An Assessment of Oil Shale Technologies

Home , Industrial processes, Oil shale industry, Paraho process, TOSCO II process

CHAPTER 8 Environmental Considerations

Page Page Introduction ...... 255 Policy Options for Water Quality Management 314 Summary of Findings ...... 256 Safety and Health...... 315 Air Quality ...... 256 Introduction ...... 315 Water Quality...... 256 Safety and Health Hazards ...... 316 Occupational Health and Safety ...... 257 Summary of Hazards andTheir Severity. ....322 Land Reclamation...... 258 Federal Laws, Standards, and Regulations. ..324 Permitting...... 259 Control and Mitigation Methods ...... 325 Summary of Issues and R&D Needs ...... 326 Air Quality ...... + ...259 Current R&D Programs...... 326 Introduction ...... 259 Policy Considerations...... 327 Pollutant Generation ...... 259 Air Quality Laws, Standards, and Regulations 263 Land Reclamation...... 328 Air Pollution Control Technologies ...... 269 Introduction ...... 328 Pollutant Emissions...... 278 Reasons for Reclamation ...... 329 Dispersion Modeling...... 279 Regulations Governing Land Reclamation. ...329 A Summary of Issues and Policy Options. ....288 Reclamation Approaches...... 330 The Physical and Chemical Characteristics Water Quality...... 291 of Processed Shale ...... 332 Introduction ...... 29l Use of Topsoil as a Spent Shale Cover ...... 335 Pollution Generation...... 292 Species Selection and Plant Materials ...... 336 Summary of Pollutants Produced by Major Review of Selected Research to Date...... 339 Process Types...... 294 Summary of Issues andR&D Needs ...... 341 Effects of Potential Pollutants on Water Policy Options for the Reclamation of Quality and Use...... 295 Processed Oil Shales...... 342 Water Quality in the Oil Shale Region...... 296 Water Quality Regulations...... 297 Permitting...... 343 Technologies for Control of Oil Shale Water Introduction ...... 343 Pollution ...... 304 Perceptions of the Permitting Procedure. ....344 Ultimate Disposition of Waste Water ...... 308 Status of Permits Obtained by Oil Shale

Monitoring Water Quality ...... 309 Developers ...... 0.,.. 345 Information Needs and R&D Programs ...... 311 The Length of the Permitting Procedure .,,.. 346 Findings on Water Quality Aspects of Oil Disputes Encountered in the Permitting Shale Development...... 314 Procedure ...... 346 Page Page Unresolved Issues...... 347 54. Effluent Limitations for Petroleum Attempts at Regulatory Simplification...... 348 Refineries Using BestPracticable Policy Options...... ,.,....,.349 Pollution Control Technology...... 299 Chapter8 References...... 352 55. Effluent Limitations for Best Available Technology Achievable for Petroleum List of Tables Refinery Facilities ...... 299 56 New Source Performance Standards for TableNo, Page Petroleum Refineries ...... 300 34. Pollutants Generated bythe Colony 57 Colorado Water Quality Standards for Development Project ...... 262 Stream Classification B2 ...... 301 58. Utah Water Qualitv Standards for 350 PollutantsGenerated by the Rio Blanco Project on TractC-a...... 263 Stream Classification CW ...... 301 36. Pollutants Generatedbythe Occidental 59 Proposed Water Quality Criteria for Operation on TractC-b ...... 263 Designated Uses...... 302 37. The Federal and State Ambient Air 60 Primary Drinking WaterStandards . . . . 303 Quality Standards and Prevention of 61 Proposed Secondary Drinking Water Significant Deterioration Standards Regulations. ,.. .. ~.. .., ..~...... 303 That Influence Oil Shale Development . . 266 62. The Types of Contaminants in Oil Shale 38. National Standards for Prevention of Wastewater Streams and Some Potential Significant Deterioration of Ambient Processes for RemovingThem ...... 305 Air Quality, ...... 267 63. Relative Rankings of the Water 39. National New Source Performance Treatment Methods ...... 306 Standards for Several Types of Facilities 269 64. Estimated Costs of Water Pollution 40. EPA Standards for Best Available Air Control in Oil ShalePlants...... 306 PollutionControl Technologies for Oil 65, Sampling Schedule Summary for Surface Shale Facilities...... 269 and Ground Water Monitoring Program 41. Technological Readinessof Air Pollution at Tract C-b During Development Phase. 312 Control Technologies ...... 276 66. Animal Studies on the Carcinogenicity of 42. Costs of AirPollutionControl ...... 277 Oil Shale and ShaleOil ...... 320 43. Pollutants Emitted by theColony 67. Benzo(a)pyrene Content of 0il Shale and Development Project ...... 278 Its Products and of Other Energy 44. Pollutants Emitted by theRio Blanco Materials ...... 320 Project on Tract C-a...... 278 68. The Chemical and Physical Properties of 45, Pollutants Emitted by the Occidental Processed Shales ...... 332 Operation on TractC-b ...... 279 69. Estimates of Reclamation Needs Under 46. ASummary of Emission Rates From Five Various Levels of Shale Oil Production. , 338 Proposed Oil Shale Projects...... 279 70. Status of the Environmental Permits for 47. A Comparison of Atmospheric Emissions Five Oil Shale Projects, ...... 345 Used in Modeling Studies...... 282 48. Modeling Results for Federal Oil Shale Lease TractC-a ...... 284 49. Models Used in SupportofPSD Applications for Oil Shale Projects . . . . . 285 List of Figures 50. Areas of Inadequate Information and Suggested R&D Responses ...... 288 59. Designated Class I Areas in Oil Shale Page 51. Generation Rates for Principal Water Region ...... 268 Pollutants for Production of 50,000 bbl/d 60, Computation Modules in Atmospheric of Shale Oil Syncrude...... , . . . . . 294 Dispersion Models ...... 281 52. Quality of Some SurfaceStreams in the 61. An Aboveground Spent Shale Disposal Oil Shale Region ...... 297 Area ...... 307 53. Quality of GroundWaterAquifers in the 62. Summary of Occupational Hazards Piceance Basin...... 297 Associated With Oil ShaleDevelopment. 323 CHAPTER 8 Environmental Considerations

Introduction

The region where oil shale development emissions and by the leaching of soluble con- will take place is, at present, relatively un- stituents into surface and ground water sys- disturbed. The construction and operation of tems. Water quality could thus be degraded plants would emit pollutants and produce by altered nutrient loading, changes in dis- large amounts of solid waste for disposal. As solved oxygen, and increased sediment and a consequence, air, water, and soil could be salinity. degraded and the topography of the land could be altered. The severity of these im- For these reasons, each potential environ- pacts will depend on the scale of the opera- mental effect along with its control technol- tions and the kinds of processing technologies ogy should be examined with respect to its net used, as well as the control strategies that impact on the total environmental system. To must be adopted to comply with environmen- do this requires full understanding of the tal regulations. separate impacts on air, water, and land, the interaction between the individual parts of Control strategies have been proposed for the ecosystem, and the efficacy of the control purifying water and airborne emissions strategies. Such an analysis needs a complete streams, for revegetation, for protecting wild- and accurate data base which is as yet un- life, and for other specific areas of envi- available because no commercial oil shale ronmental concern. However, control tech- plants have been built. OTA’s environmental nologies that are applied to one area could analysis, therefore, is limited to examining adversely affect another area. For example, the effects that an oil shale industry would to control air pollution, airborne streams are have on the separate areas of air, water, scrubbed to capture dust and gaseous con- land, and occupational health and safety. In taminants. This produces sludges and waste- order to provide a basis for policy analysis, water that have to be disposed of along with the effects are quantified wherever possible other wastes. All of these have the potential and related to a production of 50,000 bbl/d. to adversely affect the land and the water. For each of the areas examined: Airborne pollutants, such as trace metals, impacts of oil shale operations are de- might enter surface streams and ground scribed; water in fugitive dust and or rainfall and applicable laws and regulations are could alter the chemical and biological bal- summarized, and their significance to oil ances of the water systems. Plant and animal shale analyzed; life as well as human health could be harmed control strategies proposed for compli- both by an increase in water contamination ance with the laws and regulations are and by the entry of the contaminants into the described and evaluated; and food chain. Similarly, without adequate con- policies that could be focused on key is- trols, the piles of solid waste could contami- sues and uncertainties are identified nate the air and water through fugitive dust and discussed.

255 256 ● An Assessment of Oi/ Shale Technologies

Summary of Findings

Air Quality ● The costs of controlling air pollution will be particularly sensitive to the strictness of the environ- Because of the oil shale region’s rural character, mental regulations and to the design characteris- its air is relatively clean and unpolluted. Occasional- tics and size of each project. Preliminary estimates ly, however, high concentrations of hydrocarbons indicate that air pollution control could cost from (possibly from vegetation) and particulate from $0.91 to $1.16/bbl of syncrude produced (rough- windblown dust occur. The development of a large oil ly 3 to 5 percent of the selling price of the oil). shale industry (or any industrial or municipal growth) will degrade the air’s visibility and quality. Even if ● the best available control technologies are used and The only means for predicting the long-range im- compliance is maintained with the provisions of the pacts of oil shale emissions on ambient air quality Clean Air Act, its amendments, and the applicable in the oil shale area and in neighboring regions are State laws, degradation will occur. It will take place mathematical dispersion models, which are the not only near the oil shale facilities but also in nearby Environmental Protection Agency’s (EPA) tool for pristine areas (e.g., national parks, wilderness enforcing the provisions of the Clean Air Act. Mod- areas). Some places may be affected more than eling of oil shale facilities presents a number of others from local concentrations of pollutants caused problems because of the topography and meteorol- by thermal inversions. ogy of the region, the chemistry of the emissions, and the unknown quantities of emissions expected Findings of the analysis include: from commercial-size facilities. In addition, dis- ● Oil shale mining and processing will produce at- persion models developed to date have been pri- mospheric emissions including those pollutants marily for flat terrain. Thus, their predictions con- for which National Ambient Air Quality Standards tain significant inaccuracies. More R&D needs to (NAAQS) have been established (i.e., sulfur diox- be undertaken in this area. ide, particulate, carbon monoxide, ozone, lead, and nitrogen oxides); as well as various other cur- ● rently unregulated pollutants (such as silica, Even with the use of BACT, the industry’s capacity sulfur compounds, metals, trace organics, and will be limited by the air quality standards govern- trace elements). ing PSD. A preliminary modeling study by EPA has indicated that an industry of up to 400,000 bbl/d ● Under the Clean Air Act, oil shale development will in the Piceance basin could probably comply with have to comply with NAAQS and State air quality the PSD standards for Flat Tops (a nearby Class I standards; maintain air quality, especially visibili- area) if the plant sites were dispersed. Additional ty, in adjacent Class I areas (e.g., national parks); capacity could be installed in the Uinta basin, comply with prevention of significant deterioration which is at least 95 miles from Flat Tops, A 1-mil- (PSD) increments (these specify the maximum in- lion-bbl/d industry could probably not be accom- creases in the concentrations of sulfur dioxide and modated because at least half of its capacity particulate that can occur in any region); comply (500,000 bbl/d) would be located in the Piceance with New Source Performance Standards (NSPS); basin. Policy options to address this limitation in- and apply the best available control technology clude the application of more stringent emission (BACT). standards, changes in PSD increment allocation procedures, and amending the Clean Air Act. ● A wide variety of control technologies could be applied to the emissions streams from oil shale processes. They are fairly well developed and have Water Quality been successfully used in similar industries. They should be adaptable to the first generation of oil Water quality is a major concern in the oil shale re- shale plants. However, full evaluation will not be gion, especially in regard to the salinity and sediment possible until they have been tested in commer- levels in the Colorado River system. The potential for cial-scale oil shale plants for sustained periods. pollution from oil shale development could come from Ch. 8–Environmental Considerations ● 257

point sources such as cooling system discharges; ● Although control of major water pollutants from from nonpoint sources such as runoff and leaching of point sources is not expected to be a problem, less aboveground waste disposal areas and ground water is known about the control of trace metals and tox- leaching of in situ retorts; and from accidental dis- ic organic substances. Research is needed to as- charges such as spills from trucks, leaks in pipe- sess their potential hazards and to develop meth- lines, or the failure of containment structures, Un- ods for their management. Other laboratory-scale less these pollution sources are properly controlled, and pilot-plant R&D should be focused on charac- the lowered quality of surface and ground water terizing the waste streams, on determining the resources could adversely affect both aquatic biota suitability of conventional control technologies, and water for irrigation, recreation, and drinking. and on assessing the fates of pollutants in the water system. Extensive work is already under- Specific findings include the following: way; its continuation is essential to protecting ● Surface discharge from point sources is regulated water quality, both during the operation of a plant under the Clean Water Act, and ground water rein- and after site abandonment. fection standards are being promulgated under the Safe Drinking Water Act. Solid waste disposal Occupational Health and Safety methods may be subject to the Toxic Substances Control Act and the Resource Conservation and The oil shale worker will be exposed to occupa- Recovery Act. The general regulatory framework is tional safety and health hazards. Many of these– therefore in place, although no technology-based such as rockfalls, explosions and fires, dust, noise, effluent standards have been promulgated for the and contact with organic feedstocks and refined industry under the Clean Water Act. Nonpoint products–will be similar to those associated with sources present regulatory and technological diffi- hard-rock mining, mineral processing, and the refin- culties, and at present are subject to less stringent ing of conventional petroleum. However, the workers controls. might be exposed to unique hazards due to the phys- ● Developers are currently planning for zero dis- ical and chemical characteristics of the shale and its charge to surface streams and to reinject only ex- derivatives, the types of development technologies to cess mine water. This eliminates point discharge be employed, and the scale of the operations. Poten- problems because most wastewater will be treated tial risks include safety hazards that might result in for re-use within the facility, and untreatable disabling or fatal accidents, and health hazards wastes will be sent to spent shale piles. The costs stemming from high noise levels, contact with irritant of this strategy are low to moderate, and develop- and asphyxiant gases and liquids, contact with likely ment should not be impeded by existing regula- carcinogens and mutagens, and the inhalation of fi- tions if it is used. brogenic dust. ● A variety of treatment devices are available for the Specific findings include: above strategy, and many of them should be well- ● Only a few fatalities have occurred during the min- -suited to oil shale processes. However, uncertain- ing of over 2 million tons of shale and the produc- ties exist regarding whether conventional methods tion of over 500,000 bbl of shale oil. The accident would be able to treat wastewaters to discharge rate has been one-fifth that for all mining, and standards because they have not been tested with much lower than that for coal mining. However, actual oil shale wastes under conditions that ap- this record was achieved in experimental mines proximate commercial production. There are also a that employed, for the most part, experienced number of uncertainties regarding the control of miners. Whether safety risks will increase or de- nonpoint pollution sources. For example, no tech- crease as mining activities are expanded cannot nique has been demonstrated for managing be predicted. ground water leaching of in situ retorts, nor has the efficacy of methods for protecting surface dis- ● Although the carcinogenicity of oil shale dusts and posal piles from leaching been proven. It is not crude shale oil has been demonstrated by some in- known to what extent leaching will occur, but if it vestigators, the conflicting results of other studies did, it would degrade the region’s water quality. combined with an overall lack of information pre- 258 ● An Assessment of Oil Shale Technologies

elude a determination of the severity of the risk. Specific findings include:

The incidence of diseases in other industries indi- ● cates that exposure to these materials could be Several approaches can be used to reduce the hazardous. deleterious effects associated with the disposal of spent oil shale. These include reducing surface ● The large variety of substances that will be en- wastes by using in situ processing or returning countered in retorting may present as yet unde- wastes to mined out areas; the chemical, physical, tected health hazards. Of special concern is the or vegetative stabilization of processed shale; and possibility of carcinogens in shale oil and its de- combinations of the above. rivatives, Possible synergistic effects from the products of modified in situ (MIS) operations ● Research has shown that vegetation can be estab- (which combine mining with retorting) could in- lished directly on processed oil shales. However, crease the level of risk. intensive management is required, including the ● Shale oil refining poses no special hazards since leaching of soluble salts, the addition of nitrogen most of its problems will be similar to those experi- and phosphorus fertilizers, and supplemental wa- enced in conventional petroleum refining. tering during establishment. Revegetating spent shale covered with at least 1 ft of soil is less sus- ● Health and safety hazards will be reduced by ceptible to erosion and does not require as much using pollution control technologies for air and supplemental water and fertilizer. Adapted plant water pollutants and by requiring specific indus- species are required for either option, trial hygiene practices. These are required by law and are expected to be implemented by oil shale ● The long-term stability and character of the vege- developers. However, it is essential that R&D on tation is unknown, but research on small plots the nature and severity of health effects keep pace suggests that short-term stability of a few decades with the development of the industry. Such infor- is likely if sufficient topsoil is added. mation will be useful in identifying and mitigating long-term effects on workers and the public. ● Reclamation plans will have to be site specific since environmental conditions vary from site to Land Reclamation site, Proper management will be required in all instances, if only to maintain plant communities in An industry will require land for access to sites, surrounding areas. H is even more important in for the facilities, for mining, for retorting, for oil the reclaimed areas. upgrading, and for waste disposal. The extent to which development will affect the land on and near a ● Shortages of adapted plants and associated sup- given tract will be determined by the location of the port materials such as mulches probably would tract; the scale, type, and combination of processing occur if a large (ea. 1 million bbl/d) industry is es- technologies used; and the duration of the opera- tablished. The problem is compounded by the in- tions. The facilities must comply with the laws and creasing demands from other mining operations regulations that govern land reclamation and waste such as coal and other minerals. disposal. Nevertheless, there will still be effects on land conditions (through altered topography) and ● The Surface Mining Control and Reclamation Act wildlife (through changes in forage plants and habi- provides for the kind of comprehensive planning tats). In addition, unless appropriate disposal and and decisionmaking needed to manage the land reclamation methods are developed and applied, the disturbed by coal development. New reclamation large quantities of solid wastes that will need to be standards that are applied to oil shale should pro- handled could pollute the air with fugitive dust and vide for postmining land uses that are ecologically the water with runoff and Ieachates from storage and economically feasible and consistent with piles and waste disposal areas. public goals. Ch. 8–Environmental Considerations 259

Permitting visor of the U.S. Geological Survey (USGS). Once the requirements for an EIS and DDP are satisfied, During the past 10 years an increasingly complex obtaining all of the needed permits can take more system of permits has been developed to assist the than 2 years. The project would not necessarily be Federal, State, and local governments in protecting delayed by the full length of the permitting sched- human health and welfare and the environment. Per- ule, because other predevelopment activities such mits are the enforcement tool established by Con- as engineering design, contracting, and equip- gress and the States to determine whether a pro- ment procurement could proceed in parallel, if the spective facility is able to meet specific requirements developer were willing to accept the risk that some under the law. of the permits might not be obtainable.

