Issue Paper on

Oil Shale Technologies
           for the

        July 18, 1979
   Section 11  Workshop
     Denver, Colorado
                       United States Environmental
                       Protection Agency
                       Office of Energy, Minerals
                       and Industry

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                         TABLE OF CONTENTS
                                                                  Page
                                                                ..Number
Glossary	     iv

Executive Summary 	      v


I.    INTRODUCTION 	      1


II.   TECHNOLOGY BACKGROUND AND ENVIRONMENTAL CONCERNS 	      4

      A.  Oil Shale Technology 	      4

      B.  Environmental Concerns	      7
III.  DOE ENVIRONMENTAL PLANNING AND REVIEW PROCESS AND
      THE OIL SHALE TECHNOLOGY 	    12

      A.  The Extent to Which DOE has Followed
          the Process	    12

      B.  The Extent to Which DOE has Carried out
          the Planned Environmental Reseach 	    16

      C.  The Extent to Which the Results of DOE's
          Environmental Research has Affected Oil
          Shale Technology Development Decisions 	    17

      D.  The Opportunities for the Concerned
          Public, State, and Federal Agencies, and
          Industry to Participate in the Process 	    17
REFERENCES 	    21


APPENDIX A - Oil Shale Technology Description 	    A-l
                                   ii

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                       LIST OF TABLES AND  FIGURES
 Table                                                               Page

   1          Environmental Planning and Review Documents for
             Oil  Shale                                                 ix

   2          Environmental Concerns and Possible Mitigation Methods    10
Figure

   1          Shale Oil Deposits  in Western United States               Aa
                                     111

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                          GLOSSARY
AOSS         Area Oil Shale Supervisor
ASEV         Assistant Secretary for Environment
CS           Office of Conservation and Solar Applications
DOE          Department of Energy
DOI          Department of Interior
EA           Environmental Assessment
ECC          Environmental CoordinatingCommittee
EDP          Environmental Development Plan
EIS          Environmental Impact Statement
EPA          Environmental Protection Agency
ERD          Environmental Readiness Document
ERDA         Energy Research and Development Administration
ESAAB        Energy Systems Acquisition Advisory Board
ESAPP        Energy System Acquisition Project Plan
ET           Office of Energy Technology
EV           Office of Environment
MIS          Modified In-Situ
NEPA         National Environmental Policy Act
OSEAP        Oil Shale Enviromental Advisory Panel
PPMS         Program and Project Management System
RA           Office of Resource Applications
                             iv

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                           EXECUTIVE SUMMARY

     The 1979 Section 11 analysis is focused on the Department of Energy's
Program and Project Management System (PPMS) and its Environmental Research
Planning and Assessment Process.  Section 11 now charges EPA with the respon-
sibility of reviewing the DOE program for the emphasis given to environmental
concerns.  EPA is interested in making known its procedures for this review
and soliciting participation from a broad spectrum of participants.

     This paper's specific objectives, in conjunction with the background
document-"The Federal Nonnuclear Research and Development Act (PL 93-577),
Section 11, Environmental Evaluation" (June 1979)-are to:

           »   provide information on DOE's environmental planning
               and review process
           •   discuss how that process has functioned in the case
               of the oil shale technology
           •   raise issues to stimulate and focus discussion at
               the July 18, 1979, public workshop in Denver.

Of particular importance are the issues  associated with increasing
public involvement-the concerned public; local, state, and Federal
agencies; and industry-in the oil shale technology decision-making
process.

     Although oil shale deposits occur in many parts of the United States
about 50 percent of the highest-quality oil shale resources are found in
a sparsely populated, semi-arid plateau region (the Green River Forma-
tion) of southern Wyoming, northeastern Utah, and western Colorado.
The history of oil shale development in this region has been split
between technology development on public and privately owned lands.  The
U.S. Department of the Interior (DOI) has been deeply involved in oil
shale development efforts primarily because the Federal Government
owns about 80 percent of the oil shale reserves and controls some of the
major water resources which will be needed for oil shale development.  DOI's
efforts to interest private companies in oil shale development was high-
lighted by their Prototype Oil Shale Leasing Program in the late 1960s.

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     Although DOI has been the Federal "lead" agency in oil shale development.
The Energy Research and Development Administration was the lead agency for oil
shale commercialization efforts.   This responsibility has now passed to the
Department of Energy.

     In May 1979, DOE completed a comprehensive "Oil Shale Research, Development,
and Demonstration (RD&D) Program Management Plan," whose primary objective is
to foster the development of a commercial oil shale industry by the mid-1980s.
The plan consists of four principal activities for research and development
to assist in the growth of the industry.   One of these activities is research
on environmental concerns.

     The most serious environmental concerns related to oil shale appear to
be land reclamation, air pollution emissions, water pollution, and worker health
and safety.  Much of the ongoing environmental research is still involved with
characterizing the pollutants.  Once characterized, technicians hope that control
technologies can be developed to handle them.  However, the cost of such controls
may make oil shale more expensive than alternative natural and synthetic fuels.

     There is substantial regional and local concern in Colorado, Utah, and
Wyoming that planned economic growth, availability of water, and other development
issues be properly considered in decisions on oil shale projects in the area.

DOE's Planning and Review Process

     DOE's research and development programs are organized around general energy
technologies (such as nuclear, fossil, solar, and geothermal) and are designed
to move these technologies through sequential development phases from basic
research to commercialization.  Development activities are divided into two
stages, each consisting of several phases.  The technology-based stage is com-
prised of basic applied research phases and an exploratory development phase.
The second stage, energy systems acquisition, includes four phases—technology
development, engineering development, demonstration, and commercialization.

     In early 1978, DOE formulated an internal Program and Project Management
System (PPMS) to guide expenditures (Outlay Programs) for technologies through
the various development phases.  Outlay Program Plans are comprised of two
                                     vi

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components—Technology Program Plans (TPP) and Environmental Development Plans
(EDP).  The objective of the TPP is to define a development strategy for a project
or group of projects of the same technology moving through the development
phases.  The EDP will then identify and integrate required environment safety,
and health research within the appropriate phases of the technology project or
projects.

     As site-specific technology projects are supported, separate Project
Environmental Plans (PEP) detailing the necessary environmental research and
jointly prepared by the DOE Office of Environment and the appropriate program
office.  Environmental Readiness Documents (ERD), independent assessments pre-
pared by the Office of Environment to determine the "readiness" of the technology
to move to the next development phase,  provide the basis for the Office of
Environment's position on the environmental acceptability of a DOE technology
program or project at the major decision points in the PPMS.

     The combination of the EDPs, PEPs, and ERDs, coupled with a formal manage-
ment structure for their preparation and implementation, comprise the Environ-
mental Planning and Assessment Process for DOE's planning and review system for
emerging technologies.  While the EDPs, PEPs, and ERDs are not intended to be
part of the formal National Environmental Policy Act (NEPA) requirements, they
are perceived as building blocks leading to the preparation of Environmental
Assessments (EA) and Environmental Impact Statements (EIS).

     A recent development in oil shale planning and review has been the prepara-
tion of the Oil Shale RD&D Management Plan.  This plan lays out in substantial
detail the technological and enviornmental research required for oil shale
during the next 10 years if a major effort is undertaken to commercialize the
technology.  The Management Plan builds upon the Oil Shale ERD and parts of the
plan will be included in the updated Oil Shale EDP currently being written.

Oil Shale Issues

     This paper identifies a number of issues concerning DOE's environmental
planning and review process as it has impacted the oil shale technology.  The
potential impact of oil shale on a national basis and in the Colorado, Utah,
and Wyoming area makes it imperative that there be substantial local and public
involvement in DOE's environmental planning and review process including the new
Oil Shale RD&D Management Plan.

                                     vii

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     Since the DOI Prototype Oil Shale Lease Program was initiated in the early
1970s, there has been a number of National Environmental Policy Act (NEPA)
documents prepared on oil shale.  There was a Project and Program Environmental
Impact Statement prepared by DOE in 1972 and 1973,  respectively.  In 1977,  at
least seven project Environmental Assessments and a programmatic Alternative
Fuels EIS—only part of which covered oil shale—was prepared by the Department
of Energy.

     At the same time (1977), Colony Development Corporation prepared a project
                 v
EIS for the Department of the Interior.  Currently two programmatic and one
project EIA are under preparation by the Development of Energy.  (See Table 1.)

