United States
Environmental Protection
Agency
Energy, Minerals and Industry
Office of
Research and Development
Washington D.C. 20460
EPA 600/9-79-020
June 1979
The Federal Nonnuclear
Research and Development
Act (Public Law 93-577)
Section 11,
Environmental Evaluation
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United States Office of EPA 600/9-79-020
Environmental Protection Research and Development June 1979
Agency Washington D.C. 20460
Energy, Minerals and Industry
v>EPA The Federal Nonnuclear
Research and Development
Act (Public Law 93-577)
Section 11,
Environmental Evaluation
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TABLE OF CONTENTS
Page No.
Glossary
Executive Summary
SECTION I.
SECTION II.
SECTION III.
SECTION IV.
REFERENCES
vn
OVERVIEW AND FOCUS OF SECTION 11 ACTIVITIES 1
DOE ENVIRONMENTAL PLANNING AND ASSESSMENT PROCESS FOR
TECHNOLOGY RESEARCH, DEVELOPMENT AND DEMONSTRATION 5
A. Introduction 5
B. Program and Project Management System 5
C. Environmental Planning and Review 6
D. Energy System Acquisition Projects 10
E. Energy System Acquisition Advisory Board 10
F. Environmental Planning and Assessment Process 12
PRELIMINARY FINDINGS CONCERNING THE ENVIRONMENTAL
PLANNING AND ASSESSMENT PROCESS 15
A. Introduction 15
B. Environmental Planning and Review and Technology Decisions 15
C. Procedural Aspects of the Environmental Review Process 16
D. Public Participation 17
CASE STUDY: DOE's ENVIRONMENTAL PLANNING AND ASSESSMENT
PROCESS FOR GEOTHERMAL ENERGY 19
A. Evaluation Criteria 19
B. Background: Technology and Environmental Concerns 19
C. Evaluation of the Environmental Planning and Assessment Process
for Geothermal Energy 20
27
in
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Table 1.
Table 2.
Table 3.
Table 4.
TABLES
Program and Project Management System for
DOE Outlay Programs
Page No.
DOE Major Systems 8
Overview of Major DOE Environmental Planning
and Review Documents 11
Major Geothermal Environmental Concerns and
Control Technologies 21
Figure 1.
Figure 2.
Figure 3.
Figure 4.
Figure 5.
Figure 6.
FIGURES
Overview of 1979 Section 11 Activities 2
Department of Energy Organization and Functions 29
Department of Energy Field Organization 31
DOE Office of Environmental Organization and Functions 3
Major System Acquisitions—Phase Transition Decision Points 7
Relationship of DOE Environmental Planning System to
PPMS Major System Acquisiton 9
IV
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GLOSSARY
ASEV
CEQ
CS
DOE
EA
ECC
EDP
EIS
EPA
ERD
ESAAB
ESAPP
ET
EV
GRIPS
IVEP
KGRA
NEPA
PPMS
RA
Assistant Secretary for Environment
Council on Environmental Quality
Office of Conservation and Solar Applications
Department of Energy
Environmental Assessment
Environmental Coordinating Committee
Environmental Development Plan
Environmental Impact Statement
Environmental Protection Agency
Environmental Readiness Document
Energy Systems Acquisition Advisory Board
Energy System Acquisition Project Plan
Office of Energy Technology
Office of Environment
Geothermal Resource Impacts Projection Study
Imperial Valley Environmental Project
Known Geothermal Resource Area
National Environmental Policy Act
Program and Project Management System
Office of Resource Applications
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EXECUTIVE SUMMARY
The Federal Nonnuclear Energy Research and Development Act (PL 93-577) was passed in December 1974 as part
of the national response to the effects of the 1973 Arab Oil Embargo. The purpose of the legislation was to establish
and carry out a comprehensive national program promoting research, development and demonstration (RD&D) of
nonnuclear energy technologies. Section 11 of PL 93-577 directed the Council on Environmental Quality (CEQ) to
hold annual public hearings and prepare appropriate reports on "... the adequacy of attention to energy conserva-
tion methods and environmental protection . . . and the environmental consequences of the application of energy
technologies."
In addition to ensuring that an environmental evaluation was built into the national program on nonnuclear RD&D,
Section 11 also provides an opportunity for public participation in this evaluation.
In late 1977, President Carter's Executive Reorganization Plan (77-1), transferred the Section 11 responsibility from
CEQ to the Environmental Protection Agency (EPA). The Office of Energy, Minerals and Industry within EPA's
Office of Research and Development was assigned the task of conducting the Section 11 activities.
This report is the first of a series associated with the 1979 Section 11 Program. In order to evaluate the adequacy of
attention given to environmental concerns, the 1979 Section 11 program will examine the Department of Energy's
Program and Project Management System (PPMS) for determining research, development, demonstration, and com-
mercialization investments. This examination focuses on the role played by the Environmental Research Planning and
Assessment Process for determining the environmental and health consequences of energy technology RD&D. To pro-
vide a technology-specific analysis of the process, six technologies—including: geothermal, cogeneration, urban waste
utilization, oil shale, coal gasification and coal liquefaction—were chosen for detailed study.
The report then raises pertinent issues relating to this process, including preliminary findings on strengths,
weaknesses and areas for improvements. It includes a case study of the integration of geothermal energy development
within the Process. DOE regards geothermal energy development as an example of the effective use of public involve-
ment on a local level.
The DOE's research and development programs are organized around general energy technologies (such as nuclear,
fossil, solar and geothermal) and are designed to move the development of these technologies through sequential
phases from basic research through commercialization. Development activities are divided into two stages — each
consisting of several phases. The first, the technology based stage, comprises both a basic and an applied research
phase, followed by an exploratory development phase. The second stage, energy systems acquisition, covers four
phases: technology development, engineering development, demonstration, and commercialization. For nonnuclear
energy technologies such as the fossil energy program, the Office of Energy Research has responsibility for guiding
technologies from the basic research phase to the exploratory development phase. The Office of Energy Technology
then assumes the responsibility for the technology from the technology development phase through demonstration.
Finally, the Office of Resource Application moves the project through commercialization. The process differs when
applied to solar projects in that one office, the Office of Solar and Conservation Applications, guides the project from
development to final commercialization.
In early 1978 DOE formulated an internal Program and Project Management System (PPMS) to guide the commit-
ment of expenditures (Outlay Programs) for technologies through the various development phases. The Outlay Pro-
gram Plans consist of two components—Technology Program Plans (TPP) and Environmental Development Plans
(EDP). The objective of the TPP is to define a development strategy for a project or group of projects of the same
technology moving through the development phases. The EDP will then identify and integrate required environmen-
tal, safety and health research within the appropriate phases of the technology project or projects. As site-specific
technology projects are delineated, separate Project Environmental Plans (PEP) detailing necessary environmental
research for each project are jointly prepared by the DOE Office of Environment and the appropriate program office.
In the summer of 1978, as part of the DOE Commercialization Task Force Study, program offices screened can-
didate technologies for near term commercialization. A component in the screening process was the Environmental
Readiness Document (ERD), an independent assessment prepared by the DOE Office of Environment to determine
the "readiness" of the technology for commercialization. Now integrated within the PPMS, the ERD supports the
Office of Environment's position determining the environmental acceptability of a DOE technology program or proj-
ect at each development phase.
vii
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The combination of the three Environmental Research Planning and Assessment Documents (EDP/PEP/ERD)
coupled with a formal management structure for their preparation and implementation, comprise the DOE
Environmental Planning and Assessment Process for technology RD&D. Although this process is designed to insure
that environmental concerns are integrated into DOE decision-making at each phase of the development of energy
technologies, none of the documents specifically address alternative actions or projects. While the outputs from this
process are not intended to be part of the formal National Environmental Policy Act requirements, they are perceived
as building blocks leading to the preparation of Environmental Impact Statements (EISs).
Three factors limit the conclusions that can be drawn regarding the effectiveness of the DOE Environmental
Research Planning and Assessment Process: (1) A Departmental Order has not yet been developed for PPMS. (It is still
operated by an Interim Guidance and Policy Statement issued in May, 1978. A separate DOE order for Environmental
Development Plans was issued before PPMS was fully implemented and does not mention the EDP as a specific part
of the PPMS review process.) (2) Neither the Program Planning and Management System nor the environmental pro-
cess were fully operational until late 1978. (3) Only a single nonnuclear technology project (the 50 megawatt geother-
mal pilot plant in Baca, New Mexico) has been through a formal PPMS review.
In examining the Environmental Planning and Assessment Process, several relative strengths and weaknesses can be
identified:
• Key elements of an effective management system are present in this process.
• Process documentation for a significant number of energy technologies is available.
