EPA-600/7-77-092
Geothermal Industry
Position Paper
EPA Regulatory
Options and
Research and
Development
Information Needs
EPA Geothermal Working Group
-------
Geothermal Industry
Position Paper
EPA Regulatory Options
and Research
and Development
Information Needs
by
EPA Geothermal Working Group
EPA Contract No. 68-01-3188
EPA Project Officer: Gregory D'Alessio
for
Environmental Protection Agency
Office of Energy, Minerals and Industry
4th and M Streets, S.W.
Washington, D.C. 20460
-------
FOKEWARD
This document presents the approach of the Environmental Protection
Agency to the problem of regulating an evolving but essentially undeveloped
industry, namely that which uses geothermal energy technology.
While the Energy Research and Development Administration has provided
a focus for Federal initiatives in this area, a large number of private
interests, both large and small, are engaged in exploration and develop-
ment of this presently untapped energy resource.
Extensive exploration for geothermal resources is taking place
throughout the Western U.S. and significant demonstration and commercial
projects are projected to take place within several years. Much of this
activity will take place on Federal lands.
Because of this and the present uncertainty over the environmental
impact of various geothermal technologies, EPA has developed this posi-
tion paper as a first step toward guiding the evolution of the geothermal
energy industry in directions which will adequately protect the environ-
ment and human health.
The geothermal energy industry is but one potential industry based
on emerging energy technologies funded under the National Energy Plan.
By taking the opportunity to address this technology in its formative
stages, EPA can expedite the environmentally proper commercialization
of this energy resource and avoid economically undesirable pollution
control backfitting requirements in the future.
Gregory J. D'Alessio
Chairman
EPA Geothermal Working Group
ill
-------
ABSTRACT
The environmental impact of geothermal energy development may be
less intense or widespread than that of some other energy sources;
however, it is the first example of a number of emerging energy tech-
nologies that must be dealt with by EPA. EPA may consider a spectrum
of options ranging from a posture of business as usual to one of
immediate setting of standards, as favored by ERDA. The paper discusses
the regulatory approaches and the potential problems that geothermal
energy may present in the areas of air quality, water quality, and other
impacts. It is recommended that a coordinated program of research be
drawn up, comprised of specific research projects, the types of geo-
thermal resource to which they apply, and the date by which the infor-
mation is required.
iv
-------
TABLE OF CONTENTS
LIST OF ILLUSTRATIONS
LIST OF TABLES
ACKNOWLEDGEMENTS
SECTION 1 INTRODUCTION
I. Purpose
II. Objective
SECTION 2 EPA STRATEGY
I. Why EPA Should Address Geothermal Energy
A. Organization Background
II. EPA's Approach to the Problem
A. Background
B. The Geothermal Working Group (GWG)
III. Recommended Strategy
SECTION 3 EPA PLAN OF ACTION
I. ERDA's Geothermal Development Plans
II. Implications of the ERDA Plan
III. A Mission-Oriented Approach to Regulatory
Planning and Environmental Research for
the Emerging Geothermal Industry
A. Problem Evaluation
B. Regulatory Pathways and Guidance
C. Regulatory Decision Schedule
D. Recognition of Required Supporting
Information
E. Identification of Research Program Needs
F. Research Program Definition
SECTION 4 OUTLINE OF A MISSION-ORIENTED APPROACH TO
GEOTHERMAL ENVIRONMENTAL REGULATORY PLANNING,
RESEARCH, AND DEVELOPMENT
I. Air Quality
A. Problem Evaluation
1. Hydrogen Sulfide in Vapor-Dominated
Hydrothermal Sources
2. Hydrogen Sulfide in Liquid-Dominated
Hydrothermal Sources
3. Mercury
4. Other Contaminants (e.g. Carbon
Dioxide, Ammonia, Boron)
5. Geopressured and Hot, Dry Rock Sources
6. Overall Situation Assessment of
Existing Locations
B. Guidance and Regulatory Actions
1. Guidance
2.
3.
3ermits
Standards Pathways
ix
x
xi
1
2
2
5
5
5
6
6
7
7
11
11
14
14
14
14
15
15
15
16
17
18
18
18
19
19
19
19
19
20
20
20
20
v
-------
TABLE OF CONTENTS (CONTINUED)
C. Recommended Pathway and Associated
Information Needs 22
1. Recommended Pathway 22
2. Information Needs 23
3. Implications of ERDA Plans on Air
Pollution Regulatory Decision
Schedule 26
D. Specific Research Needs 28
II. Water Quality 31
A. Problem Evaluation 31
1. Water Quality Problems in Liquid-
Dominated Hydrothermal Sources 31
2. Overall Situation Assessment 32
B. Guidance and Regulatory Actions 33
1. Guidance 33
2. Permits 33
3. Standards Pathways 33
C. Recommended Pathway and Associated
Information Needs 37
1. Recommended Pathway 37
2. Information Needs 38
3. Implication of ERDA Plans on Water
Quality Regulatory Decision
Schedule 39
D. Specific Research Needs 39
III. Ground Water Protection 43
A. Problem Evaluation 43
1. Aquifer Contamination 43
2. Subsidence 43
3. Seismicity 44
4. Overall Situation Assessment 44
B. Guidance and Regulatory Actions 44
1. Guidance 44
2. Permits 44
3. Regulatory Pathways 45
C. Recommended Pathway and Associated
Information Needs 45
1. Recommended Pathway 45
2. Information Needs 45
3. Implications of ERDA Plans to Ground
Water Protection Regulatory
Decision Schedule 4g
D. Specific Research Needs /n
vi
-------
TABLE OF CONTENTS (CONTINUED)
IV. Radiation 53
A. Problem Evaluation 53
1. Radium and Radon 53
2. Impact of Pollution Control Technology 53
3. Overall Situation Assessment 53
B. Guidance and Regulatory Actions 53
1. Guidance to Other Federal Agencies 54
2. Standards Pathways 54
C. Recommended Pathway and Associated
Information Needs 54
1. Recommended Pathway 54
2. Information Needs 56
V. Solid Waste 58
A. Problem Evaluation 58
1. Sludge Disposal 58
2. Radioactivity Associated with Solid
Waste 58
3. Drilling Muds 58
4. Overall Situation Assessment 58
B. Guidance and Regulatory 59
Actions
C. Recommended Pathway and Associated
Information Needs 60
1. Recommended Pathway 60
2. Information Needs 60
VI. Noise 61
A. Problem Evaluation 61
1. Overall Situation Assessment 61
B. Guidance and Regulatory Actions 61
1. Guidance 62
C. Recommended Pathway and Associated
Information Needs 62
VII. Land Use Impact 63
A. Problem Evaluation 63
1. Impacts of Geothermal Development 63
2. Compatibility with Other Land Uses 64
3. Overall Situation Assessment 64
B. Guidance and Regulatory Actions 64
C. Recommended Pathway and Associated
Information Needs 64
SECTION 5 SUMMARY 65
I. Background 65
II. Geothermal Working Group Conclusions
and Recommendations 65
A. Problem Assessment and Conclusions of
the Geothermal Working Group 65
1. Environmental Standards 65
Vll
-------
TABLE OF CONTENTS (CONCLUDED)
2. Emmission and Effluent Information 66
3. Multimedia Pollutant Information 66
B. EPA Authorities and Capabilities 66
C. Strategy and Recommendations 67
APPENDIX A - GEOTHERMAL WORKING GROUP MEMBERS 73
APPENDIX B - GEOTHERMAL RESOURCE AREAS 75
APPENDIX C - STATUS OF H S CONTROL TECHNOLOGY AT THE GEYSERS 79
APPENDIX D - CHEMICAL ELEMENTS AND COMPOUNDS REPORTED IN
ANALYSES OF GEOTHERMAL FLUIDS 81
APPENDIX E - ANNUAL CHEMICAL DISCHARGES TO THE WAIKATO RIVER
FROM THE WAIRAKEI GEOTHERMAL POWER PLANT 83
APPENDIX F - EIS REVIEW 85
APPENDIX G - CURRENT ENVIRONMENTAL RESEARCH IN GEOTHERMAL
ENERGY 8 7
BIBLIOGRAPHY 95
VI11
-------
LIST OF ILLUSTRATIONS
Page
Figure Number
1 Near-Term Scenario for Geothermal Energy
Development 12
2 Estimated National Growth of Geothermal
Electric Power 13
3 Preferred Standards Path Analysis Flow
Chart for Geothermal Air Quality
Protection 21
4 Schedule Factors for Air Quality Activity 27
5 Preferred Standards Path Analysis Flow
Chart for Geothermal Water Quality
Protection 35
6 Schedule for Water Quality Activity 40
7 Regulatory Path Analysis Flow Chart for
Geothermal Waste Water 47
8 Schedule Factors for Ground Water Protection 50
9 Plan for Radiation Hazard Evaluation of
Geothermal Energy Sources 55
B-l Known and Potential Geothermal Resource
Areas in the United States 76
B-2 Areas of Potential Geopressured Resources
in the U.S. 77
B-3 Geothermal Exploration in the United States 78
IX
-------
LIST OF TABLES
Table Number
II
III
IV
V
VI
VII
VIII
G-I
G-II
Principal Air Pollution Regulatory Options
for Geothermal Industry Regulation
Status of Standards of Performance which may
Relate to Geothermal Energy
Research Topics in Support of EPA Program
Needs: Air Effects
Principal Water Quality Options for Geothermal
Industry Regulation
Research Priorities in Support of EPA Program
Needs: Water Quality
Principal Ground Water Protection Options for
Geothermal Industry Regulation
Research Priorities in Support of EPA Program
Needs: Ground Water Protection
Key Milestones in Proposed ERDA/EPA Geothermal
Activity
Current ERDA Environmental Studies
Current Research in Geothermal Energy
Environmental Impact
24
25
29
36
41
46
51
69
88
90
-------
ACKNOWLEDGEMENTS
Credit is due to the members of the various EPA staffs who both
guided the direction and critically examined the content of this
Position Paper during its development. These individuals and their
staff affiliations are listed in Appendix A.
Thanks are also due to Mr. George Swetnam of the METREK Division
of the MITRE Corporation who researched and produced much of the
technical material in the Position Paper.
xi
-------
SECTION 1
INTRODUCTION
The Geothermal Advisory Council (GAG)* has been established as
the forum in which the Energy Research and Development Administration
(ERDA) will coordinate interagency activities relating to its develop-
ment of viable geothermal energy technologies. The Administrator of
the Environmental Protection Agency (EPA) has designated the Assistant
Administrator for Research and Development as his representative to
the GAG, which is chaired by the Assistant Administrator for Solar,
Geothermal, and Advanced Energy Systems of ERDA. EPA is also repre-
sented on the GAG by its Office of Planning and Management on matters
relating to Agency policy.
As one of its initial actions, the GAC requested EPA's position
on environmental standards for the emerging industry, urging EPA
to immediately set interim standards. In order to initiate the
formulation of an Agency-wide position on this question, within the
context of existing priorities and commitments, EPA has formed the
Geothermal Working Group from representatives of the concerned
program and enforcement offices (Appendix A). This group was formed
to address the following questions:
1. What potential environmental problems does EPA foresee as
associated with the emerging geothermal industry?
2. What courses of action are open to EPA in the Research,
Development, and Demonstration phase of geothermal develop-
ment in order to control and minimize the environmental
impacts of the mature commercialized phase of this emerging
industry?
3. Given a course of action, an indication of its relative
priority and the immediacy of its need, how can EPA best
approach the question of environmental guidance and regula-
tion and required supporting research for the geothermal
industry?
This document is the first step in a process that will, through
discussions within EPA and dialogues with ERDA, answer these questions.
The name of the Geothermal Advisory Council (GAC) has been changed to
the Interagency Geothermal Coordinating Council (IGCC). Wherever
appearing in this document, the term GAC should be considered as the
same as IGCC.
-------
I. PURPOSE
This paper presents an appraisal of the environmental problems
presented by geothermal energy, as seen by an EPA Working Group com-
posed of representatives of:
• The Office of Water and Hazardous Materials, represented by
the Office of Water Planning and Standards (OWPS) and the
Office of Water Supply (OWS),
• The Office of Air and Waste Management, represented by the
Office of Air Quality Planning and Standards (OAQPS) and the
Office of Radiation Programs (ORP),
• The Office of Planning and Management, represented by the
Office of Planning and Evaluation (OPE),and
• The Office of Research and Development, represented by the
Office of Energy, Minerals, and Industry (OEMI).
The paper also presents the recommendation of the Working Group
to the Agency for consideration in choosing an Agency-wide approach
to the geothermal industry. Such a unified approach will assist the
program offices by providing a coherent framework for planning. It
will support the regional and enforcement offices by providing the
basis for a coherent Agency approach. It will aid the Office of
Research and Development by indicating a favored regulatory approach
to the problem toward which supporting R&D can be focused. Finally,
it will assist the geothermal industry by initiating the coordination
of EPA action on pollution limits and required control techniques.
II. OBJECTIVE
The objective of the paper is to identify EPA's areas of concern
and responsibility and to present this position to the Agency for
approval and incorporation into Agency plans. The paper will also
serve to consolidate EPA's view for the Geothermal Advisory Council
by providing the following information:
• A preliminary EPA review of specific environmental impacts
associated with geothermal energy development,
• An outline of the regulatory pathways and non-regulatory
options available to the respective program offices of EPA
with specific recommendations,
-------
• An outline of the timing of specific ERDA development plans
and the associated EPA decision deadlines required for
guidance to the developing geothermal industry, as well as to
regional and enforcement offices,
• An outline of information needs associated with preliminary
problem evaluation and with supporting the specifically
recommended regulatory approaches, and
• A list of research needs and milestones which EPA will need
to meet its information and decision deadlines.
-------
SECTION 2
EPA STRATEGY
I. WHY EPA SHOULD ADDRESS GEOTHERMAL ENERGY
Among the new sources of energy that can help supply the future
needs of the United States is geothermal energy, the heat contained
in the earth's interior. The total supply of such energy is uncertain,
partly because many undiscovered resources are believed to exist and
partly because new techniques are needed for extraction and use.
However, several geothermal fields, including one in the U.S.,
have proven commercially successful, and research is under way to
increase the number and kinds of resources that can be tapped.
Although the environmental impact of geothermal energy develop-
ment may be less intense or widespread than that of some other
energy sources, there are several reasons why it should receive
prompt attention within the Environmental Protection Agency. The
national emphasis on energy independence has focused attention on
unconventional energy sources, and the Energy Research and Development
Administration has under way programs to develop the most promising
candidates, among which is geothermal energy. To the developer of a
new energy technology, environmental protection presents a set of
problems that must be solved, but that are ill-defined both because
the environmental effects may be unclear and the stringency of EPA's
eventual regulatory actions may be hard to judge.
A. Organizational Background
Because geothermal energy raises questions that concern a
number of Federal agencies, the interagency Geothermal Advisory
Council (GAG) has been formed to facilitate the search for appropriate
answers.
The GAG was formed to coordinate those Federal plans, activities,
and policies that are related to or impact on geothermal energy.
The Council is comprised of three panels, a Resources Panel, a
Research and Technology Panel, and an Institutional Barrier Panel.
The Institutional Barrier Panel is responsible for assessing legal,
environmental, regulatory, and other aspects of Federal, state, and
local government policy. This panel, chaired by the FEA representa-
tive, recommended that the GAC promulgate interim environmental
standards for the geothermal industry.
ERDA and the Federal Energy Administration have, through the
GAC, pressed EPA for action regarding the environmental regulatory
-------
guidelines that may be required of geothermal energy development in
order that the emerging industry might develop within clear environ-
mental limits. It was argued that failure of EPA to respond will
force geothermal energy development to proceed without knowledge of
the protective measures it must eventually incorporate or the costs
they will exact, and will, for lack of Federal guidance, cause
individual states to set standards which may vary greatly, thus
undermining confidence and investment potential in the industry.
Geothermal energy conversion is but the first of a number of
emerging energy technologies to require formal consideration by EPA
for possible regulatory actions. There are three characteristics
which are common to all the new energy technologies and which should
be addressed by EPA in formulating its regulatory approach:
• Information is scarce on pollutant emissions and effluents, on
concentrations, and on control techniques for the new develop-
ing technologies being considered by the industry and ERDA.
• Government-stimulated development affords an opportunity for
EPA to influence the development and demonstration of tech-
nologies which are inherently more environmentally protective
than other alternatives.
• Government-stimulated development plans for new technologies
do not in general allow enough time for EPA to gather informa-
tion and develop regulatory guidelines prior to commercial
deployment without a special effort.
II. EPA'S APPROACH TO THE PROBLEM
A. Background
EPA finds itself in a new role in the scheduled development
of geothermal energy. In the past EPA has generally been in a
reactive mode, attempting to correct environmental damage after the
fact. In the emerging energy technologies, including geothermal
energy, the Agency has the opportunity to minimize eventual adverse
effects and control costs by advanced planning. It can do this in
such a way that it fosters energy technology development and guides
it along environmentally protective paths. In order for the Agencv
to take the initiative in the environmental area it must do so now
in the early stages of energy technology development. Research is'
required to support the regulatory and guidance mechanisms the Agencv
chooses to employ. Because time is an important factor in research
it is necessary for EPA to make immediate decisions concerning its
approach to geothermal energy and the direction of associated
-------
supporting research. The lack of a coordinated geothermal position
will put EPA in a less effective reactive mode, reducing EPA influence
over the type of processes and equipment selected.
The accelerated pace of geothermal energy development now being
considered by ERDA can be expected to have important effects on the
choice of action open to EPA. Because environmental protection
criteria are a matter of concern to geothermal energy developers and
their potential financial backers, whatever approach EPA takes is
bound to have some effect on the rate of development.
B. The Geothermal Working Group (GWG)
In order to address this problem, the Deputy Assistant Administra-
tors of the concerned EPA program offices and ORD met to discuss
the proper response to GAC's recommendations, and established a
Geothermal Working Group (GWG) within EPA to identify the environ-
mental problems foreseen for the geothermal energy industry, the appro-
priate regulatory pathways that EPA might wish to adopt, and the
consequent information and research needs which might be addressed,
both by EPA and by other agencies. The GWG was also instructed to
address itself to the question of how EPA should approach environ-
mental regulation and guidance for the geothermal industry as a part
of the response to the GAC. The issue of regulatory options is
significant in that geothermal energy represents the first example of
a number of emerging energy industries. These industries are now
choosing among alternative energy technologies, and EPA needs to be
informed in order to influence their choice.
III. RECOMMENDED STRATEGY
The Geothermal Working Group believes that immediate setting
of geothermal environmental standards is unnecessary. This is
because (except in case of dry steam) geothermal technologies
are not developed well enough for adequate pollutant and effects
information to be available. Adequate and timely pollutant and
effects information should be developed in parallel with the various
evolving geothermal technologies, in order that environmentally pro-
tective options may be demonstrated and identified.
