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Technology Transfer
Environmental Assessme
Perspective on the
Emerging Oil Shale  Industry
January 1981
This report was developed by the
EPA Oil Shale Research Group
with assistance from the
Centec Corporation
for the
Energy Pollution Control Division
Industrial Environmental Research Laboratory
Cincinnati OH 45268

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                        Foreword
Construction of mining facilities for commercial oil
shale development. Federal Lease Tract Cb in Colorado
                                                       When energy and material resources are extracted,
                                                       processed, converted, and used, the effects of related
                                                       pollution on  our environment and even on our health
                                                       often require that new and increasingly more efficient
                                                       pollution control methods be used. The Industrial
                                                       Environmental Research Laboratory in Cincinnati
                                                       is engaged in developing and demonstrating new
                                                       and improved methods that will meet these  needs
                                                       efficiently and economically.

                                                       This report provides a brief summary of a more
                                                       comprehensive report. Environmental Perspective on
                                                       the Emerging Oil Shale Industry (EPA 600/2-80-205).
                                                       The full  report provides a preliminary overview of
                                                       environmental considerations related to the emerging
                                                       oil shale industry. The report and similar ensuing
                                                       reports are intended to develop the technical basis
                                                       for eventual regulations.

                                                       The recently announced national synfuels program
                                                       relies on development of the oil shale industry.
                                                       We believe providing information on environmental
                                                       concerns and developing control technology  in
                                                       concert  with development of oil shale technology
                                                       will enable the establishment of a mature oil shale
                                                       industry compatible with national environmental
                                                       goals without unnecessary delay.

                                                       Further information on the subjects of this report can
                                                       be obtained from the Energy Pollution Control
                                                       Division, Industrial Environmental Research Laboratory,
                                                       Cincinnati, Ohio 45268.
                                                       Steven R. Reznek
                                                       Deputy Assistant Administrator for
                                                       Environmental Engineering and Technology
                                                       David G. Stephan
                                                       Director
                                                       Industrial Environmental Research Laboratory
                                                       Cincinnati

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Contents
           Foreword
           Introduction
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Recommendations and Conclusions
Environmental Impacts
    Atmospheric Emissions




    Water Quality




    Solid Waste




    Health




    Other Effects
Pollution Control Technology
    Air Emission Controls




    Waste water Treatment




    Solid Waste Controls




    Other Controls
Sampling, Analysis, and Monitoring

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 Introduction
 Oil shale deposits in the United States are among
 the richest and most extensive in the world. (Principal
 deposits are shown in Figure 1.) Total identified
 resources of medium  and rich shales in the Nation
 are estimated at 2 trillion equivalent barrels (320
 billion equivalent cubic meters) of oil. The Green
 River formation alone—which covers an area  of
 17,000 square miles (44,000 square kilometers) in
 Colorado, Utah, and Wyoming—contains an estimated
 1.8 trillion equivalent barrels (280 billion equivalent
 cubic meters) of oil. About 600 million barrels (95
 billion cubic meters) is considered recoverable by
 currently known technology.

 This environmental assessment report conveys the U.S.
 Environmental Protection Agency's (EPA's) under-
 standing of and perspective on oil shale development.
 For government agencies, private developers, and
 others involved in the oil shale  industry, the report
 provides a source of basic  information as well as
 a means of identifying EPA's concerns and interests
 relative to oil shale development. The report:

 • Summarizes available information on oil shale
   resources
 • Summarizes major air, water, solid waste, health,
   and other environmental impacts
 • Analyzes applicable pollution control technology
 • Provides  guidance for sampling, analyzing,  and
   monitoring emissions, effluents, and solid wastes
   from oil  shale processes

The report emphasizes those environmental impacts
and control  technologies that EPA believes will
be of major importance.

