Environmental Aspects
of Heavy-Oil Recovery by
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 on the process.
The environmental laws that have the
greatest impact on thermal EOR
processes pertain to air quality, water
quality, hazardous wastes, and envi-
ronmental quality. This paper also
identifies the source and type of pol-
lutant likely to be generated in a typi-
cal thermal EOR facility.
662
Thermal EOR Processes
Partha Sarathl, SPE, Natl. Inst. for Petroleum & Energy Research
Introduction
In recent years, thennal EOR operators have
faced 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-
esses. U.S. federal, state, and local agencies
are involved in the enactment and implemen-
tation of various environmental laws and
regulations. Because jurisdictions frequently
overlap, confusion can occur. For example,
in California, both the Dept. of Health Serv-
ices and the Regional Water Quality Con-
trol Board may be involved in determining
the level of cleanup of old oilfield sumps and
in improvements. The reason is that the
Dept. of Health Services regulates hazard-
ous wastes while the Regional Water Qual-
ity Control Board regulates any waste placed
on land that may affect water quality.
Although a company's environmental
specialists may be familiar with environmen-
tal laws and regulations and aware 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 of these regulations to avoid in-
advertent noncompliance with applicable en-
vironmental rules and regulations.
The purpose of this 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, environmental laws and regula-
tions that cou.ld 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 envi-
ronmental qUality. In California, separate
federal, state, and often regional or local
laws and regulations pertain to these envi-
ronmental areas. Because California is the
hub for thermal EOR operations in the 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. 1
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 thennal 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 Control
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-
tle 17, Public Health, Part III].
Regional: Air Quality Control District
Regulations.
Water Quality.
Federal: Clean Water Act and Safe Drink-
ing Water Act.
State: California Water Regulations
(CCR, Title 23, Chap. 3), California Porter
Cologne Water Quality Act, and Safe Drink-
ing Water and Toxic Enforcement Act
(Proposition 65) and implementing regu-
lations.
Regional: Regional Water Quality Con-
trol Board's water-quality-control plans.
Hazartlous Wastes.
Federal: Resource Conservation and
Recovery Act (RCRA) and Comprehensive
Environmental Response Compensation and
Liability Act.
State: California Hazardous Waste Con-
trol Regulations (CCR, Title 22, Div. 4, En-
vironmental Health, Chap. 30).
Local: Various county and city ordinances
regarding hazardous wastes.
June 1991 • JPT
Environmental Quality.
Federal: National Environmental Policy
Act and implementing regulations.
State: California Environmental Quality
Act (CCR, Public Resource Code, Div. 13).
Local: Various county and city ordinances
regarding implementation of state and fed-
erallaw.
Federal Regulatory Framework
The U.S. federal environmental policy is
formulated by codifying a variety of public
laws and acts. Any new program enacted by
Congress is called an act. Acts are amend-
ed through the enactment of public laws. A
public law may include amendments to
several acts.
The environmental statutes, whether acts
or public laws, are periodically published
as U,S. Codes (USC's). The USC's are or-
ganized into different titles. For example,
statutes pertaining to the CAA can be found
in Title 42, Sees. 7401 and the following (42
USC 7401 et seq.). Regulations promulgated
by federal agencies are initially published
in the Federal Register. The final versions
of the 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 as the final version ap-
pears in the Federal Register, a person can-
not be sure of full regulatory compliance by
reviewing the current edition of the CFR.
Regulations pertaining to the environmen-
tal area can be found in 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 different agencies
are involved with implementing and enforc-
ing laws pertaining to different environmen-
tal areas. The agencies' jurisdictions,
discussed below, may sometimes overlap.
Air Resources Board (ARB). The ARB is
a state agency with primary responsibility
to coordinate state-wide air-quality pro-
grams. It is also responsible for implement-
ing programs designed to attain the state and
national ambient air-quality standards. In ad-
dition, this agency supervises the overall
scheme to control toxic air pollutants and
conducts research on various air-quality
matters.
Air Pollution Control and Air-Quality
Management Districts (APCD/AQMD).
These are county or multicounty agencies
responsible for implementing the state air-
quality laws pertaining to stationary sources
of air 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. Its primary function is to coordinate
JPT • June 1991
the state's water-quality program. The
TABLE 1-ABBREVIATIONS
SWRCB has the authority to regulate the dis- USED IN THE TEXT
charge of wastes to land and the injection
of toxic waste into wells. APCD Air Pollution Control Dist.
(California)
Regional Water Quality Control Boards ARB Air Resources Board
(RWQCB). The RWQCB is a regional (California)
agency responsible for administering the AQCR Air Quality Control RegiOn
state's water-quality program within the AQMD Air Quality Management
region. It also has the authority to develop Diat. (California)
water-quality-control plans, to issue waste BACT Best Available Control
Techn,ology
discharge permits, and to regulate waste dis- eM Clean Air Act (federal)
posal sites. The state is divided into nine CCR California Code of
RWQCB's. Regulations
CFR COde of Federal
Dept. of Health Services (DHS). DHS is RegulationS
a state agency entrusted with implementing CWA Clean Water Act (federal)
the state's hazardous waste laws and regu- DHS Dept. of Health Services
lations, including the permitting of hazard- (California) "
ous waste facilities. DOG Div. of Oil & Gas
Normally, the lowest level of government (California)
EPA Environmental Protection
agency has the authority to implement the , AgQrtCy (federal)
various laws and regulations. For example, LAER Lowest Achievable
the APCD is responsible for enforcing air- iEmission Rate
quality laws and regulations, including is- NMQS Nat!. Ambient Air Quality
suance of permits for new air pollution Standards
sources within the district. However, some NPDES Natl. Pollutant Discharge
districts are permitted to regulate only por- Elimination System
tions oflaws. In such cases, the agency that NSPS New-Source Performance
retains portions of authority may also be in- Standards
volved and ag~ncy overlaps can occur. PL Public: Law
PSD
The major federal and California environ- Prevention of Significant
Deterioration
mental regulations that affect thermal EOR RCRA ,Resource conservation
operations will be briefly described. Other and Recovery Ac:t
applicable federal regulations relevant to RWQCS Regiona, 'NateI' Quality
thermal EOR operations are summarized Control Board
elsewhere. 1 Table 1 lists abbreviations (California)
used in this paper. SDWA Safe Drinking Water Act
SIP State Implementation Plan
SWRCB State Water Resources
Air-Quality Regulations
Control BOard
The U.S. government plays a leading role (California)
in developing a regulatory framework within USC U.S. Code
which all thermal EOR operators must oper- UIC Underground Inlection
ate. Federal environmental regulations and Control
standards supersede all less-stringent state
and local regulations. State and local govern-
ments, however, can promulgate and en- purpose of CAA is to protect and enhance
force more-stringent environmental stan- the air quality and to attain the National
dards than the federal government. For ex- Ambient Air Quality Standards (NAAQS).
ample, California's air-quality requirements Under the CAA, each state has the primary
are more stringent than those stipulated un- responsibility to provide the EPA with a
der federal statute. Kern County, CA, has State Implementation Plan (SIP) that details
adopted even more stringent measures to at- the method by which NAAQS are attained
tain and maintain state and national ambient- and maintained. EPA regulations pertaining
air-quality standards. This seetion briefly to air quality can be found in 40 CFR Sub-
describes the federal and California air- chapter C-Air Programs. The provisions
quality regulations with which thermal EOR of CAA that impact thermal EOR operators
operators must comply. are described below.
In California, the status of ambient air
quality is a critical factor influencing the lev- NAAQS (42 USC 7409, Sec. 109). NAAQS
el of potential growth in each thermal EOR are the primary guidelines used to measure
area. California thermal EOR operators are
the air quality of a region. NAAQS sets the
subject to the regulations of three institu-
ceilings that each pollutant may not exceed.
tions: U.S. EPA Region IX, the California
Air Resources Board, and the local/regional The EPA set the NAAQS according to es-
air-pollution-control and air-quality-manage- tablished criteria. These criteria are re-
ment districts. Each agency separately viewed at least once every 5 years by an
promulgates regulations that affect allowa- independent scientific committee. The air-
ble air pollution emissions and the degree quality standards are set on the basis of
of new source growth permitted. scientific data and analysis only. The EPA
The U.S. EPA is the primary agency en- is not required to consider economic or
trusted with the responsibility of implement- technical feasibility in setting air-quality
ing the federal Clean Air Act (CAA). The standards.
663
 TABLE 2-CURRENT U.S. PRiMARY AND SECONDARY
AMBiENT-AiR-QUALITY STANDARDS

