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                    October 1974

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                                                   9O8R74OO2
                       ACCOMPLISHMENT PLAN

                           Region VIII

               U.  S. Environmental Protection Agency
                            Covering

               EPA Activities Relating to Oil Shale

                     (Colorado, Utah, Wyoming)
                         September, 1974
                       / Cooper Wayman /
                Director, Office of Energy Activities
ional Administrator
    David D. Emery
Assistant for Planning
    and Evaluation
                  Environmental Protection Agency
                           Region VIII
                  1860 Lincoln Street, Suite 900
                    Denver, Colorado 80203

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                              Abstract
     This Accomplishment Plan presents the rationale and allocation
of EPA resources to carry out Its responsibilities 1n light of major
oil shale development in the Rocky Mountain States of Colorado, Utah,
and Wyoming.  The Plan addresses primarily a regionally-coordinated
effort, although the magnitude of potential development calls for
additional participation by headquarters and other local and National
groups.

     The Plan emphasizes that, to be effective, an EPA Region VIII oil
shale program must be based on as comprehensive and accurate an
assessment of environmental impacts as possible, must be based on a use
of existing EPA, other Federal agency, State and local planning and
regulatory authorities, the development of selected, new authorities
and must be based on a coordinated and cooperative program that involves
Federal, State, and local entities.  The Plan also recognizes that to
be timely, data, partial results, and assessment methodologies must be
made available to those entities with responsibilities for decision making.

     The Accomplishment Plan details the manpower and monetary requirements
that Region VIII has projected as necessary to initiate a comprehensive
assessment of oil shale development.  The projections are based upon
specific tasks described in some detail in the text.  It should be noted
that many of the Items listed relate to efforts underway or proposed by
other EPA and by other agencies.  In most cases, the work effort and
funding shown would not perform all the tasks listed or inferred.  In
those cases the effort included in this Plan involves the expenditure
of small amounts that may lead toward or supplement a larger effort —
perhaps Involving funding from outside EPA.
                                   111

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                           TABLE OF CONTENTS
Section                                                        Page

      Abstract	111
      Table of Contents    	     v
      Preface	ix

I.    Introduction 	   1

      Energy Demand and Environmental  Protection  	   1
      An 011 Shale Environmental  Protection Program -
        Overview 	   3
      History of 011  Shale Development 	   5
      Physical Description of 011  Shale Resources   	   9
      Environmental Constraints	   .        .  .         11

II.   Objectives of an 011 Shale  Program 	  17

      Objectives of the Prototype Leasing Program   	  17
      Local, State, and Federal Entitles and Key Decision
        Points	18
      Overall EPA Objectives  In an Oil Shale Program ....    20

III.  Role of Region VIII  - EPA	21

IV.   Detailed Work Accomplishment Plans and Resources  ....  23
      Regional Organization,  Coordination, and  Management

          Regional  Coordinator 	  23
          Regional  Organizational  Options  ...        ....  23
          Specific Task Group Assignments  	      . .  27

            1.  Introduction	27
            2.  Task Group for Subject A - Mineral  Resources,
                Regional Geology  and Mining Processing  ....  27
            3.  Task Group for Subject B - Water Aspects  ...  28
            4.  Task Group for Subject C - Atmospheric
                Aspects	33
            5.  Task Group for Subject D - Surface Resources .  38
            6.  Task Group for Subject E - Social, Economic
                and Cultural  Aspects  	  41
            7.  Task Group for Subject F - Regional and
                National Energy Considerations  	  45

V.    Summary	50

VI.   Appendices   	53

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                           TABLE OF CONTENTS
                              (Continued)

List of Figures                                               Page

1     Typical View:  Piceance Creek Basin, Colorado  	    2
2     General Geographic Location of the Six 011  Shale
      Lease Tracts In Colorado, Utah and Wyoming  	    7
3     Book Cliffs — Near Anvil Points, Colorado  	    8
4     Drill Site 1n Exploration Program	10
5     Revegetatlon Research Plots, August, 1973,  Anvil
      Points, Colorado . .     	12
6     Spent Shale Disposal — Anvil Points, Colorado 	   14
7     Typical Urban Water Quality Problem  . .      	   15
                                  v1

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                           TABLE OF CONTENTS
                              (Continued)

List of Tables                                               Page
1     Result of 011 Shale Lease Sales as of
      October 1, 1974	6
2     Regional Coordinator Task Assignments  	   24
3     Task Group A — Mineral  Resources, Regional
      Geology and Mining Processing  ...     .        .  .   29
4     Task Group B — Water Aspects  .      . .            .  .   34
5     Task Group C — Atmospheric Aspects  	   39
6     Task Group D ~ Surface  Resources  .              ...   42
7     Task Group E — Social,  Economic and  Cultural  Aspects   46
8     Task Group F ~ Regional and National Energy
      Considerations	     .  .   49
9     Resource Allocation Summary  	   52
A-l   Schematic of a Proposed  011 Shale Resource Program
      Organization	         ....     .  .   60
A-2   Task Matrix — Proposed  Work Groups and Participants,
      011 Shale Resource Program 	   61

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                           TABLE OF CONTENTS
                               (Continued)
                                                                Page
Appendices	53
I.     Outline of Possible Technical Investigations/
       Coordination Structure for 011 Shale Development  .  .    .54
II.    EPA Authorities Related to Oil Shale Development  .... 64
III.   Water Guidelines — 011 Shale Environmental
       Advisory Panel  	 70
IV.    Air Guidelines — 011 Shale Environmental Advlsorv
       Panel	   83
V.     Recommended Parameters for Surface Water Quality
       Monitoring Around Prototype 011 Shale Lease Tracts.  ... 93

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                                  PREFACE


     Region VIII has given careful thought to the potential  environmental
Impacts associated with oil shale development and to the proper, timely,
and forceful role and mechanisms with which the Region will  address these
problems.  This Accomplishment Plan 1s a result of this thought and of
the Region's actual experiences with coal and oil shale development to
date.  The Accomplishment Plan has as Its main themes:  (1)  the adequate
and comprehensive collection and analysis of data related to methodologies,
alternatives, and environmental parameters; (2) the full and timely use
of available EPA planning, control, and analysis programs; and (3)
cooperation with and support of relevant Federal, State, and local
governmental agencies both presently existing and as may be necessarily
created.

     Though scarcely completed, certain aspects of the Accomplishment
Plan, because of rapid changes and acceleration of development in the
region, already need revision and re-emphasis.  There 1s an urgent need
to immediately begin addressing the problems of community development,
community facility degradation, rapid urbanization of small  towns and
rural areas, and the general pressure of large and sudden influxes of
people on the quality of life of the area.  The need for regional
planning money, planning assistance and expertise, for construction grant
monies, community facilities planning, and for both a regional and
community level environmental planning program 1s evident.  Though the
main themes of the Accomplishment Plan are still relevant and will
serve as an overall guide to a Region VIII program, more immediate
actions and needs will be described which will be considered as the
first phase of the program.

     The manpower needs and Identified contracts and study efforts of
the Accomplishment Plan, though Including planning and program implementation
aspects, are oriented toward the gathering and analysis of environmental
data and examination of alternative technologies for development.  These
manpower and study needs should be considered 1n view of the immediate
needs that will be described.

     The role of regional and community planning instituted with the
express purpose of achieving orderly development and control of the
environmental, community facilities, land use, and social-economic factors
that make up the broad concept of quality of life, is a major and
pressing aspect of oil shale development.  Without the immediate
Instigation of planning on Federal, State and local levels, oil shale
related developments will occur In a haphazard and detrimental manner.
Participation by the public and Industrial Interests will be encouraged
as a vital part of these efforts.  Proper planning, backed by controls,
can go far to alleviate these Impacts.

                                      1x

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     The Accomplishment Plan has described the data and methodology
developments that will be the basis for any comprehensive planning
program.  It has also described the authorities and broad programs that
are the basis of EPA planning programs.  An Important area of concern
which will be explored as part of the Accomplishment Plan 1s the adequacy
of existing laws and authorities as related to prevention of environmental
degradation due to oil shale development.


Institutional Concerns


     A most Important and pressing need for Region VIII 1s to become
fully Involved 1n existing and future Inter-governmental Institutions
that have been created to address oil shale Impacts and Its problems.
These would Include the Federal Regional Council, the 011 Shale Environmental
Advisory Panel, the Federation of Rocky Mountain States, and other
organizations that may be created.

     Region VIII must be fully prepared to take a strong leadership
role in these Institutions. Any lesser role will probably assure that
environmental constraints, the major purpose of the Prototype Program
being their assessment, will not be adequately evaluated.  This effort
will require the devotion of considerable regional Input for the
proper execution of the EPA role.


State & Local Assitance


     EPA programs Involved in the community Impacts planning effort
would Include:  (1) Section 201 Facilities Planning, Section 208
Areawlde Planning, and Permits under FWPCA-72: (2) A1r Quality Maintenance
and Significant Deterioration Areas, Standards, and Permits under the
Clean Air Act; solid wastes and water supply programs; NEPA and the EIS
process; and other authorities.  These program efforts with their wide
range of Influence must be coordinated Into a truly active planning effort
that meshes media and that results in enforceable plans that are
implemented.

     On a larger regional environmental planning basis involving present
EPA programs, the same authorities as listed for community Impacts
would apply but would be a sub-set of the larger river basin planning,
airshed, E.O. 11752, and NEPA efforts.  These larger regional planning
concerns would require expertise in land use, water quality, transportation
and environmental/natural resources.

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     A major aspect of an EPA environmental  planning effort will  be
the Influencing of and assistance to the planning and Investigative
efforts of other Federal, State, and local  agencies.  The previously
listed EPA programs already work in this manner but because of the
Institutional arrangements and pressing needs of oil shale development
specific mechanisms for EPA assistance need to be executed.

     Inter-governmental organizations may serve as an overall  planning/
coordination entity, as previously discussed.  For example, multi county
Councils of Government have been established in the oil  shale  area and
are presently developing their planning programs.  Region VIII should
be prepared to give full environmental/community impact/regional  land
use planning Input into these programs.

     Construction grants for wastewater treatment facility construction
will be an Important EPA concern.  Area communities, many already at or
beyond treatment capacity, will be severely impacted by the large influx
of people.  It 1s estimated that $14 million will be required  for
construction of treatment works to meet the needs of the Prototype Lease
Program.  Present state construction grant allocations do not  meet
present needs.  Consequently, a means to provide wastewater treatment
construction funds to the oil shale impact area needs to be defined.
The possibility of establishing a national  priority and earmarking such
funds should be explored.


Summary of Resource Needs


     The attached Accomplishment Plan provides for EPA resources to
principally conduct technical Investigations and monitoring related to
reglonwlde environmental aspects of oil shale development.  These EPA
resource needs are summarized in the following table.  These are to be
utilized to support those planning and regulatory entities with
responsibilities 1n the three-State area of the oil shale resource.

              Oil Shale Accomplishment Plan Resources Summary


                             FY 1974    FY 1975    FY 1976    FY 1977

       Man Years                1.2        8.00      11.68      15.12

       Contract Support                 $300K      $637K      $957K
                                    x1

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     The following table summarizes estimated additional resource
needs for direct state and local assistance for environmental planning
and construction related to EPA authorities.

                     State and Local Assistance Needs

                          Planning and Management
           Inter-governmental Coordination*       $  100.000

           AQMA Planning                             300,000

           208 Planning                            1,250,000

           303(e) Planning                           300,000

           Solid Wastes Planning                     175,000

           Assistant to Local COG's                  500,000
                                                  $2,625,000


           *  Funded - FY 1974 to Colorado West COG
In addition to financial assistance, direct personnel assignment to
Inter-governmental agencies such as the Council of Governments 1s
considered a desirable approach.  Such assignment could be either
through Inter-governmental personnel assignment or by assigning EPA
personnel to the field.  Three positions for this purpose would be
considered a minimum effort.  One person has already been assigned to
work with the Western Colorado Council of Governments.

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                              INTRODUCTION
Energy Demand and Environmental Protection

     National fuel shortages have focused attention on the critical
role that the nation's energy supply plays In national affairs.   The
so-called "energy crisis" has revolved around a relatively sudden
recognition by the public and by government that problems of energy
supply, energy costs, energy conservation, and the environmental
constraints Involved 1n energy exploitation are national  Issues  of
great and Immediate Importance.

     There has been much concern 1n the face of this "crisis" that a
crash program based on a "full-speed-ahead" philosophy of energy
exploitation would prevail.  Though much of this sentiment still  exists,
more recent events and an easing of the crude oil shortage have  allowed
for a more rational analysis of an energy program based upon wise use
and conservation of the nation's energy resources.  The critical  role
of environmental protection and Its emphasis on the best use, for the
greatest good, and for the long-run, of the nation's resources Is being
asserted In a positive manner and 1s assuming Us proper role and
prominence in national affairs.

     The fact that short-term energy considerations have not been
allowed to overwhelm legitimate environmental protection concerns
attests to the role and the high regard with which the American  people
hold the quality of the nation's environment.  It now becomes a  duty
of EPA to carry on existing programs and to Initiate new ones that
will assure the protection of this environment and the consideration
of the long-term quality of life of the nation while protecting  its
environment and conserving Its vital energy resources.

     Region VIII of the Environmental Protection Agency, comprised of
the States of Colorado, Utah, Wyoming, Montana, North Dakota, and
South Dakota, is the scene of the energy demand-environmental concerns
dilemma.  The Region contains vast reserves of oil shale, coal,  uranium,
oil and natural gas (much 1n formations characterized by low permeability).
At the same time the Region is the scene of some of the nation's most
valuable and least spoiled environmental resources.  Taken together —
growing energy demand and public desire to protect environmental values —
these two aspects will tax to the fullest extent the Environmental
Protection Agency, Its environmental protection programs, and those
entities 1n the States with planning and regulatory responsibilities.
Figure 1 gives an Idea of the current status of the oil shale lands
in Colorado.

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I\J


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An 011 Shale Environmental Protection Program - Overview
     Exploitation of the various energy resources of Region VIII and
the secondary Impacts caused by and associated with this development
promise to be the primary challenge and threat to the environmental
quality of the Region.  Energy development 1n response to national
demand 1s accelerating and the nature and quality of the environment
over large areas is already stressed.  Environmental protection
programs and planning and control efforts must be comprehensive,
regionally based, and innovative to prevent wholesale degradation.1

     Oil shale exploitation and the environmental effects associated
with 1t — both on-site (primary) and off-site (secondary) — will  be
major challenges.  Meaningful objectives, program elements, program
focal points, resource needs, data gaps, etc., must be ascertained  now
and a comprehensive planning effort directed at oil shale development
undertaken.

     Already involved in the comprehensive Northern Great Plains
Resources Program — an interagency inventory of coal resources,
developmental possibilities, and environmental and social/economic
constraints and Impacts in the coal areas of Montana, Wyoming, and
North and South Dakota2 — EPA needs to initiate a program backed by
similar effort and planning and implement a policy of investigation  and
assistance with regard to oil shale developments in Colorado, Utah,
and Wyoming.

     The oil shale problem is first a regional problem and thus only
a regional approach that considers secondary impacts will be effective.
Planning efforts directed at site-specific problems will be most
important but must fit in with an overall program that is aimed at the
larger impacts -- growth, population, watershed, air shed, salinity,
etc. — and their cumulative effects.  Regional planning efforts will
be the key to effective management of the area.

     Because of the imminence of oil shale development — Federal
leases have been issued, private development is underway, companies
are tooling up and preparing actual mining plans, etc. — there 1s a
r.This is not to say that the quality of the western environment has
never before been stressed.  The mining that fouled the environment in
the past also opened much of this country to those of us who enjoy its
beauty and who populate Us urban areas.  Fortunately, the area has sorbed
many of these Impacts.  Now, however, the potential for stress 1s greatest.
The geographic concentration of such Industrial development as is
proposed and discussed is of a scale an order of magnitude greater than
previously experienced.
2.  "Accomplishment Plan - Northern Great Plains Resources Program",
Region VIII, EPA, Denver, Colorado

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great need for all levels of government, Including EPA Region VIII, to
give Immediate attention to problems of community development and
urbanizing pressures 1n the oil shale region.  The prevention of "sprawl
development" and other unregulated land uses, the amelioration of
overwhelming pressures on local facilities (schools, roads, sewage
plants, water supply, etc.) and the overall protection of the quality
of life In the region require that Immediate attention be given to these
problems that a sudden and large Influx of people Into the area will
bring.  Planning efforts for these problems, though an Intimate part
of the overall regional planning effort, need to receive high priority
In EPA efforts.  It 1s also critical that the decision-makers be made
aware of the probable Impacts of development, alternatives available to
them, and how their actions relate to National and other broad-scale
activities.

     The actual organizational structure needed by government to address
oil shale development, both Inter-agency and 1ntra-agency, 1s another
priority Item of our Oil Shale Program.  Such questions as the following
need to be addressed and answered soon:

          1.  Are existing intra-agency organizational structures
     adequate to address the problem?

          2.  Do existing structures need strengthening or should new
     ones be proposed?

          3.  What authorities should an Intra-agency group have?
     Data gathering?  Actual planning?  Controls?  Coordination?

          4.  Are existing EPA authorities adequate for the job of
     protecting the environment 1n the area?

          5.  What  authorities will planning and regulatory entitles
     need to do their jobs?

          6.  How does Region VIII EPA Interact and Influence relevant
     Federal, State and local entitles on environmental matters?