Section 7 in the more comprehensive report. Envi-
ronmental Perspective on the Emerging OH Shale
Industry (EPA 600/2-80-205a), and the companion
appendix volume (EPA 600/2-80-205b) contain
materials not included in this environmental assess-
ment. Section 7 provides a technical review of major
retorting methods and their probable emissions.
The Piceance Basin in Colorado, with recoverable
oil shale resources estimated at 500 billion equivalent
barrels of oil
effluents, and solid wastes. The appendixes com-
prise technical and data reviews:

• Appendix A. Status and Development Plan of the
  Oil Shale Industry
• Appendix B. Procedures for Ambient Air Monitoring
• Appendix C. Environmental Monitoring Activities—
  Past, Present,  and Proposed
• Appendix D. Applicable Federal, State, and Local
  Legislation, Standards, and Regulations
• Appendix E. Quality Assurance Bibliography
• Appendix F. Federal and State Permits Required
  for Operation of an Oil Shale Facility

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 Recommendations  and  Conclusions
 Shale oil production will combine a number of
 processing operations on one site: mining, ore
 preparation, retorting, gas treatment, refining, and solid
 waste management. The scale of operation will be
 massive. Consequently, the rates at which point source
 and fugitive pollutants are generated will require
 strict control. Potentially applicable control technolo-
 gies employed in related industries—such as petroleum
 production, stone crushing,  cement manufacture,
 and electric power generation—may not be directly
 transferable to shale oil production because of process
 mixes and integration.

 The environmentally problematic effluents and wastes
 from oil shale operations have  not been thoroughly
 characterized. In some cases, adequate sampling
 and analysis methods have not been developed,
 validated, and standardized.  In a commercial operation
 the  byproducts of retorting will usually be processed
 in some further way before their characteristics
 as potential pollutants can be identified and control
 technology developed. Site- and process-dependent
 pollutants, particularly trace  organics and inorganics,
 may have the greatest potential impact on health and
 welfare. Finally, refining shale oil into end use products
 may result in increased emissions of toxic compounds.

 Control technologies for treatment of off-gases are
 generally believed to be adequate, but they need
 to be demonstrated for key pollutants in off-gas streams.
 Additional studies are needed, however, to characterize
 off-gases from both in situ and surface retorting
 processes because of the potential for release  of
 toxic trace elements.

 It will be especially important to control particulates
 from mining and handling operations by use of
 suppression systems. Water sprays, along with wetting
 agents and organic binders,  need to be evaluated
for use at the points of emission as well as on
 haulways and ore piles.  In-mine localized paniculate
 removal by modular wet scrubbers, electrostatic
precipitators, or baghouses needs to be evaluated.
 For example, whether electrostatic  precipitators
can be used to control particulates from mining and
 crushing operations will depend on characteristics
 of the dust.  Raw oil shale dust resistivity has not
 been adequately investigated. Additional studies
 are needed, especially with respect to fine paniculate
 control.

 Because of the absence of a full-scale oil shale
 industry, the adequacy of control technologies for
 handling oil  shale wastewaters is still questionable.
 Some oil shale developers contemplate using retort
 water to moisten retorted shale for dust control and to
 aid compaction. If the retort wastewater  is used in
 this manner, the hazardous and toxic constituents
 might migrate to local surface and ground water supplies.

 Modified in situ oil shale processing will generate
 more wastewater than can be consumed by process
 reuse. Subsurface injection or surface discharge
 may be  necessary. Wastewater constituents may
 include  hazardous organics (polycyclic materials,
 phenolics, amines) and  inorganics (arsenic, molyb-
 denum,  vanadium, boron, among others}. Control
 techniques must be  developed, therefore, to ensure
 effective removal of  these constituents before
 wastewater disposal.

 Little is  known about the movement of ground water
 into and through abandoned chambers of modified
 in situ operations. To date, only speculations have
 been made about the leaching of such chambers by
 ground water. Consequently, laboratory studies
 should be conducted to determine probable leaching
 rates and concentrations of organic and inorganic
 constituents. These studies should be supplemented
 by field monitoring of existing and near-future in situ
 retorting operations.

The disposal  of solid wastes resulting from oil shale
 mining and processing is a major environmental
concern. Retorted shale  could  present problems of
surface and ground water degradation if pile stability
and impermeability are not maintained. All research
and monitoring programs to date have dealt with
relatively small  quantities of retorted shale.  Potential
problems, such as mass stabilization of shale piles
and maintenance of an impervious layer below
plant root zones, can likely be identified and solutions
found only by creation of a large pile from commercial-
scale processing.