Operation of an oil shale facility requires more than ● The principal problems encountered to date with 100 permits from Federal, State, and local agencies. the permitting process are related to the needs of Included are those for environmental maintenance, the regulatory agencies for technical information for protection of worker health and safety, and for the and to differing interpretations of environmental construction and operation of any industrial facility law. Future problems may be more critical than (e.g., building code permits, temporary permits for those encountered thus far. Several relevant regu- the use of trailers, sewage disposal permits). Of lations are still pending that may increase costs or these 100 permits, about 10 major environmental force changes in the design of process facilities or ones require substantial commitments of time and re- control technologies. They may also add to the sources. control requirements. Another problem that might Findings of the analysis include: emerge is the ability of regulatory agencies to handle the increasing load of permit applications and ● The time required for preparing and processing a enforcement duties. permit application depends on the type of action being reviewed, the review procedures stipulated ● Several attempts are being made to simplify regu- under the law, the criteria used by agencies to Iatory procedures. These include the streamlining judge the application, and the amount of public of permitting procedures within specific agencies; participation and controversy that is brought to the design and testing of a permit review pro- bear. If Federal land is involved, then an environ- cedure for major industrial facilities that will coor- mental impact statement (EIS) will most likely be dinate the reviews by Federal, State, and local required. The EIS process may take at least 9 regulators; and the proposed Energy Mobilization months after the developer applies for permission Board to expedite agency decisionmaking and re- to proceed with the project. In the case of the cur- duce the impacts of new regulatory requirements. rent Federal lease tracts, additional time was Colorado has recently announced a joint review needed to prepare detailed development plans process designed to accomplish the first two of (DDP) for approval by the Area Oil Shale Super- these ends.

Air Quality Introduction ● Rates are estimated for the generation of air contaminants. The maintenance of air quality is necessary for the development of an environmen- ● The applicable Federal and State air tally acceptable oil shale industry. In this sec- quality regulations and standards are tion: described. The types of atmospheric contaminants ● The effects of these regulations and produced by oil shale unit operations are standards on a developing oil shale in- characterized. dustry are analyzed. 260 ● An Assessment of Oil Shale Technologies

● The air pollution control technologies minesite that produce fugitive dust (particu- that may be applied to untreated emis- late matter discharged to the atmosphere in sion streams are described and evalu- an unconfined flow stream). ated. The net rates at which pollutants will be emitted in treated streams are es- Atmospheric emissions are expected to be timated. much larger in open pit than in room-and- pillar mining because of the significantly ● Modeling procedures that may be used to predict and monitor compliance with larger quantities of solids that must be han- air quality regulations are discussed. dled on the surface. The mine dust problem will be further aggravated by road dust from ● Potential problems that commercial- scale operations may encounter in meet- transportation of overburden, and wind- ing standards are identified. blown dust from all operations. ● Key findings are summarized. Storage, transport, and crushing of oil ● Policy options are discussed. shale result in the emission of particulate,

CO, NOX, SO2, and HC from fuel in diesel en- Pollutant Generation gines, and particulate and silica from fugitive dust. Dust is the chief pollutant. The Oil shale mining and processing will pro- amount generated depends on the grade of duce atmospheric emissions including those ore, the extent to which its size must be re- pollutants for which NAAQS have been es- duced for retorting, the number of transfer

tablished: sulfur dioxide (SO2), particulate, points in the transportation system, and the carbon monoxide (CO), ozone (0 S), lead, and level and effectiveness of control strategies

nitrogen oxides (NOX); as well as various used. other currently unregulated pollutants, such Retorting technologies generate process as silica, sulfur compounds, metals, carbon heat by the combustion of fossil fuels, which dioxide (CO ), ammonia (NH ), trace organics, 2 3 produces a number of atmospheric emissions. and trace elements. The following discussion The amount of SO2 emitted depends on the examines the types of pollutants generated by sulfur content of the fuels used in the plant each unit operation. Where data are avail- and the extent to which sulfur-containing able, the rates at which these contaminants product gases are treated. The volume and will be produced by different oil shale facil- concentration of hydrogen sulfide (H2S), car- ities are estimated. bonyl sulfide (COS), and carbon disulfide

(CS2) in the offgas streams from retorts de- Unit Operations and Pollutants pend on the type of retorting technology. COS Mining can be carried out either using un- has been detected in the offgases from Law- derground (room and pillar) or surface (open rence Livermore Laboratory’s simulated MIS retorts and trace quantities of COS and CS pit) methods. The sequential steps in room- 2 and-pillar mining are drilling, blasting, muck- have been reported in the offgases from the ing (collection of the blasted shale), primary Occidental MIS process under certain oper- crushing, and conveying the reduced shale to ating conditions. It is not known whether the the surface for retorting. Potentially hazard- retort offgases from the Paraho, Union “B,” ous substances (silica, salts, mercury, lead) TOSCO II, or Superior processes contain COS or CS . may be released during blasting. Methane 2

may be released from underground gas de- The major source of NOX emissions is the

posits, and CO, NOX, and hydrocarbons (HC) combustion of fuel in boilers, air compres- may be emitted by incomplete combustion of sors, and diesel equipment. The specific lev- the fuel oil used both for blasting and in mo- els depend on the combustor design, the ex- bile equipment. In addition, particulate can tent of onsite fuel use, and the nitrogen con- be emitted as a result of blasting, raw shale tent of the fuels used to produce process heat handling and disposal, and activities at the or steam. Most of the fuels consumed in oil Ch. 8–Environmental Considerations ● 261 shale plants will be produced onsite. Both di- chrome, zirconium, and manganese.l At typi- rectly heated aboveground retorts (AGR) and cal retorting temperatures (ea. 900° F (480° MIS generally produce sufficient low-Btu gas C)), it is generally accepted that most trace to meet retorting requirements, plus an ex- elements are not volatilized. They leave the cess for other onsite uses such as power gen- retort in the spent shale product and in par- eration. Indirectly heated aboveground re- ticulate entrained in retort gases and shale torts produce less fuel gas, but it has a higher oil. Possible exceptions are antimony, arse- heating value. In either case, it is possible nic, beryllium, boron, copper, fluorine, lead, that some shale oil will be burned for process mercury, nickel, selenium, and zinc, which heat. Since both retort fuels (gases and shale could leave the retort as vapor and be con- oil) contain nitrogen, they could potentially densed in the liquid product.2 The heavy emit more NOX. metals in raw shale oil are of economic concern because they tend to destroy the effec- HC and CO will be emitted primarily in the tiveness of the catalysts used for refining. * exhausts of mobile equipment and in flue Their removal is not expected to present any gases from boilers and other combustors. HC major problems to the refiner. Several propri- will also be emitted in vapors from oil storage etary techniques are available for this pur- tanks, pumps, flanges, seals, and compres- pose. It has also been recognized that refining sors, and CO by blasting and rubblization catalysts need careful disposal because they during the preparation of MIS retorts. Emis- may contain nickel, cobalt, molybdenum, sion levels from storage tanks should not vary chromium, iron, and zinc, in addition to trace with the type of retorting technology. The elements captured from the shale oil. Emis- other HC and CO sources have a dependence sions can occur during the onsite regenera- on retorting technology that is similar to that tion of these catalysts and during the disposal described for NO . Equipment-related emis- X of spent catalysts in landfill operations. sions are a function of the amount of solids that need handling on the surface. Upgrading, refining, gas cleaning, and power generation produce such pollutants as The quantities and the chemical properties CS2, COS, SO2, H2S, NH3, and HC; with HC of the particulate emitted vary with retort- being the dominant fugitive emission.) Par- ing technologies. Retorts like TOSCO II that ticulate such as fly ash are also produced. require fine shale feed and produce very fine retorted shale, produce the largest amounts. The handling and disposal of raw and retorted shale could create serious fugitive dust The pyrolysis of an organic material like oil problems. This dust may contain harmful par- shale kerogen produces a certain amount of ticulate and possibly POM. The problems polycyclic organic matter (POM). POM, which are most severe for technologies like TOSCO is found in conventional crude oils, has also II that produce very fine spent shale. Dust been found in the carbonaceous retorted production should be less of a problem with shales from TOSCO II, Union “B,” and Para- aboveground retorts like those of Paraho and ho indirect retorts. It is rarely found in re- Union “B” that produce coarse spent shale, torted shale that has been subjected to a They should be even less significant for MIS strong oxidizing environment such as that en- because spent shale will remain underground countered in the Paraho direct retort. and will not be subjected to wind erosion. Trace elements (particularly the heavy metals) may be released by retorting opera- The Amounts of Pollutants Produced tions. Compared with average rocks, Green River oil shale contains much higher levels of It is difficult at present to estimate the selenium and arsenic; moderately higher lev- quantities of air contaminants that would be els of molybdenum, mercury, antimony, and *Refinery modifications to mitigate this problem are dis- boron; and lower levels of cobalt, nickel, cussed in ch. 5. 262 . An Assessment of Oil Shale Technologies produced by a commercial-size oil shale facil- that the tables show levels of pollutant gener- ity. The only field measurements that have ation, not pollutant release. been made to date have been for the small- Of the three designs —Colony, Rio Blanco, scale, short-term pilot-plant or semiworks and Occidental—Colony produces the largest operations of Colony Development, Paraho, 4 amount of particulate. This plan uses both and Occidental Oil Shale. These facilities do the most underground mining and TOSCO II not simulate normal operating conditions in a AGR, which requires a fine shale feed and full-size facility, and the measurements that produces a very finely divided shale. This have been made have been mostly of the regu- retorting method is also responsible for Col- lated pollutants. Only a few of the nonregu- ony’s exceptionally high production of HC. In lated pollutants such as trace elements have the TOSCO II retorting system, vaporized been measured, and those measurements shale oil and gases evolved during pyrolysis that have been reported show considerable are stripped of high molecular weight HC in a variation. Pollution production estimates condenser, and then burned to reheat the must therefore be confined to regulated pol- heat carrier balls. Because combustion is in- lutants and must strongly rely on theoretical complete, lighter weight HC are entrained in calculations. the offgas stream from the ball heater. The quantities of pollutants produced in an In generating steam for power, the Occi- industrial facility can be estimated by apply- dental design in which large quantities of ing pollutant generation factors to the mass low-Btu gas are burned produces the most flows of material through the plant. The pro- NOX emissions. Rio Blanco, which plans to cedure used for the calculation, although an burn coke from the upgrading units, produces approximation, gives estimates of the prob- less NOX but more particulate. Colony’s on- lem’s scope. Generation factors obtained site pollutant production in this step will be from the literature were applied to the mass negligible because it plans to purchase most balances published for Colony’s proposed of its electricity from offsite powerplants. TOSCO II retorting plant on Parachute Creek, for Rio Blanco’s combination of MIS and AGR The emission of SO2, produced in the NH3 processing on tract C-a, and for the Occiden- and sulfur recovery processes, is about the tal MIS operation on tract C-b. All flows were same for all three designs. Although both Col- scaled to a uniform production level of 50,000 ony’s and Rio Blanco’s CO emissions are high- bbl/d of shale oil syncrude. The results are er than Occidental’s, the differences are not summarized in tables 34 through 36. Note significant.

Table 34.–Pollutants Generated by the Colony Development Projecta (pounds per hour)b

Operation Particulate so, NO, HC co Mining ...... 1,480 0 250 50 440 Shale preparation...... 15,940 0 0 0 0 Retorting c...... 11,440 150 1,430 480 60 Spent shale treatment and disposal ...... 1,350 0 130 10 0 Upgrading...... trace 10 20 10 trace Ammonia and sulfur recoveryd...... , 0 32,200 0 0 0 Product storage ...... 0 0 0 150 0 Steam and power...... – — — — — Hydrogen production ...... 10 30 80 trace 10 Total ...... , . . . . . 30,220 32,390 1,910 700 510

c3Tafj~ shows the ItIVtIt Of pOllUlafll generation, not pollufanf release

bRoom.and.pillar mlnlng, TOSCO II retorting, scaled 1050,000 bbl/d Of shale oll syncrude production cFlgures do not include components of the product gas and VaPOr stream also, equivalent of H*S m retort 9as stream

SOURCE T C Borer and J W Hand, /derr//hcal/on and Proposed CorJlro/ 01 A/r Po//ufartfs from O/l Sha/e Operations, prepared by the Rocky Mountain Diwslon, The Pace Company Consultants and Engineers, Inc for OTA, October 1979 Ch. 8–Environmental Considerations ● 263

Table 35.–Pollutants Generated by the Rio Blanco Project on Tract C-aa (pounds per hour)b

Operation Particulates so, NO. HC co Mining. ,, .,,,.. ,. 1,050 4 340 80 430 Shale preparation. . . . ., . . . . 7,200 0 200 0 0 Retorting ., 8,900 52 320 100 0 Spent shale treatment and disposal 650 0 0 0 0 Upgrading. ., ., 7 0 7 13 0 Ammonia and sulfur recoveryd ., ., ., 0 19,200 0 0 0 Product storage ., ., 0 0 0 105 0 Steam and power. ~ ~ ~ ~ 210 250 1,220 13 0 Hydrogen production – — — — — Total 18,017 19,506 2,087 311 430

aTab[e shows lhe level of poilulanl generation not pollutanf release bundergroun~ mlnlng modlfled [n SIfU and TOSCO II aboveground retorlng scaled tO 50000 bblld of shale oll syncrude cFlgures do not !nclude components of The product 9as and vaPor stream also, ~qulvalen[ Of H,S In retofl 9as s(ream SOURCE T C Borer and J W Hand /deohf/cat/on and Proposed Corrtro/ of A/r Po//ufarrts lrorn 0// Shale OperaOorrs prepared by the Rocky Mountain Owslon The Pace Company Consultants and Eng(neers Inc for OTA Oclober 1979

Table 36.–Pollutants Generated by the Occidental Operation on Tract C-ba (pounds per hour)b

Operation Particulate so, NO, HC co Mining 4,540 0 300 120 180 Raw shale disposal ~ 450 0 100 10 0 Retorting c ~ 0 0 0 0 0 Upgrading. . 10 10 80 trace 10 Ammonia and sulfur recoveryd ., 0 24,000 0 0 0 Product storage 0 0 0 80 0 Steam and power. . 20 trace 2,800 0 0 Hydrogen production 80 20 220 20 20 Total 5,100 24,030 3,500 230 210

aTa~ie shows [he level of ~oliufan[ generation not pollutant release bunderground mlnlng modlfted in sdu retorting scaled to 50000 bbl d Of shale 011 syncwde cFlgures do not Include components of tne product gas and vaPOr stream dsol equivalent o! HIS m reforl 9as stream SOURCE T C Borer and J W Hand Idenhkaflon and Proposed Cofltrol of +Vr Po//ufartk from 0// .S/ra/e Opera(/orm prepared by the Rocky Mountain Ow!s!on The Pace Company Consultants and Eng[neers Inc for OTA Oclober 1979

It should again be noted that the tables may also act to constrain the ultimate size of show the amounts of pollutants generated, the oil shale industry. not the amounts released. Pollutant emissions are regulated by laws and standards, which Air quality regulation is called for by the are discussed in the next section. Compliance Federal Clean Air Act of 1970, as amended in with these laws and standards requires pollu- 1977, hereafter referred to as the “Act.” Reg- tion control technologies, which are dis- ulations and standards arising from this Act cussed later in the chapter. are implemented at the Federal level by EPA and at State levels in conjunction with addi- Air Quality Laws, Standards, tional regulations and standards imposed by the individual States. The following discus- and Regulations sion first highlights major provisions of the Act, and then analyzes those that are particu- Introduction larly significant for oil shale development. The existing and proposed regulations and standards governing air pollution from the oil Highlights of the Amended Clean Air Act shale industry are discussed here because they will affect the design and operating The Clean Air Act, as amended, estab- characteristics of oil shale facilities. They lishes a national program to regulate air .