• Environmental planning and review requirements are conceptually integrated into the technology planning
process.
On the other hand, there are several shortcomings in the process:
• A lack of a formal, regular and systematic exchange of research results between researchers and technology
development planners.
• An inability to identify research results associated with environmental planning.
• Unresolved issues with respect to the content and frequency of updates for EDPs and ERDs.
Public Participation In This Process
It is critical that the public be involved in the planning and decision-making processes associated with emerging
energy technologies. The following issues are raised:
• What is the most effective way to keep the public informed?
• How can DOE's internal management process for environmental research planning and assessment be modified
to include opportunities for the public to participate effectively in the process?
Case Study: Geothermal And The Process
Findings related to how the Environmental Planning and Assessment Process functioned in the case of geothermal
energy are presented.
Vlll
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I. OVERVIEW AND FOCUS OF SECTION 11 ACTIVITIES
Section 11 of the Nonnuclear Energy Research and Development Act of 1974 calls for an ongoing review of the
Federal Nonnuclear Energy Research and Development Program to evaluate the adequacy of attention given to energy
conservation and environmental protection measures.
Since 1975 when the CEQ first conducted Section 11 Public Hearings, there has been an expression of public con-
cern over a lack of understanding of the way in which environmental considerations are brought into the energy
technology decision-making process.
During the 1978 Section 11 public hearings, this concern was focused on the Department of Energy. Witnesses
expressed:
• a lack of understanding of the DOE's decision-making process and the manner in which environmental
considerations were brought into the process.
• a sense of frustration at their inability to become effectively involved in the process; and
• a lack of credibility resulting from their being unable to review decisions concerning emerging energy
technologies.
In response to last year's testimony, the 1979 Section 11 review will focus on the DOE Environmental Planning and
Assessment Process for determining the environmental and health consequences of energy technology RD&D. Par-
ticular emphasis will be given to the current and potential effectiveness of the process, and the opportunities that could
be provided for ongoing and interactive public involvement.
This year a Report to Congress will be submitted based upon an analysis of the management process for six emerg-
ing technologies and also upon the discussion concerning this process at a series of regional workshops and a national
public hearing. Figure 1 provides an overview of the various Section 11 activities scheduled for 1979.
As background material, a general introduction to the organization and functions of DOE, its Field Organization,
and the Office of Environment—Figures 2 through 4—are included.
Section II of this report describes the DOE Environmental Planning and Assessment Process for energy technology
RD&D. The relationship of the process to the principal DOE management system for the development, approval and
execution of budgetary expenditures for technology programs is also described. Much of the descriptive material is
excerpted from DOE management documents.
Section III presents preliminary findings regarding the effectiveness of the environmental process. Some of the
relative strengths, weaknesses, and the opportunities provided for public participation are reviewed. A series of ques-
tions are raised that will serve as a focus for continuing analysis under the Section 11 legislative mandate and as poten-
tial issues for public discussion at the workshops and hearing.
Section IV provides a case study (Geothermal Energy) to permit a review of the effectiveness of the Environmental
Planning Process. A full complement of process documentation (EDP/ERD/PEP) has been completed for this energy
technology, and it is considered by DOE to be a successful example of how to involve local concerned parties in its
environmental management process.
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FIGURE 1. OVERVIEW OF 1979 SECTION 11 ACTIVITIES
REPORTS/EVENTS
1979
MAY JUNE JULY AUGUST SEPTEMBER OCTOBER NOVEMBER DECEMBER
1980
JANUARY
Report: Overview of DOE Environmental Planning
and Assessment Process
Six Issue Papers: To Raise Process Issues and
Focus Workshops
Geothermal
Coal Liquefaction
Coal Gasification
Oil Shale
Cogeneration
Urban Waste
Regional Public Workshops:
• Cogeneration and Urban Waste
• Oil Shale
• Geothermal
• Coal Gasification and Liquefaction
Pre-Hearing Document: Summarize Regional Workshops,
Present Issues For Discussion
At Public Hearings
National Public Hearings
Hearing Transcript & Summary Document
Report to Congress:
15
, To Be Distributed
^ June 15-30
A July 12, Atlanta
A July 18, Denver
A July 24, San Francisco
A July 31, Pittsburgh
A September 7
A October 3-5, Washington, D.C.
A
December 10
A
January 30
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FIGURE 4. DOE OFFICE OF ENVIRONMENT ORGANIZATION AND FUNCTIONS
OFFICE OF
MANAGEMENT SUPPORT
coordinates, implements and
overviews the EV management
and financial functions
OFFICE OF
ENVIRONMENTAL COMPLIANCE
AND OVERVIEW
assures that the Department facil-
ities and operations are in compliance
with DOE operational policies and
applicable Federal, State, and local
environmental, health and safety
regulations and policies
ASSISTANT SECRETARY
FOR ENVIRONMENT
develops policy and issuing guidance
to assure Department-wide compliance
with environmental, health and safety
plans, regulations and procedures.
OFFICE OF
PROGRAM COORDINATION
provides advice and policy
guidance on matters relating
to EV planning and
analysis,coordination
and integration
OFFICE OF
TECHNOLOGY
IMPACTS
analyzes and coordinates
the development of
departmental environmental
policy guidance
prepares environmental
research planning and
assessment process
documentation
OFFICE OF
HEALTH AND
ENVIRONMENTAL RESEARCH
plans, manages and assesses
EV research programs on
the environmental, health
and safety aspects of
energy technologies and programs
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II. DOE ENVIRONMENTAL PLANNING AND ASSESSMENT PROCESS
FOR TECHNOLOGY RESEARCH, DEVELOPMENT, AND DEMONSTRATION
A. Introduction
The Department of Energy (DOE) was established on October 1, 1977 to bring together the various energy activities
dispersed throughout the Federal government and to provide unified leadership to the Nation's energy policies and
programs. The Department has developed both a National Energy Program and an organization to oversee its execu-
tion.
A primary mission of the Department of Energy (DOE) is to implement the objectives of the National Energy Plans
by developing and commercializing energy technologies that are economically practical, technically feasible, and
environmentally acceptable. In carrying out its mission, DOE has responsibility for a number of programs, including
the development of oil and gas regulatory pricing, power marketing and transmission, weapons production, and
nuclear and nonnuclear technology research, development, and demonstration (RD&D).
This report deals with the nonnuclear technology RD&D aspects of DOE's programs. More specifically, the focus
will be on the environmental planning and review conducted within nonnuclear technology RD&D programs and
projects.
Program offices such as the Office of Energy Technology or the Office of Conservation and Solar Applications are
the units within DOE that determine technology research objectives. This is achieved through RD&D plans that
outline technical activities and allocate budget resources for energy systems. The plans are goal-oriented descriptions
of specific technical, environmental, and economic activities that are necessary to achieve energy development.
B. Program and Project Management System
The Program and Project Management System (PPMS) is the principal DOE management system that governs the
development, approval, and execution of DOE's outlay (budgetary) programs. (See Table 1.)
TABLE 1
PROGRAM AND PROJECT MANAGEMENT SYSTEM
FOR DOE OUTLAY PROGRAMS*
Interim Policy and Guidance
Objectives of the Management System
• Insure that all major programs are developed with clear operational, time-phased objectives (multi-year to relate
to current budget process).
• Insure that all significant projects and activities have clear sub-objectives that relate to program objectives.
• Relate program/project and activity objectives to National Energy Act (NBA), National Energy Plan (NEP) and
related plans and legislation, where possible.
• Provide for determining priorities among programs and projects, and, in turn, relate these to various levels of
resource availability.
• Avoid commitment of major resources prior to adequate project definition.
• Provide key program and project managers with a clear view of related program and project objectives and
plans.
• Provide visibility on all key decisions and timely feedback for all levels of management.
• Maintain accountability through all levels of the organization with a minimal amount of procedure and
paperwork.
*From Under Secretary Myers Memorandum May 31, 1978, "Program and Project Management System for DOE
Outlay Programs."
5
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PPMS was formulated in early 1978 under the direction of the Under Secretary, Dale Myers, and was first used in
Fiscal Year 1980 DOE budget development. The basic purpose of PPMS is to fully define and review projects before
any commitment of major resources occurs and to ensure that all major programs are developed with clear, opera-
tional, multiyear objectives that are in phase with budget processes. PPMS was designed to incorporate a systematic
review of every major energy system acquisition (program and project) at specifically defined transition points in their
development (Figure 5).
"Major system acquisition" is a budgetary definition formulated by the Office of Management and Budget (Cir-
cular A-109, April, 1976) for the procurement of major systems by the Federal Government. In DOE, a major system
acquisition entails a sequence of acquisition activities for high-priority programs and projects starting with basic
research and proceeding through commercialization.
