Environmental Aspects of Heavy-Oil Recovery by Thermal EOR Processes artha Sarathl |, SPE, Natl, Inst, for Petroleum & Energy Research ‘Summary. This paper summarizes the major U.S. and State of Califor- nia environmental regulations rele vant to thermal EOR processes and assesses their impact onthe process. ‘The environmental laws that have the greatest impact on thermal EOR processes pertain to air quaity, water ‘ually, hazardous wastes, and envi- ronmental quality. This paper also identifies the source and type of pol lutant likely to be generated in a typ cal thermal EOR facility 662 Intreduction In recent years, thermal BOR operators have aced increasingly stringent environmental regulations oriented toward preventing sig nificant degradation of air and water quality and land misuse. These environmental laws and regulations significantly affect the de- sign and operation of thermal EOR proc cesses, U.S. federal, sat, and local agencies Aare involved inthe enactment a implemen- tation of various environmental laws and regulations. Because jurisdictions frequently ‘overlap, confusion can occur. For example in California, both the Dep. of Health Serv~ joes and the Regional Water Quality Con- ‘rol Board may be involved in determining the level of cleanup of old cilfeld sump and in improvements. The reason is that the Dept. of Health Services regulates hazard- ‘ous wastes while the Regional Water Qual ‘ty Control Board regulates any waste placed ‘on land that may affeet water quality Although a company's environmental specials may be familiar with environmen- tal laws and regulations and awace of the agencies responsible for enforcing them, other personnel may not have that knowl edge. Technical and operating personnel responsible for reporting actions must also be aware ofthese regulations 1 avoid in- advertent noncompliance with applicable en- vironmental rules and regulations. The purpose ofthis paper is to familiar= ize thermal EOR practicing engineers and other interested personnel with applicable environmental rules and regulations. The paper provides a summary review of many, but not all,envizonmental laws and regula tions that could be applied to thermal EOR, facilities and operations. The environmen- tal laws that have the greatest impact on ther mal EOR processes pertain to air quality, water quality, hazardous wastes, and env ronmental quality. In California, separate federal, state, and often regional or local Jaws and regulations pertain to these envi ronmental areas. Because California isthe hn for thermal EOR operations inthe U.S., California regulations are emphasized. The applicable regulations for those states where thermal EOR is being implemented, or is likely to be implemented, are summarized elsewhere. ‘The material in this paper was assembled by consulting publications of various fed eral, state, and private organizations. While every attempt was made to acquire the most recent applicable regulations or standards, regulatory processes are constantly evalu. ated, and the findings presented here may not be current. At best, the information presented here was applicable up to late 1990. Furthermore, because the interpreta- tions and enforcement standards in various regions can and do differ appreciably, the future potential constraints to thermal recov- ery processes cannot be defined readily, Major Laws The following major laws are relevant to thermal EOR processes in California Air Quality, Federal: Clean Air Act (CAA) and Amendments ‘State: California Air Pollution Coatrol Law (California Health and Safety Code, Divs. 26 and 27, as amended) and Califor. nia Air Pollution Control Regulations {California Code of Regulations (CCR) Ti- te 17, Public Health, Part I Regional: Ait Quality Control District Regulations, Water Quality. Federal: Clean Water Ac and Safe Drink ing Water Act. State: Californie Water Regulations (CCR, Title23, Chap. 3), California Porter Cologne Water Quality Act, and Safe Drink- ing Water and Toxic Enforcement Act (Proposition 6) an implementing rene lations Regional: Regional Water Quality Con- trol Board's water quality-control plans. Hazarilous Wastes. Federal: Resource Conservation and Recovery Act (RCRA) and Comprehensive Environmental Response Compensation and Liability Act. ‘State: California Hazardous Waste Con- t0ol Regulations (CCR, Title 22, Dv. 4, En- vironmental Health, Chap. 30). Local: Various county nd ety ordinances regerding hazardous wastes. June 1991 «PTEnvironmental Quality. Federal: National Environmental Policy ‘Act and implementing regulations ‘State: California Envieonmental Quality ‘Act (CCR, Public Resource Code, Div. 13). Local: Varous county and city ordinances regarding implementation of state and fed- eral law, Federal Regulatory Framework The U.S. federal environmental policy is formulated by codifying a variety of public Jaws and acts. Any new program enacted by Congress is called an act. Acts ure amend- ed through the enactment of publi laws. A public Taw may include amendments 10 several acts. The environmental statutes, whether acts or public laws, are periodically published as U:S. Codes (USC's). The USC's ae or ganized into different titles. For example, Statutes pertaining to the CAA can be found in Tile 42, Ses. 7401 and the following (42 USC 7401 er se). Regulations promulgated by federal agencies are initially published in the Federal Register. The final versions ofthe regulations are then incorporated into the Code of Federal Regulations (CFR). The (CFR is updated quarterly and published in its entirety annually. Because regulations take effect as soon asthe final version ap. pears in the Federal Register, «person can- ‘not be sure of fll regulatory compliance by reviewing the current edition of the CER ‘Regulations pertaining to the eavironmen- tal area ean be found ia Title 40 of CFR. Enforcement Agencies In California, the environmental regulations ‘are enforced by a number of agencies. At the federal level, the U.S. Environmental Protection Agency (EPA) is entrusted with ‘enforcing laws dealing with air and water ‘quality and hazardous wastes and materials, At the state level, many diferent agencies ae involved with implementing and enfore- ing laws pertaining to different environmen- tal areas. The agencies’ jurisdictions, discussed below, may sometimes overlap ‘Air Resources Board (ARB). The ARB is 8 state agency with primary responsibility to coordinate state-wide ait-quality pro- grams. Its also responsible for implement- Ing programs designed to attain the state and rational ambient air quality standards In ad- dition, this agency supervises the overell scheme to contol tori air pollutants and conducts research on varions air-quality ‘matters Air Pollution Control and Air-Quality Management Distriets (APCD/AQMD). ‘These are county or multicounty agencies responsible for implementing the state alr~ quality laws pertaining to stationary sourees ‘fai pollution. There are 34 single-county ‘and 5 multicounty APCD’s, and three AQMD's. ‘State Water Resources Control Board (SWRCB). Like ARB, SWRCB is a state agency Is primary function i to coordinate PT + June 1991 the state's water-quality program. ‘The 'SWRCB has the authority to regulate the dis- charge of wastes to land and the injection fof toxic waste into wells. Regional Water Quality Control Boards (WOCB). The RWOCB is a regional agency responsible for administering the Sfate’s water-quality program within the region. Iv also has the authority to develop water-qulity-control plans, to issue waste discharge permis, and to regulate waste dis- posal sites, The Sate is divided into nine RWQCB's Dept. of Health Services (DHS). DHS is sate agency entrusted wit implementing the state's hazardous waste laws and regu lations, including the permitting of hazard- us. waste facilities. Normally, the lowest level of government agency has the authoriy to implement the various laws and regulations. For example, the APCD is responsible for enforcing a quality laws and regulation, including is- Swance of permits for new air pollution sources within the district, However, some Aistrcts are permitted to regulate only por- tions of laws. In such cases, th agency that ‘etains portions of authority may aso be in- volved and agency overlaps cam occur. “The major federal and California environ ‘mental regulations thet affect thermal EOR ‘operations wil be briefly described. Other applicable federal regulations relevant to thermal EOR operations are summarized elsewhere. Table I lists abbreviations ‘sed in tis paper Alr-quality Regulations ‘The U.S. government plays a leading role in developing a regulatory framework within ‘which all