OIL
SHALE
accomplishment
plan
environmental/Vocky
protection /mountain
agency /prairie region
October 1974
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ACCOMPLISHMENT PLAN
Region VIII
U. S. Environmental Protection Agency
Covering
EPA Activities Relating to Oil Shale
(Colorado, Utah, Wyoming)
September, 1974
/^av/,t
/ Cooper Wayman
Director, Office of Eneifgy Activities
Green David D. Emery
ig'ional Administrator 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 in 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.
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TABLE OF CONTENTS
Section Page
Abstract ........................
Table of Contents ................... v
Preface ........................ ix
I. Introduction ...................... 1
Energy Demand and Environmental Protection ....... 1
An Oil Shale Environmental Protection Program -
Overview ....................... 3
History of Oil Shale Development ............ 5
Physical Description of Oil Shale Resources ...... 9
Environmental Constraints ............... 11
II. Objectives of an Oil Shale Program ........... 17
Objectives of the Prototype Leasing Program ...... 17
Local, State, and Federal Entities 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 Oil Shale
Lease Tracts in Colorado, Utah and Wyoming 7
3 Book Cliffs -- Near Anvil Points, Colorado 8
4 Drill Site in Exploration Program 10
5 Revegetation Research Plots, August, 1973, Anvil
Points, Colorado 12
6 Spent Shale Disposal — Anvil Points, Colorado 14
7 Typical Urban Water Quality Problem 15
VI
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TABLE OF CONTENTS
(Continued)
List of Tables Page
1 Result of Oil 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 Oil Shale Resource Program
Organization 60
A-2 Task Matrix -- Proposed Work Groups and Participants,
Oil Shale Resource Program 61
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TABLE OF CONTENTS
(Continued)
Page
Appendices 53
I. Outline of Possible Technical Investigations/
Coordination Structure for Oil Shale Development .... 54
II. EPA Authorities Related to Oil Shale Development .... 64
III. Water Guidelines — Oil Shale Environmental
Advisory Panel 70
IV. Air Guidelines -- Oil Shale Environmental Advisory
Panel 83
V. Recommended Parameters for Surface Water Quality
Monitoring Around Prototype Oil Shale Lease Tracts. ... 93
vm
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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 is 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 is 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 is 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 in 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.
ix
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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 is 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 is to become
fully involved in 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 Oil 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
Areawide Planning, and Permits under FWPCA-72: (2) Air 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 is 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
regionwide 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 in 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
XI
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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 is
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.
xii
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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 in energy exploitation are national issues of
great and immediate importance.
There has been much concern in 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 conse'rvation 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 is assuming its 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 in 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 in 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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An Oil 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 in response to national
demand is 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 it -- 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 is a
1. 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 its urban areas. Fortunately, the area has sorbed
many of these impacts. Now, however, the potential for stress is 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 in 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 is 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 intra-agency, is 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 in the area?
5. What authorities will planning and regulatory entities
need to do their jobs?
6. How does Region VIII EPA interact and influence relevant
Federal, State and local entities on environmental matters?
7. What type inter-agency setup best meshes with the
intra-agency organization and what type is 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
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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 is 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 entities in planning
for the use of oil shale land on an environmentally acceptable basis.
History of Oil Shale Development
The organic-rich sedimentary rocks known as kerogenetic calcareous
marlstone of the Green River Formation of Colorado, Utah, and Wyoming
offer the greatest promise for oil shale production in the world. Known
as the "rock that burns", to Indians and early settlers, knowledge of
oil in shale has a long history, but in 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 in the recovery of shale oil crude
developed in 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, if 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 billion barrels of shale oil in 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 Oil Shale Corporation, Ashland
and Shell (Prototype tract C-b): 50,000 bpd by 1980; Phillips, Sun, White
River Shale Oil Corp, Sohio (Prototype tracts U-a and U-b): 100,000 bpd
by 1980; Occidental-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 Oil Shale Lease Sales as of October 1, 1974
Tract
Colorado C-a
Utah U-a
Utah U-b
Wyoming W-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 Oil Corporation
Atlantic Richfield
Ashland Oil Company
Shell Oil Company
The Oil Shale Corp.