264 ● An Assessment of Oil Shale Technologies pollution in order to maintain or improve air agers of affected Federal lands (and States in quality. The Act is universally applicable, but the case of Indian action). its provisions are most strongly directed to The classification of an area with respect those areas having the cleanest air (nondegradation areas) and those where air pollution to the ambient air quality has important con- may be hazardous to public health (nonattain- sequences. The Act divided the Nation into ment areas). The major elements of the pro- 247 air quality control regions (AQCRs) so gram established by the Act are: that pollution control programs could be lo- cally managed. Compliance with an NAAQS ● the establishment of NAAQS for criteria is generally determined on an AQCR basis, air pollutants, but EPA allows smaller area designations for ● the submission by each State of a State some pollutants, if that is more suitable for implementation plan (SIP) to achieve and controlling pollution. maintain Federal air quality standards, ● These AQCR designations are highly signif- the preconstruction review of major new icant. Regions that are found by EPA to be in stationary sources, and ● nonattainment status—areas where air pol- PSD. lution presents a danger to public health— National ambient air quality standards.— are subject to a particular set of restrictions Regulation under the Act focuses on six cri- under the Act. On the other hand, nondegra- teria pollutants: particulate, SO2, CO, NOX, dation regions—where air is cleaner than the

03,, and lead. Two types of ambient air quality standards—are subject to a different set of standards are designated: primary stand- regulations, which are intended for “preven- ards, which protect human health; and section of significant deterioration. ” Regardless ondary standards, which safeguard aspects of an area’s classification, almost every new of public welfare, including plant and animal major source of pollution is required to life, visibility, and buildings. The Act sets undergo a preconstruction review. forth an exact timetable by which primary standards are to be met. Secondary stand- State implementation plan.—Each State ards are to be met on a more flexible sched- must submit an implementation plan for com- ule. plying with primary and secondary standards. A State can decide how much to reduce To achieve air quality goals, areas with air existing pollution to allow for new industry cleaner than NAAQS were divided into and development. State plans must also in- Classes I, II, and III. Certain Federal areas clude an enforceable permit program for reg- that existed when the Act was passed (e.g., ulating construction or operation of any new national parks, wilderness areas) were imme- major stationary source in nonattainment diately designated as Class I areas where air areas, or significant modification to an exist- quality was to remain virtually unchanged. ing facility. New processing plants and power All others were designated as Class II—areas stations must also satisfy emission standards in which some additional air pollution and set forth in the SIP. moderate industrial growth were allowed. In- Preconstruction review of major new sta- dividual States or Indian governing bodies tionary sources.—Under the SIP, each new can redesignate some Class II areas to Class III—areas in which major industrial develop- construction project is subjected to five types ment is foreseen and contamination of the air of preconstruction review. The objective of the review process is to determine: up to one-half the level of the secondary standards would be permitted. The States or ● compliance with NAAQS and State Air Indians can also redesignate Class II areas as Quality Standards (AQS); Class 1. Either type of redesignation is subject ● compliance with any applicable NSPS; to hearings and consultations with the man- suitability for a nonattainment area; Ch. 8–Environmental Considerations ● 265

● suitability for a nondegradation area. jor stationary sources owned or oper- (PSD regulations, including the use of ated by him in the State comply with BACT and PSD increments* will apply); emission limitations. and ● ● visibility. Review in nondegradation areas. This type of review, which concerns PSD, is The major elements of these preconstruction discussed below. review procedures are:

● Review for compliance with NAAQS. The prevention of significant deteriora- The applicant must submit plans and tion.—All SIPS must specify emission limita- specifications for review that show: tions and other standards to prevent signifi- methods of operation, quantity and cant air quality deterioration in each region source of material processed, use and that cannot be classified for particulate or distribution of processed material, and SO2, or has air quality better than primary or points of emission and types and quanti- secondary NAAQS for other pollutants, or ties of contaminants emitted; a descrip- cannot be classified with regard to primary tion of the pollution control devices to be standards because of insufficient informa- used; an evaluation of effects on ambient tion. air quality and an indication of compliance with PSD restrictions; and plans Under these PSD standards, maximum al-

for emission reduction during a pollution lowable increases in concentration of SO2 alert. A permit will not be given if it is and particulate are specified for each area shown that the source will interfere with class. For the other criteria pollutants, max- the maintenance of any ambient air imum allowable concentrations for a speci- quality standard or will violate any State fied period of exposure must not exceed the air quality regulation. respective primary or secondary NAAQS, Review for compliance with NSPS. The whichever is stricter. Act directed EPA to set national standards for fossil fuel powerplants, refin- A State can redesignate a Class II or III eries, and certain other large industrial area with respect to PSD only if it follows cer- facilities. If NSPS have been established tain procedures. These include an assess- for the new source, it must be shown ment of the impacts of the redesignation, pub- that the facility will not interfere with lic notice and hearings of such a redesigna- the attainment or maintenance of any tion, and approval by EPA. standard and that BACT will be used for reducing pollution. If a facility’s construction began after Jan- ● Review in nonattainment areas. In nonattainment areas, a new facility may be uary 1, 1975, a special preconstruction re- built only if: by the time operations com- view must be undertaken if it is located in a mence total emissions from it, and other nondegradation area. To obtain a permit for new and existing sources, will be less such a facility, an applicant must demon- than the maximum allowed under SIPS; strate that it will not cause air pollution in ex- the source complies with the more strin- cess of NAAQS or PSD standards more than gent of either emission limitations re- once per year in any AQCR. BACT must be quired by the State or achieved in prac- used for all pollutants regulated by the Act, tice by such a source; and the owner or and the effects of the emissions from the fa- operator demonstrates that all other ma- cility on the ambient air quality in the areas of interest must be predicted. The air quality impacts that could be caused by any growth *In part BAC’I’ is required 10 assure that no single facility associated with the facility must also be ana- wili consume the entire PSf3 increment. lyzed.

63-898 0 - 80 - 18 266 ● An Assessment of Oil Shale Technologies

Implications of the Clean Air Act for rado’s and Wyoming’s standards. In addition Oil Shale Development to the standards shown for Wyoming, the State has also promulgated regulations to The following provisions of the Act have limit ambient concentrations of H2S, hydro- particular significance for oil shale develop- gen fluoride, and other pollutants. The stand- ment: ards are more relevant to large coal-fired powerplants than they are to oil shale proc- ● compliance with NAAQS and State AQS; essing. ● maintenance of air quality, especially visibility, in adjacent Class I areas (e.g., Since the national standards are primarily national parks); directed to urban areas, they should not seri- ● compliance with PSD increments; ously restrict oil shale development in the ● compliance with NSPS; and near future. The annual-average pollution ● the application of BACT. levels allowed by ambient standards are National Ambient Air Quality Stand- much higher than the values normally meas- ards.—Ambient air quality standards pro- ured in the oil shale development area. How- mulgated by individual States cannot be less ever, the short-term standards for particu- stringent than the national standards. Thus, late and HC are occasionally exceeded by the States set the controlling standards if natural emissions such as windblown dust there is an approved SIP. Utah’s standards and HC aerosols produced by revegetation. are identical to the national standards, while Such naturally caused infractions of NAAQS Colorado and Wyoming have set more strin- could have restricted regional development. gent standards for a number of the criteria They actually did affect oil shale development pollutants. Table 37 shows both the national schedules on the four lease tracts located in standards (the same for Utah), and Colo- Colorado and Utah. According to the provi-

table 37.–The Federal and State Ambient Air Quality Standards and Prevention of Significant Deterioration Standards That Influence Oil Shale Development (concentrations in micrograms per cubic meter)

Prevention of significant Ambient air quality standards deterioration standards

Federal (primary) Federal (secondary) Federal Pollutant human health public welfare Wyominga Colorado a Utah a (Class 1) (Class II) so, Annual arithmetic mean, . . 80 None 60 80 80 2 20 24-hour maximum ... 365 None 260 365 365 5 91 3-hour maximum ...... None 1,300 1,300 700 None 25 512 Particulates Annual geometric mean. . . . 75 60 60 45 75 5 19 24-hour maximum . . . 260 150 150 150 260 10 37

/VOX (as NO,) Annual arithmetic mean. . . . . 100 100 100 100 100 None None Oxidants (as O,) l-hour ., ., ., ... . . 240 240 160 160 240 None None co 8-hour maximum 10,000 10,000 10,000 10,000 10,000 None None l-hour maximum . . . . . 40,000 40,000 40,000 40,000 40,000 None None Lead Quarterly. 1,5 1.5 1,5 1.5 15 None None Nonmethane hydrocarbons 3-hour maximum (6-9 am). . 160b 160b 160b 160b 160b None None

astate amblen( alr ~uallly qandards are ,de”tl~al to the Federal prlrnary standards unless prlfllecl lrl llallcs The s!ncter standard IS the Conlro[llrlg standard bNot a standard, a guide 10 show achievement of o] standard cAllowable Incremental change m ambient Coflcefltratlon SOURCE Olf{ce of Technology Assessment Ch. 8–Environmental Considerations . 267

sions of the Act, the tracts and their environs Table 38.–National Standards for Prevention of were nonattainment areas. As such, they Significant Deterioration of Ambient Air Quality were not subject to any additional develop- (concentrations in micrograms per cubic meter) ment. This potential barrier was cited by Maximum allowable increase some of the tract lessees in their requests for Pollutant Averaging time Class I Class II Class Ill activity suspensions in the fall of 1976. Particulates Annual 5 19 37 24 hour 10 37 75 In December 1976, EPA ruled that new de- so, ., Annual 2 20 40 velopment could proceed in a nonattainment 24 hour 5 91 182 area if the developer would offset new emis- 3 hour 25 512 700 sions by reducing the same emissions from an aEpA IS presently developing Incremental standards tor HC CO O, NOX and pb existing source in the same area. Although SOURCE Environmental Profechon Agency Work Group Po//ufIorI Cm(m) Guidance (or 01/ Sha/e De(e/oprr?en/ Appendices 10 /he Rewsed Llraf/ EPA Clnclnna!l Ohto July 1979 p possibly applicable to urban or industrialized 0-17 areas, such a policy was not relevant to the oil shale regions because there are no substantial existing industries against which to for Class I areas could affect the siting of oil offset oil shale emissions. EPA made a subse- shale facilities. Figure 59 shows the Class I quent ruling in July of 1977 that air quality areas located near oil shale country in Col- problems arising from natural sources would orado, Utah, and Wyoming. The two Colorado not preclude oil shale development, providing areas nearest the oil shale deposits are the that facilities complied with emission and existing Flat Tops Wilderness and the proposed Dinosaur National Monument. PSD standards. The history of this ruling and its effects are discussed in detail in the Preconstruction review for oil shale facil- analysis of the Prototype Oil Shale Leasing ities.—Under the Clean Air Act, each new oil Program. (See vol. II.) shale plant must be evaluated during a pre- A second consideration is the visibility pro- construction review to determine its ability to tection afforded to Federal mandatory Class I comply with NAAQS and PSD regulations. areas under the Act. Regulations are to be Projected emission levels will be regulated by promulgated by EPA by November 1980, and EPA’s NSPS, State emission standards, and the mandated use of BACT. by the States by August 1981. These regulations may affect the siting of future oil shale At present, there are no Federal emission facilities. standards that deal specifically with oil shale Compliance with standards for PSD.—PSD operations. However, NSPS have been devel- standards exist for Class I, II, and III areas. oped for fossil-fuel-fired steam generators, The oil shale area is a Class II region, which petroleum refineries, and Refinery Claus means that some additional pollution will be Sulfur Recovery Plants. Table 39 lists the existing and proposed NSPS for these facilities allowed, but pollution up to the level of ambient air quality standards will not be accept- as a guideline to what might be considered able. EPA’s PSD standards define the max- for oil shale plants. In addition, Colorado has developed emissions standards for shale oil imum allowable increases in S02 and particulate concentrations. These standards are production and refining that limit the sum of all S02 emissions from a given facility to 0.3 shown in table 38. lb/bbl of oil produced or processed. Plants In summary, an oil shale facility will have smaller than 1,000 bbl/d are exempt. Another to meet the PSD requirements for Class II Colorado regulation limits H2S ambient con- areas, and moreover, it will not be allowed to centrations from all shale oil plants to 142 degrade air quality in nearby Class I areas micrograms per cubic meter (142 pg/m3 or 0.1 beyond the limits specified under the PSD p/m). Utah and Wyoming do not have applica- provisions of the Act. Because most pollut- ble emission limits. BACT standards have ants emitted by oil shale facilities can travel been developed by EPA for those oil shale fa- long distances, the stringent PSD increments cilities that have applied for PSD permits, as 268 . An Assessment of Oil Shale Technologies

Figure 59.— Designated Class I Areas in Oil Shale Region

WYOMING ‘ -- — --- -- —r- ~-” DAGGETT I

. MOFFAT

● GRI==STONE

VER;AL I . I I DINOSAUR . ●1 UINTAH L.. —. —.—. —. — .—. — . . .—.

GRAND i MESA ‘“;.vDELT~-’-r- & . I L . —.—. — .–.5? ( I I I . s I . —. —. — . J LEGEND: 5 ❑ GUNNISON FOREST AREAS I MONTROSE i AREA DESIGNATIONS Federal Mandatory Class I Areas: 1, 2, 3,4, 6 Colorado Class I Areas: 5, 6,8 Draft Proposed (NPS) Class I Areas: 6, 8

CLASS I AREAS 1. Flat Tops Wilderness 5. Black Canyon of the 2. Mount Zirkel Wilderness Gunnison Monument 3. Maroon Bells—Snowmass Wilderness 6. Colorado National Monument 4. West Elk Wilderness 7. Arches National Park 8. Dinosaur National Monument

SOURCE: Environmental Protection Agency Work Group, ~0//ut/orI c20~fr0/ Gwdarme /of 0// Shale ~eveloweflf Awerrdmes to (he Rev/seal Draft, U S. Environmental Protection Agency, Clnclnnatl, Ohio, July 1979, p. D.41 Ch. 8–Environmental Considerations . 269

Table 39.–National New Source Performance Standards for Several Types of Facilities’

Operation Pollutant Removal or emission standardb Status Fossil fuel fired steam generators Particulates 0.1 lb/m Btu Existing

S02, NOx 0.8 lb/m Btu for gaseous fuels; 0.3 lb/m Btu for liquid fuels

Petroleum refineries H2S 0.1 gr/scf (dry) Existing HC Floating roof tanks or vapor recovery systems if true vapor 2 pressure IS between 1,5 and 11,1 lbt/in a and reporting system only if pressure is less than 1.5 lbf/in2a

Refinery Claus sulfur recovery plants H2S 0,1 gr/scf (dry) Existing Sulfur 250 p/m SO, for oxidation systems, 300 p/m total sulfur and

10 p/m H2S for reduction systems

Gas turbines NOx 75 p/mat 15Y0 oxygen Proposed for units over 10 so, 150 p/m m/ Btu per hour Gasification plants Sulfur 99,0% removal and 250 p/m total sulfur Guideline HC 100 p/m

Field gas processing units H2S 160 p/m Proposed so, 250 p/m for oxidation systems Sulfur 300 p/m for reduction systems apre~ented ~~ ~ g“lde to what mlghl be considered for oll shale facl[llles bib, ,nza = ~ound~ ~er square Inch absolute p/m = ~er mltlron Scf = standard cubic feel cStandards tor fossil fuel fired steam generators being fevlsed SOURCE Environmental protection Agency Work Group Pol)ul/on Con/ro/ Gu@arme for OIJ Sha)e Deve/opmenl ,.lppendmes fo fhe RewseO Dra(f. EPA Clnclnnatl Oh!o July 1979 p D 34 shown in table 40. These standards specify to be promulgated, cannot be determined at levels of removal efficiency for specific this time. pollutants, and in some cases also define the maximum concentration that will be allowed in the emitted stream. Air Pollution Control Technologies In summary, oil shale facilities will have to In order to comply with the air quality laws undergo preconstruction review. BACT will and regulations, oil shale facilities will have be required for all pollutants regulated by the to control their pollutant emissions. Various Act, and plants will have to comply with am- aspects of pollutant control are discussed in bient air quality and PSD standards for Class this section. II areas. Facility siting might be affected by PSD standards in adjacent Class I areas. The ● The control technologies that can be effects of visibility standards, which have yet used to reduce emissions of particulate,