DOE uses many factors to determine if a project will be designated as a major system acquisition. These include:
development costs, technical complexity, and the projected market penetration of the technology in terms of time of
entry, energy requirements, and relationship to energy supplies displaced or substituted. For example, development
cost criteria stipulate that a project is considered major if there is an estimated $50 million annual or $200 million
lifetime cost. Of approximately 100 nuclear and nonnuclear DOE technology RD&D projects now under way, only
20 to 30 are major systems, with these accounting for nearly 50 percent of the total Departmental budget for energy
RD&D. Nuclear and nonnuclear RD&D projects which are currently designated as major systems are listed in Table 2
(DOE Order 4240.1, Designation of Department of Energy Major Systems).
Those projects which are not designated as major system acquisitions, do not come under formal PPMS review and
are under the management responsibility and direction of the appropriate program office. For example, in the Coal
Gasification program, the Gasifiers-in-Industry Project is now in the technology development phase under the direc-
tion of the Office of Energy Technology. If the project is ultimately moved to commercialization, the Office of
Resource Applications will have responsibility for the final development phase. As these projects are outside of formal
PPMS review and controlled by a less formal project development reivew there is not an opportunity for as com-
prehensive an environmental review as that provided in PPMS. The Assistant Secretary with the prime responsibility
for project implementation performs the role fulfilled by the PPMS Review Board for major systems.
C. Environmental Planning and Review
The PPMS is not a policy planning system. It was originally designed to coordinate project evaluation and planning
with the budget cycle. Although the PPMS implementation schedule was completed in October 1978, it is still
undergoing revisions. A number of the major systems that PPMS covers are ongoing projects that have not completed
a phase development cycle. Therefore, specific transition points are not yet evident. The total number of projects that
make up a technology program may not be included in PPMS, but those projects included represent a large part of a
technology budgetary program. In the DirectConversion Coal Liquefaction Program, for example, only some of the
projects are now reveiwed by PPMS, but these projects (i.e., the Solvent Refined Coal and H-Coal Projects) represent
a large share of the program budget.
With the creation of PPMS and the availability of a system for approving outlay (budgetary) program and project
plans, an opportunity for synchronizing needed environmental research with the development phases of the
technologies became apparent. This led to the integration of two separate but complementary program plans within an
outlay program — a Technical Program Plan (TPP) and an Environmental Development Plan (EDP). The objective
of the TPP is to define a development strategy for a project or group of projects of the same technology moving
through the development phases. The EDP will identify and integrate required environment, safety, and health
research within the appropriate phases of the technology project or projects.
From its inception, it was stressed that PPMS would take into consideration at all phases "...the environmental
issues..." (Myers Memo May 31, 1978) relevant to significant RD&D projects. Environmental planning and review
then was considered an integral part of PPMS at the program and project levels. There are two sets of environmental
planning and review documents that are used in PPMS: those that are generic to an energy technology and those that
are specific to each project. Environmental Development Plans, Environmental Readiness Documents, and Generic
Environmental Impact Statements (EISs) are of the first type. The second type consists of Project Environmental
Plans, the Site or Process Specific EISs, and the Safety Analysis System. The relationship of these documents to a
discrete phase in the PPMS process is shown in Figure 6. This figure shows how the program office and the Office of
Environment work together to identify uncertainties and develop solutions to environmental issues as the technology
projects move through a development phase.
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FIGURE 5. MAJOR SYSTEM ACQUISITIONS-PHASE TRANSITION DECISION POINTS
Under Secretary approves
identified and defined
specific mission, needs,
relative priority, and
general magnitude of
resources.
Under Secretary selects
competing design con-
cepts to be advanced to
engineering development
and competing demon-
stration.
Under Secretary commits
DOE to full-scale
development, test, and
evaluation or limited
production.
Under Secretary commits
DOE to full production.
1
1
1 1
1 1 1
1 1 1
1 | 2 3 . 4
1
BASIC APPLIED EXPLORATORY 1 TECHNOLOGY
RESEARCH RESEARCH DEVELOPMENT DEVELOPMENT
1
1
1
1 1
1 1
1
V i
1 ^
1 PHASES
1 1
5
ENGINEERING
DEVELOPMENT
/ ESAAB \ / ESAAB \
/ REVIEW \ / REVIEW \ ESAAB ESAAB
\ AS / \ AS / REVIEW REVIEW
\ NECESSARY / \ NECESSARY /
1
1
1
6 7
COMMERCIALIZATION
DEMONSTRATION PRODUCTION
OPERATION
1 J
\
1
ESAAB ESAAB
REVIEW REVIEW
ENERGY SYSTEM ACQUISITION PROJECTS
= Phase Transition Decision Points
ESAAB - Energy System Acquisition Advisory Board
FromUnder Secretary Myers Memorandum May 31, 1978
"Program and Project Management System for DOE
Outlay Programs"
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TABLE 2. DOE MAJOR SYSTEMS
NON-NUCLEAR
NUCLEAR
RESPON-
SIBILITY
PROJECT
RESPON-
SIBILITY
PROJECT
ET
ET
ET
ET
ET
ET
ET
ET
ET
ET
CS
Atmospheric Fluidized Bed Direct Combustion Demonstration Plant
HYGAS Demonstration Plant
Solvent Refined Coal Demonstration Plant (SRC-1 Solid or SRC-2)
Magnetohydrodynamics Engineering Test Facility
High BTU Synthetic Gas Pipeline Plant
Low BTU Fuel Gas Industrial Demonstration Plant
"H" Coal Pilot Plant
10MWe Solar Thermal Central Receiver Pilot Plant
50MWe Geothermal Demonstration Plant
Ocean Thermal Energy Conversion Test Platform
Heat Engines Project
ET
ET
ET
ET
ET
ET
ET
ET
ET
ER
RA
DP
ER
ET
National Waste Terminal Storage Facility
Defense Waste Processing Facility, Savannah River
Advanced Isotope Separation Technology Engineering Demonstration Facility
Waste Retrieval and Treatment Facility
Waste Isolation Pilot Plant
Tokamak Fusion Test Reactor
Mirror Fusion Test Facility
Fusion Materials Irradiation Test Facility
Fluorinel Dissolution Process and Fuel Receiving Improvements
Positron-Electron Project
Centrifuge Add-on Plant (Portsmouth)
High Energy Laser Facility (NOVA)
ISABELLE
Fuel and Materials Examination Facility
ET — Office of Energy Technology
ER— Office of Energy Research
RA— Office of Resource Applications
DP — Office of Defense Programs
CS — Office of Conservation and Solar Applications
(Designation of DOE Major Systems Order 4240.1, February 1, 1979)
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FIGURE 6. RELATIONSHIP OF DOE ENVIRONMENTAL PLANNING SYSTEM TO
PPMS MAJOR SYSTEM ACQUISITION
PRECEDING
PHASE
SUCCEEDING
PHASE
PROGRAM
OFFICE
PROGRAM AND
PROJECT-
MANAGEMENT
SYSTEM
OFFICE OF
ENVIRONMENT
ENERGY SYSTEM ACQUISITION PROGRAM PHASE
TECHNOLOGY PROGRAM PLAN (TPP): Long range plan for
developing emerging technology
ENVIRONMENTAL DEVELOPMENT PLAN (EDP):
companion plan to TPP for synchronizing environmental
needs with technology development
ENERGY SYSTEM ACQUISITION PROJECT PLAN (ESAPPI:
plan for specific projects within TPP addressing scientific,
technological and engineering objectives
PROJECT ENVIRONMENTAL PLAN (PEPI:
Environmental Annex to ESAPP
IMPLEMENTATION
Research Implementation Documents,
Research and development activities
identified in the EDPs and the PEPs.
o
ASSESSMENT
ENVIRONMENTAL READINESS DOCUMENT (ERD):
A review of research results used to decide the environmental
readiness of the technologies to move to the next developmental
stage, (i.e., demonstration to commercialization).
ENVIRONMENTAL ASSESSMENT (EA) AND
ENVIRONMENTAL IMPACT STATEMENTS (EIS):
EA—A preliminary analysis of the consequences of a
proposed action or technology to determine the need
for an EIS.
ElS-ln depth analysis of the environmental impacts,
mitigating measures and alternatives to the proposed
action or technology.
DECISION GATE-Poml at which the Under Secretary, following
consultation with the Environmental System Acquisition
Advisory Board (ESAAB) makes a decision, as to whether
the technology is ready to advance to the next acquisition
stage.
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Further discussion of the objectives and purpose of the various environmental documents is made in Subsection F.
Also see Table 3.
