NORTHERN GREAT PLAINS
 RESOURCES PROGRAM
 ACCOMPLISHMENT PLAN
       REGION VIII
   ENVIRONMENTAL PROTECTOR AGENCY

    ROCKY MOUNTAIN - PRA'PiE

         JUNE
                      V 4

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                                                     9O8R74OO1
                                                       APPENDIX A  TO REGION VIII

                                                       FY-75 COMPREHENSIVE ENERGY

                                                           ACCOMPLISHMENT FLAN
                          ACCOMPLISHMENT PLAN
                                  II

                              REGION VIII

                  U. S.  Environmental Protection Agency



                               Covering:

                        EPA Participation in  the
                 Northern Great Plains Resources Program
         (Montana, North  Dakota, South Dakota, Kyoming, Nebraska)
                               May 1974
REGIONAL ADMINISTRATOR
JAYID D.  EMERY
ASSISTANT FOR PLANNING AND
EVALUATION
                   ENVIRONMENTAL PROTECTION AGENCY
                            REGION VIII
                   1860 Lincoln Street, Suite 900
                      Denver,  Colorado  80203

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"The coal appears to be of better quality; I expose
a specimen of It to fire & found 1t burnt tolerably
we119 1t afforded but little flame or smoke, but
produced a hot & lasting fire..."
                           April 22, 1805 entry by
                          Capt. Meriwether Lewis 1n
                       the "Journals of Lewis and Clark"
 'Strip mining In Montana could produce a 30 percent
 Increase in the State's population1 .... "If this
 estimate proves Itself to be accurate, quality environment
 will assuredly decline and along with it the frontier
 attitude.  It would be replaced with a possible and a
 temporary increase in living standards, an increase in
 crime, urban sprawl, pollution, and other urban problems."
                            Michael Olsen and Daniel Henning
                                 Eastern Montana College
                         as quoted in The New York Times 2 Apr 73
"Energy conservation can make a substantial contribution
in ameliorating or postponing the potential energy shortages
faced by the United States over the next several decades.
To realize this contribution, however, will require not only
the political will to Implement the necessary conservation
measures but also the Imagination and intellectual resources
of the scientific community to develop new technologies to
increase the efficiency of energy uses."
                            G.A. Lincoln,  "Energy  Conservation"
                            SCIENCE, V180,  155-162,  13  Apr 73

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                             ABSTRACT
     This Accomplishment Plan presents a plan for a second phase of
the allocation of EPA resources to carry out Its responsibilities for
evaluating coal mining and power generation in the Northern Great Plains
area of Montana, the Dakotas, and Wyoming.  Emphasis of the Plan is
on Regionally-coordinated (Region VIII) efforts, though projections of
related Headquarters and NERC are included.  This Plan also summarizes
EPA's activities in the Program through 1973 and utilizes some information
developed by the Program wherever pertinent.

     The Northern Great Plains Resources Program is cosponsored by EPA,
the Departments of Agriculture and Interior, and the States of Montana,
North Dakota, Wyoming, South Dakota, and Nebraska.  The Program is
designed to procure, develop, and coordinate the necessary data to assist
all levels of government in insuring proper development of resources of
the Northern Great Plains.  Emphasis over the past year has been on the
coal resource and primarily on the strippable coal resource.

     Emphasis on utilizing western coals has increased over the past
year.  The thin overburden and extremely thick coal seams allow projections
of low cost recovery of the coal.  However, projections of concurrent
population increases, increased demands on scarce water resources,
degradation of existing clear air and difficulties in rehabilitation
of disturbed lands lead to concerns over the environmental impacts of
coal development on the rural agrarian societies of the Northern Great
Plains.

     EPA has numerous responsibilities in fields related or directly
connected to coal development.  Among these areas are the determination of
the effects of coal development on the environment and assistance to the
States in the achievement of their environmental goals.  The Northern
Great Plains Resources Program has been an extremely viable mechanism
to assist EPA  in meeting its objectives.  While EPA has many ongoing
activities related to questions posed by the Northern Great Plains
Resources Program that will continue as routine activities of its offices
regardless of the future of the Program, it is hoped that the Program
mechanism will continue.

     The Regional office of EPA has also considered the need to perform
a somewhat more active role in evaluating  the  impacts of and alternatives
to coal development  in the West.  These considerations are part of the
development of an energy-wide and even resource-wide action program in
the Region VIII office of EPA.  This more  active role would possibly
involve greater leadership in programs such as the Northern Great Plains
Resources Program and additional involvement  in legislative activities.
The objective would  be to assure that environmental degredation would
be prevented.  It may be increasingly Important to assist the regional.
state and local planning entities with planning, construction, and
regulatory functions.
                                 11

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                         TABLE OF CONTENTS
Section                                                        Page

       Abstract	     	    ii
       Table of Contents       	    11i
       Preface	     	    x

I.     Introduction	           „ . .     1

       National and Regional Energy Considerations   ....     2
       Coal  ....     	       3
       011 Shale .   .     .    . .       	     6
       Uranium	          12
       Crude Oil	    12
       Natural Gas	    18
       Geothermal Resources  	    21
       Hydroelectric Energy	. . .    21
       Coal In the  Northern Great Plains	'. .      21

       Need for Regional Participation In the NGPRP    .        27

II.    Northern Great Plains Resources Program:   Its
        Evolution and Present Framework  	        30

       Framework of NGPRP.    .	     .    30
       Objectives of NGPRP  	    30
       Program Sections  .  . ..   ,        . .     ...          32
       Status of Work Groups   . ,      	          35

III.   Objectives of EPA Involvement in the Northern Great
        Plains Resources Program 	    35

       Objectives	    35
       Approach or  Secondary Objectives  ....      .          33
       Region-wide  Considerations (Region VIII)   	    39

IV.    Detailed Work Accomplishment Plans  	    41

       Regional Office Coordination and Management 	    4]

       Specific Work Group  Assignments     	    46

        Regional Geology Work Group (Work Group  A) ....      47
        Mineral Resources Work Group (Work Group B)  ....    52
        Water Work  Group (Work Group C)  	    59
        Atmospheric Aspects Work Group (Work
         Group D)	    79
                                 iii

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Section                                                        Page

        Surface Resources Work Group (Work Group E) 	   110
        Soc1o-Econom1c and Cultural Work Group
         (Work Group F)	118
        National Energy Considerations (Work Group G) . .  .  .   122

V.     Summary	128

APPENDICES	132
                                   1v

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                         TABLE OF CONTENTS
                            (Continued)
List of Figures                                                Page
1.   Bituminous, Subbltunrfnous Coal, and Lignite Deposits
      of the Conterminous United States and Comparison,
      by Province, of Strippable Reserves	    5
2.   Genera] Location of Coal Resources 1n Region VIII
      States  	    8
3.   Principal Reported 011-Shale Deposits of the United
      States  	    9
4.   Genera] Location of Oil Shale Resources in
      Region VIII States  	   10
5.   Counties with Uranium Deposits 1n Sedimentary Host
      Rocks; Counties with Uranium Deposits In Other Than
      Sedimentary Host Rocks  	   13
6.   General Location of Uranium Resources 1n Region VIII
      States  	   H
7.   Relationship of Total $8.00 Resources to Production,
      Western United States 	   17
8.   General Location of 011 and Gas Resources 1n
      Region VIII States  	   20
9.   General Location of Geothermal Energy Potential 1n
      Region VIII States  	   22
10.  Existing and Proposed Energy Generation Facilities
      in the NGPRP Study Area 	   24
11.  Population Density 1960 — People/Square Nile  	   26
12.  NGPRP Organization, 1974	   31
13.  Schematic Representation of Interagency NGPR Program
      Schedule as Initially Proposed  	   34
14.  Task Matrix	   36
     Explanation for Figure 14  	   37

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List of Figures                                                Page
15.  Official NGPRP Stuty Area Map 	  48
16.  Water Quality Stations in the Northern Great Plains
      Region of Montana  	  62
17.  Water Quality Stations 1n the Northern Great Plains
      Region of North Dakota 	  63
18.  Water Quality Stations in the Northern Great Plains
      Region of South Dakota 	  64
19.  Water Quality Stations in the Northern Great Plains
      Region of Wyoming  	  65
20.  Combined NGPRP and Existing Air Quality and
      Meteorological Network ....   	  80
21.  Existing Air Quality and Meteorological Network       . .  81
22.  Program Management Team — Work Groups	140
23.  Northern Great Plains Resources Program (NGPRP) 	 141
                                  vl

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                         TABLE OF CONTENTS
                            (Continued)

List of Tables                                                 Page
1.   Annual Coal Production. 1972 Estimates	   4
2.   Strippable Coal	   7
3.   Result of Oil Shale Lease Sales as of May 15, 1974  .   .  11
4.   Distribution of Uranium Ore Reserves by State 	  15
5.   Uranium Ore Shipments to Mills — 1948 through 1971 ...  15
5b.  U. S. Uranium Ore Processing Mills  	  16
6.   U. S. Production of Crude Oil and Condensate,
      1972 (Preliminary)	19
7.   U. S. Marketed Production of Natural Gas,
      1972 (Preliminary)	19
RD.  Regional Coordination 	  44
A.   Regional Geology;  Subject Area "A"  	      .      50
B.   Mineral Resources; Subject Area "B" 	   	  54
8.   Trace Elements Potentially Around Power Plants      ...  66
9.   Outline of the Water Quality Subgroup Interim Report  .  .  67
C.   Water; Subject Area "C"	72
10.  NGPRP Atmospheric  Aspects Monitoring Network  	  82
11.  Trace Elements	83
12.  Outline — Atmospheric Aspects Work Group  Interim
      Report	85
13.  NGP Power Plant Summary ...   	88
D.   Atmospheric Aspects; Subject Area "D" 	  96
E.   Surface Resources; Subject Area "E" 	 113
                                 vii

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List of Tables                                                 Page
F.   Socio-Economic and Cultural Aspects; Subject
      Area "F"	120
14.  National Energy Considerations ~ Northern Great
      Plains Coal Supply Predictions 	 123
15.  National Energy Considerations — High Scenario
      Assumptions	124
G.   National Energy Considerations; Subject Area "G"  .... 127
16.  Estimated FY 73 and FY 74 Manpower and Funding  ...    .130
17.  Projected FY 75 and FY 76 Manpower and Funding  ...    .131
H.   Northern  Great Plains Resources Program -  EPA,
       Siting Conference  	    	 172
                                   viii

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                         TABLE OF CONTENTS
                            (Continued)
Appendices                                                     Page
1.   Outline of Plan — Northern Great Plains Resources
      Program	133
2.   Region VIII Recommendations on Public Involvement
      and Participation 1n the NGPRP  	  144
3.   EPA's Statutory Responsibilities Vis-a-Vis the
      Northern Great Plains Resources Program ...     ...  146
4.   Northern Great Plains Resources Program "Longer
      Term Study and Data Needs"  	  153
5.   Siting Conference  	  170
6.   Montana Strip Mining and Reclamation Act .         ...  176
                                 ix

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                              PREFACE


     The Northern Great Plains Resources Program has now proceeded in
an increasingly detailed work effort for almost one year.  What started
out as a program of moderate duration (three years) has vacillated in
scheduled duration from one to five years.  Its title is interchangeably
referred to as Program and Study,it's confused with the preceding North
Central Power Study, and efforts vary from eolation of existing data to
data manipulation and supplementation with new data.  Nonetheless, certain
individuals and a limited number of groups have worked fast and vigorously
to acquire and present pertinent data that may be considered as the
"Regional Profile" or as background data with respect to evaluation of
possible increased mining of coal.  Individuals have analyzed the data
in order to provide the public, regulatory agencies, and planning agencies
with tested methodologies useful, if not necessary, for preliminary
evaluation of the effects of increased coal development.  The Program
has continued to increase its capability to coordinate efforts that
have application to the issues and questions raised by reidentification
of the Northern Great Plains as a prime source of coal.  In a word,
the Program is good.

     The primary objective of the Northern Great Plains Resources Program
is stated in the Program outline (Appendix  I ) as follows:

          "...to provide an analytical and informational framework
          for policy and planning decisions at all levels of
          government."

The Environmental Protection Agency was instrumental in encouraging the
implementation of such a program.  The Region VIII office considered that
this comprehensive approach was an excellent method that aligned itself
well with the prevention effort, of pollution and environmental degradation
so important to the Regional activities.  EPA has supported an extensive
effort by EPA personnel in the first year of the Northern Great Plains
Resources Program.

     The Northern Great Plains Resources Program is designed to prepare
an  "Interim Report" in mid-1974.  The studious design of the title of
this report suggests thorough recognition that this 1974 report will not
be the last report of such a nature for the Northern Great Plains.
However, this recognition has been slow in coming from some, and seems
worthy of further consideration.

     It 'is recognized that decisions are being made, now, regarding
coal mining and power plant or synthetic natural gas (SNG) plants and
that many such decisions cannot wait for the preparation of some sort
of "final" report in three or five years.  Thus, the Northern Great
Plains Resources Program h^s interim goals of disseminating its information

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to the decision-makers in a timely fashion.   Unquestionably,  such
"interim reports" are necessary.   However, when a Program examines
an area of roughly 37,000,000 hectares, which includes 64 counties
and portions of four, and in some cases of interregional  impacts,at least
five states, and when this geographical area has experienced  a
much different type of activity and development in the past than is
now being suggested for the future, it seems reasonable to expect
that certain basic data have not been collected and that  certain
analytical tools have not been developed.   Such is obviously  the case
in the Northern Great Plains.  An agricultural  economy is being
challenged by an industrial, more specifically, a coal  economy.   Thus,
there are deficiencies in the analyses of  probable impacts in many
cases.  Then, depending upon the desired accuracy of the  analyses of
environmental impacts, varying amounts of  additional data may be
required.  In the case of the Northern Great Plains Resources Program,
items like air quality, water quality, revegetation potential,  social
impact, mining technology, and so on must  be investigated in  greater
depth.  Otherwise the Program will  not have addressed or  achieved
one of its objectives of filling in substantive gaps in the data.
Thus, additional reports are foreseen after the "Interim  Report".
Whether these reports are prepared as a part of a Northern Great
Plains Resources Program or some other coordinating activity  is still
under debate, though it is the hope of EPA that the Program will continue
essentially as it is now organized.

     The opposite end of the scale, that of developing an indeterminate
study, also deserves treatment.  The Northern Great Plains Resources
Program should not be designed to continue indefinitely.   At  various
points in time, activities will be complete, transferred  to responsible
parties, or curtailed.  While a need for Regional coordination  will
remain, it is likely that the present Northern Great Plains Resources
Program coordination structure would be replaced by a combination
of existing or future organizations, agencies and people.  Our  considera-
tions leads us to feel that the Program, as it is now structured,
should be continued for an additional two  years (until July of  1976)
with gradual phase-out and transfer of responsibility beginning in
July of 1975.  Measurement and reporting functions would  continue through-
out.
                                 XI

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I.                          INTRODUCTION


     In April of 1973, it was apparent that energy shortages had
contributed to renewed Interest 1n the substantial coal  resources as yet
untouched in the United States.  Increased awareness of  the health
effects of sulfur oxide focused this Interest on relatively low sulfur
(less than one percent sulfur) content in the Western United States.1
Since the geographical area of these low sulfur coal resources is
now an area of predominantly agrarian, rural societies,  significant
impositions of coal mining and energy-generation could spell disaster
to the societies and cultures, not to mention the natural qualities of the
topography and climate.

     A program entitled the "Northern Great Plains Resources Program"
was initiated in 1973 to provide baseline data and data-analysis
tools, to quantify possible impacts resulting from possible development
of coal resources in the four-state area of Wyoming, Montana, North
Dakota and South Dakota.  The Environmental Protection Agency has been
a primary participant in this program over the past year.  Much of the
agency's participation has followed the outline provided in the "Northern
Great Plains Resource Program Accomplishment Plan",2 prepared by the
Region VIII office of EPA in April of 1973.

     The original Accomplishment Plan served primarily to support
detailed requirements for an increased effort on the part of EPA, especially
in the Region VIII office, to participate in the program during Fiscal
Years 1973 and 1974.  All of EPA responded enthusiastically to this
Plan.  The original Plan also provided a long-range estimate of the work
effort needed to support the necessary effort in Fiscal  Years 1975 and
1976.  We have rewritten the Plan to better describe these future needs.
This "Edition II" of the Plan also attempts to present summaries of past
accomplishments of EPA involvement in the program, as well as ongoing
activities.

     While in early 1973 there were signs of energy fuels shortages —
possibly dilemmas as to what mix of fuels or what energy demand-supply
projections were realistic, or desirable — the winter of 1973-4 has
brought oil and oil product shortages over  the United States and the world.
The  Import restrictions of crude oil brought on by the world situation
have renewed an awareness of the limited fossil fuel reserves of the
United States.  These factors  are treated more thoroughly in the following
section of this Plan.  But renewed emphasis on development  of energy
fuels within the United States as a result  of the crude  oil  Import
 1.   In fact, western  coals contain  sulfur  in concentrations ranging  from
     0.4 percent to  over 2.4  percent.


 2.    Accomplishment Plan. Region VIII.  Northern Great Plains  Resource
     Program ,  July, 1973, 1860 Lincoln  Street,  Denver, Colorado  80203

                                  1

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restrictions has also reemphasized the need for a program like the
Northern Great Plains Resources Program to provide assistance and
impetus to comprehensive evaluations of energy fuels development
so that the United States will not have to live with "irreparable"
environmental degradation as it has as a result of coal mining 10
or more years ago.

     In view of the fact that the initial Accomplishment Plan
was of interest to numerous individuals and groups and is now out of
print, much of the information contained therein is included here
again.
National and Regional Energy Considerations

     Recent national fuel  (oil and oil products, natural gas) shortages
in the United States have  focused the entire nation's attention on
the supply and demand problems associated with what is popularly
called an energy "crisis".  It appears that the energy "crisis" is
more appropriately termed  an energy "dilemma" since a multitude of
choices exist  when projecting both a future demand for energy and
the means of supplying the demand.  The dilemma involves national
and international considerations; social and technological considera-
tions; considerations that may be basic to modifying previous economic
theory in terms of rate of growth, profits, returns or investments, etc.

     There is increasing interest in developing a higher degree of
independence from foreign  energy supplies, primarily oil and oil by-
products.  This and environmental concerns over pollutants from conven-
tional conversion of energy fuels are leading to a more complete
inventory, as well as identification of the need for ever more accurate
inventories, of national sources of energy.  Much of the reserves
of conventional fuel supplies (coal, uranium, gas, oil, hydroelectric)
are found in the western United States.3  It would also appear that
the West has the potential of supplying energy from more unique sources,
such as geothermal resources, solar, and perhaps wind energy.  While
other parts of the  nation  contain significant quantities of fossil
fuels and the potential to supply energy from non-conventional sources
such as the oceans, the West embodies a somewhat unique contradiction --
it has been renowned for both its mineral wealth and its visual splendor,
the latter a splendor that has been and might again be destroyed by
careless extraction or development of mineral resources.
3.   Energy Reserves. Region VIII , 1973.   A pictorial briefing document
    prepared by the NGPRP Staff of EPA Region VIII.   Much of the Informa-
    tion is included In following sections of this Accomplishment Plan.

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     The President's 1973 energy message^ encouraged the use of domestic
coal to meet the needs for energy.  Since low sulfur coal laying in
close proximity to the ground surface Is economically attractive to
energy producers* much of the near-surface coal resources in the West
are Important.  Region VIII (of EPA) States of Montana, Colorado,
Wyoming, Utah, North and South Dakota have vast reserves of low sulfur
coal, much of which lays near the surface In relatively thick seams
and in generally level terrain.  When combined with the Four-Corners
area of New Mexico and Arizona, the Region includes an estimated
resource of 2 trillion metric tons of coal.

     The ensuing seven subsections present quantitative estimates of
the "conventional" energy reserves found within the six states of
EPA's Region VIII.  It should be recognized that the figures presented
here are changing as new reserves are proved, or as more resources
are projected.  That is characteristic of things geologic.  Each of the
energy fuels discussed, with the exception of hydroelectric power, lies
beneath the land surface, out of sight, and until mined can only be
evaluated by examination of drill hole or outcrop data.  As a result
there can only be estimates of the amount of fuel in place until that
fuel is actually removed or extracted.  While we have tried to present
the most recent data available to us , the estimates of reserves are
always changing as more exploration occurs.  Regardless, however,
of the fact that exploration brings in more reserves of fuel, the
total conventional energy resource available to us is finite — it is
not being renewed.  Hydrocarbon fuels must be deposited and buried over
geologic ages.  They are not being formed at rates commensurate with
present use.
Coal

     Table 1 gives the estimated annual coal production rates for
certain states in 1972.  States in Region VIII of EPA are underlined.
Annual production In the United States has been on the order of 600
million metric tons.  Production from the Region VIII has recently
been on the order of 50 million metric tons per year or 8.3 percent of
the national rate.

     Estimated resources of coal in the United States are 3.3 trillion
tons or enough for about 5,500 years of use at the present rate of
production (600 million tons per year).  About 60 percent or about
2 trillion tons of these resources are located in the Region VIII states
and the Four-Corners Area in New Mexico.  Figure 1 gives some idea
of the distribution and rank (heating value) of these coals across
the United States and indicates that much of the western coals are
of lower heating  (BTU) value.  Thus, it takes proportionately more
western coal to produce the same heat as typical "eastern" bituminous
and anthracite coals.
      New York Times. 19 April 1973, "President Offers Policy to Avert
      An Energy Crisis"  This emphasis on use of western coals has been
      reiterated by private and Federal sectors with increasing frequency
      in 1974.

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        TABLE 1. - Production of bituminous coal and lignite in the United States,
                    by State and underground, strip, and auger mining «/
	 _ 	 (Thousand short tana)
State
AlaKAfliA — — — ~_. __•_. _-- 	 , . — — — •--•______
Alaska — ~ -.-p-.. -.-_...-_.« — — _..
Aw 4 wnnfi •••••••••• 	 !_••_• j__i_i 	


niinois 	
Indiana —«—---—-.—-•. •-



Kentucky: —
f^jiA^om -, — • _-•-• -•-!-• 	 _»_u 	
Uao^Mrn -_______..— .—_______..____

Tnt-_1 ___________ .,
LuTai «——————___—" _•-_________«•_—
Mni-irlflnil ________ . .____ 	 	 	
M-faannr-f — _______ _.___.___.___

Montana:
1 In-fit- A ________________________

Total 	 -i.- 	 ---.... .- . i- 	 .i----_
New Mexico 	
North Dakota (lignite) 	
rtifn ---______________._-_—_ ____
v*mo ————"•" i___>_______—i ____________

i ennsyivanio ~ _____ — -__ --——•_«._____
lennesocc _______—_—••————•• ~ —_____••
Texas \ngnx_e/ __-_.—_____.-••—__——
Ift-nh _____„________. , __j_.« _________
i>U4n ————— -^ ™_j^_ _________
nira-tn-tm _________________ . >.______
Virginia —"•——•————•• ________
Hasningcon ———•————————••———•"••- — "— —
Uoar Vlrolnlji _____________________
W(f9L VUgJLIHa ————"•——"-• _— __ _— _
TOC8J> Qf ~~~""^"' 	 - «—____-•___—
Underground
7,588
8
3,070
31,721
1,446
352
37,946
18,547
56,494
141
17
17
1,014
16,269
88
49,133
5,866
4,770
23,993
29
101,662
442
304,103
Strip
13,177
668
2,954
420
2,452
33,802
24,503
499
1.227
22,132
33.645
55,776
1.435
4.551
7.882
322
8,20;
7,235
6,632
34,077
2,536
26,264
5,113
4.045
32
7,935
2,606
19,101
10.487
275, 730
Auger
49
8,779
137
8,917
65
	
621
542
281
2,100
2,979
15,554
Total
20,814
668
2,954
428
5,522
65,523
25,949
851
1.227
68,858
52.330
121,187
1,640
4.551
7,R99
322
8,221
8.248
6.632
50,967
2,b2A
75,939
11,260
4,045
4,802
34,028
2,634
123,743
10.928
595,386
a/ Mineral  Industry Surveys; "Coal-Bituminous and Lignite In 1972"
   November 15, 1973


b/ Data may not add to totals shown  because of Independent rounding,
1 short ton
                    0.9 metric tons

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                                                                                             \J
                 FIGURE I     BITUMINOUS, SUBBITUMINOUS COAL,  AND LIGNITE  DEPOSITS OF THE CONTERMINOUS

                             UNITED  STATES AND COMPARISON, BY PROVINCE, OF  STRIPPABLE RESERVES

                                                                               after BuMines 1C  8531,  197

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     Significantly higher production rates from the West are probable
as the demand for low sulfur fuels and substitute fuels for crude
oil continues to grow.  Initial pressure 1s placed upon those reserves
which lay within about 70 meters (200 ft.) of the ground surface
and which are therefore amenable to strip mining.  So-called strippable
resources in the United States are presented 1n Table 2.  Of the total
of 142 billion tons of strippable coal in the United States (4.3
percent of the total estimated resources) about 53 percent or 76 billion
tons are to be found in the Region VIII (plus Four-Corners) states.

     Figure 2 shows the general location of coal reserves in the six-
state region of EPA's Region VIII.


Oil Shale

     While some deposits of oil-rich sediments occur throughout the
United States (see Figure 3), the organic-rich sedimentary rocks of
the Green River Formation of Colorado, Utah, and Wyoming in Region
VIII (Figure 4) offer the greatest promise for oil shale production
in the immediate future.  The Green River Formation deposits Include
reserves of high grade shale (greater than 25 gallons of oil per ton
of shale; greater than 10 foot thick seam) representing 600 billion
barrels5 of oil.  An additional 1,200 billion5 barrels are estimated
to reside In sequences of lower grade shale.  By comparison, the
nation consumed 5.5 billion bbl of crude oil in 1970.  In 1973 the
Department of Interior published a final EIS for the Proposed Proto-
type Oil Shale Leasing Program in the States of Colorado, Utah, and
Wyoming.

     The Oil Shale Leasing Program has proposed six sites of Federal
oil shale for leasing to industry.  The sites are to be used to test
methods of extracting oil from the deposits.  Each tract consists
of about 5,120 acres and there are two tracts proposed for each state.
Table 3 shows the lease bids that have been accepted to date (Nay 1974).

The Region VIII office of EPA considers the oil shale development to
rival coal in its development potential and its potential for signifi-
cant impact on the environment.  The Regional office Is therefore
preparing an Accomplishment Plan for Its activities in oil shale deve-
lopment.  A plan similar to the initial NGPRP Plan addressing coal
development in the Northern Great Plains and detailing the necessary
efforts and support required to prevent undue deterioration of the
environment is envisioned.
5.  U. S. Department of Interior Draft Environmental Statement for the
    Proposed Prototype Oil Shale Leasing Program, Volume 1. USDI, 1973,
    6 Volumes, S.O.D. #2400-00776,777,784-7.

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                             Table 2
                         Strippable Coal
                   (1n millions of short  tons)
          States!/                     Estimated Resources^/
          Montana (NGPRP)                    31,857
          North Dakota (NGPRP)               16,003
          South Dakota (NGPRP)                  428
          Wyoming (NGPRP)                    19,850
          Four Corners (SWES)                 7,862
          National (NGPRP)                  142,000

a.  Data sources:
          NGPRP  Northern Great Plains Resources Program
          SUES   Southwest Energy Study
b.  Overburden thickness varies with thickness of coal; maximum
    generally 200 feet for the thickest beds.

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                                         SOUTH  DATSQTA
                        FIGURE 2
General Location of Coal Resources In Region VIII States
                             8

-------
         T ---------- ----- ,
                                   i
                                   i
                            —
-—-r~\v
 7—
     V    1--^              '    '
     \.J       t—I^-T]
       ,/Sti
   .-/.«• .
 -f t**'n
>•"
          9  aooMiiis
                                                                                EXPLANATION
  Tertiary deposits
Green River Formation
 in Colorado, Utah, and
 Wyoming; Monterey
 Formation, California;
 middle Tertiary deposits
 in Montana. Black areas
 are known high-grade de-
 posits
   Mesozoic deposits
 Marine shale in Alaska
                                                                               Permian deposits
                                                                             Phosphoria Formation,
                                                                                   Montana
Devonian and Mississipplan
 deposits (resource esti-
 mates Included for
 hachured areas only
 In Geological Survey
 Circular 523).  Boundary
 dashed where concealed or
 where location is uncertain.
                              FIGURE 3.     Principal Reported Oil-Shale
                                           Deposits  of  tne United States.

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                          SOUTH  DAKOTA
            FIGURE  4

 General  Location of 011 Shale
    (Kerogen-R1ch Marl stone)
Resources 1n Region VIII States
               10

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                                   TABLE 3
Tract

Colorado C-a


Colorado C-b
Utah U-a


Utah U-b
Wyoming W-a

Wyoming W-b
  Date of Sale

January 8, 1974»


February 12, 1974
March 17, 1974


April 9, 1974
May 13, 1974

June 11, 1974
  Winning Bid

 $210,305,600


 $117,778,000
 $75,596,800


 $45,107,200
    Company

Standard of Indiana
Gulf Oil Corporation

Atlantic Richfield
Ashland Oil Company
Shell Oil Company
The Oil Shale Corp.

Sun Oil Company
Phillips Petroleum

White River Shale Oil
(a consortion of
Standard Oil of Ohio
Sun Oil Company
Phillips Petroleum)
No bids received
                Result of Oil  Shale  Lease Sales as of May 15, 1974

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Uranium

     Uranium-bearing deposits are located throughout the United
States, however, economic concentrations of uranium are few.  Figure
5 portrays the general area of the United States 1n which commercially-
produceable reserves of uranium may be expected.  Figure 6 summarizes
these deposits throughout Region VIII.  Table 4 lists the uranium ore
reserves by states as of January, 1972.  These reserves are (most
recently) predicated on a price of $8 per pound of U30o.  About
273,200 metric short tons  of U308 reserves were then estimated.
Ninety percent of these ore reserves were located 1n the Region VIII-
Four Corners Area of the West6 (Includes states of Regions VI and IX
of EPA).  Table 5 Indicates that of the  96,000.000 short
tons  of uranium ore shipped in the period 1948 through 1971, over
46,000,000tons or 48 percent of the ore shipments originated from
Region VIII States (Utah, Wyoming, Colorado).7  In excess of 95
percent of the total ore shipments originated from Region VIII and
Four Corners (New Mexico, Arizona) states.

     Of 70 U.S. uranium ore processing mills either operating, or
under construction in 1972, 13 are located 1n Region VIII and have
45 percent of the total nominal ore processing capacity of the United
States (see Table5b').  A total of 16 mills are located 1n the Four-
Corners-Region VIII area and contain 87 percent of the total processing
capacity 1n the U.S.

     It should be noted that the estimated reserves of uranium ore
have risen significantly since 1947 when first thought was given to
large-scale extraction (Figure 7).   Such a response of or "growth"
of reserves Is often the result of Increased exploration brought about
by promise of Increased demand.  The response 1s by no means unique to
uranium.
Crude Oil

     The estimated crude oil reserves of the United States are 35 billion
barrels.  The comparable estimate of reserves for Region VIII states
1s 1.9 billion barrels or 5 percent of the U. S. reserves.  Annual
6.  Of a total of 19,000,000 acres held for uranium mining and exploration,
    about 12,900,000 acres, or 68 percent are held 1n Region VIII states
    and over 17,250,000 acres, or 91 percent held 1n the Region VIII-Four
    Corners area.

7.   Statistical Data of the Uranium Industry ,  1 Jan 72 - Grand Junction
    Office of the USAEC, Grand Junction, Colorado  81501, P.O.  Box 2567,
    GJO-100.
                                12

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     COUNTIES  WITH  URANIUM DEPOSITS
      IN SEDIMENTARY HOST ROCKS

                FIGURE 5
COUNTIES  WITH  URANIUM  DEPOSITS
IN OTHEK THAN  SEDIMENTARY HOST  ROCKS
                          13

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           FIGURE 6

 General Location of Uranium
Reserves In Region VIII States
                                           URANIUM DEPOSITS
URANIUM MINING AREAS
                14

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TABLE 4:              DISTRIBUTION OF 1/1/72 ORE RESERVES  BY  STATE
State
New Mexico
Wyomi ng
Texas
Colorado
Utah
Others : Ari zona ,
($8.00 Reserves)
Tons Ore Grade Tons UiOa
51,705,465
51,199,682
10,225,129
3,329,806
2,646,394
8,415,201
0.265%
0.185%
0.142%
0.267%
0.325%
0.110%
137,032
94,882
14,564
8,905
8,602
9,227
% Total
Tons U^Og
50.156
34.728
5.331
3.259
3.149
3.377
No.
Deposits
67
130
39
294
115
87
        Montana, Nevada,
        North Dakota,
        Washington, Oregon,
        South Dakota, Alaska

              Totals      126,521,677   0.216%   273,200*      100.000     "731"

      *Rounded


TABLE 5:           URANIUM ORE SHIPMENTS TO MILLS -  1948 THROUGH  1971
By State
State
New Mexico
Utah
Wyoming
Colorado
Arizona
Others*
Total
Tons of Ore
41,785,800
12,872,629
19,429,136
14,289,303
2,965,900
5,289,120
96,631,888
0.22
0.32
0.22
0.25
0.30
0.21
0.24
Contained
Tons U3OA**
91,044
40,623
42,669
35,602
8,950
10,964
229,852
           *Includes Alaska, California, Idaho, Montana, Nevada,  North Dakota,
            Oregon, South Dakota, Texas & Washington.
          **Includes miscellaneous UsOs receipts.
      After  Statistical Data of the Uranium Industry    See footnote 7.
                                           15

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                             TABLE 5b

                U. S. URANIUM ORE PROCESSING MILLS
                  Operating or Under Construction
            Company

Anaconda Company
Atlas Corporation
Conoco & Pioneer Nuclear, Inc.
Cotter Corporation
Dawn Mining Company
Federal-American Partners
Humble Oil and Refining Company
Kerr-McGee Corporation
Mines Development, Inc.
Petrotomics Company
Rio Algom Corporation
Susquehanna-Western, Inc.
Susquehanna-Western, Inc.
Union Carbide Corporation

Union Carbide Corporation
United Nuclear-Homestake Partners
Utah International,  Inc.
Utah International,  Inc.
Western Nuclear, Inc.
     Location

Grants, New Mexico
Moab, Utah
Falls City, Texas
Canon City, Colorado
Ford, Washington
Gas Hills, Wyoming
Powder River Basin, Wyo.
Grants, New Mexico
Edgemont, South Dakota
Shirley Basin, Wyoming
LaSal, Utah
Falls City, Texas
Ray Point, Texas
Rifle, Colorado  )
Uravan, Colorado )
Natrona County, Wyoming
Grants, New Mexico
Gas Hills, Wyoming
Shirley Basin, Wyoming
Jeffrey City, Wyoming
          Nominal
          Capacity
         (tons ore
          per day)

           3,000
           1,500
           1,750
             450
             500
             950
           2,000 U
           7,000
             650
           1,500
             500 I/
           1,000
           1,000

           2,000

           1,000
           3,500
           1,200
           1,200
           1.200
          Total
           31,900
I/  Under construction.

After Statistical Data of  the Uranium  Industry
See footnote 7.
                                 16

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                                   RELATIONSHIP  OF TOTAL $8OO RESERVES TO PRODUCTION
                                                   WESTERN  UNITED  STATES
    550,000
    500,000
                   PERCENT OF RESERVES AND PRODUCTION!
                         REPRESENTED BY RESERVES*!
                                                                   RESERVES AND CUMULATIVE PRODUCTION
—   300,000
O)   250,000
                                                                               RESERVES
                                                   CUMULATIVE  PRODUCTION
                                                                               ANNUAL PRODUCTION
         1947 1946  1949 1950 1951  1952 1953  1954 1955  1956 1957  1958  1959  I960  1961  1962  1963  1964 1965  1966 1967  1966  1969 1970  1971
                                                        CALENDAR YEAR

                                                            Figure 7

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 U. S. useage of crude oil, from both domestic and foreign supplies, has
 been on the order of 5.5 billion barrels.  The close approximation of
 total U. S. Reserves to annual U. S. useage 1s slightly misleading
 due to an apparent lag between exploration for new reserves and produc-
 tion.    But,   demand for crude oil is encroaching  upon U. S. reserves.
 Simply stated, we are using oil faster than we are finding it.

      In 1972, production of crude oil from Region VIII states was
 on the order of 700,000 barrels per day (256 million bbls/yr) or
 just over 7 percent of the total U. S. crude oil and condensate
 production (Table 6).  Addition of the Four-Corners state of New
 Mexico to the Region VIII production increases the area production
 to almost 11 percent of the total U. S. production.

      Figure 8 portrays those general areas of Region VIII states in
 which oil, and gas, deposits may be expected.


 Natural Gas

      Total natural gas reserves in the United States, recoverable by
 conventional, "economic" methods, have been estimated to be 250
 trillion standard cubic feet (SCF).  The comparable natural gas
 reserves in Region VIII states (see Figure 8) have been estimated
 to be 10 trillion SCF or 3.5 percent of the total U. S. reserves.
 Annual useage of natural gas from all sources was  about  23
 trillion SCF (in 1973).

      Production of natural gas from Region VIII was about 1500
 million SCF per day In 1972 (550 billion SCF/yr) or 2.4 percent of
 the total U. S. production.  Production from Region VIII and Four
 Corners' States was approximately 7.5 percent of the 1972 production
 (Table 7).