          7.  What type Inter-agency setup best meshes with the
     intra-agency organization and what type 1s most effective for
     the needed planning, data gathering and assessment, and controls
     functions?

     The planning and regulatory functions found under the various EPA
authorities have direct relationship to environmental planning and
control decisions.  The passage of national land use legislation (as
currently proposed) could give EPA a special review role over State
                                   4

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plans and planning functions and could even more specifically require
a strong environmental planning effort for the area.   Whether or not
this legislation 1s passed does not change the need for EPA, through
the existing FWPCA. Clean Air Act. NEPA, and Executive Order authorities,
to work with appropriate Federal, State, and local  entitles 1n planning
for the use of oil shale land on an environmentally acceptable basis.


History of 011 Shale Development


     The organic-rich sedimentary rocks known as kerogenetlc calcareous
marIstone of the Green River Formation of Colorado, Utah, and Wyoming
offer the greatest promise for oil shale production 1n the world.  Known
as the "rock that burns", to Indians and early settlers, knowledge of
oil 1n shale has a long history,  but 1n few countries has this fossil
fuel been economically and commercially exploited.   Lack of development
in the United States has been the result of abundant economical local
alternatives, Inexpensive foreign imports and tax laws favoring overseas
development.  Sufficient interest 1n the recovery of shale oil crude
developed 1n the late 60's so that in 1968, the Department of Interior
offered to lease three public oil shale tracts in Colorado.  (Oil shale
on public lands is a "leasable mineral" subject to the provisions of
the Mineral Leasing Act of 1920, as amended.  Responsibility for leasing
and managing public oil shale is vested in the Secretary of the Interior).
Response to this 1968 lease offer was poor and no land was leased.

     The present prototype leasing program which has been evolving since
1969 contained a plan to lease six 5120 acre tracts,  two each in the
states of Colorado, Utah and Wyoming.  (Results of the lease sales to
date are shown in Table 1 and lease locations are shown in Figure 2.)
If fully developed, this and limited private operations as presently
proposed might produce a 400,000 barrel/day industry by 1981.  Further
requests for additional leases, 1f granted, might establish a one million
barrel/day operation by 1985.4  This could be a small beginning on the
mining of an estimated 600 bill ton barrels of shale oil 1n high grade
and theoretically "recoverable" deposits.(Figure 3)
3.  We are told that one earlier settler discovered "oil shale" the hard
way.  It seems that when lighting the housewarming fire in his new
fireplace, the stone fireplace ignited and burned the new house down.
The stones were "oil shale".
4.  Predictions of total capacity at selected points in time are tenuous
at best due to the indestructible link between the price of oil and the
plans of industry.  As of October, 1974, preliminary plans show the
following production capacities for shale oil:  Colony Development
Corporation (private land): 50,000 bpd by 1978; Gulf-Standard (Prototype
tract C-a): 100,000 bpd by 1982; ARCO, The 011 Shale Corporation, Ashland
and Shell (Prototype tract C-b): 50,000 bpd by 1980; Phillips, Sun, White
River Shale 011 Corp, Sohio (Prototype tracts U-a and U-b): 100,000 bpd
by 1980; Occ1dental-Garrett: 75,000 bpd by 1980; Union Oil: 50,000 bpd by
1980.  This totals only 425,000 bpd by 1982.

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                               TABLE 1
        Result of 011 Shale Lease Sales as of October 1, 1974
Tract
Colorado C-a
Utah U-a
Utah U-b
Wyoming Vl-a
Wyoming W-b
  Date of Sale
January 8, 1974
Winning Bid
$210,305,600
Colorado C-b    February 12, 1974   $117,778,000
March 17, 1974

April 9, 1974
May 13, 1974
June 11, 1974
$ 75,596,800

$ 45,107,200
   Company
Standard of Indian
Gulf 011 Corporation
Atlantic Richfield
Ashland 011 Company
Shell 011 Company
The 011 Shale Corp.
Sun 011 Company
Phillips Petroleum
White River Shale 011
(a consort1on of
Standard 011 of Ohio
Sun Oil Company
Phillips Petroleum)
No Bids Received
No Bids Received

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   \   VMONTROSE COUNTY
                                       .J
                                   REGIONAL ENERGY DEVELOPMENT


                                 LJ  PRIVATE OIL SHALE DEVELOPMENT


                                 (J) FEDERAL OIL SHALE LEASE TRACTS
                  FIGURE 2
GENERAL  GEOGRAPHIC  LOCATION OF  THE SIX OIL
SHALE TRACTS IN COLORADO, UTAH, AND WYOMING

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Physical Description of 011  Shale Resource


     The oil shale deposits  of Colorado, Utah and Wyoming He beneath
25,000 square miles (16 million acres)  of land.   About 17,000 square
miles (11 million acres) contain oil  shale of potential  value for
commercial development In the foreseeable future.9  Some 80% of the
known higher grade oil shale reserves are located In Colorado, 15% 1n
Utah, and 5% 1n Wyoming.  Of the more than 11 million acres of oil
shale land potentially suitable for commercial development, about 70X
are public lands administered by the Department of the Interior.  These
public lands contain SOX of  the high-grade oil shale.  Extensive deposits
of sodium minerals such as dawsonite (an aluminum mineral) and nahcollte
(a potential sulfur oxide scrubbing agent) are associated with the oil
shale deposits.

     In previous years, the  U. S. Bureau of Mines and various private
companies have conducted pilot-scale operations to develop the technology
for mining and retorting oil shale.  Conventional oil shale processing
consists of the following operations:  mining, crushing, retorting,
refining (Including upgrading), and waste disposal.  011 shale may be
mined by either surface or underground  methods.   At least three
significantly different oil  shale surface retorting processes have been
developed.  Shale oil will be partially refined or "upgraded" on site
and transported via pipeline to another area for final refining or use.
Sulfur oxides, saline water  and spent shale (because of Its bulk, salinity
and color) present the major known waste control problems from the
primary effort.

     In addition to conventional technology, in-situ techniques have
been tested to retort the oil shale underground.6  The in-situ
technique could eliminate many environmental problems associated with
mining, surface retorting and waste disposal.  However, some in-situ
techniques Involve substantial underground mining.  Of most significance,
though, Is that 1n-s1tu technology 1s not generally thought to be
developed to the extent that prediction of technical or economic success
Is warranted.

     011 shale development at the one million barrel per day level of
operations will require up to 80,000 acres over a 30-year period for
mining, processing, waste disposal, utility corridors, urban needs and
o.Final Environmental Statement for the Prototype Oil Shale Leasing
Program, U.S. Department of Interior, Volume I, page 1-2.
6.  The shale 1s heated underground and little solid material 1s brought
to the surface.

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other associated facilities.7  About 50,000 acres will  be required
for production, 10,000 acres for utility corridors, and up to 20,000
acres for urban expansion.8


Environmental Constraints


     The environmental Impacts associated with oil shale development
are potentially severe.  A large region of the western  United States,
a region noted for Its high quality environment, will be subjected to
stresses and changes that must be ascertained and controlled to the
greatest possible extent.  Yet the impacts will be relatively concentrated
by the geographical smallness of the area.

     The Prototype Leasing Program is first concerned with the on-site
primary impacts Involved in the lease areas.  The off-site impacts,
however, will be ones that a long-term and regionally based environmental
program must also address.  In reality, the dividing line between on-site
and off-site environmental impacts, is something of an  artificial
division and the line between such "primary" and "secondary" is not
clear.  As has been noted, the environmental Impacts from oil shale
exploration, mining, and refining and the associated population increases,
and urbanization with attendant Increases in recreational pressures
are Interrelated.  Thus a comprehensive regional approach is required.

     The following is a partial list of potential environmental impacts
of concern to EPA:

          (1)  Disposal of "spent shale" or the host rock once the
     kerogen has been removed — concerned primarily with saline
     character of material, sediment yield from drainage system thrown
     Into further disequilibrium, and vegetative growth and viability.
     (Figure 5)  Surface and underground disposal.

          (2)  Ability to pre-plan, control, maintain and regulate
     community services for growing cities.  Choices as to ultimate
     size of urban centers.  Lack of funding in early  stages of oil
     shale development.

          (3)  Water pollution from disposal of saline  ground water,
     non-point pollution from sedimentation caused by  land disturbance,
     leaching of spent shale, and possible process water effluents.
7.Final Environmental Statement for the Prototype Leasing Program,
Department of Interior, Volume I, page 111-23.
8.  Ibid, page 111-25.
                                 11

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          (4)  Salinity Increases caused by consumptive  use  of surface
     waters.  Consumptive use of area water will  affect  Colorado
     River salinity levels because of salt concentrating effect (water
     needs estimated at 123,000 acre-feet/year  for a  one million  barrel
     per day Industry;  16,500 acre-feet/year for  associated  domestic
     needs; and 19,000  acre-feet/year for associated  electrical power
     production.9

          (5)  Possible water and air quality problems from  heavy
     metals, carcinogenic materials, and municipal  wastewaters discharges.

          (6)  Land use changes such as  land disturbance from  mining
     and processing activities; wildlife disturbance  (critical male
     deer, raptor, mountain Hon); loss  of agricultural  land.

          (7)  A1r quality degradation from shale processing,  refining,
     and fugitive dust, Including (a) participates from  mining,
     crushing, and general solid materials handling;  (b)  burning of
     retort off-gases from shale ungradlng or for generating on-s1te
     power; and (d) possible air contamination  due to surface  vehicles
     and traffic.  The  major potential pollutants In  gaseous emissions
     from the plant Include sulfur dioxide, nitrogen  oxides  and to a
     much lesser extent, possible small  residual  concentrations of light
     hydrocarbons, potential carcinogens, and carbon  monoxide.

          (8)  Solid waste disposal problems resulting from  disposal
     of spent shale and other shale processing  residue.  (Figure 6)

          (9)  Population growth (estimate of 160,000 new people  in
     region by 1985) and attendant urbanization.  (Figure 7)

          (10)  Pressures on sewage treatment plants, local  Infrastructure,
     and air pollution  problems due to rapid population  growth in area
     towns.

          (11)  Increase in nonpoint water pollution  from erosion
     (construction, roads, vehicle use,  etc.) and possible proliferation
     of septic tank systems.

          (12)  Construction of water storage and conveyance facilities
     in scenic areas — attraction of secondary growth  around
     reservoirs.

          (13)  General Increase 1n air  pollution from  secondary
     Industrial and commercial sources.
9.Final Environmental Statement for the Prototype Leasing Program
Department of Interior, Volume I, page III-44.
                                 13

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          (14)  Conventional electrical generating plant expansion
     Involves Impacts on air, water, and land resources.

          (15)  General pressure and demands for Increased use of
     area recreational lands, both private and public (ski areas,
     wilderness, hunting and fishing resources).

          (16)  General Increased demand and use of area resources
     timber, minerals, land, building materials, etc.

          (17)  Expansion and new construction of roads, airports,
     railroads, and pipelines and associated Impacts.

          (18)  Surface effects of mining such as subsidence.

          (19)  Changes in the subsurface flow patterns in the mined
     areas.

     In summary, the land, air, water, biological, and human and
community Impacts associated with oil shale development will be major
concerns of a Region VIII environmental program.  These primary and
secondary Impacts will do much to change the nature and probably the
quality of the environment of a large region now noted for Us unspoiled
nature.  Even small-scale development such as that embodied in the
Prototype Program will change the present way of life significantly.
The complex regional nature of these Impacts will require a comprehensive
regionally-based program to minimize and avoid where possible environment
degradation from these Impacts.  The rapidly developing nature of the
Impacts associated with specific site Impacts — the Prototype Federal
Leases and local communities facing Immediate urbanizing pressures —
requires that a definitive program be undertaken now, while some time
remains.
                                  16

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                     OBJECTIVES OF AN OIL SHALE PROGRAM


Objectives of the Prototype Leasing Program
     Under the authority and guidance provided by the Mineral  Leasing
Act of 1920 and other public land laws, the responsibility for managing
and leasing public oil shale lands is vested in the Secretary of the
Interior.  The prototype 011 Shale Leasing Program has been formulated
to make available for private development under controlled conditions
a limited number of leases (six) of not more than 5*120 acres each.
Specifically the objectives of the program are to:10

     (1)  Provide a new source of energy that will  increase the
          range of energy options available to the Nation by
          stimulating the development of commercial oil shale
          technology by private industry;

     (2)  Insure the environmental integrity of the affected
          areas, and concurrently, define, describe, and develop
          a full range of environmental safeguards and restoration
          techniques that can be incorporated into the planning
          for a possible mature oil shale Industry in the future;

     (3)  Permit an equitable return to all  parties in the develop-
          ment of this public resource; and

     (4)  Develop management expertise in the leasing and supervision
          of oil shale development in order to provide the basis
          for future administrative procedures.

     We view it as the opportunity to more thoroughly quantify the effects
of oil  shale extraction and use on the environment.  In our opinion, no
significantly larger development of oil shale should take place until  the
Prototype Program provides sufficient data for public consumption that
show the larger development to be acceptable.
     In summary, the Prototype Program will  serve to stimulate the
development of a new source of energy, develop this new source by
encouraging the Involvement of private Industry, and to do so in a
manner that should do the least damage to the high quality environment
of the oil shale region.
10)  Final Environmental Statement for the Prototype Oil  Shale Leasing
     Program, Dept. of Interior, Volume III, Page 1-1.
                                     17

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     Further, the Prototype Program is to provide the results and
Informational back-ground that will be used to formulate comprehensive
resource utilization programs and regional land use plans.  Additional
lease of public oil shale lands will not be considered until the
prototype development program and resulting impacts under this prototype
program have been fully evaluated.1' (Emphasis added)
     It must be emphasized that the primary purpose of the Prototype
Program is to gain an understanding of the environmental impacts of
oil shale development.  If these impacts are found to be unmanageable
and to out-weigh benefits then further large-scale development of Federal
leases will not be allowed until controls are developed.
     It is clear that EPA's role in the Prototype Program, as it will be
in any future oil shale development, will be to make certain that all
environmental factors, constraints, and trade-offs are adequately analyzed,
discussed and evaluated.  EPA must utilize all its legislative authorities
to make certain that the environment is given adequate protection.  At
the same time, EPA must evaluate new requirements for legislation.


Local. State, and Federal Entities and Key Decision Points


     Oil shale development, both the Prototype Program and larger full-
scale development, will impact and in turn be impacted by a number of
local, State, and Federal entities.  Because they must make important
decisions concerning oil shale development, these entities need to be
identified.  The various entities and the general realm of their respon-
sibilities include:

     (1)  Department of Interior - responsible for the Oil Shale Leasing
          Program and most other resource development decisions on oil
          shale region public lands, further subdivided into:

          (a)  Bureau of Land Management - responsible for actual oil
               shale leases, controls most public lands and mineral
               rights  off the Prototype leases and private lands,
               that would be impacted by roads, pipelines, and some
               secondary energy development;

          (b)  Bureau of Sport Fisheries and Wildlife - in charge of
               Federal fish and wildlife programs and key involvement in
               protection of important fish and wildlife values in oil
               shale region;

          (c)  Bureau of Outdoor Recreation - involvement in public rec-
               reational aspects (wild rivers, hiking, wildlife, etc.)
               in the high recreation value oil shale region;
11)  Ibid, page 1-13.
                                      18

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     (d)  U.  S.  Bureau of Mines  - Important functions In technology
          development for energy resources  - over-all energy use
          and conservation programs;

     (e)  U.  S.  Geological Survey -  provides the mining supervisor
          who will  possess wide  ranging powers  (Including those over
          environmental  matters) for the 011 Shale Lease Program -
          also has  Important resource evaluation and water quality
          monitoring functions;

     (f)  U.  S.  Bureau of Reclamation - lead agency In development
          of water  supply needed for oil shale  development;

(2)  Department of  Agriculture - the  U.  S.  Forest Service will  be
     Involved with  secondary Impacts  from timber, mineral, water,
     and recreational demands on regional National  Forest lands.
     The Soil Conservation Service will  probably be involved in
     watershed projects  and erosion  prevention  from secondary
     developments;

(3)  Federal  Energy Administration -  FEA involvement in the oil  shale
     program will be a comprehensive  one aimed  at the larger picture
     of national energy supply and use;

(4)  Atomic Energy  Commission -  AEC  is involved in energy development,
     including possible  oil  shale development,  by nuclear means  -
     Important energy development alternative programs are in the
     realm of the AEC;

(5)  States of Colorado, Utah, and Wyoming  - State government -
     its various organizational  entities, administration, judicial,
     and legislative realms - and its possession of much of the
     actual police  power over private lands is  a major focal  point
     Involved in oil shale development.   Secondary off-site development
     and associated impacts will be  especially  pertinent to State
     government in  the oil shale region. Federal environmental
     programs Include important  State involvement and therefore,  much
     of the actual  local implementation of  Federal  environmental
     programs reaches the local  level via State programs and implemen-
     tation;

(6)  Local government in Colorado, Utah, and Wyoming - Municipal  and
     county governments  in the oil shale region will bear the brunt
     of most off-site or secondary Impacts  from development and
     attendant population and economic activity increases.  Land use
     planning  master plans, zoning,  subdivision regulations, etc.
     are within the realm of these local entities.  The inclusion of
     environmental  programs Into planning and decision processes on
     non-Federal lands must Involve  and be  directed toward these local
     governments.
                                 19

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     Each of the listed agencies and levels of government has Important
controls and Influence over the environment associated with oil shale
development.  Local and State agencies have primary authority over
secondary Impacts on private lands, though Federal agencies have Important
functions in this area, also.  The Federal agencies listed above have
many authorities and responsibilities for the problems associated with
shale development.  The major point Is - EPA needs to fully recognize
the authorities and responsibilities of all concerned levels of government
1n the oil shale region and be prepared to work with them on a compre-
hensive program of environmental protection.
     The actual organizational structure under which EPA works with and
through these Federal, State, and local organizations could be one or a
combination of several options.  These would Include:  (1) a structure
similar to that of the Northern Great Plains Resource Program;12 (2) a
Northern Great Plains Resource Program type structure with the Inclusion
of actual planning and control function; (3) creation of some new multi-
agency, Federal-State organization based on any number of jurisdictlonal and
Institutional constraints; and, (4) the working through, but strengthening
of, existing organizations and programs (River Basin Planning, Area-wide
Planning under FWPCA-72-AQMA under the Clean Air Act - the Federal Regional
Council - River Basin Commissions, etc.) that now exist.
     With the large-scale transfer of Federal funding to various activities
in the oil shale area, it is necessary to provide the most effective method
of utilizing these funds.