Sun Oil Company
Phillips Petroleum
White River Shale Oil
(a consortion of
Standard Oil of Ohio
Sun Oil Company
Phillips Petroleum)
No Bids Received
No Bids Received
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REGIONAL ENERGY DEVELOPMENT
PRIVATE OIL SHALE DEVELOPMENT
FEDERAL OIL SHALE LEASE TRACTS
FIGURE 2
GENERAL GEOGRAPHIC LOCATION OF THE SIX OIL
SHALE TRACTS IN COLORADO, UTAH, AND UYOMING
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Physical Description of Oil Shale Resource
The oil shale deposits of Colorado, Utah and Wyoming lie 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.b Some BQ% of the
known higher grade oil shale reserves are located in Colorado, 15% in
Utah, and 5% in Wyoming. Of the more than 11 million acres of oil
shale land potentially suitable for commercial development, about 70%
are public lands administered by the Department of the Interior. These
public lands contain 80% of the high-grade oil shale. Extensive deposits
of sodium minerals such as dawsonite (an aluminum mineral) and nahcolite
(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. Oil 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 in-situ technology is not generally thought to be
developed to the extent that prediction of technical or economic success
is warranted.
Oil 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
5. Final Environmental Statement for the Prototype Oil Shale Leasing
Program, U.S. Department of Interior, Volume I, page 1-2.
6. The shale is heated underground and little solid material is brought
to the surface.
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other associated facilities. About 50,000 acres will be required
for production, 10,000 acres for utility corridors, and up to 20,000
acres for urban expansion.°
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 small ness 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 II1-23.
8. Ibid, page 111-25.
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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 lion); loss of agricultural land.
(7) Air quality degradation from shale processing, refining,
and fugitive dust, including (a) particulates from mining,
crushing, and general solid materials handling; (b) burning of
retort off-gases from shale ungrading or for generating on-site
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 e)
(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 in air pollution from secondary
industrial and commercial sources.
9.Final Environmental Statement for the Prototype Leasing Program
Department of Interior, Volume I, page 111-44.
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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 its 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 environmental
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.
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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 Oil 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:'°
(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 ase 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.11 (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;
TV)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 Oil 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 tinuch 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
in 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;^2 (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 jurisdictional 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, 6tc.) 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 quality-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 it 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 is 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 delta required by all
decision makers involved in 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 in 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 in 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 liason 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
is 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 in monitoring all aspects of oil shale development
activities during FY 75. The specific detailed tasks with which these
people will be involved are presented in tabular form in the following
sections.
23
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TABLE 2
REGIONAL COORDINATION
ro
Activity
1. Coordination of EPA technical activities concerning
Oil Shale Development in 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 inter-divisional 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 Oil Shale Environmental Advisory
Panel representative — assist Regional Administrator
in insuring EPA committee assignments on the panel
are accomplished.
FY 74
FY 75
FY 76
1/2
1/8
1/8
1/4
1/2
1/8
1/8
1/4
FY 77
1/2
1/8
1/8
1/4
TOTAL: Work Years
0.0
1.0
1.0
1.0
-------
There are several ways that these people could be organized to
accomplish EPA's objectives regarding 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 in the following sections
are:
1. Establishment of another "coordinated" unit on an interdivisional
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 is 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 expertise,
continuity and priority in 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 existing 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 energy activities. The OEA would be closely associated
with the Administrator's Office in 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 is 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 it is 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 reguired. 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 in the Energy Office
would be the ease of obtaining inter-divisional 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 energy problems
might be obtained, in additon to the fact that division heads
would be routinely briefed in 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 in an existing, or perhaps new, division
to handle all oil shale activities. If a new "Energy 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 in 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 assignments 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 in 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 oroqram for EPA involvement
in oil shale development are presented in 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 inadeauate in places and too comprehensive to the
point of duplication in 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 following tables the quantity of
effort includes both professional and secretarial in 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, gilsonite, coal, etc.). The effort will
analyze maps and other representations showing aeoloay, 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 in-situ 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 estraction 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 in these totals is
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 effo.-t 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 aiven 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 in
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 leaching problems will be studied
28
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TABLE 3
TASK GROUP A -- MINERAL RESOURCES, REGIONAL GEOLOGY AND MINING PROCESSING
Work Years
ro
Activity
{1} 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 Oil 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)
-------
Activity
FY 197A
FY 1975
FY 1976
FY 1977
(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 e'fort 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 Socio-Economic 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.