   •   The Region States and New Mexico also contain significant reserves
of so called "tight" natural gas.  Tight gas refers to natural gas
trapped in rock strata of low porosity.  Extensive conventional fracturing
techniques as well as the more controversial nuclear stimulation (frac-
turing; have been proposed to free these gas reserves.  Recent estimates8
of potentially recoverable trapped gas in areas of Wyoming, Colorado,
and Utah amount to 600 trillion SCF.  This 1s in addition to the estimated
U. S. reserves of conventionally-produced natural gas (285 trillion SCF).
8.  National Gas Technology Task Force for the Technical Advisory
    Committee of the National Gas Survey by.the Federal Power
    Commission.
                                18

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                                TABLE 6


             U. S. Production of Crude 011  and Condensate
                             1972 (Preliminary)
 State

 Alaska
 Alabama
 Arizona
 Arkansas
 California
 Colorado
 Illinois
 Indiana
 Kansas
 Kentucky
 Louisiana
 Michigan
1000 bbls/dav

    202
     27
      3
     50
    952
     85
     97
     17
    205
     27
  2,456
     35
State

Mississippi
Montana
Nebraska
New Mexico
North Dakota
BnTo
Oklahoma
Texas
Utah
Wyoming
Ha, NY, Pa, U
Other
       U.S. Total
 1000 bbIs/day

         168
          92
          24
         304
          56
          22
         572
       3,542
          71
         392
Va.       57
           2
(Region VIII States underlined.)
                                TABLE 7
                  U.  S.  Marketed Production of Natural  Gas
                             1972 (Preliminary)
 State    (mmion cubic ft/day)     State
Alaska
Arkansas
California
Colorado
Illinois
Kansas
Kentucky
Louisiana
Michigan
Mississippi
Montana
367
461
1,514
308
7
2,451
218
22,757
91
293
105
                                    Nebraska
                                    New Mexico
                                    New York
                                    North Dakota
                                    TJhlo
                                    Oklahoma
                                    Pennsylvania
                                    Texas
                                    Utah
                                    Virginia
                                    West Virginia
                                    Wyoming
                                    Others
                                      (million  cubic  ft/day)

                                                 12
                                              3,230
                                                  6
                                                 89
                                                225
                                              4,717
                                                218
                                             23,662
                                                104
                                                  7
                                                686
                                                 10
                                               Total
                                             627426
(Region VIII States underlined.)
                                   19

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            FIGURE 8

General Location of Oil and Gas
 Reserves in Region VIII States
                                           OIL AND GAS FIELDS
                                          "TIGHT GAS11 RESERVES
                 20

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     The U. S. Atomic Energy Coimrisslon (USAEC) has planned, along various
time schedules, a series of field tests of nuclear stimulation methods to
free this tight gas.  Three such experiments have been conducted:  Project
Gasbuggy 1n New Mexico and Projects Rulison and R1o Blanco in Colorado.
The next experiment considered Is Project Wagon Wheel In Wyoming.  All such
applications have had questionable degrees of success to date.  Recent
projections show that the USAEC still has In mind a basin-wide "Full Commercial
Application" of nuclear-assisted gas production 1n 1983.9

Geothermal Resources

     Figure 9 Indicates the large area of Region VIII In which a potential
for geothermal energy resources appears best.  Geothermal activity in the
region Is rapidly Increasing.  A federal lease sale Is planned In Utah
for FY 74.  State leases are also being offered In Utah.  The National
Science Foundation has a geothermal exploration experiment, consisting
of drilling a deep well In an area of high heat flow, underway 1n Montana.
Considerable Interest In Federal leasing has been expressed In Utah,
Montana, Colorado and Wyoming.  The region does, along with the far
western states, contain the majority of the United States geothermal energy
potential 1n concert with the relatively youthful age of Its geologic
processes.

Hydroelectric Energy

     Hydroelectric power supplies about 3.9 percent of the nation's energy
demand or 15 percent of the nation's electrical demand.  As of 1 Jan 1972,
It was estimated that the Mountain States^ had an "undeveloped Installed
capacity" of 26,200 megawatts or 21 percent of the total undeveloped
capacity of the United States.  Estimates by major drainages show the
combined total "undeveloped" capacity of the Colorado River and Missouri
River Basins to be about 13,900 megawatts or 11 percent of the total
undeveloped capacity of the U. S.10

Coal 1n the Northern Great Plains

     The predominant conventional fuel extant In the northern part of
Region VIII Is coal.  Of the 1.6 trillion tons of reserves estimated to
be 1n the six-state Region VIII, 1.4 trillion tons are in the four states
of the Northern Great Plains (Montana, Wyoming, North Dakota, South Dakota).
Coal Production from Northern Great Plains States in 1973 has
 9.Summary Attachment to  The Nation's Energy Future — A Report to
     the President of the United States — 1 Dec 73, USAEC (Item A-2,
     under "Increase Petroleum and Natural Gas Productions")

10.  Includes Region VIII States plus Nevada, Arizona, New Mexico, Idaho
     and less the Dakotas.  From Energy Facts. Subcommittee on Energy
     of the Committee on Science and Astronautics, U. S. House of
     Representatives, Ninety-third Congress, November, 1973.
                                 21

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          NORTH DAKOTA
FIGURE 9
    22

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been estimated to be 16 million tons per year from Montana11,  15 million
tons from Wyoming12, and 7.5 million tons from North Dakota".   Projec-
tions have been made to the effect that by 1980, Montana production may
rise 400 percent to 64 million tons per year, Wyoming production may
rise 360 percent to 54 million tons per year, and North Dakota  production
may rise 560 percent to 42 million tons per year.14

      Most of these coals are sub-bituminous (range 1n heating  value from
8300 BTU's per pound to 11000 BTU's per pound) and lignites (less than
8300 BTU's per pound'5).  They are contained In or near the Fort Union
 (geologic) Formation, which, by its extensive lateral extent,  comprises
perhaps the largest coal basin area within one Nation in the world.
Sulfur content of these coals 1s often less than one percent,  though
contents as high as 2.4 percent have been reported recently.16   The
coals are projected as serving to help meet the requirements for cleaner
burning fuels — an important objective of the Clean Air Act.

      In 1971 and 1972, the U. S. Department of Interior — Bureau of
Reclamation Issued two reports17 which projected the potential  growth
possibilities for energy production in the Northern Great Plains.
Forty-two potential power plant sites were selected by the writers where
coal and water resources were considered adequate for the generation
of a cumulative total of 200,000 megawatts of power.  An "interim"
production level of 50,000 megawatts by the year 2000 was also  projected.
For comparison, the current production of power from the Northern Great
Plains Is approximately 3,000 megawatts. Existing,proposed coal-fired
power plants in the Northern Great Plains are located in Figure 10.   Two
Indicators of the growth potential of the area are the 1,500 megawatt Jim
Brldger plant under construction in southwestern Wyoming and the
construction of the first 660 megawatts Montana Power Company  has
planned for CoIstrip.  Montana Power contracted with Westinghouse Electric
Corporation to prepare an environmental report or assessment for an
Increase of the total generating capacity at Col strip to 2,060 megawatts
11. Coal Development In Eastern Montana: Report of the Montana Coal Task
    Force. January 1973.

12. Wyoming Geological Survey statistics

13. Interpolation from NGPRP National Energy Considerations Report -
    Intermediate scenario.
14. NGPRP high development scenario projections.

15. Economic Mineral Deposits; Bateman, Alan M.; John Wiley & Sons, N.Y.,NY
    1950.
16. B1g Skv EIS. U.S. Dept. of Interior, Geological Survey, Oct. 25, 1973.

17. North Central Power Study (1971) and Bureau of Reclamation Appraisal
    Report on Montana & Wyoming Aqueducts (1973).
                                 23

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                EXISTING AND PROPOSED ENERGY GENERATION FACILITIES IN THE N G P R P  STUDY AREA
ro
           EXISTING POWER PLANT
           PROPOSED POWER PLANT
           PROPOSED GASIFICATION PLANT
                                           FIGURE 10

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by 1979.  At this capacity 1t would compare In size to the 2310 mega-
watt Navajo Power Plant near Page, Arizona.  It would appear that with the
capability to produce up to 8 million tons of coal  per year, the Col strip
Western Energy Mine would displace the Navajo mine  at Frultland, New Mexico
as the largest coal mine 1n the United States.
     The projections of the aforementioned reports  assumed that an
annual production rate of eight billion tons of coal and annual usage
of up to 900,000 acre feet (1.1 x 109 m3) of water  would be required
to sustain an electrical production capacity of 50,000 megawatts.  These
reports investigated and reported favorably on the  feasibility of divert-
ing approximately one-third of the average flow of  the Yellowstone
River to the coal deposits for use at the mine-mouth power plants in
eastern Montana and northeastern Wyoming.

     So called "full-scale" development on the order of magnitude
projected above could precipitate a seven-fold increase in population
in the coal-rich areas]of Montana and Wyoming.  The social and cultural
consequences of such "development" challenge accurate description and
evaluation.

     The four-state area of the Northern Great Plains coal deposits
as well as the six-state area of Region VIII is relatively "undeveloped"
in the conventional sense of the word.  When these  six states are com-
bined with Idaho, New Mexico, Arizona, Oregon, and  Washington, one
delineates an essentially agricultural and recreational environment
with sparse population as opposed to one in which urbanization and
Industrialization prevail.  For example, the average population per
square mile In eastern Montana and northeastern Wyoming is 1.4 people
per square mile.  This compares with an average of  56 people per square
mile for the entire United States.  Figure 11 is a  population density
map of the NGPRP study area.  The environment in this area is one of
the least polluted and abused in the nation, representing very important
environmental values that will continue to increase in importance as
the nation becomes more populated and urbanized and as people continue
to demand unspoiled environments "elsewhere."  Thus, it is impossible
to correctly represent environmental matters in these states in terms
of kilometers of streams contaminated or cubic meters of air to be
cleaned up.  Rather, we must speak in terms of prevention of contamina-
tion — prevention of not just water and air contamination, but also
prevention of land disturbance, ground water contamination, and
aesthetic degradation.

     In order to prevent environmental contamination and to minimize the
unwanted impacts of the coal development that is already underway or is
presently permitted on over 1,300,000 acres (5xl05 hectares) of the area18
18.  The Bureau of Land Management has awarded permits and leases for
Fort Union coals on in excess of 320,000 acres (1.3xl05 hectares) of
public lands for coal exploration and development.  The Bureau of Indian
Affairs has leased over 16,000 acres (6.5x10* hectares) and issued
exploration permits for over 500,000 acres (2xl05 hectares) on the Crow
and Northern Cheyenne Indian Reservations.  State leases total over
490,000 acres (2xl05 hectares).

-------
ro
o*
                                                                                 Contour intervals: 5, 151 25, 100
                FIGURE  11.  POPULATION DENSITY I960 - PEOPLE/SQUARE MILE

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in the Northern Great Plains and more lands in the States of Colorado,
Utah, Arizona, and New Mexico, it is necessary to prescribe solutions
to problems of air and water pollution in the very near future.   In order
to achieve an orderly "development" of potential energy resources,
we must be able to properly estimate energy demands, modes of energy supply,
and total potential environmental Impacts of various levels and  modes
of production.  With respect to the coals occurring in the Fort  Union
Formation of Montana, North Dakota, South Dakota, and Wyoming, the only
estimates of the factors given previously have been prepared by  organi-
zations dedicated to supplying a demand through development of resources.19
No public or conservation-oriented, or broad based state, Federal, or
local participation in developing estimates had occurred prior to the
Northern Great Plains Resources Program.  Insufficient consideration had
been given to the possibilities of conserving energy or to controlling
the demand for energy prior to the 1973 restrictions on crude oil Imports.

      There are numerous unknowns to be considered when speaking of coal
and power development In the Northern Great Plains, not the least of
which is whether the people want such development, and if development
is desired, how development should be conducted.  The amount of  water
available for use in cooling is really unknown.  The best type(s) of
cooling for power plants in the area has not been determined to  everyone's
satisfaction.  The advantages or disadvantages of developing power from
other fuels found in the area have not been identified ... should power
be produced in the region for distant areas? ... should coal be  exported? ...
the questions are numerous.

      We believe that there is a need to provide these types of  data
to the decision-making entitles of the Northern Great Plains Region
such that choices relating to coal development can be made based on
data and documented preference, not just on best estimates and piecemeal  '
decisions.  We believe that the Northern Great Plains Program has and can
continue to serve as the vehicle to generate and collate data for this
purpose.  It has been important to act while the moratorium still existed
against the issuance of additional prospecting permits for coal.20

           Need for Regional Participation in the NGPRP

      The credibility of Region VIII and the agency as a whole rests on
the positive actions and decisions we make to become Involved in major
efforts of investigating the planning and management of regional energy
resource development.  Our past experience indicates the relative ease of
preventing problems from occurring as opposed to remedying the harmful
effects once the problem has surfaced.  Long-term and large-scale resource
development in Region VIII will prove no exception.
19. North Central Power Study (1971)

20. Federal Register. Tuesday, February 20, 1973, Doc 73-3175 - order
    effective February 13, 1973 and "until further notice".  Order No. 2952,


                                27

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      The Northern Great Plains Resources Program (NGPRP) has provided
an Important opportunity for  regional participation that has become the
format for environmental protection  and environmental planning throughout
the region as energy resource development occurs.  In addition to assuring
maximum regional  and local  Input  to  the study, regional participation will
aid ongoing programs by facilitating and promoting day-to-day contacts
with the Involved states, affected industries, and local Interests.  In
effect, a Program like the  Northern  Great Plains Resources Program serves
to multiply the  effectiveness of  all participants by Identifying the
experts and focusing their  efforts on subjects of greatest Import and makes
the raw data as  well as the results  available to all parties.  This
regional office  has received  correspondence  from the States of Montana,
Nebraska, North  Dakota, South Dakota, and Wyoming, and public groups
such as the tyyoming Audubon Society  requesting assistance 1n areas such
as air quality monitoring,  diffusion modeling, and trace element analysis
of coals.  During the  first year  of  our efforts, we have tried to respond,
within our capabilities, to all such requests.  Subsequently, sections of
the plan will address  our responses  more thoroughly. Since new power plants
will continually generate Interest in these  areas, we anticipate that
many NGPRP-initiated programs will be continued past the study's formal
conclusion as Integral parts  of the  EPA's programs and as Integral parts
of programs at all  levels  cf government.  While in many respects the
NGPRP resembles  the Southwest Energy Study21, 1t differs from it in the
sense that considerable development  had already occurred 1n the Four
Corners area at  the time of the Southwest Energy Study's Inception.
The NGPRP's analytical look is  occurring much earlier in the decision-
making process.   Conceivably, for this reason alone, the NGPRP may
make a greater impact  than  the  Southwest Energy Study on the planning,
development, and management of  energy resources.  In addition, whereas
the Southwest Energy Study  used only existing data, the NGPRP has and
will continue to acquire the  necessary information to fill any gaps 1n
the presently available data.  The NGPRP must also facilitate public
participation in all stages of  the Program's efforts. (Appendix 2)

      The Program may  also  serve  as  an example for a methodology that
adequately addresses and provides information on oil shale development.
The regional office is extremely  Interested  1n that potential since
all presently economically-recoverable oil shale reserves of the United
States lay within the  Region.
21. The stated purpose of both studies is to develop  an Information base
    to guide decision-makers and to identify new data needs and alter-
    natives for coal development in the west.
                                 28

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      The remainder of this document 1s organized as follows:

      Section II describes a brief history and organization of the NGPRP.

      Section III presents the objectives of EPA Involvement In the NGPRP.

      Section IV 1s an Accomplishment Plan detailing regional  resource
needs and accomplishments to date.  The needs are based upon our best
estimates as to the total work to be done and the regional  Input required
to satisfactorily affect the final outcome of the Program.   Allocation
of lesser resources has the danger of weakening our chances of Influencing
the course of the Program.  Lesser support offers a sound basis for the
Agency to reevaluate Its positive position on participation In the study.
Lesser participation would not allow EPA to do an adequate job and yet
would erroneously lead outsiders to believe that we had done our job.
A great deal of technical effort 1s required to understand the meaning
of coal and other resource development.  Thus a significant effort 1s
required.  In certain Instances this Plan Identifies activities and
contract funds that are necessary to accomplish the objectives.  Though
1t will be appropriate for EPA to continue to allocate monies and conduct
activities, every effort is being made to perform the activities 1n
close cooperation with and with monetary support from the other Program
participants.

      Section V is a brief summary.
                                 29

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 II.  Northern Great Plains Resources Program:

      Its Evolution and Present Framework

      The Increasing Interest and activity directed at this region's
 energy resource development and the large number of applications pend-
 ing for permits to explore, lease, and develop the coal reserves of
 hundreds of thousands of acres of state, Federal and Indian land
 prompted Region VIII to draft letters to Secretaries Morton and Butz
 (Interior and Agriculture), calling for a comprehensive and systematic
 study of coal development in the Fort Union area.  The Administrator
 of EPA signed these letters on March 24, 1972.  Secretary Butz re-
 sponded on May 2, agreeing to the need for such a study.  He suggested
 that other minerals be investigated and also to include in the study
 areas such as national energy requirements, environmental protection,
 and land use.

      Secretary Morton's reply of July 27, 1972 expressed a similar interest
 and indicated Interior's1 proposal for a joint Federal/State management
 plan to be used in land use and coal development decision-making.  Meet-
 ings involving EPA, Agriculture, Interior, and Commerce (through the
 Old West Regional Commission) officials on July 28, and August 9 and
 10, led to an agreement between the agencies to initiate a Federal/
 State task force to investigate the economic, environmental and social
 impacts associated with large-scale mineral resource development, pri-
 marily coal, in the States of Montana, Wyoming, North and South Dakota.
 Nebraska was added to these states because it was a member of the Old
 West Commission.  A Program Review Board at the Assistant Secretary and
 Governor level was formed to provide coordination and policy leadership
 for the study.  The Board created a Program Management Team to develop
 an outline for this Northern Great Plains Resources Program and to super-
 vise matters on a day-to-day basis.  This group consists of representa-
 tives from EPA, Interior, Agriculture, Commerce, and the States of
. Montana, Wyoming, North and South Dakota, and Nebraska.  The organiza-
 tional format of the Program 1s represented in Figure 12.

 Framework of NGPRP

      The Program Management Team released a final outline for the plan
 of the NGPRP in January 1973.  A description of the Program's framework
 follows.  The text of the Plan Outline of the NGPRP is Included as
 Appendix 1.

 Objectives of NGPRP

      The objectives of the NGPRP are three-fold:

      1.   To provide data and analytical models enabling assessments of
 the consequences of various courses of action to be made.
                                                        \
      2.   To bring together Federal, State and local groups concerned
 with the planning and management of this region's energy resources.
 The aim 1s for a coordinated regional planning program.
                                    30

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                            NGPRP ORGANIZATION 1974
                             PROGRAM REVIEW BOARD

                           INTERIOR         AGRICULTURE
                           EPA	STATE
                            PROGRAM MANAGEMENT TEAM
                         INTERIOR    -

                         EPA

                         NEBRASKA

                         SOUTH DAKOTA
             AGRICULTURE

             MONTANA
             NORTH DAKOTA

             WYOMING
                           SUBJECT AREA WORK GROUPS
REGIONAL
GEOLOGY
(INTERIOR)

MINERAL
RESOURCES
(INTERIOR)

WATER
(INTERIOR)
                  ATMOSPHERIC
                  ASPECTS
                  (EPA)
     SURFACE RESOURCES
       (AGRICULTURE)
IN-STREAM VALUES
RECREATION
WATER QUALITY
FLOOD CONTROL
GROUND WATER
OPERATIONAL STUDIES
WILD ft SCENIC
LAND
SOILS
VEGETATION
FISH & WILDLIFE
RECREATION
RESOURCE DEVEL,
 POTENTIAL
                         PROGRAM MANAGER
                         (INTERIOR 8 INTERIOR STAFF)
                  SOCIO-ECONOMIC
                  * CULTURAL ASPECTS
                  (AGRICULTURAL)
AGRICULTURE
WILDERNESS
SCENERY
ECOSYSTEM
 RELATIONSHIPS
FOREST PRODUCTS
SURFACE
 REHABILITATION
CONSTRAINTS
NATIONAL ENERGY
CONSIDERATION
(INTERIOR)
                                                                          FIGURE   12
                                                        NGPRP ORGANIZATION

                                                        MARCH 1974

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      3.  To promote the exchange of information between  organizations
 that have common activities such as data collection,  research,  plan-
 ning, etc.

      These three objectives are all to be achieved in the context of
 providing an "analytical and informational framework  for policy and
 planning decisions at all levels of government."22

 Program Sections

      The NGPRP is divided into five principal  "Sections" or phases as
 fol1ows:

           1.  Program design

           2.  Regional profile

           3.  Constraints and alternate strategies

           4.  Analysis of consequences, and

           5.  Preparation of final  report

 These Sections are further described below.

 1.   Program Design:

           After Federal, state, and local groups had  an  opportunity to
      comment on the NGPRP outline,  the Work Groups were  formed  and
      essentially enlarged the Program Design to enumerate specific
      data, research, and study needs.  Comments from  the public, as
      well as other non-government groups, were solicited.   This Re-
      gional  office has stressed the need for public participation
      throughout the course of the study.  The  Southwest  Energy  Study
      was criticized for insufficient public participation,^ and we
      must avoid making this mistake during the course of the NGPRP.
      Region  VIII drafted a set of recommendations concerning public
      involvement in the NGPRP (these recommendations  appear in  the
      Appendix), which were forwarded to the Program Management  Team.

 2.   Regional Profile

           Data were collected and analyzed to  give a  profile of the
      region's mineral, air, water and surface  resources;  baseline
      environmental  quality; and social, economic and  cultural atti-
      tudes.   The results of this effort will be finalized,  in interim
      form, during April  and June of 1974.  Certain groups have  acquired
      new  data,  others have been limited to existing data, and still
      others  are starting to collect new data.
?£Program "Outline of Plan", Appendix  1.
23.  RocKy Mountain Center on Environment ("ROMCOE") letter dated
     March 16, 1973 to J. W. Larson,  Interior, from R. P. Hansen,
     A. G. Melcher, and K. Fletcher.
                                    32

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3.  Constraints and Alternative Strategies:

          Prior to the enumeration of possible alternative strategies
     for the region, preliminary studies of  legal,  environmental,  air,
     water, Institutional, social, economic, and  physical  constraints
     operating in the area were 1n the form  of "Constraints Reports."
     These reports are Included in the Interim reports  of  each  work
     group.  Then alternative strategies were considered — alterna-
     tive strategies such as no further development or  "base develop-
     ment"; different rates and Intensities  of additional  coal  develop-
     ment in the form of "intermediate" and  "extensive" development,
     all including mine-mouth power generation, shipping coal outside
     the region, gasifying coal, development of other energy and mineral
     resources, in varying degrees.  In addition, strategies such  as
     required legislation and changes in leasing  policies  will  also be
     considered.

4.  Analysis of Consequences:

          Models and analytic methodologies  will  be developed to assess
     the environmental, economic and social  impacts of  the various
     strategies and courses of action developed in  the  previous section.

5.  Final Report:

          A final report compiling the results of all studies and  in-
     vestigations will be written.  However, data and interim reports
     will be available to decision-makers as they are generated in the
     course of the study.  A major interim report for June, 1974 is
     scheduled.  Special topic reports, such as cooling alternatives
     for power plants, coal gasification technology, etc., will also
     be published in 1974.

     The NGPRP will operate under an approximate  three  year time frame.
The program sections will be time-phased, and each  will not necessarily
last for the entire duration of the study (see Figure 13).  Activity
time frames are discussed in Section IV, the Accomplishment Plan.

     Significant and considered deliberations are presently under  way
to determine the future of the Northern Great Plains Resources  Pro-
gram.  The Program agreed to by the primary  Federal participants
(Agriculture, EPA, and Interior) was scheduled for  three years  (1972-
1975).  The Program started its technical deliberations in mid-1973
and determined that an interim report would  be required in June of
1974.  In late 1973, it became apparent that some of the  participants
had not planned to continue with the Program after  the  June, 1974
report.

     Recent (February, 1974) deliberations have reIndicated strong
support by members of the Program Management Team to continue the
Program in essentially its present format, with an  increased role
in coordination of pertinent energy research and  development.
                                   33

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PROGRAM DESIGN


   DRAFT OUTLINE
    PROGRAM DESIGN
      REPORT
REGIONAL PROFILE
CONSTRAINTS
ALTERNATIVE STRATEGIES
ANALYSIS OF CONSEQUENCES
FINAL REPORT
                       9/72 12/72 3/73

                       J	I	L
             12/73
                          12/74
                  12/75
A-©
A
A
                          /\ MILESTONES




                          O PUBLISHED or WORKING REPORTS
     —ooooooooo-©

A	ooooooo^

A	o-o—oooooo©
         0—0
OOOO-OO-©


       .   A-
                  Schematic Representation of Interagency NGPR Program
                          As Initially Proposed


                    Times Shown are Tentative Pending Further Work
                                                               FIGURE 13

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     It Is this regional  office's view that the Program should be
continued in essentially its same format for one more year ~ through
June of 1975, and then would phase out its activities during the
following fiscal year 1976 (until June of 1976).

     EPA, from its Region VIII staff, leads (L) the Atmospheric Aspects
Task Group (Figure 14] and the Water Quality Aspects Subgroup of the
Water Task Group; participates (P) in the Mineral Resources, Surface
Resources, National Energy Considerations Task Groups; and contri-
butes (C) to the Socio-Economic and Cultural Aspects Task Group.
Some input was supplied to the Regional Geology Task Group.

     Task Group Leaders and their affiliations are listed below:
          A.  Regional Geology

          B.  Mineral Resources

          C.  Water



          D.  Atmospheric Aspects

          E.  Surface Resources

          F.  Socio-Economic and
                Cultural Aspects

          G.  National Energy
                Considerations
Dick Keefer (USGS - Denver)

Bill Parks  (USBM - Denver)
Doss White
Phil Gibbs (BR - Billings)
(Robert Hagen.Jim Shaw
 EPA-Denver, Water Quality Aspects)

Louis Johnson (EPA - Denver)

Otis Copeland (USDA - Ogden)

Frank Osterhoudt (USDA - D.C.)
James A. West (Interior ASMR-D.C.)
Walter Dupree
Status of Work Groups
     All Work Groups have worked toward the objectives of issuing
interim reports during April of 1974 and contributing to the Inter-
im Report of the Program as scheduled for June of 1974.  Most Groups
have uncertain pictures at this time, due to lack of direction of
the Program Review Board as to their future role.

III.  Objectives of EPA Involvement in the Northern Great Plains
                          Resources Program

Objectives

     In Sections I and II, the need for and purpose of the Northern
Great Plains Resources Program was discussed, both directly and in-
directly.  The objectives of the Program are necessarily diverse,
since the interests of many sectors are represented.  This Accom-
plishment Plan is, however, directed toward the Environmental Pro-
tection Agency's participation in the program and, in particular,
                                   35

-------

c*>
O»
itlonal Energy
Considerations
naroy supply and demand
nergy technology
•Scenario 	
.-001 (Energy Office)
'-EPA. OOC. FPC,
AEC. USDA. BR.
BLM. BSFW
C-OST. OEP, Indust.

Current 1 projected
energy
Technology
Rational • Regional
energy
Fuel situations
nwrnate regional/
national energy
resourcef develop-
ment strategies
and technologies
to development
satisfaction or
national and
regional energy
and fuel damantf
Ion-satisfaction
Intermediate
satisfaction
SOClQ-EcOIKMiC
and
Cultural Aspects
Existing local and regional
econony
Social institutions
Ittitudes
Archeology 1 history
Aesthetics
l-USM-ARS
P-USOA, DOC. HEM. BIA.
BIN, NPS. EPA.
States. Indust.
Private Org.
C-BOR. HUD. OL
Location
Distribution
Importance
Life styles
Labor force
Attitudes
Physical constraints
on change
Economic constraints
on change
Continue current status
Accelerate selective
development
Nixes of competing
needs
MO change
Preservation or current
life style a values
Crowth of population a
economy with possible
disruptions 1 losses
i 	 •.
Surface"
Resources
PRINCIPAL
Soils
Vegetation
Timber
Grassland
Other
Fish & wildlife
Recreation
Agriculture
Scenery
Wilderness
Reclamation
ACENCV
L-USDA-FS
P-BLN. BOR. BSFW.
EPA, NPS.
States. Prlv. Org.
C-BLN. COC
Location
Production
Current use
Ownership I control
Zoning
Reclamation
Ownership I control
Economic
Biological • physical
Attltudinal
Zoning
Continue current
practices
Accelerate selective
development
Nixes of alternative
development
No development
interrerence from other
developments
Preservation/Conserva-
tion
Consumption
Reclamation
turn JU&AS 	
Atmospheric
Aspects
AftEU OF IHYEttJT
Compositional a
Regional dynamics
Control technology
PARTICIPATION*
L-CPA
P-NOAA.
States, Prlv. Org.
C-USOA. 001
Climate
Quality
Meteorology of
trace elements
QualUy
Standards
Alternative point
source locations
Export
No degradation
Regional quality
pollutant
dispersion patterns
c • —
Hater
Surface
Sub-surface
L-BR (Supply)
P-EPA (Quality).
GS (Basic date),
NRBC. BSFW. BLN,
USDA. COE. NPS.
States, Prlv. Org.
C-BOR
Quantity
Quality
Current A projected
use (current plans)
Impact on In-stream
Rights
Compacts
Quality * quality
standards
Location
Attitudes
Surface development
alternatives
Ground water manage-
ment alternatives
Interbasin diversions
No development
consumption vs.
Conversion Quality
§
Nineral
Resources
Coal
Oil A 8as
Uranium
Other
L-8N
P-BLH. EPA. USDA.
BR, GS.
States,
Industry. Prlv. Org.
C-AEC
Location t depth
Grade
Ownership 1 control
Trace elements
WneaHWy
Ownership, leases
Reclamation laws
Demand
Attitudes
Alternative
conversion
Mining methods
Extraction B exportation
Local processing
Local energy conversion
Local industrialization
No development
Consumption vs.
Conservation
Ground water
H
teglonal
Geology
Land fona
Topography
Geology
L-CS
P-USOA, States
C-BLN, EPA
icale-Coverage
loBe
liability
iurface hydrology


Read numbered blocks for program sections.
Read successtve blocks of lettered columns
for work group title, proposed group makeup
and type of subject matter addressed.
1
Regional
Profile
2
Constraints
on Changes
3
Strategies
for Change
4
Analysis of
Consequences
PROGRAM SECTIONS ]
«L - Lead. P - Participant, C - Contributor
                                                                            TASK MATRIX
                                            NGPRP WORK GROUPS AND PARTICIPANTS (Modified from January 19. 1973 Version)
                                                                             FIGURE 14

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                            TASK MATRIX
     The attached matrix Indicates the scope and organization of the
program and Illustrates how work groups, organized on the basis of
technical expertise, will participate in each of the four sections of
the program as they are described 1n the draft design outline.  The
tasks shown on the matrix are Intended to be Illustrative rather than
exhaustive.  The work groups are designed to bring together related
Inventory and modelling expertise throughout the study.  At the same
time, the major sections of the program will be coordinated across
work group lines.  Staff coordinators will be In charge of each program
section and may be members of the Program Management Team.

     The right-hand column of the matrix Indicates proposed agency
assignments.  Lead agencies are designated by L.  These agencies will
have administrative and organizational responsibilities, subject to
overview by the Program Management Team, and will be full-time
participants.  Participating agencies are Indicated by P; they also
are likely to have full Involvement in decision-making and report
review within the area of responsibility of the work group.  They will
make major contributions to the work, as well as, to decision-making
and review.  Contributing agencies are designated by C; they will
provide Input to the program as appropriate and review reports within
their areas of expertise.

     Key to abbreviations:

AEC        Atomic Energy Commission
BIA        Bureau of Indian Affairs
BLM        Bureau of Land Management
BM         Bureau of Mines
BOR        Bureau of Outdoor Recreation
BR         Bureau of Reclamation
COE        Corps of Engineers
DL     -   Department of Labor
DOC        Department of Commerce
DOI    -   Department of the Interior
EPA    -   Environmental Protection Agency
FPC        Federal Power Commission
FS         Forest Service
GS         U. S. Geological Survey
HEW    -   Department of Health, Education and Welfare
HUD        Department of Housing and Urban Development
MRBC   -   Missouri River Basin Commission
NOAA       National Oceanic and Atmospheric Administration
NPS    -   National Park Service
OEP    -   Office of Emergency Preparedness
OST        Office of Science and Technology
BSF&W  -   Bureau of Sport Fisheries and Wildlife
USDA       U. S. Department of Agriculture

                     EXPLANATION FOR FIGURE  14
                                37

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 that  participation  either conducted  1n  response to the Program or
 discharged  as  a  normal  responsibility toward the Northern Great
 Plains  by the  Region  VIII staff of the  EPA.

      The fact  that  substantial  EPA Involvement in the Program is
 critically  necessary  has  been previously indicated.24  The need for
 strong  regional  representation  in  the EPA Involvement 1s considered
 obvious.  We believe  that the credibility of EPA and the regional
 offices of  EPA rests  upon the positive  actions, decisions, and
 influence we muster during the  Implementation of the Program.

      The specific objectives  of EPA  involvement center upon the
 development, collation, and presentation of data  through
 the use of  which those decision-making entities will choose the
 most  acceptable  course  of action relating to resource development
 In the  Northern  Great Plains  area.   Primary EPA involvement will
 continue to be related  to those areas in which we have been directed,
 by law, to  work; namely:   water quality, air quality, radiation,
 solid waste, and aesthetics (the latter as addressed in the National
 Environmental  Policy  Act).  Me  have  included in Appendix 3 a state-
 ment  of statutory justification for  EPA participation in the NGPRP.
 Secondary EPA  involvement has been in the broader areas that tend to
 have  the most  impact  upon EPA's areas of responsibilities.  These more
 general areas  include revegetation,  population growth, energy demand
 and supply, mining  methods, wildlife and recreation values, and the
 choices we  have  between energy  fuels and satisfaction of energy demand,

      A  major objective  of EPA participation in the NGPRP is to aid
 Region  VIII of EPA  to define  and evaluate its on-going environmental
 protection  program  as related to this area.  The large data base,
 the research,  and the alternatives of development, technology, and
 environmental  impact  will  continue to be of immense value to Region
 VIII  1n all  of Its  program planning  and Implementation processes.
 Techniques  and analyses developed and refined here will also be of
 great value to other  regions, particularly those in the West, in
 planning  for environmental  protection and pollution control.  The
 value has already shown Itself  as oil shale and other energy fuels
 undergo renewed  development in  the West, in that our experiences
with  the  Program give us  a  guide and experience for evaluating the
 potential development of  these  other fuels.

Approach or Secondary Objectives

      In order  to achieve  our  goal of following the most environ-
mentally acceptable course  of action, It is both necessary and
appropriate  to Impact the Federal, state,  and local decision-making
processes and, in fact, to  assure the development of such processes
 If they are  presently absent.   Such  interfacing with other agencies
and the public sector takes place both  inside and outside the Pro-
gram.
     An "Action Memo" dated August 3, 1972, "Mineral Development 1n
     the North Central United States" - AH (EPA)

                                   38

-------
     It is necessary, because of the large geographic area under
consideration for coal extraction, because of the potentially large
power-generating capability, and because of the still larger area to
which power may be supplied, to select those areas of the Program
where EPA involvement may show the greatest return or benefit.  A
continuing objective will be to strengthen state and local capabili-
ties wherever necessary so that environmentally sound development,
commensurate with EPA's directives and responsibilities, is achieved.
EPA will also strive to have other Program participants contribute
both expertise and funds to accomplish those tasks we see as critical
to the Program.

     In many cases, it will be appropriate to develop arrays of data
describing alternative modes of development and the results of such
development.  To a degree, this is "modeling."  It will often be
necessary to develop and refine the tools for "modeling" and then to
transfer the "modeling" technique to other activities, such as other
Task Groups and the states, for use.

     Many tasks are and will be performed simultaneously.  Many task
items will be completed and reported prior to the end of the Program,
in order that decisions be based upon the most current Information.
The organization and interrelations of the Program elements are com-
plex and challenging.  Yet, successful implementation of the tasks is
critical to EPA's mandates.

     In the end, the success of the Program will be determined by
the public.  It can, therefore, never be emphasized enough that
public involvement, from the beginning, is the key to a successful
Program.

Region-wide Considerations (Region VIII)

     If coal development were the only development facing the Rocky
Mountain Prairie Region (Region VIII), it would be possible to
dedicate time and effort to the evaluation and direction of that
possibility, with little concern over any other mineral resources.
But the potential reserves of other energy fuels, existent 1n sub-
stantial amounts throughout the six-state region of Region VIII —
fuels such as oil, gas, water for hydroelectric plants, oil shale,
uranium, geothermal heat, and solar energy — make it necessary for
EPA to require simultaneous consideration of most all energy fuels
rather than just coal.  The large cumulative total of energy fuels
in the Region also makes it necessary to consider energy demand
alternatives.

     As the Inhabitants of the region recognize, not only does this
region view its scenery as a prized resource, but additional growth,
in terms of more people, has a far greater potential for causing
detrimental impacts on the environment in the Great Plains and Rocky
Mountain area than the same growth does in the established metro-
politan centers of the United States.  Thus, the addition of a power
                                    39

-------
plant and the support 1t requires and the secondary growth that it
can stimulate are all major factors in the lives of the area's
inhabitants.

     Trans-basin diversions of water are common in Region VIII and
may increase, if water-cooled power plants are constructed.  Such
diversions may have repercussions on agricultural development and
may significantly affect efforts to control salinity.  Thus, the
potential for coal and power development in the Northern Great Plains
could have a serious impact on water quality in the western portion
of Region VIII.