H2S, sulfur compounds, NOX, HC, and CO Table 40.–EPA Standards for Best Available Air Pollution are described, and their potential appli- Control Technologies for Oil Shale Facilitiesab cations to oil shale mining and process- . ing are discussed. Pollutant Removal requirement Maximum emissions ● The technological readiness of these Sulfur 99.0% total recovery 15 p/m H S (reduction systems) 2 techniques are evaluated. 250 p/m SO2 (oxidation systems) Particulates. 99.O% from combustion No standard ● The costs of air pollution control in com- gas streams mercial-scale oil shale plants are esti- 99 80/o from materials- handling gas streams mated. Fugitive dust control NOx Complete combustion 0.5lb/mBtu co Complete combustion No standard Technologies and Applications HC Complete combustion No standard DUST CONTROL ap m = pafls per mlllhon ~These s[andards hake been used In EPA s PSO Cleclslon process In the Pas! Water sprays. —Water sprays can be used SOURCE Enilronmenlal Proteclton Agency Work Group Po//olIon Cor?ko/ G~,dancr for 0/1 Sha/e to control fugitive dust. If adjusted properly, Lleveopmenf 4ppeoUmes to /he Rewsed Llraf! EPA Clnclnnah Ohio July 1979 p D 35 no surface runoff will result. Water sprays 270 An Assessment of Oil Shale Technologies

are about 80-percent efficient for particles probably be used for gas streams from re- larger than about 5 microns, * but less so for torts and solid heaters. smaller ones. Adding a wetting agent reduces the surface tension and improves the wetting, Baghouse filters.—Fabric filters are gen- spreading, and penetrating characteristics of erally used where higher removal efficiency the water, increasing efficiency to 90 to 98 is required for particles smaller than about percent. Chemical binders, such as latex or 10 microns. A large number of bag-shaped fil- bitumastics, can also be added. They aid in ters would be needed to clean large gas flows. particle agglomeration and also increase the In general, all of the filters would be enclosed efficiency of removal. Water sprays, with or in the same structure, called a “baghouse,” without chemical additives, are potentially and would share input and output gas mani- applicable to raw and spent shale storage folds. As a gas stream passes through the and disposal, to crushing and screening, to baghouse, dust is removed by one or more of mining and blasting, and to surface trans- the following physical phenomena: inter- portation. They could also control traffic dust section, impingement, diffusion, gravitational from temporary roads, Larger, more heavily settling, or electrostatic attraction. The ini- traveled roads would probably need to be tial filtration creates a layer of dust on the paved. bag fabric. This layer is primarily responsible Cyclones.—Cyclone separators remove for this method’s high removal efficiency; the dust by means of centrifugal force. Single cy- filter cloth serves mainly as a support struc- clones remove about 90 percent of the larger ture. The operation is very similar to that of a particles, but less than 50 percent of those household vacuum cleaner. smaller than about 10 microns. Their removal efficiencies could be increased by using sec- The efficiency of a baghouse filter depends ond-stage cleaning in scrubbers, filters, or on the particle size distribution, the particle precipitators. Cyclones will be used largely to density and chemistry, and moisture. Under clean retort gases, and possibly for primary most conditions a properly designed and op- dust control in crushers and enclosed convey- erated baghouse will achieve a removal effi- ors. ciency of at least 99 percent for particles as small as 1 micron. Baghouse filters are likely Scrubbers.— Wet scrubbers use water to to be used for dust removal from crushers, remove dust entrained in gas streams. Many screens, transfer points, and storage bins. different types of devices are available, including spray chambers, wet cyclones, me- Electrostatic precipitators.—In electro- chanical scrubbers, orifice scrubbers, ven- static precipitators, an electrical charge is in- turi scrubbers, and packed towers. High-en- duced on the surface of a dust particle and ergy venturi scrubbers are probably the only the particle is captured on a screen having type that have sufficiently high removal effi- elements with the opposite charge. Dry pre- ciencies to satisfy emissions standards. Effi- cipitators have been used for many years; ciencies between 93.6 and 99.8 percent have wet precipitators and charged droplet scrub- been achieved for particles smaller than 5 bers have been developed more recently. All microns, but these efficiencies entail high types are in common use in the electrical pressure losses and constant gas flow rates. power generating industry, in cement and Scrubbers require considerably more energy steel plants, and in many other industries. than baghouse filters or electrostatic precipi- Precipitators have removal efficiencies of up tators. Scrubbers for particulate removal will to 99.9 percent, require little maintenance, can handle large flow rates, and have low energy requirements. They might be used in sev- *A micron is one-millionth of a meter. Removal efficiencies for different particle sizes are important because effects on eral oil shale operations, including mine ven- respiration and visibility vary with the particle size. tilation and the second-stage cleaning of dust- Ch. 8–Environmental Considerations . 271

laden streams from crushers and conveyors. Claus plant (see below). Absorption processes A wet precipitator was used at the Paraho can also remove sulfur compounds, such as

demonstration plant for the combined remov- COS, CS2, mercaptans, and thiophenes, which al of shale oil vapors and particulate from cannot be processed in a Stretford unit. Be- the retort offgas. One is being used in the cause of its low cost and simplicity, the Selex- Petrosix plant in Brazil for the same purpose. 01 process is a good candidate for use in oil shale plants. HYDROGEN SULFIDE CONTROL

The systems for removing H2S that are like- Claus process.—The Claus process, which ly to be used for oil shale operations can gen- is perhaps the oldest and best known method erally remove at least 98 percent of this pol- for recovering sulfur from streams that con-

lutant. They will probably be applied to gas tain both H2S and SO2, has several variations.

streams from retorting and upgrading opera- With a feed stream containing only H2S, the

tions. required S02 is obtained by oxidizing part of

the H2S to S02 by burning it in air, and then Stretford Process.—In this process, the mixing the combustion products with the feed gas stream is scrubbed in an absorption stream. The S02 and H2S are then reacted tower with a solution containing sodium car- with each other in a series of converters to bonate, sodium metavanadate, and anthra- produce elemental sulfur, which is removed quinone disulfonic acid (ADA). Reduction of by condensation. The feed stream must have the metavanadate with H2S in solution causes a relatively high concentration of sulfur com- sulfur to precipitate. The metavanadate is re- pounds in order to achieve a high conversion generated by oxidation with the ADA, and the efficiency with reasonable equipment size. reduced ADA is then regenerated by being oxidized in an air stream. The process was This process has problems with both main- developed for coal- gas treatment, but it has tenance and downtime, thus backup units are been used for many other purposes in a num- often needed. Problems arise from sulfur con- ber of plants, especially oil refineries, in the densation in the supply and product pipe- United States and Europe. lines. The procedures for startup and shut- Any COS and CS that may also be in the down are time-consuming, and moisture and 2 CO in the feed gas are particularly trouble- gas stream would not be removed in this proc- 2 ess and their presence would interfere with some. H2S removal. Therefore, before H2S removal The tail or treated gas from a Claus plant the gas stream would need to be pretreated to still contains fairly sizable concentrations of remove these compounds. H 2S and S02. It can be recirculated, mixed Selexol and other physical absorption with a large volume of stack gas and released, or treated in other systems. In oil processes. —In these processes, H2S is dissolved in a solvent and subsequently recov- shale plants, it is likely that the Claus plant ered. The solvent is recycled. The earliest effluent would require further treatment be- process, a simple water wash, was inefficient fore being released. Processes developed specifically for this purpose include the SCOT, because H2S is not very soluble in water. Modern processes use solvents in which it is Beavon, and IFP techniques described below, more readily dissolved. SCOT (Shell Claus Offgas Treating) proc- Absorption processes are usually used for ess. In this process, the offgas is heated treating high-pressure gases and for reducing with a reducing gas such as hydrogen,

the concentrations of H2S and other sulfur and the mixture is passed through a co- compounds to extremely low levels. These bait-molybdate catalyst bed where all processes involve the selective absorption of the sulfur compounds are reduced to

H2S from gases containing CO2. This produces H2S. The gas is then sent through an ab-

an H2S-rich stream that can be processed in a sorber where the H2S is dissolved and 272 . An Assessment of Oil Shale Technologies

concentrated. The concentrated H2S is Claus plant, its control may be required. The liberated from the absorbing medium by following technologies could be used for this heating and is returned to the Claus purpose. plant. ● Wellman-Lord process. This is a versa- The SCOT process is adversely affected by high concentrations of CO . tile process, widely used by many differ- 2 ent industries, and should be adaptable Since gaseous emissions from oil shale to the oil shale industry. Colony plans to processing are expected to be rich in use it for a commercial-scale above- CO , higher rates of recycling, more com- 2 -ground retorting plant. plete fuel combustion, and perhaps This process relies on the reaction of steam injection to dissolve the CO2 may SO2 with sodium sulfate to produce sodi- be necessary. um bisulfite. The bisulfite solution is ● Beavon process. In this process, the tail next heated in an evaporator. This re- gas from a Claus plant is mixed with hot verses the reaction, liberating a concen- combustion gases and passed through a trated stream of SO2. The SO2 can then catalyst where all the sulfur compounds be converted to either elemental sulfur are converted to H S. The H S-rich gas is 2 2 or sulfuric acid. The regenerated sodium cooled by a slightly alkaline buffer solution and then treated in a Stretford unit. sulfate produced when the reaction is The Beavon process is also adversely af- reversed by heating, is dissolved and recycled. The current version of this proc- fected by high CO2 concentrations in the feed stream. Its use in oil shale plants ess is considered to be a second-generation technique for SO removal. Previous would require adaptations similar to 2 those needed for the SCOT process. problems with sludge production and scaling have been reduced. ● IFP [Institute Francais du Petrok] process. The basic reaction in this process is ● Double alkali process. Double alkali the same as in the Claus process except technology resembles conventional wet that it takes place in a liquid rather than stack-gas scrubbing methods but avoids a gaseous phase. The liquid is a polyalky- most of their problems by using two alka- lene glycol with a 5-percent concentra- line solutions, sodium hydroxide and sodium sulfite, to convert SO to sodium bi- tion of a glycol ester catalyst. Both H S 2 2 sulfite. The spent scrubber solution is re- and S02 are very soluble in this liquid, and efficient conversion to sulfur regenerated by using lime or limestone to sults. The most important operating vari- convert the bisulfite to sodium hydroxide and a precipitate that is a mixture of cal- able is the H2S to S02 ratio which must be at least 2. The process is flexible and cium sulfite and calcium sulfate. The can accommodate wide changes in con- precipitate sludge, which contains the captured S0 , can be disposed of in taminant concentrations while maintain- 2 ing constant conversion rates. Also, be- ponds. cause the gases can be treated at higher Performance of the system is well- temperatures than in other processes, established, and over 99-percent S02 reheat losses are reduced. moval has been achieved with S02 concentrations in the treated flue gas of less SULFUR DIOXIDE CONTROL than 10 p/m. Potential environmental

The amount of SO2 that will have to be re- problems are associated with waste dis- moved will depend on the prior degree of gas posal because the solid residue contains treatment and the type of fuel used in proc- soluble alkaline sodium salts that could essing. Most oil shale plants will probably use pollute surface and ground water in the desulfurized fuel for heating, processing, and vicinity of disposal sites. power generation. Where large amounts of ● Nahcolite ore process. Nahcolite is a

SO2 are emitted, such as in the tail gas of a mineral that contains 70 to 90 percent Ch. 8–Environmental Considerations 273

sodium bicarbonate. It is found in the oil the flue gas from combustion sources for par-

shale deposits in the central Piceance ticulate or SO2 will also reduce HC and CO basin of Colorado. When crushed and emissions. With proper maintenance, it will placed in contact with hot flue gases in a probably be unnecessary to further reduce

baghouse, nahcolite converts SO2 to dry emissions from these sources. sodium sulfate. Typically, 20 percent of the required nahcolite would be used to Other emissions of HC will be caused by precoat the filter bags in the baghouse, preheating raw shale prior to retorting and and the remainder would be sprayed di- by storing crude shale oil and refined prod- rectly into the flue gas stream. The sodi- ucts. Incineration is probably the only realis- um sulfate produced and any unreacted tic way to control them. Storage tank emis- nahcolite would be sent to disposal, sions can be minimized by using floating-roof Pilot-plant experiments have shown that tanks, which can accommodate higher vapor pressures than cone-roof tanks without the S02 removal efficiencies are between 50 to 80 percent depending on flow rates need for venting. through the baghouse and the ratio of OTHER EMISSIONS CONTROLS nahcolite to SO . 2 Emission control by direct flame incinera- NITROGEN OXIDES CONTROL tion systems (also called thermal combustion) Nitrogen oxides are produced in the com- is widely used to reduce the amounts of HC vapors, aerosols, and particulate in gas bustion of fuels, NOX control can be ap- proached in two ways: by adjusting combus- streams. These systems are also used to re- tion conditions to minimize NO production, move odors and reduce the opacity of plumes X from ovens, dryers, stills, cookers, and refuse or by cleaning the NOX that is produced from the stack gases, At present oil shale devel- burners. The operation consists of ducting opers plan to design combustor conditions for the process exhaust gases to a combustion chamber where direct-fired burners burn the low NOX production. Gas cleaning systems could be added in the future, if the need gases to their respective oxides. A well- designed plant flare system is a good example arises for further NOX control, However, with proper design and maintenance of combus- of direct incineration control. tion equipment, external control systems will Catalytic incineration is also used for the probably not be needed in order to comply same purpose. The chief difference is that the with existing regulations. combustion chamber is filled with a catalyst. HYDROCARBON AND CARBON MONOXIDE CONTROLS On contact with the catalyst, certain components of the process gases are oxidized. The emission of HC and CO will be caused The use of a catalyst allows more complete by the incomplete combustion of the fuel for combustion at lower temperatures, thus re- the boilers, furnaces, heaters, and diesel ducing fuel consumption and allowing the use equipment used in oil shale plants, The con- of less expensive furnace construction. How- trol of external combustion sources such as ever, catalysts are generally selective and boilers is primarily through proper design, may not destroy as many contaminants as di- operation, and maintenance. Well-designed rect flame incineration. In addition, because units emit negligible amounts of CO and only of the potential for catalyst fouling and poi- small amounts of HC. Instrumentation is soning, gas streams may need to be cleaned of needed to assure proper operating condi- smoke, particulate, heavy metals, and other tions, and comprehensive maintenance pro- catalyst poisons, grams will be needed to keep emission levels from rising due to fouling and soot buildup. Condensation is usually combined with The proper maintenance of diesel and other other air pollution control systems to reduce internal combustion engines can similarly the total pollutant load on more expensive keep HC and CO emissions very low. Treating control equipment. When used alone, conden- 274 ● An Assessment of Oil Shale Technologies

sation often requires costly refrigeration to for each regulated pollutant would depend on achieve the low temperatures needed for ade- the size of the facility; its location; the nature quate control. of the oil shale deposit; the mining, processing, and refining methods; the desired mix of Several methods can be used for cooling products and byproducts; the characteristics the gas streams. In surface condensers, the of untreated emissions streams; and the emis- coolant does not contact the vapor or condensate; condensation occurs on a wall separat- sions levels allowed by applicable environ- ing the coolant and the vapor. Most surface mental standards. The specific control equipment selected would be influenced by all of condensers are common shell-and-tube heat these factors, plus such considerations as the exchangers. The coolant normally flows through the tubes; the vapor condenses on the proximity to water and electrical power, the availability of land for solid waste disposal, cool outside tube surface as a film and is the labor and material requirements for drained away to storage or disposal. maintenance, the ease of operation, the dem- Contact condensers usually cool the vapor onstrated reliability in similar industrial situ- by spraying a liquid, at ambient temperature ations, the availability of equipment, the ex- or slightly cooler, directly into the gas stream. perience of the developer, and the cost. They also act as scrubbers in removing vapors that do not normally condense. The use An important consideration is the relative of quench water as the cooling medium re- technological readiness of each control meth- sults in a waste stream that must be con- od being considered. A developer needs confi- tained and treated before discharge. dence that a method can be directly trans- ferred to oil shale operations from other in- The equipment used for contact condensa- dustries without undergoing extensive R&D. tion includes simple spray towers, high-ve- All of the techniques described previously locity jets, and barometric condensers. Con- have been applied to industrial processes tact condensers are, in general, less expen- similar to those encountered in mining, retort- sive, more flexible, and more efficient in re- ing, and upgrading of oil shale and its prod- moving organic vapors than surface condens- ucts. However, there are three characteris- ers. On the other hand, surface condensers tics of the potential oil shale industry that re- recover marketable condensate and present quire extrapolating these technologies be- no waste disposal problem. Surface condens- yond the present levels of knowledge: the ers require more auxiliary equipment and scale of oil shale operations, the physical need more maintenance. characteristics of the shale, and the nature of Condensers have been widely used (usually the emissions streams. with additional equipment) in controlling or- Scale of operation.—The proposed mining ganic emissions from petroleum refining, pe- operations are among the largest ever con- trochemical manufacturing, drycleaning, de- ceived and as such will require extraordinary creasing, and tar dipping. Refrigerated con- efforts to control air pollution. For example, densation processes are being used for the re- underground mining on tracts U-a and U-b covery of gasoline vapors at bulk terminals would have mine ventilation rates as high as and service stations. 12 million ft3/min. Cleaning this volume of gas could be both difficult and expensive. The The Technological Readiness of Control Methods large ventilation volume is required by mining health and safety regulations and cannot be As indicated, there are a wide variety of reduced. control technologies that could be applied to the emissions streams from oil shale proc- Open pit mines could be much larger than esses. The selection of suitable technologies underground mines. Problems with fugitive for a given facility would be based on a num- dust would be increased by the larger quan- ber of factors. The degree of control needed tities of solids that must be handled on the Ch 8–Environmental Considerations ● 275

surface. Much relevant experience has been whether conventional H2S control methods gained through the extraction and processing will work well with the low H2S concentra- of other minerals such as coal, copper, ura- tions in the offgas from MIS retorting. Remov- nium, and bauxite. The simpler control tech- al efficiencies that are too low could have niques (such as water sprays) have been conflicted with EPA’s previous BACT stand- thoroughly demonstrated. However, the po- ards for oil shale facilities, which required tential size of oil shale mines may create 99-percent total sulfur recovery, no matter problems for the more complex, collection- how small the concentration of sulfur com- type control systems that have worked well in pounds in the raw gas stream. smaller mines. The cost of air pollution control for deeply buried oil shale deposits is not The technological readiness of the major known. The amount of overburden that must control techniques is summarized in table 41. be removed, and for which pollution control The readiness of dust control methods is would be needed may be prohibitively large. shown to range from low to high, with a high confidence in water sprays, cyclones, and Physical characteristics of the shale.—Oil scrubbers and a medium confidence in bag- shale is a fine sedimentary material held houses and a low to medium confidence in together by its kerogen content. When proc- electrostatic precipitators. Similar ranges essed in certain retorts (such as TOSCO II or are shown for the other control techniques,

Lurgi-Ruhrgas) the shale can disintegrate into The readiness of the nahcolite S02 removal fine particles that are more difficult to collect process is rated as low because only a few and control than other mineral dusts. Other test results have been published for its per- retorts (such as Union “B” or Paraho) will formance with oil shale streams. Also, the produce a coarser product with fewer prob- technology is relatively new and has not been lems from dust. It is uncertain whether elec- used extensively in other industries. trostatic precipitators will perform effective- ly in commercial-scale operations because The Claus H2S process is regarded highly not much is known about the electrical prop- because it has a long record of successful erties of raw and spent shale particulate. application worldwide. The SCOT and Beavon tail-gas cleaning systems have a high Characteristics of emissions streams.—To rating because they are generally used in date, the streams from small-scale versions of conjunction with the well-established Claus discrete subprocesses (such as pilot retorts) systems. The fact that the feed to these sys- have been used to obtain preliminary evalua- tems would already have been treated in a tions of the efficiencies of pollution control Claus unit removes some of the doubts about technologies. It is not known whether these the effects on their removal efficiencies of the streams accurately represent the streams unique characteristics of oil shale emissions that would have to be controlled in an inte- streams. Combustion methods and evapora- grated commercial-scale plant. For example, tion controls to reduce HC and CO emissions it is not certain that the pollutants generated also have a high rating because they should by commercial-scale retorting, when combin- not be sensitive to any great extent to the ed with the pollutant streams from other sub- scale of operation or stream characteristics. processes (such as upgrading), could be ade- Fugitive HC and CO emissions are much more quately controlled with conventional meth- difficult to control. ods. Also, the effect of volatilized trace elements on the catalysts used in the SCOT The other control techniques are given and Beavon tail-gas cleaning systems and in medium ratings either because they have not incinerators has not been determined, The been tested with oil shale streams for sus- concentration of some of the pollutants gener- tained periods or because the effects on their ated by certain processes may be too low for removal efficiencies of the projected char- efficient control. For example, it is unknown acteristics of streams from commercial-scale 276 An Assessment of Oil Shale Technologies

Table 41 .–Technological Readiness of Air Pollution Control Techniques

Pollutant and control system Readiness rating Comments Dust Water sprays High Effective and in general use with wetting agents added as needed, Low cost, Increased water needs, Road paving High Also reduces vehicle maintenance, Cyclone separators High Low cost, Effective only for large particles. Scrubbers High Low capital cost and maintenance requirements, High energy and water requirements needed for high removal efficiency. Bag house filters Medium High efficiency, Moderate energy and maintenance requirements, Low cost. Not suitable for high- temperature gas streams. Requires more area than other systems, Waste-disposal experience lacking Electrostatic precipitators Low to medium Efficiency sensitive to dust Ioading, temperature, and particle resistivity. Good removal efficiency, Low operating costs and maintenance. Good for large gas volumes. High capital cost.