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 Recommendations and Conclusions
 •  Providing adequate water quantities
 •  Maintaining air quality so as to protect health and
    welfare
 •  Minimizing detrimental land disturbances to
    preserve adequate habitat for wildlife
 •  Protecting valuable socioeconomic, cultural,
    historical, and aesthetic values

 Source standards and ambient standards will apply to
 individual oil  shale facilities and to an oil shale
 industry. The ambient standards most directly affect the
 industry as a whole, rather than any individual facility,
 in that the Piceance and Uinta Basins (and the Colorado
 River Basin) have a finite carrying capacity for air
 and water pollutants. Although attempts have been
 made to determine how large an oil shale industry
 could be without exceeding this carrying capacity,
 success has been limited because data are scarce and
 comprehensive predictive efforts  rare. Obviously,
 facility siting is a major factor in making this de-
 termination.

 In evaluating any permit application for a prospective
 oil  shale developer, the logic is and will be as follows:
 First, the proposed  pollution control equipment
 must represent best control technology as defined
 by  EPA. Second, controlled residuals must not violate
 ambient standards.

 The concept of Best Available Control Technology
 (BACT) for air emissions control has been defined
 as the maximum degree of reduction determined case
 by case, taking into account energy, environmental,
 and economic impacts and other  costs. Standards
 of Performance for water effluent  control must reflect
 the greatest degree of effluent reduction achievable
 through application  of the Best Available Demon-
 strated Control Technology, Best Available Technology
 Economically Achievable (BATEA, or simply BAT)
 processes, operating methods,  or other alternative; a
 standard permitting  no discharge of pollutants
 should be included wherever practicable. In establish-
 ing  performance standards EPA shall consider the
cost of achieving the effluent reduction, any non-
water-quality environmental impact, and energy re-
 quirements. Although disposal standard practices have
 not yet been defined for oil shale solid waste
 disposal, it appears that the concept of Best Engineer-
 ing Judgment (BEJ) will  be used. Factors associated
 with BACT and BAT will  presumably help define BEJ.

 Because industrywide performance standards do
 not exist for oil shale, all permit applications are
 evaluated case by case in terms of BACT and BAT.
 After applying BACT and BAT criteria, the permit
 writer assesses the impact of residuals on ambient air
 and water. If applicable Prevention of Significant
 Deterioration (PSD) increments or stream standards
 are predicted to be violated, better control than
 that prescribed by BACT or BAT must be employed.
 More stringent controls may be accomplished by
 reevaluating the economic and energy costs associated
 with BACT or BAT. Because it appears that PSD
 Class I air quality increments may limit the ultimate
 size of the industry, EPA Region VIM has encouraged
 potential oil shale developers to provide controls  better
 than BACT to maximize oil production from the  area.

 In the June 7 and June 14, 1979, issues of the
 Federal Register,  Parts 121-125 of 40 CFR provide
 guidance on strategy and procedures for National
 Pollutant Discharge Elimination System (NPDES)
 permitting. These regulations include critical definitions
 of terms such as "navigable waters." (In essence,
 navigable waters are any flowing waters, wetlands,
 or impoundments.) Moreover, the NPDES permit
for a new source is now required before the source is
constructed. Finally, if an Environmental  Impact
Statement (EIS) is necessary, a final NPDES permit
may not be issued until a final EIS has been issued.
In the past, EPA has encouraged oil shale developers
to apply for NPDES permits even if they  expect no
discharge. The developer is then in a more advantageous
position in case of future  enforcement actions.

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 Environmental Impacts
 The refining of crude shale oil will produce a number
 of potentially adverse environmental effects, primarily
 as a result of atmospheric emission. Data have not
 been developed on the quality and quantity of these
 emissions. Such data may indicate a need for further
 study and for development of new control technology.


 Water Quality

 Water is necessary to the development of an oil shale
 industry. Water will be needed for dust control
 during mining and crushing, for gas cleaning  and air
 pollution control, for cooling, and for moisturizing
 retorted shale. Upgrading crude shale oil, on-site
 power generation, and revegetating disturbed land and
 retorted shale disposal areas will  also consume
 large quantities of raw water. The water needs  per
 unit of net product will necessarily depend on the
 mining, retorting, and upgrading methods used. In
 general, in situ methods are expected to consume less
 water than conventional  mining and retorting.