Primary $eoondary'
Air Contaminant Averaging Time StailQard Standard
NOjt* Annual average 100 JLOIm 3 100 JLOIm 3
"Although a company's (0.05 ppm) (0.05 PJ.)1ll)
SOa Annual average 80 JLOIm 3
environmental (0.03 ppm)
specialists may be 24 hour~ . 365 p.gJlti$
familiar with '(0.14 ppm).
3 hours 1300 p.glm 3
environmental laws 1 hour 520 p.gJm3 (0.5 ppm)
and regulations ... , (0.2 ppm)
other personnel may S.uspended particulates /l.nnual Q90llletrlc mean S() p,g/m 3 50 /LgJm 3 .

not have that 24bours 1s<lp.gJm 3 si50 /LgJm 3

Hydrocarbons (corrected 3 hours 160 p,glm 3 160 /Lglm 3
technology. Technical for metnane) 6 to 9 a.m. (0.24 ppm)·' (0.24 ppm)"·
and operating Ozone 1 houf 235 lLgJm 3 2~.JtgJm3
(0.12 ppm) (0.12 ppm)
personnel responsible 8 hours 157 JLOIm 3
for reporting actions (0.08 ppm)
must also be aware of co .8 hour$ .1.0 /Lg/m~' 10 /LgJtrl$!!>!l)!
'. (9 ppm) ...,
'(9 ppm)
these regulations." 1 hour 40/Lglm 3 40 ILQ/m 3
(35 ppm) (35 ppm)
Lead 90 days 1.5/LgJm 3 1.51LgJm 3
3O.d,~ys 0.5~9/m3
J.,.,.,
.'

'NO. is the only one of Ihe nitrogen oxides considered in the ambient standards•
• 'Maximum 3-hour concentratlon betwesn I) end 9 a,m.

