices in order to best comply with existing or future operating permits.

Emissions Estimating

Based on the throughput and effectiveness of the process equipment, CleanCap can provide an estimate of emissions from a particular facility or process line with our highly trained team of experts and our on-hand equipment.

To assist with the emissions compliance and estimating process, CleanCap maintains a comprehensive inventory of ambient air sampling and meteorological monitoring equipment and the trained staff necessary to provide complete ambient air quality and meteorological monitoring services. These services include comprehensive community exposure assessments, fence line monitoring programs, wind energy studies, QA audits, data processing and reporting, and monitoring site selection.

Permit Preparation Support

CleanCap Technologies can also assist and provide the necessary information required to obtain Construction and Operating Permits for new process equipment. This could be as involved as working through specifications and equipment details to gather the relevant details or as minor as reviewing the permit request with your team to ensure it meets the qualifications for submission prior to completing and submitting your permit application. This service can save you re-filing fees or non-compliance costs as well as valuable time and delays that may be incurred due to incorrect or incomplete information being submitted.

Obtaining Permits

At CleanCap Technologies, we understand the need for negotiating permit conditions, stating correct emission inventories, performing dispersion modeling, and setting up electronic reporting. We work with clients on minor permits, Title V operating permits, and non-attainment and new source review issues. Through our history, the CleanCap team has the experience to expedite and obtain various permits from regulatory authorities.
CleanCap is able to support owners and operators of Class VI carbon dioxide injection wells to obtain permits by working with the Owner to develop, implement, and periodically review and, if necessary, amending a series of project and site-specific plans that guide the management of each geologic sequestration (GS) project. This support will focus on:

Assisting with preparing GS project plans that meet the requirements of the Class VI Rule.
Providing guidance by submitting them to the appropriate Program Director for approval.
Providing support with a periodic compliance review and amending plans.

Once the permit preparation and submission process has been completed and the plans are approved, they then become an enforceable part of the Class VI permit. CleanCap can continue with support facilities by assisting the Owner and operators with compliance in the following site-specific categories:

Area of Review (AoR): This support plan defines how an owner or operator intends to delineate the AoR for the Class VI injection well and ensure that all identified deficient artificial penetrations (i.e., wells that are improperly plugged or completed) can be addressed by corrective action techniques so that they will not become conduits for fluid movement into underground sources of drinking water (USDWs).
Testing & Monitoring Plan: This support plan entails how the owner or operator intends to perform all necessary testing and monitoring associated with a GS project, including injection monitoring, performing mechanical integrity tests (MITs), corrosion monitoring, tracking the carbon dioxide plume and area of elevated pressure, monitoring geochemical changes above the confining zone, and, at the discretion of the Program Director, surface air and/or soil gas monitoring for carbon dioxide fluctuations and any additional tests necessary to ensure USDW protection from endangerment.

Injection Well Plugging plan: This plan describes how, following the cessation of injection, the owner or operator intends to plug the Class VI injection well using the appropriate materials and methods to ensure that the well will not become a conduit for fluid movement into USDWs in the future.
Post-Injection Site Care & Site Closure Plan: This plan illustrates how the owner or operator intends to monitor the site after injection has ceased, in order to ensure that the carbon dioxide plume and pressure front are moving as predicted and USDWs are not endangered. PISC monitoring must continue until it can be demonstrated that the site poses no further endangerment to USDWs.
Emergency & Remedial Response Plan: This plan describes the actions that the owner or operator intends to take in the event of movement of the injectate or formation fluids in a manner that may cause an endangerment to a USDW, including the appropriate people to contact.

These detailed site-specific GS project plans are necessary to ensure that management of the GS project is based on the most up-to-date site characterization, modeling, operational, and monitoring data to protect USDWs from endangerment. The plans also afford the flexibility needed to address the variety of types of geologic formations in which GS will occur, while also facilitating dialogue between the Class VI injection well owner or operator and the Program Director and CleanCap will be here to ensure compliance and regulations are being met with our highly trained compliance and permit team.

Class VI well permits are issued for the operating life of the project (i.e., from authorization of injection through site closure, which may occur many decades later). Unlike some other injection well classes regulated, there is no periodic reapplication for, or reissuance of, a Class VI permit. Instead, the plans are reviewed as part of the Class VI permit application review and approval process and incorporated into the Class permit. These plans must be amended periodically, as specified in the Class VI Rule, and CleanCap can provide support for this amendment process. The iterative process of developing and executing the GS project plans described in this guidance is tailored to the unique aspects of GS and is intended to ensure that time and resources are committed to the most critical aspects of managing Class VI injection well operation.

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