Over-all EPA Objectives in an Oil Shale Program


     Over-all, the Environmental Protection Agency's main objective in
an oil shale development program is to make certain that all environmental
values and factors are taken fully Into consideration in all planning and
decision making related to oil shale development.  Concurrently, EPA will
follow its mandate in providing for protection of the environment utilizing
its legislative authority.
     In relation to this, EPA will provide a full analysis of long-term
environmental and associated quailty-of-life values and impacts and assure
that they are included to the fullest degree possible in National and
Regional energy development decisions.  This effort will provide local,
State and Federal entities and the public with a picture of (1) an analysis
of all possible environmental impacts from shale development, (2) true costs
of energy use and oil shale development, (3) a proper evaluation of possible
energy - environmental trade-offs, and (4) the Information needed for long
range decision making on this vital aspect of energy development..  The
analysis must contain common denominators with which comparisons may be
made to other energy levels In other situations.

12.  Accomplishment Plan, Northern Great Plains Resources Program, 1974,
Region VIII» EPA, Denver, Colorado, page 133.
                                      20

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                      ROLE OF REGION VIII - EPA

    Oil shale development Is a national  Issue - the size and
Importance of the resource make 1t so.   Over-all energy/environmental
related strategy will, therefore, require the Involvement of many
EPA offices.  Actual on-the-ground Involvement and a broader area
of program development and Implementation will be the primary function,
however, of Region VIII EPA.  Not only will program direction come
from the Washington level to the Regional office, but the reverse
flow of information and program elements from the Region to the
National level will be critical to the formulation and Implementation
of over-all programs.  A joint National-Regional effort 1s envisioned
that will draw upon the abilities and programs of each level.  Direct
Involvement In oil shale environmental Impact analysis, planning, and
control will be carried out by the Regional office.
    The broad areas of EPA interest in oil shale development were
listed in Part C, OBJECTIVES OF AN OIL SHALE PROGRAM.   This section
will more specifically spell out Region  VIII-EPA involvement in an
oil shale program.  Major elements of this program Involvement include:

    1.  A vigorous application of the relevant legal  authorities under
        which EPA operates.  By being the "watch dog"  agency EPA
        can help-to Insure a full consideration of all environmental
        factors associated with oil shale development;

    2.  A closely-coordinated effort with other interested agencies
        to collect and analyze environmental dtita required by all
        decision makers involved 1n oil  shale development activities.
        This effort will Include the collection of baseline data
        as well as prototype monitoring  data, and will include
        distribution of the data to the  appropriate decision makers.

    3.  A comprehensive regional planning effort consisting of the
        following elements:  (a) institutional arrangements that
        would simplify the timely participation of Individual citizens
        and local, state and federal governments in providing Input
        to the oil shale development process; (b)  a close working
        relationship among all Interested groups, including local,
        state, and federal agencies, to  ensure the proper consideration
        of environmental values related  to development decisions;
        (c)  a definition of all authorities and key decision points
        related to oil shale development which must be coordinated among
        the appropriate planning groups  and regulating agencies; (d)  a
        flexible EPA program structure which will facilitate timely
        and influential inter-action with other agencies having key
        decision points or with other groups requiring information
        and/or assistance; and (e)  the  fuller use of EPA planning
        functions and EPA support of other Federal, State, and local
        planning organizations on environmental concerns.
                                    21

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    4.  Participation 1n Inter-agency programs to the extent of
        possibly being the lead agency for environmental considerations
        related to water, air, or solid waste groups, with further
        input Into other related program areas (socio-economic,
        wildlife, etc.).

    5.  Provision of a regional focal point for the Integration of
        all EPA agency-wide program involvement (HQ, NERC's, OR&D,
        A & W, Enforcement, etc.).

    6.  Participation in the process of formulating a regional and
        national strategy on energy development, use, and conservation.

    In summary, EPA through its Region VIII offices will set up an
oil shale program that will provide the means and the methods to fully
evaluate the environmental problems associated with oil shale develop-
ment.  At the same time, Region VIII will undertake full involvement
in the ground-level of decision making by involved agencies and groups
in order to assure the full consideration of environmental values in
activities in the oil shale region.  A true cost/benefit analysis and
development of alternatives and mitigative measures for the environment
will be provided.
    The role of Region VIII EPA will be that of assuring the proper
analysis of environmental impacts associated with both on-site and
off-site oil shale development-related impacts.  Region VIII will
most importantly insure that this analysis of environmental impacts
will be fully considered in all decisions related to oil shale develop-
ment.  The Region will supply the cutting edge of EPA legal authorities
and planning functions to the base-level oil shale area resource manage-
ment and use decisions.  Importantly, the Regional office will work with
the National EPA office 1n formulating environmental-energy strategy as
it Involves oil shale.
    The regional office will not perform all the necessary work by
itself.  The limited staff will provide coordination for other EPA
efforts and will provide exput Input to programs such as those con-
ducted by the office of Research and Development of EPA.
                                     22

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           DETAILED WORK ACCOMPLISHMENT PLANS AND RESOURCES
          REGIONAL ORGANIZATION, COORDINATION, AND MANAGEMENT
Regional Coordinator


    The complex nature of the prototype and private development of oil
shale, the close alliance of this development with EPA responsibilities,
and the discharging of these responsibilities through EPA's Regional
offices document the need for the assignment of a technical oil shale
focal point or coordinator within the regional office.  The assignment
must involve a person with some technical  expertise in energy resource
development, mining, water resources development, earth and atmospheric
sciences, secondary impacts associated with development, and environmental
problems peculiar to the West and with demonstrated managerial capabilities,
The person should possess or be in a position to acquire the authority to
pursue EPA's objectives in monitoring oil  shale development.
    The oil shale coordinator must be able to devote essentially full
time to many oil shale problems.  He must have certain inter-divisional
authority to coordinate and implement regional inputs concerning oil
shale with such implementation limited to that authorized by the Accomp-
lishment Plan for oil shale.  He will also serve as a "Mason between
NERC, Division of Field Investigations, and R & D personnel who may or
should perform selected activities for Region VIII concerning oil shale
development.
    The Regional office will have, as outlined in this Accomplishment
Plan, certain individuals who will be assigned to work essentially full
time on oil shale activities within the Region, from periods ranging
from indefinately at a full-time rate, to part time, for as little as
a week.  While many of these activities will not be under the direct
supervision of the coordinator, it will be necessary for both the
individuals and the coordinator to consult frequently on EPA activities
related to oil shale.  When inter-divisional coordination and support
1s required, the coordinator will arrange such support within the frame-
work of this Accomplishment Plan.
    It is proposed that the coordination function utilize approximately
1.0 work years of effort in each fiscal year.  This amount includes
secretarial and other direct support functions.  (Table 2)


Regional Organizational Options
    The coordination effort required for a successful EPA oil shale
program is the critical element in any regional organizational structure
dealing with oil shale activities.  This effort has been detailed in the
previous  section.   In  addition to the regional coordination effort It has
been  estimated  that Region VIII should have at least seven work years of
effort  involved 1n  monitorinq all aspects of oil shale development
activities during FY 75.  The specific detailed tasks with which these
people  will  be  Involved are presented 1n tabular form 1n the  following
sections.


                                      23

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                                                        TABLE  2

                                                REGIONAL COORDINATION
r\>
      Activity

1.  Coordination of EPA technical activities concerning
    011 Shale Development 1n Region VIII.  Insure that
    all oil shale staff activities and normal program
    activities such as basin plans, air quality main-
    tenance areas, etc. are closely coordinated and
    cooperatively achieving EPA's objectives.  This
    Includes and requires 1nter-d1visional direction
    of activities.

2.  Coordination of responses to and solicitation of
    Information from the public and local sectors.
    This Includes assuring public participation in
    EPA oil shale activities.

3.  Review of Accomplishment Plan, objectives, and
    direction of EPA oil shale activities.

4.  Serve as special technical representative to Regional
    Administrator as 011 Shale Environmental Advisory
    Panel representative -- assist Regional Administrator
    1n Insuring EPA committee assignments on the panel
    are accomplished.
                                                                   FY  74
FY 75
FY 76
FY 77
                                                                                   1/2
                                                                                   1/8
                                                                                   1/8
                                                                                   1/4
               1/2
               1/8
               1/8
               1/4
             1/2
             1/8
             1/8
             1/4
       TOTAL:  Work Years
                                                                 0.0
 1.0
 1.0
 1.0

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    There are several ways that these people could be organized to
accomplish EPA's objectives regardina oil  shale development.   This
section briefly discusses the various organizational  options  available to
the region, and describes the current structure used  to coordinate oil
shale activities.
    The four organizational options discussed 1n the  following sections
are:

    1.  Establishment of another "coordinated" unit on an 1nterd1v1s1onal
        basis similar to the EPA regional  Northern Great Plains Resources
        Program (NGPRP) effort.

    2.  Selection of an existing regional  organizational entity in the
        operating division to coordinate oil shale activities with staff.

    3.  Establishment of an oil shale coordinator at  an upper management
        level operating out of a regional  Energy Office with  most staff
        assignments made through regular operating division channels.

    4.  Establishment of a new branch, section or division dealing with
        oil shale activities.

1.  Option one 1s to establish a "coordination office" within operating
    divisions consisting of one professional, with adequate clerical
    support, to coordinate most all EPA activities relative to oil shale.
    The remaining professional Input would come from  within the existing
    regional organization.  Persons with expertise required for certain
    projects would be asked to provide Input, as described in Accomplishment
    Plans such as this one and as deemed necessary by the coordinator.
    These persons could work full time or part time on oil shale problems,
    ideally with a mix of some full time to provide a wide base of eipertlse,
    continuity and priority 1n addition to providing  liaison  with other
    regional programs.  An example of this type organization  has existed
    within the region as the NGPRP.

2.  The second option Is to select an exlstlna organizational supervisor
    to function as a coordinator of oil shale activities.  As an interim
    measure this would allow coordination to begin Immediately with a
    minimum amount of disruption and lost time.  It would have the
    advantage of an absolute minimum of duplication of existing programs,
    as all staff would come from existing program and no new  organizational
    entities would be formed.  However, it would have the potential dis-
    advantage of competition with other supervisory personnel in all  divisions
    for expertise to work on oil -shale problems.

3.  A third alternative structure would be to establish a regional oil
    shale coordinator at an upper management level operating  out of an
    Office of Energy Activities (OEA) responsible for coordinating all
                                     25

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         regional  enerqy activities.   The  OEA would  be  closely associated
         with the  Administrator's  Office 1n  order to provide direct and
         timely advice  on  energy/environment matters.   For the purpose of
         this paper, we will  assume an OEA staff consisting of about three
         professionals, both  technical  and non-technical, plus clerical
         support.   It 1s assumed that  one  of the technical staff would be
         the full  time  oil  shale coordinator.   If the Energy Office consisted
         of only one managerial energy advisor  1t 1s strongly recommended
         that a competent  technical assistant be assigned to the advisor
         to assume day-to-day coordinating responsibilities related to
         oil shale activities.
         Staff support  for the oil shale coordinator would be drawn from
         all regional divisions as required.  Additional full time staff
         personnel  (overtarget) would  be required in addition to the staff
         support obtained  from existing regional  resources.  A distinct
         advantage of having  the coordinator located 1n the Energy Office
         would be  the ease of obtaining 1nter-d1visional staff support
         through the respective division directors.   Other advantages
         could accrue from the placement of  the coordinator near top level
         management where  an  overview  of oil shale and  enerqy problems
         might be  obtained, In addlton  to  the fact that division heads
         would be  routinely briefed 1n  staff meetings on the progress of
         oils shale activities as well  as  the additional support requirements.
         The coordinator would pass on  from  top level management the priorities
         for work  assignemnts to the divisions,  thereby eliminating competition
         from other programs.

    4.   The fourth oil shale organizational option  would be to establish
         a separate branch or section  1n an  existing, or perhaps new, division
         to handle all  oil  shale activities.  If a new  "Enerqy Resources"
         Division  were  formed the oil  shale  development problem would reside
         in a separate  section or branch in  parallel with other developing
         energy sources such  as coal, nuclear,  solar, qeothermal, etc.  The
         more likely situation would be for  a new branch or section to be
         formed within  an  existing division, with the branch or section
         chief to  be the oil  shale coordinator.   There  are both positive
         and negative aspects to this type of structure.

    After much deliberation, we have established an Office for Energy
Activities 1n the  Office  of  the Regional  Administrator.  This choice most
closely  resenbles  option  number 3.  The ongoing  NGPRP  coordination effort
has been moved to  that office and a staff of   five  professionals has been
provided for the  present.  Two branches exist  under the Director ~ one
for environmental  planning and the other  for the more  environmental sciences
and engineering phases of extraction and  use of fuels.  This office coor-
dinates  the energy-related activities  of  the operating divisions.  All new
requests for oil  shale efforts are directed to  that office.  The office has
the ability to respond directly to certain  types of requests and to provide
input to other requests for  outputs.
                                     26

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    In addition, it was decided that direct personal  asslanments  to
Intergovernmental agencies such as the Council  of Governments  was needed.
Therefore, as a start, one position was assigned to the Office of Energy
Activities, and filled with a person 1n Rifle to assist the Western Area
Council of Governments.  The OEA serves as the focal  point for such
assignments.


Specific Task Group Assignments


1.  Introduction

    The "Task Group Areas" which have been Identified as significant
areas of concern In developing a comprehensive program for EPA Involvement
in oil shale development are presented 1n the following section.   While
each "Subject Area" or "Task Group Area" is treated separately, certain
activities Identified under one "Subject Area"  may include, or be quite
similar to , those listed under one or more other areas.  An attempt has
been made to eliminate the duplication of resource allocation  in  these
areas, however.
    The descriptions of each task group are based upon EPA's concept
of the work to be performed.  However, these are not hard-and-fast
assignments to be performed by EPA alone.  Many of these activities will
be conducted by groups other than EPA.  Since this plan cannot adequately
address the activities of groups other than EPA, and can only  really
address those activities for which the regional office has a perspective,
the listings may appear inadeouate in places and too comprehensive to the
point of duplication 1n others.  The tasks described are those which the
regional office will either support for other entities, coordinate, pre-
cipitate, or accomplish on its own.
    It should be noted that in the followina tables the quantity  of
effort includes both professional and secretarial 1n terms of  work years.
Also, it should be noted that the Task Groups and the areas of concern
they each cover are based on a "media" concept (air, water, land, etc.)
In reality, an on-going investigation, planning, control, and  assessment
program crosses these Task Group lines.  However, division by  planning,
control, etc. would be crossed by disciplines such as geology, economics,
and engineering.  By Identifying specific Task Groups it is easier to con-
ceptualize the nature of the job to be done in terms of personnel required.

2.  Task Group for Subject Area A - Mineral Resources, Regional Geology
    and Mining Processing.

    This group has the responsibility of assisting with the quantification
of the oil shale and associated resources  (dawsonite, sodalite, nahcolite,
halite, natural gas, tar sands, gllsonlte, coal, etc.).  The effort will
analyze maps and other representations showing geology, slope, soil and
geological engineering features that are Important to the exploration for
and siting of oil shale mines, retorts, refineries, dump sites, pipelines,
                                     27

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power plants, transmission lines, urban centers, transportation routes, and
secondary  Industry  In the area.
     In addition the task of  this group will cover the assessment of all
available  mining and processing technologies  Including alternative mining
methods, retort processes and  spent  shale disposal techniques with emphasis
on the economic, environmental and secondary  Impacts.  Of concern will be
efficient  and safe  mining practices  and 1n-s1tu mining methods.
     This task will  Include reviews of land and mineral ownership, leasing
and  mining laws, geologic aspects of land reclamation, trace-element com-
position of spent shale and  product, analysis of mining methods, dumping,
and  transporting spent shale and products.  Input will be supplied to
reviews of regulations controlling the exploration and estractlon phases
of oil shale development.  The effort will consider development scenarios
for  the use of other Task Groups.  Expertise  for these areas would Include
geology, mining engineering, and chemical engineering.
     Resource estimates for accomplishing the  work of this task group are
estimated  as follows:  FY 1975 - 1.50 work years, $20,000 for contracts;
FY 1976 -  2.25 work years, $45,000 for contracts;  FY 1977 - 3.00 work years,
$90,000 for contracts.  Secretarial  support Included 1n these totals 1s
estimated  as .08 work years  for FY 1975, .50  work years for FY 1976, and
.58  work years for  FY 1977.   (Table 3)
     As an  Introduction, the  contract monies listed above and under sub-
sequent listings are summaries of monies to be held by the regional office
for  dispursement.   They will be used for complete funding of certain efforts
performed  perhaps by state organizations, other Federal agencies, or private
contractors or universities.   The monies will be used as "seed" money or
supplemental funding when it appears appropriate to precipitate or care-
fully examine an effort supported or with the potential to be supported
by other groups.