1/24
1/4
1/4
1/3
1/24
1/24
1/16
1/12
1/8
(Contract - part
of surface
resources
development
contract)
1/6
-------
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)
-------
Activity
FY 1974
(10) Secretarial
TOTAL
Work Years
Contract Funds
0.66
FY 1975
1/12
1.5
$20,000
FY 1976
1/2
FY 1977
7/12
2.25 3.0
$45,000 $90,000
CO
ro
-------
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 in 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 is most likely required for the development
of methodologies capable of analyzing stream flow depletion/augmentation
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 investigations of streams and existing 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 given 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
in 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 1s 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 1n 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
Activity
(1) Manage water related activities. Insure coordination
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
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 1974
1/24
FY 1975
1/12
FY 1976
1/8
FY 1977
1/6
1/12
1/12
1/4
1/2
($13,000) ($35,000) ($50,000)
1/4 1/8 1/4
($10,000) ($15,000) ($20,000)
-------
OJ
en
Activity FY 1974 FY 1975 FY 1976 FY 1977
(4) Define the "instream needs" of flow requirements necessary 1/6 1/4 1/3
for the maintenance and enhancement of aquatic ecosystems ($22,000) ($50,000) ($60,000)
for streams in areas impacted by oil shale development.
The initial effort requires the adapting of a methodology
most appropriate to the oil shale area streams. Questions
to be answered involve evaluating the relative impacts of
changes in streamflow caused by impoundments and diversions,
and, possibly, discharges, on the aquatic ecosystem which
consists primarily of aquatic life such as fish and their
food chain, aquatic vegetation including stream bank
vegetation, and wildfowl dependent upon the flowing streams.
A contract effort required for methodology development.
Possible NERC assistance in field verification. Regional
coordination required.
(5) Salinity. Evaluate possible salinity increases associated 1/24 1/3 1/2 7/12
with oil shale development from depletions, effluents, ($ 5,000) ($20,000) ($30,000)
spent shale disposal, etc. Evaluate mitigation efforts.
Evaluate physical/economic detriments to water users of
increased salinity in the Colorado River Basin. Requires
water resources planning expertise and economic
evaluations. Regional effort with contract assistance.
-------
Activity
FY 1974
FY 1975
FY 1976
FY 1977
(6) Develop predictive surface water quality modeling
techniques. Existing modeling or predictive
methodologies must be evaluated and modified if
appropriate. New methodologies may have to be
devised. The outcome is to be the designation
of the best model(s) with subsequent field
verification and collection of pertinent input
data. The analysis will result in a method
manual which describes in detail the models
available, the limitations and advantages, the
sensitivities of the appropriate models to changes
in key parameters and to data deficiencies.
Contract effort needed, Water Resource Planning,
computer expertise required, Regional coordination.
Possible NERC assistance.
(7) Assessment of shallow and deep ground water reserves
and the impact of mining and related oil shale
development on these resources. A comprehensive
analysis of the shallow ground water system
(including ephemeral streams where shallow
ground water flow is perennial), to enable
predictions of potential impacts on the quality
and quantity of the water should be initiated.
Leaching studies of spoils materials and spent
shales are appropriate along with microscale
investigations of changes in water characteristics
with time in the spoil materials of mines and
spent shales. Deep ground water should be
assessed as to its potential as water source for
development. Sufficient bases to allow accurate
planning of ground water withdrawals are necessary
to avoid undue depletions of the ground water
1/12 1/8 1/6
($ 5,000) ($25,000) ($50,000)
1/24 1/16 1/12
($ 5,000) ($10,000) ($25,000)
-------
Activity
FY 1974
FY 1975
FY 1976
FY 1977
CO
reserves. Regional effort largely one of funding and
coordination with other agencies such as the US6S
and State Water Resources and Geological Surveys.
(8) Evaluate the effects of impoundments along perennial
streams on water quality and the aquatic ecosystem.
Little is known about the actual effects of such
impoundments since there are few within the oil shale
areas and none have been adequately monitored.
Potential impacts on fisheries and water quality
have been identified, but not measured or verified
in the field. Field investigations of existing
natural and man-made impoundments will add
significantly to the predictive capabilities.