 Most major developers have indicated that they
 intend to discharge no wastewaters directly to surface
 streams. Surface retorting process waters would be
 reused, and perhaps ultimately applied to retorted
 shale. Effects of extraction and processing activities
 on local hydrology and water quality are therefore
 likely to be indirect or incidental. The water pollution
 implications of mine dewatering, of creating large
 retorted shale disposal piles, and of abandoning
 in-ground retorts have not been determined; these
 actions could create  major environmental impacts.

 Because of the low concentration of compounds
 in discharge waters, no acute or chronic effects on
 aquatic biota in surface waters may result; however,
 compounds of low solubility may be bioaccumulated
 by some aquatic organisms and become toxic to other
 aquatic organisms, birds, and man. Oil shale process
waters contain single-ring and polynuclear aromatics
that contain suspected carcinogens. If process
waters are discharged into the aquatic environment,
sediments may accumulate these compounds  and
later release them slowly. Research is needed on
the degradation of these  compounds and on their
potential for bioaccumulation in aquatic organisms.
 Effects of extraction and processing activities on
 existing water quality in the oil shale region will vary
 with the geography and the season. Several streams
 and shallow aquifers provide water suitable for use in
 irrigation, tn lower oil shale aquifers of the Piceance
 Basin  and in the lower  reaches of Piceance Creek,
 however, water quality  exceeds the dissolved solids,
 fluoride, or  boron criteria for domestic or irrigation
 use. On or near the Utah lease tracts (Ua/Ub), only
 the White River and the Bird's Nest aquifer contain
 significant amounts of water. Water in the White River
 is of suitable quality for  use in irrigation except during
 low flow in  the summer.

 Withdrawing good quality surface water and ground
 water  from  sources in the upper Colorado  Basin for
 consumptive use in oil shale processing may result in
 increased salinity levels in the lower Colorado River.
 The full effect of withdrawal on the Colorado River is not
 known. It is estimated, however, that an oil shale
 industry producing 1 million barrels (160,000 cubic
 meters) of shale oil per day will increase total dissolved
 solids  between 10 and 27 milligrams per liter at
 Hoover Dam.

 Aqueous wastes from oil shale processing can be
 categorized  broadly as originating from direct or
 indirect sources. Wastewaters from direct sources are
 those generated by unit operations or processes,
 including:

   Retorting
   Upgrading
   Some air  emission control and  gas cleaning
   processes
   Cooling and boiler water blowdowns
   Water treatment
   Mine dewatering
   Sanitary disposal

Wastewaters from indirect sources include:

•  Leachate  from retorted shale disposal areas
•  Runoff and erosion resulting from construction and
   site  use
•  Runoff resulting from mining and transport activities

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 Environmental Impacts
 water pollution is not unique to oil shale extraction
 and processing, but may require careful control because
 of the magnitude of site activities. Collection and
 impoundment of runoff will likely be necessary.


 Solid Waste

 The solid wastes resulting from oil shale processing
 present one of the  major environmental problems
 associated with commercial development. Shale-
 derived  solid wastes will include fines from raw shale
 crushing and conveying,  mined raw shale waste, and
 processed (or retorted) shale. Together these wastes
 constitute most of the  process  solids requiring
 disposal. Other solid wastes will depend primarily on
 the pollution controls employed and on the extent
 to which crude shale oil  upgrading  is carried out
 in conjunction with retorting. These wastes may include
 shale oil coke, treatment sludges, and spent catalysts.

 Disposal of surface retorted shale will involve transport
 and surface emplacement of large .quantities of
 solids on a scale only rarely attained to  date in the
 mining industry. The spent shale will contain potentially
 leachable  salts and, in  some cases, a carbonaceous
 residue from retorting.  If shale oil is upgraded
 in conjunction with  retorting, a  disposal pile might
 also contain spent catalysts, sludges, arsenic-laden
 solids, and other plant  wastes.

 In light of the foregoing, it would appear that potential
 hazards  exist relating to:

 • Pile stability
 • Airborne particulates, odors, and organic vapors
 • Leachates, organic and inorganic, caused by
   precipitation and  ground water movement
 • Transfer of possible hazardous organics or trace
   elements to the biosphere
 • Translocations of  toxic substances to vegetation

 Mass movement of disposal piles could adversely
affect water quality.  Sediment and salts could be
added to local surface waters, or to catchment
structures. Changes in pile drainage systems caused by
slumping, and so forth,  may encourage infiltration.
Loading spent oil shale from the retort onto trucks.
Anvil  Points, Colorado
Vegetation may be difficult to maintain on a destabilized
pile surface; as a result, surface wind and water
erosion may increase.

