EPA-908/4-77-010A
       Emissions
  From Synthetic Fuels
  Production Facilities
      VOLUME I
 EXECUTIVE SUMMARY
 US. Environmental Protection Agenq/
       Region Nlll
      Deni/er, Colorado

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DCN 77-100-092-01
                 EMISSIONS FROM SYNTHETIC FUELS
                      PRODUCTION FACILITIES
                            VOLUME I
                        EXECUTIVE SUMMARY
                        September 1977
                          Prepared for:
                 Environmental Protection Agency
                           Region VIII
                        Denver,  Colorado
                               By:
             J. D. Colley, W. A. Gathman, M. L. Owen
                       Radian Corporation
                          Austin, Texas

                              TS-6a

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                           FOREWORD

          The two volumes comprising this document present a
study of emissions from synthetic fuel production facilities
performed under EPA Contract No. 68-01-3535.  The synthetic fuel
production facilities include oil shale  and coal extraction, oil
shale processing, and coal gasification.

          This report presents  the best  available information.
Most of the data for the TOSCO  II oil  shale process have been
previously published and represent widely accepted estimates
for the process.  Accepted published data for the Union Oil and
Paraho oil shale processes are  not presently available.  The
emissions from these processes  were estimated in this report
based upon similar processes  and developer information.  Accep-
ted data for  the Lurgi  coal gasification process have been pre-
viously published.  As  more information  on these processes is
released, the contents  of this  report  will be updated or subse-
quent reports will be  conducted to present these data.

          This work was  conducted under  the direction of
Mr. Terry L.  Thoem, Project Officer, Environmental Protection
Agency, Region VIII, Denver,  Colorado.   This study is comple-
mented by another Radian study,  "Atmospheric Pollution Potential
From Fossil Fuel Resource Extraction,  On-Site Processing, and
Transportation", EPA-600/2/76-064.  The  fuel resources consid-
ered in that  report are  coal, oil shale, oil, and gas.
                              11

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                           ABSTRACT

          This report was compiled to provide the Environmental
Protection Agency with an assessment of multi-media pollutants
from oil shale processing and coal gasification facilities.

          The report examines oil shale and coal extraction
methods in addition to fuel conversion processes.  Three oil
shale conversion processes are considered:  the TOSCO II, Para-
ho,  and Union Oil processes.  The Lurgi process is considered
for coal gasification.  Process descriptions and module defin-
itions are presented for each operation.  Potential air emis-
sions ,  water effluents,  and solid wastes are then identified
and quantified for each module.  Emissions of trace elements
and organics are determined qualitatively.  An assessment of
resources required to support the production facilities is
also included.

          The overall report is presented in two volumes.
Volume I summarizes the objectives, the approach, and the re-
sults of the study.  Volume II gives detailed descriptions of
the methodology and the results.
                              111

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                       TABLE  OF  CONTENTS

                                                       PAGE
          FOREWORD	   ii

          ABSTRACT 	  iii

          TABLE OF CONTENTS 	   iv

          LIST OF TABLES 	    v

1.0       INTRODUCTION 	    1

2.0       OBJECTIVES 	    2

3.0       APPROACH	    3

4.0       RESULTS 	    6
          4.1  Air Emissions 	    6
          4.2  Water Effluents 	    9
          4.3  Solid Wastes 	    9
          4.4  Trace Elements 	   12
          4.5  Trace Organics 	   14-

5.0       CONCLUSIONS AND RECOMMENDATIONS 	   16
                               iv

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                         LIST OF TABLES

                                                        PAGE
Table 4-1.  Module Air Emission Summaries
Table 4-2.  Synthetic Fuel Facility Air Emission
            Summaries 	   10

Table 4-3.  Solid Waste	   11
                                v

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1.0       INTRODUCTION

          A large portion of the Western United States contains
vast quantities of coal and oil shale.  More than 60% of the
nation's strippable coal reserves and essentially all of the
attractive oil shale reserves are found in the 6 state EPA Re-
gion VIII area.  Technology for the conversion of oil shale
and coal into synthetic fuels is currently being developed and
assessed.