Regional effort with possible NERC assistance.
Biological, geological, hydrological expertise
required.
(9) Coordinate study data, research, results, etc.,
with EPA-State river basin planning efforts.
Integrate study results (point sources, nonpoint
sources, growth factors, salinity, etc.) and
regional environmental planning effort with
on-going EPA functions.
(10) Secretarial
1/12 1/8 1/6
($ 5,000) ($ 5,000) ($15,000)
TOTAL
Work Years
Contract Funds
1/8
3/16
1/4
.42
.75
.8
.17
1.67
65,000
2.5
160,000
3.34
250,000
-------
meteorological conditions, and resource location in 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 in other parts of the Basin. Mobile
samples mounted in a fixed wind aircraft will be collected in 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 in 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 in
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 Oil 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, if 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-RTF,
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) ($75,000)
-------
Activity
FY 1974
FY 1975
FY 1976
FY 1977
(5) Acquire information to assess the existing visibility
in the area prior to the proposed oil shale development.
Coordinate with other groups attempting to assess
visibility. Region and NERC.
(6) Participate in developing procedures and in the
assessment of the impact of alternative strategies
on the study area air quality. Region and NERC.
(7) Analyze potential air pollution problems resulting
from sepondary population, industrial, and urban
growth. Integrate results into EPA regional
environmental planning functions.
(8) Examine possible fugitive dust problems associated
with mining and secondary activities.
(9) Secretarial
TOTAL
Work Years
Contract Funds
1/12 1/8 1/6
($ 5,000) ($10,000) ($20,000)
1/12
.55
1.67
$50,000
1/8
.75
1/6
3/16 1/4
($ 5,000) ($20,000)
1/24 1/16 1/12
($ 5,000) ($10,000)
.9
2.5 3.3
$120,000 $225,000
-------
characteristics or use of these resources on-site 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 in a comprehensive fashion. The effort will be extremely
concerned with assessment of cumulative impacts from related and
unrelated activities in 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 is 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.
-------
TABLE 6
TASK GROUP D — SURFACE RESOURCES
-£»
tss
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
1/16
FY 1977
1/12
1/8
3/16
1/4
1/24 1/2 3/4 1
(contract - ($75,000) ($100,000)
$25,000)
-------
Activity
FY 1974
FY 1975
FY 1976
FY 1977
(4) Coordinate, review, and implement a regional
environmental/resource planning program in
conjunction with appropriate local, State and
Federal entities. 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 in 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 biotic trend,
erosion, increased and changed use trends, etc.)
for secondary off-site and primary on-site
impacts. Coordinate monitoring results with
appropriate Work Group and EPA Regional
personnel and with on-site 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.
1/4
3/8
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)
-------
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, perculation, 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
nonpoint 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
-------
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 is 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 in 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 in 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
1/16
FY1977
1/12
1/16
1/16
1/12
1/16 1/32 5/12
($45,000) ($115,000) ($175,000)
1/16
1/16
1/12
-------
Activity
FY 1974
FY 1975
FY 1976
FY 1977
(6) Public Participation
Assist with identification and quantification of
public attitudes regarding oil shale development.
Provide for public forum at all significant
changes in land use policy of the area and assist
interest groups in gaining technical information
they desire. Develop valid public assessment tool
(mail questionnaire random survey, newspaper
questionnaire) to quantify public attitudes
regarding oil shale policy for inclusion as
supplemental data for the Oil Shale Environmental
Advisory Panel.
1/24
1/16
($ 5,000
contract)
1/12
(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 is whether or not the proposed
oil shale development will actually produce a significantly large share
of the total national energy supply in 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 in 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 FY 1974 FY 1975 FY 1976 FY 1977
(1) Coordination and input into the identification and 1/24 1/48 1/32 1/24
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 1/48 1/32 1/24
impact on oil demand.
(3) Analysis of development potential - time tables for 1/32 3/64 1/16
oil shale development.
(4) Analysis of oil from shale uses - its major market 1/32 3/64 1/16
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?
TOTAL Work Years .04 .1 .15 .2
-------
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 is designed to obtain and develop information that can
assist the prototype oil shale program in 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 in exercising full authorities for planning, support, and
regulation in 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,13 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 is 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 Oil 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 in 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 is 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 in 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.