thermal EOR operators must oper- ate, Federal environmental regulations and standards supersede al lessstringent state ‘and local regulations. Sut and local govern- ‘meats, however, ean promulgate and en- force more-stringent environmental stan dards than the federal government. For ex- ample, California’ air-quality requirements ‘are more stringent than those stipulated un- der federal atte, Kern County, CA, has adopted even more stringent measures to al- ‘ain and maintain state and national ambient- air quality standards. This section briefly ‘eseribes the federal and California air- ‘quality regulations with which thermal EOR ‘operators must comply. Tn California, the status of ambient air ‘quality i critical factor influencing the lev- ‘lof potential growth in each thermal EOR ‘area, California thermal EOR operators are subject fo the regulations of three institu tions: U.S. EPA Region IX, the California ‘Air Resources Board, andthe local/regional ‘ir-polution-control and air-qualy-manage- ment districts, Each agency separately promulgates regulations that affect allowa- ble air pollution emissions and the degree ‘of new source growth permitted, ‘The U.S. EPA isthe primary agency en- trusted withthe responsibility of implement- ing the federal Clean Air Act (CAA). The ‘AQMD Air Qualty Management Dist. (Calforia) BACT Best Avaliable Control “Technology GAA Clean Air at (federal) CCR Calfornia Code of FRogulations CFR Code ef Federal ‘ogulatons CWA Coan Water Act (federal) DHS Dept. of Health Services Caltria | 00a. Dy of OH 8 Gas | (California) | EPA Environmental Protection | ‘Agency (ede) Len cheese | Enisson Rate NAAQS Nall Ambient Al Quality ‘Sendaras NPDES Nall Polutant Discharge Eliminabon Systom NSPS NewSouree Petormance ‘Standards PL ble Law PSD Prevention of Signiticant Detenocaton ICRA Resource Conservation ‘and Recovery Act RWOCE Regional Water Quay ‘Control Board SDWA Sale Drinking Water Act | ‘Control Board |: (Caltornia) Use US. Code UIC Underground Injection (Contr purpose of CAA js to protect and enhance the air quality and to attain the National ‘Ambient Air Quality Standards (NAAQS). Under the CAA, each state has the primary responsibilty 1© provide the EPA with a ‘State Implementation Plan (STP) that details the method by which NAAQS are attained and maintained. EPA regulation pertaining to air quality canbe found in 40 CFR Sub- chapter C—Air Programs. The provisions ‘of CAA that impact thermal EOR operators are described below. NAAQS (42 USC 7409, Sec. 109), NAAQS are the primary guidelines used 10 measure the air quality ofa region. NAAQS sets the ceilings that each pollutant may not exceed. ‘The EPA set the NAAQS according to es tablished criteria, These criteria are re- viewed at least once every 5 years by an independent scieafic committee. The ai- quality standards are set on the basis of scientific data and analysis only. The EPA is not required to consider economic or technical feasibility in setting air-quality standards 663eee eer ‘i Contaminant panies Tors_= Sed Som NO,” ‘Annual average | 700 palm? 100 pgim? “Although a company’s (08pm) environmental at see specialists may be 24 hours 26 pgm? familiar with ‘ dpm i a environmental laws pian aco Sok and regulations. .., ‘02 opm) other personnel may Ree eee Onn mari Ra not have that ia technology. Technical ‘om eweem — @ateemr omia 1 no yom? 0.1: bpm) hous 157 yom for reporting actions (G08 ppm) must also be aware of @ hous "Guan? em) these regulations.’ 1 hour: 40 poi? (@5 ppm) Lead 20 days 4.5 gm 90 days 2.25 noi? Noun ral mo ne cre alr snc ‘There are two types of air-quality stan- to atainment are implemented by SIP’. Tae and the sources affected by the SIP are ex ards. Primary standards are intended to ble 2 shows the current U.S. primary and pected to participate. Requirements of SIP’s protect the public health, while allowing an secondary ambient-air-quality standards. are contained in 42 USC, Secs. 7407(a) and ample margin of safety. Secondary standards Table 3 lists the California ambient-air- 7410(a\1). aim to specify a level of air quality consid- quality standards fered necessary o protect the public welfare A comparison of these standards indicates Emission Limitations. The CAA has de- from known or anticipated adverse effects, that California ar-quality standards gener- veloped minimum