There are two types of air-quality stan-
dards. Primary standards are intended to
protect the public health, while allowing an
ample margin of safety. Secondary standards
aim to specify a level of air quality consid-
ered necessary to protect the public welfare
from known or anticipated adverse effects,
including the effects on economic values and
personal comfort.
CAA has designated six pollutants as
harmful, and standards have been estab-
lished. These pollutants are sulfur dioxide
(S02), nitrogen oxides (NO x ), particulates,
carbon monoxide (CO), ozone, and lead. At
one time, the EPA had adopted NAAQS for
hydrocarbons, but these standards were later
rescinded. These standards are now im-
plemented through SIP's (CAA, Sec. 110).
Most thermal EOR operations use lease-
crude-fired steam generators. These gener-
ators emit S02, NO x and particulates. In
addition, oilfield wellheads can emit hydro-
carbons, depending on the degree of control.
The EPA has designated 247 Air Quality
Control Regions (AQCR's). Although
NAAQS should not be exceeded in any of
the regions, they are not directly enforce-
able. The EPA has set emission limitations
for each pollutant to attain NAAQS. If the
actual air pollutant concentration in an air
di~trict exceeds the NAAQS, more-stringent
pollution-control devices on the emission
source are imposed to reduce the concen-
tration to an appropriate level. The EPA has
rated the AQCR as either "clean" or
"nonattainment" for each pollutant. Nonat-
tainment areas are those in which state and
federal ambient-air-quality standards have
not been met for the specified pollutant.
Procedures to bring the nonattainment areas
to attainment are implemented by SIP's. Ta-
ble 2 shows the current U.S. primary and
secondary ambient-air-quality standards.
Table 3 lists the California ambient-air-
quality standards.
A comparison of these standards indicates
that California air-quality standards gener-
ally are more stringent than, but not entirely
consistent with, federal standards. Local dis-
tricts such as the Kern County APCD, are
required to adopt the more-stringent federal
or state standards with respect to each pol-
lutant.
SIP's (42 USC 7410, Sec. 110). To imple-
ment the CAA, states are required to adopt
and submit to the EPA a SIP detailing the
basic strategies for implementation, main-
tenance, and enforcement of NAAQS within
the state. The SIP forms the blueprint for
achieving air-quality goals within a state.
The SIP provides the emission limitations,
schedules, and timetables for compliance by
stationary sources of air pollution such as
oilfield steam generators. The EPA must ap-
prove the SIP for each state. The SIP should
contain measures necessary for achieving the
primary and secondary standards. In setting
these measures, the state does not need to
consider their technical or economic feasi-
bility.
The SIP must ensure attainment of
NAAQS by prescribed dates. For example,
the EPA set Dec. 31, 1987, as the date by
which Kern County had to meet NAAQS.
The SIP must meet federal requirements, but
each state may choose its own mix of emis-
sions for stationary and mobile sources to
meet NAAQS. The CAA prohibits the adap-
tation of any SIP without a public hearing,
and the sources affected by the SIP are ex-
pected to participate. Requirements of SIP's
are contained in 42 USC, Secs. 7407(a) and
741O(a)(I).
Emission Limitations. The CAA has de-
veloped minimum technological standards
for various sources of air pollution. These
sources are divided into two groups: station-
ary and mobile sources. Because stationary
sources are the originators of pollutant in
thermal EOR operations, only stationary-
source standards are outlined here.
In establishing the framework for control-
ling emissions from stationary sources, the
CAA distinguishes between new and exist-
ing sources. Because it is typically less ex-
pensive for new emissions sources to
incorporate state-of-the-art control technol-
ogies, the regulatory burden falls more heav-
ily on the new sources. Existing sources are
regulated through the SIP. Each state must
develop a standard of performance for ex-
isting sources using EPA guidelines. If a
state fails to establish standards or if the state
standards are not acceptable to the EPA, the
EPA may promulgate its own standards.
To control the pollutants from new sta-
tionary sources, the CAA directs the EPA
to establish New Source Performance Stan-
dards (NSPS). The NSPS reflect the degree
of pollution control achievable through the
best available and adequately demonstrated
pollution-control techniques. In selecting the
best available control technology for each
pollutant, the EPA must take into account
the cost of achieving such emission reduc-
tion and energy requirements.
The EPA has delegated the authority to
implement and enforce NSPS to various

664 June 1991 • JPT

 TABLE 3-CALIFORNIA AMBIENT-AIR-QUALITY STANDARDS

Pollutant Aver!Qing Time Conoentration

Oxidant 1 hour 0.10 ppm
(200 I4g1m 3 )
co 12hollrs 10 ppm
(11 mglm 3 )
1 hour 40 ppm
(46 mgfm S )
N0 2 1 hour 0.25 ppm
(470I49lm3) "Federal environmental
S02 24 hours 0.05 ppm regulations and
(131 I49Im 3)
1 hour 0.5 pprri
standards supersede
(1310 l4g1m 3 ) all less-stringent state
Susp&:nded Annual geometrl~ mean 60I4g/ms and local regulations.
particulate matter
24 hours 10014g1m 3 State and local
Sulfates 24 hours. 25 p,g/m a governments, however,
lead 30 days 1.514g1m.3 can promulgate and
1-1 2 s 1 hourf 0.03 ppm enforce more-stringent
(42 ~g/m3)
Ethylene 8 hours 0.1i Ppm
environmental
1 hour 0.5. ppm standards than the
Visibility-reducing 1 observatl9n rh suffioient amount to r$duoe federal government."
particles ·the prevailing visibility to <30
miles when the relative
humidity is <70%.
Applicable only in the lake Tahoe Air Basin
co 8 hours I 6 ppm
. (7 mglm 3 )
Vlsibility,.reducing 1 observation to
in sufficient amount reduce
particles the prevailing viSibility to <30
mil&s when the relative
humidity is < 70%.