D. Energy System Acquisition Projects
There are seven phases in the DOE research, development, and commercialization effort through which all energy
projects must pass. These seven phases are divided into two stages — Technology Base Activities and Energy System
Acquisition. The first stage encompasses basic and applied research and exploratory development, which involve the
conception and definition of technology options. When a specific project has been formalized, it passes from Phase 3
(exploratory development) into Phase 4 (technology development) and so enters the next stage, becoming an Energy
System Acquisition Project. Although PPMS covers all seven phases in the research, development and commercializa-
tion effort, it is primarily focused on energy system acquisition projects.
When technical program plans encompass more than one technology, each specific technology is addressed in a
detailed Energy System Acquisition Project Plan (ESAPP). For example, ESAPPs are prepared for the Solvent Refin-
ed Coal and H-Coal projects in the Direct Conversion Coal Liquefaction Technology Program Plan.
In general, the ESAPPs serve as baseline planning documents for DOE project activities and cover the project from
its initial proposal through ultimate completion. ESAPPs are unique to each project, and the format and level of
detail varies with the size, complexity, sensitivity, and other characteristics of the project. Generally, the elements of
an ESAPP include a mission need and project objectives summary, a management and procurement strategy, and a
risk assessment and resource plan.
In its original design, ESAPP included two mandatory annexes: Environmental Issues and Control Technology,
and Commercialization and Market Development. The Environmental Technology Annex identified "the en-
vironmental barriers or questions associated with the specified technology or process and describes the control
technology, supporting research, and other program efforts aimed at overcoming environmental constraints or pro-
blems." (Myers Memo May 31, 1978.) With such a broad mandate this Annex (now called a Project Environmental
Plan) has developed into a companion document to the ESAPP. These Project Environmental Plans (PEPs) are de-
rived from long-range environmental needs as set forth in the Environmental Development Plan.
The Commercialization and Market Development Annex identifies an early commercialization strategy which
gradually becomes a well-defined and comprehensive market development plan.
E. Energy System Acquisition Advisory Board
To guide the development of a major energy system acquisition project and to serve as an advisory body to the DOE
Under Secretary, the Energy System Acquisition Advisory Board (ESAAB) under PPMS was established. The Board
authorizes each of the successive phases of technology development. It can modify an authorized phase approval or
cancel a project. The ESABB is chaired by the Under Secretary, and the Assistant Chairman is the Assistant Secretary
or Director whose major system acquisition project is presented for decision. The Assistant Secretary for Environ-
ment, several other Assistant Secretaries, the Deputy Under Secretaries, the Controller and Director of Procurement
and Contracts Management serve on the ESAAB.
The ESAAB advises the Under Secretary at the four key decision points for energy system acquisition in the PPMS
(shown in Figure 5). The first decision occurs when an energy technology is considered ready to
move from research-related activities (exploratory development) to actual technology development and thus become a
major energy system acquisition project. Other ESAAB reviews occur at subsequent transition points between
technology and engineering development, engineering development and demonstration, and demonstration and com-
mercialization.
Participation in the ESAAB is important to the Office of Environment because it is a direct link to the development,
approval, and execution of DOE's major budgetary projects. This participation provides an opportunity for the Of-
fice of Environment to present their assessment of each major energy system and, if recommendations differ, provides
access to the DOE Under Secretary for resolution.
10
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TABLE 3. OVERVIEW OF MAJOR DOE ENVIRONMENTAL PLANNING AND REVIEW DOCUMENTS
DOCUMENT
1 Environmental Development
Plan (EDP)
2 Energy System Project
Environmental Plan (PEP)
3 Environmental Readiness
Documents (ERD)
4 Environmental Assessments
(EA) and Environmental
Impact Statements (ElS)
PURPOSE
Defines major environmental concerns
associated with a particular energy
technology and general environmental
research requirements for addressing
those concerns.
Plans environmental R&D for a
specific project.
Review environmental status of a
particular technology and serve as
formal EV input to DOE technology
development decisions.
EAs evaluate if ElS should be prepared
in order to meet NEPA requirements.
EISs assess environmental impacts of
proposed major Federal actions.
CONTENTS
• Define environmental concerns.
* Assess status and risk.
• Identify R&D needs.
• Describe R&D plan.
• List research projects (including
NEPA requirements).
• Identify the sponsoring office.
• Specify funding requirements.
• Provide a research completion
schedule.
• Assess environmental readiness of
a technology to move on to the
next development stage.
• Discuss current and potential
regulations affecting technology
and control technology options.
• Assess delays and costs asso-
ciated with adverse environmental
findings.
Describe:
• proposed actions, probable
impacts, unavoidable adverse
impacts, possible alternatives.
PREPARER
EV, in conjunction with ECC subcommittee
for that technology
EV, in conjunction with ECC subcommittee
for that technology
EV
Technology program manager.
TIMING
Annual revision of EDPs is formally
called for, however, major updates
of EDPs will likely coincide with
PPMS phases in the future.
In conjunction with the ESAPP.
Prior to PPMS decision gates.
Contained in the PEP.
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F. Environmental Research Planning and Assessment Process
To aid in planning for needed environmental research, support the environmental evaluation required in the PPMS,
and to utilize existing documentation requirements of the National Environmental Policy Act (NEPA), the Office of
Environment (EV) established an internal Environmental Research Planning and Assessment Process. To help under-
stand the formal outputs of this process (Environmental Development Plans, Project Environmental Plans and Envi-
ronmental Readiness Documents) and how these outputs are utilized, the process can be separated into planning,
implementation and assessments elements.
1. Planning
Environmental research planning is described in two specific documents: the Environmental Development Plan
(EDP) and the Energy System Acquisition Project Environmental Plan (PEP). Key to the development of these
documents is the Environmental Coordination Committee (ECC).
Environmental Development Plans
Initiated in 1976, the Environmental Development Plan (EDP) has evolved into the Office of Environment's
primary planning document for synchronizing environmental research with technology RD&D schedules. The first
generation of EDPs consisted of statements of environmental concerns, general research and development re-
quirements, and milestone schedules. With the implementation of PPMS, the EDPs are jointly prepared by the
technology program office and the Office of Environment, usually in advance of the development phase of a
technology. This joint activity is necessary to assure that environmental research and decision-making are not out of
phase with the technology development plans.
Energy System Acquisition Project Environmental Plan
The environmental planning document that addresses a specific research project is the Project Environmental Plan
(PEP). Prepared by the Office of Environment staff in collaboration with the technical program office, a PEP is the
environmental counterpart to the technology project plan (ESAPP). PEPs represent an agreement between the two of-
fices concerning the specific environmental research to be accomplished in support of that technology project.
The PEP is similar to the relevant EDP in scope and content. But while the EDP addresses an entire technical pro-
gram, the PEP is project—and—site specific to the particular phase of development. All research projects listed in the
PEP should address the research requirements identified in the EDP, and the schedule for completing these research
projects should be consistent with the technology development schedule.
Environmental Coordination Committee
To facilitate communications and interactions between the Office of Environment and the Program Offices in the
preparation of the EDPs and PEPs, Environmental Coordination Committees (ECC) were formed. The functions of
the ECC are to provide a forum for the exhange of viewpoints and requirements directed at preparation of EDPs and
PEPs and to oversee their completion and implementation. "The ECCs have no direct program management respon-
sibilty. Each ECC is a two-tier committee. The parent committee, comprised of the senior program managers from the
Office of Environment and the technology offices, delegates responsibility for actual EDP and PEP preparation to
subcommittees. Each subcommittee is identified with an energy system selected for development or com-
mercialization, e.g., under the Fossil Energy ECC, a typical subcommittee is Coal Gasification. Subcommittees are
comprised of project managers and staff engaged in planning and are chaired by Office of Environment staff
members. The parent ECC, e.g., Fossil Energy, meets only irregularly to resolve conflicts and issues not remedied at
subcommittee level." (Clusen Memo December 18, 1978.)
2. Implementation
The environmental planning documents (EDP/PEP) serve as the basis for developing budgets for environmental
research activities. As part of each budget cycle, the Office of Environment issues guidance to DOE research centers
and laboratories on research needs indentified in the EDP's. They respond with research proposals to meet these
needs.
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Generally, the facility which has primary responsibility for a specific technology prepares a research program plan.
The plan describes in scientific terms the objectives, approach, method of analysis, and schedule for each of the en-
vironmental research projects associated with that technology program.
Periodically, environmental researchers are required to submit status reports to the Office of Environment project
managers. These reports will support environmental assessments associated with the technology development process.
3. Assessment
Three documents — Environmental Readiness Documents, Environmental Assessments, and Environmental Im-
pact Statements — are used to assess the environmental acceptability of an energy system acquisition project.
However, only the Environmental Readiness Document (ERD), is produced as a formal output of the Planning and
Assessment Process.