     As the Prototype Program evolved, the need was recognized for a continuing
mechanism for review and coordination between the government and public sectors
concerned with oil shale after leasing and during development; this resulted in
the creation of the DOI Oil Shale Environmental Advisory Panel (OSEAP) in 1974.

     During the 1974-1999 period, the Panel held 24 public meetings, had 15 tem-
porary workgroups, and prepared a number of papers and annual reports.  The
Panel's charter expired in late 1977, and was reactivated in late 1978.  Under
its new charter, the primary objective of the Panel is to advise the Department
of the Interior in the enforcement of the provisions of the prototype oil shale
leases for the protection of the environment.  Upon special request, the Panel
may review the environmental aspects of the oil shale paogram of the Department
of Energy.

     In 1978, at the request of the State of Colorado, DOE formed the Environ-
mental Modified Ih-Situ Task Force to coordinate a DOE-Colorado comprehensive
program of environmental research at the Occidential Modified-In-Situ Project.
The Chairman of the Task Force, the DOE Assistant Secretary for the Environment,
formed an advisory group with representatives from environmental groups, a
single oil shale workers union, industry representations, and others.

     DOE representatives meet with members of environmental groups on an
informal basis to exchange views and information on DOE environmental research.
The public, state or local governments, or environmental groups have not yet been
involved in the drafting of the new Oil Shale RD&D Management Plan.  DOE plans to
solicit public comment on its Plan following the formal submission to Congress
in late June 1979.
                                     viii

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                                      TABLE 1
         ENVIRONMENTAL PLANNING AND  REVIEW DOCUMENTS  FOR  OIL SHALE
YEAR
DOCUMENT
COMPLETED
1971
1972
1973
1974
1975
1976
1977
1973
1979
1980
EA*






'.ieoK-inefics ?roj.
Equity Oil Proj.
Occidental Proj.
Talley-rrac Proj.
Oow Chemical Proj.
Anvil Point Proj.
Rock Springs Proj.



EIS

001 Oil Shale 3e-
tort Research Pro-
ject (2/72)
P8-203-318-F
001 Prototype Oil
Shale Leasing
Program (8/73)
EIS-73-U23F



» 001 Colony Oil
Shale Resource
Project (6/77)
• DOE Alternative
Fuels Qemo Prog.
(includes oil
shale)

« P-togrtOffmotic.
• $3 pun. 3cw,te^
7ix Cttdot
» Pastaho Tioj-nt

EDP






Oil Shale (5/77)
EDP/F-OK77)

QU. S,'ioie !r/r?)

£30







Oil Shale
(9/78)


• "
PEP:










*9ecause no central  list of EAs Is maintained, some EAs may  be missing from this 'able.
 NOTE:  Italics indicate document is in preparation.
                                         ix

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     The Department of the Interior and the Department of Energy have held a

large number of meetings and technical comments and allowed considerable public

participation in the oil shale development program:


     •  Had sufficient information on the environmental consequences of oil
        shale been developed?

     •  Has this information been disseminated widely enough?

     •  Environmental research is clearly a part of the Oil Shale RD&D Manage-
        ment Plan] however, the dual role of the Plan (i.e., technological
        and environmental development toward commercialization) raises ques-
        tions as to how conflicts will be resolved.


     There has been some progress regarding program coordination at the Federal

level on oil shale technologies.  However, the adequacy and effectiveness of

these efforts may be questioned.


     •  Has the Federal Government coordination efforts on these technologies
        been useful at the state and local levels?


     The above issues, and the issues presented in the background document,

"Section 11, Environmental Evaluation," should serve as the basis for the
workshop discussion in Denver.
                                      x

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                            I.   INTRODUCTION

     One of the primary purposes of the Department of Energy is to carry out
the planning, coordination, support, and management of a balanced and compre-
hensive energy research and development program, including programs for the
optimal development of various forms of energy production and conservation.

     This paper is part of the 1979 Section 11 analysis, which is focused on
DOE's management procedures for ensuring that adequate emphasis is given to
environmental protection measures as emerging energy technologies are devel-
oped.  The paper examines the functioning and effectiveness of DOE's environ-
mental planning review process with respect to the oil shale technology.

     The paper's objectives are to:

     •  Discuss how DOE's Environmental Planning and Review Process has
        functioned in the case of the oil shale technology;
     •  Raise issues on selected aspects of the process; and
     •  Provide a basis for stimulating discussion at the July 18 workshop
        in Denver.

     Oil shale has long been regarded as a potential source of energy, with a
U.S. interest in developing an oil shale industry stretching back nearly 60 years.
However, with the discovery and ready availability of large petroleum reserves
both in the United States and abroad, interest in developing an oil shale
industry declined rapidly.

     Renewed enthusiasm for oil shale appeared in the mid-1960s resulting in
increasing pressure from industry and state governments for new Federal oil
shale leasing.  Planning for the Prototype Program coincided with the national
upswing in environmental concern and passage of the National Environmental
Policy Act (NEPA) in 1969.  By late 1969, interest in oil shale development
once again waned  as  a  result of the identification of environmental problems
and for lack of strong economic incentives.

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     In 1971, President Nixon in his "Clean Energy Message" directed the
Department of the Interior, then the lead agency in oil shale programs, to
develop a Prototype Oil Shale Leasing Program to lease shale deposits to
companies interested in technology research.  The Arab Oil Embargo of 1973
and the subsequent drastic changes in world oil prices served to reinforce
the new wave of interest among government and industry in oil shale develop-
ment.

     The U.S. Department of the Interior (DOI) has been deeply involved in oil
shale development efforts primarily because the Bureau of Land Management
has primary management responsibilities for the Federally owned oil shale
reserves (approximately 80 percent of known reserves),  and the Bureau of
Reclamation manages the very complex water resources that are vital to
oil shale development.

     Although DOI has been the Federal "lead" agency in oil shale develop-
ment, the Energy Research and Development Administration and now the
Department of Energy is the "lead" agency for oil shale commercialization
efforts.

     In May 1979, DOE completed a comprehensive "Oil Shale RD&D Program
Management Plan" whose primary objective is to foster the development of a
commercial oil shale industry by the mid- 1980s.  The thrust of the overall
DOE oil shale program is to assist in the development of this industry
through research and development and financial incentives, not to mandate
the choice of technology or markets to be served.

     The Oil Shale RD&D Plan is structured to parallel and complement
activities that commercial and industrial developers would undertake in
establishing a commercial oil shale operation.  The major emphasis of the
Plan is on in-situ retorting processes because the technology has not
advanced to the point where it has been proven to be technically or
economically feasible.  By 1985, DOE hopes to provide the oil shale
technology base required for first-generation commercial operations in
surface retorting and vertical modified in-situ retorting (Draft DOE, Oil
Shale Environmental Development Plan, June 1979).

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     Organizationally within DOE,  four program offices have major respon-
sibilities in the development of oil shale technologies.   The Office of  Energy
Research carries out basic and applied research on oil shale.  Those tech-
nology processes selected for further development  are passed to the  Office
of Energy Technology.   The Oil Shale RD&D Program Management Plan is under
the cognizance of the Office of Fossil Energy within the  Office of Energy
Technology.

     Oil Shale processes that successfully pass through the technology develop-
ment, engineering development, and demonstration phases are assigned to  a
resource manager in the Office of  Resource Applications for the fourth and final
phase — commercialization.

     The Office of Environment has primary responsibility for identifying and
assessing oil shale environmental  concerns at each phase  of the developmental
sequence.  The Office of Energy Technology also has staff with environmental
responsibilities for specific technology processes or program.

     Section II of this paper summarizes information on both the oil shale tech-
nology and the environmental concerns associated with it.  Section III examines
the DOE environmental planning and review process as it has influenced oil
shale technology. A more detailed  description of the oil  shale technologies  is
included in Appendix A.

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              II.  TECHNOLOGY BACKGROUND AND ENVIRONMENTAL CONCERNS

A.   OIL SHALE TECHNOLOGY

     Although oil shale deposits occur in many parts of the United States,
about 50 percent of the highest quality oil shale resources are located in a
single geological formation in parts of Colorado, Utah, and Wyoming known as
the Green River Formation (see Figure 1).  A ton of this shale can be processed
to yield approximately 25 gallons of crude oil.  The U.S. Department of the
Interior (DOI) has estimated that 80 billion barrels of oil can be recovered
from the Green River Formation using existing technology, and as much as 800
billion barrels might eventually be recovered by more advanced technology and
more expensive technology.*  About 80 percent of the land covering the Green
River Formation is owned by the Federal Government.