The GWG has also concluded that EPA should not deal with geo-
thermal facilities only on an _ad hoc basis as ERDA and industry plans
become apparent through New Source Review, EIS Review, and other
actions. Without advance national planning and guidance, inconsistent
approaches might evolve in different regions, especially because
complete information is not available to ensure the applicability
of existing regulatory and review procedures to the diverse set of
-------
geothermal resources and conversion technologies. Where new
extraction techniques are being developed, the development period
allows time for EPA to gather specific information on environmental
impacts, control techniques, and cost factors.
Even though it is inadvisable to develop standards immediately,
the high national priority on alternative energy sources requires that
EPA give special attention and assistance to the development of
geothermal energy, as well as other new energy technologies. There-
fore, the GWG recommends a strategy of cooperative Research, Develop-
ment, and Demonstration (R,D&D) with ERDA.
A positive approach to geothermal environmental regulation is
to regulate known problem pollutants while collecting data on other
emissions and testing control technology. This approach must involve
ERDA's cooperation in thorough emissions characterization and control
technology evaluation at the pilot and demonstration plant level. It
minimizes EPA program resource commitment, yet offers a comprehensive
assessment of environmental, health, control, and cost factors prior
to standards development. It provides EPA with the opportunity to
influence the evolution and choice of new geothermal technologies
toward environmentally protective alternatives. It provides the
agency with an up-to-date information resource on specific technologies
that can be utilized in the normal regulatory and environmental
impact statement review processes. Environmental Impact Statement
review, New Source Review, Non-Significant Deterioration Review, and
National Pollution Discharge Elimination System Review are required
at both the demonstration and first-generation commercial scale, so
that basic regulatory procedures would still be involved. But, it is
not clear how completely these are applicable to the impacts of
geothermal development.
In order to implement this strategy, the GWG recommends that EPA
take the following steps:
o Establish a formal working relationship between EPA and
ERDA's Division of Geothermal Energy that will provide for
continual contact at the technical level as an integral part
of the EPA/ERDA R,D&D program.
o Issue by mid-1977 a preliminary guidance manual on which
to base the design of demonstration installations, and to
provide environmental criteria for permit issuance and EIS
review.
-------
Adopt a regulatory* mission-oriented research program,
undertaken in cooperation with ERDA's development program
and structured to generate environmental impact and control
information as it is required by the development schedule
for geothermal energy sources.
Evaluate, according to a long-range, but flexible, schedule,
the need for special standards based on information gathered,
Develop, where necessary, standards in time to provide
adequate environmental protection measures in advance of
commercialization.
*In this document, 'regulatory' is understood to include standard
setting as well as formal regulation.
-------
SECTION 3
EPA PLAN OF ACTION
To implement the geothermal strategy discussed above, EPA must
continually track the ERDA plan for geothermal development and select
the best program of cooperation and guidance.
I. ERDA'S GEOTHERMAL DEVELOPMENT PLANS
Figure 1 presents a summary of one national development scenario
under consideration by ERDA. It is based on the following assumptions:
(a) An attempt is made to reach the goals cited in Definition
Report: Geothermal Energy Research, Development & Demon-
stration Program (ERDA-86), subject to reasonable develop-
ment cycles.
(b) Each resource site is initiated with a small (50 MW output)
plant, with development on a commercial scale after success-
ful operation has been demonstrated.
(c) Development of resource sites is keyed to current production
or exploratory drilling operations.
The implication of such a scenario to EPA is that the next five
years are expected to see the development of several fundamentally
different types of geothermal resources such as liquid-dominated
hydrothermal* (for which few data and only one environmental installa-
tion exist), as well as geopressured and hot dry rock, for which
virtually no environmental data exist and no installations are in
operation.** The development of hot dry rock systems is not envisioned
until 1985, but thermal extraction experiments which are planned for
1978 and 1981 will merit EPA's attention. Even in the case of
existing technology for vapor-dominated systems at the Geysers,
environmental problems due to ti^S emissions have arisen and must be
solved if development of this resource is to recommence in an environ-
mentally acceptable manner.
Figure 2 presents the estimated growth curve of geothermal
energy implicit in ERDA-86. Because of the steady pace of antici-
pated growth, EPA action within the next five years will be in time
to affect the majority of the capacity projected for 1990.
*ERDA includes volcanic resources in the hydrothermal part of its pro-
gram.
"""Locations of the currently known and potential geothermal resource
areas appear in Appendix B.
11
-------
ADDITIONAL INCREMENTS OF
CAPACITY AT THE GEYSERS
DEVELOPMENT OF
LIQUID-DOMINATED SYSTEMS
DEVELOPMENT OF
GEOPRESSURED SYSTEMS
DEVELOPMENT OF
HOT, DRY ROCK SYSTEMS
ESTIMATED CAPACITY
BROUGHT ON LINE, IN
MEGAWATTS (NOTE 3)
2UMULATIVE CAPACITY ADDED
1975
(NO
TE 11
1
270
270
1
290
560
E
425
985
1980
I
I II
I
415
1400
I
Illl 1
E
525
1925
I
Mill
(NO!
165
2090
I
E2)
620
2710
I
linn
510
3220
1985
I
I II
I
i
500
3720
500
4220
1990
NOTES:
1. EACH TICK REPRESENTS ONE PLANT BROUGHT ON LINE
2. E DENOTES A THERMAL EXTRACTION EXPERIMENT
3. ESTIMATES NOT AVAILABLE BEYOND 1987
FIGURE 1
NEAR-TERM SCENARIO FOR GEOTHERMAL ENERGY DEVELOPMENT
-------
5000
<
<
^4000
3000
o 2000
1000
PLANNED
1977
CAPACITY
OF
GEYSERS
1975
1980
1985
1990
NOTE: GROWTH THROUGH 1980 IS CHIEFLY FROM
ADDITIONS TO THE GEYSERS, PLUS EARLY
IMPERIAL VALLEY INSTALLATIONS
FIGURE 2
ESTIMATED NATIONAL GROWTH OF GEOTHERMAL ELECTRIC POWER
13
-------
II. IMPLICATIONS OF THE ERDA PLAN
When the process of developing environmental regulation is com-
pared to the planned development of geothermal energy, it becomes
evident that special measures will be required to avoid the risk of
an uncontrolled environmental impact. As the following sections
make clear, appropriate regulation will require a considerable
research effort. In order to develop this information on an industry-
wide/ Federal basis and in a timely manner, it is recommended that a
mission-oriented program of coordinated research and regulatory
planning be adopted, as discussed below.
III. A MISSION-ORIENTED APPROACH TO REGULATORY PLANNING AND
ENVIRONMENTAL RESEARCH FOR THE EMERGING GEOTHERMAL INDUSTRY
An orderly, Agency-wide approach to an emerging industry demands
a coherent set of program office plans. These plans should be
based on a clearly-defined regulatory approach and should delineate
specific decision points related to ERDA's geothermal development
program. Only in this way can a balanced environmental research
program be formulated.
The development of a balanced research program is a challenging
task of weighing the areas of concern against the available funds.
In order to maximize the effectiveness of EPA efforts in view of
the accelerated pace of geothermal resource development, the program
should be mission-oriented, that is, environmental research should
be planned to focus on the most critical areas of environmental con-
cern and Agency responsibility. Research should be an integral
element in a program arranged to develop specific knowledge at the
time it is needed for regulatory decision-making related to geothermal
energy development on an industry-wide basis. Development of such a
program involves a number of tasks:
A. Problem Evaluation
The first step is examination of the development scenarios in
order to recognize specific environmental problems and requirements
for guidance and regulation for development of each type of geothermal
resource. This assessment will be developed by ORD in concert with
and for review by involved program and regional offices.
B. Regulatory Pathways and Guidance
From a knowledge of the environmental problem, EPA can proceed
to determine the appropriate form of regulatory action, and how the
necessary environmental action is related to generic geothermal
14
-------
development schedules. In view of the anticipated early development
of liquid-dominated hydrothermal sources, it may be difficult to
issue definitive regulations for initial installations in the time
available. In such cases, a target date for EPA evaluation of the
situation should be proposed, supplemented by early guidelines for
the more critical aspects of the problem.
C. Regulatory Decision Schedule
Having decided upon the approach best suited to the resource
types and their environmental impacts, EPA can draw up a regulatory
decision schedule for each type of geothermal technology. This
schedule should be incorporated into the plans of each respective
regulatory office within EPA. This schedule will provide guidance
for each resource type late enough to profit from information gained
from initial experiments and installations, but early enough to
affect the choice of which of new technology should expand on a
commercial scale. This schedule should be updated annually to
reflect actual industry progress.
D. Recognition of Required Supporting Information
From the schedule of expected activity, the next step is to
establish the information required to support each stage. The
required information will depend on:
(a) The resource type;
(b) Anticipated emissions and other effects (problem assessment);
(c) Whether the development is a thermal extraction experiment,
a pilot or demonstration plant, or a commercial power
station; and,
(d) Whether interim guidance, standards or final regulatory
action is appropriate.
These information needs will be based on the favored regulatory
pathway chosen by each respective regulatory office within EPA.
E. Identification of Research Program Needs
Once the pattern of information required by the regulatory
offices and associated deadlines have been determined, it should be
examined for areas of common need among geothermal resource types. A
special effort must be made to determine what information is avail-
able or may be expected to become available from environmental
15
-------
research pertaining to other research areas. The end product of this
step is a scheduled list of research information needs that are
unique to geothermal energy or which have higher priorities in the
geothermal field than in other research areas. The list should be
classified not only by when items are needed, but also according to
the specific geothermal resource type to which they apply. Research
topics common to more than one resource type are grouped together,
with a schedule determined by the resource type having the earliest
anticipated development.
F. Research Program Definition
When the above process is complete, EPA will be in position to
combine the specific research topics into a coordinated research
program. This should be done in the light of environmental research
being performed by other agencies and industry, in order to minimize
impact on R&D resources. This step will involve comparing the re-
quirements of time and information with the funding resources and
organizations available to perform the required work. EPA offices
which have a strong internal capability will wish to divide the
program into internal and contractor-supported efforts to make the
best use of both resources. Research topics having a common theme
may be combined and awarded to specific contractors with special
ability in the field. The program subjects at this point should
include the title of each effort, objectives of the research, relation
to specific resource types and problems, the end product expected of
the research unit, and the required completion date.
A mission-oriented regulatory planning and research program will
support EPA's responsibilities and activities in geothermal environ-
mental protection and regulation, by helping to ensure that the
required information is available when it is needed. Because it is
coordinated with ERDA schedules and oriented to EPA's mission, it will
provide a firm, logical basis for determining long-term R&D budget
requirements.
16
-------
SECTION 4
OUTLINE OF A MISSION-ORIENTED APPROACH TO GEOTHERMAL ENVIRONMENTAL
REGULATORY PLANNING, RESEARCH, AND DEVELOPMENT
Based on the factors discussed in the preceding section, the Geo-
thermal Working Group has recommended that environmental aspects of
the emerging geothermal industry should be addressed on a mission-
oriented basis. That is, environmental regulatory planning and its
supporting R&D effort should be coordinated with the evolving develop-
ment schedule of alternative technologies and resource types as planned
by ERDA and the industry. This section presents the GWG outline of the
mission-oriented approach. It evaluates the significance of geothermally
related environmental problems as understood at present, outlines the
factors determining the best approach to regulation, and presents a
brief list of information needs around which an R&D program should be
formulated to support the recommended regulatory approach. The
anticipated impacts of geothermal energy are discussed along media
lines: air quality, water quality, ground water, radiation and other
effects.
17
-------
I. AIR QUALITY
A. Problem Evaluation
Geothermal fluids are seldom clean, but commonly contain a
number of chemical elements and compounds, some of which may escape
from the exhaust steam, cooling towers, or by other paths. Among
those known to escape in gaseous form are hydrogen sulfide, mercury,
and ammonia. Radon will be discussed in the section on radiation.
The environmental threat to air quality has not been fully assessed,
but attention has already been drawn to the problem of hydrogen sulfide.
1. Hydrogen Sulfide in Vapor -Dominated Hydrothermal Sources
Most of the available information on geothermal pollution in the
U.S. comes from The Geysers, California, where 15 year old technology
has utilized a rare, vapor dominated resource since the 1960 Ts in the
only commercial U.S. geothermal power plant. At The Geysers, the steam
contains from 5 to 1600 ppm H^S depending on the well, averaging 222 ppm.
There are a total of about 70 wells extending over about 1900 hectares.
An average of 1.8 to 2.3 kg of H2S per MWh is released to the atmosphere,
mainly from the condensate cooling towers. Uncontrolled, The Geysers at
400 MW emits 725 kg of I^S per hour. A large 900 tonne per day, un-
controlled kraft pulp mill would emit 360 kg of l^S per hour.
The Geysers has a history of odors, and there are complaints
today directed at Pacific Gas and Electric (PG&E) , the owner. They
are required to meet the California ambient t^S standard of 30 ppb ,
an "average" odor threshold limit. Carl Weinberg, PG&E, estimates
that this limit is probably exceeded from 1/2 to 1 percent of the
time, mainly due to weather conditions. It is not known whether
H2S may create any more formidable problem than odor in the concen-
trations released from geothermal energy applications. Concentra-
tions of 300 ppb have reduced growth in alfalfa and grapes. The
gas is fatal to humans in 30 minutes at 600,000 ppb.
The average H2S content of other dry-steam fields varies from
186 ppm at Showa-shinzan, Japan to 900 ppm at Lardarello, Italy. Be-
cause of the large differences in chemistry of various geothermal sites
this resource may prove analogous to low and high-sulfur coals. Dr.
Martin Goldsmith, California Institute of Technology, estimates that
the amount of sulfur released at The Geysers is equivalent to that
emitted by an uncontrolled fossil-fueled plant of the same size burning
low-sulfur oil. Appendix C discusses the status of I^S control tech-
nology at The Geysers.
18
-------
2. Hydrogen Sulfide in Liquid-Dominated Hydrothermal Sources
Hydrogen sulfide is also present in many liquid-dominated
hydrothermal sources, but only the one at Wairakei, New Zealand, has
a long experience of commercial exploitation. This plant, of 145 Mega-
watts output, releases H2S at about 14 kg/hour in the stack gas. At the
developmental installation at Cerro Prieto, Mexico, a 32 Megawatt output
unit is reported to emit 355 kg of I^S per hour. The lack of proportion
are due largely to differences in source concentrations. Similar levels
could cause significant problems at U.S. sites across the border from
Cerro Prieto in the Imperial Valley, without appropriate controls.
3. Mercury
Mercury is present in many geothermal wells, and early data indi-
cate that it tends to follow the vapor phase in flashing and evapora-
tion. Some measurements of mercury emissions are now being collected
by Battelle-PNW at The Geysers and at Cerro Prieto. The results should
assist EPA in determining whether an environmental problem exists.
4. Other Contaminants (e.g. Carbon Dioxide, Ammonia, Boron)
Geothermal hydrothermal sources frequently contain a number of
other substances. Sources vary widely in chemical constitution; this
fact should be taken into account in estimating the impact of geo-
thermal development. Appendix D presents a list of chemical elements
and compounds that have been reported in geothermal fluids.
5. Geopressuredand Hot, Dry Rock Sources
Other types of geothermal sources, such as geopressured and hot,
dry rock, are still in the early planning stages. The probable effect
of such sources on air quality is not clear.
6. Overall Situation Assessment of Existing Locations
The only operating U.S. geothermal power plant is in California,
where PG&E must meet a state-imposed odor threshold regulation, and
the H2S odor threshold is well below the levels at which toxic effects
occur.
Other air pollution problems have not become apparent, but may
be involved in development of sources other than The Geysers, and l^S
may present health or welfare (e.g., crop and materials damage) prob-
lems at other sources. The GAC has now specifically raised the
question of the need for an ambient H2S standard that would provide
a reference which states might adopt and that would allow the expanded
19
-------
development of The Geysers from 500 MW to 2300 MW over a 10-year period*
if the State of California were to reevaluate its regulations.
B. Guidance and Regulatory Actions
1. Guidance
The first step in terms of Agency commitment requires an active
role in advising its own regional and enforcement offices, state con-
trol agencies, ERDA, and the industry. In addition to gathering air data,
EPA would analyze it and make recommendations. The extent of involve-
ment could vary, but as a minimum would require an initial effort to
obtain and evaluate existing data on known geothermal air pollutants and
effects. Direct input to ERDA programs and state air pollution control
agencies would be the next step. A guideline manual provides the technical
basis for this effort. At the highest level of effort under this approach,
EPA would advise agencies and the industry of appropriate ambient or
emission limits, recommend control technology research to ERDA, perform
additional research in house, and take an active role in geothermal-related
environmental decisions.
2. Permits
The GWG and the Division of Stationary Source Enforcement do not con-
sider the present mechanisms of New Source Review and Non-significant
Deterioration Review to be an adequate approach when applied to geo-
thermal installations. New Source Review addresses only the pollu-
tants for which air quality criteria have been established: carbon
monoxide, particulates, sulfur oxides, hydrocarbons, oxides of ni-
trogen, and photochemical oxidants. Non-significant Deterioration
Review addresses only sulfur dioxide and particulate emissions.
None of these pollutants appears likely to be significant in geo-
thermal industry applications. Thus, New Source Review and Non-
significant Deterioration Review—as presently applied—would serve
merely to give rubber-stamp approval to a geothermal installation.
3. Standards Pathways
The Office of Air Quality Planning and Standards (OAQPS) has
a number of regulatory options regarding pollutant control, depending
on the type of source, effects, and other factors. Figure 3 shows
"Source: 0. Citron, et. al., Report on the Status of Development of
Geothermal Energy Resources in California, 5040-25, California Insti-
tute of Technology, Pasadena, California, 31 March 1976.
20
-------
PROBLEM
ASSESSMENT
DECISION
PROCESS
ARE LAND-USE
AND TRANSPORTA-
TION CONTROL
NEEDED?
HO
V
ARE CONTROL
METHODS KNOWN?
t
ARE STATIONARY
SOURCES NUMEROUS
AND DIVERSE?
T
I
.1-
ARE MAJOR STA-
TIONARY SOURCES
CONTROLLED
BECAUSE OF
CONTROL OF OTHER
POLLUTANTS?
t |_
1
CAN PROTECTION
OF HEALTH BE
JUSTIFIED UNDER
SECTION 112?
NO
1
1
JES
HILL NESHAP
HAVE SIGNIFICANT
IMPACT ON
WELFARE EFFECTS?
VES
1
SOURCE: OAQPS/ESED, REFERENCE 21
PREFERRED
REGULATORY
APPROACH
1 . Where "yes" or "no" is ind I cated , answer must be concl us I ve .
Answers such as significantly, maybe, perhaps, could be, or
conclusive opposites to the indicated answer follow the
undesignated path.
2. NAAQS means Section 108, 109, HO as well as Section 11 1 (b) .
3. NSPS means Section 1 1 1 (b) and Section lll(d) as welt as
Section 15-
b. NESHAP means Section 112 and Section 1 1 1 (b) .