technological standards including the effects on economic values and ally are more stringent than, but not entirely for various sources of air pollution. These personal comfort Consistent with, federal standards. Loal dis- sours are divided into two groups: tation ‘CAA has designated six pollutants as tricts suchas the Kern County APCD, are ary and mobile sources. Because stationary harmful, and standards have been estab- required to adopt the more-sringent federal sources are the originators of pollutant in lished. These pollutants are sulfur dioxide or state standards with respect to each pol- thermal BOR operations, only stationary: (60), nitrogen oxides (NO,), particulates, Iutant source standards are outined here. carbon monoxide (CO), ezone, and ead. At Tinestablishing the framework or control- ‘one time, the EPA had adopted NAAQS for IP's (42 USC 7410, See. 110). To imple- ling emissions from stationary sources, the hhydrocarbons, but these standards were later ment the CAA, states are required to adopt CAA distinguishes between new and exist- rescinded, These standards are now im- and submit to the EPA a SIP detailing the ing sources. Because iis typically less ex- plemented through SIP’s (CAA, Sec. 110). basic strategies for implementation, main- pensive for new emissions sources 10 ‘Most thermal EOR operations use lease tenance, and enforcement of NAAQS within incorporate state-of the-art control tetinol- crude-fired steam generators. These gener- the stite. The SIP forms the blueprint for _opes, the regulatory burden fells more heav- fators emit SO,, NO, and particulates, In achieving air-quality goals within a state, ily onthe new sources. Existing sources are addition, oilfield wellheads can emit hydro- ‘The SIP provides the emission limitations, regulated through the SIP. Each sate must ‘carbons, depending on the degree of control. schedules, and timetables for compliance by develop a standard of performance for ex- "The EPA has designated 247 Aie Quality stationary sources of air pollution such as isting sources using EPA guidelines, If a Control Regions (AQCR's).. Although —cilfeld seam generators. The EPA must sp- stat fails to establish standards or if the stato NAAQS should not be exceeded in any of prove tho SIP for each sate. The SIP should standards are not acceptable to the EPA, the the regions, they are not directly enforce contin measures necessary for achieving the EPA may promulgate its own standards able. The EPA hus set emission limitations primary and secondary standards. In setting To control the polltants from new sta- for each pollutant to attain NAAQS. Ifthe these measures, the sate does not need to tionary sources, the CAA directs the EPA. actual air pollutant concentration in an air consider their technical or economic feasi- to establish New Source Performance Stan district exceeds the NAAQS, morestringent bility, dards (NSPS). The NSPS reflect the degree pollutioncontrol devices om the emission ‘The SIP must ensure attainment of of pollution control achievable through the Source are imposed to reduce the concen- NAAQS by prescribed dates. For example, best available and adequately demonstrated tration 1 an appropriate level, The EPA bas the EPA set Dec. 31, 1987, asthe date by —polluoa-control techniques la selecting the rated the AQCR as either ‘‘clean”” or which Kem County had to meet NAAQS. best available control technology for each ““nonatiaiament” foreach pollutant. Nonat- The SIP must mect federal requirements, but pollutant, the EPA must take into account ‘ainment areas are those in which state and each state may choose its own mix of emis- the cost of achieving such emission reduc- federal ambient-air-quality standards have sions for stationary and mobile sources to ton and energy requirements. ‘ot been met for the specified pollutant. meet NAAQS. The CAA prohibits the adap- The EPA has delegated the authority to Procedures to bring the nonatiainment areas tation of any SIP without a public hearing, implement and enforce NSPS to various 60s dune 1991 © JPstate and local agencies, although it always retains independent enforcement authority Prevention of Significant Deterioration (PSD) (42 USC 7470 et seq). In 1977, Con- ress amended the CAA to prevent signifi- ant future degradation of U.S. clean-air areas. A clear-ar area is one where the