Safety and Environmental Aspects

Introduction

There is value in assessing potential environmental, health, and safety (EHS) impacts early in the technology selection process to determine tradeoffs from an EHS standpoint. In addition to direct EHS impacts from industrial processes, there are several indirect factors that will be important to define early on as they will have a direct bearing on EHS impacts:

1. Location of Technology and Scale of Buildout: Location and scale will drive the level of EHS impact as well as trigger additional regulatory compliance—which can ultimately lead to increased operational costs. Activities such as additional reporting requirements, sampling or analysis triggered by certain types of compliance, and incorporation of Best Available Control Technology requirements may be required depending on the location and scale of the operation. Allowable storage volumes may depend on factors such as training of onsite personnel, permits, and proximity to residential or other sensitive/high consequence areas. Location of technology and scale of operation will also trigger EHS impacts (and associated compliance requirements) for waste handling depending upon the type of waste generated, and how it is stored, moved, and treated.

   The following examples delineate initial EHS focus areas that are highly dependent on location and scale:

   • Air Quality: Areas in nonattainment of the National Ambient Air Quality Standards (NAAQS) for ground-level ozone will have permitting and other compliance requirements that could make new construction, retrofits of components, storage, or increases in gas volume a challenge, dependent upon how facilities will be constructed or retrofitted. While some compliance requirements are triggered by location, others will be triggered by scale (for example, gas volume throughput increases, storage, additional infrastructure). Additionally, combustion of hydrogen has shown to produce NOx, which is a regulated criteria pollutant under the NAAQS. Regulations surrounding NOx intensify in non-attainment areas since NOx is a precursor for ground-level ozone (smog). Therefore, in non-attainment areas, combustion of hydrogen will need to demonstrate mitigative measures such that it conforms with State Implementation Plans (SIPS).

   • Water Usage and Consumption: Drought prone areas or areas with limited water supply may pose constraints to water intensive certain types of technology such as large scale electrolyzers that require pure water as an input. Use of existing municipal wastewater for treatment and incorporation of these technologies will take R&D, as well as time, and may require negotiations with local governments, factors that should be considered when evaluating technology options.

   • Water Quality: Discharging of wastewater will require additional compliance, permitting, sampling, and reporting—which may intensify depending upon the ecological sensitivities of the area. Construction or expansion of facilities over aquifer recharge zones or in karst areas with sensitive cave systems require special consideration, permitting, and regulatory compliance.

   • Critical and/or Protected Habitat: Areas located in critical habitat designated by the U.S. Fish and Wildlife Service (USFWS) contain protected or endangered flora and/or fauna species and are regulated under the Endangered Species Act (ESA)^[1]. Areas on or near critical habitat will have constraints on types of infrastructure allowed on site or in proximity. If public lands are used, environmental site assessments and/or environmental impact statements will be required. This will include impacts associated with air quality, water quality (both surface and ground), noise, cultural impacts to historic areas, ecological impacts to flora/fauna, fragmentation, and cumulative impact assessments.

   • High Consequence Areas Related to Safety and/or Terrain: Certain areas in proximity to residential dwellings or businesses will have limitations on infrastructure development depending upon the types and amounts of chemicals being processed, stored, and delivered. Additionally, there are geological features that pose increased risk to personnel and/or infrastructure constraints such as areas prone to ground movement, steep slopes, flood plains, and seasonal wetlands, among others.

   • Equity, Environmental, and Energy Justice: Applying an equity lens to projects involving new technologies involves identifying disadvantaged and vulnerable communities potentially impacted. Partnering with community and local governments can help characterize impacts, develop engagement strategies, and build relationships. An important step is to develop measures of societal and environmental impact; these include assessments of impacts to not only to human health and environmental hazards, but also to economic outcomes, occupational factors, and other cultural, social, and historical concerns.

2. Safety Training of Personnel and the Public: With many applications emerging for hydrogen, ammonia, and synthetic fuels, there is an increased risk to personnel safety as systems are scaled up and located in proximity to potentially untrained local safety and rescue personnel. Protocols, procedures, and training related to the safe operation of new technology applications will be important for their safe deployment. In addition, clear communication of safe usage protocols will be needed for use of these fuels by the public, such as in the situation of vehicle fueling stations.

3. Cumulative Impacts from Multiple, Centralized Operations: Dependent upon how facilities are designed, impacts may accumulate for a given process. For example, upstream emissions may increase with the introduction of CCS during hydrogen production. This is due to increases in the amount of input fuel required, as well as additional heat and electricity required to operate the CCS process. It may be possible to mitigate this impact by using low-carbon sources of heat and electricity, although assessing the technical and commercial feasibility, and the extent of potential mitigation, would need to be examined.

