State of California

Ventura County APCD Headquarters
Supervisors' Chambers
800 South Victoria Avenue
Ventura, CA

February 24, 1982
10:00 a.m.



82-4-1 Public Meeting to Consider a Suggested Control 001
Measure for the Emissions of Photochemically
Reactive Organic Compounds from Vents of Steam
Drive Oil Production Wells.

82-4-2 Public Meeting to Consider Status Report on an 146
Assessment of the Volatile and Toxic Organic
Emissions from Hazardous Waste Disposal in

82-4-3 Other Business

a. Closed Session
1. Personnel (as authorized by State Agency Open
Meeting Act, Govt. Code Sec. 11126(a).)
2. Litigation (Pursuant to the attorney-client
privilege, Evidence Code Sec. 950-962, and
Govt. Code Sec. 11126(q).)
b. Research Proposals
c. Delegations to Executive Officer


Harold Holmes
1102 Q' Street
Sacramento, CA 95814
(916) 322-5594


ITEM NO.: 82-4-1

A Suggested Control Measure for the Emissions of Photochemically
Reactive Organic Compounds from Vents of Steam Drive Oil
Production Wells.


The staffs of the Kern County Air Pollution Control District
(APCD) and the Air Resources Board (ARB) share lead
responsibility for development of a suggested control measure for
the control of emissions of hydrocarbon compounds from steam
drive oil production well vents. This statement discusses the
technical feasibility, and cost effectiveness of, and the reasons
for, the measure.

Steam drive wells are estimated to emit about 374 tons of non-methane
hydrocarbon compounds daily into the California
atmosphere. These emissions contribute to the formation of
atmospheric photochemical oxidants, including ozone. The air
basins in which steam drive wells are operated -- the San Joaquin
Valley, South Central Coast, North Central Coast, and South Coast
-- are federal nonattainment areas for ozone, and they experience
frequent violations of the state ambient air quality standard for

None of these air basins is expected to achieve ozone attainment
status by 1982. Accordingly, further reductions of hydrocarbon
compound emissions are needed in these air basins.

The ARB staff has found that the control of non-methane
hydrocarbon emissions from steam drive well vents is technically
feasible. In developing the suggested control measure, the staff
took into account available information including comments made
by oil producers and by Air Pollution Control District personnel.
The measure, as approved on December 15, 1981, by the Technical
Review Group for the Suggested Control Measure Development
Process, is presented for the Board's consideration. It is
recommended that the Board approve the measure as a suggested
control measure.

If approved by the Board, the suggested control measure will be
forwarded to appropriate air pollution control districts for
consideration as an amendment or addition to their rules if such
amendment or addition is necessary for attainment and maintenance
of the state and national ambient air quality standards for
oxidant and ozone, respectively. The suggested control measure
would become an enforceable regulation only after adoption into
the regulations of a district. Approval by the Board of the
suggested control measure does not create an enforceable

The major components of the proposed suggested control measure

1. None-methane hydrocarbon emissions from steam drive well
vents would be limited to 4.5 pounds per well per day;

2. Control systems which are used to control emissions from
steam drive well vents would be tested annually to determine
the compliance status of such systems, except that those
control systems which combust vented hydrocarbons could
obtain a waiver of this requirement; and

3. Wells that are being serviced may be exempted from emissions
control requirements, and wells that are remotely located
and have been only slightly influenced by steam injection
would also be exempt.

If the suggested control measure is adopted by air pollution
control districts, the major environmental impact that would
result would be a reduction of hydrocarbon emissions by about 84
tons per day in the state. Small increases in nitrogen and
sulfur oxides and particulate matter emissions would occur from
flares used to incinerate vented gases. Because most of the
hydrocarbon compounds collected as a result of implementation of
the control measure would be used as fuel, the suggested control
measure would also result in energy conservation.

The total cost of complying with the requirements of the
suggested control measure is estimated to be about $18,390,000;
approximately $12,300,000 of this amount would be spent for
controlling emissions of steam drive wells in Kern County. The
annualized cost incurred by implementing the suggested control
measure is estimated to be approximately $3,540,000; $3,300,000
of this amount would be incurred in Kern Country. Because the
emission reductions resulting from meeting the requirements of
the suggested control measure statewide are 84.6 tons per day,
the cost-effectiveness ration is about $0.06 per pound of
photochemically reactive organic compounds controlled. The
cost-effectiveness ratio is significantly less than other Board-approved
control measures such as those for double seals on
floating roof tanks and fugitive emissions from refinery pumps
and compressors ($0.80/lb and <$0.60/lb. respectively).