     Shale oil can be produced from oil shale by three general retorting
processes: surface or aboveground, modified in-situ, and true in-situ.  In
each case, the oil shale must be heated to 400 C or higher to bring about
pyrolysis of the depth, assay, and geographic location of the shale formation
or deposit, and the technological, economic, and environmental factors (Draft
DOE, Oil Shale Environmental Development Plan, June 1979).

     The following are brief descriptions of the three types of oil shale
retorting techniques:

1.   Surface Retorting

     Surface processes involve the mining and crushing of oil shale, which is
then heated in a retort vessel built above ground.  The heating can be either
indirect, through the use of heated recirculating solids or gases in the vessel,
or direct, by creating a combustion zone in the shale itself.  The products and
residuals from these two heating methods differ in their chemical and physical
properties.
*Current U.S. consumption of petroleum products is about 6 billion barrels annually.

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              Figure 1. SHALE OIL DEPOSITS IN WESTERN UNITED STATES
                              GREEN RIVER
                              BASIN
                               Gram
                               Rhmr
                                                              WYCWfNG
                (Boaievplf, ,
                        '
                  Fort Ouchesne
           UINTA BASIN
                                     VWH.WS—CREEK BASIN
                                                       COLORADO
                                                   Montrose
KEY:
Federally-owned leases in the Green River Formation
-C-a, C-b, U-a, U-b, W-a, W-b
PHOTO CREDIT:
Shale County, Mountain Empiro Publishing, Inc.
                                     4a

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     The surface retorting processes are the most technologically advanced.

The three main surface retorting projects are:


     •   The Paraho Project, initially developed by the U.S. Bureau of Mines
         and then leased by the U.S. Department of the Interior/Navy to
         Development Engineering, Inc.  Two newly designed Paraho oil shale
         retorts were placed in operation in 1974.  The retorts can be
         operated in either the direct or indirect heating modes.

     •   The Oil Shale Corporation Project (TOSCO II), developed by TOSCO
         and Colony Development Corporation on privately owned land.  This
         project is the only U.S. surface retorting method which uses
         solid-to-solid heat transfer between hot ceramic pellets and
         crushed oil shale, in a horizontal rotating retort, for shale oil
         production.

     •   The Union B. Project, developed by Union Oil Company of California.
         The development of Union's oil shale retorting technology on privately
         owned lands was initiated in the early 1940s, and several variations
         of a vertical kiln retorting process, with upward flow of shale and
         counter current downward flow of gases and liquids, have been
         developed.  Two variations are known as the Retort A and the
         Retort B, with the latter being an improved version of the process.


2.   True In-Situ Retorting

     In-situ processes involve fracturing the shale in place underground and
igniting it via a central injection well.  The volatile gas and oil derived

from the heated shale migrate through fractures in the rock formations to wells

where they can be drawn to the surface.

     True in-situ processes are still in the development stage.  Many technical

and environmental problems such as shale fracturing techniques and control of

retort burning still need to be resolved.  In-situ processes have been demon-
strated by the DOE's Laramie Energy Research Center at nine sites between

Rock Springs and Green River, Wyoming; by the Geokinetics Project
in the Uinta Basin, the Dow Chemical Company Project in Michigan,
and the Equity Oil Company Project in the Piceance Creek Basin.   All

these privately developed projects have been partially funded by DOE.


3.   Modified In-Situ  (MIS) Retorting


     The MIS process combines aspects of both surface and true in-situ retorting.
Part of the shale  (15-30 percent) is mined and brought to the surface, where it

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is processed with conventional surface retorting technologies.  The remaining
oil shale, directly above the mined zone, is fractured using explosives, and
then heated by igniting it in place.

     Three modified in-situ processes are of current interest to DOE: vertical
modified in-situ processing, horizontal modified in-situ processing preceded
by mining or removing some of the shale, and modified in-situ processing pre-
ceded by solution mining of soluble salts.

     The Occidential Oil Shale Project is a "vertical modified in-situ" project.
It is considered the most advanced of the various MIS processes; however; the
technology is still being developed and is not ready for commercialization.  One
major technical problem is to develop a fracturing technique which will provide
a higher percentage conversion of shale pieces of uniform size.

     The Dow Chemical Project in Michigan employs both true and modified in-situ
approaches.  Some of the Dow Project is modified in-situ because it involves
undermining and chemical leaching of the oil shale.   The Dow processes are
significantly different from processes employed in western shale development.

     A more detailed description of the oil shale technologies is given in
Appendix A.

   With the development of the Oil Shale RD&D Management Plan and its goal
of demonstrating the commercial feasibility of the oil shale technology by
1985, two efforts are under way by DOE in supporting first-generation oil
shale commercial operations.  The first effort is a DOE Program Opportunity
Notice (PON) for a commercial scale surface retort facility. A PON is a DOE
solicitation for proposals for jointly sponsored technology development
projects.  The surface retort PON will be announced later this year.  The second
effort is directed toward the commercialization of a vertical modified in-situ
(MIS) retort design.  The research and development activities required to
overcome the technological and environmental problems associated with the
vertical MIS design have been grouped together to form a project entitled
'Moon Shot'.

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   The objectives of the Moon Shot project is to produce a design of a com-
mercial state-of-the-art vertical MIS retort and mining system within
2h years.  The system design will be tailored to the requirements of Federal
lease tracts C-a and C-b in the Piceance Creek Basin in Colorado.   The
combined shale oil output of these two tracts in the mid-1980s is expected
to be 100,000 to 125,000 barrels per day.

   DOE believes that the combined results of the Program Opportunity Notice
and the Moon Shot Project will make shale oil production commercially
feasible.

B.   ENVIRONMENTAL CONCERNS

   The September 1978 DOE Environmental Readiness Document stated:  "There
is a high probability that commercial-scale aboveground retorting will be
found environmentally acceptable.  The primary unresolved problems that
this technology faces are; stringent air quality regulations,  management
of solid wastes, and lack of data regarding the environmental, health, and
safety impacts of the total fuel cycle.

   Significant environmental concerns have been identified with respect to
the in-situ technologies which may delay their development. However, further
data are required to judge the environmental acceptability of  in-situ
processes.   The concerns include:  acquifer disruption and/or contamination,
occupational health of the working force in the underground environment
(modified in-situ), and lack of data regarding the environmental, health,
and safety impacts.

   There appears to be differences of opinion among government, industry, and
public interest groups as to the most serious environmental concerns asso-
ciated with oil shale development.  A recent analysis done by  DOE in conjunction
with development of the Oil Shale RD&D Management Plan listed  the following
concerns for Modifled-in-situ processes in order of decreasing seriousness:

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     1)  Worker Safety and Health—mining operations and underground retorting
         create a new and unique work environment with unknown health and
         safety risks.
     2)  Retort Abandonment—toxic substances remaining in oil shale after
         retorting may contaminate aquifers in an area in the United States
         where water is a precious resource.
     3)  Treatment of process wastewater leftover after surface retorting
         of the mined shale.
     4)  Disposal of mined shale brought to the surface.  If piles of
         retorted shale are not adequately stabilized (by vegetation or
         cemeting), rain can cause leaching of toxic material into
         groundwater supplies.
     5)  Air emissions exhausted from underground retorting.
     6)  Land disruption resulting from surface operations, subsidence in
         mined-out areas, and the need for space to hold piles of raw shale
         and spent shale.

     A ranking of oil shale environmental problems by 17 companies interested
in oil shale list groundwater contamination and leaching of spent shale as the
two most important: issues.

    A number of basic questions about limited degradation in Class 1 air quality
areas, the adequacy of water supplies and the potential for harming aquifiers
or causing deterioration in regional water quality have not been answered.
For instance, under certain assumptions the background level of various air
pollutants exceed Federal and state clean air standards.  A current issue
is the impact on air quality and visibility in the Flat Tops Wilderness area
resulting from the siting of the Colony Oil 50,000 bbl per day Plant in
Northwestern Colorado.  The plant is not yet scheduled for development and
thus changes in project design, changes in control technology, and future
protective designations of Federal lands could change Colony's impacts
significantly.