3.   Task Group for  Subject Area B -  Water Aspects

     Task Group B has been given the  responsibility of evaluating for EPA
all  aspects of surface and ground water quantity and quality.  Studies of
water quality and pollution  control  will involve some collection and Inter-
pretation  of ambient surface and ground water data, assessments of the
monitoring network, determination of significant discharges and their
effect on  water uses, Identification and evaluation of problem areas, and
formulation of alternative means for solving  the problems.  Existing data
collection networks will be  supplemented.  All data collection activities
will be coordinated among interested parties  in order to best utilize the
expertise  available.  As part of the coordinated effort, preliminary and
final mining plans will be reviewed  for adequacy of water quality moni-
toring.
     Water  "requirements" for all the various  uses (processes, cooling,
conveyance, domestic, reclamation, etc.) will be determined.  Possible
return waste flows will be Identified and characterized along with the
corresponding treatment potentials and costs.  Discharge permit require-
ments will  be developed.  Since the  primary water quality problem 1n
the oil shale area  is salinity, a major effort will be made to evaluate
the effect  of development on salinity loads in the affected streams.  In
particular, spent shale revegetation and leachina problems will be studied

                                     28

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                                                        TABLE 3
                       TASK GROUP A ~ MINERAL RESOURCES, REGIONAL GEOLOGY AND MINING PROCESSING
                                                                                   Work Years
no
10
                       Activity

(I)  Review of Accomplishment Plans and periodic analysis
     of plan output to Insure that Important parameters
     and formats for various assessment routes are
     evaluated.  Consultation for 011 Shale Environmental
     Advisory Panel.

(2)  Review probable Impact of extraction and use of oil
     shale resources within the area regarding the
     following procedures:  The problems to be
     assessed with the various mining methods such
     as subsidence and dewatering of underground
     operations; altered watersheds and erosion of
     surface and open pit mines; and operations which
     Include compaction methods, water consumption,
     and leaching, for either surface, underground,
     or off-site disposal of spent shale.

(3)  Assessment of available technologies to determine
     optional mining and processing systems which
     minimize detrimental Impacts.  Analysis of
     alternative mining methods, retort processes and
     spent shale disposal techniques.  Coordination
     with other tasks to provide data on such
     alternatives.

(4)  Provide analytical  assistance for trace element
     analysis of oil  shale, product, retort and
     refinery flue gases, spent shale, and associated
     economic minerals  (Including heavy metals,
     fluorides, and carcinogenic agents).
                                                                   FY 1974

                                                                     1/12
FY 1975

  1/24
FY 1976

  1/16
FY 1977

  1/12
                                                                     1/2
  1/2
  1/2
  3/4
                                                                                 1/4         3/8         1/2
                                                                               ($20,000)   ($45.000    ($90,000)
                                                                                 1/24        1/16        1/12
                                                                                        (Contract - Part
                                                                                         of Surface
                                                                                         Resources
                                                                                         Task Group
                                                                                         contract)

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                       Activity

(5)  Secure data on reclamation techniques and analyze
     for minimal environmental Impact.   Assess final
     land use and ascertain If reclamation proposals  will
     meet such requirements.  Provide Information on
     soil mechanics, optimal compactation effort,
     optimal water content, heat build up, chemical
     stabilizers, surface contouring, top soil storage
     and placement, leaching potential, construction
     and maintenance of check dams, and landscape
     aesthetics.  This effort must be In cooperation
     with the surface resources task group and meet
     their specifications for land reclamation.
     Considerable emphasis will be given to the
     long-term stability question.

(6)  Review and evaluation of legal restraints
     (leases, permits, rules, regulations, laws,
     guidelines) existing or desired to control oil
     shale extraction.  Review EPA legislative
     controls and assess potential for new law.
     Evaluate state policy, their differences, and
     their enforcement activity.  Coordinate with
     similar reviews by Soc1o-Econom1c and
     Surface Resources Work groups.

(7)  Evaluate Impact of oil shale development on other
     coordinate Industries  (aluminum, soda ash, trace
     elements, construction materials) and with
     potentially conflicting mineral development
     (natural gas, coal, water aquifers).  Examine
     these Industries to determine cumulative and
     interdependent environmental impact.
FY 197*

  1/24
FY 1975

  1/4
FY 1976

  1/4
FY 1977

  1/3
  1/24
  1/24
  1/16
  1/12
                          1/8
                    (Contract - part
                     of surface
                     resources
                     development
                     contract)
                          1/6

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Gv>
                       Activity

(8)  Interaction between Geologic and Socio-Economic
     Parameters.  Insure that earth sciences data are
     considered regarding industrial secondary growth,
     population increase and alternative resource
     utilization.  Provide necessary input of geological
     evaluations to local and state land use planning
     agencies.

     Insure that geologic sections and unique land
     features of aesthetic or academic importance
     are considered and preserved if necessary.
     Review critical  geologic hazards to avoid
     disturbance of highly erosive soils or
     landslide areas.   Determine degree to which
     ground water recharge areas will  be affected.

(9)  Post-Development Evaluation

     Provide for on-site inspection of oil  shale  mining,
     processing and dumping procedures to insure  timely,
     consistent and proper adherence of lease, legal, and
     environmental  restrictions.   Possible inspection team
     to analyze on-site compliance with applicable rules
     and regulations  and provide data on future changes
     regarding operating procedures.  Teams will
     concentrate on smaller aspects of environmental
     degradation such  as depth  of top soil  removal,  waste
     dump disposal, accidental  fluid spillage, spent shale
     compaction,  and  other fine points of compliance.
                                                                   FY 1974
FY 1975

  1/24
FY 1976

  1/16
FY 1977

  1/12
                                                                                 1/24
              1/16
              1/12
                                                                                             1/4         1/3
                                                                                       (Contract - part
                                                                                        of Surface Resources
                                                                                        Monitoring contract)

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                               Activity
                           Activity
                  FY 1974
   (10) Secretarial
   TOTAL
Work Years
Contract Funds
FY 1975
  1/12
FY 1976
  1/2
FY 1977
  7/12
0.66
1.5
$20,000
2.25
$45,000
3.0
$90,000
f\>

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in depth with contract assistance and through close liaison with ongoing
NERC (OR & D) contracts such as those conducted by Colorado State University.
    Shallow and deep ground water reserves will be assessed for their
potential use 1n oil shale development and also for the expected Impact
on these waters from oil shale and associated mineral  development.  This
effort will be largely one of funding and coordination with other agencies
such as the USGS and state engineers.
    Instream water "needs" for the maintenance and enhancement of aquatic
ecosystems in streams affected by oil shale development will be examined
and defined.  A contract effort 1s most likely required for the development
of methodologies capable of analyzing stream flow depletlon/auamentation
and stream flow Impoundments Insofar as that may compete with the needs
of the aquatic ecosystem.  In this regard, new predictive surface water
quality modeling techniques will be developed or else  existing techniques
will be modified where appropriate to obtain a model(s) sensitive to
quality changes.  Field investiqations of streams and  existina natural
and man made Impoundments will add significantly to the predictive capa-
bility of the methodologies for analyzing of Instream  "needs" and the
surface water quality methodologies.  Support will be  aiven to defining,
quantitatively, present water uses and needs for man.
    Results from data collection and analysis, contract activities, re-
search projects, and data from other agencies and groups will be utilized
1n coordinating EPA-State river basin planning efforts.  The overall study
results and regional environmental planning effort will be integrated into
the ongoing regional EPA functions.  It will be important to identify and
assist with the correction of gaps in the data gathering and analysis system
for the entire 3-state oil shale area.
    Secondary Impacts from water use and consumption,  waste flows, and
facility construction will be ascertained and data supplied to other work
efforts.
    The total allocation resources for this task is estimated to be 0.17
work years in FY 1974; 1.67 work years for FY 1975 and $65,000 for contracts;
2.50 work years for FY 1976 and $160,000 for contracts; 3.34 work years
for FY 1977 and $250,000 for contracts.  Secretarial  support included in
these totals will be .42 work years for FY 1975, .75 work years for FY 1976,
and .8 work years for FY 1977.  (Table 4)

4.  Task Group  Subject Area  C  - Atmospheric Aspects

     This task  group will  coordinate overall  air  related  activities and
provide a liaison with  the States,  EPA NERC's,  the Department of Interior,
and other agencies  studying  atmospheric problems  related  to oil  shale
development.  Existing  data  gathering efforts will be evaluated  in order
to  determine data needs  not  currently being satisfied.

     The existing air quality  monitoring efforts, undertaken due to
requirements of the Interior Department's Prototype Leasing Program, will
be  augmented where  necessary to provide an adequate baseline data
network.   Since the Lessees' monitoring efforts are on or in close
proximity to the lease  tracts, this work group will study the terrain,
                                    33

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                                                         TABLE  4
                                               TASK GROUP B  -  WATER ASPECTS
u>
                       Activity                                 FY 1974

(1)  Manage water related activities.  Insure coordination        1/24
     of water related activities; liaison with other agencies
     and persons (task groups) Involved with water and
     related problems caused by oil  shale development.
     Review and Revise Oil Shale Accomplishment Plan as
     required.

(2)  Inventory surface and ground water quality In areas          1/12
     likely to be Impacted by oil shale development.  Ambient
     surface water quality network should be supplemented,
     ground water well inventory begun, discharges of point
     sources should be inventoried and sampled, nonpoint
     sources should be assessed.  Coordinate all data
     collection activities, augment where necessary.  Requires
     funds and water quality monitoring.  Regional effort
     with State and other Federal assistance.

(3)  Water use in oil shale development must be assessed.
     Water "requirements" for various processes, cooling,
     domestic uses, and reclamation practices must be
     assessed.  Possible future effluents and their quality,
     water pollution treatment potentials and their costs,
     and secondary water needs must be identified.  Estimates
     of water availability must be assessed.  Assistance
     from NERC's and headquarters (NSPS contracts for
     effluent guidelines) possible.   Requires process
     engineering and pollution control technology expertise.
                                                                               FY 1975     FY 1976
                                                                                 1/12
1/8
FY 1977

  1/6
                                                                                 1/12
1/4
  1/2
                                                                               ($13,000)  ($35,000)   ($50,000)
                                                                                 1/4         1/8         1/4
                                                                              ($10,000)   ($15,000)    ($20,000)

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en
                           Activity
                                                                FY 1974
FY 1975
FY 1976
FY 1977
(4)  Define the "instream needs" of flow requirements necessary
     for the maintenance and enhancement of aquatic ecosystems
     for streams in areas impacted by oil shale development.
     The initial effort requires the adapting of a methodology
     most appropriate to the oil shale area streams.  Questions
     to be answered involve evaluating the relative impacts of
     changes in stream-flow 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 wildfowl dependent upon the flowing streams.
     A contract effort required for methodology development.
     Possible NERC assistance in field verification.  Regional
     coordination required.

(5)  Salinity.   Evaluate possible salinity increases associated   1/24
     with oil shale development from depletions, effluents,
     spent shale disposal, etc.  Evaluate mitigation efforts.
     Evaluate physical/economic detriments to water users of
     increased  salinity in the Colorado River Basin.  Requires
     water resources planning expertise and economic
     evaluations.   Regional  effort with contract assistance.
                                                                                  1/6          1/4         1/3
                                                                               ($22,000)    ($50,000)    ($60,000)
                                                                                  1/3         1/2         7/12
                                                                               ($  5,000)    ($20,000)    ($30,000)

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                          Activity

   (6)  Develop predictive surface water quality modeling
        techniques.  Existing modeling or predictive
        methodologies must be evaluated and modified if
        appropriate.  New methodologies may have to be
        devised.  The outcome is tc be the designation
        of the best model(s) with subsequent field
        verification and collection of pertinent input
        data.  The analysis will result in a method
        manual which describes in detail the models
        available, the limitations and advantages, the
        sensitivities of the appropriate models to changes
        in key parameters and to data deficiencies.
        Contract effort needed, Water Resource Planning,
u,      computer expertise required, Regional coordination.
°*      Possible NERC assistance.

   (7)  Assessment of shallow and deep ground water reserves
        and the Impact of mining and related oil shale
        development on these resources.  A comprehensive
        analysis of the shallow ground water system
        (including ephemeral streams where shallow
        ground water flow is perennial), to enable
        predictions of potential impacts on the quality
        and quantity of the water should be Initiated.
        Leaching studies of spoils materials and spent
        shales are appropriate along with microscale
        investigations of changes in water characteristics
        with time in the spoil materials of mines and
        spent shales.  Deep ground water should be
        assessed as to Its potential as water source for
        development.  Sufficient bases to allow accurate
        planning of ground water withdrawals are necessary
        to avoid undue depletions of the ground water
FY 1974
FY 1975
FY 1976
FY 1977
              1/12        1/8         1/6
           ($ 5,000)   ($25,000)   ($50,000)
              1/24        1/16        1/12
           ($ 5,000)   ($10,000)   ($25,000)

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                       Activity
                    FY 1974
          FY 1975
            FY 1976
            FY 1977
     reserves.  Regional effort largely one of funding and
     coordination with other agencies such as the USGS
     and State Water Resources and Geological Surveys.

 (8)  Evaluate the effects of Impoundments along perennial
     streams on water quality and the aquatic ecosystem.
     Little 1s known about the actual effects of such
     Impoundments since there are few within the oil shale
     areas and none have been adequately monitored.
     Potential Impacts on fisheries and water quality
     have been Identified, but not measured or verified
     In the field.  Field Investigations of existing
     natural and man-made Impoundments will add
     significantly to the predictive capabilities.
     Regional effort with possible NERC assistance.
     Biological, geological, hydrological expertise
     required.

 (9)  Coordinate study data, research, results, etc.,
     with EPA-State river basin planning efforts.
     Integrate study results (point sources, nonpolnt
     sources, growth factors, salinity, etc.) and
     regional environmental planning effort with
     on-going EPA functions.
                                  1/12        1/8         1/6
                               ($ 5,000)   ($ 5.000)   ($15,000)
                                  1/8
                        3/16
                          1/4
(10) Secretarial
TOTAL
                                  .42
                        .75
                          .8
Work Years

Contract Funds
.17
 1.67

65,000
 2.5

160,000
 3.34

250,000

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meteorological conditions, and resource location 1n ascertaining
additional monitoring sites.  In addition, the task group will attempt
to coordinate data gathering efforts through the utilization of a
single format by all parties collecting data.

     Considerable meteorological data will be collected by the Lessees'
per the requirements of the Prototype Program.  A review of all the
available data will be performed and recommendation of sites for
additional meteorological data will be made.  A network to address the
needs enumerated will be designed, set up and operated to collect the
data.

     The problem of deteriorating visibility will be addressed to a
limited degree through the existing Prototype Program.  Their data
gathering efforts related to baseline visibility, prior to development,
will be supplemented by monitoring 1n other parts of the Basin.  Mobile
samples mounted in a fixed wind aircraft will be collected 1n order to
identify the size distribution and composition of existing aerosol
concentrations.

     Considerable research on various retort processes and possible control
alternatives is now under consideration.  A summary of such efforts,
will be composited and made available to the States and other interested
parties.  The task group will keep all concerned parties informed of
EPA NERC and Region VIII efforts in this area of control technology.

     Atmospheric diffusion modeling will be employed to evaluate the
potential impact of various resource development strategies on air quality.
This effort will utilize all existing information on potential emissions,
control options, and the meteorological data gathered 1n the area.  This
effort will evaluate modeling done by other groups; adapt models to the
study area whenever necessary; and look at impacts in the vicinity of
single point sources and also evaluate the potential regional impact of
oil shale development strategies.

     The allocation of resources for the atmospheric task group is
estimated as follows:  FY 1975 — 1.67 Work Years, $50,000 Contracts;
FY 1976 — 2.50 Work Years, $120,000 Contracts; FY 1977 — 3.3 Work
Years, $225,000 Contracts.  Secretarial support Included in these
totals is estimated to be 0.55 Work Years for FY 1975, 0.75 Work Years
for FY 1976, and 0.9 Work Years for FY 1977.(Table 5)


5.  Task Group for Subject Area D - Surface Resources


     This group has been assigned the task of Identifying and quantifying
surface resource values of the oil shale area in terms of soils, ground
water, surface uses of land, vegetation, and wildlife.  Changes 1n
                                    38

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                                                     TABLE  5
                                        TASK GROUP C — ATMOSPHERIC ASPECTS
                       Activity
(1)  Manage atmospheric related activities; participate in
     overall air related' activities; provide liaison with
     other agencies and persons studying air and related
     problems to oil shale program.  Serve as lead agency
     for Atmospheric Aspects on the Oil Shale Advisory
     Panel.  Review and revise Regional 011 Shale
     Accomplishment Plan as required.

(2)  Acquire background Information on air quality In the
     oil shale areas; assimilate data being collected by
     the various groups and Identify further data needs.
     Implement a monitoring system, 1f necessary, to answer
     these needs.  Region and NERC.  Review preliminary
     mining plans for monitoring adequacy.