H tS Stretford process Medium Extensive application in refining industry, Good for large volumes of dilute gases, Being tested for MIS gases, Selexol, purisol, rectisol, Medium Being tested for coal gasification streams, No experience with oil shale emissions, istosoliam, fluor solvent, and other physical systems Claus process High Extensive experience in several industries. Needs concentrated feed streams. High maintenance needs and downtime, Tail gas cleaning SCOT process High Long experience with Claus plants. Beavon process High Long experience with Claus plants, IFP process Medium Used with Claus plants that produce elemental sulfur May be applicable directly to retort gases, so, Wellman-Lord process Medium Thirty Installations worldwide High capital cost. High energy requirements, Double alkali process Medium Used successfully in Japan since 1973. Waste disposal could be costly, Nahcolite ore process Low Limited but successful testing to date, NOx Combustion control High Can easily be designed into new plants Low capital and operating cost, Diesel exhaust control Medium Recirculation— of exhaust gases can lead to maintenance problems. HC and CO Combustion control High Use of excess air easily accomplished, Evaporation control High Use of floating roof tanks is very effective but Increases capital costs, Control of fugitive emissions Low Control is difficult because of the large number of dispersed sources

SOURCE T C Borer and J W Hand /derr//f/ca/lon and ProDosed Conlro/ of A/r Pllufarrk kern 0// .Sha/e OoeraOons DreDared bv the Rockv Moufltaln Ow!slon The Pace ComDanv COOSUltafltS and Engineers Inc for OTA, October 1979 plants are still not known. In the case of the sign, the scale of operation, and the extent of Stretford process, work is underway by Occi- emission removal required by environmental dental Oil Shale which, if successful, could standards, Small-size, temporary plants such significantly improve its readiness. as modular demonstration facilities would probably be designed for minimum front-end In general, the control technologies appear costs; therefore, control systems with small to be fairly well-developed, and should be capital requirements would be used rather adaptable to the first generation of oil shale than those with low operating costs. The lat- plants. Full evaluation will not be possible un- ter systems would be economically attractive til the methods have been tested in commer- over the 20-year operating life of a commercial-scale operations for sustained periods. cial plant but not over the 2- to 5-year lifetime of a modular plant. The design of the plant Costs of Air Pollution Control would also have an effect on the costs of control. Systems to recover the byproducts sulfur

The costs of controlling pollutants from and NH3 could be included in an integrated an oil shale plant would be particularly sensi- facility, for example, not specifically for air tive to the lifetime of a project, the plant de- pollution reduction but to increase plant reve- Ch 8–Environmental Considerations . 277 nues. Additional control technologies would ant generation was summarized in tables 34 be needed to satisfy environmental stand- through 36,5 DRI’s hypothetical control sys- ards, but overall control costs would be con- terns were based primarily on developer siderably less than if byproducts were not re- plans but in some cases were modified to covered, cover technologies— having higher projected removal efficiencies. Two regulatory sce- Another example of the effect of facility narios were considered. Under the “less design on control costs is whether the proc- strict” scenario for particulate control in the esses of upgrading and refining are included. Colony plant, for example, it was assumed If so, other subprocesses such as retorting that particulate reductions from point could take advantage of the efficient control sources would average 98.5 percent, and that systems that are an integral part of any mod- for nonpoint sources of fugitive dust reduc- ern refinery. If refining was not done onsite, tions of 92.2 percent would be required. The control systems would still have to be pro- average particulate reduction for the plant vided for the other operations. The same de- was assumed to be 98.3 percent, Under the gree of removal efficiency could be achieved “more strict” scenario, overall particulate but with higher costs. reductions of 99.5 percent were assumed for The relation of the cost of pollutant control point and nonpoint sources. With some differ- to the degree of removal is usually not linear, ences, similar control scenarios were as- i.e., the costs generally are considerably sumed for other regulated pollutants, and for higher to increase a pollutant’s removal from the other two oil shale projects. Results of 98 to 99 percent than from 90 to 95 percent. DRI’s analysis for the “more strict” case are Consequently, most control costs will be shown in table 42. strongly influenced by the degree of removal As can be seen, the control costs for in- required by environmental standards. Higher dividual contaminants vary widely from proj- removals will be more costly for individual ect to project. In each project, however, the plants but would allow the region to accom- largest capital and operating costs are for modate a larger industry within the frame- SO and particulate removal. Capital costs work of the air quality regulations. 2 for SO2 control equipment, for example, are The Denver Research Institute (DRI) re- over $25 million for the tract C-a and C-b proj- cently estimated the costs of environmental ects, which strongly rely on MIS retorting and control in the three projects for which pollut- which will have to clean large quantities of

Table 42.–Costs of Air Pollution Control (thousand dollars)

Colony projecta Tract C-b projectb Tract C-a prolect’ Overall Capital Operating Overall Capital Operating - Overall Capital Operating reduction cost cost reduction cost cost reduction cost cost Fugitive dust 92 2% $ 1,460 $ 564 98 4% $ 1,460 $ 577 Highd $ 1,460 $ 543 Particulates 99. 5% 29,400 6,499 80.2% 5,792 1,530 99.6% 34,340 8,499 so, 99,0% 9,910 7,240 99.0% 26,210 11,187 99.0% 29,800 12,844 NO, (e) (f) (f) (e) 12,866 3,882 (e) 12,866 3,882 HC and” CO, 50.5% f 7,785 3,766 56.5% 240 50 89.0% 878 182 Total. $58,555 $18,069 $46,588 $17,226 $79,344 $25,950 Cost per bbl of daily capacity $ 1,246 $ 817 $ 979 Cost per bbl of oil produced – $ 1,16 — $ 0.91 — $ 0.97 a47 000 bbl/d of shale 011 syncrude b57 000 bbl/d of crude shale 011 c81 000 bb[/d Of crude shale 01[ dRoads are paved Water sprays used for disposal areas eMaxlmum reduction achievable through adlustmenl of combustion conditions fLCIW reducflofl requlremen!s because of low-temperature retorflng and use Of Iow-flltrogen fuel In combustors SOURCE Oata adapted from Denver Research lnshfule Pred/cfed Cosk of Enwomnerrfa/ CcJmro/s for A Commerc/a/ 01/ Sha/e /rrdus(ry Vo/urne /–Arr Engmeenrrg Arra/ys/s prepared for the Department of Energy under confract No EP 78-S-02-5107 July 1979 pp 407-414 —— ——-

278 ● An Assessment of 011 Shale Technologies dilute retort gas. A much lower capital invest- operations in each facility would be treated ment (about $10 million) is needed for the Col- in control systems similar to those for which ony project because the TOSCO II retorts pro- DRI prepared cost estimates. In the Colony duce a much smaller volume of retort gas. project, for example, it was assumed that According to DRI’s analysis, the overall dusty air streams from crushers and ore stor- costs of air pollution control range from $0.91 age areas would be processed in baghouses, (C-b project) to $1.16 (Colony project) per bbl as would the flue gas from the retort preheat- of oil produced These costs would have been er. Flue gases from the retort and the spent considered very high in the early 1970’s when shale moisturizer would be treated in a hot oil was selling for about $4/bbl. They are less precipitator. A Stretford unit would be used for removal of sulfur compounds. NO and significant under present conditions with oil X prices exceeding $30/bbl. CO emissions would be reduced by combustion controls on all burners, and HC emissions would be reduced with floating-roof storage Pollutant Emissions tanks and a thermal oxidizer flare system. Controlled emissions rates are summarized Table 46 summarizes the rates of pollutant in tables 43 through 45 for three oil shale emissions both for the three projects, and for projects for which pollutant generation rates modular demonstration projects proposed by were calculated previously. It was assumed Union Oil Co. and Superior Oil. The Union and that the raw emissions streams from the unit Superior results are presented for their ac-

Table 43.–Pollutants Emitted by the Colony Development Project (pounds per hour)a

Operation Particulate so, NOx HC co b b Mining ., ., ., . . ., ., ... . . 10 0 250b 50 440 Shale preparation, ., ., 60 0 0 0 0 Retorting, . . ., . 120 140 1,430 270 50 Spent shale treatment and disposal” ~ ~ ~ . ~ ~ 40 0 130b 10b o Upgrading. ., . . ., ., . . ., . trace 10 20 10 trace Ammonia and sulfur recovery ... o 100 0 0 0 Product storage 0 0 0 20 0 Steam and power. ~ ~ ~ ~ ~ ~ ~ ~ . . . 0 trace 20 trace trace Hydrogen production ., 10 30 80 trace 10 Total ., ., ... 240 280 1,930 360 500 +

aR~~m.and.pillar Mlnlng TIJSCO II retorftng scaled to 50000 bbl/d of shale oll syncrude production bThese emissions are not included 10 Colony PSO permlf aPPllcatlOn SOURCE T C Borer and J W Hand /defrf/f/ca(/on and Proposed Con/ro/ of AM Pollufarrfs From 0(/ Shale Operations prepared by the Rocky Mountain Owlsion, The Pace Company Consultants and Eng[neers Inc for OTA October 1979

Table 44.–Pollutants Emitted by the Rio Blanco Project on Tract C-a (pounds per hour)a

Operation Particulate so, NOx HC co Mining ., . ., 20 0 340 6 435 Shale preparation. ., . ., . . . 26 0 0 0 0 Retorting. ., 92 52 320 98 0 Spent shale treatment and disposal’ ~ ~ ~ ~ ~ 32 0 0 0 0 Upgrading. ., ., ., ., ., 6 0 6 13 0 Ammonia and sulfur recovery, ... ., . 0 0 0 0 0 Product storage. ., 0 0 0 105 0 Steam and power ., ., . . . ~ 210 250 1,220 13 0 Hydrogen production ., ., – — — — — Total ., ., ., . . ., ., ... - 386 302 1,886 235 435

auflde@~Ound Mlnlng M [s and Tosco II abovegfound retorting scaled 1050,000bblld of shale oil Swcrude woduchofl SOURCE T C Borer and J W Hand. /derrf/l/ca(/orr and %oposed Confro/ O( AM f’o//ufanfs from 0// S/ra/e Opera(/errs, prepared by the Rocky Mountain Owlslon The Pace Company Consultants and Engineers Inc for OTA October 1979 Ch. 8–Environmental Considerations ● 279

Table 45.–Pollutants Emitted by the Occidental Operation on Tract C-b (pounds per hour)a

Operation Particulate so, NOx HC co Mining 20 0 300 10 180 Raw shale disposal 80 0 100 10 0 Retorting, 10 0 0 0 0 Upgrading 10 10 80 trace 10 Ammonia and sulfur recovery. 0 240 0 0 0 Product storage 0 0 0 80 0 Steam and power 20 trace 2,800 b o 0 Hydrogen production 80 20 220 20 20 Total 220 270 3,500 120 210

a Underground mlnlng MIS retofilng scaled 1050000 bbl d of shale 011 syncrude production bAssumes gas turbines for power generation SOURCE T C Borer and J W Hand (der?hflcallon and Proposed Cofl(ro/ of AU Po//uranrs from 0// Shale Operal/ons prepared by the Rocky Mountain Dlvlslon The Pace Company Consultants and Engineers lnc for OTA October 1979

Table 46.–A Summary of Emissions Rates From Five Proposed Oil Shale Projects

Pollutant emissions, lb/hr

Project and retortinq technology Shale oil production Particulates SO2 NOx HC co Colony TOSCO I I aboveground retort 50,000 bbl/d syncrude 240 280 1,930 360 500 Rio Blanco MIS plus Lurgi-Ruhrgas aboveground retort 50,000 bbl/d syncrude 386 302 1,886 235 435 Occidental MIS 50,000 bbl/d syncrude 220 270 3,500 120 210 Superior Superior retort plus nahcolite and alumina recovery 11,500 bbl/d crude 75 347 172 20 47 Union Union Oil ‘ ‘B’ aboveground retort 9,000 bbl/d crude 35 81 100 59 43

SOURCE T C Borer and J W Hand /deflflf/cat/on and ProDosed ConVo/ ot AK Pol/u(an(s From 0// Sha/e Operations prepared by the Rocky Mounlain Olvlslon The pace Company Consultants and Enav neers Inc for OTA October 1979 tual design conditions, which provide about granted for modular-scale operations on C-a one-fifth of the shale oil produced by the (1,000 bbl/d) and C-b (5,000 bbl/d). EPA there- other projects. Because emissions rates are fore expects the projected emissions rates at not always directly related to plant capacity, these production levels to comply with all ap- the much smaller modular projects are not plicable Federal and State emissions regula- expected to have equivalently lower rates of tions. However, it should be noted that the emissions. In fact, S02 release from the evaluation of the environmental impacts of oil Superior project (11,500 bbl/d) is expected to shale development also requires a considera- be significantly higher than from the three tion of the effects of the emitted pollutants on 50,000-bbl/d projects. In part, the high rate of ambient air quality, which is protected by Superior’s emissions is related to the nature NAAQS and PSD limitations. Without large- of its process, which includes unique sub- scale operating facilities, the effects of emis- processes for the recovery of nahcolite and sions on air quality can only be predicted by alumina. They also arise from the scale of using mathematical models. operation, which does not encourage the use of large-scale, costly controls that would be cost-effective for the larger operations at Col- Dispersion Modeling ony and on the lease tracts. The Nature of Dispersion Models EPA has granted PSD permits for the Col- ony and Union projects at the levels of opera- The Clean Air Act, through the regulations tion listed above. Permits have also been promulgated for attainment of NAAQS and -——

280 ● An Assessment of Oil Shale Technologies

PSD standards, requires the use of mathe- flow near prominent terrain features, but can matical models to relate the emissions from a usually ignore chemical reaction, aerosol source and the resulting incremental impact coagulation, deposition, and visibility effects, that the source causes on a point some dis- which generally become most significant over tance away. At present, models are EPA’s larger distances and longer time periods. In tool for enforcing the provisions of the Act contrast, regional models can sometimes ig- and are the only means for predicting long- nore terrain features, but must consider long- range impacts of oil shale emissions on am- range atmospheric conditions and their ef- bient air quality in the oil shale area and in fects on chemical reaction, coagulation, depo- neighboring regions. sition, and visibility. Air quality models are mathematical de- A key feature that must be considered in scriptions of the physical and chemical proc- evaluating the use of any model to estimate esses of transport, diffusion, and transforma- compliance with NAAQS and PSD regulation that affect pollutants emitted into the at- tions is its ability to simulate worst case con- mosphere. In these models, specified emis- ditions, which are those meteorological condi- sions rates and atmospheric parameters are tions that lead to the highest ground-level con- used as input data, and the effects on ground- centrations. These conditions vary depending level pollutant concentration and visibility of on the location of the emitting facility, its con- plume rise, dispersion, chemical reaction, figuration, and the nature of the surrounding and deposition are simulated. Some models terrain. Some candidate worst case condi- are designed to simulate small-scale airflow tions for the oil shale region include: patterns over complex terrain within a few ● several days of atmospheric stagnation miles of the pollution source. These near- during which emissions would accumu- source models can predict the effects of oil late under an inversion in a valley; shale emissions in the immediate vicinity of the plant. They are used during preconstruc- ● a looping stack-gas plume that would tion review to indicate the facility’s expected bring maximum pollutant concentrations compliance with PSD regulations. directly to ground level; ● Other models simulate broader airflow a plume trapped in a stable atmospheric behavior over distances of hundreds of miles. layer and transported essentially intact These regional dispersion models could be to nearby high terrain; used to simulate the effects on a large area of ● fumigation, when a plume is transported an entire industry, including numerous indi- from a stable layer at medium heights to vidual plants. Regional-scale models can be the ground level. (Fumigation conditions used to predict impacts on air quality in near- normally persist for less than an hour. by Class I areas. The time scale of the input They are usually the worst case for data and the output predictions should be ap- emissions released from stacks); and propriate to the size of the region being simu- ● moderate wind conditions in which a lated. Small increments can be used for near- stable polluted layer spreads uniformly source modeling; increments of several days and causes visibility reduction over a for regional dispersion models. large area. (This is usually the worst Most models incorporate a series of com- case for emissions released near ground putational modules, as shown in figure 60. A level.) major difference between the models lies in It is reasonable to assume that some worst the manner in which the input data are ma- case conditions (e. g., several days of atmos- nipulated and in the application of the com- pheric stagnation) could occur several times putational modules. Usually, not all of the a year, while others might occur only a few modules are used in any given model. Near- times over the lifetime of an oil shale project source models need to simulate complex air and might not be detected during a 1- to 3- Ch 8–Environmental Considerations 281