     Furthermore, review of the implications of resource development
occurring or scheduled to occur in the Northern Great Plains can
supplement the expertise already within the region, and EPA, in turn,
to allow us to cope with similar developments, such as nuclear stimu-
lation of gas on the western slope of the Continental Divide, or oil
shale development.

     It should be noted that the geographical boundaries of the NGPRP
vary according to the subject surveyed.  It is a Region VIII objective
to Insure that those impacts that may extend out of the immediate
NGPRP area of four states be adequately assessed.
                                   40

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 IV.               DETAILED WORK ACCOMPLISHMENT PLANS
             Regional Office Coordination and Management
     When the regional participation 1n the Northern Great Plains
Resources Program was proposed, It was considered necessary to have
a "Regional Coordinator" of Program-related activities.  The lack
of such coordination in the very early stages of regional partici-
pation in the Program bore this need out.  At this time, the Re-
gional Administrator has appointed a "Regional Director of EPA Ac-
tivities in the Northern Great Plains Resources Program."

     More than anything else, the complex semi-technical and semi-
political nature of the Program make it Imperative that a coordin-
ating function be established, and that this function allow those
with technical expertise to pursue their detailed investigations
with a minimum of distraction and yet with the knowledge that their
efforts are being Integrated with the Program and with EPA's other
activities.  The Northern Great Plains Resources Program is and has
been an extremely important activity In Region VIII, and it has
served not only to show why large scale development of energy fuels
or mineral resources can have significant detrimental impacts upon
environmental quality, but also how we can go about increasing our
confidence that such development can be controlled, planned, and
executed 1n an environmentally sound fashion.  Thus, the Regional
Director of EPA's Program Activities has an Important role to play
in transferring, both to and from the Program, a comprehensive
framework that properly assesses, prevents, and as a last resort
controls environmental damage that may result from the develop-
ment of natural resources.

     The Director's office is to be staffed with sufficient exper-
tise In the areas of energy supply and demand, earth and atmos-
pheric sciences, and environmental problems peculiar to the West,
to supplement the remaining regional functions which thoroughly
cover surface water interactions, atmospheric aspects, and EPA's
specific legislative authorities.  The Director must have demon-
strated managerial capabilities, with emphasis on a coordinating
role.  These capabilities are Important by virtue of the fact that
much of the Region VIII activities In the Program come from Indi-
viduals who are not supervised by the Director and who may be in
various divisions of the regional office.  Further, the Director
should be in a position to properly Implement those activities re-
lated to the Program that have been determined to have high prior-
ity.  This requires inter-divisional authority to coordinate and
Implement regional inputs to the Program, within the framework of
inputs described in the Accomplishment Plans, as approved.
                                  41

-------
      Certain  individuals  from the  various divisional staffs will be
essentially "assigned"  to provide  inputs to the Program.  This Accom-
plishment  Plan will  make  those assignments in general terms.  The
periods  of assignment may range from a  few days to months (the latter
during intensive investigative efforts  and large scale field work).
While the  activities of these individuals will not be closely
scrutinized by the Director,  it will be necessary for both the
individuals and  the Director  to consult frequently.

      The Director's office serves  to perform selected portions of
the  interagency  coordination  required by participation in the Northern
Great Plains  Resources  Program. The Director also serves as liaison
between  the Program and EPA personnel outside the Regional office,
such as  NERC  (National  Environmental Research Center) or the Division
of Field Investigation  personnel,  who may perform activities directly
for  the  Program, or who may be performing an activity that is closely
related  to the Program  and that requires activity or input from within
the  Region.

      The Director directly supervises,  at this point, two positions
concerned  with administrative, secretarial, and clerical support.  All
other regional support  to the Program comes from the Division-Branch-
Section, or "existing"  organization of  the office.  The Regional
Director of EPA's Activities  in the NGPRP may be assigned either to
the  Regional  Administrator's  staff or to the Director's office of the
Air  and  Water Programs  Division.   In either case, the Regional Admin-
istrator and  the Director must provide  for proper functioning of inter-
divisional  activities.  It is important, in any organizational case,
that all Program activities mesh with other regional activities since
there is a significant  amount of interface between NGPRP and other EPA
activities.   It  is also important  that  a rule-by-committee approach be
avoided.

      The Director serves  as Chairman of the regional Energy Task Force.
This  Task  Force, in  existence since late 1972, was formed by the Re-
gional Administrator to provide a  focal point for discussion and staff-
level interdisciplinary coordination for all regional activities re-
lated to coal mining, power plants, oil shale, uranium, etc.  The Task
Force developed  the  first Accomplishment Plan for the Northern Great
Plains Resources Program.

      The Director may serve at grades equivalent to GS 14/15 and may
be temporarily assigned from  other EPA  activities.  It must be
emphasized  that  the  incumbent should satisfy some very stringent
requirements  for demonstrated competence in both technical and mana-
gerial fields.   A strong  foundation in  economics, control technology,
or similar fields  is necessary.  An established and highly regarded
reputation  In EPA Headquarters  is  desirable.

     As has been  the case with  all participants In the Northern Great
Plains Resources  Program,  the Director  has been able to place less
                                   42

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emphasis than 1s desirable on both all  technical  and all  administra-
tive matters that deserve attention.   Throughout fiscal year 1974,
the areas In which we have needed more emphasis Include  the follow-
ing:
     Energy Conversion Technology         Cultural  Impacts
     Drafting                             Geohydro logy
     Technical Editing                    Geochemistry
     Legislative Review                   Agronomy
     Economics                            Meteorology
     Sociology
     There is thus a need to consider supplemental  personnel support
in these areas, placed either in the Director's office or in other
organizational entities of the Regional office.  This need is further
identified in Table RD and in subsequent tables for other work activi-
ties.
     In Table RD there are identified a total of 1.4 and 1.0 work years
of effort for fiscal years 1975 and 1976 respectively. This includes
professional, administrative and secretarial  effort.
                                   43

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                              Table RO:  Northern Great Plains Resources Program — EPA Region VIII Accomplishment Plan
                                                           Task:  Regional Coordination
Activity
1,   Coordination of EPA Regional Activities conducted
    pursuant to the NGPRP or other entitles through
    discussions with NGPRP or other personnel and
    EPA Regional Staff -- Including Inter-divisional
    direction of activities.  Siting conference or
    seminar activities and report coordination.
2   Coordination of responses to and solicitation
    of Information from or participation of the
    public and local sectors; reporting.  Managerial
    function with technical expertise required.
3.  Chairing of Regional Energy Task Force.  Task
    Force comprised of representatives from Division
    Directors' Staffs.  Work Plan revisions.
    continuing planning effort.  Managerial function
    with technical expertise required.
	Actual Activities
PY 1973
 0.13*
 0.12
                     0.15
0.03
                                                                                                                    Proposed Activities
                          FY 1975
                           0.40*
                          Zl.OOO5
                           0.15
0.02
                            0.10
0.02
    a.  Work years of effort
    o.  Contract funds

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Activity
4   Participation as primary Regional representative
    on Subject Area "6" Work Group, "National Energy
    Considerations" and other selected Work Groups
    as expertise dictates.     Report preparation,
    reviews, contract monitoring.  Technical
    expertise covering many areas required.
5.  Regional planning, administration, and
    management of multldlsclpllnary activities.
6.  Coordination of NGPRP Activities with similar
    regional activities 1n oil shale, uranium,
    geotherml, oil and gas.
7.  Investigation of methodologies necessary to
    organize multldlsclpllnary data Into
    transferable, available and useful forms.
8.  Review of technical proposals and activities
    of Project Officer on key research projects.
9.  Secretarial & Administrative Support —
    Administrative Aid and Secretary-typist.
                 TOTALS:  Regional Work Years
                          Regional Contract  Funds
   Table RD (Continued)
      :tua1 Activities
FY 197
 0.25
                     0.30
                     0.10
 0.50

 1.50
26,000
                                                                                                                   Proposed Activities
                           FY 1975
                            0.03
                            0.15
                            0.10
                                               0.05
 0.10

 0.40

 1.40
21,000
                             0.10
                             0.10
                                                       0.10
 0.10

 0.20

 1.00
10.000

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                   SPECIFIC WORK GROUP ASSIGNMENTS


     The remainder of this section is organized in concert with the
Task Matrix of the Northern Great Plains Resources Program, as pre-
sented earlier in this Plan (Figure 10).  Each "Subject Area" or
"Work Group Area" is treated separately.  Note, however, that certain
activities listed for one Subject Area include or run together with
activities listed for a second or third Subject Area.  Such is the
nature of any multidisciplinary assessments that tries to also be
interdisciplinary.  Quantitative resource allotments have not, however,
been duplicated over the areas.

     We have not divided the EPA resource allotments into the "Program
Section" divisions shown along the right side of the NGPRP Task Matrix
(Figure 14), since such subdivisions tend to be difficult to use,
inasmuch as many of the activities "cross" these divisions.  We have,
instead, utilized these-divisions ("Regional Profile," "Constraints on
Change", etc.) in the text or activity description wherever useful and
appropriate.

     The descriptions of each Work Group are based upon our knowledge
of the past and present efforts, and EPA's view of each Group's future
assignments.  We are not aware of any detailed listing of specific
assignments, nor have the detailed work plans for all Work Groups
ever been collated.  The Work Group assignments of activities, as
shown in this Plan, have been, therefore, subject to change.  Further,
the future format of the Program is not now known.  Certain Work
Groups may not be continued past June of 1974.  We should reiterate
here that it is our hope and position that the Program continue with
continued and emphasized support from all participants.

     Various activities listed have been performed in part by groups
other than EPA, and it is conceivable that the EPA resource allotments
shown herein will be transferred to other activities or between Task
Groups, and even reduced as time progresses, needs are better identi-
fied, and other agencies or entities make known their commitments.
However, since there is, at the time of writing (May, 1974), no
guarantee of what other groups will provide or assume as their future
activities, EPA has attempted to present a fairly comprehensive list-
ing of the activities it feels should be performed, and EPA has
attempted to identify sufficient of its resources to assure that
the most important jobs are done, either directly or indirectly by
EPA.
                                   46

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                     Regional Geology Work Group

                            (Work Group A)

Scope of Activities

     Work Group A has been assigned the task of preparing maps or
other representations showing such geologic and topographic features
as are felt to be important to the siting of coal  mines, power plants,
transmission lines, urban centers, transportation  routes, and second-
ary industry.  This Group has within its scope the production of
graphical representations, in much the manner considered for Environ-
mental Impact Statements, which will allow the evaluation of geology
and topography from the standpoints of stability,  strength and geo-
logic importance.

Accomplishments

     The Regional Geology Work Group, under the direction of Mr. Dick
Keefer of the U.S. Geological Survey, has prepared a small scale geo-
logic map of the Northern Great Plains area, the area as defined by
the Program.  The Work Group has also prepared a base map of the study
area, shown in reduced size in Figure 15, for use  by other Work Groups.

     The effort, to date, has also included slope  analysis of specific
areas for purposes of planning mining and siting coal conversion facili
ties.  Criteria for delineating slopes are based upon proposed Federal
and state requirements for maximum natural slopes  and high-wall reduc-
tion.  (Montana's current Reclamation Law is included as Appendix 6.)
     The Work Group has also demonstrated the usefulness of maps show-
ing the expected change in surface topography after removal of coal.
The preliminary maps are expressed in terms of surface contours or
slope.

     The Regional Geology Work Group has brought together some ongoing
efforts of the Geological Survey directed toward a preliminary evalua-
tion of the Madison Limestone as a potential source of water for indus-
try in the Northern Great Plains.  The results are then to be analyzed
by the Water Work Group.

     The Work Group has also worked closely with the Mineral Resources
effort (Work Group B) in matters of identifying the coal deposits,
projecting overburden thicknesses, and other items of mutual concern.

Future Activities

     A great deal of basic geologic data gathering still remains to be
done in the Northern Great Plains Area.  Certain areas have not been
                                   47

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  DEPARTMENT OF THE INTERIOR

UNITED STATES GEOLOGICAL SURVEY
                                                                                                                                    -"' -TV. :K°

            l MMMtfl •-!. »•. m*M
            . 3T^     V ^^
       M. cu*. ««. • r.
        •• •*«*. un. •.» i n i  iimi •>
           '— •••"•••«•*»•••
STRIPPING COAL DEPOSITS OF THE NORTHERN GREAT PLAINS,

  MONTANA, WYOMING, NORTH DAKOTA, AND SOUTH DAKOTA

                       By

                  U. S. Geological

                       I97J
                                                                                                                                       FIGURE  15


                                                                                                                         Official   NGPRP  Study Area  Map

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topographically mapped, existing maps are out of date, and geologic
evaluations of land  uses have not been made.  Future activities
should be directed toward mapping areas of high priority, geochemical
work to ascertain chemical variations in water quality and in parent
material, and detailed structural investigations.  Aspects of sub-
surface disposal also have yet to be investigated.  Efforts will also
be directed to better describe and restore surface water drainage in
areas of strip mining.

     EPA involvement in the activity or activities related to the
Regional Geology Work Group's scope of work are projected to require
0.10 work years of effort in Fiscal Year 1975, and 0.05 work years in
Fiscal Year 1976.  While no contract or other significant support
dollars have been identified as required under this activity, monies
have been requested for other work groups for activities that closely
depend upon geologic factors.

     To date the limited contact with the Regional Geology Work Group
has been carried out by the Regional Director of EPA's Program activi-
ties.  It is in this area of earth sciences that the Program hopes to
receive more intraregional support during FY 75.  It is hoped that
renewed emphasis on earth sciences aspects of other energy fuels
assessments will make available to the NGPRP this type of support.
                                  49

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                      Table A —  Northern Great Plains Resources Program — EPA Region VIII Accomplishment Plan
                                                            Regional Geology; Subject Area "A"
Activity
 1.  Review of Hork Plan and Periodic Review of Task
    Group  Output  to  Insure that  Important parameters
    are evaluated and that the formt(s) allow
    evaluation of various development routes.
    Insure that earth sciences data are considered
    In the light  of  the probability of secondary
    growth and Industry, and alternative modes of
    power  generation and resource utilization
    (Assure  proper land use).
    Insure that geologic situations of aesthetic
    or academic Importance are adequately considered.
    Technical function with earth sciences emphasis.
 2.  Investigate topography and surface drainage to
    determine whether adequate technology or knowledge
     exists to properly mine  shallow coal and to restore
     stable,  drained  surface.  Provide liaison In areas
    ground water  evaluation.
                                                                  Actual Activities
                                                       Proposed Activities
FY 1973
 0.04
FY 1974
 0.08
FY 1975
 0.01
FY 1976
 0.01
                                                0.01
                                                       0.01

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Activity
3.  Input to evaluations of remote sensing as
    planning and enforcement tool for surface
    mining operations.
4.  Input to evaluations of trace element composition
    of coals and surrounding materials.  Establishment
    of geochemlcal patterns of soils and parent
    materials to In turn provide baseline Information.
5.  Input to assessments of Impacts on ground water
    quality and resource caused by coal development
6.  Secretarial
                    TOTALS:   Regional Work Years
                             Regional Contract Funds
                                                                  Table A (Continued)
                                                                  Actual Actlvltit
FY 1973
 0.04
1974
                     0.05
                    10,000
                     0.02
  0.15
$10.000
                                                       Proposed  Activities
                            FY 1975
                                                0.01
                             0.04
                                                0.02
                             0.01
0.10
                           FY 1976
                            0.01
                            0.01
                                                         0.01
                            0.01
                                                    0.05

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                     Mineral Resources Work Group

                            (Work Group B)

Scope of Activities

     Work Group B has been assigned the responsibility of quantifying
the energy fuels resources (coal, oil and gas, uranium, oil shale,
geothermal, and hydro) and other mineral resources (from sand and
gravel to gold) In the Program area.

     The Work Group performs a very central role 1n the Northern Great
Plains Resources Program by virtue of Its expertise In evaluating the
coal resource and siting coal-fired plants with respect to the coal
resource.  The Group 1s also concerned with land ownership, leasing
and mining laws, the chemical composition of coal and any relationships
between that composition and stratigraphy or Hthology, mining methods,
certain phases of land rehabilitation, and transportation.

     Because of Its central role, the Work Group must coordinate most
activities with, and receive Input from most of the other Work Groups,
Including Mineral Resources (A), Surface Resources (E) and National
Energy Considerations  (G).  In the early stages of the Program, we
also considered that the Mineral Resources Work Group would more care-
fully examine the technical methods of producing energy from coal as
well as from other sources of energy found within the geographical
region of the Northern Great Plains.  Such efforts are to include re-
view of coal gasification, in-sltu processes and conventional power
plants.  Questions relating to hydroelectric energy conversion will be
coordinated with the Water Work Group.

      It is necessary for those operating in this Work Group to avoid
assuming a purely mineral resources evaluation role considered typical
of most earth scientists and resource-development agencies.  Active
Involvement by EPA is directed toward assuring a more modern and
responsible role that  includes land use evaluations and assessments
of 'environmental consequences of resource development.  The EPA partici-
pation is also directed toward Insuring public participation in all
phases of the Program.

Accomplishments

     The Mineral Resources  (MR) Work Group has scoped Its efforts to
Include uranium, bentonite, and relatively minor minerals (in amount),
in addition to coal.  Much of the effort has been directed toward pro-
ducing maps and tables portraying existing and potential coal mines
and the coal-related developments, power plants and gasification plants.
In response to the three levels of coal production projected by the
National Energy Considerations (NEC) Work Group for the Northern Great
Plains, the Mineral Resources Work Group has developed three maps show-
Ing possible new mine  locations, possible coal fired power plant
                                  52

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locations, and possible coal gasification plant locations.  The number
of power plants and gasification plants was essentially projected by
the NEC Work Group, while the hypothetical siting was projected by the
MR Work Group (based on strlppable coal deposits and unit-sized plants).
The group has also compiled and presented existing data showing major
areas of strlppable coal resources 1n the Northern Great Plains.

     The Work Group has also expended considerable effort 1n Investi-
gation and review of legal constraints to mining development (Including
such Items as rail transportation costs), in documenting mineral and
surface ownership, and in discussing possible mining methods for coal
development.  EPA has assisted the Bureau of Mines in addressing surface
and underground coal mining methods.  Importantly, the Work Group has
strongly supported the need to test advanced methods of underground
mining the western coals in an environmentally sound manner.

     Activities in this Work Group have required the assistance of
qualified personnel from NERC-Cincinnati and ORD in Washington, D.C.
In particular, they have assisted with expertise in mining methods,
land reclamation, and overall maintenance of environmental quality
In the mining sector of development.

Future Activities

     There are numerous areas related to the objectives of the Program
and in need of further investigation that are within the scope of the
Mineral Resources Work Group's efforts.  Three important ones are trace
element composition of coal, pre-measurement for and planning of the
rehabilitation of disturbed areas, and Improved mining methods.  There
are also areas relating to the efficiencies and economics of trans-
porting coal as well as energy conversion methodologies.

     EPA's Involvement in activities related to the Mineral  Resources
Work Group's scope of work are estimated to be 1.0 work years through
FY 75 and .75 work years through FY 76.  Contract funds required for
FY 75 are estimated to be $105,000 in FY 75 and $60,000 in FY 76.
These funds and much of the effort are scheduled for the trace element
and rehabilitation efforts.

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Ul
                           Table B:    Northern Great Plains Resources Program — EPA Region VIII Accomplishment Plan
                                                                Mineral Resources; Subject Area "B"
Activity
 1    Review of Work Group Work  Plans; Review of work
     products  received  from Group; general management;
     •eetlngs; coordination of  Work Group activities
     with  EPA  regional  coordinators; development of
     arrays describing  Impacts  of various degrees of
     developnent;  Insuring  public participation;
     participation In Siting  Conference.
          Requires earth sciences/mining expertise
     combined  with strong managerial capability*
 2.   Review of probable environmental  Impact of
     extraction of and  use  of energy resources
     contained In  N6PRP region  Including evaluation
     of mining/extraction methods.  Coal gasification,
     coal  llqueflcatlon, shale  oil retorting* and
     other existing techniques  of fuel  to energy
     conversion must be reviewed.  Requires  mining  ft
     earth sciences expertise.
                                                                       Actual Activities
                                                                                                                    Proposed Activities
                                                                  FT 1973
                                                                   0.04
TY 1974
  0.20
                                                                                       0.10                      0.10                        0.10
                                                                                (0.05 NERC-C1ndnnat1)     (0.10 NERC-Clnclnnatl)    (0.10 NERC-C1nc1nnat1)

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       Activity
       3.   Preparation  of detailed  trace-element data
            for western  coals  and  In flyash  to be combined
            with  Identical  data for  water and  air.  All  to  be
            combined  to  provide mass balances  for selected
            trace elements  (e.g. S,  F. As, Ar, Cu,  Sb, B1,
            Hg, Mo. N1,  Pb, Be, w, Se, Ru. Cd, Sn,  La. Rh,
            Os. 6a, Ge)  (Cooperative effort  with  Work
v>          Groups C  and 0) Supplement other  contracts
            with  an appropriate research entity to  perform
            much  of this survey.  Data will  be solicited
            from  DOI.  Interagency agreements  may be In
            order.  EPA  will provide analytical assistance
            for unique elemental analyses and  will  provide
            coordination of the trace element  Investigation.
            Develop and  publish sampling and selected analytical
            techniques.  Geochemlcal  or chemical  expertise
            desired.
       Table B (Continued)
    	Actual Activities  	
    FY 1973FY  1974
     0.04                0.10
(0.04 NERC-RTP)    (0.04 NERC-RTP)
                        15.000
                                                                                                                           Proposed Activities
FY 1976
 0.05
       FT 1975
        0.10
(0.04 NERC-RTP)
$75.000 Contract for analytical    $40.000
support plus cooperative neutron
Activation analysis with US6S or
others

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Activity
4.  Preparation and demonstration of mined-land
    reclamation methods In cooperation with Work
    Group E.  It 1s proposed that this Work Group
    (B) provide Information regarding the
    mechanics of achieving suitable soil surfaces
    to meet the land reclamation requirements
    specified by Work Group E  (Surface Resources)
    and summarize the state-of-the-art.  Requires
    combination of mining methods and landscape
    expertise.
5.  Review and evaluation of and strengthening of
    legal  restraints  (leases,  permits, rules.
    regulations, law. guidelines) existing or
    desired to control minerals extraction — mining
    law expertise required.
                                                                Table B (Continued)
                                                                  Actual Activities
                                                       Proposed Activities
FY 1973
  1974
                     0.20
              (0.50 HERC-C1nc1nnat1)
       FY 1975
        0.20
(1.00 NERC-C1nc1nnat1)    (1.00 NERC-Clnclnnatl)
$30.000 add on contract            $20,000
to ongoing programs 1n
support of regionally
Important RAO
 0.02
0.02
        0.02
0.03

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 Activity
  >.  Evaluation of Impact of energy fuels development
     on other mineral resources Including those
     occurIng as trace elements and Interrelationships
     between energy fuels such as uranlferous lignite.
     Earth sciences and mineral economics expertise
     desired.
 7.  Assistance with the Identification and quantification^
     of public attitudes relating to the "development" of
     mineral resources 1n and about the NGPRP area.
 8.  Evaluation of Environmental Impacts of advanced
     longwall mining 1n cooperation with U.S.D.I.-Bureau
     of Mines.
 9   Investigation of feasibility and Impacts of 1n-s1tu
     conversion of coal to gas and liquids.
10.  Input to assessments and quantifications of the
     total efficiency with which energy fuels are
     converted and used.
   Table B (Continued)
	Actual Activities
FY 1973
                     0.03
                                                                                                                    Proposed Activities
0.03
                                               0.10                        0.10
                                       (0.30 NERC-C1nc1nnat1)    (0.30 NERC-C1nc1nnat1)
                                     ($100,000 NERC-C1ndnnat1)  ($100,000 NERC-C1nc1nnatD
                                               0.05                        0.05
                                               0.10
                           0.05

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                                                                 Table B (Continued)
 .  .                                                          	Actual Activities	                    	Proposed Activities	
 Activity                                                     FY 1973             FY 1974                    FY 1975                     FY 1978
11.  Secretarial support and technical support                 0.04                0.40                       0.20                        0.10
     (Drafting, etc.)                                         	            	                   	                    	
                TOTALS:  Regional  (NERC) Work Years            0.14  (0.04)         1.12 (0.59)                1.00 (1.44)                 0.75 (1.40)
                         Regional  (NERC) Contract Funds                           $15,000                    $105,000                    $60.000
                                                                                                   ($100,000 NERC-C1nc1nnat1)  ($100,000 NERC-Clnclnnatl)

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                           Mater Work Group

                            (Work Group C)

Scope of Activities

     Work Group C has responsibilities for evaluating all  aspects of
the impact of resource development on surface and ground water quan-
tity and quality.  EPA has the lead for the water quality aspects.

     Studies of water quality and pollution control  involve collection
and interpretation of data, determination of significant pollutants and
their effect on water uses, identification and evaluation of problem
areas, and formulation of alternative means for solving the problems.
The analyses include the sources, amount and nature of wastes, present
and expected control technology, water needs and future waste discharges
for receiving bodies.  Future water quality is being projected any com-
pared with similarly-projected use requirements to identify and problem
areas.  Consideration will be given to alternative means of meeting
quality requirements in problem areas.

     As part of the water resource work group, EPA participates in the
evaluation of environmental impacts resulting from water resource
facility construction, i.e., dams, reservoirs, pipelines, canals.  EPA
is also evaluating water quality impacts from increased population,
urbanization, and associated industrialization or changes in water use
that may occur within the study area.

     The effects of pollution on various water uses and on plans for
improving water quality in affected areas are being determined.  Water
quality goals (ambient standards and other criteria) are being estab-
lished and means to meet the demands are being closely coordinated
with other facets of the study.  This involves analyses of flows, treat-
ment, and other control measures which will be needed to meet require-
ments for municipal, industrial, agricultural, recreational, and other
water uses.  Data from other agencies has been reviewed and utilized
where appropriate to provide information on amount and nature of pol-
lutants from natural sources and to determine stream and ground water
characteristics and other major considerations reflecting the physical
effects of receiving bodies on water quality.

     The difficulty of maintaining or restoring water quality could be
Increased because of the large depletions which could be made on the
river system of the Northern Great Plains.  The flow-water quality
requirements of present and potential future instream water needs are
being determined.  These flow-water quality requirements will indicate
the minimum quantity of water needed to carry natural pollution loads
that are difficult to control and to maintain a physically and bio-
logically viable stream system.  With this information, water resources
management plans could assure that minimum stream flows would be main-
tained to meet Instream needs for quality control.
                                   59

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     Although many  pollution control  situations will be met with
existing  Information,  there is a continuing need for technological
Improvements 1n waste  treatment, alternative water uses, and land
treatment and erosion  control measures.  The Water Work Group is
serving to focus  adequate  study and evaluation on alternate means
of cooling, Including  air  cooling.  Methods and practices for the
control of adverse  water quality Impacts from strip mining-disturbed
lands  are not fully known.  The Impact of coal mining on the supply
and quality of ground  water is not known.  Effective land reclamation
measures  will be  demonstrated.

     As lead agency for  the water quality subgroup, EPA has the
primary responsibility for collecting, compiling, analyzing, and
writing report material.   Coordination and cooperation procedures
with other Federal  agencies, State agencies, and universities, local
interests and Industrial and environmental groups will be maintained
for the interchange of information, development of inputs to the study
and review and assistance  in the plan's formulation process.  Con-
tracts are being  utilized  to provide  Information and assistance 1n
those  activities  where it  is deemed appropriate.

Accomplishments

     The  Water Work Group  has been organized under the direction of
Mr. Phil  G1bbs of the  U.S. Bureau of  Reclamation.  To facilitate the
water  study* the  work  group was divided into several sub-groups.  Sub-
groups were formed  for Instream Values, Wild-Scenic Rivers, Recreation,
Ground Water, Flood Control, Operational Studies, and Water Quality.
EPA is the leader of the Water Quality Subgroup and has members on the
Ground Water and  Instream  Values Subgroups.

     The  Instream Values Subgroup has developed hypothetical minimum
flows  for the reaches  of each stream  likely to be impacted.  Develop-
ment of coal that would  result in diversions of water that would in
turn deplete streams below that flow were not to be allowed.  The
flows  served as input  into the Operational Studies Subgroup which
developed  information  on water availability in each basin.

     EPA,  as leader of the Water Quality Subgroup, attended all  meet-
Ings of the Water Work Group and the  Instream Values and Ground Water
Subgroups.  EPA established a water quality work plan, established
operating  procedures and policies for the subgroup, then staffed itself
for Implementation  of  the work plan.  The following discussion represents
the major  accomplishments of EPA as a member of the Water Work Group.

     A Regional profile report, summarizing quantity and quality of
water  in the Region, has been written and Is available through the Water
Quality Subgroup  Interim report.  Included by EPA in the report are:
(1) summaries of  existing water quality data showing present general
quality, problem  areas and major trends for the major streams In the
                                  60

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NGP; and (2) general Information on the quality of existing fisheries
1n the major streams and other biological  Information where available.

     Existing data on water quality were determined to be Inadequate.
Therefore, EPA has entered Into Interagency agreements with the various
Water Resource District offices of the USGS to supplement certain
existing water quality data collection stations and to establish others
at key locations.  Figures 16-19 show these stations along with the
existing network.

     Finding that data concerning the fate of those elements during
combustion of coal at power plants were extremely scarce, EPA has also
entered Into an agreement with the USGS in North Dakota and Wyoming to
analyze waters around representative power plants for over thirty trace
elements (Table 8).  This effort will be of a reconnaissance nature.

     Major sources of pollution needed to be identified before analysis
of future water quality could begin.  Special "white papers" have been
prepared for certain types of expected effluents which address water
quality problems of each industry and possible treatment alternatives.
Such special documents have been prepared for power plants, surface
mines, feedlots, irrigation, and municipalities.  These are published
in the Water Quality interim report.  Going one step farther for coal
conversion facilities, work has been initiated that would study water
requirements and water use alternatives in much greater detail.  A
report which (1) discusses the state-of-the-art on blowdown minimiza-
tion for wet cooling towers; (2) performs cost optimization for power
plant cooling systems; (3) gives preliminary data on water use in coal
gasification; and (4) summarizes information needs relative to water
use alternative assessment has been prepared by NERC-Corvallis and is
available in the Interim report of the Water Quality Subgroup.  An outline
of the Water Quality Subgroup interim report is given in Table 9.

     Broad assumptions concerning future effluents, probable depletions,
secondary growth impacts and other water quality factors have been
developed in preliminary form.  These and other data have been created
for use in simplistic models to project surface water quality changes
In the parameters dissolved oxygen and total dissolved solids for
various regional rates of coal mining and related development.  A
contract has been completed which reports on available methods for
predicting sediment yields in the NGP.  Computer programs for storm
simulation, hydrology modeling, sediment yield predictions, and stream
transport and deposition modeling are abstracted in this report.  The
report entitled "Available Computer Programs for the Prediction and
Evaluation of Sediment Erosion, Transportation and Deposition", recom-
mends a "best" set of models for use in the NGP.  This report will be
published in subsequent work group reports.

     Although most discussions of proposed development involve either
mine mouth conversion facilities or export mines to serve conversion
                                   61

-------
       Water Quality Stations in the Northern Great Plains Region of Montana

                                     FIGURE 16
*, v   T •   %      ' -V.-4  •*•
'  -'-.I  •*.!•-.. ;;; J •"•"' }
    USGS

 •  STATE

 •  EPA - USGS

 O  CORPS OF ENGINEERS


O
           NEW OR SUPPLEMENTED BY EPA
    '  « ' \'~! JU6ITH
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"i»* PHILLIPS
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-------
Water  Quality Stations in the Northern Great  Plains Region of North Dakota
                                      FIGURE 17
Q A V A', LX I
            I    •  e
-------
Water  Quality Stations in the Northern Great  Plains Region of South Dakota
                                       FIGURE 18
                                                      CORPS OF ENGINEERS
                                                      NEW OR SUPPLEMENTED

-------
FIGURE 19
               A   USGS
               •   STATE
               •   EPA -  USGS
               O   CORPS  OF ENGINEERS
              O NEW OR SUPPLEMENTED BY EPA
•   R^ -|*  J..
 ~  -rT/c
 ,	'—I* f

-------
                               TABLE 8
      Trace Elements Investigated in the Vicinity of Power Plants
Aluminum
Arsenic
Barium
Beryllium
Bismuth
Boron
Cadmium
Cerium
Chromium
Cobalt
Copper
Fluoride
Gallium
Iron
Lead
Lithium
Manganese
Mercury
Molybdenum
Nickel
Radium
Selenium
Strontium
Tin
Titanium
Uranium
Vanadium
Ytterbium
Zinc
Zirconium
                                    66

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                                TABLE 9

         OUTLINE OF THE WATER QUALITY SUBGROUP INTERIM REPORT

I    Water Quality Regional Profile
     A.  Water Quality Measurement in the NGP
     B.  Present Stream Quality by Basin
     C.  Important Water Quality Influences

II   Water Use Alternatives
     A.  Water Requirements for Power Plants with Wet Cooling Towers
     B.  Engineering and Economic Aspects of Wet and Dry Cooling Systems
     C.  Water Usage In the Conversion of Coal to Pipeline Quality Gas

III  Stream Flows Used for Water Quality Analysis

IV   Water Quality Impacts of Coal Development
     A.  Projections of Total Dissolved Solids Concentrations for NGP
         Coal Development
     B.  Analysis of Dissolved Oxygen Impact of Selected Locations
         within NGP
     C.  Qualitative Discussion/Water Quality Impacts
     D.  Potential Effects of Proposed Impoundments on Water Quality
         and Fisheries in the NGP
     E.  Impacts for Alternative Sites for Coal Conversion Facilities

V    Quality of Ground Water

VI   Areas Where Additional Data/Analytical Tools are Necessary
     A.  Surface Water Quality and Hydrologic Network
     B.  Non-Point Source Pollution In NGP
     C.  Identification and Quantification of Source Terms for Water
         Quality Predictions Related to Coal Development
     D.  Water Use Requirements and Alternatives for Coal Development
     E.  Development of Modelling Tools for Surface Water Quality
         Projections
     F.  Development of Verified Instream Needs for All Streams
     G.  Assessment of Shallow and Deep Ground Water Resources and
         the Impact of Coal "Development" on these Resources
     H.  Alternative Siting of Coal Conversion Facilities Near Large
         Water Bodies
     I.  Leading Potential of Spoil and Spoils Material Near Coal
     J.  Analysis of Impacts of Trans-Basin Diversions
     K.  Identification of Correlations between Trace Element Content
         of Surface and Near Surface Waters, Parent Material Soils and
         Sediment
     L.  Effects of Impoundments on Free Flowing Streams In NGP

VII  Appendices
     A.  Water Quality Criteria for TDS
     B.  Supplementary Material for Section I-C
                                 67

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                    TABLE 9 (Continued)

C.  The Determination, Assessment, and Design of "Instream Value"
    Studies 1n the NGP Region
D.  Questions Concerning Indian Water Rights
E.  A Discussion of Reservoir Limnology with Special Reference to
    Proposed Reservoirs 1n the NGP
                            68

-------
facilities at load centers or synthetic natural gas plants, a third
type of development seems likely.  Given the general arid climate and
water shortage of the area, environmental and economic problems
associated with massive water diversions may dictate that conversion
facilities locate nearer water.  Therefore, an agreement has been
reached between EPA and a group of electric generating companies to
evaluate physical Impacts of once-through cooling facilities for power
plants located on the Missouri River.  The necessity to cover all
alternatives requires the Investigation of moving coal to water as
well as water to coal.

     Where development does occur at the coal mine and water 1s conveyed
to such development, the possibility of reducing in-stream flows to
critical levels 1s possible.  However, data on minimum flows to main-
tain and Improve aquatic ecosystems are lacking.  Therefore, EPA has
entered Into a contract with the University of Montana to define and
evaluate 1n-stream needs assessment methodologies with regard to their
appropriateness In the Northern Great Plains and to develop a methodology
that can be used to predict the effects of lowered regulated stream flow
on the aquatic ecosystem.  This effort will conclude In 1974 and will be
followed by a two-year field effort which will Involve collecting bio-
logical data to evaluate and assess the chosen methodology(1es).  A
preliminary report from the first stage of this effort has been pre-
pared and 1s Included In the Interim Water Quality Subgroup report.

     A second Issue relative to depletions 1s water rights.  The water
group as a whole has addressed the question 1n Us report on Constraints
to Water Resource Development.  That report discusses all constraints to
water use In the NGP such as legal, Institutional, economic, environ-
mental, aesthetic, and technical.  Copies will be in the NGPRP report
repositories.  In addition, EPA has written a critique of the Winters
Doctrine which shows how the question of Indian water rights 1s critical
to coal development In the area.  This document 1s In the Interim Water
Quality Subgroup report.

     To provide water for continued depletions, additional storage
capacity will eventually be required.  On most streams, reservoirs
can be expected If significant water 1s to be diverted from that stream.
Therefore, EPA has Investigated the effects on water quality of Impound-
ments on free flowing streams.  A paper has been written on the expected
Impacts of such a reservoir emphasizing reservoir limnology.  While
preliminary estimates of water availability Indicate no new reservoirs
may be needed for some time, actual developments seem to point toward
some new reservoirs In the near future.  Work 1s continuing In this
effort.

     Surface water Is not the only water potentially affected by coal
development.  EPA has participated 1n the formation of an active Ground
Water Subgroup and has contributed substantial funding to the effort.
The Montana Division USGS Is heading this Investigation, which Is
designed to assess the potential physical and chemical Impacts of
                                   69

-------
strip mining on ground water at the Col strip and Decker-Blrney areas In
Montana; at the Gillette area of tyyomlng; and at the Gascoyne area of
North Dakota.  The group, with EPA participation, has summarized
existing ground water Investigations and has provided a preliminary
discussion of Important Issues relating to ground water.  A ground
water monitoring network 1s being established to provide needed data
In the aforementioned geographical areas.