(3)  Coordinate the efforts to gather meteorological data
     In the oil shale areas; Identify additional data
     requirements and Implement meterological monitoring
     program where necessary.  Perform modeling as
     necessary to estimate the Impact of oil shale
     development on air quality.  Region and NOAA.  Assist
     in calibration of air monitoring equipment.

(4)  Acquire information on the potential emissions
     (criteria pollutants, trace elements, other) for
     different processes and Identify control
     equipment options.  Region and NERC-RTP.
FY 1974

  1/5
FY 1975

  1/4
FY 1976

  1/4
FY 1977

  3/8
              1/4         1/2         2/3
           ($15,000)   ($30,000)    ($50,000)
              1/4         1/4         3/8
           ($30,000)   ($50,000)    ($50,000)
              1/6         1/4         1/3
                       ($20,000)    ($75,000)

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                       Activity
                  FY 1974
          FY 1975
            FY 1976
            FY 1977
(5)  Acquire Information to assess the existing visibility
     In the area prior to the proposed oil  shale development,
     Coordinate with other groups attempting to assess
     visibility.  Region and NERC.

(6)  Participate In developing procedures and in the
     assessment of the Impact of alternative strategies
     on the study area air quality.  Region and NERC.

(7)  Analyze potential air pollution problems resulting
     from secondary population, Industrial, and urban
     growth.  Integrate results Into EPA regional
     environmental planning functions.

(8)  Examine possible fugitive dust problems associated
     with mining and secondary activities.
(9)  Secretarial
TOTAL
Work Years

Contract Funds
.2
                                1/12        1/8         1/6
                             ($ 5,000)   ($10,000)   ($20,000)
                                1/12
  1/24


  .55


 1.67

$50,000
                        1/8
                                            .75
                          1/6
                                            3/16        1/4
                                         ($ 5.000)   ($20,000)
                                            1/16        1/12
                                         ($ 5,000)    ($10,000)
                                    .9
 2.5         3.3

$120,000    $225,000

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characteristics or use of these resources on-s1te as well  as off-site
will be evaluated by conventional data collection techniques and
supplemented by a comprehensive surface monitoring system utilizing
remote sensing techniques and appropriate expertise.  This task group
will also be Involved In an Intensified program of restoration of mined
areas conducted 1n a comprehensive fashion.   The effort will be extremely
concerned with assessment of cumulative Impacts from related and
unrelated activities 1n oil shale country.

     Secondary impacts of oil shale development constitute many
significant environment problems and must be comprehensively analyzed
in coordination with the social, economic, and cultural task group (E).
Public participation will be encouraged in reviewing secondary development
effects to Insure that surface resources are viewed from an ecosystem
point of view rather than simply an economic point of view.

     The group will pursue quantitative descriptions of complete natural
ecosystems and attempt economic evaluations  of their value and impacts
that may be felt by those systems.  Obviously, the effort will require
coordination with activities sponsored by others.

     This task group will also compile, review, and recommend legal
alternatives and constraints to be applied to the development of oil
shale to insure maximum environmental protection.

     Resource estimates for accomplishing the work of this task group
are estimated as follows:  FY 1975 — 1.5 Work Years, $120,000 for
contracts; FY 1976 — 2.50 Work Years, $192,000 for contracts; 1977 —
3.20 Work Years, $217,000 for contracts.  Secretarial support included
in these totals 1s estimated as .75 Work Years for FY 1975, 1.20 Work
Years for FY 1976, and 1.40 Work Years for FY 1977.  (Table 6)


6.  Task Group for Subject Area E - Social,  Economic, and Cultural  Aspects


     The relatively complex task of identifying and quantifying much of
the people-related aspects of oil shale development confronts this task
group.  The complexity of predicting and analyzing growth impacts
related to both primary and secondary development in the oil shale area
cannot be overemphasized.  Only a comprehensive coordination effort with
the other task groups will prevent an overemphasis of economic analysis
at the expense of more difficult to quantify social, scenic, aesthetic,
and recreational values.

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                                                        TABLE  6
                                            TASK GROUP D — SURFACE RESOURCES
no
                       Activity

(1)  Review of accomplishment plans and periodic analysis
     of entire plan output to Insure that Important
     parameters and formats for various assessment routes
     are evaluated and that appropriate changes In
     direction are implemented.  Participation in Oil
     Shale Environmental Advisory Panel.

(2)  Compile, review, evaluate, recommend, coordinate,
     with appropriate local, State and Federal legal
     constraints (leases, permits, rules, regulations,
     laws, guidelines, institutions, etc.), existing,
     or needed to protect, conserve, restore, or plan
     the use of oil shale area surface resources.
     Effort shall include identification and evaluation
     of legal/institutional mechanisms and possibilities
     for surface resource protection.  Requires legal
     and public policy and institutions expertise.

(3)  Analyze environmental impacts from secondary
     growth and activity from oil shale development.
     Includes analysis of use Impacts and demand for
     minerals, timber, roads, recreational areas,
     wildlife, replacement farm land, urbanization,
     etc., resulting from shale development and
     accompanying activity..  Coordinate with Social/
     Economics Group efforts on social/economic
     aspects of secondary growth factors and changes
     and resultant environmental impacts.  Requires
     regional planning expertise with knowledge of
     regional ecosystems approach.
                                                                   FY 1974

                                                                     1/24
FY 1975

  1/24
FY 1976     FY 1977
  1/16
1/12
                                                                                 1/8
              3/16
              1/4
                                                                     1/24        1/2         3/4         1
                                                                            (contract -   ($75,000)  ($100,000)
                                                                             $25,000)

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                       Activity

(4)  Coordinate, review, and Implement a regional
     environmental/resource planning program In
     conjunction with appropriate local, State and
     Federal entitles.  Coordinate with other Work
     Groups as needed to accomplish regional
     analysis and planning effort.  Apply and research
     needed analytical and planning methodology.

(5)  Coordinate local, State, and Federal planning
     and management efforts with EPA planning,
     review, and control functions.  Draw together
     oil shale study results and other appropriate
     data for use 1n EPA environmental programs.
     Expand EPA land use/environmental planning
     program to encompass oil shale study results
     (air pollution, water pollution, salinity,
     sedimentation, growth, etc.).

(6)  Design and Implement a surface resources
     monitoring system (Includes blotlc trend,
     erosion, Increased and changed use trends, etc.)
     for secondary off-site and primary on-s1te
     Impacts.  Coordinate monitoring results with
     appropriate Work Group and EPA Regional
     personnel and with on-s1te monitoring program.
     (remote sensing, etc., techniques).

(7)  Support selected aspects of and monitor an
     Intensified program to Improve spent shale disposal
     methods.  Such considerations would Include mine
     placement disposal, in-site retorting, and
     alternative designs of land disposal methods.
FY 1974
FY 1975    TY 1976
              1/4
              3/8
FY 1977

  1/2
              1/4
              3/8
  1/2
              1/8         3/16        1/4
       (NERC-Las Vegas- ($12,000)   ($12,000)
        $17,000 aerial
        support)
              1/16        3/32        1/8
           ($23,000    ($25,000)    ($25,000)
            contract)

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                       Activity
                          FY 1974
         FY 1975
FY 1976
FY 1977
(8)  Develop research needs to better understand the
     characteristics of spent shale and disposal as
     related to water quality.  Specific attention will
     be given to chemical aspects (carbon content,
     soluble salts, carcinogenic agents) and physical
     aspects (run off, perculatlon, etc.).  Liaison with
     ongoing and future research efforts funded by
     "outside" (extraregional) groups.

(9)  Assist with a detailed analysis of potential mining
     areas to provide an adequate Inventory of soils,
     ground water, geomorphology, wildlife, and
     vegetative conditions.  Such Inventory will be
     necessary to predict Impacts on water quality
     (salinity) and technology necessary to control
     nonpolnt source pollution.  This Inventory will
     Include mining areas, access routes, pipeline
     corridors, etc.

(10) Secretarial
TOTAL
Work Years

Contract Funds
                                        1/16        3/32        1/8
                                     ($35,000    ($50,000)    ($50,000)
                                      contract)
                                        1/8         3/16        1/4
                                     ($20,000)    ($30,000)    ($30,000)
                                        .75
                        1.2
              1.4
,08         1.5          2.5         3.2

          $120,000    $192,000    $217,000

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     EPA's Involvement will be primarily In providing management and
technical assistance for the development of methods and procedures to
be used In evaluating alternative development strategies and their
Impacts on local and regional structures.  Direct EPA assistance as
well as contractual assistance will be aimed at minimizing detrimental
social, economic, cultural, and environmental impacts, both present
and future.  A large part of this effort will concern Itself with
Identifying and developing land-use tools that are integrated with the
true Impact on people.  This will Include Identifying the extent to
which Impacts outside the Immediate oil shale area must be considered.

     This task group will make efforts to determine what environmental
and other Information 1s required by the decision-makers and local
interest groups and factor these needs back into this work plan as well
as the programs of other relevant groups.  In addition, this task group
will assist in the distribution of output from all the task groups to
the local Interest groups.  The total  allocation of resources by
Region VIII EPA is estimated as follows:  FY 1975 — .52 Work Years,
$45,000 Contracts; FY 1976 — .78 Work Years. $120,000 Contracts;
FY 1977 — 1.04 Work Years, $175,000 Contracts.  Secretarial support
included in these totals will be:  FY 1975 — .12 Work Years; FY 1976 --
.19 Work Years; FY 1977 - .6 Work Years.  (Table  7)


7.  Task Group for Subject Area F - Regional and National Energy Considerations


     One of the primary responsibilities of this task group is the
development of energy supply projections based on all energy resources
located within the region and a summary of energy supply technologies,
including their major environmental impacts.  This task group must also
insure the appropriate evaluation and presentation of regional
considerations and perspectives related to regional energy supply and
demand 1n the face of a strong national move to withdraw significant
amounts of energy from the region.The work of this group might well
become the most Important and Influential determinant of Impact upon
the oil shale area and the whole region.

     The specific effort described here will relate to oil shale only.
Concurrent efforts will be conducted by the regional office and others to
assess other energy fuels and more comprehensive analyses.  The effort
herein projected will thus be a part of a much larger effort and will
benefit from the findings of that effort.  Coordination with "Project
Independence" and other evaluations and predictions of the National
energy situations are critical.
                                   45

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                                                     TABLE 7
                               TASK GROUP E - SOCIAL, ECONOMIC AND CULTURAL ASPECTS
                       Activity

(1)  Review of accomplishment plans and periodic analysis
     of entire plan output to Insure that Important
     parameters and formats for various assessment
     routes are evaluated.  Participation 1n Oil
     Shale Environmental Advisory Panel.

(2)  Management and coordination of efforts for
     developing an analytical and Informational
     framework to quantify and evaluate alternative
     development strategies associated with oil
     shale development and associated secondary
     growth.

(3)  Provide technical assistance in developing methods
     and procedures to measure and analyze alternative
     development strategies for local communities and for
     the region toward the objective of minimizing
     social, economic, cultural and environmental Impacts,
     both present and future.  Develop regional planning
     methodology and structures for addressing Impacts.

(4)  Management, coordination and technical assistance
     In developing contractual requirements concerning
     social, economic and cultural aspects particularly
     with regard to changes expected to occur in the
     local and regional structures as a result of oil
     shale and associated development.

(5)  Coordinate planning and management efforts with
     other EPA program activities and with interagency
     Federal, State and local planning and development
     programs.
FY 1974

  1/24
FY 1975

  1/24
FY 1976     FY1977
  1/16
1/12
              1/16
              1/16
              1/12
              1/16
           ($45,000)
              1/32        5/12
           ($115,000)  ($175,000)
              1/16
              1/16
              1/12

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                          Activity

    (6)   Public  Participation

         Assist  with  Identification and quantification of
         public  attitudes  regarding oil shale development.
         Provide for  public forum at all significant
         changes In land use policy of the area and assist
         Interest groups in gaining technical Information
         they desire.  Develop valid public assessment tool
         (mall questionnaire random survey, newspaper
         questionnaire) to quantify public attitudes
         regarding oil shale policy for Inclusion as
         supplemental data for the 011 Shale Environmental
         Advisory Panel.
                    FY 1974
          FY 1975

            1/24
            FY 1976

              1/16
           ($ 5,000
            contract)
            FY 1977

              1/12
5  (7)  Secretarial
   TOTAL
Work Year

Contract Funds
.04
  3/24


  .50

$45,000
                                              3/16
                                    7/24
  .78        1.04

$120,000    $175,000

-------
     The task group will also consider the uses of oil derived from
shale and the economics of various marketing alternatives.  A significant
question to be continuously evaluated 1s whether or not the proposed
oil shale development will actually produce a significantly large share
of the total national energy supply 1n view of Its environmental and other
costs.

     The development and analysis of time frames for potential oil shale
development will be coordinated with other work groups (particularly
Group E) to Insure adequate lead time for responsive planning on the
local, regional, and national level and to Insure Implementation of the
findings of the prototype program.

     Resource allocations are estimated to be 0.10 work years for FY 1975,
0.15 work years for FY 1976, and 0.20 work years for FY 1977.  Secretarial
support requirements are Included 1n these figures, but are not broken
out Individually.  (Table 8)
                                    48

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                                                      TABLE 8
                              TASK GROUP F ~ NATIONAL ENERGY IMPLICATIONS - OIL SHALE
                       Activity

(1)  Coordination and Input Into the Identification and
     construction of energy supply projections based on
     all resources found In the region and summary of
     energy supply technologies and their Impact.

(2)  Analysis of oil conservation potential and Its
     Impact on oil demand.

(3)  Analysis of development potential - time tables for
     oil shale development.

(4)  Analysis of oil from shale uses - Its major market
     potentials both In terms of type and location of final
     use.  Does oil shale represent a way to Increase overall
     oil production as to minimize Imports?
                    FY 1974

                      1/24
          FY 1975

            1/48
          FY 1976

            1/32
          FY 1977

            1/24
                                  1/48


                                  1/32


                                  1/32
                        1/32


                        3/64


                        3/64
                        1/24


                        1/16


                        1/16
TOTAL
Work Years
.04
.1
.15
.2

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                               SUMMARY
     This Accomplishment Plan has been prepared to serve as a guide
for the Region VIII offices of the Environmental Protection Agency as
an oil shale Impact assessment.  A program was precipitated
by Increased activity associated with the mining and processing of
oil shale In Colorado.  The states of Utah and Wyoming are also
becoming rapidly  Involved  in the escalating developmental activity.
Our program 1s designed to obtain and develop Information that can
assist the  prototype oil shale program 1n determining how or whether
to develop  the full oil shale resource, based upon the outcome of
comparisons of the desired and projected results of "development". Our
program also sets objectives for protecting the environment of the
area and 1n exercising full authorities for planning, support, and
regulation  1n this effort.

     Since  the mining and  processing of all of the 600 billion barrels
of shale oil  from about 17,000 square miles of sparsely-populated oil
shale land  would  significantly alter the environment," the EPA must
assume 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 1s the forerunner of  large-scale mining.  Four Federal leases of
oil shale land have already been awarded under a combined total bonus
bid of $448,787,600 and preliminary exploratory drilling operations
are underway.  Evaluation  of the proposed development cannot wait.

     This 011 Shale Assessment Program, as previously described, can
provide the framework within which EPA can discharge Its responsibilities
while providing maximum support to other Federal, State, and local
resources.   The Program also provides the framework for evaluating oil
shale 1n relation to other reserves of energy fuels located within
Region VIII.

     This Accomplishment Plan has, therefore, Identified resources
that should be assigned to numerous and various tasks that are both
part of an   Oil Shale ResourcesProgram and part of the on-going
environmental protection activities which EPA 1s directed to address
by Its statutes.  EPA resources have been identified through Fiscal
Year 1977.   We have proposed that the Program start out at a moderate
pace that allows  us to review on-going efforts and to Initiate a very
modest amount of  work during FY 1975.  As efforts 1n the concurrent
Northern Great Plains Resources Program are completed, transferred, or
otherwise have need for fewer people by FY 1976, the oil shale effort
will be increased.
U.Final Environmental Statement for the Prototype 011 Shale Leasing
Program, Department of Interior, Volume I, page 1-2.

                                  50

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     Regionally-coordinated efforts are estimated to  require about
thirty-five work years of professional  effort and about $2,000,000
(cumulative total) for contracts, grants, and minor equipment through
1977.  An additional $300,000 is allocated for salary and support for
four overtarget positions for the three-year period.   Table 9
summarizesthese resource allocations in terms of work years, salary/
support, and contract funds for FY 74,  FY 75, FY 76,  and FY 77.   The
effort will most likely continue into the 1980's but  its magnitude
cannot be predicted since oil shale activity cannot be predicted with
certainty.

     The total regional resource allotment for the Program has been
estimated to be 8.00 work years for FY  1975 with $300,000 in contracts,
11.5 work years for FY 1976 with $637,000 in contracts, and 15.0 work
years for FY 1977 with $957,000 in contracts.

     It is important to emphasize that  those familiar with similar
efforts, Including EPA's efforts in the Northern Great Plains
Resources Program, are convinced that regional coordination is critical
to the successful Implementation of EPA's role in the 011 Shale
Program.  The need for this coordination is for the accurate weighing
of the many complex factors inherent in a resource development of this
magnitude will determine to a great extent the quality of EPA's role
in this important Program.