    Another set of issues complicating plans for shale oil development is
whether sufficien-t water supplies exist to support the industry and its
associated development.  Mich of the water resources are legally committed to
agriculture and livestock watering and river water is further controlled by
an intricate system of water rights.  The areas of uncertainty include:  What
constitutes a source of water supply?  What is the geographical distribution
and the timing of its availability?  How much water will the industry and
associated developments use on a sustained basis?
                                      8

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     Although there has been some initial research there remains considerable
uncertainty about the success and costs to reclaim waste disposal sites.  Re-
vegatation of spent oil shale will probably have to be approached on an area
specific basis because of differences in the plant communities where the
shale is mined and differences in the nature of the processed shale.

     Estimates of the amount of water needed for dust control and revega-
tation will depend upon the particular local conditions.  However, even
the most favorable estimates suggest that the total amount of water
will be relatively large compared to reclaiming strip-mined coal lands
in arid regions.

     An important RD & D concern is the need for a continuing comprehen-
sive environmental study of oil shale development.  The September 1978
ERD for Oil Shale Commercialization acknowledges that "the development of
an environmental data base upon which to structure an assessment of the
probable environmental consequences of commercialization is a key require-
ment" for further commercialization efforts.

     Scientists and regional planners have, over the past 10 years,
repeatedly urged a Green River Formation (which includes the Green River,
Uinta, Washakie and Piceance Basins) Study to assess the impacts of
full-scale development.  It is not clear how oil shale development
activities on private lands in the southern part of the Formation will
affect the northern federally owned lands.

     An economic issue that appears repeatedly is the need for a demonstration
plant of a size that is sufficiently large to provide data that can be used
to assess the impact of a commercial-size oil shale plant.  Many scientists
feel the need to observe a commercial-scale plant in operation to collect
credible data on the impacts that have stirred public concern.

     Table 2, adapted from several DOE environmental planning and assess-
ment  documents and an independent analysis by MITRE Corporation, discusses
environmental concerns for all processes by general area (e.g., air
quality, water quality), and describes possible mitigation methods to
deal with th*e concerns.  The DOE Office of Environment has indicated that
it will probably be technologically possible to mitigate nearly all
environmental impacts likely to arise in the production of shale oil.

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Table 2.  Environmental Concerns and Possible Mitigation Methods
Environmental Concent
AH! QUALITY
• Dust and nnrc Lcitlntes from
mining, transportation,
rubbllzation, crushing,
anil disposal.
• Retort Offgases.

HATER
• Water supply Is limited In the
Colorado River Basin. With-
drawal of too much water will
Increase salinity, violating
some water usage agreements
and also treaties with Mexico.
• Leaching of toxic chemicals
from spent shale piles.
* contamination of aquifers
passing through a spent
retort.
LAiJD DISRUPTION
• Disposal of spent shale.

• Disruption of habitats for
plants and animals.
HUMAN HEALTH EFFECTS
« Exposure to contaminants
and toxic chemicals

OCCUPATION HEALTH AND SAFETY
(Most occupational concerns are
related to underground mining)
• Dust and retort gases.

• Blasting.
• Diesel fumes.

SOCIOECONOMIC
• Social and economic dlsrup-
tion in sparuely populated
oil shale basins
("Boom Town" phenomenon).
Mitigation Methods

• For undergoing mining:
- Dust maako for air rauska for miners.
- Forced air ventilation with wet vcnturl scrubbers,
. .. fabric filters, or cyclones.
• For disposal of mined ghale:
- Fabric filters or wet venturi scrubbers for emissions froa
all conveyors.
- Wetting down roads and truck loads.
- Rcvegctation of oil shale disposal areas.
• Dcsulfurlzatlon of gases by Stretford Process.
• Dcnltrif Icatlon, by scrubbing and subsequent recovery of NH-j.
• Combustion of desulfurlzed and denitrified gases for electric
power production or for steam production.
• Flaring — to be used only in emergencies or failure of other
controls.
• Treat and return all water left over after retorting to
groundvater or surface runoffs.
• Cementing or vegetation of shale disposal areas.
• Covering disposal areas (e.g., gullies) with impervious
linings before filling with spent shale.
• Cementation of all retort surfaces.
• If aquifer is above retort (usual expectation) , cement
passages in aquifer zone only.

• Transport rubbllzed shale to selected landfill locations.
then compact, and revegetate.
• Minimize extent.
• Reclaim and revegetate where possible.

< Depends on characterization research and adequacy of
controls for dust, water pollution, etc.


• Dust masks or air masks for miners.
• Forced air ventilation with wet venturi scrubbers, fabric
filters, or cyclones.
• Strict adherence to Mining Enforcement and Safety
Administration regulations and procedures.
• Vehicle-mounted scrubbers and filters.
• Frequent mine air changes.

• Community planning by local governments.
• Economic -asslsance from state and Federal authorities.
                            10

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However, the cost of some controls (particularly those dealing with water
pollution problems) could be large enough to seriously affect the economic
competitiveness of oil shale.

     In Fiscal Year 1979, theOffice of Environment is spending over $4 million
on oil shale environmental research.   Much of this research deals with charac-
terization and monitoring of effluents and emissions, and the effects of oil
shale byproducts on human health.   Only after potential problems have been
better defined can more advanced control technology research be accomplished.
                                    11

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          III.  DOE ENVIRONMENTAL PLANNING AND REVIEW PROCESS
                    AND THE OIL SHALE TECHNOLOGY

     It is difficult to evaluate DOE's environmental planning and review
process — described in the background document "Section 11, Environmental
Evaluation" — until one of the oil shale technologies have been designated
a major systems acquisition or a significant energy system acquisition project.
None of the technologies have yet been so designated.  Evaluation is further
complicated by the development of the Oil Shale RD & D Management Plan wherein
DOE is apparently going from exploratory development to commercialization
without completing a phase in the energy system acquisition process.
     The following four criteria are used as a basis for evaluating DOE's
environmental planning and review process:

     • The extent to which DOE has followed the process;
     • The extent to which DOE has carried out the planned environmental
       research;
     • The extent to which the results of DOE's environmental research has
       affected oil shale technology development decisions; and
     • The opportunities for the concerned public, local, state and
       Federal agencies and industry to participate in the process.

A.   THE EXTENT TO WHICH DOE HAS FOLLOWED THE PROCESS

1.   Environmental Planning and Assessment Documentation
      The first Environmental Development Plan (EDP)  for oil shale was pub-
lished in June 1977.   It contained:  (1)   a description of the technology;
(2)  environmental concerns; (3) associated research needs (mostly dealing
with characterization and monitoring) which were given low,  medium, or high
priority; (4) timetables for research and NEPA document preparation at each
project site; (5)  lists of ongoing research projects keyed to DOE's Research
Project Information System or the Federal Inventory of Research;  and (6)'
organizations responsible for each research requirement.  This EDP was
quite comprehensive,  however its implementation may be questionable since
nearly half of the 91 research tasks were assigned the highest priority.
                                     12

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     In September 1978, an Environmental Readiness Document (ERD), was prepared
as part of a Commercialization Task Force effort to identify which energy
technologies had avanced far enough towards commercialization to warrant
additional emphasis.  It provided an assessment of the existing knowledge of
each environmental concern listed in the 1977 EDP, estimated the likelihood
that research results would apply environmental constraints to commercialization,
and estimated the costs and delays involved in controlling or mitigating each
adverse impact if it should occur.  The probabilities given showed "a medium
likelihood for surface retorting and a high likelihood for in-situ retorting
that there would be environmental constraints to commercialization."  Although
a resource manager was appointed to manage commercialization efforts, it is
unclear what effects the oil shale ERD had on that decision.
      At this time, no oil shale projects have been designated "major systems"
within the PPMS process.  Therefore, the Environmental Systems Acquistion
Advisory Board will not meet on any oil shale projects prior to their passing
to another technology development phase.  Additionally, no oil shale pro-
jects have been designated as  requiring Energy System Acquisition Project
Plans (ESAAP), although an ESAPP is being prepared to accompany the Program
Opportunity Notice for the commercial surface retorting project.  No oil
shale Project Environmental Plans have been prepared,  although one will be
required as an annex to the ESAPP for. the commercial surface retorting project.
See Table 1.