          Production of synthetic fuels can result in dischar-
ges of pollutants to the environment from conversion facilities
This study assesses emissions and effluent characteristics,
energy recovery, ancillary energy requirements and raw material
consumption involved in the production of synthetic fuels from
coal and oil shale.  The study specifically examines oil shale
and coal extraction, oil shale processing, and coal gasifica-
tion.  Three oil shale conversion processes are studied.  They
are the TOSCO II process, the Paraho process, and the Union
Oil process.  The Lurgi gasifier is studied for coal gasifica-
tion assessment.

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2.0       OBJECTIVES

          The major objective of this study is to identify and
quantify potential pollutants from production facilities for
oil shale processing and coal gasification.  The operations
studied include oil shale and coal extraction and sizing, oil
shale retorting (TOSCO II, Paraho, and Union Oil processes),
coal gasification  (Lurgi process), and shale oil upgrading.

          Resources required to support the synthetic fuel pro-
duction facilities are also assessed.  These resources include
manpower, water, and ancillary energy.
                              -2-

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3.0       APPROACH

          To assess the various synthetic fuels processes, all
readily available information sources were investigated.  These
information sources include the following:

              EPA studies and regulations, such as
              energy conversion studies and new
              source performance standards,

              other government studies dealing with
              energy conversion systems,  such as
              Federal Energy Administration, Council
              on Environmental Quality, Energy Re-
              search and Development Administration,
              and Department of the Interior,

              publications and private industry com-
              munications ,

              information retrieval networks,

              site visits to pilot plant facilities,
              and

              Radian inhouse files.

          After all the applicable information had been extrac-
ted from the above information sources it was apparent that suf-
ficient information did not exist to adequately assess all the
areas of interest.  In areas where data were inadequate to quan-
tify the pollutants from the synthetic fuels processes, similar
processes were studied.  For example, very little information is
                              -3-

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available on air emissions from the Union Oil and Paraho oil
shale processes while a detailed assessment of the emissions
from the TOSCO II process is available.  An estimate of the
emissions from the Union Oil and Paraho processes was made by
comparing similarities in the operating parameters of these
processes with those of the TOSCO II process.  Where operating
characteristics are dissimilar, similar operations from other
industries, such as the petroleum refining industry, were
assessed.  Additional information on the emissions from the
Union Oil process was obtained from the developer.

          Insufficient data is available to quantify emissions
of trace elements, such as selenium, mercury, lead, arsenic,
cadmium, beryllium, and antimony, and  trace organics, such as
benz(a)pyrene.  These trace pollutants are of special interest
due to their demonstrated adverse health effects.  A qualitative
determination of trace pollutants from synthetic  fuel processes
was made by comparing trace pollutant  studies for different op-
erations and assessing the similarities and differences between
the operations.

          After the necessary  information was gathered, a series
of standardized modules representing the basic process steps were
defined.  Emissions and effluents, process energy, ancillary en-
ergy and raw material requirements were then quantified for each
module.  Module sizes were selected to represent  "typical" com-
mercial installations currently being  considered  for construction
The oil shale modules are sized to produce 8,000  m3/day (50,000
bbl/day) of primary fuels.  The coal gasification module is sized
for 8 x 106 Nm3/day (250 x 106 scfd) of synthetic natural gas.
The modules each produce about 7 x 1010 kcal/day  (3 x 10"  Btu/
day).  Consequently, emissions from the conversion facilities
can easily be compared on the basis of energy production rates.
                              -4-

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Before making such a comparison, however, the following precau-
tions should be observed:

          1)  Energy production rates for the modules
              are only approximately equal.   Comparisons
              of emissions on the basis of energy produc-
              tion rates are intended to be used only as
              general guidelines.

          2)  The inherent value of products from the
              processes may be different.  The primary
              fuel produced from oil shale is liquid,
              while fuel produced from coal gasification
              is gaseous.  These fuels are not equally
              suitable for all applications.  For exam-
              ple, liquid fuels are presently more ap-
              propriate for use in the transporation
              industry.
                               -5-

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4.0       RESULTS

          This section presents a summary of the emissions,
effluents and solid wastes from the synthetic fuels production
facilities studied.  The pollutant rates from the facilities
are compared and discussed.

4.1       Air Emissions

          The impact of a synthetic fuel process is the sum of
the impacts of the modules that make up that process.  A summary
of the emissions from the analyzed modules is presented in
Table 4-1.  The term "hydrocarbons" in this report refers to
volatile organic emissions.