Environmental Readiness Documents
As an assessment prepared independently by the Office of Environment, ERDs are used by the Assistant Secretary
for Environment to advise the ESAAB on the suitability of allowing an energy technology to move to the next phase in
the energy system acquisition process.
In Fiscal Year 1978, as part of the DOE Commercialization Task Force Study, sixteen ERDs were prepared to assist
in selecting candidate technologies for near term commercialization.
As part of PPMS, the ERD is designed to present the results of environmental R&D from the preceeding phase and
provide further definition of concerns and research needs for the ensuing phase. ERDs support Environmental Impact
Statement (EIS) preparation. As an analytical reference document, the ERD was designed to be useful in scoping en-
vironmental concerns and supplying quantitative information on specific pollutants as well as potential ambient im-
pacts.
ERDs are reviewed by the ECC technology subcommittee, other DOE offices, and are available to the general
public; but like the EDP, there is no system for widespread comment and review outside of DOE.
Environmental Impact Statements
The National Environmental Policy Act of 1969 (NEPA) requires Federal agencies to prepare Environmental Im-
pact Statements (EIS) for major actions that significantly affect the quality of the environment. An Environmental
Assessment (EA) is a preliminary analysis to determine whether the impact of an action will be significant and is used
to decide if preparation of an EIS is necessary.
The purpose of an EIS is to assess the environmental impact of an action, reasonable alternatives to that action, and
to provide an opportunity for public review and comment on the action. EISs may cover a general technology
program or specific projects within a program. EAs and EISs are prepared by technology program offices and are
reviewed by the Office of Environment and the Office of General Counsel. Within PPMS, EAs and EISs can be
prepared at any phase, but they will normally be required at the technology development phase and at appropriate
decision points throughout the remaining phases.
Requirements, costs, responsibilities and schedules for completing EAs and EISs for technology projects are
specified in the Project Environmental Plan.
Safety Analyses
A safety analysis is not prepared as part of the Environmental Planning and Assessment Process nor as part of
NEPA requirements. It is prepared according to DOE procedures for an occupational and public health and safety
review of a proposed facility. It is usually prepared in the design phase of a facility that DOE intends to procure and
operate. The purpose of a safety analysis is to identify and limit risks to health and safety of the public and employees
and to adequately protect property and the environment.
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III. PRELIMINARY FINDINGS CONCERNING THE ENVIRONMENT
PLANNING AND ASSESSMENT PROCESS
A. Introduction
A preliminary analysis of the Environmental Research Planning and Assessment Process provides three types of
findings:
• the effect environmental planning and review has had on recent DOE technology decisions;
• identification of the procedural aspects of the environmental review process;
• opportunities for public participation in the process.
Three factors limit the conclusions that can be drawn with respect to the effectiveness of DOE environmental plan-
ning and assessment: (1) neither the PPMS process nor the environmental process were fully operational until late
1978, (2) a Departmental Order has not yet been developed for PPMS. (It is still operated by an Interim Guidance and
Policy Statement issued in May, 1978. The DOE order for Environmental Development Plans was issued before
PPMS was fully implemented. It does not mention the EDP as part of the PPMS review process), (3) only one non-
nuclear technology project (the 50 megawatt Geothermal pilot plant in Baca, New Mexico) has passed through a
PPMS decision gate.
B. Environmental Planning And Review And Technology Decisions
Several situations involving PPMS procedures and the environmental research planning and assessment process
raise questions as to how extensively environmental factors have been included in DOE's recent decisions on non-
nuclear technology RD&D projects. For example:
• Under PPMS procedures, the ESAAB (which includes the Assistant Secretary for Environment) meets to advise
the Under Secretary on the movement of technologies through development phases. Though a significant
portion of DOE's budget is for technology RD&D, the ESAAB (as of May, 1979) has met only three times in
Fiscal Year 1979 (since October, 1978).
• The implementation of PPMS and the DOE Commercialization Task Force activities were not coordinated. In
late 1978 sixteen technologies (both programs and projects) were selected for near term commercialization by the
task force. Only one of these programs (geothermal) has gone through the ESAAB review, and this was after the
Task Force announced the commercialization technologies selected. The fact that commercialization resource
managers and analysts were selected for all these technologies suggests they passed, at least partially, into the
commercialization phase; yet the formal PPMS review process — which calls for explicit consideration of
environmental issues — was not used.
• Only major energy acquisition projects come under PPMS review. The projects that do not qualify as major
systems are the responsibility of the Assistant Secretary guiding their implementation. As such, there is no
formal process to insure environmental review by the Office of Environment (EV), though EV does prepare
Project Environmental Plans (PEPs) for these projects.
• EAs and EISs being developed by the DOE Program Offices do not generally reference relevant ERD or
environmental research in general. This raises a question about the focus of some of the Office of Environment
research or an awareness of it within DOE.
As PPMS and its environmental planning and review procedures mature, some of the concerns raised by the above
events should be resolved.
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C. Procedural Aspects of the Environmental Review Process
In examining the Environmental Research Planning and Assessment Process, several relative strengths and weak-
nesses can be identified.
1. Strengths
Although components of the process are still in the early stages of development and use, there are three particular
aspects that contribute to the process' actual and potential effectiveness:
Key elements of an effective management system are present. The Environmental Research Planning and Assess-
ment Process contains the basic components of an effective management system: planning, controlling, and assessing.
Although the process is usually defined in terms of the formal documents it produces (EDPs, ERDs, and PEPs), there
are, in addition, a series of management tools and procedures which support it (e.g., the DOE budgeting process and
intra-department subcommittees).
Available process documentation. A large number of outputs from the process (EDPs, ERDs, and PEPs) have been
and continue to be produced. "In Fiscal Year 1978, DOE prepared twenty-eight EDPs and sixteen ERDs. In Fiscal
Year 1979, thirty-three EDPs are being updated or prepared, sixty-four PEPs are being prepared, and fifteen-to-
twenty new ERDs are being generated. For Fiscal Year 1980, DOE planned activities include preparing or revising
twenty-to-thirty EDPs, generating or updating thirty ERDs and preparing or revising a large number of PEPs." (DOE
Office of Technology Impacts, April 1979).
Improved process integration. Because programs and procedures varied widely across DOE's predecessor agencies,
a Departmental Order (DOE 5420.1: Environmental Development Plans, August, 1978) was issued that simplified the
EDP preparation process and designated departmental responsibility for integrating it into the then-existing DOE
planning system. With the creation of the PPMS, this integration was improved since the EDP is considered to be the
environmental counterpart to the Technology Program Plan.
2. Weaknesses
The process currently contains several shortcomings:
Lack of formal research feedback mechanism. Procedures for feeding the results of environmental research back to
the technology and environmental program offices are not well defined. Although the results of research projects may
appear in EDPs or ERDs, there is no formal requirement that the results of a specific research project be documented
and delivered to ET or CS program managers. Periodic reports are prepared by some national laboratories, and
research sponsored by the Office of Environment (EV) generally appears in the technical literature; however, these
results are not systematically integrated at the technology program level.
Inability to identify ongoing research. It is difficult to identify the results of research tasks that have already been
accomplished because PEPs list only proposed or needed research. EV is planning the development of an information
processing capability to make this task simpler and in part solve the problem.
Unresolved process issues. The need for EDPs, ERDs, and PEPs is generally recognized within DOE, but there are
significant differences of opinion concerning the content and frequency of updates for these documents. EDPs are
criticized by some for being too general and by others for being too specific. Although it is intended that EDPs be
written or updated at the beginning of an acquisition phase and not updated until the next phase, some internal DOE
documentation prescribes annual updates.
ERDs are technology-specific and written as an environmental policy input for deciding whether a technology
should move from one acquisition phase to the next (e.g., demonstration to commercialization). However, technology
programs generally comprise several technical projects. It is not clear what happens when one technical approach is
ready to move on to the next phase but another in the program is not. Will there be multiple ERDs for a technology?
On the other hand, ERDs are prepared at the end of an acquisition phase, which means that several years may separate
environmental assessments for a technology. Will there be interim assessments?
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The significance of these problems is that their resolution will have a direct impact on the content and currency of
the documents and ultimately on the use to which that information can be put. It also indicates that, although the pro-
cess is generally sound in design, a number of important implementation issues remain to be resolved.
D. Public Participation
In the context that it is used in this section, public participants include public interest and environmental groups, the
private sector, and others who are interested in the way environmental considerations are integrated into the DOE
decision-making process. The potential significance and impact of emerging energy technologies at both the national
and local site-specific levels makes it imperative that there is substantial public participation in DOE's planning and
decision-making process. It is essential to determine how best to keep the public informed and how then to ensure they
are effectively involved in the planning and decision-making process.