Figure 60.—Computation Modules in Atmospheric creasing altitude. Their mathematical ex- Dispersion Models pressions are relatively simple, and can often ‘m’ss’””ra’es~ be run on a hand calculator. However, most Background Gaussian models rely on straight-line simula- Plume rise w module tion of pollutant trajectories and do not con- Source characteristics sider spatial, temporal, and vertical vari- Atmospheric conditions ! ations in atmospheric conditions. As a result * t Dispersion Wmdfleld and other meteorological they tend to overestimate ground-level pollut- data + :%?: ant concentrations at distances greater than II 1 I 30 miles from the source. +, Reaction kmetlcs Chemical reaction Numerical or non-Gaussian models such as module Pollutant characteristics grid models are more useful for simulating $ I I I near-source complexities. They estimate pol- I lutant concentrations at each point in a three- dimensional pattern overlying the region of interest. For detailed computations and high accuracy, the spacing of the grid points must

Aerosol coagulation be small and the time interval between suc- I mcdule I cessive iterations must be short. Because of these characteristics and due to the complex t mathematical manipulations used, grid mod- Airborne concentration module els require the use of high-speed computers, and input data must include highly detailed

1 i wind field information. Such information is Visibility module Deposition usually not easily obtainable without a very lwocass (wet & dry) expensive atmospheric monitoring program. module Grid models can also be used for simulat- YGROUND ing long-range effects over a large region if SOURCE E G Walther, et al The Eva/uaf/on of AI{ Oua//fy CJ/spers/on Mode/ /rrg for 01/ Sfra/e Deve/opmerrt prepared for OTA by the John Mu Ir ln - information is available on conditions in the stltute for Environmental Studies, Inc October 1979 upper atmosphere. In these applications, terrain details usually become less important. Complex terrain features, which must be ac- year environmental monitoring program prior curately simulated in near-source modeling, to the start of constructing a project, can be simulated through use of an average Gaussian models* and grid models are roughness factor. However, because of the commonly used to simulate near-source dis- longer timespan being modeled, slow chemi- persion effects. Gaussian models were devel- cal reactions that involve, for example, SO2 oped for the relatively simple air flow pat- and NOX, become significant. Aerosol size terns over flat terrain. They can be modified, distribution (critical in visibility analysis) and with a significant loss of accuracy, to simu- the contributions of other polluting sources late complex flow around terrain obstacles, are also important. and up and down valley floors. They can A critical problem in applying regional simulate some worst-case conditions, such as models is caused by the fact that pollutants very low wind speeds, but not looping plumes pass through several meteorological regimes or variations in wind direction with in- on their path from source to deposition point. *A Gaussian model is based on a theoretical pattern of fre- Budget models, which divide the affected re- quency dlstrihution in which a bell-shaped (or normal) curve gion into discrete air cells, can be useful shows the d is! ribu lion of probabi]i ty associated with different Isues of a va riahle quantit y— in this case pollutant concentra- under these circumstances because they deal tions. only with the flow of air into and out of one

63-898 0 - 8CI - 19 282 ● An Assessment of Oil Shale Technologies cell and with the reactions that occur within photochemical reactions between HC and the cell. If the cell size or iteration increment NOX. * Thus, the conventional set of reactions is too large, important details such as rapid used to model urban photochemistry would deposition in transition areas between low- have to be augmented to accurately simulate lands and mountains may be missed. These the oil shale situation. deficiencies can be compensated for by using Also, oil shale operations emit much fugi- time trajectory models, numerical fluid flow tive dust. Proper modeling of these emissions models, box models, or sector average must consider the role of wind in creating the models. emissions as well as its role in dispersing them. In the mountainous areas downwind of Problems With Dispersion Modeling in oil shale plants, precipitation may cause the the Oil Shale Region wet deposition of the oil shale emission, thus lessening the regional transport of visibility Modeling of oil shale facilities presents a impacts but increasing impacts on ground- number of problems because of the topogra- level ecological systems. phy and meteorology of the oil shale region, the chemistry of oil shale emissions, and the Another problem in developing accurate unknown quantities of emissions expected dispersion predictions for oil shale facilities from commercial-size facilities. Dispersion is the fact that the input data on emissions models developed to date have been primarily can only be estimated, since no commercial- for flat terrain. The terrain of the oil shale ize plants have yet been built. This problem region is very complex, including many val- is exemplified in table 47, which presents a leys and canyons. Furthermore, some devel- summary of emissions data used in several opers have proposed siting their plants in the early modeling studies. These studies varied middle of a cliff face or near a canyon rim. widely with respect to the quantities of the Simulating this geometry presents unique emissions that were assumed for various modeling problems. In addition, the chemistry types of retorting technologies and the levels of oil shale emissions is quite different from that of powerplants in urban areas and may *Photochemical reactions are induced in the atmosphere by lead to increased oxidant formation through u] traviolet radiation from the Sun.

Table 47.–A Comparison of Atmospheric Emissions Used in Modeling Studies

Total emissions (lb/hr) Production capacity Study and site Retort (bbl/day) Study date so* NOx HC Particulates Battelle Colorado TOSCO II 50,000 1973 143 732 300 1,285 Federal Energy Administration Colorado TOSCO II 50,000 1974 1,332 1,464 317 741 Stanford Research Institute Colorado and Utah TOSCO II 100.000 1975 3,111 4,078 600 650 Colony Colorado TOSCO II 63,000 1975 282 1,806 324 829 317 1,746 304 842 Tract C-b Colorado TOSCO II 45,000 1976 267 1,634 262 776 353 1,894 313 968 Tract C-a Colorado TOSCO II 6,000 1976 26 322 112 148 56,000 265 994 185 573 Tracts U-a and U-b Utah Paraho 10,000 1976 8.4 108 0.88 68 50,000 148 1,369 55 452

SOURCE Adapled from the Enwronmenlal Prolectlon Agency A f’relvmrrary Assessmertrof fhe Env/ronrnerUa/ hnpacfs from (7// .Sha/e L7eve/oprnenfs July 1977 p 110 Ch. 8–Environmental Considerations 283 of production, Even if the estimates for the cluding completely different retorting tech- TOSCO II operations are scaled to the same nologies and levels of operations. As noted in production capacity, they vary by as much as volume II, the tract C-a lessees originally con- an order of magnitude. Much of this discrep- templated open pit mining and aboveground ancy is associated with assumptions by ana- retorting in a combination of TOSCO II and lysts about environmental-control technol- directly heated retorts (like the Paraho kiln). ogies and their efficiencies, Although individ- In phase I, a single TOSCO II retort would be ual modeling runs provide some insight into used to produce from 4,500 to 9,000 bbl/d of site-specific air quality effects for a given shale oil. In phase II, several TOSCO II and retort capacity under specific meteorological directly heated retorts would be used to pro- conditions, substantial variations in the induce up to 55,800 bbl/d. The lessees con- put-data assumptions prohibit comparing dif- ducted modeling studies that estimated the ferent retorts, levels of development, and air quality impacts of each development plant locations, phase. Both long- and short-term effects were studied with an EPA Gaussian Valley model, The Application of Dispersion Models to modified to account for the mixing-layer ef- Oil Shale Facilities fects of rough terrain and for inversion epi- sodes. Results were reported in the DDP in The application of flat-terrain models to March 1976.’ the oil shale region requires many adaptations in order to provide rough estimates of The lessees subsequently adopted a new the impacts of a particular facility on am- plan that was also phased but which involved bient air quality. Near-source models have underground mining and MIS processing. The been used to estimate the effects of emissions lessees prepared a revised DDP and per- from single proposed facilities. Such effects formed new modeling studies. Two mathe- must be modeled to qualify for a PSD permit matical models were used: long-term (annual) from EPA. A preliminary study has also been effects were studied with an EPA model modi- undertaken by EPA to estimate the regional fied for high terrain and atmospheric stabil- effects of several oil shale plants. Since only ity; shorter term (3 to 24 hours) effects were estimates are available for the levels of emis- studied with a modified Gaussian model. As sions from commercial-size facilities, model- in the earlier modeling studies, meteorologi- ing results can only be considered approx- cal measurements made on the tract were ima te, used as input data to the models. Worst case predictions for both phases were reported in One example of the use of near-source the revised DDP in May 1977.9 models was a study performed for Colony De- velopment by Battelle Northwest Laborato- The results of both sets of studies are re- ries. Colony was considering two plant loca- ported in table 48. Predictions are presented tions: one in the valley of Parachute Creek, for both offtract ambient air quality and for the other on an adjacent site atop Roan Pla- the incremental quality degradation. Also shown are the relevant NAAQS (either pri- teau. A model predicted that NOX concentrations near the valley site would exceed the mary or secondary, depending on which is more stringent), the Federal PSD increment national standards; SO2 and particulate would barely meet the standards. The model limitations, and the corresponding Colorado predicted that the corresponding pollution ambient air standards. All standards shown levels near the plateau site would be an order are those that currently apply to the oil shale of magnitude lower. Because of this predic- region. tion, Colony selected the plateau location.67 The models predicted that both phases of Another example is the work undertaken both plans should be in compliance with ap- for Federal lease tract C-a. Models were run plicable standards, However, the off tract for widely different operating conditions, in- concentration of nonmethane HC was pre- . —

284 . An Assessment of Oil Shale Technologies

Table 48.–Modeling Results for Federal Oil Shale Lease Tract C-a

Revised DDP (May 1977) Original DDP(March 1976)

National standards Colorado standards Ofttract ambient air Offtract increment Otftract ambient air Ofttract increment b c b c d e d e Averag- PSO increment Ambient PSD Increment Phase l Phase II Phase l Phase II Phase l Phase II Phase I Phase II a Pollutant ing time NAAQS Class II Air Category II MIS MIS/TOSCO II MIS MIS/TOSCO II TOSCO II Aboveground TOSCO II Aboveground

So2 Annual 80 20 80 20 84 8 32 27 10 11 1 2 24-hour 365 365 91 102 8 5 3 23 28 14 19 3-hour 1,300 512 700 512 352 25 30 20 91 103 82 94

NOX Annual 100 None 100 None 8 13 6 11 16 10 14 8 Particulates Annual 60 19 45 19 9 12 03 3 16 22 10 24-hour 150 37 150 37 10 12 1 3 34 41 22 29 Nonmethane HCf 3-hour 160 None 160 None 65 90 0.3 25 221 129 156 64 Lead Quarterly 15 None 15 None — — — — — — — — o, l-hour 240 None 160 None — — — — — — — —

aslrlcter Ot primary and secondary standards bcapacll 4000 bbl/d (MIS) ccapaclty 57000 bbl/d (MIS) + 19.000 (TOSCO 11) dcapaclty 9000 bbl/d (TOSCO l{) ecapaclly 55800 bbl/d (TOSCO II and. e 9 ~ paraho) \Not a standard a guide to show achievement of the O, standard SOURCE Data adapted from onglnal and revised detaded development plan for tract C.a See refs 8-9 dieted to exceed the Federal and State guide- particulate, and nonmethane HC and lower lines during Phase I of the old plan. It should levels of NOX than the revised concept (un- also be noted that in the old plan the off tract derground mining, MIS, and limited above- increment for HC is only slightly less than the -ground retorting). Although the revised facil- 3-hour average guideline. In the new plan, ity is to have 36 percent more shale oil capac- however, offsite concentrations and incre- ity, ambient air impacts and PSD increments ments for both phases are well within compli- are generally lower. ance. With respect to regional modeling, EPA has With respect to the effect of scale of opera- used a modified Gaussian model to predict tion, the table indicates that, in general, the the effects on air quality at the Flat Tops impact of the smaller scale phases of both Wilderness Area of oil shale operations at the plans are nearly equal to those of the corre- Colony site (50,000 bbl/d), on tract C-a (1,000 sponding larger scale phases. This is ex- bbl/d), on tract C-b (5,000 bbl/d), and at the plained by the lessees’ intent to use the first Union site (9,000 bbl/d). * The total shale oil phase of each plan to obtain reliable data on production was about 65,000 bbl/d, of which emissions levels and dispersion characteris- about 77 percent was assumed to come from tics, and then to use these data to design con- Colony’s TOSCO II retorts. The model was trol technologies for the subsequent commer- limited in that only one source could be mod- cial phases. Also, final commitment to the eled at a time, so four runs were needed to commercial operations was not to be made model the industry. In each run it was as- until technical and economic feasibility stud- sumed that the wind was blowing from the ies, based on operating data obtained in the source directly to Flat Tops. The cumulative early phases, could be completed. To avoid impacts of the industry were estimated by unnecessary capital commitment in the initial adding the increments from each source. Re- phases, the first facilities were designed for sults indicated that about 20 percent of the minimum investment requirements. PSD increment for particulate would be con-

sumed, and about one-third of the S02 incre- It is difficult to interpret the technology- ment. Simple linear scaling would indicate related effects of old and new plans for tract that the industry would be limited to about C-a because the levels of operation are dif- 217,OOO bbl/d by the PSD restrictions on S0 , ferent, and different models were used to 2 and to about 325,000 bbl/d by the particulate simulate air quality impacts. However, a PSD. qualitative comparison is possible. The table indicates that the original concept (open pit *Flat Tops Wilderness Area is approximately 65 miles from mining and aboveground retorting) would tract C-a, and 50 miles from tract C-b and the proposed Colony have caused higher ambient levels of SO2, and Union projects. Ch. 8–Environmental Considerations 285

Such scaling is highly inaccurate for a the exception of the Colony project, only number of reasons. First, Gaussian models small-scale plants were modeled. Some devel- tend to overestimate ground-level concentra- opers, such as Rio Blanco and the tract C-b tions of SO2, because they do not allow for for- lessees, have also modeled the effects of com- mation of sulfate particles from S02 and their mercial-scale operations at the same loca- subsequent deposition. Second, it is impossi- tions. However, EPA has not yet evaluated ble for the wind to be blowing from four di- the results of these studies for adequacy rections at the same time. Third, the pro- under the PSD-permitting process. jected SO2 and particulate concentrations at Flat Tops were affected strongly by the Col- ony project, which is predicted to emit more The widespread reliance on the Gaussian Valley model should also be noted. All of the SO2 and particulate than the technologies proposed by tract C-a, tract C-b, and Union. It developers relied on this model for simulation was EPA’s opinion that a better estimate of near-source effects. PSD permits were would be that as much as 400,000 bbl/d could granted for the projects because the models be accommodated in the Piceance basin by represented the state-of-the-art of near- the PSD standards for Flat Tops.10 EPA’s source dispersion, and because most of the analysis did not consider any project in the projects were of relatively small scale. The Uinta basin, the eastern edge of which is models used are deficient in many respects. about 95 miles from Flat Tops. Therefore, For example, the Gaussian Valley model can there are no estimates available of the addi- be used for estimating pollutant dispersion in tional capacity that could be installed in Utah stable atmospheric conditions in complex ter- without exceeding the PSD restrictions at rain, However, as described previously, it tends to overestimate SO concentrations and Flat Tops. The proposed Dinosaur National 2 Monument, about 50 miles north of tracts U-a cannot handle most worst-case conditions. and U-b, could also limit operations in Utah if Also, Gaussian models when applied to com- it is designated as a Class I area. * plex terrain introduce error by a factor of 5 to 10 when computing concentrations on high- terrain features. This factor of error in the Evaluation of Modeling Efforts model’s capability, coupled with a 2 to 5 error Table 49 lists the models used by oil shale factor in estimating emission concentration, developers to support PSD applications for increases the level of uncertainty in deter- their projects. EPA has accepted the results mining compliance with air quality stand- of these studies as evidence of expected com- ards. In a recent workshop conducted by the pliance with air quality regulations, and PSD National Commission on Air Quality, it was permits have been granted. Note that, with recommended that the Valley model be used only for screening purposes in complex terrain situations, and that it not be used for de- *A Department of the Interior task force in September 1979 recommended Iha t the Dinosaur Nntional N!onument be desig- termination of compliance with NAAQS or na led as a Class I n rcn. PSD standards. ’

Table 49.–Models Used in Support of PSD Applications for Oil Shale Projects — Maximum shale Project Retorting technology 011 production Model used Colony Development Operation TOSCO II 46,000 bbl/d Gaussian Valley model, modified for rough terrain, to study effects of long-distance transport. Box model for effects of trapping inversions near source. Union 011 Co Long Ridge Union ‘‘B’ 9,000 bbl/d Modified Gaussian Valley model. RIO Blanco 011 Shale (tract C-a) Modular MIS 1,000 bbl/d Modified Gaussian Valley model C-b Shale 011 Venture (tract C-b) Modular MIS 5,000 bbl/d Modified Gaussian Valley model Occidental 011 Shale Inc Logan Wash Modular MIS 5,000 bbl/d Modified Gaussian Valley model

SOURCE Ofllce of Technology Assessment 286 ● An Assessment of Oil Shale Technologies