state and local agencies, although it always
retains independent enforcement authority.
Prevention of Significant Deterioration
(PSD) (42 USC 7470 et seq.). hi 1977, Con-
gress amended the CAA to prevent signifi-
cant future degradation of U.S. clean-air
areas. A clean-air area is one where the air
quality is better than the ambient primary
or 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 their SIP, emission
limitations and other measures necessary to
prevent significant deterioration of air qual-
ity with respect to designated pollutants (42
USC, 7473).
To implement this program, the CAA
divided clean-air areas into three groups.
This classification determines the increment
by which S02 and suspended particulates
may be increased in a given area. In Class
I areas, which include national parks and na-
tional wilderness areas, only a minor air-
quality degradation is permitted. Class II
areas, which include regions designated by
states as within national primary and secon-
dary ambient-air-quality standards, moder-
ate degradation is permitted. In Class III
areas, which include all other regions, sub-
stantial air-qUality degradation is permitted.
In no case does PSD permit air quality to
deteriorate below secondary air-qUality stan-
dards. Table 4 shows the permitted air-
quality increments for PSD.
"Increments" are the maximum amount
of deterioration that can occur in a clean-
air area over the baseline. "Baseline" is the
existing air quality for the area at the time
the first PSD is applied. hiorements in Class
I areas are smaller than those for Class II,
and Class II increments are smaller than
those for Class III areas. For the purpose
of PSD, a major emitting source is one that
falls into one of 26 designated categories and
whose potential emission rate is greater than.
100 tons/yr. Fossil-fuel-fired steam gener-
ators that have more than 250 million Btu/hr
heat input are in the PSD-designated
categories. In addition to the 26 PSD-
designated categories, an additional "catch-
all" category designates as a major pollu-
tant source one that emits more than 250
tonslyr of designated pollutant. PSD defines
the potential emission rate as the rate to be
expected without air-pollution-control
equipment.
Thermal EOR recovery operations are a
significant potential source of S02, NOx ,
and particulates (assuming clustering of boil-
ers). Most pollutants are emitted from crude-
oil-fired steam generators. Most oilfield
steam generators used in California and else-
where are smaller than 250 million Btulhr
and hence fall within the catch-all category .
These generators will be subject to PSD
review if their potential emission rate ex-
ceeds 250 tons/yr. Table 5 gives the typical
emissions from oil-fired steam generators of
different sizes burning 1.09%- sulfur fuel.
It can be seen that a thermal EOR operator
with two generators would be subject to PSD
for S02'
Nonattainment Areas (42 USC 7501 et
seq.). Nonattainment areas are those in
which the state and federal ambient-air-
quality standards have not been met for one
or more designated pollutants. For these
areas, the SIP must include plans to clean
up existing sources of emissions to achieve
attainment. New construction in a nonattain-
ment area is prohibited unless the SIP has
been amended and approved by the EPA.
Sources wishing to locate in nonattainment
areas must (1) show that the project will re-
sult in net air-quality benefits; (2) comply
with the lowest achievable emission rate
(LAER), a type of emission rate that reflects
the control technology available and the
emission limits required by law; (3) dem-
onstrate that all other sources owned by the
applicant within the state are in compliance
with all applicable emission limitations and
standards; and (4) obtain emission offsets
to achieve a net reduction in emissions. An
offset refers to the amount by which other
sources must reduce their emissions to al-
low for the amount to be produced by the

JPT • June 1991 665

new source, thus making room for devel-
opment.
To permit future new source construction
in nonattainment area, the EPA allows ex-
isting sources to save offsets. A saved off-
set can be sold or traded to other sources.
Best Available Control Technology for
Thermal EOR Pollutants. Thermal EOR
recovery operations subjected to PSD regu-
lations must use the best available control
technology (BACT) to achieve the maxi-
mum degree of reduction with respect to a
particular source of pollutants. BACT is a
pollution-control technique defined for
categories of equipment and takes into ac-
count energy, environmental, and econom-
ic effects along with other costs.
From a practical viewpoint, BACT can be
a costly issue when a new project is permit-
ted. Because BACT is defined for categories
of equipment, a district-imposed BACT for
a particular equipment may not have been
previously tried. Even if proven in practice,
BACT is often costly. In California, BACT
requirements vary with districts.