ait quality is better than the ambient primary for secondary standard, Thus, the purpose of PSD is to “keep clean air clean.” To achieve the stated purpose, states were re- quired to identify, in theit SIP, emission limitations and other measures necessary 0 prevent significant deterioration of ar qual- ity wit respect to designated pollutants (42 USC, 7473. To implement this program, the CAA divided clean-air areas into thtee groups. ‘This clasifiction determines the increment by which SO, and suspended particulates ‘may be increased ina given area. In Class areas, which include national parks and na- tional wilderness areas, only a minor air- quality degradation is permited. Class areas, which include regions designated by Sates as within national primary and secon ary ambieat-air-quality standards, moder- ste degradation is permitted. In Class Tt areas, which nelude all other regions, sub- stantial ar-qualty degradation is permitted. Tn no case does PSD permit uir quality to Aeteiorte below secondary air-quality tan- IPT « June 1991 orate ne et Tad Pohutant Averaging Tie Concentration ‘Gnadert 7 hour 0.10 ppm, (200 polm®) co 72 hous 10 60m. (it maim’) 1 hour 40 ppm, (48 main) Noe 1 hour 026 pom 470 noim*) $0, 2¢hours 0.08 ppm, (31 9m) 1 hour 05, 0310 19m") Suspended ‘Annual geometric mean 8 poh Pariculate matter 24 nous 40 gin? Sutatos 26 hours 25 noi’ eed 3 days 18 wom? hs * hour 0.03 pr (42 pgm") Ethylone hours 0.1 por ‘or a5 pen Viti reducing 1 obeervatlon | sutcont amount rece aril the prevaling vstly te <30 ios when the relative Tumiy i < 70% ‘Applicable ony in the Lake Tahoe Ar Basin | co hous 8 ppm, gin") Visit oaucing 1 observation i suftetent amount to reduce | partes the provaling visty to <0 ‘miles when the relative humid is = 7096, dards. Table 4 shows the permitted air- ‘quality increments for PSD. “Increments” ae the maximum amount ‘of deterioration that can occu in a clean- air area over th baseline, “Baseline” isthe existing ai quality forthe area at the time the first PSD is applied. Inorements in Class Tareas are smaller than those for Class IL, and Class I increments are smaller than those for Class Ill areas. For the purpose ‘of PSD, a major emitting source i one that fas into one of 26 designated categories and ‘whose potential emission rates greater than 100 tons'r. Fossil-fucl-fired steam gener- ators that ave more than 250 million Btwlhr heat input are in the PSD-designated categories. In addition to the 26 PSD- , NO,., and paric- tulates. Additionally, small amounts of un- ‘bummed hydrocarbons and traces of CO also are emitted. On-site storage tanks and wells to be steamed also emit hyérocarbons. ‘Among these, S03 is of erical concern be- ‘cause ofthe stringent federal, state, and lo- cal regulations limiting its Iepal emission level. Table 5 lists the typical emission rates forall pollutants expected for different sizes ‘of generators. For this computation, itis assumed that the steam generator Will se a fuel containing 1.09 wt% sulfur In the insta combustion process, com- pressed aris injected into reservoir to sup- ‘port combustion, The combustion results in ‘thermal cracking and oxidation reactions. Oxidation and thermal-cracking. products ‘may be present in the emissions at produc- tion wells. The EPA analyzed the major con- stituents ofthe produced gas using samples collected at 31 in-siu-combastion test sts. ‘Table 9 presents the results of this analy- sis, The physical and chemical process of combustion within an oil-bearing porous ‘medium and the operating and reservoir characters of an in-situ combustion project alfect the emissions produced. Other pollu- tants involved with the fireflood process emanate from the compressors. ‘Water Quality. Thermal EOR operations produce large quantities of waste efluent ‘These waste effluents include those gener- ated by site-preparation activities, such as drilling and well Workovers, and effluent from proivction wells. Storm water runoff from construction areas can affect the qual- iy of local surface waters. Runoff from con- struction sites may include clay and silt parle, inorganic and organic mater from decayed vegetation and soil il from paved areas, and oil and grease from construction equipment ‘Local groundwater quality canbe affect: ced by thermal EOR wastewater eluent is- posal activites. Some of