Because no large disposal piles have been constructed
to date, little is known about pile stability in real
situations. Further, most of the work to date has dealt
with carbonaceous shales; decarbonized shales, from
which the organic content has been burned off, are
likely to differ significantly in stability and leaching
properties.

To  control fugitive dusts, and to provide  moisture for
compaction and stabilizing the disposal piles, retorted
shale will be wetted before transport and disposal.
It is not known whether wetting will be sufficient
to minimize particulate emissions at the scale of
operations contemplated at each site. The character-
istics of the spent shale and the micrometeorology
at a given site are among  the pertinent variables.

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 Environmental Impacts
                                                                                                       11
All criteria pollutants can be expected to be emitted
from processing and combustion of shale oils. Arsenic
and heteroatomic components of shale oils may
also pose health problems.


Other Effects

Some radioactivity will be released to the atmosphere
during oil shale  mining and processing.  Radioactive
elements will be contained in dust emissions, fine
particulate emissions, process water discharges, and
leachate from spent shale disposal piles. Some  radon
gas will be released directly.

Noise will be created during oil shale development by
processing plant construction and operation, community
expansion, mining, and water reservoir operation.
and by construction and operation of pipelines,
transmission lines, roads, and railways. Because oil
shale development sites are,  characteristically, a
reasonable distance from population centers, the
impacts of noise are expected to be negligible.

Social and economic impacts of development are
expected to be fairly severe because  known oil shale
reserve sites are remote and sparsely populated.
Population centers in the oil shale area are basically
rural.  The introduction of oil shale development
will significantly increase the numbers of people who
use the towns, creating higher demands on local
municipal services such as  fire and police protection,
schools,  hospitals and health care, and on  local
utilities such as electricity,  water, gas, and  sewage
treatment. The new industry will, however, also bring a
higher financial base to the area by creating more
primary and secondary employment and, therefore,
will increase local tax revenues.

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  Pollution Control Technology
                                                                                                      13
 only a few parts per million compared to quantities
 of thermally generated NOX. Thermally generated NQX
 can best be controlled by demonstrated combustion
 modification techniques. If crude shale oil is used as
 process fuel, control of both S02 and NOX emissions
 could be necessary if process heaters are needed
 to meet the same New Source Performance Standards
 as those for industrial boilers. Full hydrotreating
 would be more cost effective than flue gas treating,
 if on-site refining is included in the shale oil facility.

 Hydrocarbon emissions will result from direct pre-
 heating  of raw shale, and wiM need control. Thermal
 incineration  is  probably the method of choice.

 Hydrocarbons and carbon monoxide resulting from
 incomplete combustion will be emitted by the boilers,
 furnaces, heaters, and diesel equipment associated
 with oil shale development. With  proper maintenance,
 emissions from these sources are not considered large;
 however, high  background levels have been reported
 in some areas, and any additional contributions
 from process operations will be a cause for environ-
 mental concern. Hydrocarbon and carbon monoxide
 emissions can be held to a low level by proper design,
 operation, and  maintenance of external and internal
 combustion equipment.


 Wastewater Treatment

 The  quantity and quality of water available, methods
 of water use, and disposal  criteria will dictate the
 pretreatment, internal conditioning, and wastewater
 treatment necessary at each oil shale processing site.
 Wastewaters from oil shale processing will contain
 dissolved and suspended solids,  oil, trace elements
 and  metals, trace organics, toxics (carcinogens),
 dissolved gases, and sanitary wastes. The major
 wastewater sources are given on page 7.

 Individual waste streams have not been characterized
 adequately to make firm treatment or control technology
judgments regarding which unit processes should be
applied to which waste streams.  Nonetheless, some
 ideal processing schemes have been envisioned and
 discussed. The size of the treatment unit will depend on
 the wastewater volume to be treated at a specific
 site and on the concentrations of pollutants to be
 removed. The basic operating approach will be to
 concentrate the pollutants for ultimate  disposal or
 containment so that clean water can be recycled or
 discharged.