Presently, the major existing opportunity for public participation is the NEPA process, which requires public hear-
ings and comment on EISs. Newly proposed NEPA regulations (effective July 1979) for EIS preparation pose further
questions regarding how these documents mesh with the DOE planning processes. For instance, how specifically are
EAs and EISs linked to key decision points in the technology development process and also to the outputs of the En-
vironmental Research Planning and Assessment Process?
The Assistant Secretary for Environment has stressed the importance of public participation in interpreting the en-
vironmental consequences of emerging technologies. One of the duties of the Office of Program Coordination within
the Office of the Assistant Secretary is a program in public participation. The range and scope of this participation in
the evaluation of information on the environment has recently expanded. However, the issue of DOE's actual integra-
tion of this public review into the Program and Project Management System (which guides technology development)
still remains.
The issues and options in this section are presented to stimulate further analysis and public discussion at the 1979
Section 11 Regional Workshops and the National Public Hearing in order to assist in the development of recommen-
dations for increasing public involvement.
1. What is the most effective way to keep the public informed?
DOE's Environmental Research Planning and Assessment Process is fundamentally an internal management
system. As such, its outputs may not have the content or the detail that would allow an outsider to fully understand
the status, direction, and content of DOE's environmental research.
The information needs of the public will differ. Some segments of the public will be interested in obtaining more in-
formation and detail than that contained in the formal process documents. However, placing such information in
EDPs or PEPs could make their production burdensome enough to defeat their purpose as management documents.
Possible steps that would help meet the information needs of the informed public include:
• Increasing the range and detail in EDPs and PEPs. This step would not apply to the ERDs since they are
assessment documents that should already contain that detail.
• Producing new documents to meet information needs. One possibility is the use of "technology assessments" —
brief papers concerning a particular process or technology;
• Making "readable" research plans and results available to the public.
• Developing a standard sequence of contacts and contact points between DOE headquarters, regional offices and
the public that provide for information exchange and a system of accountability regarding specific concerns.
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Other members of the public may be particularly interested in site specific projects that directly affect local areas
(e.g., construction of a nearby demonstration plant). These information needs could possibly be met by the following
actions:
• More frequent production and active distribution of ERDs (or ERD equivalents in content) since they appear to
be a document that meets many of the public needs; and
• Workshops and informal meetings at the earliest planning stages of each proposed pilot and demonstration
plant site to allow local concerns to be voiced and incorporated.
2. How effective is DOE''s internal research management process in allowing opportunities for the public to par-
ticipate effectively in the decision process?
Among the options available for determining public attitudes and concerns about energy technologies are:
• Distribution of formal documents (EDPs, PEPs, ERDs) in draft or final form for review and comment;
• Periodic public meetings to discuss the status of environmental research within one technology or a group of
technologies; and
• Workshops and conferences focusing on technical, scientific and environmental issues within a technology.
To help insure that public concerns which have been raised are included at key points in the decision-making
process, possible options are:
• Participation of selected representatives from interested groups in ECC subcommittee meetings dealing with
EDP and PEP preparation and the setting of research priorities; and
• Creation of advisory groups for specific technologies that would include representatives of the public and would
provide a formal role for these groups in the process.
Some of these activities are presently in use in the Environmental Research Planning and Assessment Process.
Within the Office of Environment, the attention paid to public participation has increased. The issues of environmen-
tal protection are technically complex and the process of public communication and review quite difficult. It is im-
perative that present and future programs in public participation prove effective in generating a consensus on the
proper course of RD&D investments in emerging technologies.
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IV. CASE STUDY: DOE's ENVIRONMENTAL RESEARCH PLANNING AND
ASSESSMENT PROCESS FOR GEOTHERMAL ENERGY
The regional workshops will focus on specific technologies and will provide participants with the opportunity to
learn how the DOE environmental planning process works. This case study examines one technology and the ways in
which its development has been influenced by the process.
A. Evaluation Criteria
The Environmental Research Planning and Assessment Process can be evaluated by examining how it functions in
the case of Geothermal Energy Systems on a program and project specific basis. This techology was chosen for three
reasons: (1) DOE has decided to move this technology (in particular, hydrothermal energy) towards commercializa-
tion; (2) a considerable amount of DOE environmental research documentation (three EDPs, one ERD, and one PEP)
has been generated for this technology; and (3) DOE generally regards geothermal energy development as having a
good potential to effectively involve all local concerned parties in its environmental management process.
Four criteria should be used as the basis for evaluating the Environmental Research Planning and Assessment Pro-
cess:
• The extent to which DOE has followed the process;
• The extent to which DOE has carried out the planned environmental research;
• The extent to which the results of DOE's environmental research has affected technology development
decisions in the geothermal industry.
• The opportunities for the concerned public, local, State and Federal Agencies and the Geothermal Industry to
participate in the process.
This evaluation will be complicated because a major portion of geothermal development occurred prior to the ex-
istence of the Office of Environment's Planning and Assessment Process.
B. Background: Technology and Environmental Concerns
1. Geothermal Technology
"Geothermal energy is derived from the earth's natural heat and stored in hot or molten rock and in the water and
steam that fill underground rock pores and fractures. Hydrothermal systems — vapor or liquid-dominated reservoirs
— account for all the electricity currently produced from the world's geothermal reserves; California's hydrothermal
resource accounts for over 70 percent of the electrical energy potentially recoverable from such reservoirs in the
United States" (Rand Corporation Study, Jan. 1979). Fourteen western states contain geothermal reservoirs under
approximately 100 million acres, 60% of which the Federal government controls. The largest geothermal power plant
in the world is located at The Geysers dry steam reservoir in northern California's Known Geothermal Resource Area
(KGRA)*. Electricity is about to be produced commercially in the liquid-dominated reservoirs in Southern
California's Imperial Valley. Mexico is generating electricity from it's liquid dominated reservoir at Cerro Prieto, just
below the Imperial Valley; the facility will soon be expanded to 225 MWe.
DOE is currently investigating three major types of geothermal resource: hydrothermal, geopressured, and hot dry
rock. Of these, only hydrothermal has gone through the environmental review process. This discussion, therefore, ad-
dresses only hydrothermal.
The type of hydrothermal fluid used to generate electricity depends on the nature of the hydrothermal reservoir,
which can vary in phase (vapor or liquid), pressure, temperature, and salinity.
*A KGRA is defined as "an area in which the geology, nearby discoveries, competitive interests, or other
indicia....engender a belief that the prospects for extraction of geothermal steam or associated resources are good
enough to warrant expenditures ....for that purpose." (PL 91-581 Geothermal Steam Act of 1970).
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Key unresolved technical issues for hydrothermal electricity are the control of H2S emissions and reinjection of
spent geothermal fluids from liquid dominated reservoirs. Other barriers to rapid development are a shortage of
geological data about the location, size and types of geothermal fields and shortage of drilling equipment. Many
groups feel the legal problems relating to leasing and the resource classification of geothermal energy are more impor-
tant than any technical considerations at this time.
Outside of the California Known Geothermal Resource Areas there are areas where hydrothermal electricity
generating projects are under development. These projects are primarily in the Western United States (Idaho,
New Mexico, Oregon) and Hawaii.
2. Environmental Concerns
The development of geothermal energy has raised a number of environmental concerns: air quality, water quality,
ecological effects, noise, subsidence, enhances seismicity, arid other local impacts. A summary of these concerns —
taken from the DOE and EPA environmental research documents for geothermal energy — is contained in Table 4.
These environmental problems vary in significance at different geothermal projects. For example, at the Geysers
(a vapor dominated reservoir), the hydrogen sulfide emissions may be more of a problem than at liquid-dominated
reservoirs in the Imperial Valley. Decisions concerning development sites are further constrained because electricity
that is generated at the site must then be transported to the point of utilization. Resulting land use disturbances due to
the placement of transmission lines may exceed those resulting from the initial development project.
Some mitigation of the environmental problems associated with geothermal energy is occurring through the use of
existing control technologies; however, much research and development of new control technologies continues — the
major control technologies are shown in Table 4.
C. Evaluation of the Environmental Planning and Assessment Process for Geothermal Energy
This evaluation should be made by examining how closely DOE has followed the Environmental Planning and
Assessment Process outlined earlier in Section II of this report.
1. The extent to which DOE has followed its Environmental Research Planning and Assessment Process
Over the past two years, three (3) geothermal program and project specific Environmental Development Plans have
been completed. In June 1977, an EDP for Hydrothermal Energy System Projects was issued. In March 1978, an EDP
for the Geothermal Energy Program was issued. This EDP was updated and reissued in April 1979. The project EDP
and the program EDP were similar in content — summarizing environmental, health, and safety issues; describing the
planned Environmental Projects and discussing control technologies for the more significant concerns.