these potential problems are (1) seepage of injected or rein- Jected materials through the formation ‘underground aquifers, (2) leaching from un- lined waste-disposal pits, (3) accidental sur {ace spills during storage and transport of ‘wast effluents, and (4) socondary fractures that_may comnect the formation with aquifers. “Total protection of groundwater from ‘waste is impossible because the control of all flow paths from waste to groundwater aquifers, except casing leaks, is beyond reliable engineering control. ‘Waste Management. A typical thermal BOR process generates wastes during both the stepreparation and field-testing phases. The wastes produced from ste preparation activities include cla, silt, and dastparti- done 1991 « JPcles, organic and inorganic mater from decayed vegetation, dling wastes such as ‘mud and brines, and oil and grease from ‘construction machinery. The fist wo types ‘of wastes are dispoted of by landfil and are ‘of no environmental concern. Drilling wastes and oilfield brines, beeause of theit potential damage to the local watet and ecosystem, require careful handling. and must be disposed of in state-approved sites. ‘The wastes generated from field opera: tions activities include sladge produce from Scrubbers, spent liquids such as scrubber fluids, oily wastes, and hazardous (toxic) wastes. The handling and disposal of these wastes call for special measures. 1. Scrubber liquids must be treated on site before disposal into local surfece waters. 2. Serubber sludges ar difficult and cost- ly 10 dispose of and are a potential source ‘of contamination of loal surface and sub- surface water atthe disposal site. 3. Cily wastes are collected separately and ae disposed of according to local regulato- ry requirements. 4. Hazardous wastes are handled in ac- cordance with the state regulatory re- ‘quirements. Conclusions Environmental requirements for candidate ‘thermal EOR projects inthe U.S. have been identified and evaluated from federal, state, and local regulatory viewpoints. Various federal, state, and loca environmental agen- cies were contacted to obtain the desired in- formation. The following conclusions have been derived. 1, Environmental regulations pertaining to ambieot air quality and groundwater qual- ity greatly affect the growth ofthe thermal BOR process 2. Current regulations are suficient for controlling noise pollution. 3. Environmental jssues suchas solid-and liguid-waste handling procedures require site-specific details that must be evaluated in terms of the applicable governmental regulatory requirements Acknowledgments ‘This work was supported by the U.S. DOE under Cooperative Agreement DE-FC22- 83FE60149. I thank T.B. Reid ofthe U.S. DOE and A. Suycker, M. Madden, and M.K. Tham of the Natl Inst, for Petrol: tum & Energy Research for their helpful sug- pestions. References 1. Sarai: “Environmental Aspects of Hea (i! Recovery by Thermal EOR Processes, paper SPE 21768 presented atthe SPE 1991 ‘Wester Regional Meeting, Long Beach, CA, March 20-22, 2. California Steamers Named 1 First Toxic ‘Hot Spr" Lis.” Advanced Recovery Week (Dee. 10, 1990) 1, No. 40,1 General References Apleron,JF- and Soytel, T: “NO, Redution Methods in California Stam Gener: by A JPT + June 1991 lid Tecnology, paper SPE 12772 preset 1 the 1984 SPE Califoraia Regional Meeting, Long Beach. April 11-13, API Bul. 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Wilson, ML. and Kiser, S.C. “Sypergsic Ap- ‘pach for Siting aod Design for Injection of Hazardous Ligud’ Wastes: Case” Stud)” in ‘Wester San Joaguin Valley, Ker Couaty, California,” paper SPE 16327 presented a the 1987 SPE California Regional Mesting, Ver- cura, April 8-10, Wilson, 1D. Environmental Regulations Hand oak for anced Oi Recovery 1983 Updo, Report DOB/BIC/10355-1, Nat. Technica I formation Service, Springfield, VA (Oct 1983), ‘SI Metric Conversion Factors bo x nse E-ol = x os Ey0 = cP te vm = 4588924 E01 > kp wiles x Len atte Est) = te tors x 9071887 Bol = Me Provenance Original SPE manuscript, Environmental Aspects of Heavy-Oil Recovery by Ther= imal EOR Processes, received for review Jan. 21, 1991. Paper accepted for publica tion Mareh 21, 1991. Revised manuscript received March 20, 1991. Paper (SPE 21768) frst presented at the 1991 SPE. ‘Western Regional Meeting held in Long Beach, March 20-22. 7a