     EPA has, through the Water Quality Subgroup, participated with
other work groups on joint projects.  As mentioned above, the fate of
the trace elements 1n coal during combustion 1s not known.  Therefore,
EPA has Initiated an effort to conduct chemical mass balance of selected
trace elements around existing power plants.  The work Is a joint effort
of the Atmospheric Aspects Work Group and the Water Quality Subgroup.

Future Activities

     Although much has been done, much remains still to be done.
Table  C  shows the areas where significant efforts must be expanded In
FY 75.  Emphasis must be placed on continued data collection In areas
which have not been adequately addressed to date.  Data needs Include,
but are not limited to, areas concerning:  non-point source pollution;
aquatic ecosystem habitats and needs; trace element concentrations,
and ecological effects, and a better description of the hydrologlc
regime, water use and quality of rivers 1n the region.  A more complete
data base will enable use and development of more reliable tools for
evaluating Impacts on water quality.  Analytical tools are being used,
developed and evaluated 1n efforts  4, 5,  6,  7, 8 and 9  listed 1n
the following chart.  There will be continued emphasis of potential
water quality Impacts during the remainder of FY 1974 for the Interim
report of the NGPRP.  EPA can be expected to continue to lead the
efforts aimed at evaluating water quality effects, and can also be
expected to exert more Influence 1n the overall management of the
Water Work Group In FY 75.

     EPA Involvement 1n FY 75 will remain broad.  Agency experts 1n
the National Thermal Pollution Research Program 1n CorvalHs, and the
National Ecological Research Laboratory In CorvalHs will continue to
be utilized.  Academic personnel from the University of Montana and
other qualified universities will continue to participate.  In addi-
tion, state government representatives, representatives of the environ-
mental community, and representatives of Industry are expected to be
active participants and to greatly add to the program.  Such close
cooperation and coordination of diversified Interests and talents Is
one objective of the NGPRP.

     In addition, methods of  Insuring  adequate planning and management
of future water quality*  In areas likely to receive coal development
will be explored.  Section 208 of Public Law 92-500 allows the Governor
                                   70

-------
of any state to designate areas which have (or may have) substantial water
quality control problems.  This designation Includes boundaries and a
single representative organization capable of developing effective area-
wide waste treatment management plans for the area.

     Complete Federal funding Is available through FY 75 for the costs of
developing and operating a continuous area-wide waste treatment management
process.  The plan can Include Identification of needed treatment works,
a process to Identify mine related sources of pollution, agricultural and
sllvlcultural related pollution sources, and construction activity related
sources, and to set forth procedures and methods to control  such sources
as well as other needed Items.  In short a funded Institutional mechanism
for taking the data and analytical methodologies developed by the water
work group can be established and that Institution can then  plan and manage
all point and nonpolnt water pollution sources to Insure adequate water
quality 1s maintained.  Efforts to establish such a planning and management
tool will be Initiated.

     The allocation of resources for this area 1s 3.6 work years for FY 75
(plus 2.5 work years for NERL-Corvallis), and 1.5 work years for FY 76 (plus
2.5 work years for NERL-CorvalUs).   Contract support of $240,000 (plus
$350,000 for NERL-Corvallis) In FY 75 and $180,000 (plus $350,000 for
NERL-CorvalUs) In FY 76 Is also required.
                                  71

-------
ro
                             Table C:  Northern Great Plains Resources Program — EPA Region VIII Accomplishment Plan
                                                                 Water:  Subject Area UC"
Activity
 1.  Hater Quality  Subgroup Leader
    a.   Participate as  team member In  studying
    the water-related effects  of energy resource
    development,  Including planning and coordinating
    total  effort.
    b.   Act as leader In team effort to assess  water
    quality Impacts of energy resource material.
     Including planning, coordinating,  and
     Implementing study efforts.
     c.   Attend meetings of the Program, of water
     group, of water quality subgroup, etc., prepare
     reports, give briefings.
                                                                  	Actual Activities
                                                                  FY 1973
                                                                    0.30
                                                                                                                    Proposed Activities
FY1976
 0.20

-------
Activity
2.  Mater Quality Data
    a.  Improve* supplement, and expand existing
    ambient water quality data In N6P area.
    D.  Establish proved Inventory of existing
    discharges, locations, waste loads, and permit
    conditions.
    c.  Compile Inventory of major non-point source
    water pollution problem In NBP
3   Determine water use requirements and alternatives
    In coal conversion (conventional steam electric
    generating plants and coal gasification plants)
    Including:
    a.  Identification and quantification of all
    water uses 1n coal conversion.
    b.  Identification of the costs of alternative
    technologies that minimize water use requirements.
   Table C  (Continued)
     Actual  Activities
FT 1973
                    0.50
              (0.30 HERC-Corval11s)
                   $8.000
                                                                                                                   Proposed Activities
       FY 1975                     FY 1976
        0.35                        0.10
$60,000 for Interagency   $60.000 for Interagency
agreement with US6S         agreement with USGS
needed to keep water        needed to keep water
quality network active      quality network active
        0.10
(2.50 NERC-Corva111s)
($326,000-NERC-
 Corvallls)
Entire project to be
coordinated by NERC-
CorvalHs
          0.05
(2.50 HERC-Corval11s)
($95,000 NERC-CorvalUs)
Entire project to be
coordinated by NERC-
Corvallls

-------
Activity
     c.   Identification of the availability,
     maintainability,  and reliability of alternate
     water use technologies.
     a.   Development of comparison or evaluation
     methodologies which result In optimum water
     use schemes In coal conversion by cost by
     water conservation, by reliability, etc,
     e.   Define effluent requirements (BPT, BAT,
     KSPS) for coal conversion facilities
     (Region VIII).
 4.   Project Surface Mater Quality
     a.   Evaluate, choose and modify appropriate
     model for analysis. Including data required
     and Its availability.
         1.  Design, Implement data collection network
         2.  Perform stream surveys for quantitative,
             qualitative Indication of quality for
             modeling data.
                                                                 Table C (Continued)
                                                                  Actual Activities
FT 1973
TY  1974
                     0.25
                    $2.500
                                                       Proposed  Activities
FV 1975
FY1976
                             0.75                        0.25
                     $25,000  for consultant    $15,000 for consultant
                     and field work            and field work

-------
•Nl
cn
Activity
    b.  Project surface water quality via application
    of models.  Include sediment yield modeling.
    c.  Develop modeling manual summarizing modeling
    techniques, Input requirements, assumptions,
    sensitivity, and general usefulness as predictive
    total.
5.  Instream Needs Requirement
    a   Complete methodology development that will
    show how to assess Instream needs for the
    maintenance and Improvement of aquatic ecosystems.
    b.  Field evaluation, assessment, testing, and
    preliminary Implementation of Instream needs
    methodology.  A two-year field verification 1s
    required.
                                                                       Table C (Continued)
                                                                    	Actual Activities
                                                                    FY 1973FY  1974
 0.50
$45,641
                                                                                                                    Proposed Activities
                           FT 1975
                                   FY19T6
        0.20
$20,000 for continuation
of field verification
                                                                                                                                               0.10

-------
ert
Activity
6.  Ground Water Impact Evaluation
    a.  Continued monitoring of quantity and quality
    Impacts on ground water of coal development at
    selected sites 1n three states.
    b.  Investigate physical and chemical effects on
    ground water at additional, likely to be developed.
    sites.
        1,  Area of glacial significance In North Dakota
        2   Lignite-fields In Montana (gasification
            potential)
    c.  Investigate quality* effects of development, of
    Intermediate aquifers.
    d.  Investigate quality, availability, costs,
    effects of utilizing  deep  (Madison) aquifer
    ground water
                                                                       Table C  (Continued)
                                                                        Actual  Activities
                                                                   FY T973
TY1974
 0.25
$25.415
                                                                                                                    Proposed Activities
        FY 1975
         0.20
 $70,000 for Interagency
 agreement with USGS for
Xs1te specific studies
FY 1976
                                                                                                                                              0.15

-------
Activity
7.  Chemical Mass Balance
    a.  Continue working with air work group for
    detailed mass balance development at selected
    power plants of significant trace elements.  Power
    plants chosen to be representative of typical coal
    and air pollution coated devices.
    o.  Initiate new chemical mass balance in
    conjunction with field ecological survey.
8.  Field Evaluation of Effects of Once Through Cooling
    a.  Develop a detailed study of physical and
    biological effects associated with once through
    cooling* Including water conservation.   This study
    should be a model of a study sufficient to show
    feasibility, (or lack of feasibility) under
    Section 316(a) PL 92-500.
    b   Begin a coordinated Implementation of the study
    1n conjunction with Interested utilities.
                                                                 Table C (Continued)
                                                                  Actual Actlvlties
FT 1973
                     0.05
                                                      Proposed Activities
       TTT97T
        0.10
Continued work on existing
contract
FV 1S76
 0.05
        0.20
$5,000 to set up study
 0.10
                                       $50.000 to Implement
                                       study via contract
                          $70,000 for continued
                          Implementation of study

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Activity
 9   Evaluation of Water Related Impacts
     a.  Review EIS's of proposal development
     b   Study effects associated with water
     resource development, such as dams, canals,
     pipelines, etc.
     c.  Analyze Impacts of transbasin diversions.
     o.  Evaluate secondary growth Impacts on
     water quality.
10.  Biological Data Requirements
     a.  Assist states in collecting, analyzing biological
     data needed to evaluate impact from proposed
     development.
     b.  Collect specific biological information
     necessary to support other work group activities.
ll.  Secretarial  support
               TOTALS:  Regional  (NERC) Work Years
                        Regional  (NERC) Contract  Funds
   Table C  (Continued)
	Actual  Activities
FY 1973
  0.30
                      0.20
                      1.00
 3.85 (0.30)
$134.241
                                                                                                                    Proposed Activities
                            0.15
                    $40,000 for contract
                    assistance to states
                            1.00
                                                      FY rers
                                                        0.02
                             0.08
                   $40,000 for contract
                   assistance to states
                             0.40
 3.60 (2.50)
$240.000 ($326,000)
 1.50(2.50)
$180,000 ($95.000)

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                    Atmospheric Aspects Work Group

                            (Work Group D)
Scope of Activities

     This work group coordinates the various research efforts proposed
or underway 1n the stucty area which relate to the atmospheric impact of
resource development.  Areas of work include coal conversion technology,
emissions control technology, ambient air quality monitoring, meteor-
ological data acquisition, air quality diffusion modeling, visibility
determination methodology and trace element studies.   Data in these
areas are needed 1n order to evaluate alternative strategies for resource
development.  The data accumulated to date plus the proposed on-going
activities regarding data acquisition will be discussed in the June 1974
interim report.  A final report will be issued in October of 1975.  Con-
tact has been made with governmental agencies, universities, environmental
groups, and pertinent industries to inform them of the objectives of the
NGPRP, more specifically the Atmospheric Aspects Work Group, and to re-
quest their cooperation and participation.  Atmospheric Aspects Work Group
meetings which are held periodically serve to provide a source of in-
formation as well as feedback to strategies for the assessment of the
atmospheric impact of proposed resource development.

Accomplishments

1.  Establishment of NGPRP Air Quality and Meteorology Monitoring Network

     The Atmospheric Aspects Work Group has created a comprehensive net-
work designed to acquire air quality and meteorological data that is
presently unavailable.  It is expected that the complete sampling network
will be operational by July 1974.  Sampling sites are illustrated in
Figure 20. Existing (pre-NGPRP) sampling stations appear in Figure 21.
Table 10 lists the instrumentation which is or will be located at each
of the air quality monitoring stations.  The high-volume membrane,
cascade impactor, and gas bubblers samplers will collect a sample every
six days.  The hi-vol sample will be analyzed for total particulate
matter, trace elements, sulfates, nitrates, and fluorides.  The mem-
brane and cascade impactor samples will be analyzed for trace elements.
The gas bubblers will measure SO? and NOX concentrations in the atmos-
phere.  Meteorological data 1n trie form of temperature soundings and
upper atmosphere wind speed and direction will be measured twice daily
every other day.  Surface wind speed and direction will be recorded con-
tinuously at 16 locations where hi-vols are operating.  S02 and NOX levels
will be continuously monitored at two locations.
     These data should serve to provide an excellent data base, when
combined with all state and industry collected data, to determine the
existing or background air quality levels.
                                   79

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                                 A*
                           MOUTH DAKOTA
AA*
           At
      MONTANA
                                                             FIGURE 20


                                                      COMBINED  NGPRP
                                                          EXISTING AIR
                                                      QUALITY AND
                                                      NETWORK
V






s>eii«M WYOMING
A
-1

Afr'iW A
•• •• ••^•' •* Bftffl|l|ftft; »

|
U
\
.lailf Cilf
A
LEGEND
A HI-Vol Sompter
A SOj , NOx Continuous Analyzers
* Gas Bubbler
« MRI Weatherstation
• Surface Weather Station
o Temperature Soundings
• Pilot Balloon OhMrtMtlon
0 Wind Tower
• Membrane Sampler
• Cascade knpoctor
• Rawmsondo)
•A
ICIIASKA
ScttUkliU
A'H
•«VJi'«





-------
00
                                                                                                   FIGURE 21
                                                                                         EXISTING  AIR QUALITY
                                                                                         AND   METEOROLOGICAL
                                                                                         NETWORK
                                                                                                  HCIUSKA
                                                                                                               lit Ik film
                                                             HI-Vol Sompltr
                                                             502, NOi Got Anolytrt
                                                           •  Surf act Wtathtr Station
                                                           •- Rowlnsendt
                                                           • POot Balloon Obttrvatlon*

-------
                 TABLE  10
NGPRP ATMOSPHERIC ASPECTS MONITORING NETWORK
^•MMHMH^HM^H^M^H^HMMMBMMHM^HMMI^WBMIMM

LOCATION
Buffalo, WY
Gillette, WY
Lusk, WY
Newcastle, WY
Belle Fourche, SO
Buffalo, SO
Lemmon, SO
Parshall, NO
Garrison, NO
Washburn, NO
McClusky, NO
Bowman, NO
Stanton, NO
Mott, NO
Medora, NO
Lame Deer, MT
Broadus, MT
Ekalaka, MT
Gl endive, MT
Lindsay, MT
Poplar, MT
Ft. Peck, MT
Colstrip, MT


HI-Vol
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

INSTRUMENTS

MRI S02-NOX S02-N02
Membrane Station Continuous Bubbler
X
X X
X
X X
X X
X X
X
X
X
X
X

XXX
X
X
X
X

X X

X
XX X


Pilot Balloor
Cascade OBS; T-Sondes;
Impact or s Wind Towers
X
X X









X
X X

V



X



X

-------
2.  Trace Elements Mass Balance Around Coal Fired Power Generation Plants

     Three sites have been selected to perform our study.  The three
plants burn different types of coal and have different pollution control
devices.  These plants were contacted during February 1974 via letter
followed by a personal visit to the parent company 1n order to explain
our research study effort.  A contract will be let by June 1, 1974,
to perform a detailed sampling program for the three plants.  Samples
of coal, bottom ash, collected fly ash and flue gas will be analyzed
for 53 trace elements.  A 11st of elements 1s presented 1n Table 11.

                              TABLE 11

                           TRACE ELEMENTS
     Aluminum                   Iron                     Rubidium
     Antimony                   Lanthanum                Ruthenium
     Arsenic                    Lead                     Silicon
     Barium                     Lithium                  Silver
     Beryllium                  Magnesium                Sodium
     Bismuth                    Manganese                Strontium
     Boron                      Mercury                  Sulfur
     Cadmiurn                    Molybdenum               Thai11 urn
     Calcium                    Nickel                   Thorium
     Cerium                     Osmium                   Tin
     Chlorine                   Palladium                Titanium
     Chromium                   Phosphorus               Uranium
     Cobalt                     Platinum                 Vanadium
     Copper                     Potassium                Ytterbium
     Fluorine                   Radium                   Yttrium
     Gallium                    Rhenium                  Zinc
     Germanium                  Rhodium                  Zirconium
     Progress during FY 74 Includes (1) a literature search per-
formed to expand EPA's knowledge regarding trace elements, (2) various
analytical techniques reviewed for adequacy 1n our study effort,
and (3) work of a similar nature performed by the TVA on the Allen
Steam Plant near Memphis was reviewed.  A complete report on the status
of our trace element effort 1s Included 1n the Work Group report to
be published In June 1974.

3.  Air Pollution Control Technology

     An overview report on the present status of air pollution control
technology for fuel conversion facilities 1s Included In the June
report.  It discusses the types of control available, such as wet
                                  83

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scrubbers, electrostatic preclpltators, and fabric filters.  Major
equipment manufacturers are Identified.  Other techniques of control
are also discussed, such as combustion modification.  Pollutants of
concern are particulates,sulfur oxides, nitrogen oxides, reduced
sulfur compounds and hydrocarbons    Sources of pollution  dis-
cussed Include power plants, coal gasification plants and coal
liquefaction plants.  Also, a special detailed report on coal gasifi-
cation will be published.

     Discussions with NERC-RTP have led to much of the accumulation
of control technology Information.  Achievements to date consist of
the accumulation and assimilation of a large bank of Information re-
garding the control processes.

4.  Interim Atmospheric Aspects Work Group Reports

     a.  Regional Profile  (Draft) Report (completed December 1973)

     b.  Constraints (Draft) Report (completed December 1973)

     t.  May 15, 1974 Interim Work Group Report to Program Management
         Team (which will  be placed 1n repositories with all NGPRP
         Work Group reports.'  Table 12 provides the table of contents
         of this Interim report.

5.  Proposed Fuel Conversion Facilities Development

     Contact was made of utilities, state planning agencies, and State
environmental officials In order to gather the most reliable data
regarding the kind of and magnitude of development of fuel conversion
facilities for the forseeable future.  Estimated or projected capacities
and locations of these facilities were obtained.  Table 13 presents
these data.  A detailed discussion of these projected plants and their
estimated atmospheric Impact 1s Included 1n this Work Group's report.

6.  Point Source Modeling

     Elevated point source air quality diffusion modeling was performed
for eight regional coal fired power generating plants.  Results of
the modeling effort are detailed 1n the Work Group report and summarized
1n the June NGPRP Interim report.  Estimated Impact from a coal gasifi-
cation plant was also calculated and 1s reported In the Work Group report,

7.  Coal Gasification Seminar

     A seminar was held 1n Denver to acquaint government officials,
Industry and the public with the coal  gasification process.   Various
processes were discussed.  The proceedings of this seminar are being
published and will be available from this office.
                                 84

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                             TABLE 12
                             OUTLINE
          ATMOSPHERIC ASPECTS WORK GROUP  INTERIM REPORT
                             May  1974

      Abstract
      Introduction
  I.   Regional  Profile Report
          Report on  baseline atmospheric  aspects of stu4y area.  Based
      on  existing data.
      1.   A1r quality (participates, S02>  NOX, trace metals)
      2.   Meteorology (climate; topography (as 1t affects pollutant
          dispersion); mixing layer heights, visibility)
      3.   Emission  Inventory of point sources emitting greater than
          100 tons/year  of S02 and parti dilates
      4.   Complete  list  of power plants and related data, e.g.,
          capacity; fuel  used; emissions;  and control devices used
 II.   NGPRP  A1r Quality/Meteorology Data Acquisition Network
      1.   Objectives  of  network
      2.   Site  locations
      3.   Equipment used
      4.   Sampling  frequencies
      5.   Data  analyses
III.   Revised Constraints Report
      1.   Clarification  of significant deterioration
      2.   Expansion of  "other environmental effects such as acid  rain,
          solar radiation, etc."
      3.   Present report Includes  legislation, regulations, standards,
          financing,  and manpower
                                  85

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                         TABLE 12 (Continued)
 IV.  Development Scenarios
      1.  Projected power plants and gasification plants
      2.  Projected NGP and State emissions
      3.  Export activity
      4.  Extractive Industry emissions
      5.  Secondary effect emissions
  V.  Diffusion Modeling
      1.  Point source models to predict short and long-term pollutant
          concentrations arising from eight proposed NGPRP study area
          power plants:  Sutherland, Nebraska; Colstrip, Montana;
          Center, Stanton, and Underwood, North Dakota; Kemnerer, Rock
          Springs and Wyodak, Wyoming.
      2.  A detailed description of the point source and regional
          diffusion models to be used In post April '74 work and how
          the new NGPRP data will be factored Into these diffusion models.
 VI.  Coal Conversion Alternatives
      1.  Process efficiencies
      2.  Process descriptions
          A.  Direct coal fired power plant
          B.  Coal gasification
          C.  Coal liquefaction
          D.  Coal cleaning
VII.  Control Technology Overview
      1.  Control equipment design parameters
      2.  Processes for wet scrubbing
      3.  Operational problems experienced to date
      4.  Potential gasification plant controls
                                    86

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                         TABLE 12 (Continued)

VIII.  Report Assessing State of the Art of Measuring Visibility
       1.  Schemes for measuring visibility will  be Investigated, e.g.,
           those Involving light scattering and extinction; photographic;
           visual.
  IX.  Trace Element Status Report
       1.  Discussion of present source sampling program
           A.  Type Coal, trace elements concerned with analytical methodologies
       2.  Presentation of literature search data
           A.  Analytical techniques
           B.  Trace element effects
           C.  Coal concentrations of trace elements
           0.  Previous mass balance efforts - TVA
           E.  Expected gasification trace element emissions
   X.  Future Activities
       1.  FY '75 and FY '76 activities of Atmospheric Aspects Work Group
       2.  Long term research needs.
                                     87

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00
00
              Montana
              Nebraska
              North Dakota
              South Dakota
              Wyoming
                                                     TABLE 13
                                                          •
                                               NGP Power Plant Summary
                                      Installed Generating Capacity,  Megawatts
Existing u'
345
1,534
862
252
1,205
Proposed v '
2,060
650
7,112
100
2.690
Total
2,405
2,184
7,974
352
3,895
                         TOTAL
4,198
12,612
16,810
              (1)  In operation as of January 1, 1974 - Statewide
              (2)  Proposed construction through about 1984 - NGP study area

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Future Activities

    The Work Group activities are expected to require 4.0 work years
1n FY 75 followed by 2.75 work years 1n FY 76.  Contracts 1n the
amount of $580,000 In FY 75 and $126,000 In FY 76 are required.  Upon
completion of the final report In October of 1975, EPA will  phase out
of the NGPRP activities.  It 1s hoped that the States will continue
with some of the programs.  Some of the activities, however, will
continue to be supported by EPA under the auspldes of Its energy-
related program plans.  Future activities are discussed below:

    1.  The Work Group will continue in FY 75 to take the lead In
coordinating all air-related activities in the study area.

    2.  We will continue the collection and analyses of the samples
obtained from the NGP ambient air monitoring network through FY 76.

    3.  We will continue the collection and reduction of meteorological
data obtained at all meteorological stations through FY 76.

    4.  We will continue to compile data and Information that will
be used in writing the NGPRP final report and the special reports
that this Work Group has Identified as being appropriate.  These
special reports will discuss Items such as control technology, coal
gasification, trace element mass balances, and effects upon visibility.

    5.  The disturbance of land as a result of mining and related
activities will cause an Increase In the emissions of fugitive dust.
In order to assess Impact of these emissions on air quality, a study
on a specific area will be designed.  The background level should
be assessed in an area prior to the start of a mining operation.

    An air monitoring network will be designed using hi-volume
samples to assess particulate concentrations in the Immediate vicinity
of a mining operation and at several sites at varying distances from
the operation.

    6.  The Work Group will expand upon Its trace element sampling
program which was funded in FY 74.  An Intensive study will  be planned
to source sample a coal fired power plant In FY 75.  Guidance from the
FY 74 trace element sampling program will be utilized in order to nar-
row down the 11st of elements to be studied.  An attendant intensive
ambient monitoring program will be provided at the same time as the
source sampling effort.  This dual sampling effort should provide data
with which to assess the adequacy of present diffusion models to
predict trace element concentrations.
                                  89

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    7.  There is a need to identify the type and quantity of trace
element emissions from coal gasification plants so that we may pre-
dict the atmospheric loadings and effects resulting from these plants.
Bench scale and pilot plant studies are being performed on a couple
processes in this country, but there is no work published on com-
mercial plants, since the U. S. does not have any commercial sized
plants.  There is a need to study the European and/or African gasifi-
cation plants.  Research funds may be funneled through AGA or other
avenues to perform source sampling programs on those plants.  The
NERC-RTP via CSL may be the vehicle for promoting these studies be-
cause of their substantial budget.  However, Region VIII should have
input to this activity in the form of suggestions to the type of
work performed.

    Also, a literature survey of the type of data available regarding
these gasification plants will be performed.

    8.  A concern exists over the concentrations of trace elements
in the respirable size range of participate matter.  The program
carried out with FY 74 funds through Region VIII was not able to
identify or characterize these data.  An intensive sampling program
will be performed on a single coal-fired plant to provide insight
to this concern.  This work may.be performed in conjunction with item
#6.  This type of work would complement the work that has been per-
formed by the NERC-RTP upon an Eastern coal fired power plant.

    The AEC (Livermore Lab) is interested in participating in this type
of program.  It is conceivable that an interagency agreement could be
entered into in order to conduct an extensive program.

    9.  A coordinated study will be conducted in the vicinity of a
major coal fired power generating plant to assess the impact of emis-
sions.  The study Mill include an air quality monitoring network, a
mass chemical analyses, and an evaluation of the concentrations in
soils, plants and animals.  This work may be performed in conjunction
with item #'s 6 and 8.

    The air quality monitoring network will sample the particulate and
certain gaseous concentrations.  Gases considered will include the
criteria pollutants and other gases of general concern.  The filters
used to collect particulates will also be used to assess certain trace
elements.

    The concentration of trace elements In the soil, plants and animals
will be correlated with the emissions coming from the plants.  It is
recommended that a cooperative arrangement be made with the State Game
Commission for the animal studies.  The study dealing with soils and
plants could be coordinated with EPA research laboratories.  Special
                                  90

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attention will be given to the effect of sulfur oxide emissions on
young plants, especially on land areas In the process of being reclaimed.

    10.  Little or no firm knowledge exists regarding the quantity
of criteria pollutant emissions from gasification plants.  Also,
of significant Interest are the magnitude and type of reduced sulfur
compound emissions from these plants.  The NERC-RTP Is working on
the development of emissions estimates and NSPS for gasification
plants at the present time.  It would be helpful for them to have
actual emissions data from the commercial plants overseas.  Region VIII
Input to this aspect of work will consist of keeping In close con-
tact with what RTP 1s doing and making suggestions on the scope of
work being followed.

    Adequacy and extent of control technology is unknown for the
present viable gasification processes.  Region VIII will perform a
literature search after consulting with RTP 1n an attempt to provide
data on this topic.

    11.  The Work Group will expand upon Us present diffusion model-
Ing efforts.  The availability of a model to predict regional air
quality and long distance transport of pollutants is desirable.  A
case by case investigation of single emission sources will overlook
the cumulative and Interactive impacts of many sources within a region.
Consequently, we will adapt an existing regional transport and dif-
fusion model for use in the Northern Great Plains Region.  This
model will:

    a.  Be capable of being understood by decision-makers without
        technical expertise.

    b.  Have been tested with some verification data available.

    i.  Use readily available air quality and meteorological data.

    d.  Provide output which can be easily compared to air quality
        standards.

    An additional longer term need is for the development of new,
more refined regional air quality models which remove some of the
simplifying assumptions of existing models.  Some site specific veri-
fication is required.

    12.  The need for the development of methodologies to assess
visibility and other impacts of increased sub-micron participate load-
Ings upon the atmosphere is apparent.
                                 91

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    All available existing visibility data 1n the Northern Great
Plains Region will be compiled.  Airports and local observers are
two possible sources.

    Within the next year, an attempt at formulating a visibility
assessment methodology will be made.  Furthermore, the methodology
will be tested at least at one site in the Northern Great Plains, for
example Col strip or Gillette.  Data collection should occur before
and after large power plants begin operation to assess the effects
that increased particulate emissions have on visibility.  Sampling
ambient air for particulate particle size will accompany in-field
visibility assessment.                           "

    13.  The large-scale development of fuel conversion facilities
in Region VIII will result in a significant Increase of emissions.  Sub-
stantial HC and NOX emissions will occur.  This situation plus the
high frequency of sunlight in the NGP provides the excellent potential
for photochemical oxldant formation.  Also, 1t 1s suggested that
presently the hydrocarbon and possibly the oxldant air quality standards
are being exceeded in many non-urban locations.  In order to assess
the Impact of the proposed development, this Work Group will locate
some HC and oxldant air quality monitors in the region.  This effort
may be a part of the present NGP monitoring network and tied into
the present contractural arrangement.

    14.  A requirement for wide-scale fluegas desulfurizatlon (FGD)
development is not anticipated in Region VIII unless State regulations
(such as Colorado's) become more stringent than the NSPS, or if resolu-
tions to significant deterioration mandate additional control.  The
amount of material to be disposed of 1s not as critical as the nature
of the material.  Collected flyash volume would not be much greater
than the anticipated SO? or $04 sludge, but the chemical nature of
the sludge could present a potential water problem.

    Also, the capture and ultimate disposal of sludges containing
possibly significant quantities of trace elements heretofore uncol-
lected may require careful handling.

    Utilization of sludge 1s being studied by NERC-RTP and others
and should be followed and promoted.

    Most of the work in this area will be In-house requiring manpower
from Region VIII as well as RTP.  Some contractual work 1s anticipated,
possibly through expansion of ongoing work at RTP-CSL.

    15.  The quantity of emissions coming from an energy resource
development area would Indicate that health assessments should be
scheduled both before and after the facility 1s operational.
                                  92

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     A potential site would be the Crow or Northern Cheyenne Reservation
1n Montana.  A number of samplers will be Installed on the reservation
and allowed to operate for several years as development takes place.   This
will allow for documenting impacts on air quality and human health over
time as mines, power plants and gasification facilities become operational.
The Indian Health Service could cooperate with health related aspects of
study.

     A second potential study would be a CHESS type study in an intensive
development area such as Stanton.  Since development is just starting, the
study could acquire baseline information, if started immediately, and then
track related health effects, if any, as development proceeds.

     This would be a long-term study running perhaps 10 years.

     16.  The Interplay of the Northern Great Plains Resources Program
and recently promulgated federal and state regulations will be studied in
detail.  In view of recent promulgation of air regulations, Indirect  source
regulations, 10-year maintenance plans and the soon to be promulgated
significant deterioration regulations, the problem of energy resource
development compatibility with such regulations should be evaluated in a
systematic way.  This will require an assessment of air sheds in the  area,
establishing air quality zones, and redesigning, if necessary, an air
quality monitoring network to ascertain if the standards are achieved.

     The compatibility of the energy resource development scenarios from
the NGPRP to pertinent standards will be evaluated by employing point source
and regional diffusion models.  This effort could provide considerable
Information to the States in terms of siting guidance.

     17.  Effects upon health, vegetation, and visibility by $04 are  not
well understood.  It 1s theorized that some concentrations may prove  to
be harmful.  Due to the increased fuel conversion facility development in
the NGP, an increase in partlculate matter and S0£ will result.  Thus, we
have the makings for sulfate production.  Measurement of the S04 concentrations
on all hi-vol filters 1n the NGP monitoring network would provide the data
necessary to make some comments upon the trend of $04 levels in the
atmosphere.  Also, it will provide an Important function by comparing the
data to existing State standards.  A long-term study is required (at  least
10 years) in order to make meaningful conclusions.

     18.  Effects upon health, vegetation and visibility due to concentrations
of nitrates and fluorides are not well understood.  Nitrate and fluoride
emissions 1n the Northern Great Plains will undoubtedly Increase with the
addition of new power and gasification plants.  Therefore, it will be
necessary to analyze the NGPRP high-volume sampler filters for nitrate
and fluoride concentrations as well as sulfate and trace elements.  Trend
analysis Is desirable and requires long-tern sampling (at least ten years)
In order to draw valid conclusions.
                                 93

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     19.  The task group will Investigate the effect of an Increase 1n
cloud condensation nuclei upon the amount of rainfall.  Several research
studies have produced statistical support of both positive and negative
effects of anthropogenic aerosols (e.g. from power plants) on precipitation.
The difference in the conditions constituting a positive effect as
compared to a negative effect have not been conclusively determined.  Many
new power plants and gasification plants planned for the Northern Great
Plains area will produce considerable air emissions, some of which will
become cloud condensation nuclei.  The effect of the addition of significant
quantities of these nuclei on precipitation in this region will be
Investigated.

     20.  Scientific theories have been advanced which predict profound
effects upon the weather and climatological status of the earth.  It is
theorized on one hand that if C0£ levels continue to increase as a result
of combustion of fossil fuels, an increased trapping of infrared radiation
will occur.  This would result in a gradual heating effect and eventually
cause the "greenhouse" effect.  Increased C02 levels have been noted at
the Nauna Loa observatory in Hawaii.  On the other hand, it has been
suggested that if the atmosphere is subjected to Increased participate
loadings, the amount of solar radiation reaching the ground will be
reduced.  This would result in an "ice age" effect.

     A long-term monitoring program would be necessary in order to make
sound judgments on these two theories.  At least 15 years of data would
be needed to make any meaningful conclusions.  C0£ measurements should
be made as a part of the NGP monitoring network in order to provide one
or two data points for this trend analyses.
     21.  In order to verify the effects of increased atmospheric
loadings upon the pH of rainfall, extensive rain data and analyses would
need to be performed.  The key factors determining the pH of rain should
first be identified.  The chemistry should be discussed.  This work group
will provide substantial input to this research project.  Also, a
literature search regarding this subject especially looking at University
thesis will provide some initial data.

     Collection of rainwater along with routine analyses could be
performed in conjunction with the NGP monitoring network.

     22.  EPA was recently directed to require states to address the
question of the maintenance of air quality in the period beyond the
original attainment dates specified in the State Implementation Plans
(1975-77).  To accomplish this, the states 1n Region VIII are designating
areas which either currently exceed the standards or which have the
potential to exceed the standards by 1985.  In the coming year the state
agencies, with EPA assistance, will be doing in depth analyses of these
areas for the purpose of developing a "Maintenance Plan" for each
                                 94

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designated area.  Because most of the Region VIII states contain large
untapped sources of energy in the form of coal and oil shale, the Regional
Office has encouraged the states to designate areas containing deposits
of either as Air Quality Maintenance Areas (AQMA's).  Maintenance plans
will be developed for these areas in the coming year.