BACT's for major thermal EOR pollu-
tants are listed below.
S02' The EPA-approved BACT for the
control of S02 from oil-fired steam gener-
ators is fuel oil containing < 0.05 wt % sul-
fur or the equivalent rate achieved by
scrubbing.
NOr For NOx , the EPA requires a case-
by-case analysis. It maintains that BACT at
a minimum shall be a modification of burner
that will result in the lowest amount of oxy-
gen to be consumed for combustion. Cali-
fornia thermal EOR operators frequently
use 10w-NOx burners to control NO x
emissions.
Particulate Matter. BACT for particulate
matter has not been defmed. The EPA main-
tains that S02 scrubbers should satisfy the
BACT requirements for particulates because
the S02 scrubbers, although designed
primarily for S02 removal, also remove a
small percentage of particulate matter.
Particulate-matter emissions from oilfield
steam generators are small, and it would
take an average of nine or more 50-million-
Btu/hr units to produce more than 250
tons/yr.
LAER. Thermal EOR operators wishing to
locate in nonattainment areas must comply
with LAER. LAER for a particular pollu-
tant is the most-stringent emission limit for
the pollutant contained in the SIP's of the
TABLE 4-PERMITTED AIR-QUALITY INCREMENTS FOR
PREVENTION OF SIGNIFICANT DETERIORATION
Averaging
Pollutant Time
Total suspended particulate 1 year
; 24 hours
Lead 3 months
SOa 1 yea"
24hou1s
3 hours
NO x 1 year
00 8 hours
1 hour
Ozone 1 hour
U.S. In no instance can the LAER be perc
mitted to be less stringent than the amount
allowed under an applicable new-source per-
formance standard. Unlike BACT, the
LAER does not permit cost-effectiveness to
be taken into consideration. Thus, LAER is
more stringent than BACT.
In California, all areas of heavy thermal
EOR activities are designated as attainment
areas for the steam-generator pollutants
S02 and NOr However, the EPA has
designated the area around the Kern River
oil field as nonattainment for S02' Also in
Kern County, a small portion in the north-
ern area of Midway-Sunset oil field is con-
sidered a potential nonattainment area for
S02' Thus, operators wishing to locate in
the Kern River area must obtain LAER. If
the emissions after LAER are still more than
50 tons/yr, offsets are required.
New operators of thermal EOR activity
outside Kern River field proper, but in the
general vicinity (such as the Kern Front
field), must demonstrate that the concentra-
tions of S02 caused by sources do not ex-
ceed the significant levels in Kern River oil
field. If the emissions from the source are
< 50 tons/yr, no such demonstration is
needed.
The LAER for oil-fired steam generators
is considered to be 0.05 wt% sulfur in fuel
or the equivalent rate achieved by scrubbing.
This limit is based on technology achieva-
ble in practice for these types of sources.
LAER changes, however, and must reflect
the advances in technology and SIP require-
ments. As SIP requirements become more
stringent, LAER must reflect these changes.
Similarly, as scrubber technology advances,
LAER must also reflect these changes.
LAER for NO x is not considered a major
factor because the only nonattainment areas
for NOx in California are the South Coast
Air Quality inQrem$llts {eWm a~
Class I
--- Class ! Class lU,
51 19 37
10 37 75
None None None
2 I 20 40
5 I 91 182
25 512 700
None None Ndne
None None None;
None Nbne None
None None; None
air basin and western San Diego County air
basin. Thermal EOR activities in this area
are somewhat limited, and the operators are
using 10w-NOx burners for reductions in
NOr
1990 Amendments. The CAA amendments
of 1990, signed into law Nov. 15, 1990,
were the first major revisions of the CAA
since 1977. The act addresses several prob-
lems encountered in the 35-year history of
the CAA. The 1990 amendments made
several significant changes to the NAAQS
and revised the nonattainment programs.
The revision contains new requirements for
an area to qualify as an attainment or un-
classifiable area with respect to ozone, CO,
and particulate matters. The area classifica-
tion provisions of the 1990 amendments are
expected to result in redesignation of many
current attainment areas to nonattainment
areas. The impact of the 1990 CAA amend-
ments on thermal EOR sitings and opera-
tions will not become clear until well into
the decade, but is expected to be minimal.
The salient features of the 1990 CAA
amendments are summarized elsewhere. 1
California and District Air-Quality Re-
quirements. The California air-quality re-
quirements parallel CAA but are more
stringent than their federal counterparts. The
state air-quality laws can be found in State
Health and Safety Code Div. 26-Air
Resources. The ARB regulations are located
in Title 17 starting at Sec. 60000. In addi-
tion, the local APCD adopts its own rules
and regulations for the implementation of
stationary-source pollution control laws, in-
cluding permit systems, enforcement, pro-
hibitions, and other similar items. One law
(To Page 718)