          Mining

          The oil  shale surface mining module generates more
pollutants than the room-and-pillar oil shale mining and the
coal surface mining modules.  Particulate emissions for oil
shale surface mining are mainly due to the large amount of
overburden that must be removed to expose the resource.  For
coal surface mining, a smaller quantity of overburden needs
to be removed per  energy equivalent of resource recovered.
Nitrogen oxide, hydrocarbon, and carbon monoxide emissions
from oil shale surface mining are significantly larger than
from oil shale room-and-pillar mining.  This is primarily due
to the assumption  that surface mining uses mostly diesel
power while room-and-pillar mining uses significant amounts
of electric power.
                               -6-

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                        TABLE 4-1.  MODULE  AIR EMISSION SUMMARIES
Emissions (kg/day)

1.
2.
3.
4.
5.
6.
7
8.
9.
10.
11.
12.
13.
14.
Module
Oil Shale-Surface Mining
Oil Shale-Room- and-Pillar Mining
Oil Shale-Primary Sizing
Oil Shale-Secondary and Tertiary Sizing
Oil Shale-TOSCO II Retorting
Oil Shale-TOSCO II Upgrading
Oil Shale-Paraho Retorting
Oil Shale-Paraho Upgrading
Oil Shale-Union Oil Retorting
Oil Shale-Union Oil Upgrading
Coal Surface Mining
Coal-Lurgi High-Btu Gasification
Coal-Lurgi Low-Btu Gasification
Coal-Lurgi Medium-Btu Gasification
Particulates
31,010
665
245
486
7,652
i90
988
190
683
190
3,794
790
790
790
S02
2,640
--
--
--
1,587
1,490
1,244
1,490
1,528
460
83
10,970
10,100
9,740
NOX
35,990
2,945
--
--
15,557
1,378
12,407
1,378
6,788
1,378
1,125
17,930
17,930
17,930
HC
4,170
590
--
--
2,948
7,659
265
7,659
325
7,659
130
210
210
210
CO
21,590
5,180
--
--
508
168
425
168
715
168
676
N/A
N/A
N/A
N/A - Not available

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          Oil Shale Retorting

          The TOSCO II retort indirectly heats oil shale by
using heated solids (ceramic balls).  The Paraho retort and
Union Retort B are assumed to indirectly heat oil shale with
heated recycle gas.

          Emissions from TOSCO II retorting and Paraho retor-
ting are very similar except for particulates and hydrocarbons.
TOSCO II emits more particulates because the oil shale is more
finely crushed and because of an additional heat exchange step
for heating the raw oil shale prior to retorting.  This heat
exchange step is probably also the  cause of higher hydrocarbon
emissions from TOSCO II.  The Union Oil emissions are similar
to the Paraho emissions except for NO .  Lower NO  emissions
                                     X           X
could result from Union Oil's plans to combust only fuel gas
for retorting, while the other processes may also use fuel
oil and  C^  liquid.

          Oil Shale Upgrading

          Different retorting methods produce different quali-
ties of  fuel.  Since all the retorting methods are assumed to
use indirect heat, the fuels produced that are available for
process  heat are very similar.  Consequently, the upgrading
emissions for the processes should be very similar.  SOz emis-
sions from  the Union upgrading steps are less than for TOSCO II
and Paraho  since Union has no S02 emissions from the sulfur
recovery unit because the tail gas  is sent to the retorting
unit to  be  combusted.
                               -8-

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          Coal Gasification

          Emissions from Lurgi high-,  medium-,  and low-Btu
gasifiers are very similar for the same energy output.   Differ-
ences in the processes do not have a large impact on emissions.
Gas production rates for the modules,  however,  are different.
The high-Btu gasifier module is sized for a typical commercial
facility.  The medium-, and low-Btu gasifier modules produce
higher gas rates to achieve the same energy output.

          Summary

          Total air emissions from synthetic fuel facilities,
based on the sum of the modules, are presented in Table 4-2.
In general, oil shale facilities have higher emission rates
than coal gasification facilities except for S02 emissions.
Surface mining modules of the oil shale facilities contribute
the greatest amounts of emissions.

4.2       Water Effluents

          All of the synthetic fuels processes examined are
based on zero discharge of water effluents to the surface water.
This design feature has not been established at full scale
facilities.  Also, the potential impact from the leaching of
pollutants into ground water systems,  has not yet been de-
fined .