The sources of information used to develop the proposed suggested
control measure include the following: empirical data from
operators of steam drive wells and the EPA on emission rates from
steam drive well vents; journal articles on vapor control systems
used to control emissions from steam drive wells; contacts by
telephone and letter with manufacturers of components of well
vent emissions control systems; industry consultation meetings
held by the staffs of the Kern County APCD and the ARB; and
correspondence with representatives of the oil production
industry. The information obtained from these sources and relied
on by the staff in developing the proposed suggested control
measure is discussed or referenced in the staff report, which
will be available from the ARB Public Information Office 30 days
prior to the meeting to consider the suggested control measure.

ITEM NO.: 82-4-2

Public Meeting to Discuss an Assessment of the Volatile and Toxic
Organic Emissions from Hazardous Waste Disposal in California.


Approximately 3,000,000 tons of waste containing volatile or
toxic organic materials are disposed of in California each year.
The major amounts of these wastes are from the petroleum,
chemical products, and electronic industries.

Current methods of waste storage and disposal allow the escape of
volatile wastes to the atmosphere in significant quantities.
Land disposal practices such as ponding, land application, and
codisposal with municipal refuse permit direct exposure of
hazardous wastes to the atmosphere. Emissions of photochemically
reactive, volatile organic wastes contribute to smog formation,
and volatile toxic wastes may pose a direct threat to health.

Because of the potential for emissions of photochemically
reactive and toxic compounds, the Air Resources Board staff
examined current disposal methods, identified the types of wastes
that could pose an air quality problem, reviewed air monitoring
data collected in the vicinity of hazardous waste disposal sites,
estimated emissions for various disposal methods, and studied
alternative disposal technologies.

From these studies, the staff has estimated that approximately
440,000 T/Y of waste are disposed of by methods that are likely
to result in air emissions of volatile material. The average
volatile content of these wastes is estimated to be 20 percent
making the total amount of volatile material contained in the
waste potentially 80,000 T/Y.

In addition to volatile but generally nontoxic organics, at least
8900 T/Y of waste containing known or suspected human
carcinogens, (13 different compounds), was disposed of in Class I
facilities in 1979-1980. The disposal of these compounds is of
serious concern because present disposal techniques do not
adequately ensure that the compounds will not eventually escape
into the atmosphere.

The staff's analysis indicates that land disposal methods lead to
substantial emissions of volatile organic compounds. Sample
calculations for the BKK Class I facility in West Covina show
that emissions of selected volatile compounds are 4900 T/Y or 47%
of the selected volatile or toxic organic component of the waste
disposed of at this facility. This emission rate would make the
BKK site the largest single emission source in the Los Angeles
Basin. The Chevron, USA refinery in El Segundo is the next
largest source at 2860 T/Y.

High levels of hydrocarbon emissions have been detected at the
major hazardous waste disposal sites and downwind of the sites.
In some cases the concentrations of hydrocarbons are several
orders of magnitude higher than the National standard for
hydrocarbon emissions.

In October 1981, a state program was announced to address the
need to reduce the state's dependence on land disposal of
hazardous waste. State agencies were directed to study and
identify safe alternative disposal methods. The ARB, as the
state air pollution control agency, has therefore joined the
Department of Health Services (DHS), the Office of Appropriate
Technology (OAT), and the State Water Resources Control Board
(SWRC), in the study of improved methods for managing and
disposing of hazardous wastes. As a part of this effort, the ARB
staff has identified several environmentally preferable
alternatives for waste disposal. These alternatives include the
reduction of waste generation, increased waste recycling,
disposal using thermal decomposition techniques, and reduction of
waste through pretreatment. These alternative methods have been,
used extensively outside of California. Although they are
generally more expensive than land disposal techniques, these
alternatives are cost-effective, when viewed in terms of their
overall environmental benefits and in terms of the absolute cost
increase to industry.

The staff is also working with the Bay Area Air Quality
Management District (BAAQMS) to develop a suggested control
measure (SCM) to limit volatile organic emissions from hazardous
waste disposal operations.

As a result of investigations to date, the ARB staff has
concluded that land disposal of hazardous waste is a major source
of air pollution which is largely controllable. Although the
design of specific regulations to effect this control has yet to
be accomplished, all information to date supports the conclusion
that controls are both technically feasible and economically

Accordingly, this report recommends that activities to develop
these controls by both the ARB and air pollution control
districts be accelerated. It is also recommended that the Board
endorse a number of policies designed to accelerate the
implementation of alternatives to land disposal of volatile and
toxic organic wastes and to set the framework for decision making
on the safe operation of hazardous waste disposal facilities.