     The information already generated by the NGPRP has been extensively
used in the designation process; however, the level of sophistication
of the analysis to be conducted in the next year will be much higher.
Outputs from the NGPRP will be vital as inputs to the maintenance
planning process for plans developed either by the states or by EPA.
                                 95

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                       Table D:   Northern Great Plains Resources Program -- EPA Region VIII Accomplishment Plan
                                                     Atmospheric Aspects:  Subject Area "D"
Activity
1.  Continue Atnosphtrlc Aspects Lead:
    Participate 1n overall air related activities and
    plan and Monitor Work Group development. (Reg)
    a.  Attend Meting* of Program Management Team
    and Work Group Leaders.  Plan and attend
    atmospheric Aspects Work Group meetings..
    b   Meet with State and local government groups
    to explain atmospheric aspects portion of NGPRP
    and solicit their cooperation and support.
    c.  Meet with Industrial groups to explain
    work group activities and solicit cooperation
    and support.
     J.  Invite participation of environmental groups
    with expertise Ifl this area.
    e.  Examine related ongoing and proposed government,
    Industrial, and/or university regional atmospheric
                                                                  Actual Activities
                                                       Proposed Activities
FT 1973
 0.15
TY  197*
 1.50

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Activity
1   e.  (Continued)
    studies and try to Incorporate within framework
    of NGPRP.  Help coordinate efforts of research on
    atmospheric aspects of resource development.
    f   Coordinate activities with other work groups.
2.  Acquire and analyze air quality data from NGPRP
    sampling network. (Reg.)
    a.  Collect data from high volume samplers;
    membrane samplers; particle size samplers; S(>2 and
    NOX samplers.
    b.  Data reduction and analyses.  Results submitted
    to Regional Office at monthly Intervals.
        1.  TSP mass concentrations.
        2.  Trace element concentrations from the high
            volume and cascade Impactor samplers.
        3   S02, NOX concentrations.
        4   TSP particle size ranges.
        5,   Sulfate, Nitrate, Fluoride concentrations
            from high volume samples.
 Table D (Continued)
  Actual  Activities 	
1973FY 1974
                  0.30
                 $195.000
                                                                                                                    Proposed Activities
                                            ri  1975
                                                                        FY 1976
        0.25
       $50,000
data collection between
June 1974 and July 1975
data analyses between
July 1974 and August 1975
        0.05
       $20,000
continued data
collection at
selected stations

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Activity
2.      6.  Statistics, means, standard deviations, etc.
    c.  Monitor progress of contracts.
    0.  Contract funds to  
-------
Activity
3   c.  Monitor progress of contracts.
     i.  Contract funds to Insure completion of data
        collection.
4.  Allowance for selected sampling stations to continue
    operation for more than one year.  Continuation of
    •onltorlng effort at Colstrip past November 1974.
    States or EPA id 11 operate stations.  (Reg.)
5.  Acquire visibility Information for study area. (Reg.)
    a.  Develop procedure for field work.
    b.  Conplle existing available visibility data.
    e.g. from airports.
    c   Assess visibility for various meteorological
    situations using In-field methodology at a
    selected site In the NGP study area.
6.  Perform a trace element mass balance around a coal-
    fired power generation plant. (Reg.)
Table D (Continued)
  Actual Activities ____
                 FY 1974
1973
                 0.05
                $157.000
                                                                                                                    Proposed Activities
                                            0.10
                                           $60.000
                                             0.10
                                     $60,000 contract
                                            0.20
                                    $75.000 contract
                                                                         0.05
                                                                        $20,000

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                                                                Table  D  (Continued)
Activity
6,   a.  Identify a power plant upon which extensive
    source sampling may be performed.
    b.  Partlculate and gaseous samples will be
    obtained.
    c.  A major facet of this sampling effort will
    be to collect partlculate samples In various
    particle size ranges In order to determine 1f
    there Is any enrichment of trace elements In the
    resplrable size range.
    a.  Coordinate study with other trace element
    studies that are planned or ongoing such as
    NERC-Corvallls or the AEC.
7.  Prepare status report on air pollution control
    technology.  Keep abreast of recent developments
    1n advancement of control techniques.  (Region
    w/ffTP assistance)
                                                                  Actual Activities
                                                       Proposed Activities
FT
TYT974
                     0.20
FY 1975
FY 1976
                            0.10
                    (0.05 NERC-RTP)
                                                                 (0.05 NERC-RTP)

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Activity
7.  a.  The report should discuss  In detail the following
    pollution control devices:
        1.  Electrostatic preclpltators
        2.  Met scrubbers
        3   Fabric filters
    b.  The report should focus upon the following
    process:
        1.  Power generation plants
        2,  Coal  gasification plants
        3   Coal  liquefaction plants
        4.  Uranium enrichment plants
8.  Participate In development of  alternative strategies
    of study area.(Region)
    a.  Meet with government and private groups to determine
    planned or  anticipated development In area.
    D.  Incorporate Information from (a) In development of
    development scenarios.
   Table D (Continued)
     Actual  Activities
FY 1973FY 1974
                                                                                                                    Proposed Activities
FY 1975
FY 1976
                     0.05
 0.05
 0.10

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Activity
9.  Estimate Impact of resource development on air
    quality.   (Region)
    a.  Employ point  source and regional  diffusion
    models  to  Mice estimates on pollutant (TSP, S02,  NO*.
    trace el events) concentrations resulting  from various
                                                     of
     possible schemes for resource development.
     b.   Employ estimates from (a) to study problt
     plant sitings.
     c.   Employ estimates from (a) to study the  Issue of
     significant deterioration.
     d.   Exaarlne possible Impact on air quality  of secondary
     development related to resource development.
     e.   Correlation between ambient sampling and
     mathematical diffusion model estimates.
     f.   Estimate AQ Impacts of mining activities.
10.  Continue preparing reports on atmospheric aspects of
     NGPRP.  (Region)
                                                                Table 0 (Continued)
                                                                  Actual Activities  	
                                                              rT 19/3             FT  1S71
                                                                                   0.20
                                                                                   0.25
                                                                                                                    Proposed Activities
       rT 19/9
        0.80
       $50.000
adaption of existing regional
diffusion model for N6P
FT 19/0
 0.70
        0.35
 0.50

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       Activity
      10.  a.  InteHn reports.
               1   Regional Profile update Incorporating NGPRP
                   AQ/NET data.
               2.  Special Reports
               3   Report on stack sampling and mass  balance.
               4.  Visibility Status Report.
               5.  Modelling Status Report.
8         b.  Final Report on atmospheric aspects.
      11.  Investigation of ambient levels of  trace elements
           around coal-fired power plants.  (Region)
           a.  In conjunction with Item 16 an  extensive ambient
           sampling program shall  be performed for partlculates
           with analyses for certain trace elements.
           b.  Verification of diffusion modeling results will
           be Investigated.
           c.  Site Identification.
           a.  Contract Administration.
           e.  Evaluation of results.
   Table D (Continued)
	Actual Activities 	
FY 1973FY 1974
                                                                                                                         Proposed Activities
FT 1975
FYT376
                                               0.05
                                       $25.000 contract

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                                                                 Table D (Continued)
 Activity
12.  Identification of trace element and "criteria"
     pollutant emissions fro* coal gasification plants.
     (Region with RTF assistance)
     a.  A More complete set of knowledge must be
     obtained regarding coal gasification and coal
     liquefaction plants.  Because of the vast number
     of gasification plants predicted to be constructed
     In the MGP In the extensive development scenario
     (42). the EPA Must obtain better Missions data.
     All that we have available now Is pilot plant
     studies or bench scale data.
     b.  The type *nd adequacy of control equipment
     on coal gasification plants should be Identified
     and discussed.
     c.  A Region VIII contractual effort or expansion
     of the work contemplated by the NERC-RTP via CSL
     must be Mounted during FY-75.  This may Include
     funding work to be done on the European plants,
     such as the Lurgl plant at Mestfleld. Scotland.
                                                                   Actual Activities
                                                       Proposed  Activities
FT 1973
FY 1974
      FY 1976
       0.10
(1 NERC-RTP)

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 Activity
13.  Determine the photochemical oxldant formation
     potential 1n the N6P.  (Region)
     a.  In conjunction with Item 112, a determination of
     the likelihood of photochemical oxldant formation
     should be made.  This may mean an effort directed
     toward modeling.
     b.  The added Impact of a power plant 1n the vicinity
     of a coal gasification plant, 1n light of the
     significant HC and NOX emissions from gasification
     should be assessed.
     c.  A background HC and oxldent sampling network
     should be established and maintained.
14.  Improved disposal methods or expanded utilization
     of solid waste from fuel  conversion facilities should
     be Studied.   (Region with RTP assistance)
                                                                 Table D (Continued)
                                                                   Actual Activities
FY 1973
FY 1974
                                                       Proposed Activities
                                               FT 1975
                                               0.10
                                              $40,000
                                               0.05
                                              $10.000
                                                       FY 1976
                                                       0.10
                                                       0.05

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       Activity
      14.  a   The amounts and chemical nature of solid waste
           from power plants, especially those with flue gas
           desulfurlzatlon, should be Identified.
           b   The effects of disposal and/or utilization
           should be looked at.
      15.  Determine the long tern trends of effects of Increased
           atmospheric loadings of C0£ and partlculate.  (Region
o         w/RTP assistance)
           a.  Establish two COg monitoring stations In the NSP.
           b.  In conjunction with Item 12. monitor Increased
           partlculate loadings.
      16.  Determine potential of acid rain.  (Region with RTP
           assistance)
           a.  Search literature for chemistry of add rain
           formation.  Identify main constituents of add formation.
           b.  Conduct measurements of rain In the NGP.  These
           measurements should be made for a few stations with the
           thought In mind of continuing over a long term, say
           30 years, In order to get a trend analyses.
  Table D  (Continued)
	Actual Activities
FY 1973FY  1974
                                                                                                                           Proposed Activities
FY 1975
IT 1976
                                               0.05
                                          (0.05 NERC-RTP)
                                              $5.000
                                               0.05
                                              $5,000
                            0.05
                     (0.05 NERC-RTP)
                           $3.000
                            0.05
                           $5.000

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                                                                  Table D (Continued)
 Activity
17.  Determine environmental effect of right-of-way
     grants.  (Region)
     a.  Identify any harmful effects (primary and
     secondary) resulting from land cleaning and
     associated activities for transmission line,
     pipeline* or water ways routes.
     b.  Monitor ambient air quality as deemed necessary.
18.  Determination of health effects In areas of energy
     conversion facilities development.  (NERC-RTP
     coordinate; Region assist)
     a.  A study of the "before and after" health of
     Individuals In the development areas should be
     conducted.   A program similar to CHESS Is
     desirable.
     D.  This program, because of the nature* 1s
     necessarily long term In nature — perhaps 10
     years.   A potential site would be near Stanton,
     North Dakota.
                                                                   Actual  Activities
                                                       Proposed Activities
FY 1973
FY 1974
Ft 1975
 0.05
$2.000
                                                0.05
                                          (0.90 NERC-RTP)
                                               $3,000
                                               0.05
                                          (0.90 NERC-RTP)
                                               $3,000
FY 1976
 0.05
$10.000
                                                       0.10
                                                 (0.40 NERC-RTP)
                                                      $3.000
                                                       0.10
                                               (0.40 NERC-RTP)
                                                      $3.000

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                                                                       Table D (Continued)
       Activity
      19.  Correlation of health effects with ambient air
           quality levels in energy development areas.  (Region
           with RTP assistance)
           a   A monitoring network should be established on
           Indian lands to be separated and maintained by the
           tribe.  The Crow or Northern Cheyenne Reservations In
           Montana are likely candidates.
g         b   A health effects study similar in nature to
           Item 119 should be conducted In conjunction with the
           ambient air quality monitoring effort described 1n
           20a.
      20.  Determination of effects of energy conversion development
           upon significant deterioration and maintenance areas.
           (Region)
           a   Strategies for the designation of air quality
           maintenance areas should be developed taking Into
           consideration the energy development being planned
           1n the NGP.
                                                                         Actual Activities
                                                       Proposed  Activities
FV 1973
FY 1974
    FY 1975
     0.05
(0.10 NERC-RTP)
    $20.000
                                               0.05
                                              $5,000
     TYI97S
       0.05
(0.10 NERC-RTP)
      $15,000
                                                       0.05
                                                      $5,000

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                                                                      Table D (Continued)
8
 Activity
20.  D.  Compliance with these air quality regulations
     will require Information regarding siting of energy
     development facilities.
21.  Investigation of the Increase In anthropogenic cloud
     condensation nuclei on rainfall 1n the Northern Great
     Plains.  (Region)
22.  Secretarial Support and Drafting (Region)

             TOTAL:  Regional (NERC) Work Years
                     Regional Contract Funds
                                                                        Actual Activities
                                                                                                                     Proposed Activities
FY 1973 FY 1974


0.75
0.15 3.50
$565.000
FV 1975
0.05
$25,000
0.75
4.00 (2.10)
$580,000
FY 1976
0.05
$25.000
0.40
2.75 (1.60)
$126,000

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                     Surface Resources Work Group

                            (Work Group E)
Scope of Activities
     Work Group E has been assigned the task of quantifying the surface
resource values of the NGPRP area in terms of soils, vegetation, wildlife,
and the uses of these surface resources.  The group is also charged with
the task of identifying land (surface) ownership in cooperation with the
Minerals Work Group.  We have urged that the Work Group continue to
address the problems of restoration or rehabilitation of disturbed areas
in a comprehensive fashion.  The Work Group's work also includes the
quantification and review of the impacts of such items as transmission
lines and routes.  Based upon these objectives, we have continued to
allocate significant resources to activities within the scope of this
Work Group.

     It is necessary to insure a high degree of public participation in
the work of this Work Group and to insure that the surface resources are
reviewed from an ecosystem approach and not from just one of economy.
Agricultural evaluations must review the appropriateness of crop use or
grazing as well as the extent of and type of grazing or crop use.  The
Work Group must also provide an insight on the management of surface
resources.

     The Work Group is also faced with the difficult job of relating
effects on varied surface resources such that some sort of overall
evaluation may be composed of good and bad, desired and undesired, plus
the undefined impacts of resource development.

Accomplishments

     The Surface Resources Work Group, under the leadership of Dr. Otis
Copeland, U. S. Department of Agriculture, Forest Service, has assumed
the tasks of Inventorying the major surface resources of the Northern
Great Plains and of inventing various methods of comparing and evaluating
the impact on these numerous surface resources.  The Work Group has been
subdivided into thirteen subgroups as follows:

          1.  Land                      7.  Agriculture
          2.  Soils                     8.  Wilderness
          3.  Vegetation                9.  Scenery
          4.  Fish & Wildlife          10.  Ecosystem Relationships
          5.  Recreation               11.  Forest Products
          6.  Resource Development     12.  Surface Rehabilitation
               Potential               13.  Constraints
                                110

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     EPA 1s represented in the F1sh and Wildlife Subgroup, the
Rehabilitation Subgroup, the Recreation Subgroup, and the Ecosystem
Subgroup.

     The Work Group has prepared numerous maps which depict soil types,
vegetation types, rainfall, the habitats of various wildlife species,
and which combine certain of these data to project, for example, the
relative ease or difficulty of revegetating disturbed lands (in terms
of precipitation and soils type).

     EPA coordinated an effort to complete a bibliography of information
on rehabilitating disturbed land in the Northern Great Plains.

     The Work Group and sub-work groups have had few meetings and
therefore attendance cannot be used as a yardstick for participation.
Much effort has been done independently with verbal coordination with
the Program.  EPA has arranged to provide an aerial photographic inventory
of the strip mined areas (approximately twenty-five sites) so that all
interested parties may adequately evaluate the surface impacts of such
operations.  The initial effort, that of scanning the existing satellite
photography and lower altitude information, is being accomplished by the
EPA Division of Field Operations in Denver.  A low altitude photographic
mission is scheduled by the EPA National Environmental Research Center
in Las Vegas, Nevada, for June of 1974.  A photographic inventory is
scheduled to be published for each effort.  Future flights have been
proposed.

Future Activities

     There are very important areas in which a Surface Resources Work
Group type effort must be continued.  There is also a five-year Department
of Agriculture Project (Project SEAM) that is funding and directing
research into the Surface Environment And Mining as it relates to coal
and other resources.  Depending upon the type of Northern Great Plains
Resources Program that follows after June of 1974, EPA activities may be
coordinated to varying degrees with either program, or may be semi-
independent.

     Some of the areas in dire need of additional investigation are:
rehabilitation of disturbed lands, trace element fates in the ecosystem,
ecosystem classifications, detailed soils surveys, monitoring of effects
on surface resources, evaluation of alternative mine locations, legislative
needs for adequate control of development, and land-use planning.

     EPA activities through FY 75 and FY 76 are projected to require
1.0 and .5 man years respectively and to require, for adequate  investiga-
tions, $110,000, and $87,000 for FY 75 and FY 76.

     It is envisioned that EPA's NERC in Cincinnati will contribute at
least 1 man year of effort toward this Northern Great Plains Program as
a part of their contract direction and technical consultation related to
                                111

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coal mining In the West over the next two years.  They are negotiating
a contract with experts in the field of surface reclamation 1n order to
gain a better understanding of the possible effects on and controls for
reclamation that may prevent water pollution from the surface mining
operation.
                                 112

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                        Table E.  Northern Great Plains Resources Program -- EPA Region VIII Accomplishment Plan
                                                      Surface Resources:  Subject Area  "E"
Activity
1.  Review of Work Group Mork Plans, review of work
    products received from Group; general management;
    Meetings; coordination of Work Group Activities
    with EPA regional coordinator; preparation of
    data; Insurance of public participation;
    resources Inventory - necessitates use of
    knowledge of ecology, biology and managerial.
2.  Project Officer for demonstration grant to
    document strip-urine revegetatlon practices
    on a 100 acre plot In NGPRP area plus selected
    plots* analyses, and demonstrations on a
    •nailer scale 1n geologically, hydrologlcally,
    or cllmatologlcally different areas.  A five-
    year grant of $500,000 to cover direction,
    seeding, transplanting, etc., and documentation.
    Grading to be accomplished by other sources.
    Includes subsurface water quality monitoring.
                                                                  Actual Activities
FT is/3
  0.04
     FT 197*
       0.25
  0.02
(0.20 NERC-Clnn.)
                $100,000 grant
                                                      Proposed Activities
      FT 1975
        0.15
        0.05
(0.20 NERC-Clnn.)
 $600.000 grant
 $30,000 contract
      FT
        0.10
        0.05
(0.30 NERC-Clnn,)
 $100.000 grant
 $10,000 contract

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Activity
    FY 76-78 would Involve continued documentation only.
    Requires agricultural, forestry, earth sciences,
    and landscape technical expertise with demonstrated
    managerial capability.
3.  Compilation review, evaluation, and strengthening
    (If necessary) of legal constraints/leases, permits.
    rules, regulations, laws, guidelines existing or
    needed to protect, conserve, or restore those
    surface resources of Importance.  Requires legal
    expertise.
4.  Development and Implementation of an "ecosystem"
    approach to the surface resources work plan along
    with public Involvement In Identifying and
    evaluating such systems.  Requires an "ecologlst"
    familiar with animal and vegetative ecosystem In
    particular.
                                                                Table E (Continued)
                                                                  Actual Activities
FY 1973
FY 1974
 0.02
 0.10
  0.02
 0.05
                                                       Proposed Activities
FY 1975
FY 1976
 0.04
 0.02
 0.05
 0.02

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 Activity
5,  Design and Implementation of a surface resources
    monitoring system which may be used to monitor
    the condition of selected surface resources If
    development of coal continues.  Inventory
    disturbed areas.  May utilize remote sensing
    and. therefore, support from NERC-Las Vegas,
    and Hdqtrs.  Expertise requirements are
    variable.  Requires knowledge of measurable
    characteristics of surface resources.
6.  Provide coordination from the Surface Resources
    and ecological systems approach to the Siting
    Conference to be held 1n the region cosponsored
    by the N6PRP.   Requires managerial  capability.
  Table E (Continued)
	Actual  Activities 	
FY 1973FY 1974
                     0.10
           (0.08 NERC-Las Vegas)
          $9,000 for aerial support
                                                                                                                    Proposed Activities
        FY197S
          0.10
(0.50 NERC-Las Vegas)
  $20,000 contracts
                                                0.05
      FY 1976
       0.05
$7,000 contracts
7   Assistance with the Identification and quantifi-
    cation of public attitudes relating to the
    "development" of surface resources (Including
                     0.04
          0.08
       0.04

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Activity
     the maintenance of the status  quo)  1n and about the
     M6PRP area.   Requires managerial  capability.
8.   Analysis of the effects of airborne emissions  from
     coal-fired plants on soils, vegetation,  and animal
     systems.
9.   Experimentation and evaluation of computerized
     plotting routines that may facilitate the planning
     of mines, mine mouth power plants,  and land
     rehabilitation In cooperation with USDA Project
     SEAN.
10.   Coordination of design of detailed soils surveys
     \
     at potential development sites.  Input to EIS
     reviews and preparation thereof.
11.   Identification of correlations between trace element
     content of surface and near-surface waters, parent
     (rock) materials, soils, sediment, vegetative, and
     animal ecosystems.
   Table E (Continued)
	Actual Activities  	
FY 1973             FTT1974
                     0.10
                                                                                                                    Proposed Activities
        FY1975
          0.10
       $30.000

          0.02
$30,000 for contracts
                                                0.01
                                                0.05
  FY  1976
   0.05
$70.000

   0.01
                                     0.01
                                     0.05

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 Activity
12.  Secretarial - Clerk Typist support and other
     Technical Support.
                  TOTALS:  Regional (NERC) Work Years
                           Regional (NERC) Contract Funds
                                                                 Table E  (Continued)
                                                                  Actual Activities
I93
0.04
0.14
                     ____
                  FY 1974
                   0.05
                   0.69  (0.28)
                 $9.000
               ($50.000  grant)
                                                    Proposed Activities
  FY 1975
    0.03

    1.00 (0.70)
 $110.000
($300,000 grant)
  FY 1976
    0.10

    0.50 (0.30
  $87.000
($200.000 grant

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                Socio-Economic And Cultural Work Group

                            (Work Group F)
Scope of Activities

     Work Group F has been assigned the relatively complex task of
Identifying and quantifying many of the people-related aspects of the
Program area as these aspects may control (to the extent of prohibit-
ing) or be controlled by resources (primarily coal) and resource
development In the area.  In addition to determining present and
future public opinion regarding both the current status of develop-
ment and possible future status of development, this Work Group's
assignment 1s considered to Include quantification of that ill-
defined parameter -- growth.  The Work Group must carefully avoid
over-emphasis of conventional economic analyses which, however useful
and Important, must be viewed on a one-to-one basis with social,
scenic, aesthetic, and recreational values, all values that are
extremely difficult to quantify.

     Work Group F coordinates its activities with Work Groups C, D,
E, and G.

     EPA's Involvement is primarily in the area assisting with and
assuring that, the total potential environmental impact is evaluated
and that the techniques developed to evaluate impacts are useful to
the decision-makers and local interest groups.  In general, there is
a lack of a focal point for support of socio-economic and cultural
activities, and EAR will try to have that role filled.

     Much effort may be expended in the process of developing land-
use tools that are integrated with the true impact on people.  EPA
will be involved in the definition of the extent to which impacts
outside of the NGPRP area must be considered.  Furthermore, EPA is
making efforts to determine what are the environmental information
needs of the decision-makers and local interest groups.  The EPA
Work Group "F" representatlve(s) will continue to help factor these
needs back Into the socio-economic work plan as well as the programs
of other relevant task groups and will assist in the distribution of
output from the task groups to the local Interest groups.

     For example, the State of Montana has projected a need for con-
siderable effort, perhaps as much as $1,000,000 for up to five years
of effort 1n surveying areas felt to fall within the scope of Work
Group F.  Thus, EPA must play a major role 1n coordinating the
efforts of the Work Group with Montana and the other states in
making certain that state participation and support of the states'
involvement is achieved.
                                  118

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Accomplishments

  As the Work Group charged with the task of identifying and evaluating
possible social, economic, and cultural effects of resource development
has, with difficulty, initiated several contract studies which begin to
scratch the surface of this complex area.  Under the direction of Frank
Osterhoudt of the Economic Research Center, Department of Agriculture,
various experts and Work Group participants have been asked to Investigate
primarily "site-specific" questions.  Most of these relate to the social
and economic impact of coal development in terms of impact on existing
services or need for new services.  Thus, for geographical areas of limited
size, the Work Group will estimate the increases or changes in population,
employment, income, taxes and other revenues, and how these factors may
stress and support existing services and opportunities.   The "site-specific"
areas are (1) Rosebud and Custer Counties, Montana, (2)  Oliver and Mercer
Counties, North Dakota, (3) Sheridan and Campbell Counties, Wyoming.

     Some relatively macroscopic economic analyses will  be performed for
the five-state area in terms both of the impact of coal  mines and power
conversion plants and of "spill-over" type population impacts, e.g.,
Black Hills, South Dakota tourism and secondary industry.

     An effort 1s also planned to show the effects of coal mining and
coal utilization in the Crow and Northern Cheyenne Indian Reservations.
Another effort will be directed toward the investigation of the community
impact of the cessation or decrease in mining.

Future Activities

     There is a contlnulng'rtfeed to coordinate, and redirect if appropriate,
the various research efforts that fall under the umbrella of "Socio-
Economic, and Cultural Studies".  For example, the recently-initiated
effort of the Denver Research Institute, under Office of Coal Research
sponsorship, to predict people impacts for a large gasification/power
generation complex in the Northern Great Plains, must be coordinated with
region-wide activities throughout the coal area and should be based upon
studies that meet the planning and evaluation criteria of the Northern
Great Pla-ins States.

     The Socio-Economic Work Group also has the challenge to provide model
legislation and regulations that enable the various levels of government
to both quantify the probable impacts of regional coal development and to
control the social, economic, and cultural effects to the degree desired.

     EPA support of the Socio-economic Work Group effort is scheduled to
increase in FY 75 to .4 man years of effort and continue through FY 76 at
about .25 man years of effort.  It is envisioned that contract funds in
the amount of $100,000will be required for both years to insure this area
1s not neglected.
                                119

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                        Table F.  Northern Great Plains Resources Program — EPA Region VIII Accomplishment Plan
                                            Soclo-EcoiMMlc and Cultural Aspects:  Subject Area "F"
Activity
1.  Managerial and coordination role 1n reviewing work
    plans and work products of the Work Group.  Contact
    of public and other Interest groups who will affect
    and who will be affected by Mineral resources
    development to provide for quantification of
    opinions and their values.  Requires Managerial
    and soclo-ecoiNMric talent all Modified by an active
    envlronMMital awareness and concern.
2.  Technical assistance In developing and producing
    documents that describe the possible Impacts upon
    people nf various development alternatives.
    Including that of no development.  Also the
    development of alternatives to minimize
    detrlMental socio-economic and cultural aspects.
                     4
3.  Preparation for and participation 1n the Siting '
    Conference Insofar as Methods of evaluating socio-economic
    and cultural  aspects are concerned, and as public opinion
    and polls are concerned, social scientist.
Actual Activities 	
               FT..1974
                 0.02
                 0.02
                                                                                                                    Proposed Activities
 FT 1975
   0.10
   0.10
$100.000
 FT  1976
   0.08
   0.10
$100.000

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Activity
4.  Investigation and assessment of regulatory framework
    and reconmndatlons for Improvement.
5.  Assessment of public benefits derived from NGPRP and
    Identification of alternative futures for N6P.
6.  Secretarial Support
                 TOTALS:  Regional Work Years
                          Regional Contract Funds
                                                                 Table F (Continued)
                                                                  Actual Activities
Proposed Activities
FY 1973



0.01
0.04

FY 1974
0.02
0.02
$25.000
0.01
0.09
$25,000
FY 1975
0.10
0.05

0.05
0.40
$100,000
FY 1976
0.05


0.02
0.25
$100,000

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                    National Energy Considerations

                            (Work Group G)


Scope of Activities

     This Work Group has the primary responsibility for a critical
quantification of the national and regional energy demand and the national
and regional energy supply situation as this demand and supply situation
may exist in the future.  It 1s necessary for this Group to thoroughly
review the accuracy of energy demand projections on a local and regional
basis to document and publicize the reviews, and to give careful
consideration to ways and means to reduce the demand.  "Historical
Perspectives" of energy demand figures must not serve as the only basis
for projections of energy demand.

     Work Group G had the initial tendency to staff with technical
experts in fields such as power generation and electrical transmissions,
emission control technology, and the Hke.  This tendency must be
countered by a strong dependence upon the other Work Groups for such
technical data In order that Work Group G may concentrate on energy supply
and energy demand.  It is equally important for Work Group G to give equal
time to regional energy demands as well as national demands, and to
national energy supplies as well as regional energy supplies.  Public
participation 1s again critical to the success of the effort.

     The regional director for EPA activities 1n the NGPRP serves as a
principal participant in the activities of Work Group G in order, among
other items, to Insure the appropriate evaluation and presentation of
regional considerations and regional perspectives.  The work of this
Work Group can be the most  Important and  influential determinant of Impact
upon both the area of the NGPRP and EPA's Region VIII.  Therefore, strong
representation and participation by the regional office of EPA 1s considered
mandatory.  In view of the complex and Interrelated Issues, 1t is necessary
for the regional coordinator to call upon most every area of expertise within
the region.

     It was initially envisioned that this Work Group would provide a
lead 1n developing and Implementing an Information-disseminated system
for NGPRP data.  This activity may still  fall under their scope of work.
The Initial Accomplishment  Plan also Identified this Work Group as a NGPRP
leader 1n the organization  of the Siting  Conference.


Accomplishments

     The National Energy Considerations Work Group has concentrated its
efforts In the critical area of projecting the coal, electrical and
synthetic natural gas (SNG) requirements  for and  of the Northern  Great
                                 122

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                              TABLE 14

             NATIONAL ENERGY CONSIDERATIONS WORK GROUP

           NORTHERN GREAT PLAINS COAL SUPPLY  PREDICTIONS
Scenario


low
                            Trillion BTU
Year   Production   Consumption   Export
1985
2000
 2881
 5436
1632
3800
1249
1636
                                   %  of National
                                  Energy Requirement
2.5
2.8
Intermediate
1985
2000
 1620
 2164
                           1.4
                           1.1
high
1985
2000
 5730
14659
                           4.9
                           7.6
                            Million Tons
low
Intermediate
high
1985
2000
1985
2000
1985
2000
192 108 84
362 252 110
108
144
382
977
2.5
2.8
1.4
1.1
4.9
7.6
                                123

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                                Table 15


                NATIONAL ENERGY CONSIDERATIONS WORK GROUP

                       "HIGH SCENARIO" ASSUMPTIONS


i.  Lowest estimated national gas imports from Canada


                 deficit  (109 ft3)

    1980            1000       entire deficit to be made up by

    1985            2100       synthetic gas — k of this synthetic

    2000            4000       gas from NGP


2.  Nuclear Generating Capacity Lag

              1985        20,000 MW

              2000       240,000 MW


    NGP coal  is assumed to be used to fire stations in electric
reliability councils bordering the NGP.  All additional coal tonnage
to fire fossil stations to make up this amount of power added to export
sector.   (For the sake of clarity, Regional generating capacity was held
constant.)


3.  Oil Import Shortage

                1985             3 x 106 barrels

                2000             5 x 106 barrels


      50% of  fossil plants using oil switch to coal.  Those in geographically
neighboring electric reliability councils will use NGP coal.  All additional
coal requirements added to export sector.  (For the sake of clarity,
Regional generating capacity was held constant.)
                                   124

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Plains.  EPA has not been closely Involved with this Work Group, since
most operations have been carried out in Washington, D.C.  We have had
the opportunity to review the Nov., 1973 and May, 1974 drafts of the Work Group
report.  The majority of the Work Group effort has been carried out under
the direction of Mr. James West and Mr. Walt Dupree of the Department of
Interior.  The Regional VIII office of EPA is represented on the Work
Group, as is the Research and Development Office of EPA Headquarters.
The Region VIII office of EPA also collected data on new plants in order
to identify all existing and proposed coal development activities.

     The Work Group report and supplemental efforts have produced both
a tabulation of past energy demands made upon the Northern Great Plains
region, by Sections (Residential and Commercial, Transportation,
Industrial, Electrical Generation) and a projection of future demands
for the years 1985 and 2000.  The demands are based upon three sets of
projections as to how the Northern Great Plains coal will be used to
satisfy a projected national need.  A relatively low level of production
of energy in 2000 from Northern Great Plains coal is projected where 1.1
percent of the national energy requirements is supplied by that coal,
a higher or moderate level ("Intermediate Forecast") is assumed by 2000,
where 2.8 percent of the national energy requirements are supplied by
that coal, and a very high level (high scenario) where 7.6 percent of
the nation's energy requirements are satisfied by Northern Great Plains
coal in the year 2000.  These three demands require 144 million tons,
362 million tons, and 977 million tons by the year 2000, respectively.
The three sets are thus assumed levels of energy production, or requirements,
of the Region and serve as bases for further analysis by the six other
Work Groups.  See Tables 14 and 15.

     Major questions have arisen regarding the derivation of both the
projection of national energy requirements and the levels selected for
the Northern Great Plains.  Many such questions result from the complexity
involved in projecting public demand for energy and policies relating to
supply of that energy.  Further complicating the complex calculation is
the recent decrease in oil imports and a trend of energy conservation or
energy use reduction seldom experienced in the past.

Future Activities

     Since the projections made by the National Energy Considerations Work
Group are essential to comprehensive planning of coal and other resource
use In the Northern Great Plains, these projections should be constantly
updated.  Further, the projections should be thoroughly explained,
regionalized, and the consequences of various choices portrayed.  As one
example, the possible effects of continued shortages of crude oil, as
well as reduced usage of gasoline, should be factored in varying formats.
                                125

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     Within the scope of this Work Group's efforts are also the
deliberation over and delineation of possible mixes of energy supplies
from the varied sources of energy.  From Region VIII's viewpoint, it 1s
Important that these studies be applicable to the energy choices of the
West.  It may be most appropriate to establish the Work Group in the
regional area as opposed to Washington, D. C. such that this objective can
be achieved.

     EPA has projected a total of .5 work years for Its efforts in this
Work Group during FY 75 and .2 work years during FY 76.  No funding
requirements have been Itemized, however, we consider that EPA as a whole
will be funding related and useful efforts In this area.
                                 126

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                        Table 6:  Northern Great Plains Resources Program — EPA Region VIII Accomplishment Plan
                                                National Energy Considerations:  Subject Area "6"
Activity
1.  Identification and construction of energy supply
    projections based upon all resources found in region
    and summary of energy-supply technologies and their
    Impact.
2.  Identification and construction of energy demand
    projections for sectors, regions, and nation.
3.  Analyses of Demand-Supply system, including the
    system of reducing demand.
4.  Identification of mixes of energy fuels.
5   Secretarial Support
                 TOTALS:  Regional Work Years
                                                                  Actual Activities
FY 1973
FY 1974
                     0.25
                     0.25

                     0.25

                     0.10
                     0.25
                     1.10
                                                       Proposed Activities
FY 1975
                            0.10
                            0.10

                            0.20

                            0.05
                            0.10
                            0.50
FY 1976
                             0.10

                             0.05
                             0.05
                             0.20

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 V.  Summary

     This Accomplishment  Plan  has  been  prepared to serve as a guide
 for the  Region  VIII  offices  of the Environmental Protection Agency as
 the Northern  Great Plains Resources Program progresses.  The Program
 was precipitated  by  the Increased  activity occurring in Montana, North
 Dakota,  South Dakota,  and Wyoming  associated with the extraction and
 utilization of  "low  sulfur"  coal.   The  Program 1s designed to procure
 and develop information that can assist in either developing the coal
 resource or restricting such development, depending upon the outcome
 of comparisons  of the  desired  and  projected results of "development".

     Since mining and  burning  of some 35xl09 metric tons*5 Of strlppable
 coal from the sparsely populated area of the Northern Great Plains
 would  significantly  alter the  environment, the EPA must assure that
 those  responsibilities delegated to it, especially the responsibilities
 to prevent pollution,  to  assist the States, and to Involve the public,
 are incorporated  in  the decision-making process that is the forerunner
 of large-scale  mining. Though only 5 x 10& hectares of land are
 essentially committed  to  coal  mining in the Northern Great Plains, the
 area affected could  increase by two orders of magnitude.  Fortunately,
 a moratorium  has  been  placed on issuance of Federal Prospecting Permits.
 Few power plants  of  size  have  been established in the area, though one
 study  projects  as many as forty-two new coal-fuel steam-electric plants
 in the coal-rich  area. The  time to evaluate the proposed development
 is now.

     The Northern Great Plains Resources Program provides the framework
 within which  EPA  can discharge its responsibilities while making
 maximum  use of  other Federal,  State, and local resources.  The Program
 also gives the  framework  to  evaluate coal in light of and as it affects
 other  resources,  including the reserves of other energy fuels contained
 1n Region VIII.

     The detailed Tables, RD and A through G, of this Plan propose the
 continuation  of an Interdisciplinary effort spearheaded by the Region
 VIII office to  provide the quantitative analysis of questions and issues
 (the latter which may  be  viewed as the  more Important question) that
 arise  as decision-makers  at  all levels  of government strive to plan for
 and regulate  coal  and  associated "development" in the Northern Great
 Plains States.  Based  upon our experiences through the past year and
 those  activities  that  are outlined 1n those Tables, we have estimated
 that 12.0 work years of effort will  be  spent by the Region VIII office
 In activities directly concerned with this Northern Great Plains
 Resources Program — through FY 75.  In order that we may continue to
 fill the need for support of short-term research, monitoring, and other
 Investigations, it has been  proposed that we continue to provide
 contract funds  for the tasks described  1n the Tables 1n the amount of
 about  1.2 million  dollars.   This continued support 1s essential to
 the Program.
25.  "High" Scenario production for 35 years.
                                128

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     The continued full-time assignment of EPA personnel  to the
Program (approximately seven positions) 1s considered mandatory for
the success of EPA's activities.  As the only Program participant able
to arrange Us staff in a manner such as that described In this Plan,
EPA has developed a high degree of credibility 1n its activities over
the past year.

     The Headquarters allocation is based upon the tentative
identification of Individuals who either themselves or through their
staffs will participate in the Program effort.  These efforts will be
largely conducted without regional coordination.

     It is important to note that those familiar with similar efforts,
including EPA's efforts in Interior's 011 Shale Program,  are convinced
that the position of regional coordinator is critical to  the successful
Implementation of EPA's role in the Northern Great Plains Resources
Program, and that the ability of this coordinator to accurately weigh
the many factors extant in such a series of dilemmas is required.

     We have always recognized that the descriptions herein and
previously published regarding our activities have contained a high
degree of emphasis on what some would term the "technical" aspects of
an assessment of impacts or effects of coal "development".  But throughout
the design of the effort, it has been recognized that the data or
analytical methodologies will be useless unless Implementable and
Implemented.  During this second and likely last year of extensive
funding by EPA Into the Program as such, our activities must emphasize
the use of the data produced for viable regional planning and
regulation.  Investigative activities will have to be conducted to
answer specific questions or issues the answers to which define policy.
The Program is not to develop the policy — that is the perogative and
responsibility of the various levels of government organized by law.
However, there is obviously a very fine line between answering questions
and developing policy.

     The region must also develop upon the foundation already laid to
coordinate research into areas that relate to an assessment of the
Impacts of coal development.  If Project Independence funds become
available, the need for such coordination will Increase even more.  Such
coordination has as its theme the transfer of hypotheses and results
produced by research to the decision-makers before it 1s too late to
use the data.  This 1s particularly important in the rapidly-developing
field of energy production 1n the western United States.
                                129

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                                                                                           Table 16
la
o

Mork Croup
Subject Area
RC - Regional Coordination
A - Regional Geology
B - Hlneral Resources
C -Hater
D - Atmospheric Aspects
E - Surface Resources
F - Soclo-Econcsric and
Cultural Aspects
6 - National Energy
Consideration
TOTALS:
FISCAL VEAR 1973
(Apr - Jun)
Regie
Coordlnat
Work Years
(Actual)
0.25
0.04
0.18
(Incl. 0.04
NERC-Clnn.)
0.30
0.15
0.14
0.04
_
1.10
nal ly-
ed Effort
Salary, Support*
(Esttaated)
$ 6.250
1.000
4.500
7.500
3.750
3,500
1.000

$27.500
^ - Hflix
Mork Years
(Estlaated)
0.35
—
0.05
0.05
0.05
».
—
0.10
0.60
Hfort
lary, Support*
(Estleated)
$8,750
—
1,250
1,250
1.250
••
-
2.500
$15,000
Regional
Contract
Funds
—
—
--
—
--
--

-0-
FISCAL VEAR 1974
Regie
Coordlna
Work Years
(Actual)
1.50
0.15
1.71
(Incl. 0.59
NERC-C1MI.)
4.15
(Incl. 0.30
NERC-Corv.)
3.50
0.97
(Incl. 0.28
NERC-Clnn;
0.08
NERC-LV)
0.09
1.10
13.17
naiiy-
fd Effort
Salary, Support*
(Estlmted)
$37.500
3.750
42.750
103.750
87,500
24,250
2,250
27.500
$329.250
Hqs.
Morfc Years
(Estimated)
1.50
~
0.50
0.75
1.25
-™
0.25
1.50
5.75
Effort
Salary. Support*
(Estimated)
$ 37,500
—
12,500
18.750
31,250
"**
6.250
37.500
$143.750
Regional
Contract
Funds
(Obligated)
$ 26.000
10,000
15,000
150.000
565.000
9.000 |
1
i
25.000
$800.000
        •  Bued on $25.000 per work year.