     The Program is designed to have a  significant beneficial impact
on the Prototype Oil Shale Leasing Program which is currently underway
and will likely continue until 1979 or 1980 and the more pressing
community development/urbanization problems that are  rapidly becoming
reality.  Although the specific Task Group efforts have been herein
designed to extend only through FY 1977, there will be a need to
extend the more critical functions into later years.   Particularly,
in light of a possible move to future full-scale development of the
oil shale resource, it 1s envisioned that certain of the activities
herein specified will continue long after this particular Program is
phased out.  These activities either are or will become integrated
with Region VIII's continuing efforts in environmental protection.
                                  51

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                                                          TABLE  9
                            OIL SHALE RESOURCE PROGRAM - EPA REGION VIII ACCOMPLISHMENT PLAN
                                               RESOURCE ALLOCATION SUMMARY
                                FY 1974
FY 1975
FY 1976
FY 1977
                                 Work    Work   Salary,            WorkSalary,            WorkSalary,
      Task Group Subject Area    Years   Years  Support  Contract  Years  Support  Contract  Years  Support   Contract
Regional Coordination
Mineral Resources
and
Regional Geology
Water Aspects
Atmospheric Aspects
Surface Resources
Social, Economic
and
Cultural Aspects
National Energy
Considerations
Totals (Rounded)


.17
.08



.25
1.00
1.50
1.67
1.67
1.54
.52
.10
8.00

$ 20,000
$ 65,000
$ 50,000
$120,000
$ 45,000

100 $300,000
1.00
2.25
2.50
2.50
2.50
.78
.15
11.50

$ 45,000
$160,000
$120,000
$192,000
$120,000

100 $637,000
1.00
3.00
3.34
3.34
3.20
1.04
.20
15.00

$ 90,000
$250,000
$225,000
$217,000
$175,000

100 $957,000
  B

  C
en
  E



  F
      Explanation:  Work years Includes both professional and secretarial effort.   Salary and support for four
                    over-target positions have not been broken down by task group areas, but are listed as a
                    total for each Fiscal Year.

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APPENDICES
     53

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                              APPENDIX I
                     OUTLINE OF POSSIBLE TECHNICAL
                      INVESTIGATIONS/COORDINATION
                  STRUCTURE FOR OIL SHALE DEVELOPMENT
Introduction
     The Centra] Rocky Mountains, an area which consists of large
segments of Colorado, Wyoming, and Utah, has been the focus of Increasing
attention because the area 1s a potential source for vast amounts of oil
in the form of oil shale.  Interest In the development of oil shale and
other energy resources stems primarily from the continuing growth of
national energy consumption and dwindling national petroleum production.
The possibility of large scale development of the oil shale 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 affected 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 oil shale resources
on public lands, regulations for air and water quality, and development
of water projects.  Congress is 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 Air 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.

     These factors have led the three States, and several Federal agencies
to see a need for a cooperation program to coordinate data acquisition
and analysis needed for development decisions.  This document sets forth
possible objectives, a design outline and an organization for such an
Oil Shale Resources Program.
                                  54

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Objectives


     The primary objective of an Oil  Shale  Resources  Program  (OSRP)
would be 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, nondevelopment, or
rate-of development beyond the prototype leasing program, of  land
resources within the oil shale areas  of Colorado, Wyoming, and Utah.
The program would 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 would present both quantifiable and nonquantifiable implications
of alternative'land and resource uses.  Reports  would not recommend  a
particular development plan for the region, rather, they  would 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 would be 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 could 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 and appropriate River Basin
Commissions.  Policy and decision-making authority must be retained  by
established agencies, organizations, and the State and local  entities.
The OSRP would contribute in every possible way to encourage  this
coordination.

     A third objective would be the development 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 OSRP.


Scope and Guidance
     All analyses will deal with the implications of proposed resource
management actions for the three-state area.  Although focus will center
on the study area, the program would adopt whatever appropriate
                                  55

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perspective for each subject of analysis.  For example, analysis of
energy requirements would consider the national energy situation and
Its principal geographic components, as well as other demands for
petroleum from oil shale.

     Thus, an alternative to delayed full-scale development of oil
shale or other minerals would be considered In 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,
1n considering energy development cases, analyses of air quality, for
example, would Include Implications of petroleum refining In distant
urban areas as opposed to refining 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 potential concerns within the
OSRP.

     The program would foster Integrated consideration of basic natural
resource use and protection, Including human Interests and economic
and social development.  It would consider the full range of economic,
social, and environmental consequences of alternative plans of land and
resource management 1n 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 could become a model for future studies
or programs concerned with development of all energy resources In the
Western United States.

     To the fullest possible extent all concerned entitles would have
the opportunity to participate 1n the design and Implementation of the
program.  Vehicles for participation and use of study results would
Include frequent reports, regular briefings of broad-based advisory
personnel, direct participation 1n 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 would provide an objective display of data and analysis
to allow a user to draw conclusions based on his particular value
system.
The Program


     The OSRP would consist of a series of Investigations and studies
dealing with a common theme, rather than a single area of concern.  The
overall study could be time-phased over a 5-year period and, although
                                  56

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a comprehensive final summary report would be Issued,  study results
will be reported as they are completed.   Frequent and  timely reporting
will provide maximum assistance to decision-makers on  Issues which often
cannot be delayed until a full, final report 1s Issued.

     The proposed program has five principal sections:   (1) program
design, (2) regional profile, (3)  constraints and alternate strategies,
(4) 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'hatuYe 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 If 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 attitudes, and (g) past
and present activity.  In short, complete ecological,  natural resource,
social, and economic Inventories will be developed, as specified  In 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.
                                  57

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     3.  Constraints and Alternative Strategies.  To provide a basis
for judging the feasibility of development and management alternatives,
1t 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 Hm1t
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 accomplished
by continual monitoring of all tasks by the Program Management Team.
These studies should also Identify development stimuli.  (See following
section on Organization.)  Because this 1s the phase of the study in
which exercise of judgment is Inevitable and the possible loss of
objectivity is most likely, it may prove to be most crucial.  It is,
1n effect, an Inventory of institutions and attitudes.  The relevant
institutional constraints are readily identified — The Clean A1r Act,
National Environmental Protection Act, mine reclamation laws, regional
water compacts, mineral leasing laws, or 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, in 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 OSRP study not select a single
goal or system of values, and thus prejudge results.

     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 the prototype leasing program;
that Is, to maintain the status quo.  Additionally, several strategies
should be developed to represent a range of rates and Intensities of
new development in the region.

     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.
                                  58

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     4.  Analysis of Consequences.   The proposed strategies will  be
analyzed to determine economic, social  and environmental  implications
locally, 1n the region, and nationally.  These implications will  be
arrayed against a variety of goals  and  the results presented without
value judgment.  The multi-objective principals 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 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 comprehensible 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, any final report will consolidate results and provide a
readable overview of the program.  Such a final report could serve
as the principal input to an EIS on the future of oil shale, beyond
the prototype program.


Organization and Participation


     A schematic of the proposed organization is shown in Figure A.
Figure 2B is a further breakdown of a similar organization, as it
evolved for the NGPRP.  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 and the PMT.  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 would be encouraged to the fullest possible extent.
                                  59

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8
                                                                    Program Review Board
                                                                    EPA
                                                                         DRCG
                                                                    States
                                                      Interior

                                                        Public
                                                                  Program Management Team
                                                                  EPA  USGS      SCS
                                                                  MY   BSF&H     FS
                                                                  CO   Public  One person
                                                                  UT   ORCG   (with staff)
                                                                  BLM  FED    as Program
                                                                               Manager
                                             Work Groups
                                                                                          Ad Hoc Committees
                                                                                             Monitoring
                                                                                             Planning
 Regional Geology
 and Mineral Resources

 USGS • USBM

 States - Public
    Hater


     EPA

States - Public
     A1r


  EPA - NOAA

States - Public
Surface Resources
(on-s1te Impacts)

    BLM - Ag

States - Public
Soclo-Economlc -
Secondary Impacts
(off-site Impacts)
EPA - States - HUD

States - Public
National Importance
        of
    Oil Shale
 FFO - Interior

States - Public
                                             Schematic of a  Proposed Oil Shale Resource Program Organization


                                                                    TABLE  A-l

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                                                                                             TASK MATRIX



                                                                                PROPOSED WORK GROUPS  AND PARTICIPANTS

G
Rational Energy
Considerations



Energy supply and demand
Energy technology








L-DOI (Energy Office)
P-EPA. OOC. FPC.
AEC. USDA. BR.
BLM. BSFU
C-OST. OEP. Indust.


O»
"-

Current t Projected
energy
Technology
National 1 Regional
Energy
Fuel Situations
Alternate regional
energy resources
development strategies
and technologies
No development
Satisfaction of National
and Regional Energy
and Fuel Demand



SUBJECT AREAS -,
f
Soclo-Economic
and
Cultural Aspects


Existing local and regional
Social institutions
Attitudes
Archeology ft history
Aesthetics





L-USOA
P-USOA. DOC. HEM. BIA.
BLM. NPS
States, Indust.
Private Org.
C-aOR. EPA. HUD. DL


Location
Distribution
Importance

Attitudes
Physical constraints
on change
Economic constraints
on change

Continue current status
Accelerate selective
development

Preservation of current
life style 1 values
Growth of population t
economy with possible
disruptions 1 losses

£
Surface
Resources

0
Atmospheric
Aspects

c
Water



Soils
vegetation
Timber
Grassland
Other
Fish t Wildlife
Recreation
Agriculture
Scenery
Wilderness

L-USOA
P-BLM. BOR. BSFIN.
EPA. NPS
States. Prlv. Org.
C-BLN. COE


Location
Production
Current Use
Ownership t control
Zoning
Ownership 1 control
Economic
Biological t physical
Attltudlnal
Zoning

Continue current practices
Accelerate selective
development

Interference from other
developments
Preservation/Conservation
Consumption


Compositional ft
regional dynamics







AGENCY PARTICIPATION*
L-EPA
P-NOAA
States. Prlv. Org.
C-USOA. 001


SUBJECT NATTER CONSIDE
Climate
Quality


Quality
Standards




Alternative point
source locations


Regional quality
pollutant
dispersion patterns



Surface
Sub-surface








L-BR (Supply)
P-EPA (Quality).
GS (Basic date).
MRK. BSFIN. BIN.
USDA. COE. NPS
States. Prlv. Org.
C-BOR
IFD
Quantity
Quality
Current t projected
use (current plans)

Rights
Compacts
Quality ft Quantity
Standards
Location
Attitudes
Surface development
alternatives
Ground water management
alternatives
No development
Consumption vs
conservation Quality



B
Mineral Resources
Resources



Coal
Oil ft Gas
Uranium
Other







L-BH
P-BLN. EPA. USOA.
BR. GS
States
Industry. Prlv. Org.


Location t depth
Grade
Ownership t control

MlneabtHty
Ownership, leases
Reclamation laws
Demand
Attitudes

Extraction t exportation
Local Processing
Local energy conversion
Local Industrialization
No development
Consumption vs
Conservation



A
Regional
Geology



Land form
Topography
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• L - Lead; P - Participant; C - Contributor
                                                                                                 TABLE A-2

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     Implementation of the program would be the responsibility of a
Program Management Team, consisting of one representative from each of
the major participating agencies.  The Program work would 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 would best consist of field representatives of the involved
agencies.  Members of the PMT, ad hoc committees, and work groups
should be comprised essentially of a full time personnel funded for
and committed to oil shale activities and related resource development
investigations.

     The Program Management Team would assume direct responsibility
for preparing the Program Design, interim outputs, and reports.  Initial
areas of responsibility would be the development of ad hoc committees,
of the Regional Profile and of Constraints and Alternative Strategies,
and the Analysis of Consequences.  These three study areas would be
broken up into specific tasks.  Task Groups representing particular
areas of expertise and drawing from various agencies would be formed
to carry out the work of the program.  The Groups would 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, would form a
task coordination committee reporting to the PMT.  Sepcific tasks
would be assigned to the individual Task Groups by the Program Management
Team.

     As an example, the group developing the regional profile on air
quality might also continue to identify environmental constraints for
the Constraints and Alternative Strategies Reports.  The same group,
or part of it, will also analyze alternatives and develop models.  In
addition, modeling expertise would 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 could coordinate
State, local, and Federal Involvement through programs now 1n the
planning stage.  Leadership in 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 would likely provide information
useful to specific tasks under Constraints and Strategies and under
the Analysis of Alternatives.
                                  62

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     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 must  be developed initially by
the PMT.  The preliminary design phase will make dates  and tasks explicit,
Consultation between  the Program Management Team and the Program Review
Board would be frequent and informal.  It  may  be useful  to schedule
periodic meetings with the Program Review  Board for progress reports.

     In addition to periodic oral and written  progress  reports to the
Program Review Board, the substance of the program's output would take
the form of a series  of committee reports  and  staff papers, some of
which would 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 could be made available by program
redirection and personnel detail with little sacrifice in on-going
programs.

     The Program Management Team and adequate staff must devote full
time to the OSRP.

     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.
                                 63

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                            APPENDIX II

           EPA AUTHORITIES RELATED TO OIL SHALE DEVELOPMENT
     This Accomplishment Plan has been prepared to detail the activities
that EPA must take 1n the discharge of Its statutory authority.  All of
the authorities under which EPA operates would probably have some relevance
to oil shale development and the secondary Impacts associated with 1t.
The following 1s a 11st of especially relevant legislation that direct the
Involvement detailed previously:

(1)  FEDERAL WATER POLLUTION CONTROL ACT AMENDMENTS - 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 under-
ground waters."

11... 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, demonstrations, surveys, and
                      studies relating to the causes, efects, extent, pre-
                      vention, reduction, and elimination of pollution;

                  (2) "... encourage, cooperate with, and render technical
                      services to pollution control agencies and other
                      appropriate public or private agencies, Institutions,
                      and organizations, Individuals, Including the general
                      public, ....

                  (5) "... (1n 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, ....
                                  64

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       (6)  "collect  and disseminate, 1n 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 varying
           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):
Section 105(d):
Section 107(a):
Section 201(e):
           (f):


Section 208(a):
       "...  (in  cooperation) conduct continuing comprehensive
       studies of  the  effects  and methods of control of  thermal
       discharges  ....

       "...  an accelerated  effort to develop, refine and
       achieve practical  application of:

       (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,  Includ-
           ing 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
        In  Integrating facilities for  sewage treatment and re-
        cycling  with facilities  to treat, dispose of,  or
        utilize  other  Industrial and municipal wastes  	

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

       "For the  purpose of  encouraging and  facilitating the
       development and Implementation  of areawide  waste treat-
       ment management plans
                       65

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Section 301(a):
Section 303(a):
(b):   "... a continuing areawide waste treatment management
       planning process consistent with Section 201  of this Act."

       (2) "Any plan prepared under such process shall Include
           but not be limited to - "

            (A) "the identification of treatment works necessary
                to meet the anticipated municipal and industrial
                waste treatment needs of the area over a twent"
                year period, annually updated ..."

            (B) " the establishment of construction  priorities
                for such treatment works and time schedules..."

            (C) "the establishment of a regulatory progress..."

       (1) "The Administrator shall make grants to any agency
           designated under subsection (a) of this section for
           payment of the reasonable costs of developing and
           operating a continuous areawide waste treatment
           management planning process ...."

       "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 adn propagation of a balanced
       Indigenous population of shellfish, fish, and wildlife.

(b):   "... estimate ... total maximum daily thermal level 	
            (f):
           (c):
Section 304(a):
       "Each State shall have a continuing planning process
       approved under paragraph (2) of this subsection which
       is consistent with this Act."

      (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 protection and propagation
                  of shellfish, fish, and wildlife ....
                                  66

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           (e):    "...Issue ...(1)  guidelines for  Identifying and
                  evaluating the nature and extent of non-point sources
                  of pollutants, and  (2) processes, procedures, and
                  methods  to control  pollution resulting from ..."
                  non-point sources.

Section 306(b):   (1) (A)  "... stream  electric power plants  ... (B)  ...
                 Federal  standards  of performance  ...."
Section 316:

Section 402:
(Thermal  Discharges)

(National  Pollutant Discharge Elimination System)
 11  The Administrator may  ... Issue  a  permit for  the
 discharge of any pollutant...upon  condition  that
 such discharge will meet either  all  applicable
 requirements under sections 301, 302,  306, 307, 308,
 and 403  of this Act  ..."
CLEAN AIR ACT, 1970
Section 101
Section 102(a):
Section 103(a):
           (b)
           (c)
 "Federal financial  assistance and leadership is
 essential for the development of cooperative Federal,
 State, regional, and local programs to prevent and
 control air pollution.

 "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 	

 "The Administrator shall  establish a national research
 and development program ... part of such program shall
 ... conduct and promote the coordination and acceler-
 ation 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 of such
 problem ....

 "In carrying out the provisions of 103(a) the Adminis-
 trator Is authorized to:   ... cooperate with other
 Federal departments and agencies, with other public and
 private agencies, Institutions, and organizations, arid
 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.

 "... conduct research on, and survey the results of
 other scientific studies on the harmful effects on the
 health and welfare of persons  ....

                 67

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          (f):
Section 104(a)
Section 108(a)
Section 111

Section 114(a)
"... 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 	

"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 bomcustlon of fuels.

"... 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.

(Standards of Performance for New Stationary Sources)

"For the purpose of (1) developing or assisting 1n 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
Section 101(a)
"... to promote efforts which will prevent or eliminate
damage to the environment and biosphere and stimulate
the health and welfare of man ....