13. Final Environmental Statement for the Prototype Oil Shale Leasing
Program, Department of Interior, Volume I, page 1-2.
50
-------
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 Oil 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 is 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 WorkSalary, WorkSalary, Work Salary,
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
overtarget positions have not been broken down by task group areas, but are listed as a
total for each Fiscal Year.
-------
APPENDICES
53
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APPENDIX I
OUTLINE OF POSSIBLE TECHNICAL
INVESTIGATIONS/COORDINATION
STRUCTURE FOR OIL SHALE DEVELOPMENT
Introduction
The Central Rocky Mountains, an area which consists of large
segments of Colorado, Wyoming, and Utah, has been the focus of increasing
attention because the area is 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,
in 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 in the region. The accumulation of knowledge and
analysis techniques has implications which extend beyond the study area
and into other areas of the country that are confronted with similar
problems. The resultant data 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 entities would have
the opportunity to participate in 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 in work groups when appropriate, and
the periodic assembly of policy officers from involved local, State
and Federal agencies, concerned individuals, and representatives of
special interest groups, to discuss issues, alternatives, and possible
joint regional policies.
The program 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 is 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 nature of the data and methodology to be used, and will elaborate
on the tasks and structure of the effort.
The draft Program Design will then be reviewed with other Federal
agencies, States, regional commissions, and the public. Such review
should be expedited, but data collection and the assessment and
development of analytical techniques can begin simultaneously. Comments
on the draft Design will be further solicited directly from interested
parties through the mechanism of Advisory Committees (discussed below
under Organization), and the Program Design will be the basis for an
expression of views 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,
it will be necessary to identify and evaluate legal, institutional,
social, economic, environmental, and physical constraints on resource
development and management. The analysis of physical constraints will
include, for example, the need to commit or divert a resource such as
water, for the development of coal. Existing arrangements may limit
the extent to which this can be done.
As such constraints are identified, findings will be fed into
other program elements to avoid duplication. This will be 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 is 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,
in effect, an inventory of institutions and attitudes. The relevant
institutional constraints are readily identified -- The Clean Air Act,
National Environmental Protection Act, mine reclamation laws, regional
water compacts, mineral leasing laws, 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, in the region, and nationally. These implications will be
arrayed against a variety of goals and the results presented without
value judgment. The multi-objective 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
entities 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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Program Review Board
EPA
DRCG
States
Interior
Public
Program Management Team
EPA USGS SCS
WY BSF&W FS
CO Public One person
UT DRCG (with staff)
BLM FEO as Program
Manager
Ad Hoc Committees
Monitoring
Planning
en
0
Regional Geology
and Mineral Resources
USGS - USBM
States - Public
Water
EPA
States - Public
Air
EPA - NOAA
States - Public
Work Groups
Surface Resources
(on-site impacts)
BLM - Ag
States - Public
Socio-Economic -
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
SUBJECT AREAS
2
National Energy
Considerations
Energy supply and demand
Energy technology
L-DOI (Energy Office)
P-EPA. DOC. FPC.
AEC. USOA. BR.
BLM. 8SFIW
C-CST, OEP. Indust.
CT»
*-*
Current & Projected
energy
Technology
National 4 Regional
Energy
Fuel Situations
Alternate regional
energy resources
development strategies
and technologies
So development
Satisfaction of National
and Regional Energy
and Fuel Demand
F
Soeio-Economic
and
Cultural Aspects
Existing local and regional
economy
Social Institutions
Attitudes
Archeology & history
Aesthetics
L-USDA
P-USDA. DOC. HEM, BIA,
BLH, NPS
States, Indust.
Private Org.
C-BOR. 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 & values
Growth of population &
economy with possible
disruptions 4 losses
E
Surface
Resources
D
Atmospheric
Aspects
C
Water
Soils
Vegetation
Timber
Grassland
Other
Fish & UlldHfe
Recreation
Agriculture
Scenery
Wilderness
L-USDA
P-BLH, BOR, BSF&H.
EPA, UPS
States, Prlv. Org.