      DOE has major involvement in several oil shale projects through coopera-
tive funding agreements with private companies, and technology grants to both
national laboratories and private companies.  For these projects, decisions
(including decisions relating to environmental concerns) are generally made
within the responsible program office with advice from Office of Environment
staff — there is no formal process calling for the Assistant Secretary for
Environment's personal involvement.
     Until this spring, it appeared that DOE's oil shale research program had
been characterized by a lack of coordination among the cognizant offices.  The
Offices of Environment, Energy Technology, and Resource Applications, as well
as the field personnel at Laramie Energy Research Center (LERC), were sometimes
                                     13

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preparing their own management plans for sponsoring and conducting both
technological and environmental research.  This lack of coordination was
highlighted in an April 1978 report by the General Accounting Office on
"Opportunities to Fully Integrate Development Into Developing Energy Technologies".
An internal DOE study completed in December 1978 by the Office of Policy
and Evaluation led to a series of recommendations  approved by the Under
Secretary dealing partly with defining responsibilities and roles of the various
DOE offices concerned with oil shale.

 2.    The Oil Shale RD&D Management Plan

      The spring of 1979 has seen a major change in the relationship of the
Offices of Environment and Energy. Technology.  These two Offices have
worked together to develop a comprehensive management plan — The Oil Shale
RD&D Management Plan — for oil shale development.  The plan outlines a
schedule for required research in four major activities:

      • Resource Characterization and Planning

      • Environment

      • Development and Extraction, and

      • Retorting and Product Preparation.

      The plan provides specific environmental research tasks in significant
detail, including the responsible organization.

      Because the Plan has just been developed and has not yet been approved
by Congress, ( it is to be formally submitted in late June 1979), it will be
some time before its effectiveness can be judged.  However, both the Office
of Environment and Office of Energy Technology staffs, including the cognizant
Assistant Secretaries, have expressed optimism that this Management Plan
will be able to get the oil shale program "on track", and that the Plan will
be copied in other technology areas.
*Although oil shale was the principal subject of the recommendations, many
of the problems identified were not limited to oil shale, but were wider
problems affecting all emerging technologies.  Various recommendations dealt
with:  defining the roles of various offices, prioritizing research needs,
and maintaining central lists of envrionmental concerns and ongoing research
projects.
                                     14

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     A second Oil Shale EDP is now in preparation.  The June 1979 draft of

this EDP has been quoted several times in this paper.  This new EDP will
incorporate the environmental research program from the overall Management

Plan.


     Coordination of DOE oil shale environmental research takes place through

three committees:


     •  The Environmental Coordination Committee (ECC).  The ECC Oil Shale
        Subcommittee has membership from a number of DOE Program Offices.
        It is chaired by a representative from the Office of Environment.
        Its primary role is the preparation of Environmental Planning and
        Assessment Process Documents.

     •  The Environmental R&D Working Group.  This group consists of Office
        of Environment representatives only.  It is chaired by a representa-
        tive from the Office of Health and Environmental Research.  Its
        principal responsibility is for developing detailed research plans
        for all Office of Environment-sponsored research in oil shale.

     •  The Implementation Working Group or Management Coordinating Committee.*
        This group includes the members of the R&D Working Group (and is
        chaired by the same person) as well as representatives from the Offices
        of Energy Technology, Resource Applications, and Planning and Evalua-
        tion.  Its function is to facilitate communication between the various
        offices to implement the environmental research identified in the EDP.
        Much of the most effective research coordination takes place through
        this committee rather than the ECC Oil Shale Subcommittee.


     Under the Oil Shale RD&D Management Plan, a fourth coordinating group
will be set up:


     •  This group will consist of the four DOE Managers who will direct
        activities in each of the major research areas—Resource charac-
        terization and planning, environment, development and extraction,
        and retorting and product preparation.  The activities are further
        divided into subactivities, each with its own manager.  The
        environmental subactivities are: air, land, and solid waste; water,
        health, and safety; and socio-economic, ecological, and compliance.
        DOE hopes that regular meetings of the subactivity managers and
        activity managers will be a major coordinating and feedback mechanism
        for technology program and environment staff at the working levels.
*The group is referred to by both titles.
                                    15

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     The development of the new Oil Shale RD&D Management Plan will now
control the oil shale technology and environmental research program.  There
is a question as to how this may impact the existing planning and review
process for technology RD&D (the PPMS process).

 3.   National  Environmental Policy  Act Documentation

     Several Environment Assessments were issued by ERDA for specific oil
shale projects, but the only Environmental Impact Statement (EIS) issued by
ERDA was on the Alternate Fuels Demonstration Program.  This EIS discussed a
variety of fuels and was not specifically focused on oil shale.  DOE now has
three EISs under preparation:  a Programmatic Oil Shale EIS, an EIS for the
Paraho Project, and an EIS to support the $3/barrel tax credit.

     Three EISs have been issued by the Department of the Interior: one in 1972
for an Oil Shale Retort Research Program, one in 1973 for its Prototype Oil
Shale Leasing Program, and one in 1977 for the Colony Development Corporation
TOSCO Project (see Table 1).

B.   THE EXTENT TO WHICH DOE HAS CARRIED OUT THE
     PLANNED ENVIRONMENTAL RESEARCH

     Environmental research projects are generally based on an assessment of
environmental concerns, identification of research needed to resolve these
concerns, and a set of budget decisions required to fund the necessary research.
It appears that all major concerns raised in the original EDP and ERD are, at
present, being addressed by environmental research programs.

     Under the new Oil Shale RD&D Management Plan, however, the direction and
extent of the ongoing oil shale environmental research program will change.
The new program calls for a larger commitment of resources for technology
research, in contrast to the recent decreases in DOE funding for oil shale.*
If this increased funding is not approved, some of the research listed in
the Management Plan could be postponed or cancelled.
*Environmental research funding in the Office of Environment has remained
 at a fairly constant level.
                                    16

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C.   THE EXTENT TO WHICH THE RESULTS OF DOE'S ENVIRONMENTAL RESEARCH
     HAS AFFECTED OIL SHALE TECHNOLOGY DEVELOPMENT DECISIONS

     Because the formal Environmental Plannine and Assessment Process has
onlv been in olace since 1978  there has been little oooortunitv for the
svstem to reoort research results which could affect oil shale technoloav
decisions.  The funding for oil shale technoloev research has decreased in
recent years, but DOE representatives say that it is more likely due to the
lack of planning coordination than because of adverse environmental impacts.
Oil shale (especially the in situ processes) was identified in the 1978 ERD
as having severe environmental constraints to commercialization.  However,
this would not have impacted budgeting decisions before the FY 1980 budget.
     If environmental research were to identify problems which could not be
mitigated by control technology, or controlled only at great expense (e.g.,
aquifer contamination) this would likely have an adverse impact on commer-
cialization efforts.  Following the September 1978 Commercialization Task
Force Report (which was accompanied by the ERD), a resource manager was appointed
for oil shale.   A decision was made to push ahead with commercialization efforts
despite the environmental concerns noted in the ERD.

D.   THE OPPORTUNITIES FOR THE CONCERNED PUBLIC, LOCAL, STATE, AND
     FEDERAL AGENCIES, AND INDUSTRY TO PARTICIPATE IN THE PROCESS

     Two major objectives of an environmental review and assessment process
should be to collect data on issues of concern to interested parties early in
the planning process, and to disseminate widely both technology and environmental
research findings.  Accomplishing these objectives tends to allay concerns
about motives and research priorities, to help eliminate research gaps and
redundancies, and to help provide for the entry of and access to new information
by the interested parties.
     Accomplishing these objectives is particularly important for future oil
shale technology development because previous oil shale development activity
has a history of disagreements and conflicts.  Opposition to oil shale develop-
ment by conservationists has centered on the environmental effects of surface
and modified in situ technologies.  State and local governments in Colorado
                                    17

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and Utah have a critical interest in oil shale development because the
industry would have statewide effects in terms of investment,  jobs,  environ-
mental effects, and water consumption. Utah has been generally supportive
of oil shale development, and Colorado has encouraged the development by easing
sulfer dioxide emission standards and by reclassifying air quality regions in
the oil shale development areas to allow less stringent pollution control.

1.   Environmental Conflicts

     Significant environmental opposition to oil shale development occurred
at the time the Department of Interior started planning for the Prototype
Oil Shale Leasing Program in 1969.  When a proposed leasing program was
submitted to Interior Secretary Hickel in 1970, he postponed announcement
pending further environmental study.  Regional involvement began in early
1970 with the formation of a Colorado Governor's Committee on Oil Shale.
This committee consisted of federal, state and industry members.  The committee,
which did not have representatives from environmental groups,  issued a
report to the Colorado Governor on development related problems.  Following
objections by several environmental groups, a new committee was formed
and they subsequently issued a report that was to be the basis for the
Draft  Environmental Impact Statement for the Prototype Program.