"The Congress ... declares that 1t Is 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
and measures, Including financial and technical assist-
ance, 1n a manner calculated to foster and promote the
general welfare, to create and maintain conditions under
 which man and nature can exist 1n productive harmony,
and fulfill the social, economic, and other requirements
of present and future generations of Americans.
                                  68

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Section 101(b):   "...  1t  1s  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  	

Section 102      "...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 in planning  and decision making which  may have
                     impact on man's  environment;

                 (B) "Identify and develop methods  and procedures  ...
                    which  will  Insure that  presently  unqualified
                     environmental  amenities  and  values may  be given
                     appropriate  consideration  1n decision making  along
                    with economic and technical  considerations;

                 (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  in restoring, maintaining, and enhancing the
                     quality of the environment;

                 (G) "Initiate and utilize ecological  Information in the
                     planning and development of resource-oriented projects;"

EXECUTIVE ORDER 11752

     This order requires Federal  agencies to meet the standards found  1n
FWPCA-70, The Clear A1r Act, and other environmental legislation under
which EPA operates.
                                  69

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                           APPENDIX III

                    PROPOSED POLICY GUIDELINES

                  WATER AVAILABILITY AND QUALITY

                              for the

              OIL SHALE ENVIRONMENTAL ADVISORY PANEL

                            August 2, 197U
Prepared by Temporary Working Group:

Bureau of Reclamation - Salt Lake City, Utah
Geologic Survey - Denver, Colorado
                  Salt Lake City, Utah

State of Utah - Salt Lake City, Utah
Office of the Solicitor - Denver, Colorado

Environmental Protection Agency - Denver,
                                  Colorado

Department of Commerce - Boulder, Colorado

Colorado Open Space Councel, Audubon Society,
                          Denver, Colorado
Paul T. Sant, Chairman
Clyde D. Gessel
Harl M. Noble

George Snyder
Fred Fields

Gordon Harmston
Dale Carpenter

Lowell Madsen

Robert Hagen
Robert Fox

H. t>. Boyne

V. Crane Wright
                                70

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                           TABLE OF CONTENTS

                                                                  PAGE

Summary General Policy Guidelines                                  1

Proposed Guidelines, Water Availability and Quality                2
     Keep it Judicious                                             2
     Keep it Clean                                                 3
     Keep it Monitored                                             5
     Keep it Public                                                7
     Keep it Firm                                                  8

Background Data                                                    9
     Introduction                                                  9
     Surface and Groundvater Availability                          9

Reference to Related Documents, Regulations and Guidelines        12
                                   71

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         Proposed Guidelines, Water Availability and Quality


     KEEP IT JUDICIOUS.  The Mining Supervisor should require an account-
ing from the Lessees in their detailed development plans of their complete
planned vater budgets for whatever development plans they propose.  Such
a water budget should indicate all planned Lessee vater sources including
alternatives, their quantity and quality, and all planned Lessee vater
uses, the quantity to be apportioned to various onsite and offsite oil-
shale-related uses and the anticipated immediate effects and accumulative
effects of these uses on downstream and dovngradient vater quantity and
quality.  The Mining Supervisor's approval of any detailed development plan
should be conditional on concrete evidence of advance Lessee preparations to
obtain sufficient vater, on a reasonable use plan that guarantees neces-
sary quantity and quality to downstream and down gradient users, and on
a consistent balancing of the supply and use sides of this vater budget.

     The Mining Supervisor should assure that appropriate water conserva-
tion measures are undertaken and should encourage the Lessee to promote
vater reuse and alternate processing technology to reduce water require-
ments.

     Non-Federal entities obtaining leases or other rights to develop
Federal energy resources will be expected to obtain the water necessary
for the development of such resources under State procedures unless
water is available for marketing for municipal and industrial purposes
from Federal water projects.

     The lease notes that all water rights developed by the Lessee through
operations on the leased lands shall immediately become the property of the
Lessor.  One of the Mining Supervisor's functions should be guardianship
of these developed water rights for the Lessor.
                                72

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      KEEP IT CLEAN.  Each lessee must comply with appropriate local,
 state and Federal water pollution control regulations and water quality
 standards.   All discharges into surface waters require a permit from the
 Environmental Protection Agency (EPA) and/or the state which regulates
 the quantity and quality of the discharge.  A discharge for EPA permit
 purposes  is  defined to include almost all point source return flows of
 vater, including cooling water and other industrial effluents, municipal
 discharges and vater pumped from mine pits.  The effluent limitations
 in these  permits are to he consistent nationally for industrial categories
 and reflect  the application of the best practicable control technology
 by 1977,  the best available technology economically achievable by 1983
 consistent with Public Law 92-500, the Federal Water Pollution Control
 Act as amended.  State regulations govern permit requirement for dis-
 charges to ground water.

      The  development of effluent standards representing the definition
 of best practicable technology and best available technology is pre-
 sently underway or completed for certain types of facilities.  Effluent
 guidelines for power plants and secondary wastevater treatment facilities
 are available.  Affluent guidelines are presently being prepared for
 mining activities.  Standards for other types of facilities, such as
 oil shale retorting, have not been developed and currently tjre not under
 development.  All new facilities will have to apply the best available
 pollution control technology, process, operating methods, or other al-
 ternatives to minimize pollution, including no discharge if appropriate.

     Before a discharge will be allowed and a permit granted the state in
which the discharge is  to  occur must  approve of the discharge and certify
that all provisions of  the Federal Water Pollution Control Act will be
met.  Eventually,  all permits will be issued by the states and separate
certification will not  be  necessary,  but the same  effluent requirements
will be applied.   The permits can  be  issued for up to five years at a
time.  Reapplication is necessary  upon expiration  and a reexamination of
the adequacy of the effluent limits must be conducted.   After January 1,
1975> applications for  permit to discharge must be submitted 180 days
prior to the time  any wastewater is discharged into the rivers.   If there
is no discharge to surface or ground  water, there  is no need for a permit.
It is the responsibility of the Mining Supervisor  to guard against water
pollution from non-point or diffuse sources such as leakage from spent
shale piles,  saline water  storage  reservoirs, and  runoff from roads and
other disturbed land areas.  Discharges from non-point  sources are not
subject to state or Federal permits but control is necessary to comply
with Federal and state  water quality  standards and regulations and environ-
mental stipulations of  the lease.  Examples of the above considerations
are;

   (l)  Disposal system for solid  and liquid wastes must be designed and
constructed so as  to avoid landslides, control wind and water erosion,
and establish conditions conductive to vegetative  growth in the disposal
area.

   (2)  Spent shale disposal sites must be selected and prepared so as to
avoid downward percolation of leached and other pollutants into ground
vater aquifers.  Surface vater  should be diverted  around the disposal sites,


                                73

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   (3)  The supervisor should requirr mroper operation of all water diver-
sion structures to insure a minimum impact on the environment.

   The Federal Water Pollution Control Act prohibits the discharge of
toxic pollutants in toxic amounts.  Production or other vaters containing
injurious or toxic materials must be treated before discharge from the site.

   Leach solutions and seepage from waste disposal sites such as salts,
oil and other contaminants must be collected and impounded to prevent their
reaching surface and ground water sources.

   In order to serve the purposes of the Federal Water Pollution Control
Act and to protect the public health and welfare, the Act requires that
minimum standards of quality be established for all surface waters.  Each
state has adopted water quality standards for interstate and intrastate
vaters.  Such standards are established taking into consideration their
use and value for public water supplies, propagation of fish and wildlife,
recreational purposes and agricultural, industrial and other purposes.
A continuing planning process has been established in each state which pro-
vides a management plan for assuring that water quality standards are met
and that the actions are achieved in a timely and consistent manner.

   An EPA regulation is presently under review which would establish a
salinity control policy and lead to the establishment of salinity standards
and an implementation plan for controlling salinity in the Colorado River
System.  The principal requirement of the proposed regulation is that
salinity be maintained at or below present levels in the lower main stem
of the Colorado River while the Upper Basin continues to develop its Com-
pact apportioned waters in accordance with the Standards and implementa-
tion plan which are to be developed and adopted by the basin states by
October 18, 1975-
                                74

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     KEEP IT MONITORED.   Adequate surface and ground water measurement
  systems must be provided to determine  -withdrawals, usage and  return flows
  to streams and ground  water regimes.

     To establish baselines of water  quality,  to monitor quality changes during
  construction and development, and to assess  the water quality during opera-
  tion, the lessee shall establish and maintain a network of  surface  water
  monitoring stations  for use in obtaining physical, chemical,  and biologi-
  cal data and data concerning seasonal  and other variations.-  The use of
  remote sensing and automatic monitoring techniques in conjunction with the
  network is encouraged  where such appropriate techniques may effectively
  serve as a supplement  or approved alternate  to manual monitoring.   The
  number and locations of monitoring  stations, parametric coverage, and
  sampling frequencies must be adequate  to represent the quality of the sur-
  face waters and any  changes to that quality.

  Stations shall be located:

     1.  In stream segments largely unaffected by man's activities for
  determining background levels of quality and biological populations;

     2.  Upstream and  downstream from existing or proposed diversions and
  discharge or nonpoint  drainage to determine  any future; effects on  water
  quality

     3.  In major high quality water  use areas.

  In addition to the requirements contained in the  lease, design, the water
  quality network should include but  not be limited to the following  con-
  siderations:

     1.  Field measurements such as dissolved oxygen, specific  conductance,
  and pH

     2.  Parameters specifically indicated in the State's water quality
  standards

     3.  Heavy metals, and trace elements and other potentially toxic
  materials

     U.  Biological and  microbiological  parameters


     5.  General organic and nutrient parameters and specific organic parameters

     6.  Salinity,  solids, pesticides,   herbocides  radiological parameters

     Precipitation measuring stations must be  located as necessary to deter-
mine the impact of precipitation events  on water quality.

     Ground water quality monitoring  shall be  conducted to establish  baselines,
to monitor quality changes during development  and to assess the quality
during operation.  The location of stations shall be detennined by the
type and degree of use of ground water and the type and decree  of potential
pollution sources.   Parameter coverage will vary with natural and nanmade
conditions and with the  use of the waters, but should initially include
all parameters included  in the surface water  quality monitoring program.
                                   75

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     Dnphasis shall be placed upon quality assurance and standardization for
all monitoring programs.  Water quality monitoring programs should be
comprehensive.  The initial monitoring program will serve as a screening
phase after which continued monitoring of significant parameters will be
conducted on an accelerator for reduced basis as required.
                                  76

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KEEP IT PUBLIC.   The Mining Supervisor should insure  that  the Lessee implies
with all of the  lease provisions  which require the  submission of reports
and other information relating to water quantity and  quality.  Accurate,
continuously updated records of all monitored parameters should be kept
by the Lessee and submitted to the  Mining Supervisor.   All such records will
be available for public inspection  and copying.

     Reports submitted by the Lessee  should include supporting data, such
as maps, charts, photographs etc.,  and should utilize,  where possible,  non-
specialized language.

     Water use and development impacts shall be considered in determining
bond requirements.

     In order to assure that State  and Federal water  quality standards  are
met, report of the data from the  monitoring and analysis program must be
regularly submitted to the state  water pollution control agency and EPA.
                                   77

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KEEP IT FIRM.  The Mining Supervisor should act promptly and firmly to
insure strict compliance with, the water quality terms of the lease.

     In the absence of Federal, State or local requirements, the Mining
Supervisor should take whatever steps are necessary to insure that no
degradation of existing water quality will occur.  In this regard, the
Mining Supervisor should consult with appropriate Federal, State and local
agencies and other experts to determine standards of compliance.
                                     78

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                          Background Data

                           Introduction

     The vater situation, is complex and varied.   The  de' .rmination of vater
available in the Upper Colorado River Basin is  dependent  on physical avail-
ability, reservoir sites for regulation,  water  laws  and quality considera-
tions, of the Color««3o Fiver system,  in perpetuity to  the Upper Basin and to
the Lower Basin.  Two sources are available:  (1)  ground water and (2)
surface water.   The withdrawal of ground  water, which  underlies most of the
public lands in the Piceance Creek Basin  of Colorado,  may be used to satisfy
the initial needs for water.  However,  the  water bearing  strata may be de-
pleted faster than it can be naturally recharged.  Thus,  even  in Colorado,
large-scale industrial development probably would  ultimately depend on the
continued availability of surface supplies.

     Even with stringent controls to  avoid  or minimize contamination,
the long-term effects of industrialization  would result in a decline in
water quality.   Water quality impacts will  be focused  on  the White  River,
Green River, and the Colorado River.   Potential for  serious degradation
exists  but due to the uncertainties  inherent in many  of  the individual
impacts, the degree of severity cannot now  be fully  quantified. The con-
centrating effect of stream depletion,  return flows  from  municipal  and
industrial sources storage of excess  groundwater from  mine dewatering,
leachate from spent shale, and runoff from  disturbed lands may contribute
to water quality problems.

Surface and Groundwater Availability

     In addition to the physical availability of water at required
points within the Upper Colorado River Basin, its  use  is  highly de-
pendent upon storage facilities and  the laws and compacts that govern
the Colorado River.  Storage facilities are needed for most projects and
uses throughout the basin for annual regulation and short-term- carryover.
The major main stem reservoirs, such as Flaming Gorge, Lake Powell, and
the Curecanti system a:-e required for long-term carryover storage  to
provide delivery to the Lower Basin  under terms of the Colorado River
Compact of 1922 and to allow continuous use above  Lee  Ferry.   Thus, only
a portion of the lU.9 million acre feet average annual natural flow remains
available for all uses in the Upper  Colorado River Basin.

     The Bureau of Reclamation has estimated that  5.8  million  acre feet
could be consumptively I/ used under the following primary assumption
(l)  release of 8.25 million acre feet annually at Lee Ferry of the
Colorado River Compact, (2)  operation of the  storage  project  system of
reservoirs through the most critical low-flow period of  record  (1931-
196U), (3)  capacity of the reservoir system remaining after sediment
portion of water delivered, (5)  evaporation from main stem reservoirs
consistent with the other assumptions, and  (6)   allowance for  shortages
to irrigation users during subnormal years.
 I/  As defined in Article  III of the Upper Colorado  River Basin Compact

                                   79

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      set Of assumption .it      atote "'oti5 "^I*"* '"<* «» partic-
      . particularly those associated ^>, °th" COB"«»«ons or assump-
 of years used for v»ter SUMI» .»*   ^   iovnstream deliveries; period
 of resenoirs due ™ sedS?     ***** o*er««<>ni l^ure  condUion
 i.«.  irrigate indust"^^"^ £ «f «bution of uses .

 ~ « Projected WUld ^ ^^•^^£^^,^2 of
 deliveries at Lee Perry would increase the level of  available vater
 for use in the Upper Basin by far  the greatest  amount.  Other assumptions
 could either increase or decrease  the available supply by a  smaller but
 substantial annual amount.

      An engineering consultant's study performed for the  Upper Colorado
 River Commission 2j determined that  6,3 million acre-feet would be
 available for consumptive use if 7.5 million acre-feet only released
 at Lee Ferry and no shortages were required of  Upper Basin users.  The
 above cited studies illustrate the effect  of differing assumptions on
 the probable water supply available  for use in  the Upper  Colorado River
 Basin.   Thus, estimates  of water supply will likely  remain within a range
 rather than a single figure.

      The Upper Colorado  River Basin  Compact of  19^8  gave Arizona the right
 to the consumptive use of 50,000 acre-feet  per year, and  the remaining
 water is apportioned to  the other  Upper Basin States in the fpllowing
 percentages:
                 Colorado	51.75
                 New Mexico	11.25
                 Utah	23.00
                 Wyoming......	lU.OO

      Estimated Colorado  River water availability, 1971* depletion includ-
 ing main stem evaporation, committed future uses, and water remaining are
 as  follows:
State
Colorado
Utah
Wyoming
Share at
5.8 MAP
level
2,975,000
1,322,000
805,000
Estimated 197^
depletion
2,097,000
811,000
387,000
Estimated Future
Committed Use
850,000
381,000
371,000
Remaining
Water
Tear 200(
29,000
130,000
1*7,000
The estimated future committed uses are based upon committments in authorize
federal and non-federal projects.  It is unlikely that all of the projects
to utilize estimated future committed uses will be constructed as pro-
jected.
2/  Water Supplies of the Colorado River, Tipton and Kalmback, Inc.,

    Denver, Colorado.  July 1965.

                               80

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         Water available from exist?rg and potential facilities is as follows:
State
Colorado
Utah
Wyoming
Thousands of Acre-Feet
Amount From
Existing
Facilities
Green Mt. U5"\
Ruedi 33 j
Flaming Gorge
Fontenelle
Amount From
Additional
78. I/ West Divide
Yellow Jacket
Yampa River
130. 2/ Jensen Unit
Upalco Unit
Uintah Unit
258. 6/

77.
100.
100.
7
2
3
Total
Without
Aiifmen+ft+l r»H
I/ 167. %
~~ 1U2. $J
 Upper Basin Total
U66
289.
567.
I/  Presumes use to be from the Colorado River in the vicinity of Rifle,
    Colorado.
2/  Presumes use near the Green River in Uinta Basin of Utah,  but would
    be marginally located with respect to development in White River  Basin.
    Could be used in Colorado or Utah.
    Would exceed compact entitlements.
5j  Maximum available for oil shale development from presently uncommitted
    supplies.
6f  Part of this water has been identified for coal resource development.