Other models that have been used to pre- ity, near-source effects and more distant dict emissions from proposed oil shale facil- impacts could be modeled simultane- ities include the CRSTER and the AQPUF2. * ously. The CRSTER model is generally used by EPA ● Chemical reaction and deposition mod- to simulate effects of emissions from tall ules should be included wherever the stacks in complex terrain. It tends to overesti- modeled region is large enough for these mate pollutant concentrations where plumes effects to be significant. are intercepted by terrain features higher ● A simulation of photochemical oxidant

than the plume rise height, ” The CRSTER formation and of the conversion of SO2 to model used by Rio Blanco in their DDP could sulfates should be combined in the same not handle fugitive dust emissions, gravita- model. tional settling, separated stacks, chemical reactions in the plume, some high-terrain More specific research needs can be iden- features, and a change of wind direction with tified for the oil shale region. The models used height. All of these variables are important to to date have given only rough estimates of the accurate prediction of some near-source ef- impacts of oil shale development on ambient fects. The AQPUF2 model also used by Rio air quality. Because the models are only ap- Blanco in their DDP for short-term studies proximations, they cannot provide definitive was better able to simulate plume behavior in answers to crucial air quality questions. No complex wind fields and to compare the ef- commercial-scale oil shale facilities exist that fects of emitting stacks a significant distance could supply the data for verification. Fur- apart from each other. The effect of wind thermore, essential information is lacking on speed on the generation of fugitive emissions meteorological conditions in locations other was not simulated in any of the models used. than in the immediate vicinities of some of the proposed development sites. Research and Development Needs The models themselves need to be improved for the oil shale region. Near-source The problems of modeling pollutant disper- models need to be modified to better simulate sion in the oil shale area are also encountered chemical reaction, coagulation, deposition, in other regions with complex terrain, such and visibility effects of oil shale plumes dur- as the Ohio River Valley and the Four Corners ing stagnation periods. Models are also need- area of Colorado, Utah, Arizona, and New ed that can simulate the effects that several Mexico. The Dispersion Modeling Panel at a facilities would have on air quality in a small recent workshop conducted by the National area having complex terrain. This capability Commission on Air Quality recommended the will be critical in evaluating the effects of following research on the modeling of atmos- ] second-generation oil shale plants. A good pheric dispersion in such areas: ] site for analysis would be the southeastern . Regional models should be developed corner of the Piceance basin. PSD permits that can simulate effects at long dis- have already been issued for three projects in this area, which contains much of the private- tances from the sources, For SO2, these distances could approach 600 miles. Up- ly owned oil shale land in Colorado. More ap- wind pollutant concentrations should be plications may be submitted in the near fu- determined and used as input data to the ture. Models are also needed that can simu- models. late the effects of wind rate on generation ● The regional models should allow the use and transportation of fugitive dust from stor- of a fine-resolution grid spacing near the age and disposal areas. pollution sources, and a coarse spacing Many of these improvements also are at greater distances. Given this capabil- needed by regional dispersion models. In par- *CRSrI’ER is a Gaussian model developed by EPA, AQPUF2 is ticular, existing models should be modified to a segmented-plume Gaussian rough-terrain model, simulate long-range visibility effects of oil Ch 8–Environmental Considerations ● 287 shale plumes. This capability will be required The state-of-the-art of near-source and re- to respond to the forthcoming visibility reg- gional dispersion modeling is being advanced ulations. Visibility models exist that deal with by R&D programs under the sponsorship of the formation of aerosols and particulate EPA and other organizations. The following from SO2 and NOX, but these models are ap- projects are of particular importance to eval- plicable to examinations of urban smog and uating the air quality impacts of oil shale powerplant emissions. Greater emphasis plants. would have to be given to HC reactions in order to modify these models to simulate oil EPA is funding a project with DRI to shale plume effects. combine information on oil shale emissions and meteorology, and to use region- The need to model the cumulative impacts al models to assess air impacts from sev- on regional air quality is particularly impor- eral commercial-size oil shale facilities. tant. Each scenario should include specifica- The model will also handle emissions tions for the locations of oil shale plants, a from other sources such as traffic, pow- characterization of their pollution control erplants, and other mineral-processing technologies, and estimates of their emissions plants. rates. The region’s meteorology would have to EPA is funding a project with the Univer- be accurately characterized over periods of sity of Minnesota to develop a simple several days, or for at least the time required model of aerosol dynamics, including for the full impact of the combined emissions conversion of gases to aerosols, that may to be experienced in nearby Class I areas. be of use in evaluating the effects of the Computational modules would have to be in- chemistry of oil shale plumes on visibili- cluded for the effects of emissions, disper- ty. sion, aerosol dynamics, chemical reaction, Los Alamos Scientific Laboratory is deposition, and visibility, The model also funding a project with the John Muir In- should handle differences between daytime stitute for Environmental Studies to de- and nighttime mixing heights and atmos- velop a multiple-source visibility model pheric chemistry, In addition, the regional that could be applied to regional disper- models would have to be validated, either sion studies in the oil shale area. In a through tracer studies in the oil shale region related study, the University of Wyoming itself or by examining the ability of the model and Los Alamos are funding a project to to simulate the behavior of emissions from a develop a regional haze model which group of coal-fired powerplants or smelters. might be useful in assessing visibility ef- One type of tracer study that could be used fects of oil shale plumes. to validate the models is the release of sulfur EPA is funding an in-house project at Re- hexafluoride, or a similar tracer compound, search Triangle Park to develop a multi- followed by the monitoring of tracer concen- ple-layer atmospheric model that is de- trations at numerous ground-level locations. signed to explain regional O3 patterns in A dense pattern of monitoring stations would the Northeast. It may also be useful for be needed to locate maximum concentrations, explaining the high O3 concentrations because the widely varying wind patterns in encountered in the oil shale area. the oil shale region prevent any attempt to EPA is funding a project with Systems characterize total wind fields by interpolat- Applications, Inc., to model the air quali- ing data from a few stations. Baseline meas- ty effects of oil shale industries with urements of pollutant concentrations and vis- capacities of 400,000 bbl/d (including ibility parameters upwind from the source tract C-a, tract C-b, Colony, Union, Supe- would be required to accurately simulate the rior, tract U-a, and tract U-b) and 1 mil- chemical interactions of the tracer plumes. lion bbl/d. The model will handle all 288 ● An Assessment of 011 Shale Technologies

sources simultaneously and will model suggested R&D responses are summarized in visibility effects. The project is designed table 50. Some of the uncertainties, such as as an extension to EPA’s early regional dispersion behavior, could be reduced some- modeling exercise. Its major objective is what by means of laboratory studies and to estimate cumulative impacts on exist- computer simulations; others, such as the ing and proposed Class I areas such as performance characteristics of control tech- Flat Tops. nologies, may necessitate full-size facilities and extended programs under actual operating conditions. It is important that emissions A Summary of Issues and Policy Options studies and monitoring and modeling pro- Issues grams keep pace with oil shale development. LIMITS ON OIL SHALE DEVELOPMENT INADEQUATE INFORMATION The atmosphere has a finite carrying ca- Extensive work has been undertaken in the pacity; that is, it can only disperse limited public and private sectors to determine the quantities of airborne pollutants. The effect degree of pollution control that will have to be of the carrying capacity of air in the oil shale used by oil shale facilities to protect air quali- region on the long-term development potential ty. However, no large-scale facilities exist to of oil shale resources is unknown. A crude re- verify the predictions arising from this work. gional modeling study undertaken by EPA has Furthermore, the dispersion characteristics indicated that an industry of 200,000 to of treated emissions streams cannot be accu- 400,000 bbl/d could probably be controlled to rately predicted because modeling and moni- meet PSD regulations in the Piceance basin. It toring methods are not yet adequate. In its is unclear whether a larger industry (the present state of development, modeling can order of 1 million bbl/d) could be established be used, but the results must be carefully in- in the Piceance and Uinta basins without vio- terpreted. Therefore, it is not known what im- lating air quality regulations. pacts oil shale unit operations will have on air quality at various shale oil production lev- Additional questions arise regarding the els. Specific areas of uncertainty and some manner in which PSD increments will be allo-

Table 50.–Areas of Inadequate Information and Suggested R&D Responses

Area of uncertainty Relevance Research need Baseline air quality conditions and Inhibits accurate modeling of emis- Regional characterization studies, including measurement of visibility and meteorological characteristics sions dispersion and deposition concentrations of criteria and noncriteria pollutants and determination of meteorology, especially with respect to worst case conditions. Emissions characteristics Prevents evaluation of control effec- Characterization of stream and fugltive emissions, beginning with pilot-plant tiveness and cost and reduces studies and continuing with first-generation modules and pioneer commercial- modeling accuracy. size plants. Streams from individual unit operations should be Integrated to simulate expected commercial conditions. Performance of control Inhibits modeling and cost Additional pilot-plant and demonstration-plant programs. technologies estimation. Dispersion behavior Inhibits evaluation of near-source and Improvement in modeling and monitoring techniques for complex terrain, regional air quality impacts. including development and validation of near-source and regional dispersion models Models to be validated for the terrain and meteorology of the 011 shale region and for emissions similar to those expected from 011 shale operations. Trace element behavior Inhibits evaluation of the effects of 011 Monitoring of trace element concentrations in process feed streams, treated shale development on human health, emissions streams, and fugitive emissions. Examination of the effects of plants, and animals. conventional control technologies on trace elements. Determination of the relationships between trace element concentrations in soils and plants and nutritional problems. Development of indicator species Studies of the synergistic effects of trace elements on vegetation

SOURCE Ofl[ce of Technology Assessment Ch. 8–Environmental Considerations ● 289 cated to potential oil shale developers. The oil shale basin that could be developed, and thus shale region has been designated Class II, but limit the ultimate size of the industry that several Class I areas exist nearby that could could operate within the basin, be affected by oil shale operations. The law prohibits any facility to exceed the PSD limi- UNDEFINED REGULATIONS tation in any area, including the area in The Clean Air Act stipulates a need to pro- which the facility is to be sited and any adja- tect visibility in Federal mandatory Class I cent areas, Thus, oil shale developers will areas. While regulations are to be promul- have to demonstrate that their facilities will gated by EPA by November 1980, and by the satisfy both Class II PSD standards and Class States by August 1981, uncertainties still ex- I standards. ist as to the potential implications for oil shale development in regard to the siting of Under the present regulatory structure, future oil shale facilities. In addition, EPA is PSD increments are allocated on a first-come, presently developing incremental PSD stand- first-serve basis. The first oil shale plants in a ards for HC, CO, O3, NOX, and lead. Oil shale given area could exhaust the entire incre- facilities will have to comply with these new ments. If this occurs, subsequent developers, standards. who might be delayed by the preliminary status of their processing technologies, will not Another area of uncertainty concerns be able to locate in the same area, regardless emission standards for hazardous air pollut- of the efficiency of their air quality control ants under section 112 of the Clean Air Act, strategies. To date, the emissions that are regulated are asbestos, vinyl chloride, mercury, and berylli- Under the provisions of the Act, new facil- um. Controls have been required for indus- ities can be located in a polluted area if they tries that produce these substances at high are able to offset their emissions by reducing rates. To date, the oil shale industry has not the emissions of other industrial plants in the been included under the regulations for these same area. This strategy may be feasible in pollutants because it is expected that they urban industrialized areas, especially where will be generated at low levels, if at all. How- existing facilities are old and do not employ ever, EPA is in the process of developing haz- state-of-the-art air pollution control methods. ardous emissions standards for POM, arse- It is not applicable to the oil shale areas at nic, and possibly other substances. It does not present because there are few industrial fa- appear at this time that these substances will cilities against which to offset new emissions. be regulated for oil shale operations, but the It probably will continue to be inapplicable as regulations could be applied to oil shale if the the area industrializes, because any new substances are found in the emissions plants will be built with the best available streams during future characterization stud- control technologies to reduce emissions to ies. Furthermore, it is also possible that addi- minimum levels. A subsequent oil shale devel- tional regulations could be promulgated for oper would thus be forced to improve on these substances that have already been detected control methods. It is uncertain whether this in these streams. could be done at reasonable cost. It should also be noted that a recent U.S. These constraints could result in each oil Circuit Court of Appeals decision in the case shale plant being surrounded by a buffer of Alabama Power, et al. v. EPA may result in zone in which no additional industrial activ- significant changes in the PSD regulations. ities (including oil shale development) would The definition of baseline conditions, fugitive be allowed. Without reliable regional air dust control requirements, and monitoring re- quality modeling studies, it is impossible to quirements are among the issues on which predict the width of these buffer zones, How- the court has rendered a decision. As a result ever, it is very possible that such zones could of the decision, EPA proposed certain revi- substantially reduce the area of a given oil sions to the PSD regulations on September 5, 290 . An Assessment of Oil Shale Technologies

1979. However, the effect of the court deci- all prospective oil shale developers prior sion and the proposed regulations on the con- to their preparation of PSD applications. ditions for PSD permits for oil shale facilities This effort would seek a coordinated is unclear at this time. strategy for maximizing shale oil production while maintaining the ambient air Policy Options quality at regulated levels. Implementa- tion could be constrained by, for exam- LIMITS ON DEVELOPMENT ple, antitrust laws. Siting constraints will probably not be Alter existing regulatory procedure in al- severe for an oil shale industry of 200,000 to location of PSD increments. Under this 400,000 bbl/d. However, it appears likely that option, EPA would allocate a portion of a large industry (the order of 1 million bbl/d) the total PSD increment to each firm could encounter siting difficulties because of when it applied for a PSD permit. The re- the Class H status of the resource region, the maining portions of each increment possibility that the initial facilities will ex- would be reserved for future industrial haust the total PSD increments over large growth. Although this option would areas, and the existence of Class I areas near allow for a certain level of additional the region. If this appears to be the case, growth, it could impose technical and there are several possible actions that could economic burdens on the individual ap- be taken. These are briefly described below. plicants, because each proposed facility would be required to maintain lower Retain the current regulatory structure. emission levels than would be the case This option would not alter existing air under the existing regulatory structure. quality standards and PSD regulations Redesignation of the oil shale region as promulgated under the Clean Air Act. from a Class II to a Class III area. This Under existing law, all oil shale facilities option would lower air quality but would would have to undergo a preconstruc- allow for more industrial development. tion review before a PSD permit would The action would be initiated at the be granted. The use of BACT would be State level, with final approval being required, and the developer would have necessary from EPA. The following cri- to demonstrate that air quality regula- teria would have to be satisfied: tions would not be violated either within the Class II area of development or in —the Governors of Colorado, Utah, or nearby Class 1 areas. As indicated previ- Wyoming must specifically approve ously, the current policy of allocating the redesignation after consultation PSD increments on a first-come, first- with legislative representatives, and serve basis might constrain the commer- with final approval of local govern- cialization of those technologies that are ment units representing a majority of in the early phases of development, and the residents of the area to be redesig- in addition might limit the ultimate size nated; of an oil shale industry within the re- —the redesignation must not lead to pol- source region. lution in excess of allowable incre- Coordinate issuance of PSD permits for ments in any other area; and oil shale plants. This option would not —other procedural and substantive re- alter existing PSD regulations as promul- quirements for redesignation under gated under the Clean Air Act. However, State and Federal law must be satis- it would change the current approach to fied. the issuance of PSD permits for oil shale While such an option would appear to plants by EPA. Rather than issuing PSD allow for about twice as much oil shale permits on a first-come, first-serve basis, development as is presently possible EPA would encourage coordination with under a Class II area designation, con- Ch. 8–Environmental Considerations ● 291

straints would still occur because of the ance basin and an unknown amount in nearby Class I areas. Utah and Wyoming, but at the cost of in- Amend the Clean Air Act. This congres- creased air pollution. sional option would exempt the oil Shale region from compliance with certain provisions of the Clean Air Act. Con- IMPROVE TECHNICAL INFORMATION gress might direct EPA and the States in Additional analysis is needed of the poten- question to redesignate the oil shale re- tial effects of oil shale development on air gion from a Class 11 area to a Class 111 quality. Such analysis will be useful in identi- area, and to exempt the oil shale devel- fying long-term R&D needs in protecting air opers from maintaining the visibility and quality and in identifying siting problems im- air quality of nearby Class I areas. This posed by existing air quality regulations and option would remove the major uncer- standards. Some options for improving the tainties surrounding the siting of oil quality of technical information might in- shale facilities within the resource re- clude: the further development of existing gion itself, and would remove any siting R&D programs, the coordination of R&D work barriers connected with the degradation by Federal agencies, the redistribution of of nearby Class I areas. Such an option funds within agencies for air quality re- would allow development up to the Class search, increased appropriations to agencies III standards, which permit lower air to accelerate their air quality studies, and the quality than Class II standards. Thus, passage of new legislation specifically tied to this option would allow an industry of up funding R&D relating to air quality impacts at to 800,000 bbl/d to be sited in the Pice- various levels of oil shale development.