The updated Geothermal Program EDP — utilizing environmental research data gained from a variety of geother-
mal projects — contains a much more detailed and comprehensive discussion of the technology, the environmental
concerns, and an updated listing of environmental research requirements. The second Geothermal Program EDP
clearly is an improvement over the earlier program EDP.
A project specific Environmental Readiness Document (ERD) was prepared for Hydrothermal Electric and Direct
Heat as an input to the DOE Commercialization Task Force Study. This Task Force identified those energy
technologies (programs and projects) that would be considered for commercialization. In late 1978, DOE appointed a
commercialization resource manager for geothermal/hydrothermal energy. It is not clear what effect the ERD —
which assessed the existing knowledge of each environmental concern in the EDP — had on the decision to push the
development of hydrothermal energy.
When the Energy System Acquisition Advisory Board met in late 1978 to review the 50 MWe Hydrothermal Pilot
Plant for Baca, New Mexico, only the first two EDPs and the ERD were available. At that time, DOE decided to go
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TABLE 4. MAJOR GEOTHERMAL ENVIRONMENTAL CONCERNS AND CONTROL TECHNOLOGIES
ENVIRONMENTAL CONCERN
DESCRIPTION OF ENVIRONMENTAL CONCERNS
POSSJULE CONJROL TECHNOLOGIES
Air Quality - Air quality concerns involve non-
condensible gases contained in geothermal
fluids. These gases are released to the
atmosphere through the cooling tower and when
the plant shuts down.
Water Qua 1ity - Water quality concerns
involve the disposal of spent geothermal
fluids and, in certain cases, water use
problems.
Noise -
Concerns with noise include both
site development and operations.
• Hydrogen sulfide represents the most signifi-
cant concern due to il.s noxious odor and low
detection threshold. It is also toxic, but
only at concentrations much higher than the
odor detection threshold. Community com-
plaints have been received in the case of the
Geysers.
t Small amounts of boron are released which, in
the case of the Geysers, have had a measure-
able effect on nearby vegetation.
• The disposal of large volumes of spent geo-
thermal fluids present an environmental
concern due to the potentially high salinity
of the fluid. This may preclude the dis-
charge to surface waters of untreated geo-
thermal fluids.
• In areas of scarce water resources, water
use (for cooling purposes) may conflict
with other local need-;.
The two major sources of noise are well
drilling operations and the venting of
stream during plant shutdowns. Citizen
complaints have been received at the
Geysers. It is expected that noise prob-
lems will not be as significant at KGRAs
with liquid-dominated resources.
* There are four major processes under considera-
tion for controlling airborne emissions:
-- Stretford Process
Iron Catalyst Process
-- EIC Process
— Dow Process
The Stretford Process has been used in the paper
and pulp industries. The EIC Process removes
hydrogen sulfide from raw geothermal steam and
therefore eliminates the- corrosive effects of
hydrogen sulfide on the turbine and piping. The
Dow Oxygeneration Process removes hydrogen sul-
fide from the geothermal brine at the wellhead,
but is at an earlier stage of development.
From the standpoint of cost and effectiveness,
the Stretford and EIC processes appear most
promising. The key issue at each site will be
the amount of airborne emissions as opposed to
the efficiency of the process.
• The most promising control technology is the
reinjection of spent geothermal fluids into
the ground. Care must be taken that aquifers
are not disturbed. Reinjection technology has
not been demonstrated on a large scale and has
experienced problems with the scaling and plug-
ging of injection wells which may result in the
need for pretreating the fluid to remove cer-
tain compounds (e.g., silica). Other means of
disposal include evaporation ponds and ocean
disposal (for suitably located sites).
Water treatment technologies include sedimenta-
tion, chemical precipitation, filtration, re-
verse osmosis and evaporation. Although indi-
vidual efficiencies of these technologies may
not be high, they usually can be grouped in
series to yield a satisfactory result.
• High noise levels can generally be controlled
through appropriate operating procedures and by
using mufflers or expansion towers.
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TABLE 4. MAJOR GEOTHERMAL ENVIRONMENTAL CONCERNS AND CONTROL TECHNOLOGIES (CON'T.)
tNVIRONMENTAL CONCERN
ts>
Ecql_ogi_cal_ Effects - Ecological effects
include both the short and long term
effects of geothermal development on
the surrounding area.
Subsidence and Seismicity - Subsidence
refers to the sinking or settling of
the land that may accompany the re-
moval of large amounts of geothermal
fluid from a rpservoir.
Seismicity refers to the potential
for an increased number of seismic
events due to the removal or injec-
tion of geothermal fluids.
Local Impacts - Geothermal development
can significantly effect local econo-
mies through capital investment, job
creation, and tax revenues.
DESCRIPTION OF ENVIRONMENTAL CONCERNS
• Of particular concern jre the effects of
geothermal development on any rare and en-
dangered plant and animal species in a KGRA.
* Subsidence is a major concern in the Imperial
Valley, an agricultural area with an exten-
sive irrigation system.
• Increased seismicity i; a concern in areas
already possessing high levels of seismic
activity.
Geothermal development can result in land
use difficulties and can be perceived as
detracting from the quality of life or
other segments of the local economy
(e.g., tourism) in areas with scenic,
pristine characteristics.
POSSIBLE CONTROL TECHNOLOGIES
• Subidence is most easily controlled through
the reinjection of geothermal fluids.
• If seismicity is a concern at a particular
site, reinjection could aggravate the problem.
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ahead with the Pilot Plant. They later issued a revised Program EDP and a Project Environmental Plan. An EDP and
PEP were prepared in early 1979 to guide development of the succeeding phases in the development process (see
Figure 6 in Section II).
Both site specific and more general geothermal and hydrothermal Environmental Assessments (EA) and En-
vironmental Impact Statements (EIS) have been prepared, though most were completed prior to implementation of
the Environmental Research Planning and Assessment Process. One exception, however, is the EIS for the 50 MWe
facility at Baca, New Mexico, which, as of June 1979, has not yet been completed.
2. The extent to which DOE has carried out the planned environmental research
Environmental research projects are generally based on an assessment of environmental concerns and a set of
budget decisions reflecting those concerns — i.e., decisions to undertake research related to the most pressing con-
cerns.
The EDPs prepared for geothermal energy identified the following environmental and socio-economic concerns
(these concerns are a further subdivision of those listed in Table 4): release of airborne effluents; release of waterborne
effluents; noise, subsidence; enhanced seismicity; water use; land use; social services and community structure; and
system safety and occupational health. Although much of the planned research is being carried out on schedule, there
are still large research gaps, notably in the design and implementation of long term baseline studies and in the develop-
ment of wet-steam systems. Many groups feel that little progress has been made in solving the land use, political, legal
and institutional issues.
3. The extent to which the results of DOE's environmental research has affected technology development decisions
in the Geothermal Industry.
It is possible to point to current research activities which may cause significant variations in the technology, depend-
ing upon whether methods can be developed to mitigate possible adverse environmental consequences. For example, if
reinjection of large amounts of spent geothermal fluids does not prove feasible, new control technologies must be
found or the course of geothermal energy development will be changed. Similarly, if measurements of subsidence
prove significant or if detection of public health problems from geothermal emissions (Hydrogen Sulfide, Mercury,
Radon) occurs, development in particular areas may be curtailed. There is also some concern that because research
results are not widely publicized, there may be some redundancy among the various research programs.
4. The opportunities for the concerned public, local, State and Federal agencies and members of the geothermal
industry to participate in the process.
A major objective of the Environmental Planning and Assessment Process should be to collect data on issues of
concern to interested parties as early in the planning process as possible. A major issue concerning public participation
is that many parties are brought into the planning process at the final stages after the course of RD&D has been
established. These parties are often suspicious of information, prior motives and decisions on research priorities.
Thus, they are often forced into an adversary role with the government or developers that results in long delays.
A second major objective of the Environmental Planning and Assessment Process should be the dissemination of
information. Ready availability of data on research and government and industry performance might reduce uncer-
tainty regarding the Federal geothermal RD&D effort. In addition, it could help eliminate redundancy in research ef-
forts, point out gaps in the programs, and establish a network for the entry of and access to new information.
The notion of public participation in geothermal energy development activities is not new to many western states.
For instance, Caliornia has an extensive network of commissions, committees, agencies, advisory panels, task forces
and study groups that have been formally or informally dealing with the problems surrounding geothermal develop-
ment since the early 1960's. The dominance of local agencies has been further enhanced by the strong tradition of
home rule in the West.
In California, the Air Pollution Control District and the Regional Water Quality Control Board play dominant
roles in that each has the power to confer or deny crucial permits at each stage of development at the state level. Both
the California Energy Commission and the State Geothermal Resources Council deal with geothermal issues.