     Another early planning activity in Colorado was the formation of
a three-county Oil Shale Regional Planning Commission that was organized
with representatives from Garfield, Rio Blanco and Mesa Counties.  This
Commission had as its goal the orderly and planned development of the
region.  Subsequently, a Council of Governments, consisting of elected
officials from Garfield, Rio Blanco, Mesa and Moffat Counties was formed
and took over the activities of the Oil Shale Regional Planning Commission.

     Another controversy involving the DOI Leasing Programs arose in
1976 when the three lessee groups (two in Colorado, one in Utah)
requested 1-year suspensions of operations because of legal, technical,
and economic problems which had developed in connection with immediate
development as then planned.
                                  18

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      The suspensions were granted effective September 1, 1976, for the
 two Colorado leases and November 1 for the two in Utah.  The
 suspension period ended September 1, 1977, for the two Colorado tracts
 but because of litigation over title to the oil shale lands and
 resources in Utah, the suspension remains in effect for the two Utah tracts,

      In addition to the litigation, two lawsuits have been instituted
 against the Prototype Program by environmental groups.  The first, filed
 in December, 1976, challenged the legality of the suspensions.  It
 was dismissed for failure to include the lessees as indispensable
 parties.  The second suit, filed in December. 1977 by  the Environmental
 Defense Fund, the Colorado Open Space Council,  and Friends of  the
 Earth,  challenged the approval of the Development Plans for the two
 Colorado projects, arguing that additional Environmental Impact State-
 ments should be required.  The Federal District Court rejected that
 argument and affirmed the Department1s actions  under the Prototype
 Program on August 25, 1978.   An appeal on that  decision is now pending.

 2.    Opportunities for  Public  Involvement

    DOI feels they have shown good faith by allowing public participation
in program planning.  The Oil Shale Environmental Advisory Panel was
established in 1974.  Key provisions of the Panel charter were  to:

    •  Assist the Department in attaining the objectives of the Proto-
       type Program.
    •  Ensure maximum public participation
    •  Advise the Area Oil Shale Supervisor of the Geological Survey
       and District Managers of the Bureau of Land Management of environ-
       mental matters in connection with their responsibilities under the
       Prototype Oil Shale Leasing Program.
    •. Advise the Department of Energy on environmental aspects of its oil
       shale programs upon special request to the Department of the Interior
       Assistant Secretary - Land and Water Resources by DOE.
                                    19

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     During the 1974-1977 period, the Panel held 24 public meetings,  had
15 temporary work groups and prepared a number of papers and annual reports.
The Panel's charter expired in late 1977, and was reactivated in late 1978.
The new charter authorized a 26-member Panel comprised of members from
Federal, state, and county governments as well as four public members named
by the DOI (two representing the industry/energy sector and two from the
environmental/public interest sector).

     DOI also feels they have complied with both the spirit and letter of
the National Environmental Policy Act.  However, environmentalists and public
interest groups feel that they have been excluded from access to decision
makers and that there is no accountability in the system.  The major factors
contributing to the controversies and disputes surrounding this Prototype
Program were lack of trust of the goals and motives of the various parties,
a lack of agreement about what access to decision making meant, and the fact
that major program decisions and the associated EIS preparation were conducted
in Washington with very little local involvement (Resolving Environmental
Issues, Rand Corporation, 1979).
                                     20

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                            REFERENCES
Environmental Development Plan:  Oil Shale,  FY1977.   Energy Research
     & Development Administration,  EDP/F-01  (77).
Environmental Readiness Document:   Oil Shale.   Commercialization Phase  II
     Planning.  Department of Energy DOE/ERI-0016.   September 1968.
EPA Program Status Report:  Oil Shale 1979 Update.   Interagency Energy—
     Environment Research and Development Program Report.   Environmental
     Protection Agency.  EPA-600/7-79-089.  March 1979.
Draft Environmental Development Plan:   Oil Shale.   Department of  Energy.
     June 1979.
Prototype Oil Shale Program and Environmental Advisory Panel Summary.
     Department of Interior, March 1979.
Resolving Environmental Issues in Energy Development.   Roles  for  the
     Department of Energy and its Field Offices.   Rand  Corporation.
     January 1979.
Technological Overview Reports for Eight  Shale  Oil  Recovery Processes.
     Interagency Energy/Environment R & D Program Report.  EPA-600/7-79-075,
     March 1979.
                                  21

                                                                             V

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           APPENDIX A
OIL SHALE TECHNOLOGY DESCRIPTION

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                                 APPENDIX A
                      OIL SHALE TECHNOLOGY DESCRIPTION

TECHNOLOGY BACKGROUND

     Oil shale is the common term used for a sedimentary rock containing a
waxy organic material known as "kerogen,"which has been compacted within
deposits of clay, mud, and silt.  When the shale is heated to temperatures
of 800° F to 1000° F, the kerogen undergoes a chemical change (pyrolysis)
whereby about 65% of the kerogen is converted to hydrocarbon liquids,  about
10% to a low Btu gaseous product, and about 25% to a carbonaceous residue.
After pre-refining, the liquid product can be turned into a high-quality
synthetic crude oil that substitutes for conventional crude oil.

     Retorting is the heating of oil shale to obtain the energy-rich oil
and gas products.  Currently, there are three retorting processes.  In the
first, "surface retorting," oil shale is mined, crushed, and then heated
in a retort vessel above ground.  In the second process, "in situ retorting,"
the rock is heated in place in the ground and then the volatile products of
kerogen conversion are forced through fractures in the rock formations
condensed and brought to the surface.  The third process, "modifed in
situ" (MIS) retorting, combines the above two processes, whereby part of
the shale is mined and brought to the  surface (where it may be retorted),
while the balance is reduced to rubble and retorted in the ground.

     Oil shale generally occurs in geologic basins, sandwiched between
layers of other kinds of sedimentary rock.  Low grade deposits underlie large
parts of the eastern and central United States and northern Alaska, but
about 90% of the identified oil shale resources of the U.S. are located in
a single geological formation in western Colorado, Utah, and Wyoming known
as the Green River Formation.  About 80% of this 16,500 square mile basin
is owned by the Federal government, and it is the richest source of oil
shale presently known in the world.

     The U.S. Department of the Interior estimates that 80 billion barrels
of oil can be recovered from the Green River Formation using existing
technology.  However, this is only one tenth of the 800 billion barrels of
shale oil that might eventually be recovered by more advanced technology
                                     A-l

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and with more favorable economics than presently exist.   Total shale oil
resources of this formation are about 1.8 trillion barrels.   Considering
that the U.S. consumption of petroleum products is about  6 billion barrels
annually, one can perceive the enormous magnitude of  shale oil resources
potentially available.

     There are a large number of oil shale retorting  processes which have
been conceived, and several have been successfully developed through the
pilot plant or demonstration plant stage.  In descending  order of  demon-
strated competence, the list would appear approximately as shown in Table A-l.
For the first three processes (Paraho, TOSCO II, and  Union B, which are all
surface retorting processes), the extended demonstration  technology has been
completed and specific engineering design is available or is being developed.
Of the four in-situ processes, the Occidental Modified In-Situ (MIS) process
is considerably more advanced.  The next two processes — Geokinetics and
Equity — are worthy of consideration as they  have successfully completed
the pilot plant stage of development and still appear viable.  The remaining
processes in Table A-l are in too early a stage of development for serious
consideration.

     At present, the major DOE involvement is a cooperative funding program
with Occidential Petroleum, Geokinetics, and Equity Oil for MIS research.
Proposals have been requested for a cooperative program in surface retorting
processes, but no awards have been made.
                                     A-2

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                                   TABLE A-l

                        Shale Oil Processes and Status
                  (listed in descending order of development)
                  PROCESS


 1.  Paraho*

 2.  TOSCO II

 3.  Union B

 4.  Occidential Modified*
     In-Situ

 5.  Geokinetics Horizontal*
     In-Situ

 6.  Equity Steam In-Situ*

 7.  Rio Blanco Side Entry
     In -Situ

 8.  Superior Rotating Grate

 9.  Lurgi

10.  Radio Frequency Processes

11.  Multi-Mineral

12.  Batch Process
Ready for pre commercial plant status

Ready for precommercial plant status

Ready for precommercial plant status


In field test demonstration


In field test demonstration

Field test demonstration starting soon


No demonstration planned for near future

Pilot plant tests completed

Pilot plant tests completed

Bench scale or theoretical

Bench scale or theoretical

Bench scale or theoretical
 * Indicates major DOE involvement.
                                       A-3

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SPECIFIC RETORTING PROCESSES

     1.  Paraho Oil Shale Process

         History of Technology Development

     The Paraho Oil Shale Process, probably the most technologically advanced
of all oil shale retorting processes, is an outgrowth of:  (a)  the gas com-
bustion process initially devloped by the U.S. Bureau of Mines  (USBM) at Anvil
Points, Colorado, in the 1940"s and 1950*s; and (b)  research extending over
many years by Developing Engineering, Inc.  (DEI)  on the calcination of lime-
stone, and on the pyrolysis of oil shales.