C-BLM. COE
Location
Production
Current Use
Ownership & control
Zoning
Ownership 4 control
Economic
Biological & physical
Attitudinal
Zoning
Continue current practices
Accelerate selective
development
Interference from other
developments
Preservation/Conservation
Consumption
Compositional &
regional dynamics
AGENCY PARTICIPATION*
L-EPA
P-NOAA
States, Prlv. Org.
C-USDA. 001
SUBJECT HATTER CONSIDE
Cl imate
Quality
Quality
Standards
Alternative point
source locations
Regional quality
pollutant
dispersion patterns
Surface
Sub-surface
L-BR (Supply)
P-EPA (Quality),
GS (Basic data).
HRBC. BSF4U. BLH.
USOA. COE, NPS
States, Prlv. Org.
C-BOR
JFD
Quantity
Quality
Current 4 projected
use (current plans)
Rights
Compacts
Quality * Quantity
Standards
Location
Attitudes
Surface development
alternatives
Ground water management
alternatives
No development
Consumption vs
conservation Quality
B
Mineral Resources
Resources
Coal
Oil 4 Gas
Uranium
Other
L-BM
P-BLH. EPA, USDA,
BR, GS
States
Industry, Prlv. Org.
C-AEO
Location & depth
Grade
Ownership 4 control
Hineabllity
Ownership, leases
Reclamation laws
Demand
Attitudes
Extraction & exportation
Local Processing
Local energy conversion
Local industrialization
No development
Consumption vs
Conservation
A
Regional
Geology
Land form
Topography
Geology
L-GS
P-USDA, States
C-BLM
Scale-Coverage
Slope
Stability
•a 30
» -*»o n
3 p. at
ex a. a.
r» f 3
S SI
™ 2?
*/» ~1
— a.
^
ra o~
«-* CT O
O 7T
O VI
u* -*»
0
O I
"T,
— •• T
5S
r* T
fS tt
i»
O <9
•0 0 r»
gE*o"
3 3
JT 3 VI
2V* -
^1
T fl»
-•» -*•
= 3
n «
O «-» ro
3 0
3
<~t
3"
Of
3
U3
n
VI
? "
o
1
«3
05* A.
O 3
3 »
vt — <
!»*<
ft V>
c -1
n v>
So
A -*
VI
5
O
O
t/»
1*1
o
-H
i
t/i
* L - Lead; P - Participant; C - Contributor
TABLE A-2
-------
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 in 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 in 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 it.
The following is a list 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)
(b)
'... 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."
"... 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)
(2)
"... in 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;
"... 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)
"... (in cooperation) establish, equip, and maintain
a water quality surveillance system (utilizing all
resources available)
(3) "make grants
(4) "contract with public or private agencies,
64
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(6) "collect and disseminate, in cooperation with Federal
departments and agencies, and with other public or
private agencies, institutions, and organizations
having related responsibilities, basic data on
chemical, physical, and biological effects of 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 acid 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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(b):
(f):
Section 301(a):
Section 303(a):
(b):
(c):
Section 304(a):
"... 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.
(l)'(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.
"... estimate ... total maximum daily thermal level
"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)
Section 306(b):
Section 316:
Section 402:
"...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.
(1) (A) "... stream electric power plants ... (B) ...
Federal standards of performance —"
(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, and
with any industries involved, in the preparation and
conduct of such research and other activities ... develop
effective and practical ... methods ... for prevention
or control of air pollution.
"... 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 epidemiological studies ...
conduct ... studies on the immunologic, biochemical,
physiological, and the toxicological 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 bomcustion 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)
assisting in the
under sections
"For the purpose of (i) developing or assisting in
development of any implementation plan under secti
110 or lll(d) ... The Administrator may require ..
records ... reports ... monitoring ... and sample any
emissions which the owner or operator ... is 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 it is the continuing
policy of the Federal Government, in 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, in a manner calculated to foster and promote the
general welfare, to create and maintain conditions under
which man and nature can exist in productive harmony,
and fulfill the social, economic, and other requirements
of present and future generations of Americans.
68
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Section 101(b): "... it is the continuing responsibility of the Federal
Government to use all practical means ... to improve
and coordinate Federal plans, functions, programs, and
resources to the end that the Nation may ...