5. Mobile means Section 201
6. "Land-use and transportation controls" means any measures
other than permanent emission reduction, such as:
intermittent control, tall stacks, traffic control,
fuel switching, development of transit systems, site
7. The term air quality goal means concentrat i on-t ime
relationships which separate effects from no-effects;
contamination to the goal is permissible.
8. Dose-response means a relationship between pollutant
dose and effects, independent of exposure route.
FIGURES
PREFERRED STANDARDS PATH ANALYSIS FLOW CHART
FOR GEOTHERMAL AIR QUALITY PROTECTION
-------
the standards path analysis applicable to geothermal industry sources
used by OAQPS. The principal regulatory possibilities are:
• Establishment of National Ambient Air Quality Standards
(NAAQS) under Section 108 of the Clean Air Act.
• Establishment of New Source Performance Standards (NSPS)
under Section 111 of the Act.
• Establishment of National Emissions Standards for Hazardous
Air Pollutants (NESHAP) under Section 112.
Under each of these regulatory approaches, a wide range of
standard-setting activity is possible:
• Standards can be established based on existing information
(e.g., 90% control of hydrogen sulfide emissions as an NSPS).
• R&D efforts (ERDA and/or EPA) can be initiated to explore
attainable emission and technology levels. Standards would
be based on this data base.
• A full-scale standard-setting effort could be initiated,
including health studies, control technology evaluation,
and economic effects, resulting in nationwide standards.
Selection of the appropriate option depends, of course, on the
nature and extent, of the problem geothermal plants are expected to
present as this energy resource is developed.
C. Recommended Pathway and Associated Information Needs
1. Recommended Pathway
Of the three alternatives available to EPA, GWG concludes that the
most feasible approach for both OAQPS and the Division of Stationary
Source Enforcement (DSSE) is the establishment of New Source Perform-
ance Standards under Clean Air Act Sections lll(b) and (d) .
The establishment of ambient air quality standards under Section
108 would require supporting information on the health effects of
the pollutant in question. In addition, the designation of a pollu-
tant as a criteria pollutant under Section 108 requires that emissions
be controlled from all sources, implying a massive effort to review
available control technology from sources other than geothermal
power plants.
22
-------
Action under Section 112 to establish a NESHAP requires informa-
tion that "the pollutant may cause, or contribute to, an increase in
mortality or an increase in serious irreversible, or incapacitating
reversible, illness." Section 112 action is not considered likely
because available information does not indicate that the emissions
from geothermal installations are likely to cause health problems
of that magnitude.
The New Source Performance Standard, in contrast, provides an
opportunity to control geotherraal emissions on an industry-specific
basis and thus offers an effective and selective approach to the
problem. Table I compares the information needs and timing for
each of these regulatory options.
The Emission Standards and Engineering Division, QAQPS, has under
consideration several NSPS that are relatable to potential geothermal
air pollutants. Although these standards apply to other industries,
information gathered in their development may be useful in evaluating
whether NSPS should be needed for geothermal applications. The sources,
affected facilities, and status (as of November 1, 1976) appear in
Table II.
2. Information Meeds
Based on the selection of NSPS as the most feasible approach, the
path analysis diagram (Figure 3) requires the acquisition of certain
information to support eventual NSPS promulgation.
Because the geothermal industry is expected to develop in other
states in addition to California, GWG and OAQPS recommend a two-phase R&D
program to (1) quantify air pollution emissions and ambient air im-
pact at The Geysers and the Imperial Valley and extend this informa-
tion to other geothermal sources which may be developed and (2)
evaluate air pollution emission control technology for these energy
resources.
a. Atmospheric Emissions Studj.es. The first step would be an
extensive literature search followed, if necessary, by source sampling
at emission points at The Geysers such as direct contact condensers,
gas ejectors, and cooling towers. PG&E reports that an eight-station
monitoring network, run by Stanford Research Institute, is deter-
mining actual ambient I^S concentrations. In addition to ^S measure-
ment, samples should be analyzed for ammonia, mercury, and other organics
and trace metals.
The University of California, Lawrence Livermore Laboratory, is
currently conducting an extensive baseline study of the Imperial
23
-------
TABLE I
PRINCIPAL AIR POLLUTION REGULATORY OPTIONS FOR GEOTEERMAL INDUSTRY REGULATION
PRINCIPAL
REGULATORY
STRATEGY
CLEAN AIR ACT
SECTIONS
INVOLVED
KEY FACTORS
LEAD ORGANIZATION
FOR IMPLEMENTATION
INFORMATION
REQUIREMENTS
TIME REQUIRED
TO DEVELOP
REGULATION
National Ambient
Air Quality Standard
108, 109, 110
• Pollutant oriented
• Most difficult to write;
requires control of all
emission sources: acts
via state implementation
plans
States
Health and Welfare
Information
Control Technologies
and Costs
Effect of emission reduc-
tions en air quality
2-6 years or more; addi-
tional time is required
to develop and implement
State Implementation
Plans
New Source
Performance
Standard
lll(b), (d)
• Source oriented
• Specific to industry
• Specific to pollutant
(see note 1)
EPA
Administrative judg-
ment of contribution
to air pollution
Information on effec-
tiveness and costs of
control techniques
Typically 3 years
National Emissions Standard
For
Hazardous Air Pollutants
112
• Pollutant oriented
• Health effect involves
mortality, serious,
irreversible, or in-
capacitating reversable
human illness
EPA
Knowledge or emission
level providing ample
margin of public safety
Typically 2 years
(see note 2)
Notes: 1 If pollutant is neither a criteria pollutant under Section 108-110 nor a hazardous pollutant
Under Section 112, states must apply similar control to existing sources of the same
industrial type, based on best available control technology.
2 Regulatory process is usually expedited due to public pressure to eliminate health hazards.
-------
TABLE II
STATUS OF STANDARDS OF PERFORMANCE WHICH MAY RELATE TO GEOTHERHAL ENERGY
SOURCE
Sulfur Recovery in
Petroleum Refineries
Kraft Pulp Mills
Carbon Black Plants
Gasification of Fossil
Fuels
Natural Gas and Crude
Oil Production
Kraft Pulp Mills
lll(d)
Primary Copper, Zinc,
and Lead Smelters
AFFECTED FACILITY
Standards i
Sulfur recovery plants
Digesters, lime kiln,
recovery furnace, washer,
evaporator, strippers,
smelt and BLO tanks
Technical
Furnace
Coal gasification plants
Oil gasification plants
Sulfur recovery plants
Existing digesters, lime
recovery furnace, washer,
evaporator, strippers,
smelt and BLO tanks
Roasters, smelters and
converters
POLLUTANT
n Preparation for
so2
Sulfides
Total reduced
sulfur (TRS)
Studies (Post Sci
Particulate
CO
H_S
2
Hydrocarbons
SO & sulfides
z
SO & sulfides
£.
Total reduced
sulfur (TRS)
Arsenic
OPACITY
REGULATION
Proposal
eening)
Included
Included
PROMULGATION
DATE
REMARKS
Proposed 10/4/76
Proposed 9/2A/76
Typographical
Corrections
10/29/76
Scheduled Proposal
9/77
Scheduled Proposal
9/77
Scheduled Proposal
9/77
Scheduled Proposal 1/78
The NSPS will be
promulgated about
7/77; lll(d) after
this date
Assessment Report
complete - Decision
to set standards to
be made - 4/78
-------
Valley of California and plans to perform further measurements as
geothermal development proceeds. Other sites (Appendix B) should
be monitored as development occurs.
b. Dose-response and Welfare Data. Because most of the emissions
anticipated from geothermal projects are also found in other indus-
trial processes, EPA has specific health and ecological effects infor-
mation from specific atmospheric concentrations. This should be docu-
mented for geothermal applications. Research on health and ecological
effects can be limited to characterizing and screening of potential
new pollutants at new sites. Such studies need to be done on a case-
by-case basis.
c. Control Methods. Unless the test data indicate otherwise,
control method evaluations should concentrate on hydrogen sulfide
capture at The Geysers, with evaluations of each new demonstration
site on an individual basis. Effectiveness of control systems should
be determined from two viewpoints: first, on percent removal effi-
ciency; second, on overall reduction of environmental impact, includ-
ing whether the steam can continue to be controlled during turbine
and well startup, shutdown, and malfunction periods and whether
noise, radiation, solid waste, and water pollution problems are
diminished or increased by application of the air pollution control
system.
If a choice of energy extraction techniques is available, ERDA
should be influenced to include the costs of environmental impact and
control in its evaluation. That is, the costs associated with environ-
mental problems should be estimated and weighed along with the value of
the energy recovered, capital investment, and other factors.
3. Implications of ERDA Plans on Air Pollution Regulatory
Decision Schedule
The accelerated pace of geothermal energy development as pro-
jected by ERDA reflects the national priority given to development
of new energy sources. This priority also merits attention by EPA, and
funds to support the necessary studies should be made available, directly
and through cooperation with ERDA. GWG recommends a corresponding accel-
eration of EPA's evaluation of geothermal energy to provide early identi-
fication of problem areas, define needed regulation, and indicate where
air pollution control is required. As implied by ERDA time lines in
Figure 4,* different type of geothermal resources will be developed on
'^Figures 4, 6, and 8 are based on: A National Plan for Energy Research,
Development, and Demonstration; Creating Energy Choices For the Future!
Volume 2: Program Implementation.. ERDA 76-1T 1976. '
26
-------
RESOURCE TYPE
DRY STEAM
THE GEYSERS
LIQUID- DOMINATED
HYDROTHERMAL
IMPERIAL VALLEY
OTHER HYDROTHERMAL SITES
E.G. , COSO H.S. , BEOWAWE
GEOPRESSURfO
LOUISIANA, TEXAS GULF COAST
HOT, DRY ROCK
SCHEDULE ALSO APPLIES TO AIR IMPACTS
FROM RADIOACTIVE EMISSIONS
1975
ERDA
EPA
ERDA"'''
EPA
ERDA
ERDA
ERDA
1980
ADDITIONAL
12/77
EVALUATE EMISSIONS
AND CONTROLS
1 ^
L'
M
PREPARE GUIDANCE
OR REGULATION '
4ITIAL GUIDANCE
WUAL TO INDUSTRY
PREPARATORY EXPERIMENTS
DESIGN OF INITIAL NSTALLATION
1985
INCREMENTS OF CAPACITY
•12/79
CHARACTERIZE EMISSIONS FOR H,S Hg, ETC.
EVALUATE PROBLEM
1
M
npERfl
TITN np TEST INSTALLS! f)NS
DES GN OF COMMERCIAL EQUIPMENT
' 2/80.1 DEVELOP STANnARnS
EVALUATE CONTROL TECHNOLOGY "] IF REQUIRED '
N TIAL GUIDANCE
ANUAL TO INDUSTRY
_-^-~
L
— i
FINAL GUI DANCE MANUAL-
TO INDUSTRY
EXPLORATORY ACTIVITY
INITIAL INSTALLATION DESIGN
EPA
EVALUATE
PROBLEM
12/82
1990
CO'iMEDCIAL 5ASIS
EVALUATE EM SSI ON
IMPACT FROM
C:MMERCIAL DEVELOPMENT
OPERATION OF 50 MW INSTALLATIONS
I~DESK4 OF COMMERCIAL E1UIP|JENT
EMISS QNS CHARACTER ZATION 1 DEVELOP STANDARDS
CONTROL TECHNOLOGY EVALUATION J IF REQU RED '
12
CONVERSION TECHNOLOGY DEVELOPMENT
EPA
DEVEL
EPA
EVALUATE
PROBLEM
PMENT OF ROCK FRACTUR NG
CHARAC
, ~~~~
112/83
GUIDANCE
MANUAL"''
FIRST SERRATION
TESTS
ERtZE EM SSIOMS
DEV;LO°MENT ON
EVALUATE EMISSION 1
IMPACT «^OM 1
CiMSiERCIflL DEUtLOPHE'JTl
OPERATION OF 50 MW DEKONSTRAT O'-l
12/85
EVALUATE CONTROL TECHNOLOGY
AND ENERGY EXTRACTION TECHNOLOGY
EXTRACTION EXPERIMENT NO. 1
EXTRACTION EXPERIMENT NO. 2
DATA CAPTURE ON EXPERIMENTS
IG 'HJ
PILOT
OPERATION
EVALUATE
PROBLEM
h DEVELOP STANDARDS
IF REQUIRED
— — _ — •
k 2/37
GUIDANCE-
* MAN UA L
DEMONSTRATION
PLANT DESIC-'J
CO"IMERCIAL
DEVELOPMEM
£V°LUATE
DEMONSTRATION PLANT
OPERATION
EMISSIOiJS CHARACTERIZATION
CONTROL TECHNOLOGY .
EVALUATION
Y — -
> 2/5?
'^OPTIMUM SCHEDULE FOR DELIVERY
IN TIME'TO IMPACT DESIGN
OF COMMERICAL PLANTS
""'INCLUDES BUREAU OF RECLAMATION
COMBINED DESALTING AND POWER
PRODUCTION UNIT
FIGURE 0,
SCHEDULE FACTORS FOR AIR QUALITY ACTIVITY
+ DECISION ON NEED FOR AIR STANDARDS
A TARGET DATE FOR STANDARD IF POSITIVE DECISION
-------
different schedules. The Geysers, the only known U.S. vapor-dominated
resource, is already in operation and additions to its capacity are planned
yearly. EPA research is needed now to obtain reliable data on emissions at
The Geysers and on control techniques as they are developed, so that the
Agency can ensure that projected future capacity increments are handled in
a timely, environmentally protective manner.
The press of time is also keen in the case of liquid-dominated
hydrothermal resources of the Imperial Valley, where little is known about
air quality impacts. The logical approach is to influence the design and
demonstration phase and to make a final evaluation of the need to regulate
before development reaches the commercial stage. EPA is committed to issue
an initial guidance manual to the geothermal industry by July, 1977.
This should be followed by a final guidance manual in 1980 or 1981, which
will be in time to influence the design of commercial additions to the
initial installation at each site. Information for such a manual can be
obtained from measurements during the testing and operation of the initial
installation. Air pollution control of the later sites will profit from
experience gained from the Imperial Valley combined with site-specific
emissions measurements made during initial development.
Geopressured and hot dry rock development is expected to
quicken about 1980; Figure 4 indicates appropriate EPA R&D action
to evaluate air quality problems, to characterize emissions, and
to provide guidance to industry.
Figure 4 is based on the information available from ERDA's Program
Implementation Plan in 1976. It must be revised annually as geothermal
development proceeds. In particular, as ERDA and other organizations
commit funds to specific projects for initial installations and loan
guaranties the range of proposals will narrow, EPA will be able to direct
its activity along the appropriate paths. This revision should be pro-
vided to the regulatory offices by ORD.
D. Specific Research Needs
Table III presents a list of research topics generated by OAQPS that
GWG recommends be considered as part of an accelerated program of environ-
mental investigation. The portion of EPA's R&D effort on geothermal
energy that is related to air pollution should be based on the needs
that support the NSPS approach. ORD should define the R&D program
in collaboration with OAQPS.
28
-------
TABLE III
RESEARCH TOPICS IN SUPPORT OF EPA PROGRAM NEEDS: AIR EFFECTS
EMISSIONS CHARACTERIZATION
Study emissions of non-condensable gases and other pollutants
'^Characterization of emissions of non-condensable gases
^Characterization of pollutant release from cooling towers,
gas ejectors, and other sources
**Develop advanced sensors for atmospheric pollutant
measurements
Project emission information for other fields based on resource content
"Develop models to relate emissions to extraction technology
and resource type
^Verify models at existing operational sites
"Estimate emission potential of known geothermal resources
Assess local and national environmental impact
^Development of strategies for monitoring systems
"'Baseline measurement of ambient air quality at potential
resource area
'•Monitoring of pollutants at geothermal sites
"Analyze gaseous emissions for known carcinogens
'^^Characterize pollutant release during exploration
CONTROL TECHNOLOGY EVALUATION AND DEVELOPMENT
Evaluate existing techniques
*Review information sources for available basic systems
*Determine potentially applicable pollution control techniques
from other industries
^Evaluate control efficiencies and energy consumption of
control techniques
Develop improved control technology or extraction processes
^Identify pollutants presently lacking adequate control technology
^•"Feasibility studies for advanced concepts in basic systems
**Propose chemical or physical control processes
**Perform laboratory studies of candidate processes
*High priority studies EPA should initiate
**Low priority studies to be considered if time and funds are available
29
-------
TABLE III (Continued)
RESEARCH PRIORITIES IN SUPPORT OF EPA PROGRAM NEEDS: AIR EFFECTS
Estimate interactions and impacts for control and extraction
combinations
^Evaluate energy penalties for control/extraction combinations
"Evaluate costs associated with control/extraction combinations
"Evaluate environmental benefit for control/extraction
combinations
^Assess environmental side effects for control/extraction
combinations
CONTROL STRATEGY DEVELOPMENT
Estimate level of importance and order of priority of extraction
techniques
"Evaluate development schedules and impact of uncontrolled
processes
''"Develop prioritization of extraction techniques
Develop systematic control strategies
""Develop systematic control strategies for vapor-dominated
hydrothermal installations
-'Develop systematic control strategies for liquid-dominated
hydrothermal installations
"^Develop systematic control strategies for geopressured
installations
^"Develop systematic control strategies for hot dry rock
installations
"High priority studies EPA should initiate
**Low priority studies to be considered if time and funds are
available
30
-------
II. WATER QUALITY
A. Problem Evaluation
Assessment of the potential impact of geothermal energy develop-
ment on water quality is complicated by the fact that the chemistry
of geothermal fluids varies significantly from source to source, and
the character of the effluent stream will depend on the process used
to extract the heat. Geothermal fluids are frequently high in total
dissolved solids, and may contain toxic substances such as mercury
and arsenic. In addition to the more severe toxicants, other prob-
lem effluents include boron, lithium, nitrates, silica, radium, radon,
and the waste heat itself, which may contribute to thermal pollution.
An important factor in the pollution threat of some toxicants is the
ionization state in which they are present. lonization state is signi-
ficant in the case of such pollutants as arsenic, which is more toxic
as As~*~3 than As+-\
The energy extraction technique employed will also determine the
profile of the effluents that must be dealt with. In a flashed steam
process some pollutants tend to follow the steam while others remain
in solution. If a binary cycle using a secondary working fluid is
employed, all the pollutants should remain in the geothermal fluid,
but some may tend to precipitate at lower temperatures, complicating
disposal efforts.