     It should be stressed that while the remaining unconnitted supplies
both undeveloped and from existing facilities, could be nade available
for oil shale development, there will be many competing uses for this
water.  These include domestic, agriculture, power generation, coal
gasification and liquefaction, municipal and other industrial, and fish-
ing and other recreational uses, and as a practical matter, significant
quantities will probably be utilized by competing uses.

     Groundwater might satisfy demands in Colorado for nuch of the pro-
cessing needs through 1987 for those mines on Federal lands in the nor-
thern part of the Piceance Creek Basin.  In fact, some mines might ini-
tially pump more water than could be used because of dewatering problems.
Limited explorations to date indicate there are no known significant
dependable quantities of groundwater in or near the prototype  oil shale
lease tracts in Utah or Wyoming.  The amount that must be pumped is related
to local aquifer characteristics and to the method of mining.   The quan-
tity that could be used depends on the quality of the groundvater and
how much change in quality takes place.  The quality of the groundwater will
be different and the rate of quality change will be different  at different
places in the basin.  In the event that groundwater quality were not  suitable
for all uses (which might be true in some areas soon after development
and in all areas before a mine is exhausted), then part of the demands
must be met by diversions from the White River, Green, Yampa,  and Colorado
Rivers.
                                 81

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      Reference  to Related Documents.  Regulations and Guidelines

 j..   Rules,  regulations  and procedure relating to administration of State
     Water Lav
       Colorado
       Utah
       Wyoming

 2.   State Water Quality Standards
       Colorado
       Utah
       Wyoming

 3.   Report  by Secretary of Interior "Task Force on Water for Energy," to
     be appended later.

 k.   Public  Health Service Drinking Water  Standards

 5.   EPA Regulations  for National Pollutant  Discharge Elimination System
       (Effluent Permits)
 6.   EPA Effluent Guidelines
       Secondary Treatment
       Power Plants

 7.   EPA Oil Pollution Prevention Regulations

 8.   EPA Colorado River  System Salinity Control Policy  and  Standards .Procedures

 9.   EPA Guidelines Establishing Test  Procedures for Analysis of Pollutants

10.   U.S.G^S.  T.W.R.I.  Series Publications
       (.Techniques of Water-Resources  Investigations)
          Book 1 - Surface Water Techniques
          Book 2 - Collection of Environmental Data
          Book 3 - Applications of Hydraulics
          Book U - Hydrologic Analysis and Interpretation
          Book 5 - Laboratory Analysis
          Book 6 - Modeling Techniques                     *
          Book 7 - Automated Data Processing and Computations
          Book 8 - Instrumentation
          Book 9 - Water Data Reports (Preliminary)
                   Plus Professional Papers, Water Supply Papers and Open
                   File reports.
11.  Previous panel ^morandarecc^ending monitoring techniques and
     analytical measurements  (e.g., see U/23/7U, 5/17/7^, 5/27/7", et al
     memoranda and attachments of George L.  SnyderJ
                                                                         t
12   Previous panel memorandum dated  5/1677U "Water Available for Oil Shale
     Development in the Upper Colorado River Basin and Related Water Quality
     Aspects" - Paul T. Sant
                                 82

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              APPENDIX IV
            AIR GUIDELINES

           Submitted to the
Oil Shale Environmental Advisory Panel

         Ad hoc Air Workgroup
       John A. Gre-en, Chairman
            July 17, 1974
                    83

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                        Table of Contents

Introduction

Summary of Lease Stipulations Related to Air Quality

Air Guidelines

     General
     Planning Stage
     Exploratory Stage
     Construction Stage
     Operations Stage

Appendix:  Summary of Federal, State and Local Air Regulations

     Ambient Air Quality Standards

          National
          Colorado
          Utah
          Wyoming

     Air Emission Standards

          National
          Colorado
          Utah
          Wyoming

     Other

          EPA Promulgated Indirect Source Reviov/ Regulation
                                 84

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                               -1-

Introduction

     Each lessee will  be required to  adhere  to  the  pertinent local.
State, and Federal  air regulations.   The  National Ambient Air Quality
Standards (NAAQS) apply to each of  the  oil shale States  unless the
State has a more stringent standard,  in which case  the State stan-
dard would apply.  Under Section 110  of the  Clean Air Act of 1970,
the States were required to develop implementation  plans to achieve
the NAAQS.  The emission limitations  included in the plan must be
met, and the proposed  facility must undergo  a new source review
to determine if a permit to construct should be issued by the State.
The new source review, which applies  to stationary  sources and also
certain highways, airports and parking  lots, involves an evaluation
to determine whether emissions from the facility or the  mobile source
activity associated with the facility and the resultant  air quality
are compatible with the pertintnt State and  Federal  standards.

     Air quality maintenance areas  ere  being identified  where special
plans will be developed to insure that  the N/
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                               -2-
       SUMMARY OF LEASE STIPULATIONS RELATED TO AIR QUALITY
1.  Baseline Data
    a.  Air Quality monitoring - 2 years at 4 stations
        (1)  Particulate, S02» H2S — mandatory
        (2)  HC, NOX, others — conditional
    b.  Meteorological data collection - 2 years at 1 station
        (1)  Wind speed and direction
        (2)  Temperature at 30 feet and 100 feet above plant
        (3)  Relative h'.'nridity at ground level, 30 feet and 100
             feet above plant.
    c.  Lessee main^ins records of all baseline data collection
        and monitoring programs
2.  Oparations Data
    a.  Air Quality
        (1)  Begin 6 months prior to develop.Trnt operations ond
             continue through extent of lee.se period
    b.  Meteorological
        Same period r.s sir quality
3.  Observe all local, State, and Federal air quality regulations
    (See appendix for specifics)
4.  Minimize fugitive dust emissions
5.  Lessee must submit annual progress report on development
    program and this will report on monitoring programs
                                 86

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                               -3-
                          AIR GUIDELINES
General
  The panel  should  recommend to the Mining Supervisor that:
    1   Each lessee should be required to develop an environmental
        analysis  report  for his specific site and development  plan.
        a.   The report should discuss environmental impacts  and
            include, but not necessarily be limited to
            (1)  Siting  considerations
            (2)  Proposed mining method
            (3)  Retorting and/or  in situ process
            (4)  Waste disposal plan
            (5)  Land reclamation  plan
            (6)  Air and water quality considerations
            (7)  Control  equipment
        b.   Tho impact of primary  air pollutant  sources  (e.g.,
            fugitive dust, retorting, refining,  and associated
            power plants) should be quantified.
        L.   Consideration should be given to quantifying the impact
            of secondary sources (e.g.,  automotive, offsite construc-
            tion, and recreational activities) on  air  quality.
        d.   Adverse findings disclosed by the environmental  analysis
            should  be corrected and  the  mining plan modified accordingly.
    2.  He  support  a program to  regionally  evaluate the impact of
        several oil shale operations on  the  surrounding air quality.
                                     87

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                               -4-
                                       *
Planning Stage

  The Panel should recommend to the M.S.  that:

    1.  The appropriate State agency and  EPA have an opportunity
        to review and comment on any pre-planning by the lessee
        which pertains to air quality and report back to the Panel.
        Items of consideration would include

        a.  Evaluation of the location of monitoring sites by EPA
            and the relevant State agency.

        b.  Air pollution control technology, and

        c.  Air monitoring equipment.

    2.  The lessee determine permit requirements for a new source
        to insure that all the necessary  environmental data and
        equipment information are available.

    3.  The point of estimated maximum concentration be chosen on
        the basis of an acceptable computer diffusion model employing
        the meteorological data currently available.  If after the
        two year baseline data gathering  period a worse site is
        identified by the lessee;, State agency or EPA via a refine-
        ment of meteorological parameters or via more specific pro-
        cess siting data, the monitoring  sites should be relocated
        for the next phase of program.

    4.  EPA and State msteorologists review meteorological data
        needs.  Surface readings will not provide adequate data
        for diffusion modeling i-nd upper  atmospheric wind and
        temperature data may be required.

    5.  The lessee be required to insure  that averaging times for
        air quality monitoring be performed on a schedule compatible
        with the relevant air quality standards.

    6.  The lessee be required to monitor for S02» particulars,
        H2$, NOX> HC, and oxidants.  Available EPA Quality Assurance
        manuals for air quality monitoring should be followed.

    7.  The lessee be required to use the best available control
        technology in controlling emissions.  Technical assistance
        on control equipment issues could be supplied to the Panel
        by the State air pollution control agency and EPA.

    8.  Since this is a prototype operation, the lessee be encouraged
        to utilize new and original  ideas to reduce emissions from
        the facility and related operations.
                                 88

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                            -5-
 9.  The lessee analyze quarterly composite  particulate samples
     for trace elements during  the baseline  data collection program.

10.  The lessee consider ways of providing mass transit as a means
     of reducing the secondary  impact.

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                               -6-

Exploratory Workstage

  The Panel should recommend to the M.S. that the lessee be required
to continue air quality and meteorological monitoring during this
phase of their development, if this stage extends beyond the two
year baseline study.
                                  90

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                               -7-
Construction Stage
  The Panel should recommend to the M.S.  that:
    1.  The lessee be required to minimize the  amount of land
        disturbance during the period of  construction.
    2.  The lessee be required to pave roads where possible to
        reduce fugitive dust.  Any  minor  unpaved roads must use
        fugitive dust controls.
                                  91

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                                 -8-

Operations Stage

  The Panel should recommend to the M.S.  that:

    1.  An operations manual be submitted by the lessee for all
        phases of the operation.  This manual  should include, among
        other things:

        a.  Proper control be exercised of all  dust emissions as
            a result of materials handling operations.  Considera-
            tion should be given to covering conveyors, capturing
            crushing emissions, wetting down storage piles, etc.

        b.  Consideration to be given to routine dust suppression
            procedures such as wetting down exposed areas where
            spent shalt* is disposed.  This typa of effort must
            be compatible with other environmental considerations,
            i.e., not create salinity problems, etc.

        c.  Procedures to be followed by the lessee in the case
            of an air stagnation situation.  Such procedures should
            be compatible with the relevant state air pollution
            control agency requirements.

        d.  Maintenance plans and procedures for insuring optimal
            reliability from the emission control equipment.  Fre-
            quent inspections should be provided for, and emission
            monitoring conducted.

        c.  Procedures be established for treating malfunction situa-
            tions, especially where the ambient air standards might
            be violated.

    2.  The lessee develop an air quality monitoring program, com-
        plete with calibration procedures, instrument replacement
        schedules, etc., to insure the quality of the information
        which is collected.

    3.  If at any time during the operational  stage of the program,
        air quality standards a»s violated under normal operating
        conditions, the lessee must curtail operations to the degree
        necessary to meet the standards.   Normal operations would
        only be resumed after the lessee had submitted and received
        approval of an emission control plan.
                                92

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                             APPENDIX V
Mr. Will1am Rogers
Chairman
011 Shale Environmental Advisory Panel
Building 67, Room 638
Denver Federal Center
Denver, Colorado  80225

Dear Mr. Rogers:

     As follow-up to earlier staff meetings on water quality monitoring,
I have enclosed a list of parameters we feel should  be monitored for at
each surface water quality monitoring station for the tracts C-a,  C~b,
U-a, and U-b.  The listing also recommends a frequency and, where  ap-
propriate, detection llPilts.  Although this 11st may seem extensive, we
have given It careful consideration and feel 1t  represents a minimum pro-
gram when one considers both cost and coverage.

     Please note that the 11st also contains recommendations for reducing
the number of parameters arid the frequency of measurement should redundant
or unnecessary data be collected.  In view of the unknowns related to
needed water quality monitoring at this time. I  hope your approval of  a
data collection program would also retain the ability to add parameters
and/or stations, and to Increase frequency should such  Increases be war-
ranted.

     We regret that our recommendations are only now reaching  you. How-
ever, such recommendations Imply the commitment of significant resources
and cannot be made hastily.  Concurrently we may be evaluating significant
changes In oil shale operations based on these data and  we would not wish
to find appreciable deficiencies 1n the data after many years  of collec-
tion.  Proper attention to these details now can help  us assure that
later delays In the program are not encountered as a result  of our own
mistakes caused by haste.  Should you have any questions regarding this
11st or how it was developed, please feel free to contact us.

                                       Sincerely,

                                       "Signed"

                                       John A. Green
                                   Regional Administrator
                                 93

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                        Continuous Measurements
 Specific Conductance
   Temperature
                         1
Turbidity
 PH
^Dissolved Oxygen
 Suspended Solids
 Dissolved Solids
 Calcium
 Magnesium
 Potassium
 Silica
 Sodium
Semi-Monthly

   Bicarbonate
   Bromide
   Carbonate
   Chloride
   Fluoride
   Nitrate
   Nitrite
   Sulfate
   Sulfide
Total Alkalinity

Ammonia
Kjeldahl Nitrogen
Ortho Phosphorus
Total Phosphorus

COD
Phenols
Oil & Grease
                               Monthly

        3Gross Alpha                             ^Gross Beta
Fecal Coliform          Fecal Streptococcus          Total Coliform
1.  Principal stations on perennial  streams  only - S-M on other streams.
2.  In addition to semi-monthly measurements, quarterly detailed surveys
    lasting 24-48 hrs of dissolved oxygen will be run.  These surveys will
    involve measurements at sufficient frequency to characterize diurnal
    D.O. fluctuations.
3.  If gross alpha activity exceeds 4 picocuries/liter, specific analyses
    will be made for Uranium, Thorium $ and Radium 226.
4.  If gross beta activity (exclusive of tyo) exceeds 100 picocuries/liter,
    specific analyses will be made for Uranium, Thorium* Radium 226,
    Lead 210 and Radium 228.
                                   94

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                          Monthly (Cont.)
                         Minimum Acceptable
                        Detection Limit (mg/1)
         Analytical
       Detection Limit
Aluminum
Arsenic
Barium
Boron
Cadmium
Chromium
Cobalt
Copper
Cyanide
Iron
Lead
Lithium
Mercury
Manganese
Molybdenum
Nickel
Selenium
Vanadium
Zinc
.1
.01
.4
.05
.005
.05
.02
.05
.0005
.05
.01
.5
.001
.01
.005
.05
.001
.02
.05
.01
.01
.4
.0002
.001
.01
.02
.005
.0005
.004
.01
.02 - 1.0
.0002
.005
.001
.01
.001
.02
.005
                              Quarterly
              BOD-5 day

               Color
     DTOC

Dissolved Gas
5.  If the TOC concentration exceeds  (10) mg/1,  the  sample will be further
    analyzed for dissolved organic carbon  (DOC)  and  suspended  organic  carbon
    (SOC).  Further an acid extraction will  be done  with  analysis for  sulfur
    and a base extraction will  be done with  analysis for  nHronpn.
                                   95

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                           Quarterly  (Cont.)
 Odor
 Antimony
 Beryllium
 Silver
 Strontium
 Titanium
 Zirconium
Suspended Sediment
      Minimum Acceptable
     Detection Limit (mg/1)
               .1
               .01
               .01
               .1
               .5
               .75
   6Bed Sediment
   Analytical
 Detection Limit
      .06
      .001
      .01
      .06
      .02
Asbestos  and  similar  fibers
                             Semi-Annual
Pesticides
Polycyclic Aromatics
ABS
NBAS
Bismuth
Gallium
Germanium
Thorium
Tin
Yttrium
       To be included in spectrographic  semi-
       quantitative scan of trace elements
6.  Bottom sediment samples will be collected and analyzed for mineralogy,
    particle size distribution and rate of deposition.
7.  If neutral oil fraction of organic extraction warrants.
                                   96

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                      Additional Considerations
a.  Three consecutive samples below the "minimum acceptable detection
    limit" would reduce a parameter to the next lowest frequency.

b.  Six consecutive samples below the "minimum acceptable  detection  limit"
    would reduce the parameter to semi-annual  (or annual depending on a).

b.  No fewer than four measurements would be run for any parameter
    unless no flow occurs for both years of the baseline data  collection
    period.

d.  If one quarter were to pass with no flow at a station  or stations
    recorded on scheduled sampling days, there shall be increased effort
    to have personnel available to sample any flow event.

e.  Two quarters shall never pass without a sampling being collected
    unless the company can conclusively show that no flow  occurred  in
    the second three months.

f.  Semi-annual shall mean one late winter-spring measurement and one
    late summer-fall measurement.                               ,

g.  Quarterly sampling shall mean in addition to the semi-annual
    measurements two additional measurements in different  hydro!ogic
    and seasonal circumstances.

h.  All data shall be collected in a manner that attempts  to character-
    ize flow in terms of precipitation events (location, amount, dura-
    tion, time, etc.)

i.  Attempts shall be made to correlate TDS as a function of flow.   If
    a correlation is found, intensive surveys of particular precipita-
    tion events shall be conducted to determine which parameters cause
    the correlation.

j.  Microinvertebrate sampling shall also be conducted in such  a matter that
    it is thoroughly coordinated with the water quality monitoring  pro-
    gram.

k.  Additional modification of the monitoring schedule, both increases
    and decreases, can be made if comprehensive USGS, EPA,  State, BLM,
    and citizen review warrants.
                                    97
   U ft. GOVERNMENT PRINTING OFFICE _>7S-S6BM« REGION NO. 8

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  "Sec. 2.  The purposes of this Act-are:  To
declare a national policy which will encourage
productive and enjoyable harmony between man
and his environment; to promote efforts which
will prevent or eliminate damage to the envi-
ronment and biosphere and stimulate the health
and welfare of man; to enrich the understanding
of the ecological systems and natural resources
important to the Nation . ..."
National Environmental Policy Act

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