Approximate Typical Yearly

Rated Output . Operating Schedule EmisSions (Ibmlbbl fuel) Emissions (tonslyr)
(10& Btulhr) ; (days) S02* N0 2 Particulate HC; S02' NO!? Particulate HC
5 16 365
--.-
7.2 2.5 0.7 0.1 21 10.3 2.9 0.43
10 50 292 7.2 2.5 0.7 0.1 52.6 18.3 I
5.1 0.73
20 115 292 7.2 2.5 0.7 0.1 120.9 42 11.8 1.60
50 210 292 7.2 2.5 0.7 0.1 220 76.7 21.S 3.07

• Assuming use of fuel containing 1.09wt% sulfur.

HC- hydfooWorn!.

666 June 1991 • JPT

 TABLE 6-COMPLIANCE DATES FOR
AIR TOXIC HOT SPOT INFORMATION
AND ASSESSMENT ACT
Amount Compliance
(tonslyr) Date Date
>25 July' 1, 1988 Aug. 1, 1989
10 to 25 July 1, 1988 Aug. 1, 1990
<10 July 1, 1988 1992
Environmental Aspects
of Heavy-Oil Recovery by
Thermal EOR Processes
(From Page 666)
that is specific to California and has signif-
icant effects on the operation of thermal
EOR facilities is the Air Toxic Hot Spot In-
formation and Assessment Act described in
the next section.
Toxic Air Contaminants. To control toxic
air contaminants, California adopted the Air
Toxic Hot Spot Information and Assessment
Act in 1987. The purpose of this law is to
prevent localized concentrations or "hot
spots" of air toxics. The law directs ARB
to identify toxic air contaminants and to
adopt meaSl'res to control the toxic air con-
taminants and requires ARB to prepare a list
of toxic substances that must be inventoried.
The air toxics in the ARB list of interest to
thermal EOR include S02, NOx ' and par-
ticulate matters.
The local AQMD is responsible for en-
forcing the toxic hot spot regulations with-
in a district. The toxic hot spot law requires
thermal EOR operators to provide detailed
inventories of NO x ' S02' and particulate
matter emissions from their facilities to the
local district. The compliance date for
providing the detailed plan on preparing the
toxic emissions inventory depends on the
amount, as shown in Table 6.
The plan must be submitted to the local
districts and meet the ARB guidelines, as
well as any additional guidelines established
by the local district. The district must review
and approve the plan within 120 days of sub-
mittal. The operator then has 180 days to
implement the plan and to submit the de-
tailed inventory. The district will then
review the inventories submitted by the
operator and place them in a high-priority,
medium-priority, or low-priority category.
The prioritization of the sources is done
in consultation with ARB and DHS and con-
siders the nature and amount of toxics and
the proximity to schools, hospitals, day care
centers, residences, and similar facilities.
Facilities designated as high priority must
submit a risk assessment within 150 days of
the category designation. The risk assess-
ment must be comprehensive and should in-
clude, among other things, community-wide
exposure risks and dispersion predictions.
The Kern County APCD on Nov. 29,
1990, released its first toxic hot spot list. 2
This list included 10 thermal EOR opera-
tors with steam EOR activity centered in
Kern County. The list ranked these opera-
718
"Stringent limitations are placed on the disposal
of produced water In unlined pits."
tors anywhere from high to low, based on
their emission amount.
Water.Quallty Regulations
This section summarizes the major water-
quality laws that affect thermal EOR oper-
ations. These include the Clean Water Act
(CWA), the Safe Drinking Water Act
(SDWA) and Underground Injection Con-
trol (UIC) Program, Toxic Substances Con-
trol Act, spill prevention regulations, and
regulations governing the handling, storage,
and disposal of oilfield waste waters.
Federal CW A. The objective of the CWA
is to restore and maintain the chemical,
physical, and biological integrity ofthe na-
tion's water. The EPA has nationwide
authority to promulgate regulations and to
implement the CWA.
To achieve its stated objectives, the CWA
set effluent standards to limit discharges
from point and nonpoint sources and estab-
lished ambient standards to maintain the
quality of surface waters. The CWA can be
found in 33 USC starting at Sec. 1251. The
EPA regulations are found in 40 CFR Sub-
chap. D-Water Programs.
Thermal EOR effluent guidelines are en-
forced through the Nat!. Pollution Discharge
Elimination System (NPDES). To receive
a discharge permit, a thermal EOR opera-
tor must comply with all applicable effluent
limitations for the particular discharge.
NPDES's are effective for terms not exceed-
ing 5 years. The NPDES permit is issued
by the EPA or by a state with a certified
CW A program. California has received
authority from the EPA to administer the
NPDES permit program. The state's
RWQCB's generally issue the NPDES per-
mits in conjunction with the state permit,
which is called the Waste Discharge Re-
quirements.
SDWA. The SDWA has two primary ob-
jectives: protection of public water supply
systems and protection of underground
drinking water sources. To accomplish these
objectives, EPA has established Nat!.
Primary Drinking Water Regulations to pro-
tect public health (40 CFR, Part 141) and
state UIC program regulations (40 CFR,
Parts 144-149). The Nat!. Primary Drink-
ing Water Regulations establish maximum
contaminant levels for possible physical,
chemical, microbiological, and radiological
pollutants in public water systems. The UIC
regulations of SDWA require states to es-
tablish UIC waste disposal programs to pre-
vent underground injection activities that
endanger drinking-water resources. Under
the federal scheme, injection wells related
to oil and gas production are classified as
Class II wells.
Miscellaneous Regulations Governing Oil
and Gas Waste Waters. These regulations
enforced by the U.S. Dept. of Interior
govern the handling, storage, and disposal
practices of waste waters from thermal EOR
fields located on U.S. and Indian lease lands.
These regulations required that by Oct. 1,
1977, the waste waters produced in oil and
gas recovery operations be disposed of only
by subsurface injection, impoundment in
lined pits, or other acceptable methods.
Stringent limitations are placed on the dis-
posal of produced water in unlined pits.
Monitoring requirements are established for
disposal to both lined and unlined pits. Mon-
itoring activities for water impounded in
lined pits are to include daily measurements
of chloride, sulfate, and other constituents
that are potentially toxic to animal, plant,
and aquatic life.
Spill Prevention Regulations. The EPA has
established regulations to prevent discharge
of oil and oil products into or upon the
navigable U.S. waters. These regulations re-
quire the development of spill prevention
control. As far as thermal EOR operations
are concerned, the practice of on-site mix-
ing or storage of oil-related substances is af-
fected by these regulations. To ensure
compliance with these regulations, surface-
water monitoring during rainstorms, as well
as during and immediately following any
discharge of retained waters into surface
water bodies, is required.
California Water-Quality Regulations.
Through a network of nine RWQCB's,
California implements the provision of the
CWA and state laws regarding water quali-
ty. The RWQCB also implements provisions
regarding discharge of wastes onto lands and
sets requirements for the disposal of wastes
in situations where the waste has the poten-
tial to contaminate groundwater.
The RWQCB prohibits the discharge of
waste water from steam generators to sur-
face waters. It permits, however, the dis-
posal of the waste either by reinjection into
the same well formation or by discharge into
sumps, holding ponds, etc. If reinjection is
to be used for discharge, the thermal EOR
operator must obtain a permit from the state
Div. of Oil & Gas (DOG). The RWQCB
will then be involved to the extent that they
will comment on DOG's action.
June 1991 • JPT
 When an operator wishes to discharge