 Wastewaters that contain dissolved solids (more than
 1,000 milligrams per liter) and suspended solids,
 and that are essentially free of oil and trace  organics,
 can be collected and flow-equalized in large holding
 lagoons before treatment. Oily wastewaters (more than
 10 milligrams of oil per liter) from all wastewater
 sources should be collected and processed by American
 Petroleum Institute (API) separators or similar equip-
 ment before receiving further treatment. Wastewaters
 contaminated with trace elements and metals should
 be essentially free of oil and dissolved solids to allow
 them to be treated separately. Trace organic wastewater
 volumes are not expected to be large, but these
 wastewaters will contain highly diverse types of organic
 pollutants. Toxic wastewater volumes are expected
 to be small, but advanced treatment and control will
 be needed for the concentrates collected. Specific
 controls and treatment will  be necessary for waste-
 waters from scrubbers that absorb common oil shale
 process gases—such as hydrogen sulfide, ammonia,
 and carbon dioxide—before the water is reused or
 discharged. Sewage and water treatment plant releases
 should be considered for separate treatment and
 disposal.

The amounts and qualities of water to be expected
from mine dewatering are not known, and they will
depend on the site. In contrast to some earlier
characterizations of surface  retorting operations as
large water consumers, true and modified in situ
developments may produce a surplus of water that will
have to be treated and discharged or reinjected
into aquifers.

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  Pollution Control Technology
                                                                                                        15
 necessary to provide for collection, treatment, and
 reuse of this leachate.

 Process-generated solid wastes—such as spent
 catalysts, lime sludges, coke, and other solids from
 water and wastewater treatment systems—may contain
 toxic substances. Disposal of these wastes by burying
 them  in the spent shale pile would be  likely to in-
 crease the  levels of toxic pollutants in the  spent
 shale  leachate., It may be possible to dispose of some
 process wastes along with the spent shale if it is
 demonstrated that the wastes do not themselves
 produce a leachate or promote production of additional
 pollutants in the spent shale leachate. A preferred
 method of  handling potentially toxic spent catalysts
 would be to return them to the manufacturer for
 regeneration and subsequent reuse.

 It may be possible to dispose of surface-retorted
 spent shale by returning it to the mine, backfilling either
 with dry spent shale or with a spent shale  slurry.
 Because of the  potential for chronic leaching, it is
 recommended that spent shale not be returned to a
 wet mine; leachate problems would be more easily
 controlled on the surface than in a subsurface environ-
 ment.  Returning dry spent shale to a dry mine,
 however, would create support, decrease subsidence
 potential, and reduce surface spent shale storage
 by about 60 percent. In any case, mine disposal of spent
 shale should not be considered viable until it has
 been critically investigated to ensure that leachates will
 not degrade ground  or surface waters.

 Leachate will  contain water-soluble organic and
 inorganic solids. Because of its expected poor quality,
 leachate from surface disposal piles will probably be
 collected behind dams constructed for the purpose
 and  located slightly downstream of the  toe of the
 pile. An impermeable base should underlie the pile,
 and drains should be included to pick up the  leachate
 and discharge it at the collection point. For modified
 in situ oil shale operations, it will probably be necessary
 to minimize water flow through the retorts and
 collect and treat as necessary any leachate. Most  of
the ions present in leachate are also present  in
various flue  gas  desulfurization process  liquids;
therefore, it could be possible to use the leachate on
site for removal of sulfur dioxide from flue gas streams
of surface retorts. The leachate problem could also
 be reduced by leaching the soluble minerals from the
 raw shale feed before retorting and passing the
 retorted shale through a spent shale burner to remove
 residual carbon and organics.

 Modified in situ retorting, conventional underground
 mining, and possibly true in situ retorting may pose
 fracturing and subsidence problems unless subsidence
 control technology is provided. For conventional
 underground  mining, some control technology exists
 that could probably be  modified and applied to the
 specific hydrologic and geologic environment
 of a particular underground oil shale mine. Backfilling
 mine voids with spent shale cou|d provide additional
 support, though ground water pollution could be a
 concern. Special attention would be needed to avoid
 long-term problems from weakening of pillar strength
 by spelling and weathering. For modified and perhaps
 true in situ retorting, the key to controlling subsidence
 or fracturing of surrounding strata will  probably lie in
 learning to control rubblization and in  developing a
 technology that will provide pillars adequately sized
 and appropriately  spaced to support overlying strata.