4.3       Solid Wastes

          The amount of solid waste produced by each module is
presented in Table 4-3 along with a description of the waste.
Surface mining of coal and oil shale produce significant amounts

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               TABLE  4-2.  SYNTHETIC  FUEL FACILITY AIR EMISSION  SUMMARIES

1.
2.
3.
4.
5.
6.
7.
8.
9.
Process
Oil Shale-Surface Mining/TOSCO II
Oil Shale-Surface Mining/Paraho
Oil Shale-Surface Mining/Union Oil
Oil Shale-Room-and-Pillar/TOSCO II
Oil Shale-Room-and-Pillar/Paraho
Oil Shale-Room-and-Pillar/Union Oil
Coal-Surface Mining/Lurgi High-Btu
Coal-Surface Mining/Low-Btu
Coal-Surface Mining/Medium-Btu
Emissions (kg/day)
Particulates S02 NOX HC CO
38,852 5,717 52,925 14,777 22.266
32,188 5,374 49,775 12,094 22,183
31,883 4,628 44,156 12,154 22,473
8,507 3,077 19.B80 11,197 5,856
1,843 2,734 16,730 8,514 5,773
1,538 1,988 11,111 8,574 6,063
4.584 11,053 19,055 340 676*
4,584 10.183 19.055 340 676*
4,584 9,823 19,055 340 676*
"'•"Includes only CO emissions for coal surface mining.

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                                     TABLE 4-3.   SOLID WASTE
                   Module
   Solid Waste
(Metric Tons/Day)
       Composition
  1.  Oil Shale-Surface Mining
     65,000
Overburden
  2.  Oil Shale-Room-and-Pillar Mining
 3.  Oil Shale-Secondary and Tertiary Sizing
 4.  Oil Shale-TOSCO II
     49,380
Processed shale/softener
sludge/spent catalyst
 5.  Oil Shale-Paraho
     49,380
Processed shale/softener
sludge/spent catalyst
 6.  Oil Shale-Union Oil
     48,500
Processed shale/softener
sludge/spent catalyst
 7.  Coal-Surface Mining
 8.  Coal-Lurgi High-Btu Gasifier
     42,700


      5,940
Overburden
Gasifier ash/softener
sludge/spent catalyst
 9.   Coal-Lurgi Low-Btu Gasifier
      5,470
Gasifier ash/softener
sludge/spent catalyst
10.   Coal-Lurgi Medium-Btu Gasifier
      5,280
Gasifier ash/softener
sludge/spent catalyst

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of overburden waste material.  Oil shale processing also gener-
ates large quantities of solid waste.  Disposal of processed
shale may be a significant problem unless careful processed shale
management is undertaken.  The slightly smaller solid waste gen-
eration by the Union Oil process is solely due to the assumption
that the Union Oil process uses a higher grade oil shale.  This
assumption is based on available data for the processes.

4. 4       Trace Elements

          Quantitative information on trace elements from oil
shale processing and coal gasification is currently unavailable.
Consequently, the fate of trace elements is qualitatively dis-
cussed.

          Oil Shale Processing

          Information on the fate of trace elements from pro-
cesses similar to oil shale processing was assessed.  A chemical
equilibrium program was used to predict the behavior of trace
elements in oil shale processing.  The results show that the fol-
lowing trace elements are expected to volatilize in the oil shale
retort:

          antimony          cadmium          mercury
          arsenic           germanium        selenium
          boron             lead             tin

These trace elements will tend to become enriched in the shale
oil.  Thus, while most of the trace elements will be removed in
subsequent shale oil processing, these trace elements will become
air emissions when the shale oil is refined or combusted.
                             -12-

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          The study also indicates that the following trace
elements tend to stay in the processed shale:

          barium           copper             nickel
          beryllium        manganese          uranium
          chromium         molybdenum         zinc
          cobalt

These trace elements may be leached from processed shale and
enter ground water systems if the processed shale is improperly
disposed.

          Coal Gasification

          Available information on the fate of trace elements
from coal gasification and processes with similar operating con-
ditions was assessed.   Studies including the Equilibrium Program
predict that the following trace elements volatilize in the
gasifier:

          antimony        fluorine         phosphorus
          arsenic         lead             selenium
          bromine         mercury          tellurium
          cadmium

These trace elements will tend to become enriched in the synthe-
sis gas.  Subsequent processing of the synthesis gas may remove
some of these elements, but those that remain will become air
emissions as the gas is combusted as fuel.