     "During World War II, a high demand for liquid  fuels prompted Congress to
pass the Synthetic Liquid Fuels Act of April 5, 1944.  This act gave the
Secretary of the Interior 5 years to construct a demonstration  plant to produce
synthetic liquid fuels from oil shale.  The plant would give cost and engineering
data to the Government for developing a synthetic liquid fuel industry.  With two
extensions and additional appropriations from Congress, the Department of the
Interior (DOI) constructed an aboveground retorting  facility at Anvil Points,
Colorado, where research was conducted until expiration of the  act in 1955.

     Following expiration, a jurisdictional void existed for several years. In
1962, the problem was resolved with the creation of  Naval Oil Shale Reserves
1, 2, and 3.  Congress delegated administration of the reserves, excluding
the experimental facilities, to the Secretary of the Navy, and  the Secretary of
the Interior was empowered to take possession and encourage the use of the
Anvil Points Oil Shale Facility reserves.  From 1964 to 1968, DOI leased the
Anvil Points facility on Naval Oil Shale Reserve 3 to the Colorado School of
Mines Research Foundation, Inc., for research on oil shale retorting.

     On April 24, 1972, the lease was reactivated with a new lessee, Develop-
ment Engineering, Inc.  (DEI) for 5 years (until July 1977).  The Paraho
Development Corporation was formed with DEI as a subsidiary, and the Paraho
Oil Shale Project was launched in late 1973 with funds provided by ^partici-
pating companies, including many with long experience in oil shale research.
DEI continued as the operating company, and Arthur G. McKee and Co. was selected
as engineering contractors.
                                     A-4

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DEI constructed a semiworks plant on the same pad holding the pilot retort
built under the Synthetic Liquid Fuels Act.   The lease allowed DEI to  mine
400,000 tons of oil shale.  In 1975, DEI's lease was extended from July
1977 to July 1982.  Also in 1975, the Secretary of the Navy,  with the  approval
of the Committees on Armed Services of Congress, authorized DEI to mine
11 million tons of oil shale from the Anvil Points facility for operating a pro-
posed full-size module.

     DOE has been delegated the responsibility for the oil shale facility.   An
Environmental Impact Statement is under preparation for the commercial module
at Anvil Points to evaluate the environmental consequences of DOE approval  for
mining 11 million tons of shale and operating the proposed full-sized  module."*

PROCESS TECHNOLOGY

     A schematic representation of the Paraho direct-mode retort** is  pictured
in figure A-2, which illustrates the physical and chemical changes which occur
in the various retorting zones.

     The Paraho retort vessel is a vertical cylinder of steel lined with refrac-
tory brick.  During direct-mode operation, shale is fed to the top through  the
rotating "pants-leg" distributor.  The shale passes down along with retort
axis and encounters a rising stream of hot combustion gases.   Kerogen  decom-
poses to oil, gas, and residual carbon.  Oil and gas are drawn from the retort
through collecting tubes near the top of the retort.  As retorted shale approaches
the burner bars, oxygen in the gas-air mixture ignites residual carbon to yield
*Draft Oil.Shale Environmental Development Plan Department of Energy. June 1979.

**The two types of Paraho retort operation are "direct-mode" and "indirect mode."
  In the former operation, a portion of the retort off gas is combusted with
  the residual carbonaceous content of the spent shale in the combustion zone
  of the retort to furnish the heat required for retorting.  In the "indirect
  mode" operation, there is no combustion zone in the retort.  The off gas has
  a much higher heating value (800 Btu/scf as compared to 100 Btu/scf for
  direct-mode off-gas).  The indirect-mode off-gas is heated externally and
  then used to pyrolyze the shale in the retort.  The Paraho process
  developers prefer direct-mode operation for various engineering reasons.
                                      A-5

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the heat required for additional kerogen pyrolysis.  Heat is recovered from
spent shale by the recycle-gas stream which is injected into the bottom of
the retort.  Cool shale exits the retort through a discharge grate.  Tem-
perature in the retort is controlled by adjusting the compostion of the gas
streams fed to each set of burner bars and by adjusting the composition of
the recycle gas stream.

      2.  Union Oil Shale Process

          History of Technology Development

      The Union Oil Company of California (Union Oil) has been involved in
oil shale activities for more than fifty years.  All of their research has
been conducted on privately owned lands with the majority of funds coming
from the company itself.  Several variations of a vertical kiln retorting
process, with upward flow of shale and counter current downward flow of
gases and liquids, have been developed by Union.  Two variations are known
as Retort A and the Retort B.  The first concept, the Retort A process, has
been carried through 2 tons per day and 50 tons per day pilot plants.  This
was followed by the construction and operation of a large demonstration plant
in the late 1950's.  An imporved version of the Union Oil process, the Retort
B process, was developed in subsequent work in response to the increasing
energy demands and shortage of fuel supplies, and has been carried through
pilot plant stage.  It is the Retort B process that Union Oil now proposes to
construct and demonstrate at the 10,000 tons per day rate along with all
necessary auxilliary facilities.

      PROCESS TECHNOLOGY
      A simplified schematic of the Retort B process is shown in Figure A-3.
Crushed oil shale flows through two feed chutes to a solids pump in the
bottom of the retort.  As shale is moved upward through the retort by the
upstroke of a piston, it is met by a downward flowing stream of 950° to 1000°F
recycle gas from the recycle gas heater.  The rising oil shale bed is heated
to retorting temperature by countercurrent contact with the hot recycle gas,
resulting in the production of shale oil vapor and fuel gas.  This mixture
of shale oil vapor and fuel gas is forced downward by the recycle gas, and
cooled by contact with the cold incoming shale in the lower section of the
retort.
                                     A-6

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                                              RAW SHALE
                         RETORT GAS
 ELECTROSTATIC
 PRECIPITATGR
MOIST SHALE ZONE
                                           OIL MIST FORMATION
                                           AND SHALE PREHEATING
                                             RETORTING ZONE
                                            COMBUSTION ZONE
                                           SPENT SHALE COCUNG
                                           AND GAS PREHEATING
         RECTCLE GAS
         SLOWER
                                  CONTROL
                                  VALVES
                                                             GRATE
        AIR SLOWER
                                              SPENT SHALE
FIGURE A-2.   PARAHO DIRECT  MODE RETORT FLOW  DIAGRAM
                         A-7

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00
SHALE FEED
FROM FEED
PREPARATION d>— — i MTOR
If;
L|_
T



RETORTED SHALE //
COOLING VESSEL^J/

WATER LEVEL 	 _^ Quf

RETORHO SHALE
TO RE10HTEO
SHALE DISPOSAL
MAKEUP WATER l__^—
RECYCLED PLANT WATER I 	 } 	
OVEREO
IICII WATER

RECVCLE CAS

DISENGAGED CAS
VAPOR QUENCHING R|
AND SCRUBBING C(
-•—1
I

vji) X"^v.
QUENCH PUMP V.
\^ VENTURI
DIStHCAGEO J^ JCRUBB"
OIL f \^S
SCRUBBER Jh 1
CIRCULATION^/ \ • — C
PUMP j
OIL-WATER
y SEPARATOR
L|Q--.I 	 ^^j D 	 1 LICM1
WATEr6'^'^^
V/Uin CIRCULATION
COOLER ' C
	 — — . — — r
f^^ RECYCLE GAS
HEATER
/ -
^^ WATER STRIPPER
, 	 NOHCONOENSIBLE
i GASES
1 PLANT
1 	 C~~» fUEL GAS
:C»CLE GAS 1
x- ' \ ^ KNOCK OUT


HAKE GAS
HI^ TO TREATING
ENDS OIL
— \ WATER TO WATER
~~* STRIPPER
LIQUID PRODUCT
— \TO TREATING
                FIGURE A-3.  Flow Diagram for Retort System  in Union Oil  Retort  B  Prototype Plant

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      The fuel gas is first sent to a scrubber for cooling and particulate
removal.  That portion of the fuel gas not to be recycled is then processed
by compression and oil scrubbing to remove additional naphtha and heavy ends,
followed by a Stratford unit to remove hydrogen sulfide.  The sulfur-free
fuel gas is used as plant fuel.  The remaining gas, taken off after the
scrubber, is recycled to the retort through the recycle gas heater to provide
the heat for oil shale retorting.