1. Water Quality Problems in Liquid-Dominated Hydrothermal Sources
Most of the geothermal development to date has been at vapor-
dominated resources such as The Geysers and Lardarello, Italy. The
quantity of effluent from such sources is low, and reinjection has
been used successfully at The Geysers for its disposal. While at least
one 50 MW plant is presently planned at Heber, in the Imperial Valley,
the largest commercially developed liquid-dominated resource is at
Wairakei, New Zealand, where effluents are discharged directly into
the Waikato River. At Wairakei, significant environmental effects are
suspected from arsenic, mercury, and silica. For comparison, the fol-
lowing information has been developed from Wairakei.
a. Arsenic. The annual discharge of arsenic at Wairakei is
approximately 160 metric tons. During periods of average river flow,
the concentration has been computed by Axtmann to be about 0.04 ppm,
but during periods of drought the stream flow falls to such low levels
that arsenic concentrations could reach 0.250 ppm, five times the U.S.
standard for drinking water. Clearly, all U.S. sites must be screened
for such a serious situation.
31
-------
b. Mercury. The Wairakei plant is not the only source of mercury
in the Waikato River; the river also receives natural geothermal dis-
charges from adjacent areas. Mercury concentrations in trout taken
from the river showed an average mercury concentration of approxi-
mately 0.5 mg/kg, about the accepted limit for human consumption.
Because of the natural sources of mercury discharge, the importance
of the geothermal power station discharge is not clear. Again, screen-
ing will be necessary for all U.S. sites to avoid initiating a problem
or exacerbating an existing situation.
c. Silica. The effluent flow from the Wairakei plant is super-
saturated with silica; when the temperature falls the silica precipi-
tates in the amorphous form. The total discharge is large—over
25,000 metric tons per year—and the precipitating silica clogs the
discharge channels, requiring its periodic removal. The environmental
impact of this discharge on the Waikato river has not been reported,
but the disposition of silica and other large volumes of solids must
be carefully checked, including fate after reinjection. (In some parts
of the Imperial Valley brines contain 250,000 ppm total dissolved solids
(TDS).
d. Other Contaminants. In addition to the arsenic, mercury, and
silica, Axtmann lists 14 other chemical discharges from the Waraikei
plant. (Appendix E) These bear examination in the case of U.S. re-
sources. Also, radioanalysis should be performed on U.S. sources.
2. Overall Situation Assessment
It is evident that uncontrolled discharge of geothermal fluids can
have a significant effect on surface water quality. Less clear are the
specific threats posed by the individual U.S. sources, or the control
measures that may be practical. Reinjection of spent fluids is often
cited as a solution to the problem of effluents from liquid-dominated
systems. However, as discussed later in the section on ground water
protection, reinjection schemes themselves must address a number of prob-
lems of engineering and aquifer contamination.
The list of substances found in geothermal fluids (Appendix D) con-
tains a number of elements which appear in Quality Criteria for water
that have been developed by the Office of Water Planning and Standards
(OWPS). These include ammonia, arsenic, cadmium, chromium, copper, lead,
mercury, silver, and zinc. Whether the presence of these substances
constitutes a problem must be evaluated for each site in the light of
the expected discharge concentration and its relation to the flow of
the water bodies receiving the discharge.
In summary, geothermal energy poses potential water quality im-
pacts which are likely to depend on the specific details of the
source, its extraction technique, and the body of water to which the
32
-------
pollutant is discharged. These details must be further investigated in
order to adequately evaluate both the problem and the appropriate
final EPA action.
B. Guidance and Regulatory Actions
1. Guidance
As a minimum level of effort in geothermal water pollution protection,
EPA can issue guidance to ERDA, state control agencies, and its own
regional offices. Initial activity can comprise the collection of existing
data, its evaluation in the light of known water pollution effects, and
recommendations for effluent control. EPA should expand this role by
collaborating with ERDA to insure that the water data collection and
control activities of ERDA reflect EPA and state water pollution planning
concerns and to develop the information EPA needs to perform its role.
EPA should participate directly in joint water pollution assessment and
control efforts with ERDA in order to influence technological choices
toward adequate effluent controls and practices.
2. Permits
A geothermal installation that discharges effluents to navigable
waters must apply to its state permit-issuing agency or to EPA for a
permit under the National Pollutant Discharge Elimination System (NPDES).
Under present regulations, the permit-issuing agency must deal with the
geothermal plant on an ad hoc basis because no effluent guidelines have
been issued for geothermal sources. It must issue a permit or require
controls based on experience with similar effluents from other industrial
sources. Problems will arise if the geothermal plant effluents differ in
character from other industrial sources and if standard control techniques
are not applicable to the physical and chemical characteristics of speci-
fic geothermal resources and conversion technologies.
Also, under Section 404 of the FWPCA, a permit may be required from
the Corps of Engineers prior to the discharge of dredged or fill material
into navigable waters of the U.S.
3. Standards Pathways
Under the Federal Water Pollution Control Act Amendments of 1972,
PL 92-500, EPA has available four avenues of approach to the control
of geothermal impact of water quality:
o Toxic and Pretreatment Effluent Standards
o Effluent guidelines
33
-------
o Control via Section 208 agencies
o Water quality standards
Figure 5 illustrates the decision involved in selecting an approach
to geothermal regulation, and Table IV compares the information and the
time factors involved.
a. Toxic and Pretreatment Effluent Standards. Regulation could be
approached under Section 307, Toxic and Pretreatment Effluent Standards.
This path would probably be extremely difficult due to the lengthy hear-
ing process and the burden on EPA to support criteria and to demonstrate
levels providing margins of safety.
b. Effluent Guidelines. Effluent guidelines for water quality are
analogous to New Source Performance Standards for air quality in that
they address point sources of effluents, are industry-specific, and
require knowledge of treatment technology and costs as well as efflu-
ent characteristics.
Within the Office of Water Planning and Standards there is no
on-going program for the development of effluent guidelines for the
geothermal industry. Potential resources for guideline development
are heavily committed for the next three years and the placement of
any emphasis on the potential geothermal industry problem would re-
quire either additional funds and resources, or a reprogramming of
existing resources in the face of stringent court mandates, remands,
and consent decree actions.
There is a need for a substantial amount of baseline data re-
lating to the problem prior to the development of any effluent guide-
lines. Control via the avenue of effluent guidelines is possible
if data on effluents and control technologies were obtained through
cooperative efforts between EPA and ERDA. Once the needed information
was in hand, development of effluent guidelines would require between
2 1/2 and 3 1/2 years to accomplish.
c. Control by Section 208 Agencies. A substantial number of Sec-
tion 208 areawide wastewater management agencies have been designated
by state governors during the past several months. Because they are
concerned both with the quality of bodies of water and with control of
industries that discharge into the water, the 208 agencies represent
another way to approach control of geothermal effluents.
Any plan prepared under the 208 process shall include:
"...the identification of treatment works necessary to meet
the anticipated municipal and industrial waste treatment
needs of the area over a twenty year period..." 208(b)(2)(A)
34
-------
PREFERRED
REGULATORY
APPROACH
U>
(Jl
SOURCE: OUPS
FIGURES
PREFERRED STANDARDS PATH ANALYSIS FLOW CHART
FOR GEOTHERMAL WATER QUALITY PROTECTION
-------
TABLE IV
PRINCIPAL WATER QUALITY OPTIONS FOR GEOTHERMAL INDUSTRY REGULATION
REGULATORY
APPROACH
FEDERAL WATER
POLLUTION CONTROL
ACT SECTION
KEY FACTORS
INFORMATION
REQUIREMENTS
TIME REQUIRED
TO DEVELOP
REGULATION
Water Quality
Ambient Standards
303
State has primacy
unless it fails to
write an acceptable
standard.
Health and environ-
mental effects
Identification of
potential uses for
specific body of
water
About 1 year
Effluent
Guidelines
301, 302, 304, 306,
402
Focuses on point
sources of effluents;
requires considerable
EPA effort.
Health and environ-
mental effects
Treatment technology
and costs
2% to 3!j years
Toxic and
Pretreatment
Effluent Standards
307
Burden of proof on
EPA for establishing
criteria, safe
levels .
Requires preliminary
Proposal as a toxic
Subs tance
Health effects;
Emission level with
margin of safety;
Treatment technology
and costs
Toxic: 2?3 - 3^ years
Pretreatment: 1-4
years
Control via Section
208 Agencies
301, 302, 208
Relies on state
agencies to establish
adequate control
technology. Guidelines
so developed would not
have national
applicability.
Health and environ-
mental effects
EPA guidance could be
developed in 6 to 18
months .
-------
Consistent with determining treatment needs, 208 agencies could
recommend treatment levels for geothermal power plants. If such
recommended levels went through a public participation process and
eventually became part of an approved 208 plan, those levels would
have to be considered by the authority issuing the required National
Pollutant Discharge Elimination System permit. A 208 planning
agency (areawide or statewide) could be given EPA contract funds to
manage a project which would seek to generate effluent limitations
for a facility or facilities located in the planning area. Such
effluent guidelines would not serve as national guidelines. The
guidelines developed by this process could be used in writing per-
mits for the plant(s) in question. EPA guidance to the states under
such a process might take a form similar to Waste Load Allocations,
and could be expected to require between 6 and 18 months to develop.
d. Water Quality Standards. Some existing regulatory standards
are applicable to the industry. Principally these are water quality
standards supported by particular water quality criteria that may be
identified, and specific state regulations that are applicable to
the geothermal industry. EPA's role in the process involves setting
water quality criteria that must be met if a given body of water is
to sustain a specific type of use. Unless a state has ceded primacy
to EPA, the state first determines the beneficial uses applicable to
each body of water, then sets water quality standards by consulting
the EPA water quality criteria corresponding to those beneficial uses.
e. Related Program Office Activities. The Office of Water Plan-
ning and Standards has developed criteria for about 60 water constituents.
These criteria, developed pursuant to Section 304(a) of PL 92-500, have
been published as Quality Criteria for water. In connection with this
effort, the Agency has produced a draft guidance document for the develop-
ment of Water Quality Standards. If a particular state doesn't adopt the
304(a) criteria in developing its standards, it must justify its decision
to EPA.
In addition, the Office has embarked on the development of criteria
for an additional 65 constituents based upon existing information, which
will be completed by June 1978. Associated with this effort will be the
development of effluent guidelines for effluents containing such con-
stituents for 21 industrial categories. ORD is conducting research in
water constituent-related areas and such research will be helpful to these
regulatory efforts when the results become available.
C. Recommended Pathway and Associated Information Needs
1. Recommended Pathway
First, GWG recommends that, in the near term, existing water quality
37
-------
criteria and standards be examined for applicability to potential
effluent contaminants from geothermal sources.
Second, because geothermal development is projected to take place
throughout several states and because it will encompass various distinct
conversion technologies and resource types, GWG recommends that EPA adopt
a basic, long-term approach aimed at establishing effluent guidelines for
the evolving geothermal industry.
The toxic and pretreatment effluent standard approach does not appear
to be entirely applicable to geothermal energy at this time, but should be
reevaluated as specific types of commercial processes crystallize.
2. Information Needs
The recommended pathway implies the need for supporting information
as Figure 5 indicates. GWG and OWPS recommend that the required informa-
tion be developed through studies in the following areas:
o Periodically evaluate the nature and extent of the environmental
contamination (initially site-specific, later regional)
o Collect data on effluents from geothermal applications
o Baseline monitoring at installation sites
o Assessment of the environmental impact of various energy
extraction and conversion techniques
o Reactions of wastewater pollutants
o Synergistic effects of toxicants
o Potential disposition of geothermal wastes, including direct
discharge, solar evaporation, and subsurface reinjection
As geothermal technology evolves, the effluent guideline approach
for the geothermal industry will also require information on:
o Methods of cooling waste water prior to surface disposal
o Treatment technologies and their associated costs.
The recommended method of gathering this information would be
through ERDA's experimental and initial installation activities. EPA
technical personnel should be part of such research in an advisory or
coordinating capacity.
38
-------
3. Implication of ERDA Plans on Water Quality Regulatory
Decision Schedule
EPA concern with geothermal energy water quality protection is
greatest in the case of liquid-dominated hydrothermal sites, because
they combine early projected development with a potential for large
volumes of effluent brine. Liquid effluents represent a relatively
small fraction of mass flow at The Geysers, and effluent reinjection
has been successfully demonstrated for this vapor-dominated system.
The earliest anticipated development of liquid-dominated sources
is expected at Heber, in the Imperial Valley of California (Figure 6).
EPA plans to issue a preliminary guidance manual in mid-1977 to
provide advance information on environmental protection problems. If
environmental information is to be furnished in a timely manner for
commercial development of the Imperial Valley sites, a final guidance
manual must be available in 1980. Information on which to base the
manual should be obtained from effluent measurements at existing in-
stallations.
Other groups of hydrothermal sites are expected to see initial
operation in 1980 and 1981, with commercial expansion following the
initial operation by five years. EPA guidance for these sites should
be issued in 1981 and 1982, and will probably require site-specific
effluent data that can be obtained from the initial equipment.
Geopressured and hot dry rock installations are not expected to
see commercial development prior to 1990. EPA should plan now to
follow the progress of these types and to obtain data to provide
water quality protection guidance by 1985 or 1986.
It should be recognized that this 1976 development scenario can
be expected to change, and should be periodically revised. As ERDA
and the industry commit themselves to loan guaranties and specific
projects, EPA will be better able to focus its information gathering
and its guidance.
D. Specific Research Needs
Table V presents a tentative list of research topics generated
by OWPS that GWG recommends to satisfy the information requirements
involved in geothermal environmental protection. The portion of EPA's
R&D effort on geothermal energy that is related to water pollution
should be based on these needs, that generally support the effluent
guidelines approach. ORD should define the R&D program after collabora-
tion with OWPS.
39
-------
Jx
O
RESOURCE TYPE
DRY STEAM
THE GEYSERS
LIQUID-DOMINATED
HYDROTHERMAL
IMPERIAL VALLEY
OTHER HYDROTHERMAL SITES,
E.G. , COSO H.S. , 0EOWAWE
GEOPRESSURED
LOUISIANA, TEXAS GULF COAS
HOT, DRY ROCK
NOTE: SCHEDULE ALSO APPLIES TO UATER QU^LITV
FROM RADIOACTIVE EFFLUENTS
1975
ERDA
EPA"
ERDA**
EPA
ERDA
EPA
ERDA
TS
ERDA
IMPACTS
1980
ADDITIONAL
INITOR WATER QUALITY
)R POSSIBLE EFFECTS
1
L
f
•12/77
NITIAL GUIDANCE
ANUAL TO INDUSTRY
1
PREPARATORY EXPERIMENTS
DESIGN OF N TIAL INSTALLATION
EVALUATE PROBLEM
t
NCREMEHTS OF CAPACITY
-^-^ 1
1985
12/80 DESIGN OF COMMERCIAL EQUIPMENT
utma run/As, rin^, o, LIL. ^ DEVELOP STANDARDS
EVALUATE CONTROL TECHNOLOGY J IF REQUIRED
~— -_
NITlftL GUIOftMCE
ANUAL TO INDUSTRY
L
— t
FINAL GUIDANCE MANUAL*
TO INDUSTRY
EXPLORATORY ACTIVITY
NITIAL INSTALLATION DESIGN
EVALUATE
PROBLEM
.12/82
1990
DEVELOPMENT ON
COMMERCIAL BASIS
CO*",ERC IAL !>EV
OPERATION OF 50 MU INSTALLATIONS
p2/81 DESI r,H OF COM^ERC'AL EQUIPMENT
EFFLUENT CHARACTERIZATION
CONTROL TECHNOLOGY EVALUATION
CONVERS ON TECHNOLOGY DEVELOPMENT
DEVELOP STANDARDS
' 1 F REQUI RED '
^n
PLANNING AND PILOT PLANT CONSTRUCTION
EPA
DEVEL
EPA
EVALUATE
PROBLEM
PMENT OF ROCK FRACTURING
•
L 12/83
_^ GUIDAHCE
MANUAL"
FIRST GENERATION
TESTS
S^i'r.Sis
E'^L'jAlE EF-LUENT
IMPACT CR.DM
Cfl^M.ERC IAL 3E"ELOPMEN7
OPERATION OF 50 MW DEMONSTRATION
[DESIGN OF COMMERCIAL EQUIPMENT
CHARACTERIZE EFFLUENTS ';/o.
EVALUATE CONTROL TECHNOLOGY
AND ENERGY EXTRACTION TECHNOLOGY
EXTRACTION EXPERIMENT NO. 1
EXTRACTION EXPER MENT NO. 2
DATA CAPTURE ON EXPERIMENTS
10 MW
PILOT
OPERAT 1 ON
EVALUATE
PROBLEM
DEVELOP STANDARDS
' 1 F REO,U
1
RED ^
J2/87
GU DANCE
"i AN UAL-
DEMONSTRAT ON
PLANT DESIGN
3EVELCP-E
EVALUATE
DEVELCPlEN
L
11 T
DEMONSTRATION PLANT
OPERATION
EFFLUENT CHARACTERIZATION
CONTROL TECHNOLOGY EVALUATION
M2/3?
GUIDANCE
HAN UAL -
^OPTIMUM SCHEDULE FOR DELIVERY
IN TIME TO IMPACT DESIGN OF
COMMERCIAL PLANTS
*"lNCLUQES 8URE.A.U OF RE.CLAIAAT ION
COMBINED DESALTING AND POWER
PRODUCTION UNIT
DECISION ON NtED FOP WATER STANDARDS
TARGET DATE FOR STANDARD IF POSITIVE DECISION
FIGURE 6
SCHEDULE FOR WATER QUALITY ACTIVITY
-------
TABLE V
RESEARCH PRIORITIES IN SUPPORT OF EPA PROGRAM NEEDS:
WATER QUALITY
CHARACTERIZATION, MEASUREMENT, AND MONITORING
*Baseline Measurement of Ambient Water Quality at Potential
Resource Area
"Characterization of Liquid Effluents, Including Cooling Tower
Drift and Waste Water
*Water Quality Monitoring at Geothermal Sites (H2S Trace Element)
'"Characterize Toxic Agents
PHYSICAL AND CHEMICAL PROCESSES AND EFFECTS
*Study Movement/Fate of Geothermal Effluents (Brines, Gases,
Cooling Towers)
*Evaluate Ability of Soil to Absorb and Neutralize Water Pollution
•"Hydrological Characterization of Geothermal Resource Areas
^Study/Model Changes in Surface Water Due to Geothermal Operations
"'Assess Annual/Seasonal Variations in Flows
*Study Effects of Geologic Disturbances on Water Flow
HEALTH EFFECTS
**Determine Dose Effects in Animals
**Determine Levels of Human Exposure
"*Determine Health Effects of Toxicant Combinations
ECOLOGICAL EFFECTS
^Review Toxicological Literature (Geothermal Pollutants)
^Conduct Baseline Inventory and Monitoring Studies
^Literature Review of Hazardous Effluents From Cooling Systems
^Identify Transfer and Fate of Cooling Systems Pollution in
Freshwater Ecosystems
**Marine and Estuarine Dose-Response Studies (Cooling Systems
Research)
**Freshwater Dose-Response Studies
**Effects of Cooling Systems on Coastal Ecosystems
*High priority studies EPA should initiate
**Low priority studies to be considered if time and funds are available.
41
-------
POLLUTANT CONTROL TECHNOLOGY
'''Establish Waste Products and Side Effects of Geothermal Energy
Systems
^Evaluate Existing Geothermal Energy Pollution Control Techniques
^Determine Potentially Applicable Pollution Control Techniques
From Other Industries
*Determine Hazards and Disposal Problems Associated with Waste
Products and Side Effects
-'Compare Input Stream Treatment With Output Stream Treatment
For Each Pollutant
"Evaluate Control Efficiencies and Energy Consumption of Control
Side Effects
-^Identify Pollutants Presently Lacking Adequate Control Technology
"Propose Candidate Chemical or Physical Control Processes
**Determine Feasibility of Geothermal Materials Recovery
**Perform Laboratory Studies of Candidate Techniques
**Conduct Pilot Installation and Evaluation of Selected Control
Techniques
**D'eve'lop Systematic Control Strategies for Vapor-Dominated
Hydrothermal Installations
^"Develop Systematic Control Strategies for Liquid-Dominated
Hydrothermal Installations
"""Develop Systematic Control Strategies for Geopressured Installations
**Develop Systematic Control Strategies for Hot Dry Rock Installations
^"Assess Local Impacts of Geothermal Field Development
*High priority studies EPA should initiate
**Low priority studies to be considered if time and funds are available.
42
-------
III. GROUND WATER PROTECTION
A. Problem Evaluation
1. Aquifer Contamination
The problem of minimizing the impact of geothermal energy de-
velopment on drinking water supplies involves questions not only of
geothermal chemistry, but also of geology, the composition of the
rock formations involved, and standards for the drilling and comple-
tion of wells. Drinking water aquifers are frequently protected by
impervious strata from contamination by surface water or by other
subsurface aquifers. Geothermal exploration and development activity
can open paths between aquifers creating a pollution hazard that is
independent of the composition of the geothermal brine itself.