          The studies also indicate that the following trace
elements tend to remain in the gasifier ash;
                             -13-

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          barium           copper             tin
          beryllium        manganese          uranium
          cadmium          molybdenum         vanadium
          chromium         nickel             zinc
          cobalt

These trace elements may be leached from ash and enter ground
water systems if the gasifier ash is disposed of improperly.

4.5       Trace Organics

          Quantitative information on trace organics such as
benz(a)pyrene from oil shale processing and coal gasification
is currently unavailable.  Therefore, the fate of these trace
organics is qualitatively discussed.

          Oil Shale Processing

          Fugitive air emissions of trace organics such as
polycyclic aromatic hydrocarbons, including benz(a)pyrene, are
a potential problem in oil shale processing.  There is no data,
however, to indicate that these fugitive emissions are any worse
than those incurred at a petroleum refinery.

          A potential problem exists that is unique to processed
oil shale disposal.  Preliminary studies indicate that benz(a)-
pyrene is present in processed shale and can be leached from car-
bonaceous deposits on processed shale by saline water.  This in-
dicates that trace organics such as benz(a)pyrene may be intro-
duced into ground water systems if processed shale is improperly
^•i sposed.
                             -14-

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          Coal Gasification

          Data on trace organics from coal gasification is in-
adequate.  However, examination of similar processes such as
coal combustion and coal coking indicate that trace organics
such as benz(a)pyrene are likely to be present in coal gasifier
tars.  There is also the possibility that trace organics may
enter the cooling water system through heat exchanger equipment
leaks.   They would then be concentrated and emitted from the
cooling system.
                             -15-

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5.0       CONCLUSIONS AND RECOMMENDATIONS

          The following conclusions result from this study:

          1)  For equivalent energy outputs, oil shale
              processing facilities using surface
              mining emit greater quantities of hydro-
              carbons, particulates,  NO .  and CO than
                                       X
              coal gasification facilities.

          2)  Oil shale surface mining is the greatest
              source of particulates, N0x, and CO.
              Particulate and NOX emission rates for
              oil shale facilities using room-and-pillar
              mining are reduced to levels similar  to
              coal gasification facilities.

          3)  Of the oil shale processes studied,  the
              TOSCO II process has the highest emis-
              sion rates of hydrocarbons and particu-
              lates.

          4)  SOz emissions are higher from coal gasifi-
              cation facilities than oil shale processing
              facilities.

          5)  Air emissions and water effluents may
              contain trace elements and organics from
              both oil shale processing and coal gasi-
              fication.

          6)  The quantity of solid wastes produced in
              the process is large, especially for  oil
                               -16-

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              shale processing.   Improper disposal  of
              processed oil shale and coal gasifier ash
              may result in the leaching of trace elem-
              ents and organics into ground water systems.
              Processed oil shale, in particular, may be
              a source of benz(a)pyrene.

          7)   Water effluents from the processes will
              be negligible if they are operated in the
              "zero discharge" mode.  "Zero discharge",
              however, has not yet been demonstrated on a
              commercial scale.

          As  a result of the study, the following recommendations
for future work have been identified:

          1)   Sampling of EPA criteria pollutants from
              all the systems studied is recommended.
              Pilot plant and prototype operations
              should be sampled before a widespread
              industry is developed.

          2)   The data are insufficient on trace element
              and organic emissions and effluents for
              all the processes studied.  Data should be
              gathered from existing facilities.   A soph-
              isticated sampling plan should be developed
              to ascertain the ultimate fate of these
              pollutants in the environment.

          3)   The assumption of "zero discharge" of
              water effluents from the synthetic fuels
              processes is a critical parameter in
                              -17-

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                   this  study.   The credibility of the basis
                   of  this  assumption should be established
                   for the  processes by further modeling of
                   the aqueous  water systems to establish
                   an  optimum water reuse strategy.  The
                   merit of treating effluents to a quality
                   that  may be  discharged should also be in-
                   vestigated.   Facilities will be located
                   in  water-short areas.   Removal of water
                   for plant consumption will deplete surface
                   streams.   The resultant increase of total
                   dissolved solids in the streams may produce
                   an  environmental impact.