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TABLE 17


u
Work Group
Subject Area
RC - Regional Coordlnatloi
A - Regional Geology
B - Mineral Resources
FISCAL YEAR 1975
Regional ly-
Coordl ated Effort
Work Years
Projected
1.40
0.10
2.44
(Incl.1.4
NERC-Clnn.
0.04
INERC-RTP)
NERC-Corv.)
6.10
D - Atmospheric Aspects (Incl.2.10
NERC-RTP)
E - Surfaces Resources
F - Socle-Economic and
Cultural Aspects
1.70
Incl.0.20
IERC-C1nn.
1.5 NERC-LV)
0.40
H
G - National Energy „ cn
Considerations | 0
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                            APPENDICES
APPENDIX 1


APPENDIX 2


APPENDIX 3

APPENDIX 4


APPENDIX 5

APPENDIX 6
OUTLINE OF PLAN - NORTHERN GREAT PLAINS RESOURCES
PROGRAM

REGION VIII RECOMMENDATIONS ON PUBLIC INVOLVEMENT
AND PARTICIPATION IN THE NGPRP

EPA STATUTORY AUTHORITY FOR NGPRP PARTICIPATION

NORTHERN hREAT PLAINS RESOURCES PROGRAM "LONGER
TERM STUDY AND DATA NEEDS"

SITING CONFERENCE

MONTANA STRIP MINING AND RECLAMATION ACT
                                132

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                            APPENDIX 1
                          OUTLINE OF PLAN

              NORTHERN GREAT PLAINS RESOURCE PROGRAM

                           JANUARY. 1973

      (as prepared by originators of the Interagency program)


Introduction

     "The Northern Great Plains, an area which consists of large segments
of Montana, Wyoming, North Dakota, South Dakota, and Nebraska,  has been
the focus of Increasing attention because the area 1s a potential source
for vast amounts of relatively low sulfur coal.  Interest in the develop-
ment of the Northern Great Plains coal  resources stemmed primarily from
the continuing growth of national energy consumption and Increasing
emphasis on Improved urban air quality.*  The possibility of large scale
development of the coal reserves has, at the same time, heightened regional
concern for effective land use and resource planning; Including such Issues
as environmental quality, mined area reclamation competition for scarce
water resources, development of other mineral resources, and potential
effects on the people and economies of the Northern Great Plains States.

     "The local, state and Federal governments which make land  use and
resource planning decisions affecting the area face competing economic,
social, and environmental alternatives.  The Federal government continues
to make decisions regarding leasing schedules for coal resources on
public and Indian lands, regulations for air and water quality, and
development of water projects.  Congress 1s considering several measures
related to surface mining.  The States also are concerned with  resource
development; many have considered or taken legislative action related to
surface mining and have prepared State Implementation Plans for air
quality under the Clean A1r Act.  Local governments promulgate  zoning
and land use plans, and provide for essential public services.   Regional
Commissions for economic development and water supplies share  similar
concerns and responsibilities.  Local, state, regional, and national
Interests are not well coordinated at this time.
* Author's note:  While Interest originally stemmed from growth of energy
  consumption and the desire to Improve air quality, renewed Interest may
  be attributed to the more recent restrictions on oil Imports to the
  United States.

                               133

-------
     "These factors have led the five States, the Old West Regional
Commission, and several Federal agencies to cooperatively initiate the
Northern Great Plains Resource Program (NGPRP).  This document sets
forth the objectives, design outline and organization of the program.

Objectives

     "The primary objective of the NGPRP 1s to provide an analytical and
informational framework for policy and planning decisions at all levels
of government.  The end result is Intended to be a decision-making tool
for Federal, State and local interests who together must plan and manage
the area's land and natural resources.

     "The principal Issue concerns the development, or nondevelopment, of
land resources within the Powder River and Fort Union areas.  Particular
emphasis is placed on coal resources.  The program will provide data and
analytical methodology, including the development of appropriate models,
to demonstrate the economic, social and environmental consequences of
various courses of action.  The program will present both quantifiable
and nonquantifiable implications of alternative land and resource uses.
The final report will not recommend a particular development plan for
the region, rather, it will provide adequate information on the balancing
of values and net benefits of alternative plans to guide development of
a coordinated Federal-State plan.

     "The second objective is to encourage the organization of ad hoc
institutional entities that will bring together all facets — local,
State and Federal — concerned with collection and interpretation of
information which will affect the future development and quality of the
region.  It is anticipated that this will lead toward a coordinated
planning program for the entire region.  The organization would draw
from existing State-Federal mechanisms for socio-economic planning in
the region, such as State planning groups, Title V Commission, and
appropriate River Basin Commissions.  Policy and decision-making authority
must be retained by established agencies, organizations, and the State
and local entities.  The NGPRP will contribute 1n every possible way to
encourage this coordination.

    "A third objective 1s provision of a coordinating link between data
collection, research, planning and operational resource management
activities that exist within many different organizations.  Such a link
should assure rapid interchange of technology and methodology between
Individual programs associated with the NGPRP.
                                134

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      and Guidance

     "All analyses will deal with the Implications of proposed resource
management actions for the five-state area.   Although focus will  center
on the study area, and particularly Powder River and Fort Union resources,
the program will adopt whatever appropriate perspective for each subject
of analysis.  For example, analysis of energy requirements will consider
the national energy situation and Its principal  geographic components,
as well as other demands for Great Plains coal.

     "Thus, an alternative to delayed development of coal or other minerals
will be considered 1n relation to Impact on the local economy, as well as
Impact on the esthetic and cultural values of the region, and relation to
the National energy situation.  Likewise, in considering energy develop-
ment cases, analyses of air quality, for example, will Include Implications
of electrical generation in distant urban areas as opposed to generation
in the study area, as well as the relative effects of each on local air
quality.  These two examples are meant to illustrate the wide range of
concerns within the NGPRP.

     "The program will foster integrated consideration of basic natural
resource use and protection, including human interests and economic and
social development.  It will consider the full range of economic, social,
and environmental consequences of alternative plans of land and resource
management in the region.  The accumulation of knowledge and analysis
techniques has implications which extend beyond the study area and Into
other areas of the country that are confronted with similar problems.
The resultant data may become a model for future studies or programs
concerned with resources in other areas.

     "To the fullest possible extent all concerned entitles will have the
opportunity to participate In the design and implementation of the program.
Vehicles for participation and use of study results will Include frequent
reports, regular briefings of broad-based advisory personnel, direct
participation in work groups when appropriate, and the periodic assembly
of policy officers from Involved local, State and Federal agencies,
concerned Individuals, and representatives of special interest groups,
to discuss issues, alternatives, and possible joint regional policies.

     "The program will provide an objective display of data and analysis
to allow a user to draw conclusions based on his particular value system.

The Program

     "The NGPRP will consist of a series of investigations and studies
dealing with a common theme, rather than a single area of concern.  The
                               135

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over-all study will be time-phased and, although a comprehensive final
summary report will be Issued, study results will be reported as they
are completed.  A schematic of the timing sequence 1s shown 1n Figure 1;
specific dates and tasks are not Included; that will be one of the
study's first steps.  Frequent and timely reporting will provide maximum
assistance to decision-makers on Issues which often cannot be delayed
until a full, final report Is Issued.

     "The program has five principal sections:  (1) program design,
    regional profile, (3) constraints and alternate strategies,
    analyses of consequences, and (5) preparation of a final report.

          "1.  Program Design.  The first step of the program will be to
     submit this preliminary outline to other Federal agencies, States,
     Industry, and Interested citizens for review.  The preliminary
     outline will then be expanded Into a Program Design document which
     will discuss at length the nature of the data and methodology to
     be used, and will elaborate on the tasks and structure of the
     effort.

          "The draft Program Design will then be reviewed with other
     Federal agencies, States, regional commissions, and the public.
     Such review should be expedited, but data collection and the
     assessment and development of analytical techniques can begin
     simultaneously.  Comments on the draft Design will be further
     solicited directly from Interested parties through the mechanism
     of Advisory Committees (discussed below under Organization), and
     the Program Design will be the basis for an expression of views
     1f public hearings are held.  Final approval of the Program Design
     will be the responsibility of the Program Review Board.

          "The Program Design should be an evolving document rather than
     a fixed statement or work plan.  The Program Management Team will
     continually modify Its concepts, and refine Ideas and tasks on the
     basis of experience gained and suggestions from co-workers and
     users during the course of the study.

          "2.  Regional Profile.  Data will be collected and analyzed on:
     (a) physical characteristics of the region, (b) resources, such as
     minerals and fuels, wildlife and fisheries, scenic and recreational
     areas, timber, agricultural products and water — Including their'
     location, current use, ownership and control, (c) present baseline
     environmental quality, Including data on solid waste generation and
     disposal, (d) regional Infrastructure, (e) population density,
     distribution, and character, (f) regional social and economic
                                136

-------
attitudes, and (g) past and present activity.   In short,  complete
ecological, natural resource, social, and economic Inventories will
be developed, as specified 1n the Program Design phase.   Inventory
will begin with a review of the available data, will  Identify gaps
and then recommend collection of data to fill  those gaps.  As data
are gathered, they will be published.  Preliminary Investigations
should examine the need for maps to display land use  and  ownership,
water, minerals, and other resources.

     "3.  Constraints and Alternative Strategies.  To provide a
basis for judging the feasibility of development and  management
alternatives, It will be necessary to Identify and evaluate legal,
Institutional, social, economic, environmental, and physical
constraints on resource development and management.  The  analysis
of physical constraints will Include, for example, the need to
commit or divert a resource such as water, for the development of
coal.  Existing arrangements may limit the extent to  which this
can be done.

     "As such constraints are identified, findings will be fed into
other program elements to avoid duplication.  This will be accom-
plished by continual monitoring of all tasks by the Program
Management Team.  Some of this monitoring and feedback also will
be a function of the Technical Advisors.  These studies should
also identify development stimuli.  (See following section on
Organization.)  Because this is the phase of the study in which
exercise of judgment 1s Inevitable and the possible loss  of
objectivity 1s most likely, 1t may prove to be most crucial.
It 1s, 1n effect, an inventory of institutions and attitudes.
The relevant Institutional constraints are readily identified ~
The Clean Air Act, National Environmental Protection  Act, mine
reclamation laws, regional water compacts, mineral leasing laws,
other related State and Federal laws, land ownership, and the
like.  Equally important are economic and social constraints on
resource management alternatives.  A variety of attitudes and
views must be surveyed and considered.

     "The output of the constraints section would be, 1n  effect,
an Identification of potential Issues and an Improved definition
of alternative goals, such as maximum contribution to the solution
of the U.S. energy problem.  The analysis may help redefine specific
goals consistent with the requirement that the NGPRP  study not
select a single goal or system of values, and thus prejudge results.
                          137

-------
     "To produce more detailed analyses of the Implications of
resource management and development alternatives, general alternative
management and development strategies must be postulated.  One
strategy should assume no further development beyond that presently
underway; that 1s, to maintain the status quo.  Additionally,
several strategies should be developed to represent a range of rates
and Intensities of development In the region.  Possibilities might
Include shipping mined material out of the region for processing;
mine-mouth generation of electricity with coal, gasification and
on-site burning of gas, or pipeline transport of coal gas to distant
use sites.  Other models could concentrate on consequences of
favoring surface use such as recreation and ranching, rather than
mineral development.  The alternative of generating power within the
study area, and using it for such processes as uranium enrichment,
must be considered in light of both economic and environmental
implications.  Possible new electrical transmission methods must
be considered in any model concerned with mine-mouth generation
of energy.

     "Strategies should include not only the physical management and
development of the resources of the region, but also concomitant
actions that various levels of Government and industry may have to
take, such as regulation, leasing or investment.  All strategies
or options must consider total resource management in the region.
Relationships of the proposed development strategies to regional
and national demand and supply projections must be analyzed.
That can perhaps best be accomplished through econometric and
other appropriate models.

     "4.  Analysis of Consequences.  The proposed strategies will be
analyzed to determine economic, social and environmental Implications
locally, in the region, and nationally.  These Implications will be
arrayed against a variety of goals and the results presented without
value judgment.  The multi-objective principles and standards being
developed by the Water Resources Council will be reviewed and applied
to the extent possible.

     "To perform these tasks, an array of analytic methodologies
and/or models shall be identified, evaluated, and extended, or
developed as needed.  These models must address such diverse effects
as national economic patterns, regional and State economic status
and development activities (econometric models), air quality (emission
and meteorological models), land use, and resource use.  Modeling and
regional profile inventories shall be closely coordinated, should
proceed in a parallel manner, and should be carried out by the same
                           138

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     people.  In addition to detailed models of specific sectors,
     Integration of sector models will be required.  This will be a
     particularly delicate task, but necessary to provide a means of
     translating alternatives regarding limited areas Into a compre-
     hensible whole.  The need to establish methods for assuring
     crosswalks between various models cannot be overemphasized.

          "This array of models, when fully developed and Integrated,
     will themselves be a major product of the program and should be
     useful for resource planners in other areas, as well as planners
     In the study area who may need to further evaluate development
     proposals.

          "5.  Final Report.  Assuming resource and use Inventories,
     analytical methodology, and Interim results are published as they
     are developed, the final report will consolidate results and provide
     a readable overview of the program.

Organization and Participation

     "A schematic of the proposed organization 1s shown in Figures 22
and 23.  Policy guidance and overall direction will be provided by a
high-level Program Review Board, which will have ultimate authority over
the Program.  Day-to-day direction will be in the hands of the Program
Management Team.  The Program Manager will frequently report to the
Program Review Board.  Other Federal agencies and State, citizen, and
Industrial organizations will advise the Program Review Board.  Individual
advisors will be designated or approved by the Review Board.  Advisory
Groups, as well as interested private entitles may also desire to exchange
Information with the Program Management Team and participate in the
working groups.  Such participation will be encouraged to the fullest
possible extent.

     "Implementation of the program will be the responsibility of a
Program Management Team, consisting of one representative from each of
the major participating agencies.  The Program work will be carried out
by a cross-section of full and part time staff under the overall direction
of the Program Management Team.

     "The Program Management Team will assume direct responsibility for
preparing the Program Design and Final Report.  The remainder of the
Program will be coordinated by three Staff Coordinators, who will report
to the Program Management Team.  Their areas of responsibility will be
the development of the Regional Profile and of Constraints and Alternative
                                139

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FIGURE 22
                                      PROGRAM MANAGEMENT TEAM
                                            WORK GROUPS
            1
   REGIONAL PROFUJE
 Basic geologic character-
  istics  (e.g., geology,
  landform)

 Mineral  Resources
  (e.g.,  coal, oil,  gas,
  uranium, current
  development)

 Water
  (e.g.,  quantity, quality)

 Air  and  Climate  Baseline
  (e.g.,  quality)

 Surface  Resources
  (e.g.,  recreation,
  agriculture, vegetation,
  biota,  soils, ownership
  and control)

 Socio-economic Baseline
   (e.g.,  population distri-
  bution, social  institutions,
  local and  regional economy)
  I
CONSTRAINTS AND ALTERNATIVE STRATEGIES
                                                T
jCONSTRAINTS (LOCAL*
IREGIONAL, NATIONAL)
I
1 Legal and institutional
  (e.g., water rights,
!  mineral ownership)
 Economic and Technical
  (e.g., National energy
  picture, Industry capa-
  bility, conversion tech-
  nology, mining and recla-
  mat ion technology)
 Environmental
  (e.g., air and water
  quality standards)

 Attitudinal
  (e.g. , regional vs.
  national)
                                SAMPLE STRATEGIES
                           Emphasis on ranching
                           grazing and recreation
                           with minimum mining
                           and little Industry

                           Emphasis on development
                           of coal and uranium
                           but with  transport out
                           of region for  conversion
                           and use

                           Emphasis of mine-mouth
                           conversion of  coal to
                           gas, liquid and
                           electrical energy—
                           also mine-mouth
                           uranium enrichment
                                                                       1
                                                          ANALYSIS CF CONSEQUENCES
                                                       Economic, Regional

                                                       Economic, National

                                                       Social

                                                       Environmental, Regional

                                                       Environmental. National

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FIGURE 23
NORTHERN GREAT PXAINS  RESOURCE  PROGRAM  (NGPRP)
       ADVICE AND SUPPORT
     Other Federal Interest*
     Industrial Interests
     Conservation Groups
     Indians
     Other Interests
               PROGRAM REVIEW BOARD
             Environmental Protection Agency
             Dept. of Interior
             Dept. of Agriculture
             Wyoming, States Member
TECHNICAL ADVISORS
                                                                          I
                                                            PROGRAM MANAGEMENT TEAM
                                                          Environmental Protection Agency
                                                          Oept. of Interior
                                                          Dept. of Agriculture
                                                          Montana
                                                          Wyoming
                                                          North Dakota
                                                          South Dakota
                                                          Nebraska
nuiuv \jtvjuro
A
Regional Geology
Leader: USGS
Members: USD I,
USDA, States,
Other
B
Mineral Resources
Leader: USBM
Members: USD I, EPA,
USDA, ABC, States,
Industry, Other
C
Water
Leader: USBR,
EPA
Members: USDI,
USDA, COE, MRBC,
States, Private,
Other
D
Atmospheric
Aspects
Leader : EPA
Members: EPA,
NOAA, USDI,
States, Private,
Other
E
Surface Resources
Leader: USDA
Members: EPA, USDI,
DOT, States, Private,
Other , USDA
F
Socio-Economic
& Cultural
Leader: USDA
Members: USDA. EPA,
USDI, DOC, DL, MSF,
HEW, HUD, DOT, AEC,
Industry, Indians,
Other
G
National Energy
Considerations
Leader: USDI
Members: USDI, EPA,
USDA, DOC, AEC,
FPC, NSF. OEP,
Industry, Other

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Strategies, and the Analysis of Consequences.  These three study areas
will be broken up Into specific tasks.  Task Groups representing
particular areas of expertise and drawing from various agencies will
be formed to carry out the work of the program.  The Groups will be of
Interagency composition, Including expertise from the State and local
levels as well as the private sector.  Group leaders, selected on the
basis of agency expertise In each particular subject, will form a task
coordination committee reporting to the Staff Coordinators.

     "Specific tasks will be assigned to the Individual Task Groups by
the Program Management Team through the Staff Coordinators.  One such
Group may work on several different tasks that may form1part of the
programs of different Staff Coordinators.

     "As an example, the group developing the regional profile on air
quality may also continue to Identify environmental constraints under
the Staff Coordinator for Constraints and Alternative Strategies.  The
same group, or part of It, will also analyze alternatives and develop
models.  This will simplify feed-back between the various Coordinator
areas.  In addition, modeling expertise will be maintained with the
Task Groups, providing coordination with the collection of basic data.

     "Some tasks, particularly those developing regional profile data,
may be assigned, fully or partially, to on-going State or Federal
programs.  As an example, one or more tasks, or a portion of several
tasks, related to surface resources could be carried out by Agriculture's
Surface Environment and Mining (SEAM) program, which would coordinate
State, local, and Federal Involvement through programs now 1n the
planning stage.  Leadership 1n other tasks or sub-tasks could be assigned
to Individuals or groups which now have key national roles, such as the
collection and display of the geologic data base by the U.S. Geological
Survey and the offices of various State geologists.  As another example,
on-going studies with EPA of national supply and demand of energy and
clean fuels will likely provide Information useful to specific tasks
under Constraints and Strategies and under the Analysis of Alternatives.

     "Maximum reference to and use of on-going programs should prevent
duplication of effort and speed completion of key jobs.  However, full
Involvement of public agencies. Industry, and Individuals knowledgeable
about a subject will be necessary.

Reports and Scheduling

     "A pattern of reports and scheduling 1s suggested by the schematic
1n Figure 13; the preliminary design phase would make dates and tasks more
explicit.  Consultation between the Program Management Team and the Program
                               142

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Review Board will be frequent and Informal.  It may be useful  to schedule
periodic meetings with the Program Review Board for progress reports.

     "The Advisory Groups should serve in effective review roles.  Comments
of participants can be Incorporated directly 1n final  papers,  ensuring
participation by all Interested parties at the most opportune time.

     "A specially selected group of Technical Advisers will be called
upon as needed to review the efforts and products of the Work Groups.
The Technical Advisers shall be designated by and shall report to the
Program Management Team and to the Staff Coordinators as appropriate.

     "In addition to periodic oral and written progress reports to the
Program Review Board, the substance of the program's output will take
the form of a series of staff papers, some of which will appear in both
draft and final form.  The series would Include the program design,
resource and use Inventories, analytical model descriptions, studies of
Institutions, and Interim results.  A final report, as noted, would
provide an overview and consolidation of efforts and results.

Personnel
     "In many cases, resources can be made available by program
redirection and personnel detail with little sacrifice in on-going
programs.

     "The Program Management Team and Staff Coordinators murt devote
full time to the NGPRP.

     "It may be necessary to contract some of the modeling effort.
Certain resource inventory work and impact studies may also require
explicit funding.  Expenditures for preparation and publication of
maps and reports could be considerable.  Details of requirements and
potential sources of funds will be estimated as part of the preliminary
design effort.
                              143

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                            APPENDIX 2
                    REGION VIII RECOMMENDATIONS

       ON PUBLIC INVOLVEMENT AND PARTICIPATION IN. TH£ NGPRP*


     "The Program Management Team should decide soon, the policy on
Information dissemination and public Involvement, especially on whether
a coordinated effort by the Team, or separate Agency efforts should go
Into Information distribution.

     "We recommend the following actions:

          "1.  A series of public Information broadcasts and newspaper
     articles, especially 1n the Great Plains Region, to formally
     Introduce the NGPRP.  A notice that the overall NGPRP outline 1s
     available for public comment and review should be Included.

          "2.  In addition to the national environmental groups provided,
     we feel 1t 1s Important that regional Interest groups be Identified
     and made aware of the study's imminence.  Region VIII recommends
     that participating agencies contribute a 11st of potential groups
     that would be Interested 1n the study, from which a master 11st
     could be made.  We have Included a 11st of regional environmental
     and other selected Interest groups that should be contacted.  The
     overall study outline, or a suitable description of the study
     criteria and goals should be sent to these groups.  The groups
     should be able to reply as to a choice of participatory alternatives
     such as:

               a.  comment and review overall study,
               b.  comment and review on working drafts, and
               c.  comment and review on technical papers.

          "They could then be Included on an appropriate mailing 11st, or
     arrangements could be made to Include them 1n the work process.
  Submitted to Program Management Team by Region VIII, EPA.
                               144

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     "3.  Me feel that the public meeting process 1s a key element
for this study's success.  We would strongly recommend public
meetings at a number of locations 1n the study area crt the outset.
perhaps timed with the release of the overall study outTTneT^o
present for public Information, the broad objectives and approaches
of the study.  The Program Management or even Program Review Board
should perform this activity.

     "We also feel that the public will  be Interested In recommenda-
tions of this study, at task force as well as overall policy levels,
Any one of these areas might require a public meeting, but at this
point, 1t Is difficult to predict which ones.  We recommend that a
policy be adopted to Inform the public through the meetings, and
perhaps 1n written form, of the Initiation of various tasks of this
program.  Comments should be Invited, and the public reaction would
determine whether a hearing needed to be held.
                         145

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                            APPENDIX 3
          EPA'S STATUTORY RESPONSIBILITIES VIS-A-VIS THE

              NORTHERN GREAT PLAINS RESOURCE PROGRAM
     "This Accomplishment Plan has been prepared to detail the activities
that EPA must take 1n the discharge of its statutory authority.  There
follows a summary of selected sections of EPA's statutes that direct the
involvement detailed previously.  Note that the directives of the Federal
Water Pollution Control Act cover far more items than just water if those
Items can or do cause water pollution.

FEDERAL WATER POLLUTION CONTROL ACT. AS AMENDED, 1972
Section 102(a):
      Excerpts:


Section 103(a):
Section 104(a)
"... in cooperation with other Federal agencies, State
water pollution control agencies, and the municipalities
and industries involved, prepare or develop comprehensive
programs for preventing, reducing, or eliminating the
pollution of the navigable waters and ground waters
and improving the sanitary condition of surface and
underground waters."

"... improvements necessary to conserve such waters 	
"... authorized to make joint investigations ...."

"... shall encourage cooperative activities by States
for the prevention, reduction, and elimination of
pollution, encourage the enactment of improved and,
so far as practicable, uniform State laws relating
to the prevention, reduction, and elimination of
pollution; ...."

"... shall establish national programs for the prevention,
reduction, and elimination of pollution and as part of
such programs shall -

(1) "... 1n cooperation with other Federal, State,
    and local  agencies, conduct and promote the
    coordination and acceleration of, research,
    Investigations, experiments, training,
                               146

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                     demonstrations,  surveys, and  studies relating  to
                     the causes,  effects,  extent,  prevention, reduction,
                     and elimination  of  pollution;

                 (2)  "... encourage,  cooperate with, and render  technical
                     services to  pollution control agencies and  other
                     appropriate  public  or private agencies,  institu-
                     tions,  and organizations, individuals, Including
                     the genera]  public, ....

                 (5)  "... (in cooperation) establish,  equip,  and maintain
                     a water quality  surveillance  system (utilizing all
                     resources available)  ....

           (b):   (3)  "make grants 	

                 (4)  "contract with public or private  agencies,  ....

                 (6)  "collect and disseminate, in  cooperation with  Federal
                     departments  and  agencies, and with other public or
                     private agencies, institutions, and organizations
                     having  related responsibilities,  basic data on
                     chemical, physical, and biological effects  of  vary-
                     ing water quality and other information  pertaining
                     to pollution and prevention,  reduction,  and
                     elimination  of pollution.

                 (7)  "develop effective  and  practical  processes, methods,
                     and prototype devices for the prevention, reduction,
                     and elimination  of  pollution.
           (d):  (2) "Improved methods and procedures to identify and
                     measure the effects of pollutants, including those
                     pollutants created by new technological  develop-
                     ments ....
           (t):  "... (in cooperation) conduct continuing comprehensive
                 studies of the effects and methods of control of thermal
                 discharges ....

Section 105(d):  "... an accelerated effort to develop, refine, and achieve
                 practical application of:
                               147

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Section 107(a):
Section 201(e):
           (f):


Section 301(a):
Section 303(a):
           (b):

Section 304(a):
(1) "waste management methods applicable to point and
    non-point sources of pollutants, ....

(3) "Improved methods and procedures to Identify and
    measure the effects of pollutants on the chemical,
    physical, and biological Integrity of water,
    Including those pollutants created by new
    technological developments.

"... projects to demonstrate comprehensive approaches
to the elimination or control of add or other mine
water pollution ....

"... encourage waste treatment management which results
1n Integrating facilities for sewage treatment and
recyqllng with facilities to treat, dispose of, or
utilize other Industrial and municipal wastes ....

"... encourage waste treatment management which combines
'open space1 and recreational considerations ....

"Except as in compliance with this section and sections
302, 306, 307, 318, 402, and 404 of this Act, the
discharge of any pollutant by any person shall be
unlawful.

(1)(B) "Each State shall Identify those waters or parts
   thereof within Its boundaries for which controls on
   thermal discharges under section 301 are not stringent
   enough to assure protection and propagation of a
   balanced Indigenous population of shellfish, fish,
   and wildlife.

"... estimate ... total maximum dally thermal level ....

(1) "... (publish and periodically revise) criteria for
    water quality accurately reflecting the latest
    scientific knowledge (A) on the kind and extent of
    all Identifiable effects on health and welfare ...
    (C) on the effects of pollutants on biological
    community diversity, productivity, and stability ....

(2) "... Information (A) on the factors necessary to
    restore and maintain the chemical, physical, and
    biological Integrity of all navigable waters, ground
    waters ... (B) on the factors necessary for the pro-
    tection and propagation of shellfish, fish, and
    wildlife ....

                     *  *  *
                               148

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           (e):  (2) (B) "mining activities,  Including runoff and
                     siltatlon ...  (F) changes 1n  the movement,  flow,
                     or circulation of any navigable waters  or ground
                     waters ....

Section 306(b):  (1) (A) "...  steam electric  power plants  ...  (B)  ...
                     Federal  standards of performance ...."

Section 316:     (Thermal Discharges)

Section 402:     (National Pollutant Discharge Elimination System)

CLEAN AIR ACT, 1970
Section 101:
"Federal financial assistance and leadership 1s essential
for the development of cooperative Federal, State,
regional, and local programs to prevent and control
air pollution.
Section 102(a):  "The Administrator shall  cooperate with and encourage
                 cooperative activities by all  Federal  departments and
                 agencies having functions relating to  the prevention
                 and control of air pollution ....
Section 103(a)
           (b):
"The Administrator shall establish a national research
and development program ... part of such program shall
...conduct and promote the coordination and acceleration
of, research, Investigations, experiments, training,
demonstrations, surveys, and studies relating to the
causes, effects, extent, prevention and control of air
pollution ... conduct Investigations and research and
make surveys concerning any specific problem of air
pollution In cooperation with any air pollution control
agency with a view to recommending a solution to such
problem ....

"In carrying out the provisions of 103(a) the Administrator
1s authorized to: ... cooperate with other Federal depart-
ments and agencies, with other public and private agencies,
Institutions, and organizations, and with any Industries
Involved, in the preparation and conduct of such research
and other activities ... develop effective and practical
... methods ... for prevention or control of air pollution.
                               149

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           (c):  "... conduct research on, and survey the results of
                 other scientific studies on the harmful effects on the
                 health and welfare of persons ....
           (f):  "... special emphasis to research on the short and long-
                 term effects of air pollutants on public health and
                 welfare  ... may conduct ep1dem1o1og1cal studies ...
                 conduct  ... studies on the 1mmunolog1c, biochemical,
                 physiological, and the toxlcologlcal effects ...
                 consult with other appropriate Federal agencies to
                 assure that research or studies ... will be coordinated ,

Section 104(a):  "The Administrator shall give special emphasis to
                 research and development Into new and Improved methods .
                 for prevention and control of air pollution resulting
                 from the combustion of fuels.
Section 108(a)
Section 114(a)
"... The Administrator shall Issue air quality criteria
for an air pollutant ... criteria ... shall Include
Information ... on those variable factors (Including
atmospheric conditions) which ... may alter the effects
on public health or welfare of such air pollutant ...
types of air pollutant which ... may Interact ... to
produce an adverse effect on public health or welfare ..
any known or anticipated adverse effects on welfare.

"For the purpose of (1) developing or assisting In the
development of any Implementation plan under sections
110 or lll(d) ... The Administrator may require ...
records ... reports ... monitoring ... and sample any
emissions which the owner or operator ... 1s required
to sample ...."
NATIONAL ENVIRONMENTAL POLICY ACT
Section 2:
"... to promote efforts which will prevent or eliminate
damage to the environment and biosphere and stimulate
the health and welfare of man ....
Section 101(a):  "The Congress ... declares that it 1s the continuing
                 policy of the Federal Government, 1n cooperation with
                 State and local governments, and other concerned public
                 and private organizations, to use all practicable means
                               150

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Section 101(b)
Section 102:
and measures, Including financial  and technical
assistance. 1n a manner calculated to foster and
promote the general welfare, to create and maintain
conditions under which man and nature can exist  in
productive harmony, and fulfill the social, economic,
and other requirements of present  and future genera-
tions of Americans.

"... 1t Is the continuing responsibility of the  Federal
Government to use all practical means ... to Improve and
coordinate Federal plans, functions, programs, and
resources to the end that the Nation may ...

(2) "assure for all Americans safe, healthful,
     productive, and esthetlcally  and culturally
     pleasing surroundings;

(3) "attain the widest range of beneficial uses  of
     the environment without degradation, risk to
     health or safety, or other undesirable and
     unintended consequences;

(4) "preserve Important historic,  cultural, and
     natural aspects of our national heritage, and
     maintain, wherever possible,  an environment
     which supports diversity and  variety of Individual
     choice;

(5) "achieve a balance between population and resource
     use which will permit high standards of living
     and a wide sharing of life's  amenities ....

"... all agencies of the Federal Government shall

(A) "utilize a systematic, Interdisciplinary approach
    which will Insure the Integrated use of the  natural
    and social sciences and the environmental design
    arts 1n planning and decision  making which may have
    Impact on man's environment;

(B) "Identify and develop methods  and procedures  ...
    which will Insure that presently unquantlfled
    environmental amenities and values may be given
    appropriate consideration  in decision making along
    with economic and technical considerations;
                               151

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(D) "study, develop and describe appropriate
    alternatives to recommended courses of action
    1n any proposal which Involves unresolved
    conflicts concerning alternative uses of
    available resources ....

(F) "make available to States, counties, municipalities,
    Institutions, and Individuals, advice and Information
    useful 1n restoring, maintaining, and enhancing the
    quality of the environment;

(G) "Initiate and utilize ecological Information 1n
    the planning and development of resource-oriented
    projects; ...."
              152

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                               APPENDIX 4

                   Northern Great Plains Resources Program
                     "Longer Term Study and Data Needs"

                                                  Submitted by Region VIII,
                                                  EPA, March,  1974


1.  Surface water quality and hydrologic (flow,  cross sections) network.
Water quality data have not been collected to any degree which allows
either accurate characterization of ambient quality or prediction of changes
In quality as a result of changed use of water.   Data deficiencies are
attributable to (1) short periods of record, (2) sparse  distribution of
stations, and (3) limited chemical, biological,  or physical measurements  of
presently occupied stations.  The USDI-Geological Survey and EPA have
Initiated a somewhat more extensive surface water quality network 1n the
States of Wyoming, North Dakota, and Montana as  of the Spring of 1974.
However, the sampling frequencies and 1-year period of record are Insufficient
to serve as a basis from which predictions can be made since the vagarities
in flow from one year to the next may not be represented 1n the one year
of data.  Further, the ongoing analyses will be  reconnaissance in nature
due to the lack of Information available on the  Importance of trace elements.
With this and other ongoing research, the most Important trace elements may
not be Identified until we are well into the surface water sampling operation
and adequate baseline data for as yet unmeasured parameters would have to be
acquired in subsequent sampling.

     The gathering of background data cannot continue forever both because
of ensuing development and because of a need to  avoid studies with Indefinite
time frames.  However, it will be necessary to develop monitoring networks
for surface water quality that adequately measure impacts of man's activities.
Thus there is an additional need to design sampling and  assay networks that
will allow planning and regulatory agencies to detect changes in water quality
that may, In turn, affect the aquatic ecosystem.

     At a minimum and based on our present knowledge of  the importance of
water quality parameters, measurements should include daily flow, daily
temperature, daily conductance (with reliable conversion factor to total
dissolved solids), dally to composited weekly pH, weekly dissolved oxygen
with Intensive surveys of hourly and daily DO during critical periods,
weekly to composite bi-weekly assay of common ions (Ca,  Mg, Na, etc.),
weekly BOD (or COD or TOC providing interrelationship 1s determined) with
Intensive surveys of mixing zones in areas of BOD loadings, bi-weekly to
composite monthly assay for "metals" (lead, copper, mercury, aluminum, boron,
zinc, selenium, molybdenum, uranium, arsenic, etc.) and  for fluorine, ammonia,
nitrate-nitrite, and phosphorous with Intensive surveys  of daily concentrations
in selected areas.  Ideally, the network will be adapted to measure a
minimum number of parameters whose selection will be based upon ongoing
(present) efforts and new developments that may Indicate which variables
are most likely to be affected by coal or other resource "development".
                                 153

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2.   Identification and quantification of source-terms for water quality
predictions related to coal  "development".  There are no reliable or
documented estimates of what changes in water quality parameters may occur
if new coal-fired energy conversion facilities are installed in the
Northern Great Plains.  The  Inability to estimate changes 1n water quality
is not only a function of the  lack of ambient surface water and ground water
quality data but also of the lack of definition of the amount and quality of
water discharges from somewhat unique conversion processes such as coal
gasification.  Further, we lack  information regarding the sediment yield
from mined areas at various  stages of development.  As a result, it 1s
difficult to predict changes in  total dissolved solids concentrations and/
or total suspended solids resulting from discharges.

     While this need is a part of a complex situation which includes the
need to accurately Identify the  quality of water conveyed to the conversion
facilities, types of conversion  processes, including cooling, and true water
needs, disposal techniques, and  shallow hydrologic regimes, the specific
need herein described is to quantify water uses and discharges with measure-
ment of any changes in water quality in operations such as mines, urban
centers, or gasification plants.  EPA has initiated an evaluation of water
uses, needs, and economics through its Con/all is National Environmental
Research Center.  However, the effort is not yet extensive enough to cover
coal strip mines and/or coal gasification plants with any high degree of
certainty.  The question of the  impact on water quality of urban non-point
sources is also not adequately addressed as yet.