      The raw shale oil from the retort is treated sequentially for solids,
arsenic, and light ends removal.  The dearsenated shale oil is sent to a
stripping prior to shipment.  This partially upgraded shale oil may now be
marketed as a low sulfur burner fuel in various locations in the United States,
and is also a suitable feedstock for refineries that have adequate hydro-
treating capacity.  At the present time, however, Union Oil does not envision
additional upgrading of the crude shale oil on-site.

      3.  TOSCO II Oil Shale Process

           History of Process Development

      TOSCO II is a process developed by The Oil Shale Corporation (TOSCO).
Initial development work (1955-1966) was conducted under TOSCO sponsorship
by the University of Denver Research Institute in a 24 ton/day pilot plant.
In 1964, a joint venture of Standard Oil Company of Ohio, Cleveland Cliffs
Iron Company and TOSCO was formed.  A 1,000 ton/day plant was constructed
on 8,500 acres of privately owned land on upper Parachute Creek near Grand
Valley, Colorado.  When Atlantic Richfield joined the venture in 1969, the
venture name was changed to Colony Development Operation.  The plant and
associated pilot room and pillar mine were operated until 1972.

      A full scale 66,000 tons/stream day commercial plant which would pro-
duce 47,000 bbl/day of low sulfur fuel oil and 4,300 bbl/day of liquefied
petroleum gas (LPG) has been designed.  Plans for commercialization have
been dormant since 1974 pending initiation of a federally-sponsored synfuels
commercialization program.
                                     A-9

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     Process Technology

     Unlike other proposed U.S. oil shale processes, the TOSCO II/Colony
commercial plant is designed not only to produce shale oil, but also to up-
grade it on-site to produce synthetic crude oil and LPG, with ammonia, sulfur,
and coke as by-products.  In addition, a treated fuel gas, a C, liquid stream,
fuel oil, and diesel oil are obtained for internal plant use.  The simplified
schematic flowsheet for the raw shale oil production portion of this process
is shown in Figure A-4.

     The raw shale is first fed to a dilute phase fluidized bed, where it is
preheated to about 500° F with flue gases from the ceramic ball heater.  The
preheated shale is fed to a horizontal rotating retort (pyrolysis drum),
together with approximately 1.5 times its weight in hot ceramic balls from a
ball-heater in order to raise the shale to pyrolysis temperature (900° F)
and convert its contained organic matter to shale oil vapor.  The mixture
of balls and denuded shale are discharged through a trommel, in order to
separate the emerging warm balls from the processed shale.  The warm balls
are purged of dust with flue gases from a stream preheater.  The dust-free
warm balls are returned to the ball heater via the ball elevator.  In the
ball-heater they are reheated to about 1300° F, using in-plant fuel, and
recirculated to the pyrolysis drum.

     4.  Modified In-Situ (MIS) Processes

         The modified in-situ process involves mining about 10 to 30 percent of
the shale to increase the void volume for in-situ retorting.  The remaining oil
shale (directly above the mined zone) is fractured and retorted in place.  Re-
torting in the modified in-situ process can be accomplished by forcing the
combustion zone to move horizontally for this shale deposits or vertically for
thick deposits.  The mined shale may be processed in a surface retort.
                                    A-10

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             UU£ 6*5
           10 AIMOSWBt
MEHEAI SYSTEM
    SUCK
                                                        eAUi.
  RAW
CRUSHED
 SHALE
                                          r—»-GAS "


                                       ^>, fOUL WAIER fO
                                             IQlil WAIER
                                                                          NAPIHHA**
                                                                          —r-

                                                                          GAS OIL 10 CAS OIL
                                                                          -+• IHDHOGENAIIOft
                                                                              UNI I
                                                                          uonous OIL TO
                                                                            DELAYED COMER
                                                                            UNI I
           PHEHCAT SYSfCU

         I INCLUDES INCINtHATOHt
                            * ALL. SCRUBBER SLUDGE STREAMS
                              10  fROCESSEO SHALE DISPOSAL

                            ** 10  GAS RECOVERY AND
                               TREATING UNIT
                                                                                                             MOISIURUEfl
                                                                                                             SCRUBBER
                                                                                                             SUCK
                                                                                                             VlNlUAl WEI
                                                                                                               SCHUUUEa
                                                                                                         MOlSlUHIifO PHOCESSEO
                                                                                                         SMAIf 10 DISPOSAL
                                                                                    COVlHtO PROCESSfD
                                                                                    SHALE  CONVEYOR
               FIGURE A-4.   Pyrolysis  and  Oil  Recovery  Unit  TOSCO  II  Process

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         The advantages of in situ over surface processing include the reduction
of shale mining and shale transport, reduction of shale disposal problems, and
substantial reduction of surface installations and manpower requirements.  Oil
recovery is lower, however, because particle size and void distribution cannot
be well controlled, and because the fracturing of shale deposits is not well
understood.

     The Occidental Petroleum Corporation is the principal domestic developer
of the MIS process, their vertical type retort is presently based at a federally
leased tract in Colorado.

     The Occidental process involves three basic steps.  The first step is
the mining of approximately 20 to 25 percent of the oil shale deposits.  This
is followed by drilling long holes from the mined-out space into the shale,
loading with an explosive, and detonating it with appropriate time delays so
that the broken shale will fill both the volume of the mined-out space and the
volume of the shale column before blasting.  Connections are made to both the
top and bottom of the prepared retort and retorting is carried out.  Figure
A-5 shows the finished retort and connections.

     Retorting is initiated by heating the top of the rubblized shale column
with a flame from compressed air and oil, propane, or natural gas.  After
several hours, the flame is turned off, and the compressed air flow is maintained,
utilizing the carbon in the retorted shale at the top to sustain combustion.
The hot gases from the combustion zone move downwards to pyrolize the shale
just below that zone, producing gases, water vapor, and shale oil mist which
collects in trenches at the bottom of the rubblized column.  Oil production
precedes the advancing combustion front by 30 to 40 ft.  The shale oil and
some byproduct water are collected in a sump and pumped to storage.  The off-gas
consists primarily of gases from shale pyrolysis, carbon dioxide and water
vapor from the decomposition of organic carbonate (primarily dolomite and
calcite), and hydrogen from the water gas reaction as well as N«.  This off-gas,
after being discharged through gas blowers is cooled and passed through a
Stretford-type hydrogen sulfide removal system, and part through a thermal
oxidizer and steam generation system, where steam needed for the retorting
                                    A-12

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     RAW SHALE

                             OIL  RECOVERY
VENT GAS
  n.
                                    RECYCLE GAS
                                    COMPRESSOR
                     FUTURE RETORT
                      CENTER SHAFT
BARRIER
                         AIR MAKE-UP
                         COMPRESSOR
                                                    \^Jr^r^." & *• ^« • vi « /
                 I OIL SUMP  AND PUMP
   FIGURE A-5.  Schematic of the Occident!al Modified In Situ Process
                                 A-13

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operation and perhaps other plant uses may be generated by the combustion of
the treated off-gas.

     The first commercial size MIS retort, with 120 ft. by 120 ft. cross
section and 250 ft. height, was ignited by Occidental from the top on December
10, 1975.  The ignition was successful, with oil being recovered from a sump
at the bottom of the column and sustained combustion and temperature control
achieved by recycle of a portion of the retort gas.  A total of 27,500 barrels
of oil was produced.  A second test was unsuccessful in that voids distribution
was poor and bad channeling of the flame front developed, causing poor oil yield.
Another test is presently in progress.

     The other modified in situ processes are similar to the Occidental pro-
cess.   The Geokinetics project involves relatively shallow, thin shale beds, and
produces a surface disturbance (upheaval) following fracturing.  The Equity Oil
project involves injection of super heated steam into thick, deep, and leached
shale beds, and may include recovery of other minerals.
                                    A-14

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