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In 1978, the Boards of Supervisors of four California northern counties approved a Joint Powers Agreement for-
malizing creation of a commission to prepare a Geothermal Resource Impact Project Study (GRIPS), the first Califor-
nia local government agency established solely to deal with geothermal development. The GRIPS Commission's
primary function is to assist agencies involved in the geothermal development permitting process in speeding up en-
vironmentally sound decision-making. These agencies include the County Boards of Supervisors, Planning Depart-
ments and Air Pollution Control Districts, the California State Division of Oil and Gas, the State Energy Commis-
sion, DOE, EPA and the Department of the Interior.
The Commission intends to sponsor research, collate and disseminate information and review research progress. In
addition, they have planned for an aggressive program of local citizen involvement by holding workshops, publishing
reports and establishing Citizens Advisory Councils and Study Groups.
The GRIPS Commission appears to have sufficient credibility and the local support necessary to successfully in-
tegrate the interests of Federal, State and local agencies and developers in planning the development of geothermal
resources. However, the program has not yet developed according to plans.
The Commission received initial funding from DOE, the California Energy Commission and participating counties
for planning and program development. Although DOE played a positive role in facilitating the formation of the
GRIPS Commission, as of June 1979, no apparent decisions have been made regarding funding of the various ac-
tivities that are necessary if the organization is to accomplish its intended purpose.
The pattern of public, local and state involvement in geothermal development planning followed a different course
in the Imperial Valley in Southern California. Residents of the area have not had experience with a commercially
operated plant and many still do not fully understand the impacts of geothermal energy development. However,
elected officials are aware of the potential problems and they have expressed concerns about controlling geothermal
development and minimizing environmental impacts on the area's rich agricultural lands.
In 1975, the Energy Research and Development Administration (ERDA), partially as a result of the lessons they
learned at the Geysers area, attempted to coordinate the participation of existing state and local agencies in the
geothermal development process. This approach, the Imperial Valley Environmental Project (IVEP), brought
together existing concerned groups to develop a comprehensive assessment of regional issues associates with geother-
mal energy development.
The IVEP was designed to accomplish two objectives: (1) to produce an environmental baseline (information and
measurements on environmental quality in the Imperial Valley before any major development, and also monitoring
networks for detecting future changes); and (2) to identify the types of involvement (e.g., concerned regulatory agen-
cies, and local planners) needed for a regional environmental assessment. Although successful, the IVEP was a one-
time, short term project that failed to provide the continuity needed to deal with long term research and development
problems.
Based on the experience of IVEP, the DOE Office of Environment, in 1977, developed the Geothermal En-
vironmental Overview Program as the mechanism for conducting preliminary environmental assessments and gaining
public participation at selected, high priority KGRAs. The preliminary assessments — which are based on the objec-
tives of the Imperial Valley Environmental Project — are intended to provide regional assessment "snapshots" for
energy technology development. The Geothermal Environmental Overview Program is managed within the Office of
Environment and involves the DOE San Francisco Operations Office and the Lawrence Livermore Laboratory for
field management and technical support.
For each project, the Geothermal Environmental Overview Program establishes a close working relationship with
state and local agencies and produces a preliminary project assessment for use by the Office of Environment in
research and development planning. Copies of project specific preliminary assessments are provided to the En-
vironmental Coordinating Committee (ECC) subcommittee for use in preparing and updating Environmental
Development Plans and Program Environmental Plans.
Citizen involvement in the planning and decision-making process has been encouraged by the Geothermal
Resources Council, a regional non-profit professional society founded in 1972. The council was founded to en-
courage and promote research on all aspects of geothermal resources development, to collect and disseminate infor-
mation related to these activities, to serve as a public forum to provide objective and unbiased information on geother-
mal energy and to facilitate cooperation and coordination among various interested parties. The council teaches short
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courses, publishes reports and has participated in or coordinated several workshops on Geothermal Environmental
Problems sponsored by the National Science Foundation and the U.S. Bureau of Mines.
At the National Level there are at least five Federal agencies or departments that have separate mandates, programs
and procedures for dealing with geothermal resources. Among these, the Department of Energy, the Department of
the Interior and the Environmental Protection Agency have major roles. In addition to the separate agency specific
programs there are several levels of cooperative programs designed to integrate the multi-agency involvement in
research, planning and development. For instance, there is an Intergovernmental Geothermal Coordinating Commit-
tee, several Regional Federal Research Councils and the Geothermal Energy Advisory Panel. The latter organization
was established by the Secretary of the Interior in 1974 to advise responsible officials of the Department and others
regarding environmental problems associated with the exploration and development of geothermal energy on Federal
leased lands carried out under provisions of the Genthermal Steam Act of 1970. Membership of the Panel is drawn
from the Interior Department, Geologic Survey, Bureau of Mines, Bureau of Land Management, Bureau of Reclama-
tion, Heritage Conservation and Recreation Service, Fish and Wildlife Service, National Park Service and Office of
the Solicitor General. Other Federal Agencies represented include the EPA, DOE, Department of Labor, and Depart-
ment of Defense.
The Panel was established to act as the final level of review of environmental constraints applicable to geothermal
operators on Federally leased lands. The meetings, although infrequent, are announced in the media and open to the
public. The Panel has the potential to function as an important interface between the public, industry, environmental
groups, and the Department of the Interior. However, the role of the Panel is strictly advisory and it is only authorized
to deal with activities on Federal lands. Major issues concerning Federal leasing arrangements that appear to fall
under the purview of the Panel remained unresolved after several years of discussion. Thus, while the Panel has af-
forded a channel by which local concerns can be heard and responded to, it is not clear how the Panel's findings are
used in planning for Federal, state and private RD&D.
Further inter-agency cooperation with respect to geothermal energy was promoted by the Geothermal Energy
Research, Development, and Demonstration Act of 1974 which created the Interagency Geothermal Coordinating
Council (now the Geothermal Advisory Council). Its membership consists primarily of DOE, the Environmental Pro-
tection Agency (EPA), the Department of Interior, the Department of Agriculture, and the National Science
Foundation.
In 1976 the Council requested regulatory guidance for geothermal energy from EPA. EPA responded by producing
in 1978, a Pollution Control Guidance Document (EPA, June 1978) which identified major environmental research
needs and recommended guidelines for: hydrogen sulfide emissions, surface discharge of spent fluids, containment of
solid wastes, noise, and monitoring of air and water emissions gram concerns that were addressed in the EDP. EPA
has also prepared a position paper outlining possible regulatory approaches for geothermal energy and identifying in-
formation needs in order to make DOE more aware of likely EPA actions related to geothermal technology.
In summary, a large number of organizations exist for the expressed purpose of assessing the impacts of geothermal
energy development. An almost equally large number of groups, some with overlapping membership and similar man-
dates, exist to coordinate the activities of these organizations. In addition, DOE has developed its own regional assess-
ment model (i.e. the Overview Program) for involving the public at sites where geothermal development is being con-
sidered.
Although an extensive network of local, state and Federal action and coordinating committees exists, very few of
these groups are familiar with DOE's environmental review process or planning documents (PEPs, EDP, ERD's).
Thus, in spite of the original objectives of the Environmental Development Plans to "allow the public to help DOE
evaluate its progress toward...the development of environmentally acceptable and commercially viable tech-
nologies", there does not appear to be any mechanism to incorporate a wide spectrum of non-DOE views, reviews or
research efforts into the formal Environmental Research Planning and Assessment Process except in an ad hoc
fashion.
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REFERENCES
California Environmental Quality Act of 1970, as Amended (Public Resources Code Sections 21000 et. seq.).
Department of Energy Policy and Program Planning System (Interim Management Directive 0203).
Designation of Department of Energy Major Systems (Order 4240.1).
Environmental Development Plans (Order 5420.1).
Environmental Planning and Review in Relation to Major Systems Acquisition Projects. Assistant Secretary Ruth
Clusen, Memorandum, December 18, 1978.
Executive Office of the President, Office of Management and Budget. Major System Acquisitions. Circular A-109.
April 5, 1976.
National Energy Plan II, Environmental Trends and Impacts, May 9, 1979.
Office of the Assistant Secretary for Environment, Office of Technology Impacts Report, April 1979.
Pollution Control Guidance for Geothermal Energy Development. Environmental Protection Agency. Cincinnati,
Ohio. June 1978.
Program and Project Management System for DOE Outlay Programs. Interim Policy and Guidance. Under Secretary
Dale Myers, Memorandum, May 31, 1978.
Resolving Environmental Issues in Energy Development: Roles for the Department of Energy and its Field Offices.
Rand Corporation, January 1979.
Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act. Council on En-
vironmental Quality. November 29, 1978.
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