waste into sumps or into a percolation pond,
a permit from RWQCB is required. In
general, discharges to these types of ponds
are allowed only when the groundwater is
already of poor quality. In essence, the role
of RWQCB is to ensure that such discharges
are in compliance with an area's "ground-
water objectives." Each regional board is
responsible for developing a water-quality
plan. The board examines the groundwater
quality of the area under its jurisdiction and
sets effluent limits that ensure that the
groundwater-quality objectives of the area
are met. Thus, such limits vary from field
to field.
In central Kern County near Bakersfield,
discharge to percolation ponds is prohibit-
ed because of the abundance of freshwater
aquifers. In western Kern County, however,
discharge to a percolation pond is permit-
ted in various fields. Effluent limits vary
from field to field. In some areas, such as
Midway-Sunset field, the groundwater qual-
ity is so poor that no effluent limits are set
for the discharge of water. In other areas,
however, such as the anticline region, ef-
fluent limitations are set. As mentioned
above, such determinations are made on a
case-by-case basis and depend on the
groundwater quality in each area.
Compliance Requirements of Thermal
EOR Operations With the DOG. Most
thermal EOR operators in California dis-
charge waste water by underground injec-
tion into the same well formation from
which water is extracted. Such reinjection
operations are subject to DOG permit re-
quirements. No NPDES permit is required.
The RWQCB's involvement would then be
limited to concurrent review with the DOG
to ensure that no damage to groundwater
occurs.
The DOG bases approval of reinjection
on whether the groundwater table will be
contaminated. This determination is based
on the quality of the water to be discharged
and the quality of the water in the aquifer
that will receive the discharge. If the water
in the receiving aquifer is of comparable or
worse quality than the water to be dis-
charged, then no contaminant danger exists
and discharge would be allowed. If this is
not the case, then reinjection would not be
allowed. In such cases, an aquifer with com-
parable or worse water quality would have
to be located to allow discharge.
Where scrubbers are used for S02
removal, disposal of scrubber water may
pose problems because the quality of scrub-
ber water is usually much worse than the
aquifer from which the process water origi-
nated. Reinjection of scrubber water into the
formation is prohibited in most areas. Scrub-
ber water frequently is reinjected into the
formation in San Luis Obispo County,
where the quality of aquifer water is com-
parable with scrubber-water quality. In Kern
County, scrubber waste is removed to a
designated injection site. Table 7 shows the
JPT • June 1991
typical chemical composition of waste water
associated with thermal operations.
Classification of Injection Wells in
California. In California, wells injecting
only fIlter backwash or fIlter backwash com-
mingled with produced water are classified
as Class II wells. Wells injecting water-
softener regeneration brine or air scrubber
wastes into an oil-producing formation are
also classified as Class II wells. On the other
hand, wells injecting water-softener regener-
ation brine or scrubber liquor into a non-
oil-producing formation are classified as
Class I or Class V wells. This classification
depends on the toxicity of the injected fluid.
Injection into Class II wells is regulated by
DOG and injection into other wells is regu-
lated by the EPA.
Waste.Management Regulations
This section summarizes the federal and
state waste-management regulations that af-
fect thermal EOR operations. The principal
U.S. law that provides the framework for
managing waste is the RCRA.
RCRA (42 USC Secs. 6901-6099K).
Among the objectives of RCRA are the pro-
visions for the. safe disposal of discarded
materials and the regulations for the
management of hazardous wastes. The EPA
is the primary agency that administers the
provisions of RCRA. The act required the
EPA to prepare guidelines for the effective
management of solid waste. The term "solid
waste" is defined broadly to include gar-
bage, refuse, and other discarded materials
and includes solid, liquid, and gaseous ma-
terials.
The disposal practices for these wastes are
to be such as to protect public health and
welfare and to prevent deterioration, as re-
quired by other federal laws. This includes
protection of the surface and groundwater
quality from leaching and runoff, protection
of ambient air quality, disease and vector
control, safety, and aesthetics. Many states
implement their own solid-waste programs.
Most oilfield wastes were exempted from
classification as hazardous waste by the EPA
in 1988.
California Waste Management Program.
The waste-management regulations under
California Water Resources Board Title 23,
Chap. 3, Subchap. 15, governs land waste-
disposal requirements. These regulations es-
tablish a statewide disposal-site and waste
classification system. The classification of
disposal sites is based on the geologic and
hydrologic features of the disposal area and
the capability for protection of surface and
groundwater qUality.
The wastes from thermal EOR sites in
California are categorized into two types:
(1) nonhazardous wastes, which include
construction and demolition materials, aban-
doned equipment, rubbish, and garbage, and
(2) hazardous wastes, which include oilfield
brines, spent cleaning fluids, spent washing
TABLE 7-TYPICAL CHEMICAL
COMPOSITION OF WASTE WATERS
FROM THERMAL OPERATIONS
Concentration
(ppm)
Boron 20.8
. OtlJ.Qium 11.2
, MagneSIum (M3
S~ium 53,00Q
..' POlassium 10:1
0
Carbonate 'i"
irate ... 31.183
~i237.3
Sulfate 79913
Nitrate , O~5
Fluoride &.2
tron)::, 32.S), .
Copper 0.5
. ~~~ane~} 0~63
5:3
0.4
loum
420
Total dis$Olved souci' 1~,438'
. Phosphate ... ' 0;6
liquids, chemicals, acids, alkalis, drilling
fluids and mud (if they contain a hazardous
material), tank-bottom sediments, tank-
cleaning sludges, and scrubber wastes. The
nonhazardous wastes from thermal EOR
sites are disposed of in Class II disposal sites
within Kern County and are not of much en-
vironmental concern. Hazardous wastes are
disposed of at a Class I disposal site, which
requires complete protection for the quali-
ty of surface and groundwaters. Class I sites
are certified by the SWRCB. The SWRCB
require that Class I sites provide protection
for the active life of the site, and all runoff
from Class I waste-disposal sites must be
contained.
Enforcement of California laws relating
to hazardous wastes and Class I sites falls
under the jurisdiction of the California Dept.
of Public Health and the SWRCB. Accord-
ing to the State Health and Safety Code, Sec.
25100-25185, the Dept. of Public Health is
required to adopt regulations for handling,
processing, and disposal of hazardous
wastes to protect against hazards to public
health, to domestic livestock, and to wild-
life. It is unlawful to dispose of any such
waste except as provided for in such regu-
lations. The California Administrative Code
and the State Water Code give the SWRCB
the authority to specify the solid-waste
disposal-site requirements.
Nolse.Quality Regulations
The U.S. Noise Control Act (42 USC Sec.
4901 et seq.) authorizes the EPA to set am-
bient noise-quality criteria. The EPA re-
quires that noise from the operation of one
or more pieces of equipment not exceed a
given value. This value depends on demo-
graphic characteristics of the land surround-
ing the EOR site.
Noise associated with thermal EOR activi-
ties arises from site-preparation activities
and field-test activities. The site-preparation
activities include those associated with the
drilling of observation wells, workover of
719