3.   Water use requirements and alternatives for coal "development".  It
appears appropriate for planners and regulatory agencies to know, with
relative certainty, water use  requirements are for various stages of coal
development including mining,  coal-fired power plants, coal gasification
plants, in-situ conversion processes, urban centers, land rehabilitation,
etc.  This relates to the aforementioned need to quantify source terms for
water quality predictions.  However, it relates to all operations related
to coal development rather than  just those for which there 1s little
knowledge regarding changes in water quality.  For example, there is no
basis upon which anyone can specify the minimum amount of water necessary
to operate a 1000 Megawatt coal-fired plant or a 250x10° SCF/D coal
gasification plant.  Assessments of what Improvements in technology might
lower the present requirements are only started.  The objective of fulfilling
the  need is to develop a methodology that allows the decision-makers to
compare water use alternatives for proposed plants and to Include in the
comparisons economic tradeoffs.

4.   Development of modelling tools that allow prediction of changes in
aquatic ecosystem with emphasis  on surface water quality.  Water quality
modelling has not been attempted in a comprehensive fashion for the areas
such as the Northern Great Plains where data describing ambient quality
and  interrelationships between quality, flow and water uses are scarce.
Existing modelling or predictive methodologies must be evaluated and modified
if appropriate.  New nethodologles may have to be devised.  The outcome is
to be the designation of the best model(s) with subsequent field verification
                                 154

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and collection of pertinent Input data.   The analysis  will  result in a
method manual which described In detail  the models  available,  the limitations
and advantages, the sensitivities of the appropriate models to changes In
key parameters and to data deficiencies.  From this Information,  the
monitoring network referred to above in  Need #1 can be refined.

5.  Continuation of the development of instream needs  methodology and
implementation of verified methodologies.  EPA has  funded an effort to review
and refine the most appropriate measure  of the affect  of "artificial"
(changed) stream flows on the aquatic ecosystem.  EPA  has also submitted
for approval a contract that will further this effort  to the field testing
and verification stages.  Questions to be answered  involve evaluating the
relative impacts of changes in streamflow caused by impoundments  and
diversions, and, possibly, discharges on the aquatic ecosystem which consists
primarily of aquatic life such as fish and their food  chain, aquatic
vegetation including stream bank vegetation, and wild  fowl  dependent upon
the flowing streams.

     A methodology that adequately addresses both the  macroscopic and
microscopic levels of the ecosystem is required.

     Upon successful development of the  methodology for most streams, a
scheme for collection of data and for monitoring impacts is required.

6.  Assessment of shallow and deep ground water reserves and the  impact of
coal and related "development" on these  resources.   There are  a number of
areas under the subject of ground water  that require additional efforts.
To date the NGPRP has initiated a reconnaissance effort to enable predictions
of the impact of strip mining on the physical and chemical  characteristics
of the shallow ground water regime.  This effort is necessarily site-specific
and limited.  A comprehensive analysis of the shallow  ground water system to
enable predictions of potential impacts  on the quality and quantity of these
waters should be initiated.  Leaching studies of spoils materials are
appropriate along with microscale investigations of changes in water
characteristics with time in the spoil materials of mines.

     Deeper ground water resources have  been reviewed  in only  a reconnaissance
manner.  Drilling programs have not been started.  In  order to assess the
potential for developing (which assumes  the simultaneous evaluation of the
impacts of developing) deep (Madison) ground water, numerous measurements
of aquifer characteristics and water quality are required.  Sufficient bases
to allow accurate planning of ground water withdrawals are necessary to
avoid undue depletions of the ground water reserves.

     Shallow aquifer data are needed to permit evaluation of the impact of
large (new) reservoirs, primarily those used to cool or evaporate water
discharges.  For this purpose and others, the data needs Include extensive
aquifer testing to enable prediction of the reaction of the hydrologic
system to new stresses.
                                 155

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7.  Fate of trace elements  1n coal-fired energy conversion plants.  EPA
will be supporting a reconnaissance effort to determine the fate of trace
elements contained 1n coal  as the coal is burned and emissions formed in
coal-fired power plants.  It is hoped that three plants will be addressed.
The objective  is to quantify these fates so as to better identify what,
if any, materials that are  potentially hazardous may be emitted.  Based then
on these results, environmental sampling and assay schemes will be devised
or modified to follow these critical trace elements.

     It must be recognized  that this effort, which in itself 1s a future
need, will give data representative of only one point 1n time.  Based upon
this reconnaissance effort, one will be better able to assess the need for
repetitive sampling at plants to arrive at average, maximum, and minimum
concentrations in effluents.

     The subject of trace elements also Involves other areas in which
additional work 1s required.  Under needs described earlier for surface
and ground water measurements, trace element content was discussed.  The
content of these elements on the terrestrial environment — primarily in
vegetation and animals.  Also  germaine  1s the adapation and testing of
atmospheric diffusion modelling for discharges of trace elements.

     The ongoing efforts have not, at this point, addressed the fate of
trace elements in coal gasification plants.  Since such plants are under
serious consideration for the Northern Great Plains, it makes sense to
evaluate these plants in the very near future.

     The results of these measurements, when combined with studies of the
secondary effects of emissions on the environment, will be useful in
developing adequate emission control technology.

8.  Alternative siting of energy conversion plants at greater distances
from coal but  closer to large water-bodies.  This 1s a question 1n need of
an answer that in turn requires more Investigation.  It is also a part of
a larger question that will be addressed next.  In general, three methods
of energy production from coal have been seriously considered in the
Northern Great Plains.  Two methods Involve coal-fired power plants, the
third Involves coal gasification.  Siting of such plants has followed two
lines of thought — one suggests mine-mouth power plants and coal
gasification plants, the other involves transportation of the coal to
power plants near electrical demand centers.  In both cases, water 1s
generally transported to the plants unless the load center lies conveniently
near a water supply.  The question of interest then is, "1s there a
'half-way point' where coal 1s transported to a site near large surface
water bodies such as the Missouri River and electricity Is then transported
some distance  to demand centers".  The need obviously Includes a need to
assess the physical and ecological Impact of the large discharges of heat
Into such water bodies as well as the efficiencies of such transportation.
                                 156

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9.  Efficiencies of energy conversion and transportation.   It would seem
appropriate for the decision-makers to be able to make reasonable comparison
between, for example, transportation of coal  and transportation of electricity.
A frequently-mentioned choice is that of mine-mouth power plant versus
railroads to export coal from the region.  This choice should have the
benefit of quantitative analyses of coal transport economics, secondary
fuel useage, status of more efficient means of transmitting electricity,
1n addition to impacts covered by other research needs or ongoing investigatory
efforts.  Choices between production of electricity versus gas should also
have the benefit of economic and efficiency analyses.

     Agencies such as the Federal Power Commission have supported efforts
in these areas but the Northern Great Plains Resources Program has not
reviewed nor utilized nor evaluated any ongoing efforts or planned efforts
in this area of conversion efficiencies or transmission (transport) needs.
Availability or feasibility of new technologies need to be publicized.

     These considerations of the efficiency of conversion and distribution
of energy are basic to siting and planning decisions required to guide coal
"development" 1n the Northern Great Plains.

10.  Social and economic description of present inhabitants of the Northern
Great Plains.  The short time alloted to Northern Great Plains Resources
Program to date has not allowed a thorough description of the Northern Great
Plains in terms of source of income, capital  investments, taxes and expenditures.
While EPA may be supporting efforts in future years, these efforts will be
limited in nature.  Extensive research through the records of various levels
of government and interviews with representatives of the inhabitants will
be required.

     It would be hoped that this research need would also be extended to
develop a methodology that might adequately identify and articulate the
desires of the inhabitants insofar as coal development is concerned.

11.  Demonstration of rehabilitation of strip mined areas in the Northern
Great Plains.  Rehabilitation of lands disturbed by strip mining activities
In the Northern Great Plains Resource area has not been adequately achieved
over large acreages.1  The majority of rehabilitation that has been attempted
has met with little success in stabilizing areas, providing a base for some
land use, or improving aesthetics characteristics of the disturbed area.
Failure or limited success of rehabilitation efforts thus far is a result
of several factors and considerations.  Lease stipulations and state
reclamation law have failed to adequately define or require realistic and
adequate rehabilitation procedures and objectives.  Past and on-going
research has been fragmented into several geographical areas with little


1^It 1s recognized that varying degrees of reclamation success have  been
    achieved at a limited number of sites.  One in North Dakota appears to
    be an excellent example of at least short-term success.  Of course the
    annual precipitation 1s higher at this site.


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 technology transfer from one area to another.  Research efforts that have
 been demonstrated as having high potential for successful rehabilitation
 have not been demonstrated on areas large enough to resemble future needs
 for the large land areas that may be disturbed in the future.

      The objectives of a large area demonstration would be (1) to develop
 adequate rehabilitation stipulations for use in leasing permits and as a
 basis for legislative requirements, (2) to combine the various results of
 research efforts, both past and on-going, into a viable and realistic
 approach to rehabilitation, (3) to demonstrate the technology and methodology
 of rehabilitation to allow industry to determine costs and equipment require-
 ments necessary to carry out the job, (4) to determine and evaluate long
 term trends and effects of rehabilitation, (5) to determine if the best
 present methods of rehabilitation are adequate and to identify possible
 weaknesses or shortcomings needing further research, and (6) to prepare
 examples of reclamation costs.

      The objectives outlined are comprehensive and far-reaching.  To achieve
 these objectives a very comprehensive program will be required.  The duration
 of the demonstration should be a minimum of 10 years with on-going observation
 from time to time thereafter.  Remote sensing techniques will be evaluated as
 an observation tool.  Other areas to be assessed are (1) relationships of
 vegetation to groundwater aquifers, (2) fertilizer effects on water quality
 and (3) development of seed sources for natural vegetation.

 12.  Adequacy of laws and regulations to properly review, approve, plan for,
 monitor, and terminate the various activities possible in the course of
 coal "development".  The Northern Great Plains Resources Program has very
 adequately presented so-called "constraints reports" from the various work
 group efforts.  However, time has not permitted an assessment of the
 existing laws, regulations, and regulatory staffs as to their capabilities
 of coping with coal "development".  It would seem that comprehensive lists
 of lease stipulations and required data are needed to allow proper control
 of development.  It is also possible that significant increases in staffing
 are necessary for proper control.  An objective would be the preparation
 of model legislation.

 13.  A thorough assessment of the Northern Great Plains Resources Program
 as a comprehensive fact-finding, analytical, and informational effort that
 could serve as a guide to assisting with the evaluation of similar resource
 "development" opportunities.  The Northern Great Plains Resources Program
 may be viewed as the second attempt to plan, evaluate, and prepare for
 large-scale development of energy fuel reserves located in a relatively
 small  geographical area.  The first was the Southwest Energy Study and
 addressed itself to the development of coal in the Four Corners area of the
 Southwest United States.  The NGPRP was next and was designed to provide
 an "analytical and informational frame work for policy and planning decisions
 at all  levels of government" in relationship to development of coal and
other resources in the Northern Great Plains (Montana, North Dakota, South
 Dakota,  Wyoming).  The NGPRP has been working for one and one-half years
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of Its projected three-year lifetime.   Its future must  be assessed  in
terms of its objectives and accomplishments.   Now geographically-confined,
rich* deposits of oil shale are being  opened  to prototype development.   The
most effective framework to plan and direct these developments  must be
established immediately.  The proposed project will  evaluate  the NGPRP  as
an example of such a framework and recommend  the most effective methodology
to address oil shale and other Regional energy resources.

     The assessment will address the mechanism, the  timing, the participants
(composition), the methodology, the success,  and the future in  terms of
adequacy of data, Program continuance, transfer of responsibilities, and
the appropriateness of a similar effort for oil shale and Energy Resource
Development as a whole, the latter primarily  in the  West. The  assessment
will review the Program timing as it relates  to resource development,
leasing, technology development, and energy demands. Program success will
be reviewed from the standpoint of producing  regional profile data,
providing support to planning and regulatory  agencies,  providing leader-
ship and a focal point, directing related research and  investigative
efforts, and identifying future legislative,  research,  and monitoring needs.
The assessment will treat the various  alternatives for  Program  continuance,
whether it be in the same format, abandoned,  divided into ongoing coordination
effort, or some combination.

     The value of such an assessment lies in  the information  garnered to
direct comprehensive efforts in evaluating oil shale and other  large-scale
energy (or human) resource "development".

14.  Continued evaluations and new demonstrations of alternative cooling
techniques for coal-fired plants.  The need to quantify water requirements
and evaluate reductions in water uses  has been noted previously (#3).   The
alternatives of combination cooling (dry-wet) have been identified  and
accepted as applicable to the Northern Great  Plains  by  some.  There is  a
need to both demonstrate the efficiencies and monitor impacts of dry-wet
cooling options.

15.  Evaluation of the impact on water resources if  a large scale shift
from agrarian water use to industrial  and domestic use  occurs.   This need
phases with many earlier identified needs but it seems  appropriate  to
reemphasize that little is known about the effects of present agricultural
water use in the Northern Great Plains or about the  effects of  transferring
water from agricultural to consumptive or non-consumptive industrial use.

16.  Effects of impoundments along perennial  streams on water quality and
the aquatic ecosystem.  Little is known about the actual effects of such
impoundments since there are few within the Northern Great Plains and none
that have been monitored.  Potential impacts  on fisheries and water quality
have been identified but not measured  or verified in the field.  Some field
investigations of existing natural and man-made impoundments  will add
significantly to the predictive capabilities.
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 17.  Development of  remote  sensing  (aerial imagery) as an inventory and
 enforcement  tool.  EPA  is supporting the continuing effort to inventory
 strip mined  areas.   More specifically, the areas of interest are:

     1.   Inventory of active  and  "abandoned" coal strip mines in the
 Northern  Great  Plains.  Evaluate  natural terrain and geomorphological
 features,  provide quantitative  summary of disturbed lands, and provide
 quantitative evaluation of  reclaimed lands.  Species groupings, drainage
 patterns,  aesthetics, and subsurface hydrology are of concern.  In most
 cases the subsequent use of the mined land could either be for grazing
 or scenic (wildlife, view)  use.

     2.   Evaluate the use of  remote sensing (imagery) for purposes of
 land use  planning associated  with coal development in the Northern Great
 Plains  (planning for coal mining, urbanization, power plants, etc.) by
 State and local entities.   Determine usefulness, optimum techology, and
 methods of interpretation.

     3.   Evaluate the use of  aerial photography and photogrammetric
 methods to plan the  recontouring  of disturbed areas to "approximate original
 contour".  Such methods, if feasible, to be available to State and local
 entities  and industry.  Possible  computer analysis to derive statistical
 description  of  terrain  which  is then converted to earth-moving instructions
 for the rehabilitation  process.

     4.   Evaluate the use of  remote sensing (aerial) to monitor rehabilitated
 areas and to monitor conformanee  with State, local and Federal regulations.
 Identification  of viability of  species, quantitative progress of rehabili-
 tation, problem areas (vegetative stress, erosion), and invasion of native
 species.

 18.  Evaluate the use of imagery  and remote sensing for purposes of energy-
 conversion plant siting in  terms  of meteorological variables.  Also evaluate
 in terms  of  impact of emissions from existing energy-conversion plants on
 vegetation.   Results from fluoride-contaminated areas indicate the potential
 for some  success with such  methods.

 19.  Analysis of the effects  of airborne emissions from coal-fired plants
 on soils  and vegetation in  terms  of trace elements and more common pollutants.
 This is essentially  the study of  "secondary effects" of pollutants on other
 than those effects directly affecting human health.  These effects are the
 complex changes in ecosystem  dynamics that may result from the stresses of
 pollution  or harmful elements as  opposed to the "simple" or direct affects
 of air pollutants previously  reported in the literature.  Response mechanisms
 may result in reversals of  successions or in simplifications of the ecosystem
 structure, in reductions in the ratio of photosynthesis to respiration, or
 in reductions in the nutrient inventory.  Effects may be temporary and
 reversible or may be chronic  and  cumulative.  To be studied are food chains
 and mass and energy  flow patterns.  Laboratory, field plots, and in-situ
work is appropriate.  Include effects on new vegetation.
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     It will be necessary to determine and refine  the  state-of-the-art  in
sampling for trace elements in soils,  animals,  and vegetation.

20.  Identification of trace element content  of coals  and  correlation with
stratigraphy and lithology.  This correlation will assist  in  planning the
mining of coals if it allows identification of  high concentrations  of
potentially hazardous trace elements.

21.  Experimentation and evaluation of computerized plotting  routines that
facilitate the planning of plant siting (mine mouth) and land rehabilitation
(after strip mining).  It appears feasible to utilize  graphical methods to
plan rehabilitation of lands that may  be mined. Such  rehabilitation would
include not only reconturing to minimize erosion and to maximize  vegetative
growth but also rehabilitation that adequately  provided for large scale
drainage and appropriate post-mining land use.

22.  Detailed on-site characterization of ecosystems in the areas of
potential mining.  The objective is to identify fundamental interactions
among various biological and physical  components of the ecosystems. The
Surface Resources Work Grouphas not had the opportunity to perform the
field work necessary to both develop the best methodology  or  to collect
information.

23.  Detailed soils surveys of potential development sites.   Such surveys
would describe in great detail (in excess of  that  utilized for the Crow
Reservation) those soil characteristics that  both  determined the vegetative
ecosystem including the potential for  disturbed soils  to support  new
vegetation and for how long, and the animal ecosystems extant.

24.  Leaching tests of soils and spoils materials  laying in proximity to
coals.  The potential impacts of leaching on  ground water  quality are
addressed in an earlier Need.  The leaching tests  of spoils samples are
required to better estimate the potential of  spoils to contaminate ground
water and to develop appropriate field tests  as well as laboratory tests
that allow the planner, through mediums including  the  mining  plan, to
avoid highly detrimental overburden.  If appropriate,  such tests may lead
to identification and testing of methods to limit  leaching of potentially
harmful elements.  EPA is planning to  support a reconnaissance effort  in
this area during 1974.

25.  Identification of correlations between trace  element  content of
surface and near-surface waters, parent material,  soils, and  sediment.
For purposes of land use planning as well as  for identifying  and  under-
standing ambient levels of selected trace elements such  as mercury, selenium,
molybdenum and arsenic, it is necessary to establish relationships
between the concentrations of these elements  in these  various mediums  and
weathering/transport mechanisms.  The  value lies not only  in  the increased
understanding of "background" concentrations  vis-a-vis increased
concentrations caused by coal "development" but also in  the  identification
of situations where improper land use  would cause high concentrations of
hazardous elements.  EPA is planning to fund  a  reconnaissance effort in
South Dakota in 1974 that approximates the initial phases of this  need.

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 26.   Identification  of  vegetative and micro-animal succession in
 rehabilitated  areas.  This  is  related to earlier described needs, however,
 the  problem is of  sufficient impact  to warrant separate and simultaneous
 study.  The question involves  the quantification of invading species and
 the  viability  of these  species.  Obviously the question entertains answers
 to the  length  of time required for viable vegetation to be established to
 the  same  degree of permanence  enjoyed by vegetation extant before
 disturbance.

 27.   Is the waste  heat  produced  by coal fired plants a potential year-
 around  source  for  warm  water fisheries?  Franklin Institute has planned to
 test the  theory in the  East.   A  feasibility study of literature and
 experiments seems  appropriate  for the Northern Great Plains.

 28.   Determination of the feasibility and, if appropriate, demonstration of
 advanced  longwall  mining techniques  in western coals.  This need has been
 expressed to members of the Mineral  Resources Work Group.  Methods of
 11 longwall ing"  shallow,  thick coals have been developed in Europe.  Shallow
 longwall  mining of a relative  thin coal seam is underway in West Virginia.
 Questions of equipment  requirements, efficiency, and surface impacts of
 identical  mining of  thicker, shallower, and, perhaps, younger coal seams
 in the West have yet to be  answered.  The Bureau of Mines is considering
 a feasibility-demonstration of advanced longwalling in the West.

 29.   Increased and comprehensive investigations into the feasibility of
 in-situ conversion of coal  to  gas and liquids.  The single Bureau of Mines
 experiment in  Wyoming has not  provided an in-depth investigation of the
 pros and  cons  of in-situ production  from coal.  Due to the potential for
 both extraction with less surface disturbance (assuming no subsidence) and
 for  a relatively (to stripping)  low  recovery efficiency, increased
 investigation  is most desirable.

 30.   Compilation of  water rights, uses, and efficiencies of use.  To date,
 water rights,  as awarded or claimed  under western water low, have not been
 addressed by the Northern Great  Plains Resources Program.  The present
 uses  of and legal  rights to water should play a large role in planning for
 coal  development.

 31.   A thorough assessment  of  coal reserves in the Northern Great Plains.
The  lack  of ability  to  estimate  the  coal reserves beneath those 1.3+ million
 acres of  land  already leased in  the  Northern Great Plains indicates the
 lack  of knowledge  as  to how much coal lies where.  Since without these
data  it is  unlikely  that decision-makers can identify better (versus worse)
courses of  action  regarding coal development, an intensive effort to garner
coal  resource  data should be mounted immediately.

32.  Completion of topographic mapping in Northern Great Plains should be
a high priority item.

33.  Development of refined, updated, and streamlined models for predicting
or developing  energy  demand-supply curves.  The Northern Great Plains
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Resources Program has utilized a projection of energy demand based upon
assumptions that are neither clearly understood nor agreed with.   It would
appear that the decision-makers require better and clearer projections of
realistic energy demands.  Such demands should be projected objectively
by agencies with no particular prejudice.

34.  A more comprehensive evaluation of resources development in  the
Northern Great Plains.  The need exists to broaden the Program to include all
energy fuels or sources that exist in the  region plus those that  could
affect the same region in terms of population increases or transportation.
Resources include uranium, oil, gas oil shale, hydroelectric power, recreation,
solar energy, wind energy, increased agriculture, or other industry.  While
there are recognized limitations to such an evaluation, it is imperative
that certain of the aforementioned resources are included in the  quantification
and evaluation of coal "development"-

35.  Analysis of impacts of transbasin diversions (including coal slurry
pipelines) on quality of water and environmental effects in areas of water
origin, including the Colorado River Basin.  To date, the Northern Great
Plains Resources Program has not treated transbasin diversions seriously.

36.  Siting Conference.  The Program should serve as the sponsor  for an
informational, technical, and public conference covering the complex subject
of coal-fired, steam/electric generating plant siting as well as  energy
conversion alternatives to CFPP's (coal fired power plants).  The Conference
would be major, similar in size and scope  to annual meetings of multi-
discipi 1nary groups such as the American Association for the Advancement of
Science (AAAS).  A four-day schedule of simultaneous meetings and an
additional day of field trips is envisioned.  EPA has previously  prepared
an outline for such a conference in the Regional "Accomplishment  Plan"
(Jul 73).

37.  Survey, identify, and evaluate unique geologic, archeologic, historic,
wildlife, and other ecologically-recreationally-, and aesthetically-valuable
resources of the region.  Identify areas and situations where strip mining,
coal conversion, energy transport systems, etc. will threaten resources.
Recommend measures to protect or otherwise preserve appropriate resource
values.

38.  Fugitive dust.  The disturbance of land as a result of mining and
related activities will cause an increase  in the emissions of fugitive dust.
In order to assess impact of these emissions on air quality, a study on a
specific area will be designed.  The background level should be assessed
1n an area prior to the start of a mining  operation.

     An air monitoring network will be designed using hi-volume samples to
assess particulate concentrations.  The network will be developed to assess
impact in the Immediate vicinity of the mining operation and at several
sites at varying distances from the operation.
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     In addition to assessing the Impact in terms of mass per volume for
partlculates, the filters will  be analyzed for trace elements.  This will
be accomplished by using a combination of quantatlve and qualitative
procedures for measuring trace  elements.

     A study of trace element content 1n surrounding vegetative growth will
be conducted 1n conjunction with the partlculate air monitoring efforts.

39.  A coordinated study will be conducted in the vicinity of a major coal
fired power generating plant to assess the impact of emissions.  The study
will include an air quality monitoring network, a mass chemical analyses,
and an evaluation of the concentrations in soils, plants and animals.

     The air quality monitoring network will sample the partlculate and
certain gaseous concentrations.  Gases considered will include the criteria
pollutants and other gases of general concern.  The filters used to collect
particulates will also be used  to assess certain trace elements.

     The concentration of trace elements in the soil, plants and animals
will be correlated with the emissions coming from the plants.  It is
recommended that a cooperative  arrangement be made with the State Game
Commission for the animal studies.  The study dealing with soils and plants
could be coordinated with EPA research laboratories.

     Special attention will be  given to the effect of sulfur oxide emissions
on plants, especially on land areas in the process of being reclaimed.

40.  Regional diffusion models.  The availability of a model to predict
regional air quality and long distance transport of pollutants is very
desirable.  A case by case investigation of single emission sources will
overlook the cumulative and interactive Impacts of many sources within a
region.  Consequently, we identify the need for the adaptation of an
existing regional transport and diffusion model for use in the Northern
Great Plains Region.  This model should:

     1.  Be capable of being understood by decision-makers without
technical expertise.

     2.  Have been tested with  some verification data available.

     3.  Use readily available  air quality and meteorological data.

     4.  Provide output which can be easily compared to air quality
standards.

     An additional longer term  need is for the development of new, more
refined regional air quality models which remove some of the simplifying
assumptions of existing models.  Some Site Specific Verification is
required.
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41.  Trace element source sampling.  There is a need to identify the type
and quantity of trace element emissions from coal  gasification plants so
that we may predict the atmospheric loadings and effects resulting from
these plants.  Bench scale and pilot plant studies are being performed on
a couple processes in this country, but there is no work published on
commercial plants, since the U. S. does not have any commercial  sized
plants.  There is a need to study the European and/or African gasification
plants.  Research funds may be funneled through AGA or other avenues to
perform source sampling programs on those plants.   The NERC-RTP via CSL may
be the vehicle for promoting these studies because of their substantial
budget.  However, Region VIII should have input to this activity in the form
of suggestions to the type of work performed.

     Also, a literature survey of the type of data available regarding
these gasification plants should be performed.

     A concern over the concentrations of trace elements in the respirable
size range of particulate matter is evident.  The program carried out with
FY 74 monies through Region VIII will not be able to identify or characterize
these data.  An intensive sampling program should be performed on a single
coal-fired plant to provide insight to this concern.  This type of work
would be an expansion to the work that has been performed by the NERC-RTP
upon a few (about 10) trace elements.

     The AEC (Livermore Lab) is interested in participating in this type
of program.  It is conceivable that an interagency agreement could be
entered into in order to conduct an extensive program.

42.  Visibility assessment.  The need for the development of methodologies
to assess visibility and other impacts of increased sub-micron particulate
loadings upon the atmosphere is required.

     All available existing visibility data in the Northern Great Plains
Region needs to be compiled.  Airports and local observers are two possible
sources.

     Within the next year, an attempt at formulating a visibility assessment
methodology is needed.  Furthermore, it must be implemented at least at one
site in the Northern Great Plains, for example Col strip or Gillette.  Data
collection should occur before and after large power plants begin operation
to assess the effects that increased particulate emissions have on visibility.
Sampling ambient air for particulate particle size will accompany in-field
visibility assessment.

43.  Oxidant potential from coal gasification.  The large scale development
of fuel conversion facilities in Region VIII will bring with it the large
increase of emissions.  Substantial HC and NOX emissions will occur.  This
situation plus the high frequency of sunlight in the NGP provides the
excellent potential for photochemical oxidant formation.  Also, it is
suggested that presently the oxident air quality standards are being
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exceeded in many non-urban locations.  In order to assess the impact of
the proposed development, 1t will be necessary to locate some HC and oxidant
air quality monitors in the region.  This effort may be a part of the
present N6P monitoring network and tied into the present contractural
arrangement.

44.  Coal gasification emissions.  Little or no firm knowledge exists
regarding the quantity of criteria pollutant emissions from gasification
plants.  Also, of significant interest are the magnitude and type of
reduced sulfur compound emissions from these plants.  The NERC-RTP is
working on the development of emissions estimates and NSPS for gasification
plants at the present time.  It would be helpful for them to have actual
emissions data from the commercial plants overseas.  Region VIII input to
this aspect of work will consist of keeping in close contact with what RTF
is doing and making suggestions on the scope of work being followed.

     Adequacy and extent of control technology for the present commercial
plants is unknown.  Region VIII will perform a literature search after
consulting with RTP in an attempt to answer this question.  It is not
anticipated that any contractual work will be required.

45.  Determination of the effect increase in cloud condensation nuclei
might have upon amount of rainfall.  Several research studies have produced
statistical support of both positive and negative effects of urban produced
aerosols (e.g. from power plants) on precipitation.  The difference in the
conditions surrounding a positive effect as compared to a negative effect
have not been conclusively determined.  Many new power plants and gasification
plants planned for the Northern Great Plains area will produce considerable
air emissions, some of which will become cloud condensation nuclei.  The
effect of the addition of significant quantities of these nuclei on
precipitation in this region must be investigated.

46.  FGD*waste disposal.  A requirement for wide scale FGD development is
not anticipated in Region VIII unless State regulations (such as Colorado's)
become more stringent than the NSPS, or if resolutions to significant
deterioration mandate additional control.  The amount of material to be
disposed of is not as critical as the nature of the material.  Collected
flyash volume would be significantly greater than the anticipated SOs or
$04 sludge.  The chemical nature of the sludge could present a potential
water problem.

     Also, the capture and ultimate disposal of sludges containing possibly
significant quantities of trace elements heretofore uncollected may require
careful handling.

     Utilization of sludge is being studied and should be followed and
promoted.

     Most of the work in this area will be in-house requiring manpower
from Region VIII as well as RTP.  Some contractual work is anticipated,
possibly through expansion of ongoing work at RTP-CSL.
  Flue Gas Desulfurization
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47.  Col strip.  An Intensive study should  be  planned  to  source  sample  the
Col strip plant when 1t comes on line.   Guidance  from  the FY  74  trace element
sampling program will be utilized.  An attendant Intensive ambient
monitoring program should be provided  at the  same time as the source
sampling effort.  This dual  sampling effort should provide data with which
to assess the adequacy of present diffusion models to predict trace element
concentrations.

48.  Effects of CO? and/or particulate. Scientific theories have been
advanced which predict profound effects upon  the weather and climatologlcal
status of the earth.   Global measurements  of  C02 and  participates are  being
conducted.  It is theorized on one hand that  if  C0£ levels continue to
Increase as a result of combustion of  fossil  fuels, an increased trapping
of infrared radiation will occur.  This would result  in  a gradual heating
effect and eventually cause the "greenhouse"  effect.  Increased C02 levels
have been noted at the Mauna Loa observatory  in  Hawaii.

     On the other hand, it has been suggested that if the atmosphere 1s
subjected to increased particulate loadings,  the amount  of solar radiation
reaching the ground will be reduced.  This would result  in an "ice age"
effect.

     A long term monitoring program would  be  necessary in order to make
sound judgments on these two theories.  At least 15 years of data would be
needed to make any meaningful conclusions. C0£  measurements could be  made
as a part of the NGP monitoring network.

49.  Add rain.  In order to verify the effects  of increased atmospheric
S02 loadings upon the pH of rainfall,  extensive  rain  data and analyses
would need to be performed.   The key factors  determining the pH of rain
should first be identified.   The chemistry should be  discussed. Region VIII
could provide substantial input to this project.  Also,  a literature  search
regarding this subject especially looking  at  University  thesis  would  provide
some initial data.

     Collection of rainwater along with routine  analyses could  be  performed
in conjunction with the NGP monitoring network.

50.  $04 levels.  Effects upon health, vegetation, and visibility  by $04 are
not well understood.   It is theorized  that some  concentrations  may prove
harmful.  Due to the increased fuel conversion facility  development  in the
NGP, an Increase in particulate matter and S0£ will result.  Thus, we have
the makings for sulfate production. Measurement of the  $04 concentrations
on all hi-vol filters in the NGP monitoring  network would provide  the data
necessary to make some comments upon the trend of $04 levels in the
atmosphere.  Also, it will provide an  important  function by comparing the
data to existing State standards.  A long  term study is  required (at least
10 years) in order to make meaningful  conclusions.
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51.  Nitrate and flouride levels.  Effects upon health, vegetation and
visibility due to concentrations of nitrates and flourldes are not well
understood.  Nitrate and flouride emissions in the Northern Great Plains
will undoubtedly increase with the addition of new power and gasification
plants.  Therefore, it will be necessary to analyze the N6PRP high-volume
sampler filters for nitrate and flouride concentrations as well as sulfate
and trace elements.  Trend analysis is desirable and requires long term
sampling (at least ten years) in order to draw valid conclusions.

52.  The interplay of the Northern Great Plains Resources Program and
recently promulgated federal and state regulations needs to be studied in
detail.  In view of recent promulgation of air regulations, Indirect source
regulations, 10-year maintenance plans and the soon to be promulgated
significant deterioration regulations, the problem of energy resource
development compatibility with such regulations should be evaluated in a
systematic way.  This wi]l require an assessment of air sheds in the area,
establishing air quality zones, and redesigning, if necessary, an air
quality monitoring network to ascertain if the standards are achieved.

     The compatibility of the energy resource development scenarios from
the NGPRP to pertinent standards will be evaluated by employing point source
and regional diffusion models.  This effort could provide considerable
information to the States in terms of siting guidance.

53.  The quantity of emissions emitted from an energy resource development
area would indicate that health assessments should be scheduled both before
and after the facility is operational.

     A potential site would be the Crow or Northern Cheyenne Reservation
in Montana. A number of samples should be Installed on the reservation and
allowed to operate for several years as development takes place.  This would
allow for documenting impacts on air quality and human health over time
as mines, power plants and gasification facilities become operational.  The
Indian Health Service could cooperate with health related aspects of study.

     A second potential study would be a CHESS type study in an Intensive
development area such as Stanton.  Since development Is just starting, the
study could acquire baseline information, 1f started immediately, and then
track related health effects, if any, as development proceeds.

     This would be a long term study running perhaps 10 years.

54.  Characterization of trace element and major element distribution in
partlculates to determine sources.  The need is to relate various trace
and major elements to sources, both natural and man-made, by electron
microscopy and x-ray diffraction techniques which may be used to quantify
the shapes and origins of partlculates.  The method has been used successfully
in studies of Denver's air pollution.  The objective includes determination
of background distributions.
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55.  Inventory vegetation characteristics of strip mineable areas to
determine rehabilitation potential  of ecosystems.   Synthesize part research
data and field analyses to facilitate the characterization of vegetation
groups that overlie strlppable coal deposits.  Formulate specifications
for the best known means of rehabilitation that also safeguard against
environmental degradation.  Incorporate vegetative and animal sciences with
landscape architecture and geomorphology.

56.  Research into, development, and testing of methodologies necessary
to organize related data generated as a part of or related to the activities
of the Northern Great Plains Resources Program.  This need is not yet well-
defined hut may be considered to include methodologies to relate and compare
the total impacts of development alternatives where the impacts are diverse
and difficult to quantify (e.g. environmental impact analyses).  The need
also includes the identification of those NGPRP data, if any, that may not
be adequately available or stored as a part of some agency's function and
which therefore should be stored for retrival using a new procedure, methodology,
or format.  Such data may be maps,  numerical data, news releases, technical
investigations, etc.
                                  169

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                            APPENDIX 5

Siting Conference

     It has become Increasingly apparent that the Northern Great
Plains Resources Program should serve as a sponsor of an Informational,
technical, and public conference covering the complex subject of
coal-fired, steam-powered, electric-generating plant siting as such
siting pertains to the Northern Great Plains (Montana, North Dakota,
South Dakota, and Wyoming).  This subject has been treated in the
resources allocation for all Task Groups or Subject Areas where EPA
Input from and EPA participation 1n the Conference would be expected.
But, due to the all-encompassIng nature of such a Conference, this
separate section has been prepared to express our concern for Interest
In, and a tentative outline for this Conference.

     We envision the Conference as a major one, similar to annual
meetings of such national organizations as the American Geophysical
Union, the Geological Society of America, the American Institute of
Mining, Metallurgical and Petroleum Engineers, the American Association
for the Advancement of Science, the American Institute of Electrical
Engineers, etc.  We propose a three or four day schedule of simultaneous
sessions and at least one-day long field trip.  The Conference would be
comprised of major addresses, Invited papers, and public discussions
and forums.  The Conference proceedings must be published.

     We have considered cosponsors to Include the States of Montana,
North Dakota, South Dakota, and Wyoming; the Federal agencies contributing
to the NGPRP; selected Universities; public groups such as the Sierra
Club; private groups such as the Edison Electric Institute and the
American Public Power Association; and one or more National Professional
Organizations.  The location of Billings, Montana for the Conference
has been briefly discussed.  Assuming that the Conference should be
held at a time when travel Is possible and when Universities are either
open or during short vacation periods, we have tentatively scheduled
the Conference for the early spring of 1975, though an earlier date,
such as the fall of 1974, would be preferable.

     A proposed outline for the Siting Conference 1s presented in Table
H.  The outline presents only the possible Session Headings and specific
Items that may be discussed.  The outline does not attempt to schedule
simultaneous sessions.

     The objectives of this Siting Conference are as follows:

     1.  To gather technical data that Identify the state-of-the-art
         Insofar as control technology, energy conversion technology,
         mining technology, revegetation technology, predictive
         techniques, and monitoring are critical to the decision-
         making process that Is to be supported by the NGPRP, and
         to allow the NGPRP to benefit from these data.
                               170

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2.  To poll both the public sector and the technical  sectors
    on their attitudes regarding resource development In the
    area of the NGPRP and to document these attitudes for the
    benefit of those who must make decisions regarding coal
    and other resources development.

3.  To present the work of the NGPRP  Staff as It exists to
    date.

4.  To develop a power plant siting philosophy and criteria
    therefore which begins to identify the many options existing
    and methods to predict and evaluate the impacts,  both direct
    and secondary Impacts.