(2) "assure for all Americans safe, healthful,
productive, and esthetically 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 unquantified
environmental amenities and values may be given
appropriate consideration in decision making along
with economic and technical considerations;
(D) "study, develop and describe appropriate
alternatives to recommended courses of action
in 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 in
FWPCA-70, The Clear Air Act, and other environmental legislation under
which EPA operates.
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APPENDIX III
PROPOSED POLICY GUIDELINES
WATER AVAILABILITY AND QUALITY
for the
OIL SHALE ENVIRONMENTAL ADVISORY PANEL
August 2, 1971*
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. S. Boyne
V. Crane Wright
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TABLE OF CONTESTS
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 Finn 8
Background Data 9
Introduction 9
Surface and Groundwater 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 water budgets for whatever development plans they propose. Such
a water budget should indicate all planned Lessee water sources including
alternatives, their quantity and quality, and all planned Lessee water
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 downgradient water 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 water, 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 water budget.
The Mining Supervisor should assure that appropriate water conserva-
tion measures are undertaken and should encourage the Lessee to promote
water 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 m\is^ 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 water pumped from mine pits. The effluent limitations
in these permits are to be 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 wastewater 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 t.re not under
development. All nev 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 vill 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 water should be diverted around the disposal sites.
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(3) The supervisor should requir> proper operation of all vater 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 vater 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
waters. 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.
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KEEP IT MONITORED. Adequate suriV.ce 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 determined 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.
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Emphasis 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.
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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.
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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.
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Background Data
Introduction
The water situation, is complex and varied. The de' .-rraination of vater
available in the Upper Colorado River Basin is dependent on physical avail-
ability, reservoir sites for regulation, vater lavs and quality considera-
tions, of the Colorado Fiv^r system, in perpetuity to the Upper Basin and to
the Lover Basin. Two sources are available: (l) 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, nay 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
vater 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 are 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 1^.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-
196M» (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.
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as a possible ~ir^rof"lfoner"R "SLermlnation of the 5.8 million acre-
ular set of assumptions mentioned above ^nti* ^ Valld f°r the Partic-
tions, particularly those «««??;! V er combi^ions of assume-
jy CLiD 5O C1Q, \f 6d VI "t" rl (^ f^T.m e? 4~ >*/•% j i • **
of years used for water sironlv nnrt + aovnstream deliveries; period
of reservoirs due to ..dl^t'accJ^TtS^"™;,^ C™dlW<»
I.e. irrigation, industrial or export- and th f t USGS "
uses are projected would alter the total water^iv l^ ^^ tO VhJ:°h
deliveries at Lee Ferry would increase the level of available water
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 2_/ 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 following
percentages:
Colorado 51.75
New Mexico 11.25
Utah '...23.00
Wyoming lU.OO
Estimated Colorado River water availability, 197^ depletion includ-
ing main stem evaporation, committed future uses, and water remaining are
as follows:
State
Colorado
Utah
Wyoming
Share at
5.8 MAF
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
Year 200(
29,000
130,000
U7,000
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.
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Water available from exist-ing and potential facilities is as follows;
State
Colorado
Utah
Wyoming
Thousands of Acre-Feet
Amount From
Existing
Facilities
Green Mt. 1*5"\
Ruedi 33J
Flaming Gorge
Fontenelle
78. I/
130. 2/
258. 6/
Amount From
Additional
FVi 17 i 1 J tip n
West Divide
Yellow Jacket
Yampa River
Jensen Unit
Upalco Unit
Uintah Unit
77.
100.
100.
7
2
3
j
I/
f
Total
Without
167.
11+2.
I/
Upper Basin Total
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.
3/ Could be used in Colorado or Utah.
5/ Would exceed compact entitlements.
_5/ Maximum available for oil shale development from presently uncommitted
supplies.
6/ Part of this water has been identified for coal resource development.
It should be stressed that while the remaining uncommitted supplies
both undeveloped and from existing facilities, could be made 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 much of the pro-
cessing needs through Ip87 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 groundwater 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.
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Reference to Related Documents , Kerulations and Guidelines
1. Rules, regulations and procedure relating to administration of State
Water Law
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.