It is evident, then, that efforts to protect ground water must
consider the direct problem of leakage of geothermal fluids from wells
or disposal ponds into other aquifers. Equally important is the problem
of aquifer contamination during well drilling, or from poor casing or
cementing practices that may allow fluids to flow from one aquifer
to another. When an exploratory well is abandoned, it can create a
similar hazard by providing a vertical channel through several im-
permeable strata, in which leaks may later create interconnecting
paths.
Reinjection of geothermal fluids, frequently mentioned as an
answer to subsidence and to prevent surface water contamination,
can also provide opportunities for aquifer contamination through
leaks and other problems. Indeed, reinjection may not be feasible
in all cases because dissolved solids may precipitate at the lower
effluent temperature or may react with minerals in the receiving
formation, plugging up the pore spaces and preventing further dis-
posal. Problems of corrosion and scaling in the reinjection equip-
ment must also be solved before reinjection can be considered a
practical pollution control technique. These problems of compati-
bility between reinjected fluids and the disposal formation and of
effect on the reinjection equipment can be expected to differ sig-
nificantly among geothermal sites, and may require solution on an
individual basis. Fluid characterization and reinjection compati-
bility should be assessed together at specific sites.
2. Subsidence
An important topic related to geothermal extraction and in-
jection is the possibility of induced subsidence. Subsidence fre-
quently occurs where large quantities of fluid are withdrawn from
a geologic formation, removing the support from the overlying strata.
43
-------
It may be a critical consideration in the Gulf Coast area, where a
large geopressured geothermal resources that are rich in methane exist
in conjunction with land areas that are only a few feet above sea level.
3. Seismicity
Seismicity presents a problem because geothermal resources are
commonly found in areas of natural seismic activity, implying dif-
ficulty in distinguishing the effects of geothermal development as
well as raising questions involving possible interaction effects.
It has been argued that reinjection could stimulate seismic effects
by lubricating fault areas, and this effect has been reported in
connection with the disposal of hazardous wastes in Colorado. On
the other hand, withdrawal of fluids could conceivably cause a
fault to lock, causing tectonic pressures to build up and produce
a large earthquake in place of a natural series of minor shocks.
The ambiguity in this issue is emphasized by the fact that fluid
injection has been proposed as a technique for reducing the
severity of earthquakes through controlled lubrication of geo-
logic faults.
4. Overall Situation Assessment
In the cases of aquifer contamination and subsidence, the physi-
cal mechanism of the environmental impact is well understood, and
what is required is specific information on the engineering of appro-
priate drilling standards and other control measures to prevent
adverse effects. The topic of seismicity requires significantly
more information about the basic phenomenon and whether it is likely
to present a significant environmental problem, or even be a serious
obstacle to geothermal development.
B. Guidance and Regulatory Actions
1. Guidance
Because much of the authority over ground water is reserved to
the states, guidance should be an important part of any EPA program
of ground water protection. The EPA can play an active role in
gathering and evaluating data on ground water problems and control
measures. Some of this guidance can be general in nature, but
should be supplemented by assistance in site-specific problems of
geology, fluid chemistry, and extraction and development technique.
2. Permits
Although ground water contamination can occur either from ex-
traction or injection, direct EPA regulatory authority extends only
to injection activities, either reinjection of hydrothermal fluids
44
-------
or direct injection into hot dry rock. Regulation of pollution inci-
dental to extraction wells would have to be covered under state regula-
tions for such wells. As discussed below, EPA is in the process of
issuing injection regulations (40 CFR Part 146) as part of its State
Underground Injection Control Program.
3. Regulatory Pathways
Under present practices EPA has two avenues of regulatory con-
trol over subsurface injection; these are compared in Table VI, and
the implied decision process appears in Figure 7. When the state-
administered regulations of 40 CFR Part 146 take effect, an applicant
for a reinjection permit will be required under subpart C to furnish
geologic and fluid data regarding the proposed operation and design
information showing compliance with the protective requirements.
A second opportunity for control exists where reinjection
involves storage or treatment of subsurface fluids. Where a geo-
thermal operation reinjects subsurface fluids, the state has the option
to regulate the reinjection under 40 CFR 146. If the state has
declined to accept primacy on geothermal reinjection, the EPA
region would require a permit under the Underground Injection Control
(UIC) program. Where the wastes are stored or treated prior to re-
injection, then the application would be handled under the National
Pollution Discharge Elimination System (NPDES). When an application
for an NPDES permit is received the EPA regional office may elect to
apply 40 CFR 146 or Administrator's Decision No. 5. The choice is
unlikely to affect the operation, since the two documents are very
close, the difference being that some information that is manda-
tory under Administrator's Decision No. 5 is at the option of the
regulatory agency under 40 CFR 146.
C. Recommended Pathway and Associated Information Needs
1. Recommended Pathway
The GWG concludes that the present EPA authority vested in OWS
is adequate to support a posture of early guidance to and minimal
regulation of geothermal energy. The injection regulations of 40
CFR Part 146 can serve to control geothermal reinjection operations,
and studies can be performed to develop information regarding specific
problems of reinjection. In view of the accelerated development fore-
seen for geothermal energy, ERDA's cooperation should be enlisted to
derive such information.
2. Information Needs
Based on the fact that existing groundwater reinjection regulations
are at least minimally adequate for geothermal development, the path
45
-------
TABLE VI
PRINCIPAL GROUND WATER PROTECTION OPTIONS FOR GEOTHEKMAL INDUSTRY REGULATION
INJECTION OPERATIONS
EXTRACTION OPERATIONS
REGULATORY APPROACH
Permit Issuance under
Administrator's Decision
No. 5
Permit Issuance under
40 CFR 146
Mo specific Federal
Authority Exists; must be
addressed under state
authority over extraction
wells.
KEY FACTORS
Requires mandatory
submission of data
regarding proposed well
design, operation,
relation to other wells
and geologic structures,
etc.
Similar data required,
but some items are at
the option of the permit
issuing authority.
Fluid extraction may affect
drinking water aquifers, or
may cause subsidence in
certain geologic structures.
INFORMATION
REQUIREMENTS
TIME REQUIRED TO
DEVELOP INFORMATION
Application of existing regulations requires
knowledge of compatibility of injected fluids with
formations and possibilities for pretreatment.
Eighteen months to determine problem boundaries
and point out areas of specific concern. Some required
information is site-specific and will need determination
on an individual basis as part of permit issuance.
-------
PROBLEM
ASSESSMENT
DOES INJECTION OF
WASTE WATER
PRESENT A THREAT
TO DRINKING WATER
SOURCES?
I'
NO ACTION
REQUIRED
SUPPORTING
INFORMATION
DEVELOPMENT
Ji.
•XI
DETERMINE QUALITY OF
WASTE WATER AND
TREATMENT POSSIBLITIES
DETERMINE WHETHER
NON-TREATABLE WASTE
WATER CAN BE INJECTED
INTO SUBSURFACE
RESERVOIRS
COMPILE AND STUDY
DATA ON
COMPATIBILITY
SUBSIDENCE
SEISHICITY
TOXICITY
PRESSURE
MAINTENANCE
HEAT RECOVERY
REGULATORY
APPROACH
EPA HANDLES PERMIT
APPLICATION FOR
TREATMENT AND
DISCHARGE UNDER
NPDES
STATE HANDLES PERMIT
APPLICATION FOR
TREATMENT AND
DISCHARGE UNDER NPOES
EPA HANDLES PERMIT
APPLI CAT I ON
UNDER UIC PROGRAM
STATE HANDLES PERMIT
APPLICATION UNDER
UIC PROGRAM
EITHER NO WATER SUPPLY
INVOLVED OR NO THREAT
FIGURE?
REGULATORY PATH ANALYSIS FLOWCHART FOR GEOTHERMAL WASTE WATER
-------
analysis diagram (Figure 7) requires the development of certain information
to support regulation in specific cases. In order to determine the feasi-
bility and environmental protection requirements of reinjection practices.
GWG and OWS recommend that information be developed in three basic areas:
0 Lithology of the strata in geothermal areas
• Chemistry of the injected and formation fluids
• Possibilities for preinjection treatment
These areas should be investigated through a number of related
efforts:
• Collection and tabulation of fluids data from geothermal
resource areas
• Baseline monitoring of ground water at installation sites
« Laboratory studies of the compatibility of geothermal
fluids and injection formations based on actual samples
from the area under development
• Laboratory studies of possible preinjection treatment of
geothermal effluents to ensure their compatibility with
the receiving formations
• EPA participation with ERDA in three or four initial
experiments and installations, to develop knowledge of
the problems and hazards involved
• Verification studies to provide independent confirmation
of the effect of control techniques and construction
practices
• Cooperation with the Geological Survey in research on the
seismic and subsidence hazards of geothermal operations
3. Implications of ERDA Plans to Ground Water Protection
Regulatory DecisjLon Schedule
The problems of ground water protection, subsidence control,
and feasibility of reinjection are interrelated, and require solution
if the anticipated growth of the geothermal industry is to be achieved.
It is believed that EPA has in hand sufficient information involving
the mechanics of reinjection to control the problem of ground water
pollution. In contrast, reinjection to prevent subsidence involves
the questions of fluid formation compatibility already discussed. In
48
-------
order to issue guidelines for subsidence control, EPA needs informa-
tion on the compatibility issues. Laboratory studies to define the
basic problems and indicate critical factors could be completed in 2
years. Joint efforts with ERDA, verification studies, and USGS-
related subsidence and seismic efforts are also essential, but
schedules would depend on the cooperation of the other agencies and
the availability of suitable experimental projects.
As in the case of water quality protection, ground water pro-
tection is likely to be most heavily concerned with liquid-dominated
hydrothermal sites in the near future (Figure 8). Reinjection has
been successfully demonstrated at The Geysers, and EPA attention can
be limited to ground water quality monitoring to discover problems.
The Imperial Valley hydrothermal sites will need guidance at an
early date because reinjection is likely to play a major role. The
initial EPA guidance manual is planned for mid-1977. It seems
reasonable for EPA to plan for full environmental control by the
time commercial expansion begins. This implies that a final package
should be written by about 1980 to be in time to affect the design
of commercial additions to the initial installation. Such guidance
could rest on effluent and compatibility data collected at the
initial installation. EPA guidance for subsequent hydrothermal sites
will probably be able to draw on much of the Imperial Valley experi-
ence, with supplementary data collected from each site as initial
installations are built.
The question of subsidence is prominent in development of geo-
pressured sites. Here the scheduled activity is less immediate,
and EPA should aim for guidance to be issued about 1985.
The scenario presented here rests on the best information avail-
able in 1976. It should be given periodic revision as ERDA and the
geothermal industry commit themselves to specific projects. Such
commitment will narrow the range of possibilities confronting EPA
and allow EPA in turn to address its efforts to the most productive
and necessary activities.
D. Specific Research Needs
Table VII lists specific research projects identified by OWS to
develop the information discussed above. The topics have been ranked
in three categories:
1. Need exists to verify ongoing or completed high-priority
studies by others
2. High priority studies EPA should initiate
49
-------
RESOURCE TYPE
DRY STEAM
THE GEYSERS
LIQUID-DOMINATED
HYDROTHERMAL
IMPERIAL VALLEY
OTHER HYDROTHERMAL SITES,
E.G. , COSO H.S. , 5EOWWE
0
GEOPRESSURED
LOUISIANA, TEXAS GULF COAS
HOT, DRY ROCK
NOTE: SCHEDULE ALSO APPLIES TO GROUND
WATER IMPACTS IHVOLVI'IP RADIOACTIVITY
1975
ERDA
EPA
ERDA'"
EPA
ERDA
EPA
ERDA
TS
ERDA
1-980
1985
ADDITfOMAL INCREMENTS OF CAPACITY
MflNITOR GROUND '-/ATER
FO-R POSSIBLE EFFECTS'
I
H
•12/77
NIT1AL GUIDANCE
ANUAL TO INDUSTRY
PREPARATORY EXPERIMENTS
DESIGN OF INITIAL NSTALLATION
OPERATin-l
T TEST INSTALLATIONS
|" 12/80 DESIGN OF COMMERCIAL EQUIPMENT
EVALUATE REJECTION AND FLUID COMPATIBILITY J^ DEVELOP
EVALUATE PROBLEM
L
i
EVALUATE CONTROL TECHNOLOGY | IF REC
"- "
NITIAL GUIDANCE
ANUAL TO INDUSTRY
~1~~" f
TANDARDS
UIRED '
|_^. FINAL GUIDANCE
MANUAL TO INDUSTRY/;
EXPLORATORY ACTIVITY
INITIAL HSTALLAT10N DESIGN
EVALUATE
PROBLEM
STUDY
JZ/82
1990
FURTHER DEVELOPMENT ON
COMMERCIAL BASIS
EVALUATE IRO'J'iD .CIAL DEVELOPMENT
OPERATION OF 50 Wf 1NS~ALLAT ONS
j" DLSIG:J OF COMMERCIArTl'JlP.'^T
FLUIDS AND L ThOLOGtES 1
OF EACH SITE T 2/°'
-"• ~~^~
CONVERSION TECHNOLOGY DEVELOPMENT
^^~" — '
PLANNING AND PILOT PLANT CONSTRUCTION
EPA
DEVELO
EPA
EVALUATE
PROBLEM
GU 1 DA
"*" MANUA
VCE*
L
FIRST GENERATION
TESTS
ASSESS SUBSIDENCE PROBLEM
MENT OF ROCK FRACTURING AND ENERGY EXTRACTION TECHNOLOGY
EXTRACTION EXPERIMENT NO. 1
EXTRACTION EXPER MENT NO. 2
DATA CAPTURE ON EXPERIMENTS
10 MVJ
PILOT
OP E RAT 1 Of-
EVALUATE
PROBLEM
DEVELOPMENT a'l
COMMERCIAL BASIS
EVALUATE GROUND ','ATE^
MPACT PROM
COMME^C AL DEVELOPMENT
OPERATION OF FIVE, 50 "V INSTALLATIONS
DESIGN OF COMMERCIAL EIUIPME'T
DEVELOP
' IF RE
"I
TANDAROS
JU 1 RED '
•12/87
GU 1 3A4CE =-
OE MO1 1 STRATI 0>i
PLANT DESISH
COMMERCIAL
DEVELOPMENT
EVALUATE
CO'IMERC AL
DEVELOPMENT
PL^r^E^n,
E^ErB.;:r;: f-^
~-
I . GUIDANCE
MANUAL*
-''OPTIMUM SCHEDULE FOR DELIVERY
I ft TIME TO IMPACT DESIGN
OF COMMERCIAL PLANTS
'"INCLUDES BUREAU OF RECLAMATION
COMBINED DESALTING AND POWER
PRODUCTION UNIT
+ DECISION ON MEED FOR STANDARD TO PROTECT GROUND WATER
A TARGET DATE FOR STANDARD IF POSITIVE DECISION
FIGURES
SCHEDULE FACTORS FOR GROUND WATER PROTECTION
-------
TABLE VII
RESEARCH PRIORITIES IN SUPPORT OF EPA PROGRAM NEEDS:
GROUND WATER PROTECTION
CHARACTERIZATION, MEASUREMENT, AND MONITORING
^Baseline Measurement of Ambient Ground Water Quality at Potential
Resource Area
*Characterization of Liquid Effluents, Including Cooling Tower Drift
and Waste Water
^Characterize Toxic Agents
PHYSICAL AND CHEMICAL PROCESSES AND EFFECTS
"Study Compatibility of Geothermal Brines With Associated Geologic
Formations
''Assess Subsidence in Geothermal Fields
^Assess Reinjection Practices—Induced Seismicity
*Study Aquifer Disturbance by Geothermal Operations
***Studies of Physical/Chemical Properties of Soils, Rocky Mountains and
Northern Great Plains
**Study Subsidence Potential of Various Geologic Formations
**Study Seismic Potential of Various Geologic Formations
***Study Relationship of Aquifers to Geologic Formations
**Hydrological Characterization of Geothermal Resource Areas
*Study Modification of Thermal Structure of Ground Water at Geothermal
Sites
*Physical/Chemical Studies of Reaction/Movement of Geothermal Brines
**Study and Model Changes in Surface/Ground Water Due to Geothermal
Operations
A*Study Flow Pathways of Water in Various Geologic Formations
***Study Effects of Geologic Disturbances on Water Flow
***Study Chemical/Exchange Processes in Various Materials
A*'5Assess Impact of Extraction of Geopressured Resources (Gulf Coast)
CONTROL TECHNOLOGY
*Evaluate and Develop Methods for Pre-injection Treatment to Assure
Compatibility
*Need to verify ongoing or completed high-priority studies by others
**High-priority studies EPA should initiate
A**Low-priority studies to be considered if time and funds are available
51
-------
3. Low priority studies EPA may wish to perform if time and
funds are available
Early contacts with ERDA indicate many of the important topics
have been studied by others or are addressed by ongoing studies in
related problem areas. What is needed in this case is to obtain and
evaluate the data and results to assure that what has been done is in
fact accurate and complete. The data should then be reviewed to assure
that all factors concerning ground water protection have been covered
and if not, to make recommendations for additional work that may be
considered necessary. The portion of EPA's R&D effort on geothermal
energy that is related to groundwater pollution should be based on
these needs that support existing regulations. ORD should define
such a program after collaboration with OWS.