Activity. _-=E::.:!q~uj:;;..pm.:...e.:...n_t_,.O~fing Time! (tiour$)
Working over 350-hp diesel
e~!Dg~ectlon::~!ingine to
and production ····ope,rate rig
w~ls
Drilling ob$erv$fio~ 250-hp dieseI
wells .. '. engine to operate
ayger drill. .
Site preparation Dozers (3)500 hr/dOzer'{'·1.500·A'~
. Loaders (4) .. 500 hr/Ioader . 2;000
Tractors (4)\~0 h~~actor
TranspOrtation of Heavy-duty 'trucks
material and (10)
.p~t
Gene.:aJ MiseelianeouS"
'Total susil8ndedparticulates.
existing wells, and movement of heavy-duty
vehicles used in the operation of several
major pieces of equipment. The typical
pieces of equipment include crawler trac-
tors, air compressors, diesel generators,
pumps, and heavy trucks. Noise associated
with field-test activities arises primarily
from the operation of steam generators for
steamflood and air compressors for fire-
floods.
Because most thermal EOR fields are in
rural areas, compliance with noise require-
ments is not considered a major environmen-
tal issue.
Thermal·EOR Pollution Sources
In this section, the source and type of pol-
lutant likely to be generated in a typical ther-
mal EOR production field are identified.
The potential emission/effluents are de-
scribed for the environmental parameters of
air quality, water quality, and waste
management.
Air Quality. In a typical thermal EOR field,
air emissions occur during site preparation
and field operations. Air emissions evi-
denced during site-preparation facilities con-
sist primarily of CO, hydrocarbons, N0 2 ,
S02, and suspended particulates. In addi-
tion, uncontrolled fugitive dust emissions
occur in areas of land disturbances caused
by drilling, bulldozing, etc. The magnitude
of the fugitive emissions depends on the time
of year, the methods of construction, the size
of the area disturbed, and the type of con-
trol measure. Table 8 shows estimates of
uncontrolled emissions from all equipment
used in the field during the site-preparation
phase.
Air-pollutant emissions generated during
a typical thermal EOR field activity include
those emanating from steam generators,
internal-combustion compressors for fire-
flood, and wellheads. The only significant
emissions to the atmosphere from steam
generation and combustion equipment in
normal operation result from the burning of
720
....: ,;Jot~, Ti!'l\~ _--==~
1.600
1500 hr/truck 15,000
400 hours 4,000
fossil fuels. Most steam generators used in
California are at about 50 million Btu/hr of
heat input. Most steam generation activity
occurs in Kern and Fresno counties. Other
counties in which thermal EOR activity is
implemented include Monterey, Santa Bar-
bara, and to a lesser extent, San Luis
Obispo, Orange, and Los Angeles. In-situ
combustion operations are confmed to Kern
and Orange Counties in California. Steam
generators produce S02, NOx , and partic-
ulates. Additionally, small amounts of un-
burned hydrocarbons and traces of CO also
are emitted. On-site storage tanks and wells
to be steamed also emit hydrocarbons.
Among these, S02 is of critical concern be-
cause of the stringent federal, state, and lo-
cal regulations limiting its legal emission
leveL Table 5 lists the typical emission rates
for all pollutants expected for different sizes
of generators. For this computation, it is
assumed that the steam generator will use
a fuel containing 1.09 wt% sulfur.
In the in-situ combustion process, com-
pressed air is injected into a 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 of the produced gas using samples
collected at 31 in-sitl.l-combustion test sites.
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
affect 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 effluents.
These waste effluents include those gener-
ated by site-preparation activities, such as
drilling and well workovers, and effluent
from production wells. Storm water runoff
from construction areas can affect the qual-
ity of local surface waters. Runoff from con-
~ " .;:,' h;'~:
(x'6~1.1lJj':.;;\O..O.12 .
- 1.56 0.19 2.400.iltO.17
1.72 0.12 <p.80 O.07':,f;'l
'V):~
13.50 125 22:~:'
'1
0.82 0.32 4.60 9.•':6~8
Compound
OOz
, CO'"
, Nittogen and NOlC t
Oxygen I
rtydrocafllQr~"
struction sites may include clay and silt
particles, inorganic and organic matter from
decayed vegetation and soil, oil from paved
areas, and oil and grease from construction
equipment.
Local groundwater quality can be affect-
ed by thermal EOR wastewater effluent dis-
posal activities. Some of these potential
problems are (1) seepage of injected or rein-
jected materials through the formation into
underground aquifers, (2) leaching from un-
lined waste-disposal pits, (3) accidental sur-
face spills during storage and transport of
waste effluents, and (4) secondary fractures
that may connect 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
EOR process generates wastes during both
the site-preparation and field-testing phases.
The wastes produced from site preparation
activities include clay, silt, and dust parti-
June 1991 • JPT
cles, organic and inorganic matter from
decayed vegetation, drilling wastes such as
mud and brines, and oil and grease from
construction machinery. The first two types
of wastes are disposed of by landfill and are
of no environmental conceru. Drilling
wastes and oilfield brines, because of their
potential damage to the local water and
ecosystem, require careful handling and
must be disposed of in state-approved sites.
The wastes generated from field opera-
tions activities include sludge produced 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 surface waters.
2. Scrubber sludges are difficult and cost-
ly to dispose of and are a potential source
of contamination of local surface and sub-
surface water at the disposal site.
3. Oily wastes are collected separately and
are 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 in the U.S. have been
identified and evaluated from federal, state,
and local regulatory viewpoints. Various
federal, state, and local environmental agen-
cies were contacted to obtain the desired in-
formation. The following conclusions have
been derived.
1. Environmental regulations pertaining
to ambient air quality and groundwater qual-
ity greatly affect the growth of the thermal
EOR process.
2. Current regulations are sufficient for
controlling noise pollution.
3. Environmental issues such as solid- and
liquid-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 of the U.S.
DOE and A. Strycker, M. Madden, and
M.K. Tham of the Natl. Inst. for Petrole-
um & Energy Research for their helpful sug-
gestions.
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1111,.....18 laralM,is
a refta"h e",l-
neer,ln the, Et:lergy
Production Re-
search Dept. of the
NatI.IMt. for Petro-
leum Be Energy Reo
ftarch(NIPER) In
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8efcn.)otn1l'lg NIPER
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sociated With the Commercialization of En-
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presented at the 1981 SPE/DOE Symposium on
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SI Metric Conversion Factors
bbl x 1.589 873 E-OI = m'
Btu x 1.055 056 E+OO = kJ
OF (OF - 32)/1.8 = °C
hp x 7,460 43 E-OI = kW
Ibm x 4.535 924 E-Ol = kg
miles x 1.609 344* E+OO = km
tons X 9.071 847 E-Ol = Mg
• Conversion factor is exact.
Provenance
Original SPE manuscript, Environmental
Aspects of Heavy-Oil Recovery by Ther-
mal EOR Processes, received for review
Jan. 21, 1991. Paper accepted for publica-
tion March 21, 1991. Revised manuscript
received March 20, 1991. Paper (SPE
21768) first presented at the 1991 SPE
Western Regional Meeting held in Long
Beach, March 20-22.
JPT
721