!». 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 h - 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 memoranda recommending monitoring techniques and
analytical measurements (e.g., see U/23/7^, 5/17/7^, 5/27/7^, et al
memoranda and attachments of George L. Snyder)
12. Previous panel memorandum dated 5/l6/7^ "Water Available for Oil Shale
Development in the Upper Colorado River Basin and Related Water Quality
Aspects" - Paul T. Sant
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APPENDIX IV
AIR GUIDELINES
Submitted to the
Oil Shale [{nvironniontal Advisory Panel
Ac! hoc Air Workgroup
John A. Green, Chairman
July 17, 1974
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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 Revicv/ Regulation
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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 he 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 pertinent State and Federal standards.
Air quality maintenance areas are being identified where special
plans will be developed to insure that the NAAQS arc maintained. It"
a State adopts a maintenance plan for an area which includes the oil
shale deposits, then tha lessee will have to adhere to the provisions
of that plan also.
EPA has pro!;;uUictcci standards of performance (emission standards)
for certain source categories. If a new source falls into one of
presently 12 categories, including storage vessels for petroleum
liquids, some refinery facilities and electric power genereting
plants, then the applicant must meet the emission limitations spelled
out in the regulation.
EPA proposed non-significant deterioration regulations in July
1973, but to date no regulations have been promulgated. One of the
source categories considered of concern under such regulations is
oil shale retorting. When any such regulation, State or Federal,
is promulgated, the lessee will be required to adhere to that regu-
lation also.
Any recommendations made by the air quality advisory committee
and adopted by the Panel and mining supervisor would also be followed
by the lessee.
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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> I^S -- 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 humidity at ground level, 30 feet and 100
feet above plant
c. Lessee maintains records of all baseline data collection
and monitoring programs
2. Opsration3 Data
a. Air Quality
(1) Begin 6 months prior to development operations and
continue through extent of lease period
b. Meteorological
Sains period as air 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 v/ater quality considerations
(7) Control equipment
b. The impact of primary air pollutant sources (e.g.,
fugitive dust, retorting, refining, and associated
pov/er plants) should be quantified.
c. 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.
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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 arid
equipment information arc: available.
3. The point of estimated maximum concentration bo 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.1, 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 meteorologists review meteorological data
needs. Surface readings will not provide adequate data
for diffusion modeling t-.nd upper atmospheric wind and
temperature data may be required.
5. The lessee be required to insure that averaging tiroes 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,
H2S, NOX, MC, 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.
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9. The lessee analyze quarterly composite participate 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 stags extends beyond the two
year baseline study.
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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.
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Operations Stage
The Panel should recommend to the M.S. that:
1. An operations manual he 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 arens where
spent shale 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 procodurcr^ should
be compatible1 with the relevant state air pollution
control agency requirements.
d. Maintenance plans and procedures for insuring optimal
reliability from the emission control equipriitnt. Fre-
quent inspections should be provided for, and emission
monitoring conducted.
e. 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 are violated under normal operating
conditions, the lessee must curtail operations to the degree
necessary to inset the standards. Normal operations would
only be resumed after the lessee had submitted arid received
approval of an emission control plan.
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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 11st 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 Units. 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 recotumcndatlons Iraply 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 In the data after many years of collec-
tion. Proper attention to these details now can help us assure that
later delays 1n 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
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Continuous Measurements
Specific Conductance
Temperature
1
Turbidity
Semi-Monthly
PH
2Dissolved Oxygen
Suspended Solids
Dissolved Solids
Calcium
Magnesium
Potassium
S i 1 i ca
Sodium
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
Fecal Coliform Fecal Streptococcus
*Gross Beta
Total Coliform
1.
2.
3.
4.
Principal stations on perennial streams only - S-M on other streams.
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.
If gross alpha activity exceeds 4 picocuries/liter, specific analyses
will be made for Uranium, Thorium, and Radium 226.
If gross beta activity (exclusive of l<4o) exceeds 100 picocuries/liter,
specific analyses will be made for Uranium, Thorium, Radium 226,
Lead 210 and Radium 228.
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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
5TOC
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 nHroqen.
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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
DBed Sediment
Analytical
Detection Limit
.06
.001
.01
.06
.02
Asbestos and similar fibers
Semi-Annual
Pesticides
Polycyclic Aromatics
ABS
MBAS
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.
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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 hydrologic
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.
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U.S. GOVERNMENT PRINTING OFFICE —678-565/41 REGION NO. 8
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