52
-------
IV. RADIATION
A. Problem Evaluation
The radiation hazards associated with geothermal energy are a form
of Technologically Enhanced Natural Radioactivity (TENR). Geothermal
energy production does not create radioactive isotopes, but it may
produce increased or even hazardous levels of exposure by concentrating
a naturally radioactive element or by bringing it to the surface of
the earth.
1. Radium and Radon
Radium and Radon, the two principal radioactive elements identi-
fied with geothermal development, occur naturally and may be released
through geothermal extraction or may be concentrated in the atmosphere
in hothouse or hydroponic applications. The biological impact results
from the subsequent radioactive decay products or short half-life radon
daughters, or from the release of radium in the effluent.
2. Impact of Pollution Control Technology
Pollution control technology for other pollutants may be a factor
in determining the radiation hazard, since the control devices in-
stalled to remove a chemical pollutant may be effective in removing
radioactive elements as well. Viewed another way, the control device
may concentrate radioactive products in its sludge or other output,
creating a radiation problem in its storage and removal.
Radioactivity also must be considered in disposal of solid waste,
as discussed in a later section.
3. Overall Situation Assessment
The elements involved in radioactivity are well-known, as are the
effects of radiation. The principal unknown factor in geothermal
energy is the magnitude of individual and population doses which
might be encountered from specific applications. Impacts may be
significant chiefly for persons whose place of work or residence is
near a source of geothermally-enhanced radiation. Occupational studies
are in order at initial installations.
B. Guidance and Regulatory Actions
Since naturally radioactive materials may be present as solid
waste, liquid effluents, or gases, radiation presents an environ-
mental problem that cuts across the traditional EPA program office
53
-------
boundaries. EPA's authority includes an advisory role to other
Federal agencies in addition to its own regulatory function.
1. Guidance to Other Federal Agencies
EPA acts in an advisory capacity to other Federal agencies in
writing their own internal regulations regarding environmental radi-
ation impacts. EPA has not revised the general numerical limits
originally set by the Federal Radiation Council for individual doses,
which are not sufficiently restrictive, because radiation exposure
can usually be made much lower without significant economic penalties.
In addition to the numerical bounds, EPA provides qualitative guidance,
to ensure that adequate controls are provided. Because there is no
known radiation level at which zero impact exists, qualitative guid-
ance has been to require that radiation doses be kept as far as
practicable below the numerical limits. Practicability is judged
by a cost/benefit analysis which addresses the effectiveness of the
control technique, and includes the impact of the anticipated radia-
tion level as a cost.
2. Standards Pathways
The Criteria and Standards Division of the Office of Radiation
Programs has determined that the Standards for Protection Against
Radiation (10 CFR 20), that form the basis for activities regulated
by the Nuclear Regulatory Commission, do not apply to geothermal
energy. This is because 10 CFR 20 is limited to the component
materials and by-products of nuclear fission, under the Atomic Energy
Act of 1954. EPA does have authority to regulate radiation aspects of
geothermal energy under the Clean Air Act, Federal Water Pollution
Control Act and the Safe Drinking Water Act. The options for such
actions are the same for radiation as for chemical problems, as dis-
cussed in the preceding sections on air quality, water quality and
groundwater protection.
C. Recommended Pathway and Associated Information Needs
1. Recommended Pathway
The need and form of any required regulation involving radiation
will rest on the specifics of the problem. EPA's Office of Radiation
Programs (ORP) has under way a study to determine the scope of the
impact and whether further work in this area is required. ORP's
efforts concerning the radiological aspects of geothermal energy fall
logically into three groups: (1) electrical power applications,
(2) non-electrical power applications, and (3) related studies. The
plan for this evaluation appears in Figure 9.
54
-------
PROBLEM
ASSESSMENT
DECISION
PROCESS
PREFERRED
REGULATORY
APPROACH
0-1
ELECTRIC
POWER
APPLICATIONS
PHASE 1 - IDENTIFY
CHARACTERISTICS OF
ENERGY SOURCES
- SAMPLING STEAM AND
HOT WATER TEST WELLS -
AND SAMPLING RADON
PARTITIONING
- PARTICIPATE IN ERDA
DEMO PROJECT
TERMINATE
1
-J
\
/
EVALUATE RESULTS OF
PHASE 2 - ANALYZE TECHNOLOGY
AND EVALUATE IMPACTS
- DOSE ASSESSMENT OF DEMO
PROJECTS INCLUDING
POSSIBLE MEASUREMENTS
4 ,
TERM NATE
A i
fr / \ ^
^^\ /
COORDINATE ACTIVITIES
WITH OTHER AGENCIES
SUCH AS:
- ERDA
- ORD
- PPBI
- OTHER AGENCIES
NON-POWER
ENERGY
APPLICATIONS
PHASE 3 - IDENTIFY
CHARACTERISTICS OF
ENERGY SOURCES
- FIELD SURVEY OF
HOT SPRINGS AND
SHALLOW WELLS
REPORT 1
(AVAILABLE)
REPORT 2
(ABSTRACT
AVAILABLE)
- PARTICIPATE IN
ERDA DEMO
PROJECTS
~(
\ ,
/ '
PHASE 2 - ANALYZE TECHNOLOGY
AND EVALUATE MPACTS
- DETAILED DOSE EVALUATION
AND MEASUREMENTS OF SPAS,
AGRICULTURAL AND
INDUSTRIAL USES
- PUBLISH REPORT
XV
TERMINATE
TERMINATE
PHASE 3 - ANALYZE EFFLUENT
ADJUST PRIORITIES —^CONTROL TECHNOLOGY OPTIONS
AND EMPHASIS PUBLISH REPORT
t
ALGAE UPTAKE STUDY,
REPORT TO BE PUBLISHED
REPORT 3 (ABSTRACT
AVAILABLE)
REVIEW OF EIS'S, ER'S,
i
ADJUST PRIORITIES PHASE 3 - ANALYZE EFFLUENT
flun FWPHOCK: — ^ CONTROL TECHNOLOGY OPTIONS
AND EMPHASIS ~ ^ pmu^ REpQRT
SOURCE: OFFICE OF RADIATION PROGRAMS
FIGURES
PLAN FOR RADIATION HAZARD EVALUATION
OF GEOTHERMAL ENERGY SOURCES
-------
For non-electric applications, ORP expects to complete by the end
of FY 76 the first phase of the prograni—the characterization of geo-
thermal sources, their radiological effluents, and preliminary analyses
of the environmental impacts.
In early FY 77, ORP will make a decision concerning the level of
effort to be applied on geothermal energy tasks for the future. This
will be based on theoretical calculations of potential environmental
radiological impacts. If warranted by the scoping dose assessment of
non-power geothermal hot springs and shallow wells, ORP will progress
into the second stage of making on-site dose measurements. For the
electrical power applications, the level of effort will depend on three
developments: (1) the timely completion of a power plant prototype
project by ERDA, (2) the results of the preliminary field surveys at
the Imperial Valley prototype demonstration project and (3) availabil-
ity of contract funds for ORP from other EPA groups. If the decision
is made to continue the effort in geothermal power applications, ORP
will make detailed evaluations of the environmental effects of ERDA's
power plant prototype through field measurements and paper studies.
Based on the results of the power plant prototype study, ORP will
decide whether to proceed with further work on geothermal power sources,
which would lead to standards development.
It should be noted that ERDA has identified five sources of geo-
thermal energy: hydrothermal convective, geopressured, hot dry rock,
volcanic, and normal gradient. Only one of these sources, hydrothermal
convective, has been commercially demonstrated and only one commer-
cially developed resource, The Geysers, exists in the U.S. ORP's
efforts have been concentrated on this source; however ORP plans to
evaluate other future sources in a fashion similar to the present plans
for hydrothermal convective.
The power applications efforts will be centered around ERDA's de-
velopmental program plans. The initial plant, and the only near-term
effort, began test operation in the Imperial Valley, California, geo-
thermal fields in June 1976.
The non-power uses of geothermal energy include space and water
heating, irrigation for agricultural purposes, industrial process heat
applications, and development of health spas. Each application will
be evaluated initially for the potential of contributing significant
doses. Since the basic dose problems will arise from the radon, the
geothermal efforts will draw on the ongoing ORP radon modeling work
associated with the uranium mining and milling analyses.
2. Information Needs
As with other impacts, the most urgent requirement in the radia-
tion area is for a continuing program of research and cooperation with
56
-------
ERDA to assess the nature and extent of the problem. In the area of
radiation, such a study should focus on the potential individual and
population doses that might be encountered from the various applica-
tions of geothermal energy. This study would in turn be used to in-
dicate the need for further investigations. These investigations
would address the radiation release points in various industrial appli-
cations of geothermal energy. For each release point the source terms
(release rates) would be evaluated, together with the capabilities
for source term control.
a. Technology for Radon and Radon Daughter Measurement. Current
techniques need to be addressed for measuring radon and radon daughters
in geothermal fluid under conditions of high steam/water pressures,
temperatures, and humidities. Development of rapid field techniques
will be an important step in assessing doses to individuals from
applications of geothermal fluids. Some initial work is in progress
and should be evaluated and included in planning EPA's own efforts.
b. Radium Uptake by Crops. The emphasis of this study will be on
hothouse and hydroponic applications of geothermal fluids. Radio-
nuclides in crops from such enterprises (as well as potentially
elevated radon concentrations in hothouses) affect small, but different,
populations than electrical geothermal applications. The populations
must be identified and their risk evaluated.
c. Radionuclide Enrichment Effected by Resource Recovery. Addi-
tional study is necessary to determine if the products of the mineral
recovery processes associated with geothermal developments are enriched
in radionuclides as a. result of'the process.
d. Radon in Water. Increased understanding of radon steam/water
partitioning and radon solubility in the temperature and pressure
ranges characteristic of geothermal fluids would have application to
several areas of interest. An initial, somewhat theoretical, approach
would provide an estimate of the quantities of radon expected from
geothermal reservoirs. Knowledge of radon behavior in water has
application to other studies such as indoor radon concentrations from
drinking water supplies.
e. Additional Studies. In addition to the foregoing areas, it is
likely that several additional areas of study, or of sharper defini-
tion of those stated above, will become apparent from the dose assess-
ment study. A need is foreseen for research in environmental measure-
ments of waste effluents (air and liquid) from geothermal applications
of the natural radioactivity in the environs of the prototype
facilities.
57
-------
V. SOLID WASTE
A. Problem Evaluation
Solid waste disposal does not at this time appear to present as
great a problem with geothermal energy as it does in many other energy
technologies, but some problems of solid waste disposal associated with
liquid-dominated hydrothermal operation will merit EPA's attention.
1. Sludge Disposal
The sludge that accumulates at the bottom of cooling towers con-
tains a number of the elements found in the source wells. At the
Geysers, this sludge is currently disposed of by burial in areas known
to have a stable geologic structure and negligible potential for ground
water contamination, but such sites are not plentiful and the process
is costly. Other sources of problem waste can accumulate in holding
ponds receiving liquid wastes and from devices installed to control
air or water pollution.
2. Radioactivity Associated With Solid Waste
Radioactivity must also be considered in addressing solid waste
impacts. As discussed in the section on radiation, the accumulation
from environmental control processes may result in pollutants reaching
problem levels of concentration. Any materials recovery from solid
waste would require review because of natural radioactivity. Use of
land where wastes have been buried must consider the possibility of
radon emission.
3. Drilling Muds
The muds used in drilling operations often contain toxic substances,
and may be considered as solid waste produced in the processes of
exploration and development.
4. Overall Situation Assessment
The solid waste resulting from cooling tower operations, emission
control, materials recovery, or exploration may present difficult
problems. The existence, nature, and extent of the problems will
depend on the specifics of the resource, type of geothermal development,
and technological details. This question should be addressed on a
site-by-site basis.
58
-------
B. Guidance and Regulatory Actions
Collection and disposal of solid wastes continues to be primarily
the function of State, regional and local agencies. However, the
national scope of the solid waste problem necessitates Federal action
through financial and technical assistance and leadership. The Resource
Conservation and Recovery Act of 1976 (Public Law 94-580) assigns to
EPA and the States authority and responsibility for control and manage-
ment of the disposal of solid wastes, especially hazardous wastes, in
the following areas.
• Issuance of guidelines and regulations for the management and
disposal of solid wastes and especially hazardous wastes
including:
a. Defining the characteristics of various solid wastes and
identifying and listing hazardous wastes to be controlled;
b. Developing standards for the generation, transport, storage,
treatment, and disposal of hazardous wastes and guidelines
for the management of other wastes, and
c. Promulgating criteria which define acceptable methods of
disposition in sanitary landfills, and which define prohibited
methods such as disposal in open dumps.
• Assistance to States and other jurisdictions in complying with
the Act by:
a. Providing advisory Resource Recovery and Conservation Panel
teams of specialists for consultation;
b. Promulgating guidelines for State management plans along
with statutory approval or disapproval;
c. Providing study grants and financial assistance to operators
of disposal facilities,
d. Coordinating, collecting and disseminating related infor-
mation; and
e. Determine training needs for operating disposal facilities
59
-------
• Conducting a National Research and Development program to:
a. Develop and demonstrate waste management technology;
b. Conduct studies in specifically enumerated waste manage-
ment areas; and
c. Develop operating criteria for available disposal technologies.
• Integrating administration and enforcement of the act with
related statutes (Clean Air Act, Federal Water Pollution Con-
trol Act).
• Conducting miscellaneous activities in:
a, Evaluation of the potential for employment loss or shifts;
b. Reporting to the Congress; and
c. Instituting Federal suit to restrain imminent hazards.
C. Recommended Pathways and Associated Information Needs
1. Recommended Pathways
GWG recommends that EPA institute close coordination with ERDA
in the development of geothermal resources which will be accompanied
by the production of geothermal wastes requiring disposal. This close
coordination should extend to State and local agencies in geothermal
resource areas.
2. Information Needs
Because the impact of solid waste disposal depends on the site
and extraction and conversion technologies involved, it will be
necessary to establish site-specific evaluations of solid waste
production including the wastes produced from pollution control
devices.
60
-------
VI. NOISE
A. Problem Evaluation
The noise produced in connection with geothermal development activity
may constitute a significant environmental impact in certain cases. Noise
emission can arise from a number of phases of geothermal exploration such
as drilling operations and the release of steam during well-bore cleaning.
After a plant is in operation, noise is produced by the generating
machinery cooling towers, transformers, and other devices. During periods
of maintenance, the steam wells are shut down and, when generation resumes,
the wells and collection lines must be purged of condensed water and
allowed to reach thermal equilibrium before steam is admitted to the
generator. During this process, steam is exhausted directly to the at-
mosphere, a process that is very noisy if suitable mufflers are not
applied. Very loud noises can cause temporary or permanent loss of
hearing, especially in an occupational setting, but lower levels can
also affect public welfare, as in the case of a vacation site or
residential area whose attractiveness is decreased by noise from a nearby
geothermal installation.
1. Overall Situation Assessment
Acoustic noise as an environmental problem may show up as a
nuisance affecting recreational land use or may have adverse effects
on some forms of wildlife. Either effect is likely to occur only in
special circumstances peculiar to individual sites.
B. Guidance and Regulatory Actions
EPA does not have any direct authority over noise generated by
geothermal installations. The agency's authority in noise abatement
and control is limited to a few closely defined areas including trans-
portation noise as it occurs in airports, railroad switching yards,
and highways. EPA also has the authority to prescribe regulations for
products designated as major noise sources, where noise emission
standards are feasible and where the product falls into one of the
following categories: construction equipment, transportation equip-
ment, any motor or engine, electrical or electronic equipment.
However, under Section 14 (Research, Technical Assistance and
Public Information) of the Noise Control Act of 1972, EPA is authorized
to complement, as necessary, the noise research programs of other
Federal agencies on the effects, measurement and control of noise. In
addition, Section 4(c)(l) authorizes EPA to coordinate the programs of
all Federal agencies relating to noise research and noise control.
61
-------
1. Guidance
If noise becomes an environmental problem in geothermal develop-
ment, EPA could collect data and issue guidance to state and local
noise control authorities.
C. Recommended Pathway and Associated Information Needs
GWG recommends that EPA keep abreast of noise production associated
with geothermal projects so that it can recognize potentially significant
impacts and issue appropriate guidance. This activity may involve
coordination with ERDA and review of data by EPA, supplemented by
specific noise measurement activity where the need is evident. Early
guidance can influence ERDA's internal environmental and safety regula-
tions, which are applicable to all projects using ERDA funds.
62
-------
VII. LAND USE IMPACT
A. Problem Evaluation
The development of a geothermal resource involves use of sub-
stantial land areas. In addition to the generating station, which
may occupy about 51 hectares (ha) for a power plant of 1000 MW electrical
output (MWe), geothermal development involves the drilling of numerous
wells and installation of a system of pipelines to collect the fluid.
Based on experience at The Geysers, a geothermal power plant of 1000
MWe may require from 90 to 150 wells. The spacing involves about 24
hectares of land per well, or between 2000 and 3600 hectares for such
installation. Since geothermal steam and hot water cannot be trans-
ported economically over long distances, the energy must be used or
converted into electrical power near the source. Thus, the impact of
a geothermal source is principally on the development site itself.
This is in contrast to most other energy sources, which may require
considerable land areas for mining, fuel processing, and transporta-
tion in addition to the actual use or electrical generation site.
1. Impacts of Geothermal Development
As noted above, the bulk of the affected area is involved with
the geothermal wells and collection lines. The wells require heavy
machinery for their drilling and completion, which in turn implies a
need for construction or improvement of access roads to support the
activity. Depending on soil conditions in the area, the roads may
require some form of artificial surface or soil stabilization.
The drill pad required for each well may range from one half to
one hectare, and must be leveled and cleared of vegetation. The
drilling operation includes a sump for the containment of waste fluids
and drill cuttings, which must be lined or sealed to provide a basin.
Its size depends on the expected depth of the hole; the surface area
may range from less than a hundred to several thousand square meters,
with a depth of one to three meters or more. Steam or hot water lines
are run above ground, and include large loops placed at intervals to
allow for thermal expansion and contraction. Construction of these
lines involves ecological disturbance to wild areas, and their existence
may impede the use of farm machinery in agricultural areas.
Local riparian and other customary land rights may be infringed
by the intrusion of the structure and its attendant lines. Odor and
acoustic noise, both discussed in preceding sections, may reduce the
value of resort, recreational, or residential land use if not adequately
controlled.
63
-------
2. Compatibility with Other Land Uses
Although the development of a geothermal resource may prevent some
land uses, other uses may continue in reasonable harmony. The site at
Lardarello, Italy is also used for farms, vineyards, and orchards.