4. Enhancing Circularity of Low Carbon Technologies: As deployment of low carbon technologies accelerates, circular economy participation can enhance environmental stewardship, incorporate responsible economics, and reduce regulatory and recycling/reuse market uncertainties at end of life. Common fundamental objectives managed in circular economies include reduction of natural resource use and loss; designing a technology for repair, reuse, or recycling; extending the useful life of technology; and recovering embedded value through recycling and reuse of components or raw materials. Designing technologies and systems for circularity at the point of wholesale industry shifts is easier than attempting to retrofit to meet these principles.

5. Atmospheric Impacts: There has been growing concern of potential atmospheric impacts related to hydrogen leakage from larger scale operations. This means that monitoring for intended and unintended releases may need to be integrated into operations with the possibility of emissions factor development.

Key Research Questions

Over the course of the LCRI, the TSC intends to address the following research questions.

1. What are the industrial processes involved for each of the AECs being considered under LCRI and where are the largest safety and environmental impacts anticipated?

2. How do safety and environmental impacts scale with the footprint of the technology, its location, and local regulatory parameters?

3. How do different EHS metrics associated with hydrogen, ammonia, synthetic hydrocarbons, and biofuels compare when assessing realistic impacts of alternative operating scenarios?

4. What types of safety and environmental data are needed to support accurate evaluations of various impacts?

5. Once impacts are identified, what is the procedure to quantify those impacts (for example, estimation, measurement)?

6. What are the regulatory pitfalls associated with existing processes and procedures? What are the regulatory barriers for emerging technology and processes?

7. What does a successful "regulatory landscape" look like for new technologies?

8. What format is needed for results of safety and environmental R&D such that it translates seamlessly into quantifiable and defensible environmental, social, and corporate governance metrics and carbon reduction quantification?

9. How should impact assessments be refined such that both the inputs and outputs are appropriate for an integrated energy system analysis?

10. How can low carbon technologies and fuels effectively integrate in circular economies to enhance environmental, social, and economic outcomes?

11. How should the deployment of new technologies be evaluated in terms of equity and environmental and energy justice?

Research Effort

The overall research objective for this TSC is to understand the safety and environmental aspects of AEC production, storage, delivery, and end use and develop solutions to any challenges, where appropriate, in accordance with the overall goals of LCRI. Note that the goals/strategies/actions outlined below are not necessarily presented in a linear structure—several actions are intended to progress in parallel.

Goal 1: Identification of Impacts

• Strategy 1: Map Industrial Processes and Identify EHS Issues

  • Action: Identify value chain elements that pose increased risk of EHS issues to be assessed.

• Strategy 2: Develop a Decision Support Tool to Compare EHS Impact in Different Scenarios

  • Action: Create decision support software to explore the intensity of impacts such that decisions can be made on differing types of technology integration scenarios.

Goal 2: Quantification of Impacts

• Strategy 1: Prioritize High Impact Areas in Need of Quantification

  • Action: Determine high impact areas.

• Strategy 2: Gather Information from Literature and Collect Data for life cycle assessments

  • Action: Project scoping for data collection to fill R&D and data gaps not found in literature.

  • Action: Launch quantification projects.

Goal 3: Mitigation of Impacts

• Strategy 1: Determine Regulatory Pitfalls based on Area and Scale

  • Action: Identify regulatory pitfalls of existing processes and procedures associated with AECs. Develop a summary of potential regulatory and permitting needs of new technology integration scenarios.

• Strategy 2: Create a Regulatory Pathway for New Technologies

  • Action: Launch projects to validate performance of mitigation technologies.

  • Action: Develop methods, protocols, and procedures for safe operation and mitigation.

• Strategy 3: Create Circular Economy Pathways for Low Carbon Technologies and Fuels

  • Action: Evaluate barriers and opportunities for supply chain transparency, procurement requirements, life extinction, recycling, and reuse of low carbon technologies.

  • Action: Demonstrate improved refurbishment, recycling, and reuse opportunities with lower associated costs and improved environmental and social impacts.

Goal 4: Decarbonization and Environmental, Social, and Governance Metrics

• Strategy 1: Design and Develop a Tool that Identifies Environmental Impacts Throughout the Value Chain

  • Action: Perform framing and planning for assessing health, safety, and environmental impacts and integrate results with existing LCRI models.

• Strategy 2: Support Equity, Environmental, and Energy Justice Goals

  • Action: Develop strategies that help promote planning and development of projects in disadvantaged communities and/or that improve conditions for overburdened communities.

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1. The U.S. is used as an example. Other nations have similar agencies and restrictions as those described here. ↩︎