               4)   The environmental impact of alternate
                   synthetic fuels processes such as in-situ
                   oil shale recovery and coal gasification
                   should be assessed and compared with more
                   conventional methods.
                                    -18-
U-U.S. Government Printing Office: 1977-781-335/119 Region

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                                 ERRATA
EPA-908/4-77-010A   Emissions from Synthetic Fuels
                    Production Facilities - Volume I

                    Executive Summary


Table 4-1   Module Air Emissions Summaries     p. 7

     1.  Oil Shale Surface Mining            Emissions (Kg/day)

          Parti culate's                  5038
          S02                            640
          NOX                           8700
          HC                            1000
          CO                            5200

Table 4-2   Synthetic Fuel Facility Air Emission Summaries   p-10

                                             Emissions (Kg/day)
                                      Particulates    SO?   NOY    HC    CO
     1.  Oil Shale-Surface Mining/        13,611    3,717  25,635  11,607  5,876
             TOSCO II

     2.  Oil Shale-Surface Mining/         6,461    3,374  22,485   8,924  5,793
             Paraho

     3.  Oil Shale - Surface Mining/       6,156    2,628  16,866   8,984  6,083
             Union Oil


EPA-908/4-77-01 OB    Emissions from Synthetic Fuels
                     Production Facilities - Volume II Report


Table 2.1-2   Summary of Environmental Impact from Surface Mining of Oil Shale-p.9

                                      Parti culates   SO?     NOY     HC     CC^

     Air emissions (Kg/day)              5,038       640   8,700   1,000   5,200

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           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                   REGION VIII

                               I860 LINCOLN STREET

                             DENVER, COLORADO 8O2O3
 Dear  Colleague:

     I am transmitting the enclosed report "Emissions from Synthetic
Fuels Production Facilities" (EPA-908/4-77-010A) for your information and
use.  This report is one of a series of publications resulting from
programs administered and performed by the EPA Office of Energy Activities.
The enclosed report was performed by the contractual agreement with Radian
Corporation.  Special credit is recognized to the EPA Office of Energy,
Minerals, and Industry for providing the funding for this project.  The
subject report is published in two parts—an executive summary and a
fully detailed report.

     The study was initiated in order to provide the EPA with an assess-
ment of the multi-media pollutants emanating from oil shale and coal
gasification facilities and their associated resource extraction
activities.  Three oil shale conversion processes—TOSCO II, Paraho,
and Union—are investigated.  The Lurgi coal gasification process is
studied.  Extraction processes studied include both surface and under-
ground operations.  Process descriptions, resource characteristics,
in addition to the potential air emissions, (including fugitive losses)
water effluents and solid wastes generated are presented in the report.
Emissions of trace inorganic elements and organic compounds are presented.
Net energy efficiency has also been calculated and discussed.  An attempt
to relate ambient air or water quality concentrations has not been
performed.

     Availability, reliability, and accuracy of data pertaining to this
study was difficult to assess, but in general it was felt that the
information included in this report was the most current as of early
1977.   Since that time other oil shale processes including the Superior

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1977.  Since that time other oil shale processes including the Superior
multi-mineral recovery and the modified in-situ process have been
promoted for potential commercialization.  These processes should be
the subject of a similar analysis such as is performed in the enclosed
report.
     Conclusions which may be drawn from this study include.
     1.  For equivalent energy outputs, oil shale processing facilities
using surface mining emit greater quantities of hydrocarbons,
particulates, NOX, and CO than coal gasification facilities.

     2.  Oil shale surface mining is the greatest source of particulates.
NOX, and CO.  Particulate and NOX emission rates for oil shale facilities
using room-and-pillar mining are reduced to levels similar to coal
gasification facilities.

     3.  Of the oil shale processes studies, the TOSCO II process has the
highest emission rates of hydrocarbons and particulates.

     4.  S02 emissions are higher from coal gasification facilities
than oil shale processing facilities.

     5.  The environmental impact of alternate synthetic fuels processes
such as in-situ oil shale recovery and coal gasification should be
assessed and compared with more conventional methods.

     If you should have any questions regarding this report please
contact me or members of my staff.  For additional copies of this report
or for information regarding other publications resulting from the
Office of Energy Activities Energy/Environment Program please contact
Ms. Betty Thalhofer (303-837-5914) of my staff.

                                 Sincerely,
                                 Cooper H. Wayman    (I
                                 Director            "
                                 Office of Energy Activities
Enclosure

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