Prior to the development of The Geysers, the land was used for hunting
and fishing. This use has continued, along with approximately 360 hec-
tares recently leased for cattle grazing. The impact of geothermal
development on land use can be expected to present different problems
for each site, which must be resolved with the cooperation of the
developer, property owners, and state and local government agencies.
3. Overall Situation Assessment
The question of land use impact tends to be highly site-specific
for any energy generating plant, because of the disparity of other
uses to which a given site may be put. Geothermal energy presents an
opportunity in this area to blend energy extraction with other bene-
ficial uses of the land.
B. Guidance and Regulatory Actions
The Environmental Protection Agency has no specific authority in
the area of land use control at the present time.
C. Recommended Pathway and Associated Information Needs
GWG recommends that EPA keep abreast of the land-use impacts at
existing geothermal installations in the U.S. and abroad, as well as
the potential conflicts involved with planned EKDA projects. This
activity will generate a data base for EPA guidance to its regional
offices and to EKDA, which may be influenced toward adopting environ-
mentally protective site selection criteria and land use practices in
geothermal demonstration installations where extensive commercial
development might follow.
64
-------
SECTION 5
SUMMARY
I. BACKGROUND
The Federal Geothermal Advisory Council (GAG), on which EPA is
represented, has requested that EPA develop standards or guidelines
for the emerging geothermal energy industry.
Because geothermal energy is only one of a series of new energy
technologies and because EPA's regulatory program priorities and
resources are largely committed to addressing existing industrial
problems (including conventional energy-related pollution sources),
an internal EPA working group was formed to recommend an approach
to answer GAC's request. It was agreed that the Office of Research
and Development should chair the working group because of its lead
role in the Interagency Energy/Environment R&D Program, which is
aimed at developing information on the environmental effects of the
emerging energy technologies.
II. GEOTHERMAL WORKING GROUP CONCLUSIONS AND RECOMMENDATIONS
A. Problem Assessment and Conclusions of the
Geothermal Working Group
While the evolutionary phase of the geothermal energy industry
does not immediately present a significant environmental threat,
environmental issues relating to geothermal energy are expected to
arise in several locales throughout the Western U.S. within the
next 5 to 10 years. The diverse nature of geothermal resources
demands that the severity of the local threat to health and the
environment be examined on a case by case basis. Therefore, the
GWG has reached the following conclusions.
1. Environmental Standards
• In view of the state of knowledge of geothermal resources
and the status of and ERDA's plans for conversion technology
development, and given the evolutionary nature of geothermal
development, the immediate setting of standards for the
industry by EPA is unnecessary.
• However, in view of the federal plans for and commitment to
energy development, EPA as a whole should plan now to be in
a position to set standards and to regulate the evolving
industry as events demand.
65
-------
2. Emission and Effluent Information
• Continually updated information on emission and effluent
profiles and environmental implications of geothermal
energy extraction and conversion technologies is (and will
continue to be) needed from ERDA and industry during
development, but especially in advance of key decision
points in ERDA's choice of specific processes.
• Therefore, EPA must actively consult and participate with
ERDA and industry as development proceeds.
3. Multimedia Pollutant Information
• Much environmental information on geothermal resources is
available from various federal and state agencies, but it
is not comprehensive when compared with EPA's regulatory
needs.
• Information on geothermal resource sites is needed from
these sources (e.g., ERDA, USGS, states) as early as possi-
ble in advance of development, with additional data to be
gathered by EPA as development demands.
B. EPA Authorities and Capabilities
• No specific EPA standards, criteria or regulations exist for
the geothermal industry as such.
• New Source Review in its present form cannot regulate expected
emissions from geothermal plants.
• NPDES may be capable of regulating some geothermally related
contaminants, but not in a comprehensive manner at present.
• Environmental Impact Review provides an important mechanism
for assessing the overall effects of a specified project, but
it is not designed to impact the evolution and development of
the technology and resource type selection which lead to the
EIS for specific projects or to the EAR for programmatic
documents.
• Existing NAAQS and NESHAPS cannot effectively control geotherm-
ally related air pollutants.
• Existing water quality criteria may be applicable in regulating
some geothermal effluents. This approach should be examined in
detail at once to determine its breadth of effectiveness.
66
-------
o Existing injection regulations appear to be generally adequate
for regulation of geothermal development, but this must be re-
evaluated periodically in the light of evolving technology.
C. Strategy and Recommendations
The basic strategy recommended for adoption by EPA is to influence
the eventual (commercialization phase) choices of geothermal resource/
technology combinations to be made by ERDA and industry by continually
participating in the RD&D phase of the national geothermal program as
it evolves, through the establishment of a formal consulting role with
ERDA's geothermal development office.
It is recommended, therefore, that EPA take the following steps:
a) Establish a formal Memorandum of Understanding (MOU) with
ERDA's Division of Geothermal Energy defining the role of EPA
in DGE's program.
b) Embark on an interim program of periodic dissemination of
formal guidance to ERDA and industry which is geared to devel-
opmental progress.
c) Issue, as requested by GAG, an initial Guidance Manual based
on present knowledge in July 1977.
d) Adopt a coherent, EPA-wide regulatory mission-oriented time-
table and associated R&D program wherein comprehensive regula-
tory decision milestones are geared to the pace of industry
development and the R&D information required to make such
decisions is developed in the course of actual technology
development. The expected ERDA and EPA milestones in this
development are summarized in Table VIII and for OAWM and
OWHM in Figures 4, 6, and 8.
e) The need for special standards should be evaluated for certain
specific or unique problems, such as that of hydrogen sulfide
at The Geysers.
f) The decision to promulgate standards and criteria for the geo-
thermal industry should be evaluated well in advance of com-
mercialization in order to be useful in preliminary environ-
mental review processes. (See Figures 4, 6, and 8.)
g) A comprehensive, long-range EPA R&D program should be
developed in accordance with the needs herein noted.
67
-------
h) A standing internal EPA staff group should be maintained to
coordinate development of the guidance manuals.
i) The recommended approach for geothermal air regulation is
through evaluation of the need for and development of NSPS
keyed to events in geothermal development.
j) The recommended approach for geothermal water quality regulation
is through development of effluent guidelines keyed to events in
geothermal development.
68
-------
TABLE VIII
KEY MILESTONES IN PROPOSED EEDA/EPA GEOTHERMAL ACTIVITY
These EPA Agency milestones are keyed to ERDA/industry events in the development of various geothermal resource types. The dates given are best
estimates as of 1976. They must be updated by ORD each year to reflect changes in the ERDA Geothermal RD6.D Program and in industrial initiatives. The
relative relationship of EPA events to ERDA/industry events must be preserved or changed through intra-EPA review to ensure a comprehensive and temporally
coherent EPA response.
EPA EVENTS
(Parentheses Indicate ERDA/industry Events Determining
YEAR Schedule of EPA Events and Future EPA Events for which
(1976 ESTIMATE) ERDA/INDUSTRY EVERTS Earlier EPA Events Prepare)
1976
DRY STEAM (GEYSERS)
LIQUID DOMINATED
HYDROTHERMAL
ex
GEOPRESSURED
HOT DRY ROCK
1977
DRY STEAM (GEYSERS)
1. Continue additional increments of capacity at
The Geysers, CA
2. Continue equipment tests for desalting-power
production units* (Imperial Valley, Mesat CA)
3. Continue development and testing of high
temperature, high salinity thermal test loop
(flash to binary cycle). (Imperial Valley,
Niland, CA)
4. Begin development and testing of high temperature,
high salinity direct flash test rig. (Imperial
Valley)
5. Begin development of high temperature, moderate
salinity test facility. (Imperial Valley,
East Mesa, CA)
6. Continue planning of liquid-dominated hydrothermal
demonstration plant number 1. (Imperial Valley,
Heber, CA)
7. Continue volcanic hydrothermal evaluation studies.
(Hawaii)
8.- Continue production and completion technology
development studies- for geopressured resources
(Louisiana and Texas)
9. Continue conversion technology development
stud ies for geopressured resources
10. Continue hot dry rock energy extraction
technology studies
11. Continue hot dry rock heat extraction experiments
and development of test facilities (Jemez Mt. , NM)
12. Industry initiates continued expansion planned
annually through 1985 (Pending resolution of local
environmental questions)
1. Begin evaluating emissions, effluents, and ground
water impact at The Geysers (ERDA event 1, EPA
event 3)
2. Begin evaluating air, water, and ground water
problems for Imperial Valley hydrothermal sites.
(ERDA events 2-6; EPA event 4)
3. Decision on need for EPA standards applicable to
The Geysers (ERDA event 12, EPA event 9)
Bureau of Reclamation activity
-------
TABLE VIII (CONTINUED)
KEY MILESTONES IN PROPOSED ERDA/EPA GEOTHERMAL ACTIVITY
YEAR
(1976 ESTIMATE)
LIQUID-DOMINATED
HYDROTHERMAL
ERDA/INDUSTRY EVENTS
GEOPRESSURED
1978
LIQUID-DOMINATED
HYDROTHERMAL
GEOPRESSURED
HOT DRY ROCK
1979
• DRY STEAM (GEYSERS)
LIQUID-DOMINATED
HYDROTHERMAL
HOI DRY ROCK
13. Begin development and testing of high temperature,
high salinity test facility. (Imperial Valley)
14. Decision to construct moderate temperature resource
thermal loop (Raft River, Idaho)
15. Begin planning liquid-dominated hydrothermal
demonstration plant number 2
16. Begin planning of geopressured resource pilot plant
Begin construction of 500,000 GPD-500 kW desalting
power production pilot plant* (Imperial Valley)
Decision to construct high temperature, high salinity
pilot plant (Imperial Valley)
Decision to construct geopressured resource test
facility/pilot plant
20. Begin impermeable hot, dry rock energy
extraction test
21. Industry enpansion phase underway
Begin construction of liquid-dominated
hydrothermal demonstration plants number 1 and
number 2
Begin operation of 500,000 GPD-500 kW desalting-
power production pilot plant* (Mesa, Imperial
Valley, CA)
Decision to convert moderate temperature thermal
loop to pilot plant (Raft River, Idaho)
Decision to construct test facility and thermal
loop for volcanic resources
Begin planning and construction of hot dry rock
pilot plant
EPA EVENTS
(Parentheses Indicate ERDA/Industry Events Determining
Schedule of EPA Events and Future EPA Events for which
Earlier EPA Events Prepare)
4. Issue initial guidance manual for air, water, and
ground water effects of Geysers, Imperial
Valley and Raft River hydrothermal sites;
characterize emissions, effluents, and ground water
effects (ERDA events 1-6, 12, 13, 14) (July, 1977)
5. Evaluate environmental problems for other liquid-
dominated hydrothermal sites (e.g. Eeowawe,
Roosevelt H.S., Coso H.S.) (ERDA event 15,
EPA event 10)
6. Begin control technology evaluation for Imperial
Valley and Raft River hydrothermal sites (ERDA
events 2-6, 13, 14, 17, 18, 22; EPA events 11,12)
7 . Begin to evaluate environmental problems of geo-
pressured resources (ERDA events 8, 9, 16, 19, 36;
EPA events 19, 25)
8. Begin data capture on hot, dry rock thermal
extraction experiment (ERDA event 20, EPA event 20)
9. Target date for EPA standards for dry steam, if
necessary from EPA decision event 3
10. Characterize emissions and evaluate control
technology at initial installations at other hydro-
thermal sites (ERDA events 15, possibly 7; EPA
event 13)
Bureau of Reclamation
-------
TABLE VIII (CONTINUED)
KEY MILESTONES IN PROPOSED EEDA/EPA GEOTHERMAL ACTIVITY
YEAR
(1976 ESTIMATE)
1980
LIQDID-DOMINATED
HYDROTHERMAL
1981
LIQUID-DOMINATED
HYDROTHERMAL
HOT DRY ROCK
GEOPRESSURED
1982
LIQUID-DOMINATED
HYDROTHERMAL
GEOPRESSURED
1983
LIQUID-DOMINATED
HYDROTHERMAL
GEOPRESSURED
1984
HOT DRY ROCK
ERDA/INDUSTRY EVENTS
27. Begin construction of CRBSCP—Title 1 desalting-
power production plant*
28. Begin construction of Mesa anomaly desalting-power
production plants*
29. Begin operation of high temperature, moderate
salinity test facility in Imperial Valley
30. Begin operation of high temperature, high salinity
pilot plant in Imperial Valley
31. Begin operation of moderate temperature pilot
plant (Raft River, Idaho)
32. Begin operation of demonstration plant number 1
(Imperial Valley)
33. Begin operation of demonstration plant number 2
34. Begin permeable hot, dry rock extraction test
35. Begin operation of volcanic hydrothermal
resource test facility
36. Begin operation of geopressured resource pilot
plant
37. Initial commercialization of other hydrothermal
sites
38. Geopressured pilot plant operation continues
39. Begin planning and construction of hot, dry
rock demonstration plant.
EPA EVERTS
(Parentheses Indicate ERDA/Industry Events Determining
Schedule of EPA Events and Future EPA Events for which
Earlier EPA Events Prepare)
11. Decision on need for EPA standards applicable to
Imperial Valley and Raft River sites (ERDA events
2-6, 13, 17, 18, 23, 29, 30, 31, 32, 33; EPA
events 12, 16)
12. Issue final guidance manual for Imperial Valley and
Raft River hydrothermal sites (ERDA events 27-30,
32)
13. Decision on need for EPA standards applicable to
other hydrothermal sites (ERDA events IS, 22, 33;
EPA event 18 )
14. Begin emissions characterization at geopressured
test sites (ERDA events 8, 9, 19, 36; EPA events
19, 22)
15. Issue guidance manual for other hydrothermal sites
(ERDA events 15, 21, 33; EPA event 24)
16. Target date for EPA standards for Imperial Valley
and Raft River hydrothermal sites if required by
EPA event 11 (ERDA events 31 and 32)
17. Geopressured emissions characterisation (ERDA event
36 ; EPA event 19)
18. Target date for EPA standards for other hydrothermal
sites if required by EPA event 13 (ERDA event 33)
19. Evaluate control technology for geopressured test
installations (EHDAevents 36, 38)
20. Evaluate environmental problems of hot, dry rock
resources (ERDA event 39, EPA events 28, 29)
Bureau of Reclamation activity
**Colorado River Basin Salinity Control Project
-------
TABLE VIII (CONCLUDED)
KEY MILESTONES IN PROPOSED ERDA/EPA GEOTHERMAL ACTIVITY
YEAR
(1976 ESTIMATE)
1985
LIQU ID-DOMIN ATED
HYDROTHERMAL
GEOPRES5URED
• HOT DRY ROCK
1986 - 2000
• LIQUID-DOMINATED
HYDROTHERMAL
• GEOPRESSURED
ERDA/INHUSTRY EVENTS
40. Begin operation of CRBSCP—Title 1 desalting-
power production plant*
41. Geoprassured demonstration (1985)
42. Begin operation of hot, dry rock pilot plant
43. Widespread hydrothermal commercialization
(After 1985)
44. Geopressured commercial plant (1986 - 1991)
EPA EVENTS
(Parentheses Indicate ERDA/Industry Events Determining
Schedule of EPA Events and Future EPA Events for which
Earlier_EPA Events Prepare)
21. Assess impacts of commercial-scale development of
Imperial Valley sites
22. Decision on need for EPA standards applicable to
geopressured development (ERDA event 36; EPA
events 25-27)
23. Environmental data capture (ERDA event 42; EPA
event 29)
24. Assess impacts of commercial-scale development of
other hydrothermal sites (1986 - 1990)
25. Issue guidance manual for geopressured development
(1986)
VI
IO
HOT, DRY ROCK
45. Begin operation of hot, dry rock demonstration
plant (Date uncertain)
Target date for EPA standards for geopressured
(1987 - 1990)
Assess impacts of commercial-scale development of
geopressured resources (1990)
Begin emissions characterization and control
technology evaluation for hot , dry rock resources
(Approximately 1986) (ERDA event 42; EPA event 29)
Issue guidance manual for hot dry rock resources;
evaluate need for EPA regulation (1989) (ERDA
event 45)
Bureau of Reclamation activity
*
Colorado River Basin Salinity Control Project
-------
Member
APPENDIX A
GEOTHERMAL WORKING GROUP MEMBERS
Organization
Gregory J. D'Alessio Office of Energy, Minerals
Chairman & Industry
William E. Bye
Albert E. Fry
David Shaver
Robert P. Hartley
Kenneth Mackenthun
Gary McCutchen
Neill Thomasson
David Duncan
George Stevens
Eugene Wyszpolski
Mark Mercer
Ground Water Protection
Branch
Office of Planning and
Management
Office of Planning and
Management
Industrial Environmental
Research Laboratory-
Cincinnati
Office of Water Planning
and Standards
Office of Air Quality
Planning and Standards
Office of Radiation
Programs
Office of Radiation
Programs
Participant from Other Offices
Stationary Source
Enforcement Division
Office of Noise Control
Programs
Office of Solid Waste
Programs
Telephone Number
(202) 426-4568
(202) 755-2484
(202) 755-2811
(202) 755-2893
(513) 684-4335
(202) 755-0100
(919) 688-8146
Ext. 271
(202) 755-4860
(202) 755-0920
(202) 755-0103
(202) 557-8292
(202) 755-9170
73
-------
APPENDIX B
GEOTHERMAL RESOURCE AREAS
75
-------
EXPLANATION
KNOWN GEOTHERMAL
RESOURCE AREAS
<£>
POTENTIAL GEOTHERMAL
RESOURCE AREAS
AREAS VALUABLE
PROSPECT1VELY
KNOWN GEOTHERMAL RESOURCE AREAS
POTENTIAL SEOTHERMAL RESOURCE AREAS
Source: Comptroller General of the United States, "Problems in Identifying
Developing and Using Geothermal Resources," March 6, 1975.
FIGURE B-1
KNOWN AND POTENTIAL GEOTHERMAL RESOURCE
AREAS IN THE UNITED STATES
76
-------
EXPLANATION
DtPlH OF OCCURRENCE. IN
METERS BELOW MEAN SEA LEVEL
940
O^ CONTINENTAL
GULF OF MEXICO
26
MEXICO
Kilometers
26°
FIGURE B-2
AREAS OF POTENTIAL GEOPRESSURED RESOURCES IN THE U.S.
-------
VOBOISE
MOUNTAIN
KLAMATH
OFALLS Q
ALAKEVIEW
Developed Geothermal
Field
Areas Undergoing
Evaluation for
Development
Deep Exploratory
Drill Hole, 1968-75
Drilling as Part of
Research Program
Utilization of Low-
Enthalpy Fluids
Source: Jamas B. Koenig, et al, "Exploration and Develop-
ment of Geothermal Resources in the United
States," Second United Nations Symposium for
the Development and Utilization of Geothermal
Resources, San Francisco, May 1975.