5.  To define the options or decisions Inherent in energy supply
    and demand projections and to evaluate such options and the
    means to both measure and improve predictions of energy
    demand.

6.  To publish the papers presented and summaries of discussions
    held.
                          171

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                   Table H • Northern Great Plains Resources Program - EPA, Region VIII Accomplishment Plan
                                         Task:  Siting Conference - Proposed Outline
I.  General Session
    A.  Keynote Address(es)
        Problem of states relating to coal development and power production.
        Problems of Regions relating to coal development and power production.
        Problems of Nation relating to coal development and power production.
    B.  Northern Great Plains Resources Program (NGPRP)
        Objectives ft Participants.
        Accomplishments to date.
        Future Actions.
    C.  Purpose of Conference
II. Available Mineral and Surface Resources 1n NGPRP Area
    A.  Energy Fuels - Identify, quantify, and evaluate
    B.  Other Mineral Resources - Identify, quantify, and evaluate
    C  Surface Resources Including scenic values, recreational values, fish ft wildlife - Identify, quantify, and evaluate
    0  Ecosystem - Type Evaluation of Interactions between resources If selected developments occur
    E.  Mining Methods

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                                                                         Table H   (Continued)

                  III.   Atmospheric and Meteorological  Aspects of Coal-fired  Power  Plant Siting
                        A.   Present A1r Quality - Including visibility
                        B   Climatology and Meteorology - prevailing patterns and modeling
                        C   Emissions - Including steam
                            1    Health and legal  consideration.
                            2    Present and future quality and control  technology.
                            3    Other energy conversion processes and gaseous emissions.
                            4.   Monitoring and  chemical analysis.
                            5    Modeling.
                            6    Secondary Impacts.
_,                      0.   Ongoing State, Federal and  Institutional  activities
-4
**>                 IV.   Subsurface and Surface  Water Resources and Aspects of Power Plant Siting
                        A.   Present water quality and quantity and use
                        B.   Effluents
                            1    Water use and options.
                            2    Present and future quality and control  technology.
                            3    Other energy conversion processes and liquid  effluents.
                            4.   Secondary Impacts.
                            5.   Legal considerations and health Implications.
                        C.   Ongoing State, Federal and  Institutional  activities

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                                                       Table H  (Continued)
«.   Land-Use Considerations (See also II)
         1   Choices, legal constraints or guidelines, public desires.
         2   Restoration and rehabilitation of disturbed areas.
         3   Alternative methods of resources extraction.
         4.  Future land uses.
VI.  Socio-Economic Considerations
         1.  Economics of region and solutions.
         2.  Economics of coal developments - Mine-mouth plant vs. transport.
         3.  Social and cultural impacts.
         4.  Associated and secondary growth.
         5.  Recreational values.
VII. Environmental Synerglsms
         1   The  Integrated impact on people, wildlife, air, water, vegetation, etc.
         2.  The  National Environmental  Policy Act.
         3   Methods  of predicting and analyzing the  Integrated Impact.
VIII.   Public  Forum
         Somewhat "Free-Form"  series of  written statements and formal discussions Interspersed with Informal  work shops
         conducted by chain people and Recorders.
 IX.  Legal  and Regulatory Constraints
         A power  plant  siting  law.
          State laws and regulations - proposed and existing.

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                                                                       Table H  (Continued)
               X      Energy Production and Transmission Techniques and Potential
                      A   Geothermal
                      8.  Nuclear
                      C   Gasification
                      D   HMD
                      E.  Solar
                      F   Transmission
                      G   Hater
                      H   Research needs
_,             XI.    Summary Session • Siting Criteria
>j
01                    What criteria* how evaluated, wlio regulates, economics, public Involvement.
               XII.   Energy Demands and Supply
                      A   Regional
                      B   National
                      C.  How shall the two coexist
               XIII.   Field Investigations
                          (Field trlp(s))

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     APPENDIX 6

MONTANA STRIP MINING
AND RECLAMATION ACT
        176

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                                      in .ac
SECTION       CONTENT              PACK      SECTION

         Title                     1          16
         Policy                    1          17
         Definitions                2          16
         Directives to Board         3          19
         Directive* to Department     3          20
         Mining permit              4          21
         Application requirements     4          22
         Bonding 6 Fee              6          23
  7      Renewal t Amendment of                  24
         Permit                    6          25
  8      Prospecting Permit          7          26
  9      Selective Denial            7          27
 10      Reclamation Plan « Hethod               2B
         of Operation               8
 AA      Area Mining « Highwall                  29
         Reduction                  9
         Topsoil                   9
         Bond Release              10
 12      Vegetation                10
 13      Concurrent Reclamation      10
 14      Planting Report           10
 15      Vegetation as Property      11
    COMTEOT                PACE

Annual Report               11
Honeomplianoe               H
Succession                 11
Appropriation  of Funds       12
Use of Outside Funds         12
Orphan Spoils               12
Mandamus                   12
Violation Penalties         13
Hearing « Appeal Procedures  13
validity of Acte            13
Repeal                     13
Application Deadline         13
Cancellation of Existing
contracts                  13
Effective Date              13
                                    CHAPTER NO. 325
                               MONTANA SESSION LANS  1973
                                  SENATE BILL NO.  94

       AN ACT CREATING  "THE MONTANA STRIP MINING  AND RECLAMATION ACT" AND
       PROVIDING FOR THE  CONTROL OP PROSPECTING FOR AND THE STRIP MINING  OP
       COAL. CLAY, PHOSPHATE ROCK,  AND URANIUM; PROVIDING FOR PERMITS,
       RECLAMATION PLAN REQUIREMENTS, METHODS OF  OPERATION, AND PENALTIES;
       PROVIDING FOR THE  TERMINATION OF RECLAMATION CONTRACTS ENTERED INTO
       UNDER CHAPTER 2^5, LAWS OF MONTANA, 1957;  REPEALING SECTIONS 50-1018
       THROUGH 50-1033. R.C.M.  1947; AND PROVIDING  AN EFFECTIVE DATE.

       BE IT ENACTED BY THE LEGISLATIVE ASSEMBLY  OF THE STATE OF MONTANA:

            Section 1.  This act shall be known and may be cited as "The
       Montana Strip Mining and Reclamation Act."

            Section 2.  It  being the declared policy of this state and  its
       people

            —to maintain and improve the state's clean and healthful
       environment for  present and future generations,

            —to protect  its environmental life-support system from
       degradation,

            --to prevent  unreasonable degradation of its natural resources,

            —to restore, enhance, and preserve its scenic, historic,
       archeologlc, scientific, cultural, and recreational sites,

            —to demand effective reclamation of  all lands disturbed by
       the taking of natural resources, and

            —to require  the legislature to provide for proper administra-
       tion and enforcement, create  adequate  remedies, and set effective
       requirements and standards (especially as  to reclamation of dis-
       turbed lands)  in order to achieve the  aforementioned objectives,

            the  legislature hereby  finds and  declares:

            (1)   That, in order to  achieve  the  aforementioned policy
       objectives,  promote the health and welfare of the people,  control
       erosion  and pollution, protect domestic  stock and wildlife,

                                  SENATE BILL NO.  9«
                                     177

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preserve agricultural and reereablonal productivity,  save  cultural,
historic, and aesthetic values, and assure a long-range  dependable
tax base, it Is reasonably necessary to require, after the effective
aate or thla act, that all strip mining operations be limited  to
those for which annual permits are granted, that no permit be  Issued
until the operator presents a comprehensive plan for surface reclam-
ation and restoration, together with an adequate performance bond,
and the plan Is approved, that certain other things must be done,
tnat certain remedies are available, and that certain lands because
of their unique or unusual characteristics may not be strip mined
under any circumstances, all as more particularly appears  In the
remaining provisions of this act.

     (2)  That this act be deemed to be an exercise of the authority
granted in the Montana constitution, as adopted June 6,  1972,  and
in particular, a response to the mandate expressed in article  IX
thereof, and also be deemed to be an exercise of the general police
power to provide for the health and welfare of the people.

     Section 3.  Unless the context requires otherwise in  this act:

     (1)  "mineral" means coal, clay, phosphate rock, and  uranium;

     (2)  "overburden" means all of the earth and other  materials
which lie above a natural mineral deposit and also means such  earth
and other material after removal from their natural state  In  the
proccos of strip mining;

     (3)  "strip mining" means any part of the process followed in
the production of mineral by the open cut method Including mining
by the auger method or any similar method which penetrates a  mineral
deposit and removes mineral directly through a aeries of openings
made by a machine which enters the deposit from a surface  excavation,
or any other mining method or process in which the strata or  over-
burden is removed or displaced In order to recover the mineral;

     (4)  "prospecting" means the removal of overburden, core drill-
Ing, construction of roads or any other disturbance of the surface
for the purpose of determining the location, quantity, or quality
of a natural mineral deposit;

     (5)  "area cf land affected" means the area of land from which
overburden Is to be or has been removed and upon which the over-
burden is to be or has been deposited and Includes all lands  affected
by the construction of new railroad loops and roads or the Improve-
ment or use of existing railroad loops and roads to gain access and
to haul the mineral;

     (6)  "operation" means all of the premises, facilities,  rail-
road loops, roads, and equipment used In the process of producing
and removing mineral from a designated strip mine area, or prospect-
Ing for the purpose of determining the location, quality, or quantity
of a natural mineral deposit;

     (7)  "operator" means a person engaged in  strip mining who
removes or Intends to remove more than ten thousand  (10,000) cubic
yards of mineral or overburden;

     (8)  "person" means a person, partnership, corporation, associ-
ation, or other legal entity, or any political  subdivision, or
agency of the state;

     (9)  "method of operation" means the method or manner by which
the cut or open pit is made, the overburden la  placed or handled,
water Is controlled and other acts are performed by the operator in
the process of uncovering and removing the mineral that affect the
reclamation of the area of land affected;

     (10)  "topsoll" means the unconsolldated mineral matter

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                            178

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                 on the surface cf the  earth  that has been  subjected
       *nfluenced by genetic and environmental  factors of parent
«»*«   * climate, macro- and mlci'oorsanisms, and topography,  all
accins over a period of time, and that  Is  necessary  for  the growth
and regeneration of veSetation on the surface of the earth;

     (11)  "department" means the department  of state lands provided
for In title 82A, chapter 11;

     (12>  "commissioner" means the commissioner of  state lands
provided for in section 82A-1104;

     (13)  "board" means the board of land commit^loners provided
for In article X, section 4 of the constitution of this  state;

     (14)  "reclamation" means backfilling, grading, hlghwall  re-
duction, topsoiling, planting, rcvegetatlon, and other work  to  restore
an area of lend affected by strip mining under  a plan approved by
the department;

     (15)  "degree" means from the horizontal,  and In each  case  is
subject to a tolerance of five percent  (5%) error;

     (16)  "contour strip mining" means that  strip mining method
commonly carried out in areas of rough  and hilly topography in which
the coal or mineral seam outcrops along the side of  the  slope  ana
entrance is made to the seam by excavating a  bench or table cut  at
and along the site of the seam outcropping with the  excavated  over-
burden commonly being cast down the slope  below the  mineral seam
and the operating bench;

     (17)  "bench" means the ledge, shelf, table, or terraces  formed
in the contour method of strip mining;

     (18)  "fill bench" means that portion of a bench or table which
is formed by depositing overburden beyond  or  down slope  from the
cut section as formed In the contour method of  strip mining;

     (19)  "abandoned" means an operation  where no mineral  Is  being
produced and where the department determines  that the operation
will not continue or resume.

     Section 4.  The board:

     (1)  shall issue after an opportunity for a hearing,  orders
requiring an operator to adopt the remedial measures necessary to
comply with this act and rules adopted under this act;

     (2)  shall issue after an opportunity for a hearing,   a final
order directing the department to revoke a permit,  when the require-
ments set forth by the notice of noncompliance, order of suspension,
or an order of the board requiring remedial measures have  not been
complied with according to the terms herein;

     (3)  shall adopt after an opportunity for a hearing,  general
rules pertaining to strip mining to accomplish the purposes of this
act;

     (4)  shall conduct hearings under provisions of this  act or
rules adopted by the board.

     Section 5.  The department:

     (1)  shall exercise general supervision,  administration, and
enforcement of this act and all  rules and  orders adopted under this
act;

     (2)  shall examine and pass upon all  plans and specifications
submitted by the operator  for  the  method  of  operation,  backfilling,
grading, hlghwall  reduction, topsolling and  for the reclamation of

                           SENATE BILL NO.  94
                            179

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the area of land affected by his ooeratlon;

     (3)  ahall or<**r the suspension of any permit for failure  to
comply with this act or any rule  adopted under this act;
          shrill order the halting of any operation that Is started
without first having secured a permit as required by this actj

     (5)  shall make investigations and inspections necessary to
insure compliance with this act;

     (6)  may encourage and conduct Investigations, research, experi-
ments and demonstrations, and collect and disseminate information
relating to strip mining and reclamation of lands and waters
affected by strip mining;

     (7)  may adopt rules with respect to the filing of reports,
the issuance of permits and other matters of procedure and
administration.

     Section 6.  (1) An operator may not engage in strip mining with-
out having first obtained from the department a permit designating
the area of land affected by the operation.  The permit shall
authorize the operator to engage In strip mining upon the area  of
land described in his application and designated in the permit  for
a period of one (1) year from the date of its issuance.  Such permit
shall be renewable from year to year thereafter upon application
to the department at least thirty (30) but not more than sixty  (60)
days prior to the renewal date so long as the operator is In com-
pliance with the requirements of this act, the rules hereunder, and
the reclamation plan provided for in section 10 of this act, and
agrees to comply with all applicable laws and rules in effect at
the time of renewal.  Such renewal shall further be subject to  the
denial provisions of sections 9 and 13 of this act.

     (2) An operator desiring a permit shall file an application
which shall contain a complete and detailed plan for the mining,
reclamation, revegetatlon, and rehabilitation of the land and water
to be affected by the operation.  Such plan shall reflect thorough
advance investigation and study by the operator and ahall Include
all known or readily discoverable past and present uses of the  land
and water to be affected and the approximate periods of such use
and shall state:

     (a)  the location and area of land to be affected by the opera-
tion, with a description of access to the area from the nearest
public highways;

     (b)  the names and addresses of the owners of record of the
surface of the area of land to be affected by the permit and the
owners of record of all surface area within one-half (.5) mile  of
any part of the affected area;

     (c)  the names and addresses of the present owners of record
of all subsurface minerals in the land to be affected;

     (d)  the source of the applicant's legal right to mine the
mineral on the land affected by the permit;

     (e)  the permanent and temporary post office addresses of  the
applicant;

     (f )  whether the applicant or any person associated with the
applicant holds or has held any other permits under this act, and
an identification of those permits;

     (g)  whether the applicant is In compliance with subsection
(2) of section 17 and whether every officer, partner, director, or
any individual owning of record or beneficially (alone or with

                          SENATE BILL NO. 94


                            180

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associates) If known, ten percent  (10*)  or more of any class of
SCOCK or the applicant, Is subject to  any of  the provisions of sub-
section (2) of section 17 and he ti.iall so certify, and whether any
or tne foregoing parties or persons have ever had a  strip raining
license or permit issued by any other  state or federal agency
revoked, or have ever forfeited a  strip  mlninc bond  or a security
deposited In lieu of a bond and if so, a detailed explanation of
tne facts Involved In each ease must he  attached;

     (h)  the names and addresses  of any person who are engaged In
•trip raining activities on behalf  of the applicant;

     (1)  the annual rainfall and  the  direction and  average velocity
of the prevailing winds in the area where the applicant has requested
a permit;

     (j)  the results of any test  borings or  core samplings which
the applicant or his agent has conducted on the land to be affected,
including the nature and the depth of  the various strata or over-
burden and topsoil, the quantities and location of subsurface water
and Its quality, the thickness of  any  mineral seem,  an analysis of
the chemical properties of such minerals, including  the acidity,
sulphur content, and trace mineral elements of any coal seam, as
well as the britlsh thermal unit (B.T.U.) content of such  seam, and
an analysis of the overburden, Including topsoil.  If test borings
or core samplings are submitted, each  permit  application shall  con-
tain two (2) copies each of two (2) sets of geologic cross-sections
accurately depicting the known geologic  makeup beneath the surface
of the affected land.  Each set shall  depict  subsurface conditions
at five hundred (500) foot Intervals across the surface and  shall
run at a ninety (90) degree angle.'to the other set.   Each  cross-
section shall depict the thickness and geological character  of  all
known strata beginning with the top soil;

     (k)  the name and date of a daily newspaper  of  general  circula-
tion within the county in which the applicant has prominently publish-
ed an announcement of his application  for  a  strip mining permit,  and
a detailed description of the area of  land to be  affected  should a
permit be granted;

     (1)  such other or further information  as  the  department may
require.

     (3)  The application for a permit shall  be accompanied by two
(2) copies of all maps meeting the requirements of the subsections
below.  The maps shall:

     (a)  identify the area to correspond with the application;

     (b)  show any adjacent deep mining and the boundaries of sur-
face properties and  names of owners of record of the affected area
and within one thousand  (1,000) feet  of any part of the affected
area;

     (c)  show the names  and locations of all streams, creeks, or
other  bodies of water, roads, buildings, cemeteries, oil and gas
wells, and utility lines  on the area  of land affected and within
one thousand  (1,000) feet of such  area;

     (d)  show by  appropriate markings the boundaries of the area
of  land  affected,  any cropline  of the seam or deposit of mineral  to
be  mined, and the  total  number of acres involved In the area of
land affected;

      (e)   show  the date  on which  the  map was prepared and the north
point;

      (f)  show  the drainage plan  on and away from the area of  land
 affected.   This plan shall Indicate the directional flow  of  water,

                           SENATE  BILL NO. 90
                            181

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constructed dralnways, natural waterways used for drainage, and the
streams or tributaries receiving Vie discharge;

     (g)  show the proposed location of waste or refuse  area;

     (h)  show the proposed location of temporary subsoil  and  top-
soil storage area;

     (l)  show the location of test boring holes;

     (J)  show the surface location lines of any geologic  cross-
sections which have been submitted;

     (k)  show a listing of plant varieties encountered  In the area
to be affected and their relative dominance In the area, together
with an enumeration of tree varieties and the approximate  number  of
each variety occurring per acre on the area to be affected,  and the
locations generally of the various kinds and varieties of  plants,
including but not limited to grasses, shrubs, legumes, forbs and
trees;

     (1)  be certified as follows:  "I, the undersigned, hereby
certify that this map is correct, and shows to the best  of my  know-
ledge and belief all the Information required by the strip raining
laws of this state."  The certification shall be signed  and notarized.
The department may reject a map as Incomplete if its accuracy  is  not
so attested;

     (m)  contain such other or further information as the depart-
ment may require.

     (1)  In addition to the information and maps required above,
each application for a permit shall be accompanied by detailed plans
or proposals showing the method of operation, the manner,  time or
distance, and estimated cost for backfilling, grading work, hlghwall
reduction, topsoillng, planting, revegetating, and a reclamation  plan
for the area affected by the operation, which proposals  shall  meet
the requirements of this act and rules adopted under this  act.

     (5)  An application fee of fifty dollars ($50) shall  be paid
before the permit required in this section shall be Issued. The
operator shall file with the department a bond payable to  the  state
of Montana with surety satisfactory to the department in the penal
sum to be determined by the board (on the recommendation of the
commissioner) of not less than two hundred dollars ($200)  nor  more
than twenty-five hundred dollars ($2,500) for each acre  or fraction
thereof of the area of land affected, with a minimum bond  of two
thousand dollars ($2,000), conditioned upon the faithful perform-
ance of the requirements set forth in this act and of the  rules of
the board.  In determining the amount of the bond within the above
limits, the board shall take into consideration the character and
nature of the overburden, the future suitable use of the land  In-
volved and the cost of backfilling, grading, highwall reduction,
topsolling, and reclamation to be required; but In no event shall
the bond be less than the total estimated cost to the state of
completing the work described in the reclamation plan.

     Section 7.  The department may increase or reduce the area of
land affected by an operation under a permit on application by an
operator, but an Increase may not extend the period for which an
original permit was Issued.  An operator may, at any time  within
one (1) year from the date of issuance of the permit, apply to the
department for an amendment of the permit so as to Increase or
reduce the acreage affected by it.  The operator shall file an
application and map in the same form and with the same content as
required for an original application under this act and shall  pay an
application fee of fifty dollars ($50) and shall file with the
department a supplemental bond in the amount to be determined  under
section 6 for each acre or fraction of an acre of the Increase
approved.  If the department approves a reduction In the acreage

                          SENATE BILL NO. 9*»


                            182

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covered by the original or supplemental permit,  it  shall  release  th*J
bond for each acre reduced, but In nd case shall the bond be  re-
duced below two thousand dollars ($2,000), except as provided in
subsection (5) of section 6.

     Section 8.  (l)  On and after the effective date of  this act
prospecting by any person on land not included in a valid strip
mining permit shall be unlawful without possessing  a valid pros-
pecting permit Issued by the department as provided in this section.
No prospecting permit shall be Issued until tne  operator  submits  an
application, the application is examined, amended if necessary, and
approved by the department, and adequate reclamation performance
bond is posted, all of which prerequisites must  be  done in conformity
with the requirements of this act.

     (2)  An application for a prospecting permit shall be made in
writing, notarized, and submitted to the department in duplicate
upon forms prepared and furnished by it.  The application shall
Include among other things, a prospecting map and a prospecting
reclamation plan of substantially the same character as.required  for
a surface mining map and reclamation plan under this 'act.  The de-
partment shall determine, by rules and regulations, the precise
nature of such required prospecting map and reclamation plan.  Any
operator who Intends to prospect by means of core drilling shall
specify the location and number of holes to be drilled, methods to
be used in sealing aquifers, and such other information as may be
required by the department.  The applicant must state what types  of
prospecting and excavating techniques will be employed on the affect-
ed land.  The application shall also include any other or further
information the department may require.

     (3)  The application shall "be accompanied by a fee of one hund-
red dollars ($100).  This fee shall be used as a credit toward the
strip mining permit fee provided by this act if the area covered by
the prospecting permit becomes covered by a valid surface mining
permit obtained before or at the time the prospecting permit expires.

     (4)  Before the department gives final approval to the pros-
pecting permit application, the applicant shall file with the
department a reclamation and revegetatlon bond in a form and in an
amount as determined in the same manner for strip mining reclamation
and revegetatlon bonds under this act.

     (5)  In the event that the holder of a prospecting permit
desires to strip mine the area covered by the prospecting permit,
and has fulfilled all the requirements for a strip mining permit,
the department may permit the postponement of the reclamation of the
acreage prospected if that  acreage is Incorporated into the  complete
reclamation plan submitted  with the application  for a  strip  mining
permit.  Any land actually  affected by prospecting or  excavating
under a prospecting permit  and not covered by the strip mining re-
clamation plan shall be promptly  reclaimed.

     (6)  The prospecting permit  shall be valid  for one  (1)  year,
and shall be subject to renewal,  suspension, and revocation  in the
same manner as strip mining permits under this  act.

     (7)  The holder of the prospecting permit  shall  file with the
department the same progress  reports, maps,  and revegetatlon pro-
gress reports, as  are required of strip  mining  operators  under this
act.

     Section  9.   (1)  An application for a  prospecting or strip
mining permit  shall not be approved  by  the  department if there is
found on the  basis* of the  information set forth in the application,
an on-site  inspection, and an evaluation of the operation by the
department  that  the requirements of  the act or  rules will not be
observed or that the  proposed method of operation, backfilling,
 grading, highwall reduction,  topsolling, revegetatlon, or reclama-
 tion of the affected area cannot be  carried out consistent with  the
 purpose of this act.

                           SENATE BILL NO. 94
                             183

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«««.««    department shall not approve the application for
prospecting or strip mining permit where the area of land described
in the application Includes land having special, exceptional, crlti-
thi^ ?  unique characteristics, or that mining or prospecting on
that area would adveraely affect the use. enjoyment, or fundamental
«5 !£?iel °£ nelfhborl»8 land having special, exceptional, critical,
or unique characteristics.  For the purposes of this act. land Is
aerined as having such characteristics if it possesses special.
exceptional, critical or unique:

     (a)  biological productivity, the loss of which would Jeopord-
ixe certain species of wildlife or domestic stock; or

     (b)  ecological fragility, in the sense that the land, once
adversely affected, could not return to its former ecological role
In the reasonable foreseeable future; or

     (c)  ecological importance, in the sense that the particular
land has such a strong Influence on the total ecosystem of which It
Is a part that even temporary effects felt by it could precipitate
a system-wide reaction of unpredictable scope or dimensions; or

     (d)  scenic, historic, archeologic. topographic, geologic,
ethnologic, scientific, cultural, or recreational significance.  In
applying this subsection, particular attention should be paid to
the Inadequate preservation previously accorded Plains Indian
history and culture.

     (3)  If the department finds 'that the overburden on any part
of the area of land described in the application for a prospecting
or strip mining permit Is such that experience In the state with a
similar type of operation upon land with similar overburden shows
that substantial deposition of sediment In streambeds, landslides,
or water pollution cannot feasibly be prevented, the department
shall delete that part of the land described In the application
upon which the overburden exists.

     (1)  If the department finds that the operation will constitute
a hazard to a dwelling house, public building, school, church,
cemetery, commercial or institutional building, public road, stream,
lake, or other public property, the department shall delete those
areas from the prospecting or strip mining permit application
before it can be approved.

     Section 10.  (1)  As rapidly, completely, and effectively as
the most modern technology and the most advanced state of the art
will allow, each operator granted a permit under this act, shall
reclaim and revegetate the land affected by his operation.  Under
the provisions of this act and rules adopted by the board, an opera-
tor shall prepare and carry out a method of operation, plan of
grading, backfilling, highwall reduction, topsoillng and a reclama-
tion plan for the area of land affected by his operation.  In
developing a method of operation, and plans of backfilling, grading,
highwall reduction, topsoillng and reclamation, all measures shall
be taken to eliminate damages to landowners and members of the
public, their real and personal property, public roads, streams
and all other public property from soil erosion, landslides, water
pollution, and hazards dangerous to life and property.  The reclama-
tion plan shall set forth in detail the manner in which the appli-
cant intends to comply with this section and sections 11, 12 and
13 of this act.  The plan shall be submitted to the department and
the department shall notify the applicant by registered mall within
one hundred twenty (120) days after receipt of the plan and com-
plete application If It is or is not acceptable.  The department
may extend the one hundred twenty (120)days an additional one
hundred twenty (120) days upon notification of the operator In
writing.  If the plan Is not acceptable, the department shall set
forth the reasons why the plan Is not acceptable and It may propose
modifications, delete areas, or reject the entire plan.  A land
owner, operator, or any person aggrieved by the decision of the

                          SENATE BILL NO. 9«

                            184

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department may, by written notlc' ,  request  a hearing by the board.
/5S\ 2ar  8ha U notlfy tj»e person by registered mail within twenty
if ;•, aya after tne hearing of itr  decision.  Every reclamation plan
Shall be subject to annual review and modification.
          Ir> addition to the method of operation,  grading, back-
    w    highwall reduction, topsnlllng and  reclamation  requirements
or this act and rules adopted under this act.  the  operator,  con-
sistent with the directives of subsection (1)  of this  section
shall:

     (a)  bury under adequate fill all toxic materials,  shale,
mineral, or any other material determined by the department  to  be
acid producing, toxic, undesirable, or creating a  hazard;

     (b)  seal off, as directed by rules, any  breakthrough of water
creating a hazard;

     (c)  impound, drain, or treat all runoff  water so as to reduce
soil erosion, damage to grazing and agricultural lands,  and  pollu-
tion of surface and subsurface waters;

     (d)  remove or bury all metal, lumber,  and other refuse
resulting from the operation;

     (e)  use explosives in connection with  the operation only  in
accordance with department regulations designed to minimize  noise,
surface damage to adjacent lands and water pollution,  ensure public
safety, and for other purposes.

     (3)  An operator may not throw, dump, pile or permit  the dump-
Ing, piling, or throwing or otherwise placing any  overburden,  stones,
rocks, mineral, earth, soil, dirt, debris, trees,  wood,  logs or any
other materials or substances of any kind or nature beyond  or out-
side of the area of land which is under permit and for which a bond
has been posted under section 6, or place the materials described
In this section in such a way that normal erosion or slides brought
about by natural physical causes will permit the materials  to go
beyond or outside of the area of land which is under permit and for
which a bond has been posted under section 6.

     Section 11.  (1)  Area strip mining, a method of operation which
does not produce a bench or fill bench, is required.  All hlghwalls
must be reduced and the steepest slope of the reduced hlghwall shall
be no greater than twenty  (20) degrees from the horizontal.  High-
wall reduction shall be commenced at or beyond the top of the high-
wall and sloped to the graded spoil bank.  Reduction, backfilling,
and grading shall eliminate all hlghwalls and spoil peaks.  The area
of land affected shall be  restored to the approximate original
contour of the land.  When directed by the department, the  operator
shall construct in the final grading, such diversion ditches, depres-
sions, or terraces as will accumulate or control  the water  runoff.
Additional restoration work may be required by  the department accord-
ing to rules adopted  by the board.

      (2)  In addition to  the backfilling and  grading requirements,
the operator's method of  operation on steep slopes may be regulated
and controlled according  to rules  adopted by  the  board.  These rules
may require any measure whatsoever to accomplish  the purpose of
this  aet.

      (3)  All  available  topsoll shall be removed  In a separate
layer*  guarded from erosion and pollution,  kept in such a condition
that  It can  sustain vegetation of at  least  the  quality  and  variety
it  sustained prior to removal, and returned as  the top  layer after
the operation has been  backfilled and graded; provided  that the
operator shall accord substantially the same  treatment  to any  sub-
 surface deposit of material that  is capable,  as determined  by  the
 department,  of supporting surface vegetation virtually  as well as
 the present topsoll.

                           SENATE BILL NO. 91
                               185

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««. w   ^ ^S determlned *>y rules vf the board, time limits shall be
«tabllshed requiring backfilling, grading, highwall reduction,
topsolling, planting, and revegetation to be kept current.  All
oncirrilllns, grading, and topsolling shall be completed before
necessary equipment Is moved from the operation.

     (5)  When the backfilling, grading, and topsolllns have been
completed and approved by the departuent, the commissioner may
release so much of the bond which was filed for that portion of the
operation as the commissioner may determine, providsd that no less
than two hundred dollars ($200) per acre shall be retained by the
department until such time as the planting and revegetation is done
according to law and approved by the department, at which time the
commissioner shall release the bond In the remaining amount.
          An operator may propose alternative plans other than back-
filling, grading, highwall reduction, or topsoillng if the restora-
tion will be consistent with the purpose of this act.  These plans
shall be submitted to the department, and, after consultation with
the landowner, If the plans are approved by the beard and complied
with within the time limits as may be determined by the board as
being reasonable for carrying out the plinn, the backfilling, grad-
ing, highwall reduction, or topsolling requirements of this act may
be modified by the board.  An operator who proposes alternative plans
that will affect an existing permit shall comply with the notice
requirement of section 6 (2) (k).

     Section 12.  After the operation has been backfilled, graded,
topsoiled, and approved by the department, the operator shall pre-
pare the soil and plant such legumes, grasses, shrubs, and trees
upon the area of land affected as are necessary to provide a suit-
able permanent diverse vegetative cover capable of:

     (a)  feeding and withstanding grazing pressure from a quantity
and mixture of wildlife and livestock at leest comparable to that
which the land could have sustained prior to the operation;

     (b)  regenerating under the natural conditions prevailing at
the site, including occasional drought, heavy snowfalls, and strong
winds; and

     (c)  preventing soil erosion to the extent achieved prior to
the operation.

     The seed or plant mixtures, quantities, method of planting,
type and amount of lime or fertilizer, mulching, irrigation, fencing,
and any other measures necessary to provide a suitable permanent
diverse vegetative cover shall be defined by rules of the board.

     Section 13.  The operator shall commence the reclamation of the
area of land affected by his operation as soon as possible after
the beginning of strip mining of that area In accordance with plans
previously approved by the department.  Those grading, backfilling,
topsolling, and water management practices that are approved In the
plans shall be kept current with the operation as defined by rules
of the board and a permit or supplement to a permit may not be
issued, if In the discretion of the department, these practices
are not current.

     Section 1
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     (c)  the date of planting e- seeding;

     (d)  the area of land plantsi;

     (c)  any other relevant information  the  department  requires.

     (2)  All planting reports shall be certified  by  the operator.

     (3)  Inspection and evaluation  for permanent  diverse vegetative
cover shall be made as soon as it is possible to determine if a
satisfactory stand has been established.   If  the department deter-
mines that a satisfactory permanent  diverse vegetative  cover has been
established, it shall release the remaining bond held on the area
reclaimed after public notice and an opportunity for  a  hearing; but
in no event shall such remaining bond be  released  prior to a period
of five (5) years from the initial planting provided  for in section
12 of this act.

     Section 15.  All legumes, grasses, shrubs,  and trees which are
planted or seeded on the area of land affected as  required by this
act or rules adopted under this act, becoxe the  property of the
landowner, after complete release of the  bond, unless the operator
and the landowner agree otherwise.

     Section 16.  Within sixty (60)  days  after each date of expira-
tion of a permit, the operator shall annually file with the depart-
ment a report stating the exact number of acres of land affected by
the operation, the extent of the reclamation  already  accomplished
by him, and any other information required by the  rules of the
department and the board.  The report shall be accompanied by a
copy of the map filed with the original application which shall show
any revisions made necessary by results of the operation.

     Section 17.  (1)  If any of the requirements  of  this act or
rules or orders of the department and the board have  not been comp-
lied with within the time limits set by the department  or the board
or by this act, the department shall serve a  notice of  noncompliance
on the operator, or where found necessary, the commissioner shall
order the suspension of a permit. The notice or order  shall be
handed to the operator in person or  served by registered mall add-
ressed to the permanent address shown on  the  application for a
permit.  The notice of noncompliance or order of suspension shall
specify in what respects the operator has failed to comply with this
act or the rules or orders of the department  and the  board.  If the
operator has not complied with the requirement set forth in the
notice of noncompliance or order of suspension within time limits
set therein, the permit may be revoked by order of the  board and the
performance bond forfeited to the department.

     (2)  Any additional permits held by an operator whose mining
permit has been revoked shall be suspended and the operator is not
eligible to receive another permit or to have the suspended permits
reinstated until he has complied with all the requirements of this
act in respect to former permits issued him.   An operator who has
forfeited a bond is not eligible to receive another permit unless
the land for which the bond was forfeited has been reclaimed without
cost to the state, or the operator has paid into the reclamation
account a sum  together with the value of the bond, the  board finds
adequate to reclaim the  lands.  The department may not  issue any
additional permits to an operator who has repeatedly been  in non-
compliance or  violation  of this act.

     Section 18.  Where  one operator succeeds another at an uncom-
pleted operation, either by sale, assignment, lease, or otherwise,
the department may release the  first operator from all  liability
under  this  act  as to that particular operation  if both  operators
have been  issued  a permit and have  otherwise  complied with the
requirements of this  act, and the successor  operator assumes  as part
of his obligation under this  act, all liability for  the reclamation

                           SENATE BILL NO. 90
                            187

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of the area of land affected by the former operator.

«,«
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     (5)  This section does not create,  modify,  or affect  any
right, liability, or remedy other than as expressly provided In this
section.

     Section 23.   (1) A person or operator who violates  any of the
provisions of this act or rules or orders adopted  under  this act
shall pay a civil penalty of not less than one hundred dollars ($100)
nor more than one thousand dollars (11,000) for  the violation, and
an additional civil penalty of not less  than one hundred dollars
($100) nor more than one thousand dollars ($1,000) for each day
during which a violation continues, and  may be enjoined  from continu-
ing such violations as hereinafter provided In this section.   These
penalties shall be recoverable in any action brought in  the name of
the state of Montana by the attorney general In  the district court
of the first Judicial district of this state, in and for the county
of Lewis and Clark, or In the district court having jurisdiction
of the defendant.

     (2)  The attorney general shall, upon the request of  the  commis-
sioner, sue for the recovery of the penalties provided in  this
section for, and bring an action for a restraining order,  temporary
or permanent Injunction, against an operator or  other person violat-
ing or threatening to violate an order adopted under this  act.

     (3)  A person who willfully violates any of the provisions of
this act, or any determination or order adopted  under this act which
has become final Is guilty of a misdemeanor and  shall be fined not
less than five hundred dollars ($500) and not more than  five  thou-
sand dollars ($5,000).  Each day on which a violation occurs  consti-
tutes a separate offense.

     Section 24.  All hearings and appeal procedures shall be  in
accordance with sections 62-4209 through 82-4217.

     Section 25.  If a part of this act Is Invalid, all valid parts
that are severable from the invalid part remain In effect.  If a
part of this act Is Invalid in one or more of Its applications, the
part remains In effect In all valid applications that are severable
from the Invalid applications.

     Section 26. Sections 50-1018 through 50-1033, R.C.M.  1947, are
repealed.

     Section 27. Every operator shall within ninety  (90) days after
the effective date of this act file with the department an applica-
tion for a permit.

     Section 28.  Ninety  (90) days after the effective date of  this
act, the state shall proceed to cancel, according to  their terms,
all existing contracts entered Into pursuant to chapter 245,  laws  of
Montana, 1967.   If the contract does  not provide  according to its
terms,  for the cancellation, It shall be terminated  and void  within
two hundred seventy  (270) days from the effective date of this  act.

     Section 29.  This act is  effective on Its  passage  and approval.

                                    *Ul OOVONWNT MMTM6 OfWCfc 1*74—711 Ml '141 MOON NO •
                           SENATE BILL NO. 9t
                            189

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