 Other Controls

 Other process controls  include those necessary to
 reduce storage tank emissions, biological sludges,
 tank bottom sludges, and separator sludges. Floating-
 roof tanks and internal floating covers  reduce both
 diurnal breathing losses and filling losses associated
 with fixed-roof tanks. The technology is well developed,
 having been used  in the petroleum and chemical
 industries. Internal floating covers are preferable in
 sites having high wind,  rainfall, or snowfall because
 they are  protected from the weather.

 Refineries limit or  reduce  sludges and other solid
 wastes primarily through source control. Source control
 techniques involve identifying and monitoring
 sources of oil, water, and other contaminants and then
 implementing  inplant operating procedures to intro-
 duce less water into drains, to recover  oil and water
from solid wastes,  to decrease the amount of con-
taminants in oily drainage, and to reduce the oil content
of API separator solid waste.

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  Sampling, Analysis, and Monitoring
                                                                                                        17
 One problem facing developers is sampling and
 analysis of product and waste streams associated with
 producing oil from oil shale. The methods that have
 historically been used to analyze air and water
 samples have been applied to oil shale effluents, but
 without the straightforward results  expected. Extra-
 ordinary interferences and matrix effects apparently
 make some methods ineffective. Many workers in the
 field are addressing the problem of standardization
 of methods for collecting, shipping, storing, and
 analyzing samples. Interlaboratory studies on many
 different types of environmental samples will be
 needed to validate those methods best suited for
 consistent analysis of oil shale pollutants.

 Effective monitoring through sampling and analysis is
 expected to provide:

 • A baseline evaluation of conditions before devel-
   opment
 • A record of changes from baseline conditions
 • A continuing check of compliance with environ-
   mental regulations and laws
 • Predictive capability for timely notice of developing
   problems
 • A check on the effectiveness of mitigating procedures

 A monitoring program should include sampling of point
 source effluents at and around the facility, non-
 point-source effluents resulting from activity at the
 mining, processing, and disposal sites, and accidental
 discharges. Monitoring should begin with a baseline
 survey; it should continue for the life of the project
 and afterward as long as necessary to ensure compliance
with environmental  regulations and  laws and lease
 stipulations.

 An  air-monitoring program should include on-site gas
 and  paniculate analyses and a network of meteorolog-
 ical and air quality measurement stations remote
from the processing site. It should also include upper
air studies and diffusion modeling to demonstrate
and  ensure compliance with Federal and State
air quality standards.
 Surface water monitoring should incorporate biological
 monitoring as well as physical and chemical analyses.
 Changes in aquatic biota may indicate subtle changes
 in water quality characteristics before they are
 detected by physical-chemical analyses for specific
 pollutants  or by indicator parameters such as dissolved
 oxygen, pH, and hardness. Water monitoring should
 be done both upstream and downstream; wet and
 dry surface streams and springs and observation wells
 should be  monitored to detect ground water changes.

 In a water-monitoring program, non-point-sources
 will probably receive greater attention than point
 sources because of the difficulty of monitoring pollutants
 emanating from shale piles, construction sites,
 access roads, unlined catchments, and evaporation
 ponds. Adding to this problem will be the possible
 discharge of saline ground waters. Moreover, site
 activities may result in reduced water flows and,
 therefore, may affect already limited supplies of water
 for agriculture,  livestock watering, and other beneficial
 uses.

 In addition to spent shale, disposal sites will probably
 contain raw shale  fines, spent catalysts, sludges,
 and process wastewaters. Surface erosion and leaching
 of soluble salts and organic compounds will necessitate
 extensive disposal site monitoring, particularly
 of revegetation trenches, of the alluvium, and at the
 toe of the pile where pollution is most likely. The
 spent shale monitoring program particularly should be
 designed to identify environmental problems in  time
for corrective measures to be taken.

 Monitoring programs and long-term studies should
also  be undertaken for:

  Revegetation
  Terrestrial biology
  Game management
  Aquatic biology
  Soil mapping and analysis
  Toxicology
  Trace elements in the ecosystem
  Ecological interrelationships
  Visibility
  Scenic, archaeologic, paleontologic, and historic
  values

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