FIGURE B-3
GEOTHERMAL EXPLORATION IN THE UNITED STATES
78
-------
APPENDIX C
STATUS OF H2S CONTROL TECHNOLOGY AT THE GEYSERS
PG&E has recently begun full-scale source control of 110 MW
Unit No. 11. H2S is combined with oxygen in the presence of an
iron catalyst to yield water and sulfur. The sulfur is iron-
contaminated and unsalable, creating a solid waste problem. An
estimated 90 percent efficiency reduces ^S emissions to 0.5 pounds
per MWh. Newer power plants use surface rather than direct contact
condensers, so that most (90 percent) of the ^S comes out in the
noncondensable gases. This permits use of the Stretford process to
remove ^S, a system which, if efforts are made to minimize H2S
escape at the cooling tower, results in overall efficiencies as
high as 98 percent.
Both control systems treat gases after the steam leaves the
turbine. If the turbine is shut down, the ^S-laden steam is vented
directly to the atmosphere. Because it requires 24 hours to shut down
a well and additional time to reopen one and clear out pebbles and
rocks which can be picked up by the steam and damage the turbine, it is
impractical to shut down the well during brief periods of turbine down-
time.
Treating steam prior to the turbine may prove feasible. This
would permit control during shutdown. ERDA-sponsored laboratory
studies are exploring the feasibility of using regenerated copper
or nickel to capture the H£S as a sulfate.
79
-------
APPENDIX D
CHEMICAL ELEMENTS AND COMPOUNDS REPORTED IN
ANALYSES OF GEOTHERMAL FLUIDS
Aluminum
Ammonia
Argon
Arsenic
Bicarbonate/carbonate
Barium
Boron
Bromide
Cadmium
Calcium
Carbon Dioxide
Carbon Monoxide
Cesium
Chloride
Chromium
Copper
Ethane
Fluoride
Hydrogen
Hydrogen Sulfide
Iodide
Iron
Lead
Lithium
Magnes ium
Manganese
Mercury
Methane
Nitrogen
Nitrous oxides
Nitrate
Oxides of sulfur
Phosphate
Potassium
Rubidium
Silica
Silver
Sodium
Strontium
Sulfate
Sulfide
Zinc
Source: J. G. Douglas, et al., Geothermal Water and Gas:
Collected Methods for Sampling and Analysis,
Battelle Pacific Northwest Laboratories, Richland,
Washington, August 1972.
81
-------
APPENDIX E
ANNUAL CHEMICAL DISCHARGES TO THE WAIKATO RIVER FROM
THE WAIRAKEI GEOTHERMAL POWER PLANT
Constituent Approximate Annual Discharge in
Metric Tons per Year
Boron 1,100
Lithium 520
Sodium 48,000
Potassium 7,600
Rubidium 120
Cesium 100
Magnesium 0.19
Calcium 680
Fluorine 310
Chlorine 83,000
Bromine 220
Iodine 19
Ammonia 6
Sulfate 96°
Arsenic 160
*Mercury 0.006
Silica 25,000
Appears on list of 65 chemicals named in consent degree between
environmental groups and LfA.
Source- R. C. Axtmann, "Environmental Impact of a Geothermal Power
Plant", Science, v 187, n 4179, 7 March 1975
83
-------
APPENDIX F
EIS REVIEW
The Environmental Protection Agency participates in the
environmental impact statement (EIS) process in a number of ways:
o EPA may provide guidance and information to other Federal
agencies at the pre-EIS stage of a major Federal action.
Under certain circumstances, EPA may assist in the prepara-
tion of another agency's EIS, but such a contribution must
be clearly identified as a product of EPA.
o EPA must review and comment in writing on all EIS's issued
by other Federal agencies. EPA comments, directed to the
ElS-issuing agency, address both the adequacy of the EIS
and the environmental impact of the proposed action.
o EPA may refer to the Council on Environmental Quality those
proposed major Federal actions which, through the EIS review
process, EPA has determined to be unacceptable from the stand-
point of environmental quality.
o Also, EPA itself can have direct EIS preparation responsibili-
ties for those of its actions (NPDES permit issuance, ocean
dumping permits, wastewater treatment plant construction grants,
etc.) which may have significant environmental impact.
The EIS preparation and review responsibilities of EPA are shared
between the Office of Federal Activities (OFA) at the headquarters
level and each of the regional offices. OFA serves as the principal
reviewer for those EIS's having a national or programmatic scope or those
which affect more than one EPA region. The Agency's regional offices
generally coordinate the review of site-specific EIS's.
85
-------
APPENDIX G
CURRENT ENVIRONMENTAL RESEARCH IN
GEOTHERMAL ENERGY
Tables G-I and G-II summarize research now under way, sponsored
largely by the Federal government. Table G-I comprises current and
proposed ERDA-sponsored work. Table G-II, compiled from information
furnished by Smithsonian Science Information Exchange, Inc., is more
lengthy because it includes many efforts in which the environmental
effect of geothermal energy plays one role in a much larger study and
some that are program efforts rather than research itself. It does
include work addressed to the environmental problems of water quality,
noise, thermal pollution, and subsidence.
The Office of Radiation Programs of EPA recently prepared a
Technical Note describing initial investigations of the radioactivity
of geothermal waters in the western United States*- This report pre-
sents radiochemical data for 136 hot springs and shallow wells, and
includes some brief remarks about potential activities involving human
exposure.
The picture presented by current research appears to be a piece-
meal attack on the problem, with many areas of concern addressed
peripherally or omitted entirely-
It should be noted that MITRE is currently conducting a study
for ERDA to provide a comprehensive compilation of research programs
having geothermal applications. It is expected that this study will
provide a more complete accounting of research efforts, including
geothermally applicable projects stimulated by the problems of other
energy sources.
*M.F. O'Connell and R.F. Kaufman, Radioactivity Associated with
Geothermal Waters in the Western United States. Environmental
Protection Agency, ORP/LV-75-8A, Las Vegas, Nevada, March, 1976.
87
-------
TABLE G-I
CURRENT ERDA ENVIRONMENTAL STUDIES
CONTRACTOR
00
CD
Oak Ridge National
Laboratory
Battelle-Pacific
Northwest Laboratory
Argorme National
Laboratory
EIC, Inc.
Newton, Mass
Dow Chemical,USA
Lawrence Berkeley
Laboratory
Los Alamos
Scientific
Laboratory
TITLE
Preparation of General Environmental Assessments
for the Hydrothermal,Geopressured, and Hot Dry Rock
Subprograms
Removal of Hydrogen Sulfide from Geothermal Steam
Guidelines to the Preparation of Environmental
Reports for Geothermal Development Processes
Control of Hydrogen Sulfide Emission from Geothermal
Power Plants
Investigation of Hydrogen Sulfide Removal from
Simulated Geothermal Brines by Reactions with
Oxygen
Subsidence in the Imperial Valley
Hydrothermal Seismic and Ground Water Studies
Geopressured Baseline Assessment - Seistnieity,
Subsidence, Etc.
OBJECTIVE
FUNDING *
FY 75 FY 76
Provide Independent Assessments of the Potential
Environmental Impacts Associated with Pursuit of
Geothermal Resource Development
Identify and Evaluate a Metaloxide Hydrogen Sulfide
Removal Process far Geothermal Steam 50
Provide Reporting Guidelines to Those Persons Who
Are Required to Submit Environmental Impact Informa-
tion in Connection with ERDA-Supported Geothermal <
Projects i
To Develop a Wet Scrubbing Process Which Can j
Economically Reduce Hydrogen Sulfide Concentrations ;
in Geothermal Steam ! 200
Evaluate a Hydrogen Sulfide Removal Process for
Geothermal Brines
185
72
156
*In thousands of dollars.
-------
00
-o
TABLE G-I (CONCLUDED)
CURRENT EKDA ENVIRONMENTAL STUDIES
CONTRACTOR
Lawrence Berkeley
Laboratory
Sandia Labora-
tories
TITLE
Geothermal Technology Environmental Impact
Assessment
Sandia Magma Energy Research Project
OBJECTIVE
Focus on Effects in Nevada
Feasibility Study of Tapping Magma Sources;
Attempt to Minimize Environmental Impact
FUNDING*
FY 75 PY 76
*ln thousands of dollars.
-------
TABLE G-II
CURRENT RESEARCH IN GEOTHERMAL ENERGY ENVIRONMENTAL IMPACT
SUPPORTING
ORGANIZATION
Central Power & Light Co.
EPA
EPA
EPA
FEA
FEA
FEA
FEA
PERFORMING
ORGANIZATION
University of Texas
Stanford Research
Institute
Industry and Environ-
mental Research
Laboratory
Environmental Monitor-
ing and Support Lab
RAND Corporation
Radian Corporation
Radian Corporation
University of
Oklahoma
PROJECT TITLE
Geopressured Geothermal Investigations in
South Texas
Support of Advanced Energy R6D Program Planning
for EPA
Survey of Environmental Regulations and the
Assessment of Pollution Potential Control
Technology Applications for Geothermal
Resources Development
Geothermal Systems: Environmental Assessment of
Extraction, Conversion, and Waste Disposal
Energy Alternatives for California
A Western Regional Energy Development Study —
Executive Summary
A Western Regional Energy Development Study—
Vol I, Analysis of Energy Scenarios
Energy Alternatives - A Comparative Analysis
1975
FUNDING*
100
—
122
250
122
—
—
--
COMMENTS
Environmental Impact Is One
Aspect
Geothermal Energy Included
Among Other Resources
Description of Legal and Techno-
logical Requirements for Geo-
thermal Pollution Control
Focus on Development & Validation
of a Monitoring Strategy for
Effects on Plants, Animals, &
Groundwater
Geothermal Development Appears
As Alternative to Alaskan Oil
Importation
Geothermal Energy and Environ-
mental Impact as Aspects of
Larger Study
Geothermal Energy and Environ-
mental Impact as Aspects of
Larger Study
Geothermal Energy and Environ-
mental Impact as Aspects of
Larger Study
*In thousands of dollars.
-------
TABLE G-II (Continued)
CURRENT RESEARCH IN GEGTHERMAL ENERGY ENVIRONMENTAL IMPACT
SUPPORTING
ORGANIZATION
PERFORMING
ORGANIZATION
PROJECT TITLE
1975
FUNDING*
COMMENTS
Ford Foundation
NASA, Space Science
Office
Netherlands Min.
of Trans, and
Public Works
New Mexico State
Government
NSF, Adv. Energy
Res.
NSF, Adv. Energy
Res.
NSFt Adv. Energy
Res.
California Institute
of Technology
NASA, Goddard Space
Flight Center
Netherlands Commission
on Remote Sensing
Technology
New Mexico State
University
University of Texas
Battelle, Northwest
University of New Mexico
Imperial City Government
Examination of Economic and Environmental
Limits of Growth
Geological Investigations Using Landsat
and Related Data
Mapping by Remote Infrared Recording of Thermal
Water Pollution
Geotherraal Investigations in Southwest
New Mexico
Phase 0 Resource Management and Scope of
Work Study for Generation of Electric
Power— Gulf Coast Geopressured
Geothermal Resource
Investigate the Nature and Environmental
Impacts of Heavy Metals Released During
Geothermal Energy Development
An Economic and Environmental Evaluation of
Solar and Geothermal Energy
Planning for Resource Development—Geothermal
Engineering in Imperial County, California
*In thousands of dollars.
59
318
135
364
Includes Geothermal Energy as
Alternative Power Source
Remote Sensing of Environmental
Fac tor s Includ ed
Addresses Water Chemistry and
Potential for Pollution
Establish Boundaries; Develop
Preliminary Plans—Environmen-
tal Impact Is One Aspect
Concentrates on As, Hg, Sb, Se
and Te at Geysers and Cerro
Prieto
Broad-Scale Evaluation of Social
Costs
City Government Study of
Resource, Costs, Benefits,
Policy Implications
-------
TABLE G-II (Continued)
CURRENT RESEARCH IN GEOTHERMAL ENERGY ENVIRONMENTAL IMPACT
SUPPORTING
ORGANIZATION
NSF, Adv. Energy
Res.
NSF, Research
Applications
NSF, Adv. Energy
Res.
NSF , Adv . Energy
Res.
NSF, Adv. Energy
Res.
NSF, Adv. Envir.
R&T
Pacific Gas &
Electric Co.
University of Texas
USGS, Water Res. Div.
USGS, Water Res. Div.
PERFORMING
ORGANIZATION
Systems, Science &
Software
University of Colorado
Colorado School of Mines
California, State
Division of Oil & Gas
St. Mary's College of
California
Systems Control Technology
Pacific Gas & Electric
Company
University of Texas
USGS, Woods Hole, Mass.
USGS, Sacramento, Cali-
fornia
PROJECT TITLE
Geobydrological Environmental Effects
of Geotherraal Power Production -
Phase II
Transport of Mass and Energy Due to Natural
Convection
The Geotherraal Basin Problem
Assessment of a Potential Geothermal
Reservoir in the Basin and Range Province
Workshop on the Environmental Aspects of
Geothermal Resources Development
Environmental Effects of Noise from Geothermal
Resource Development
The Analysis of Subsidence Associated with
Geotherraal Development and its Potential for
Environmental Impact
Environmental Studies at the Geysers Geothermal
Site, California
Geothermal Utilization Technology for Gulf
Coast Geopressure Resources
Hydrologic-Oceanographic Interrelations
Subsidence and Related Aspects of Geothermal
Systems
1975
FUNDING*
200
113
198
58
45
184
122
29
114
—
COMMENTS
Computer Model for Reservoir
Behavior During Production
Addresses Subsidence and
Seisraicity
Environmental Assessment As
One Aspect
California/Oregon Multi-
Disciplinary Workshop
Measurement of Noise Levels,
Auditory Damage, and Other
Effects
Imperial Valley
Geothermal Development Appears
as Alternative to Alaskan Oil
Importation
Environmental Aspect Addresses
Wastewater
Study of Transition Zone Between
Fresh and Salt Water
Establishment of Benchmarks and
Surveying
to
*In thousands of dollars.
SOURCE: Smithsonian Science Information Exchange, Inc.
-------
TABLE G-II (Concluded)
CURRENT RESEARCH IN GEOTHERMAL ENERGY ENVIRONMENTAL IMPACT
SUPPORTING
ORGANIZATION
EPA
EPA
EPA
EPA
EPA
PERFORMING
ORGANIZATION
ERL
National Institute
for Occupational
Safety and Health
National Bureau
of Standards
Oak Ridge National
Laboratory
Ames Laboratory
USERDA
Iowa State University
PROJECT TITLE
Identification of Components of Energy-
Related Wastes and Effluents
Direct-Reading Personal Gas and Vapor
Monitors
Standard Reference Materials for Air
and Water Pollution Monitoring
Instrumentation and Methods for
Geothermal Source Related Effluents
Development of Aqueous Effluent
Instrumentation and Methods for Energy-
Related Sources
1975 A
FUNDING
110
__
COMMENTS
Includes Geotherraal Energy
Among Other Source Types
Includes an H S Monitor
Segment of a larger effort
Segment of a larger effort
Segment of a larger effort
*o
co
-------
BIBLIOGRAPHY
1. G. McCutchen, Geothermal Energy Air Pollution Research Needs
EPA Memorandum, May 12, 1976.'~
2. W. E. Bye, Geothermal Energy Industry Standards and Guidelines.
EPA Memorandum, May 19, 1976.
3. W. N. Thomasson, ORP/EPA Geothermal Study Needs, EPA Memorandum,
May 18, 1976.
4. K. M. Mackenthun, Geothermal Energy Industry Standards and
Guidelines, EPA Memorandum, April 19, 1976.
5. K. M. Mackenthun, Geothermal Energy Research and Needs, EPA
Memorandum, May 5, 1976.
6. D. Anderson and Richard G. Bowen, Proceedings: Workshop
on Environmental Aspects of Geothermal Resources Develop-
ment, California Department of Conservation and Oregon
Department of Mineral Industries, 1974.
7. D. Britt, et al. , Balanced Program Plan, Vol. II: Energy
Technology Focus, MTR-7174, The MITRE Corporation, McLean,
Virginia, March, 1976.
8. R. C. Axtmann, "Dosimeters for Geothermal Contaminants,"
Energy/Environment Workshop on SRM's for Geothermal Energy
Utilization, National Bureau of Standards, Gaithersburg,
Maryland, (in press).
9. R. A. Axtmann, "Geothermal Emission Control," ibid.
10. General Discussion, Energy/Environment Workshop on SRM's
for Geothermal Energy Utilization, National Bureau of
Standards, Gaithersburg, Maryland, (in press).
11. M. F. O'Connell and R. F. Kaufman, Radioactivity Associated
with Geothermal Waters in the Western United States, Environ-
mental Protection Agency, ORP/LV-75-8A, Las Vegas, Nevada,
March, 1976.
12. S. L. Chiang and R. C. Kent, "U.S. Geological Survey's
Regulatory Function in Environmental Protection—Problems
and Needs," Energy/Environment Workshop on SRM's for Geo-
thermal Energy Utilization, National Bureau of Standards,
Gaithersburg, Maryland, (in press).
95
-------
BIBLIOGRAPHY (concluded)
13. E. W. Bretthauer, et al., "Current Needs and Future Plans of
.the Environmental Monitoring and Support Laboratory—Las Vegas
Program for Assessing the Impact of Geothermal Energy Develop-
ment on the Environment," ibid.
14. S. K. Gupta and K. Y. Chen, "Arsenic in Aqueous Solutions by
Flameless Atomic Absorption Spectrophotometry," ibid.
15. Environmental Aspects of Geothermal Energy Development,
Smithsonian Science Information Exchange, Inc., Washington,
May, 1976.
16. R. C. Axtmann, "Environmental Impact of a Geothermal Power Plant,"
Science, v. 187, n. 4179, 7 March, 1975, p 795.
17. A National Plan for Energy Research, Development, and Demonstration:
Creating Energy Choices for the Future. Volume 2: Program
Implementation, ERDA 76-1, Energy Research and Development
Administration, 1976.
18. Western Energy Resources and the Environment: Geothermal Energy,
RA-76-24, Resource Planning Associates, Inc., Cambridge, Mass.,
July 19, 1976.
19. Geothermal Water and Gas—Collected Methods for Sampling and
Analysis, BNWL-2094, Battelle Pacific Northwest Laboratories,
Richland, Washington, August, 1976.
20. H. W. Joy, The Salinity of Geothermal Brines as a Function of
Temperature, W52-M919, The MITRE Corporation, METREK Division,
Washington, D.C., 26 May, 1976.
21. G. Walsh, Flow Chart for Preferred Standards Path Analysis, EPA
Office of Air Quality Planning and Standards, Research Triangle
Park, North Carolina, unpublished.
22. K. Mackenthun, Preferred Standards Path Analysis Flow Chart for
Geothermal Water Quality Protection, private communication,
July, 1976.
23. W. E. Bye, Underground Injection Control (UIC) Path Analysis Flow
Chart for Geothermal Waste Water, private communication, September,
1976.
24. M. Schoaff, Union Oil Co., Private Communication, October 12, 1976.
96
------- |