Water Quality Introduction might be released. Much work has been done to describe the quantity and quality of sur- Development and operation of oil shale fa- face and ground water resources in the oil cilities could contaminate surface and ground shale region. However, little is known about water from point sources such as cooling wa- the nature and ultimate impacts of the pollut- ter discharges, nonpoint sources such as run- ants produced by oil shale processing. For ex- off and erosion, and accidental discharges ample, a number of these pollutants may be such as spills from trucks, leaks in pipelines, carcinogenic, mutagenic, and teratogenic.* or the failure of containment structures. The Information is not available on the risks pollutants could adversely affect aquatic posed by these pollutants at the levels likely biota, irrigation, recreation, and drinking to be encountered in the surface and ground water. The severity of these impacts will be water affected by oil shale development. determined by the scale of operation, the In this section: processing technologies used, and the types and efficiencies of the pollution controls. . The types of wastewaters produced by oil shale operations are characterized. The water systems may be affected during ● Rates for the generation of these con- the operating lifetime of an oil shale facility, taminants are estimated. and such long-term impacts as those from the ● Potential impacts of effluent streams on leaching of disposal piles could continue for surface and ground water are identified. many years after operations ceased. Accu- rate prediction of the impacts requires an understanding of the characteristics, trans- *(krcino~ens cause cancer. Nlutagens cause mut[ltions in port routes, and fates of the pollutants that offspring. ‘1’era togens cause fetal defects. 292 ● An Assessment of 011 Shale Technologies

● The quality of surface and ground water Pollution Generation resources in the oil shale region is examined. The following discussion examines the ● The applicable Federal and State water types of effluents generated by various oil quality regulations and standards are shale processes. Where data are available, described. the rates at which these effluents are pro- ● The effects of these regulations and duced by different types of facilities are standards on a developing oil shale in- estimated. dustry are analyzed. ● The pollution control strategies that may Unit Operations and Effluent Streams be applied are described and evaluated. The net rates at which pollutants will be Mining will produce dusty air and gases emitted in treated streams are then esti- that must be cleaned to protect the miners. mated. Wet scrubbing of this mine ventilation air will ● Procedures for predicting and monitor- produce wastewater streams that will have ing compliance with water quality regu- to be treated. If the shale deposits are located lations are discussed. in ground water aquifers, then mine drainage ● Issues and R&D needs are summarized. water will be produced that must be con- ● Policy options are discussed. sumed, discharged to a surface stream, or re-

1%0(0 credit OTA staff Mine dewatering at tract C-a— water quantity has been greater than anticipated at this site Ch. 8–Environmental Considerations ● 293

injected into the aquifers. The drainage wa- produce significantly different quantities of ters will contain inorganic salts, chloride and wastewater with different types and concen- fluoride ions, and boron. They should not con- trations of contaminants. For example, a tain significant concentrations of dissolved Claus/Wellman Lord sulfur recovery system gases or organic chemicals, although dis- would produce a neutralized acidic wastewa- 15 solved H2S may be found in some locations. ter; a Stretford sulfur absorption unit would Retorting produces water by combustion of not. hydrogen, by release of moisture present in Steam generation and water cooling.— the feed shale, and by chemical decomposi- High-quality water must be used to generate tion of kerogen. In some aboveground retorts steam for power generation or process needs. (such as TOSCO 11 and Lurgi-Ruhrgas), this Generally, the boiler feedwater must be water is entrained in the retort’s gas stream treated to remove inorganic salts. The treat- and is condensed when the product gas is ment (usually lime softening or ion exchange) cooled. This “gas condensate” will be con- generates liquid wastes. In addition, the

taminated with NH3, CO2, H2S, and volatile or- water in a boiler becomes concentrated in ganics, but will not contain appreciable quan- dissolved materials, and a portion must be tities of inorganic salts. In other processes continually replaced with freshwater. The (such as in situ retorting or the Paraho or chemical species in the boiler wastewater Union “B” aboveground retorts) some of the (blowdown) will be similar to those in the raw water may condense within the retort or in water, but they will be more concentrated. the oil/gas separators. This “retort conden- Wet cooling towers will be used to cool the sate’ will contain H2S, NH3, CO2, and dissolved organics, plus inorganic salts that water that is used in heat exchangers. Cool- have been leached from the shale in the re- ing towers work by evaporating a portion of tort, Trace elements and toxic metals could the water passing through them. This evap- also be present. oration concentrates the chemicals that enter with the feedwater, just as in a boiler. The Upgrading will include several operations: water that must be removed to control the ac- gas recovery, hydrogen generation, gas-oil cumulation of solids (blowdown) will be chem- and naphtha hydrogenation, delayed coking, ically similar to the feedwater but will also

NH 3/acid-gas separation, foul-water strip- contain chemicals that are added to control ping, and sulfur recovery. Gas recovery and the growth of algae in the tower. hydrogen generation produce little wastewa- Spent shale disposal. -Spent shale from ter. However, hydrotreaters and cokers pro- aboveground retorting will be exposed to duce foul condensates that are contaminated leaching by rainfall, snowmelt, or irrigation with dissolved gases and organics. Gases are water. If wastes are disposed of by backfill- usually removed within the upgrading unit. ing mines, they may be leached by ground Thus, the principal pollutants in the final ef- water. Leachates from various spent shales fluent stream are dissolved organic com- have been studied by a number of investi- pounds. 16 17 gators. Their properties vary widely with Air pollution control.—Dust scrubbers and the retorting process but in general they con- water sprays will produce an effluent that tain significant concentrations of total dis- contains suspended solids and dissolved in- solved solids (TDS), sulfate, carbonate, bicar- organic salts. Effluent streams from gas bonate, and other inorganic ions, and lesser cleaning devices will also contain solids and amounts of trace elements and organic com- salts as well as HC, H2, NH3, phenols, organic pounds. They are alkaline, with pH values acids and amines, and thiosulfate, and thio- ranging from 8 to 13. Their addition to the cyanate ions, The principal sources of waste- naturally occurring waters in the oil shale re- water will be scrubbers and units for the region could result in significant water quality 14 covery of sulfur and NH3. Different devices changes, but the severity of the risk is diffi- 294 ● An Assessment of Oil Shale Technologies

Table 51 .–Generation Rates for Principal Water Pollutants for cult to ascertain. For example, one leachate a was tested according to EPA procedures, and Production of 50,000 bbl/d of Shale Oil Syncrude (tons/d) the spent shale could not be classified as a Type of retortinq facility hazardous waste on the basis of its trace ele- Aboveground Aboveground MIS/ ments and toxicity .18 However, some spent direct indirect MIS aboveground shales could be classified as hazardous be- Gas condensates 19 NH . 75.6 147 276 189 cause of the presence of organic residues. 3 H 2 S 0.9 23 15 1.1 co 136 17.5 541 371 Leaching of in situ retorts.—In situ retort- 2 ing presents an environmental problem be- BOD : : 19.2 285 18,5 127 Subtotal 232 63 837 574 cause ground water is found in many of the Retort condensates deposits to which this process could be ap- NH3 (b) (b) 3,5 2.4 H S. . . (b) (b) – – plied. The increases in permeability that 2 co2 (b) (b) 48.2 331 would result from mining, fracturing, and re- BOD ., (b) (b) 10.1 7.3 torting would facilitate leaching after dewa- Subtotal – — 62 43 tering operations are discontinued. Soluble Upgrading condensates NH . 134,2 1342 134,2 134,2 materials in the spent shale would thus enter 3 H 2 S 58.8 58.8 58.8 58.8 the ground water and would eventually reach co* 1,4 14 14 1.4 surface streams. Such transport would take BOD 3.7 37 37 3,7 long periods of time. However, if aquifers are Subtotal 198 198 198 198 contaminated, cleanup would be virtually im- Blowdown and waste treatmentc Ca/Mg/Na d 60 6.3 12,2 11 2 possible. Chloride. 5.3 57 09 0.8 Fluoride ., – — 03 0.2 Sulfate 6.5 6.8 8.4 76 Summary of Pollutants Produced by Subtotal 18 19 22 20 Major Process Types Mine drainage treatment CO3 =/ HCO3 -e (f) (f) 23,1 23,1 Boron (f) (f) 01 0.1 Approximate rates of generation of major Ca/ Mg/Nad. (f) (f) 145 14,5 pollutants are summarized for four facilities Chloride (f) (f) 0.7 0.7 in table 51. * Five factors should be kept in Fluoride. (f) (f) 05 0.5 Silica. ., ., (f) (f) 05 0.5 mind in reviewing this table: Sulfate (f) (f) 126 12.6 — — ● The rates are for the generation of pol- Subtotal 52 52 lutants—not for their release to the en- Total, 488 295 1,171 887

vironment. The rate of release will be de- a;ons per stream day bAssumes above-ground retorts operated a! temperatures that do not Produce condensate termined by the strategies that are used cln~]”de~ water pretreatment Above-ground plants use Colorado Rwer wafer MIS and MIS’ to remove the contaminants. above-ground plants use mme drainage waler ● dGalclum magnesium and sodium Ions Retort condensates are not shown for ecarbonale and bicarbonate IOnS the AGR processes because it is as- fAs~umes above-ground relorflng plants are not located w ground water areas sumed that the retorts will be operated SOURCE Of ftce of Technology Assessment at temperatures that will avoid condensation of water vapors within the retort. fleets present developer proposals. It This should be achievable with most re- would not be valid for future plants in torting systems. However, others (like the center of the Piceance basin. the Union “B”) may produce substantial ● No retort leachates are shown for the quantities of retort condensate. MIS retorts because the rate of leaching ● No mine drainage water is shown for the and the efficacy of control systems can- aboveground plants because it is as- not be accurately estimated. One study sumed that they will not be sited in estimated that a commercial MIS facility ground water areas. This assumption re- might yield over 2,000 ton/d of soluble salts, but only crude estimates were 20 *See app. C for details, made of the rate of release. Ch 8–Environmental Considerations ● 295

No rates are shown for trace elements, increase over 500 mg/1, treatment for munici- heavy metals, or toxic organic chemicals pal and industrial water users becomes more because these are produced in much costly, and the yield of irrigated farmlands smaller amounts than the major pollut- might be reduced. 29 For public drinking water ants. However, they can be both more supplies, EPA recommends limits of 500 mg/1 hazardous and more difficult to re- for dissolved solids and 250 mg/1 for both move.21-28 chlorides and sulfates. 30 The estimates indicate that MIS processing on tract C-b will produce the greatest quanti- Oil and Grease ty of wastewater contaminants for treatment, Because large amounts of shale oil will be mostly because of the large gas condensate produced, processed, and transported, there stream. A substantial difference is shown be- is a possibility of oilspills. If they cannot be tween the aboveground direct and above- contained or removed, detrimental impacts -ground indirect plants with respect to the would occur to aquatic biota. Small spills, rates at which pollutants are generated in the such as from pipeline leaks, could cause local gas condensate streams: the directly heated damage. If undetected, the long-term impacts facility produces about four times as much could be substantial. Oil and grease in public dissolved gas (largely CO2 and NH3). This is water supplies cause an objectionable taste because more air is introduced into directly and odor, and might ultimately endanger pub- heated retorts. The trend is consistent with lic health. the even higher gas condensate production of the MIS retorts, which are also assumed to be Suspended Solids directly heated. Sedimentation problems will be increased Effects of Potential Pollutants on because large amounts of land will be disturbed, which will increase the area’s sus- Water Quality and Use ceptibility to erosion. Suspended solids make Salinity surface water cloudy and increase its temperature, thereby affecting aquatic life. Sus- Oil shale development could increase the pended solids in industrial waters can dam- salinity in surface and ground water systems age some types of equipment. through two processes: Concentration of naturally occurring Temperature Alteration saltwater as high-quality water is with- An industry may alter stream tempera- drawn for consumptive uses. (This effect tures by discharging warm waste streams, by is discussed in ch. 9.) consuming cool water, or by lowering the Salt loading from leaching of waste dis- ground water table. Discharges from power- posal piles and in situ retorts, from re- plants could also increase temperatures, but lease of saline mine or process waters, the developers do not expect to do this. The and from ground water disturbances construction of new reservoirs could also caused by reinfection. alter stream temperatures. While tempera- Salinity increases are a significant problem ture is not a critical factor in water for in- because as water becomes more mineralized, dustrial use, for drinking, or for irrigation, its municipal, domestic, ecological and agri- tion, wildlife, Federal lands, and Indian reservations all com- cultural utility is reduced. * If dissolved solids pete for its waters. PresentIV, salinity of the Colorado River at IIoover Dam is 745 mgl. Unless efficient control technologies “I’his is of ma jor importance because the Colorado River sys- can be employed, estimates have indicated that a large oil tem is one of the most important river systems in the South- shale industry has the potential, due to salt loading and salt west. I t serves :~pproxima tel~’ 15 m i]iion people. ~funicipalit ies, corwent ration, to increase the salinity level a t Hoover Dam bv agrirul t u re, energv proriuc t ion. i ncfus t rv and mining, recrea- several mg 1. — —

296 ● An Assessment of Oil Shale Technologies large variations would affect all aquatic life, Microbial Contamination both directly and indirectly (e.g., by influenc- ing their susceptibility to disease and toxic The microbial contamination of surface compounds. )3] Because the Colorado River waters could occur if rapid population system is large, and variations in water tem- growth overloads sewage treatment facil- peratures occur naturally, it is not expected ities. (See ch. 10 for a discussion of the prob- that oil shale development will significantly lems of rapid growth.) Improperly treated affect its temperature. 32 sewage containing viruses, bacteria, and fungi could be released into the water system. These problems could be controlled by the Nutrient Loading construction or expansion of sewage treat- The potential sources of nitrogen and phos- ment plants. phorous are ground water discharge, runoff from raw and spent shale, municipal wastes, Water Quality in the Oil Shale Region and chemical fertilizers used for reclaiming land. These nutrients would adversely affect The current properties of the water define nearby surface waters, but the effect on the how it must be treated before it can be used total river system is uncertain. The overall in oil shale facilities. More importantly, they impact will depend on where the facilities are define the level to which wastewater must be located and on the degree of waste treatment treated before it can be discharged. In gener- used. al, regulations do not permit the discharge or reinfection of wastewater unless it is at least Toxic Substances as pure as the receiving stream or aquifer. As indicated by the data in table 52, the quality Sources of toxic trace elements and organ- of surface streams is highly variable. It also ic chemicals include stack emissions from tends to deteriorate between upstream and processing operations, chemicals used in up- downstream reaches, as exemplified for Pice- grading and gas processing, leachates from ance Creek east and west of tract C-b. All of raw and retorted shale, and associated in- the streams described in the table satisfy the dustrial and municipal wastes. These sub- standards promulgated by EPA and the U.S. stances are of concern because of their po- Public Health Service for the maintenance of tential impact on aquatic life, and on human aquatic life and wildlife. Moreover, with the health through drinking water supplies and exception of Evacuation Creek, all are suit- irrigation. Concentrations of certain minerals able for irrigation water supplies and for live- in the region’s water already exceed the lim- stock watering. Evacuation Creek’s boron its set for certain water uses. * Oil shale de- content exceeds the irrigation standard, and velopment could increase these levels and its dissolved solids level exceeds the livestock could also add other toxic contaminants. For watering standard. However, none of the example, cadmium, arsenic, and lead, and streams satisfies the standards for public other heavy metals could be leached from drinking water. The standard for dissolved spent shale piles. Organic compounds (phe- solids is exceeded by all the streams, espe- nols, benzene, acetone) that are suspected cially Yellow Creek and Evacuation Creek. carcinogens and that have been identified by Evacuation Creek also exceeds the standard EPA as high-priority hazardous water pollut- for boron, sodium, and sulfate ions. The sodi- ants also are found in oil shale process um standard is also exceeded by Yellow waters. Creek, and the sulfate standard by all three creeks and the spring. *For example, the boron content in Eva ma lion Creek, near Ground water is generally of poorer quality lease tracts U-a and U-b exceeds the irrigation standard. See the next section on water quality in the oil shale region for a than surface streams. The quality of alluvial more detailed discussion, aquifers and of the upper and lower bedrock Ch. 8–Environmental Considerations ● 297

Table 52.–Quality of Some Surface Streams in the Oil Shale Region (mg/l)

Basin Piceance Uinta Piceance Piceance Piceance Piceance Piceance Uinta Piceance Creek Piceance Creek Spring at Evacuation Stream Colorado River White River east of C-b west of C-b Yellow Creek WIIIOW Creek Wallow Creek Creek

Reference 14 15 16 16 17 16 16 15

b Ammonia NA 006 NA NA 0.153 01 01 006 Bicarbonate 168 241 542 601 1,470 606 540 575 Boron NA 0088 NA NA 0.642 0.2 0.6 1. 95 Calcium 72 72 70 79 319 143 161 214 Carbonate NA 02 00 00 118 01 01 00 Chloride 205 42 16 14 124 40 08 66 Dissolved solids 734 551 718 944 2,430 995 910 4,948 Fluoride NA 003 10 0.7 2.09 17 14 09 Hardness NA 299 NA NA 541 576 516 1400 Magnesium 19 29 47 69 112 53 28 209 pH NA 82 82 82 87 79 7.9 79 Silica 70 13 16 17 105 13 13 10 Sodium 153 78 130 160 746 138 125 972 Sulfate 158 188 170 300 550 350 310 2.889 aSee reterence IISI bDala not ava(lable SOURCE Office of Technology Assessme~t ground water aquifers in the Piceance basin Table 53.–Quality of Ground Water Aquifers near Federal lease tracts C-a and C-b is in the Piceance Basin (mg/l) shown in table 53. * Water from the alluvial Aquifer Alluvial Alluvial Upper Lower and upper aquifers could be used for irriga- Referenced 17 16 16 16 tion, but its high dissolved solids content Ammonia 0337 NAb NA NA could harm many crops, Water from the low- Bicarbonate 573 1,220 550 9,100 Boron 1 25 NA NA NA er aquifer could be used only with very toler- Calcium ., 102 57 50 74 ant plants on permeable soil, and that from Carbonate 11.4 NA NA NA some portions of the aquifer could not be used Chloride 17.9 42 16 690 Dissolved solids 1,190 1,750 960 9,400 at all because the lithium and boron concen- Fluoride 0367 46 14 28 trations would be toxic to many plants. Ex- Hardness 600 NA NA NA cept for the lower aquifer, the ground water Magnesium 839 80 60 95 pH 65 NA NA NA resources could be used for livestock, All of Silica NA NA NA NA the water would be suitable for maintenance Sodium. 202 490 210 3,980 of aquatic life and wildlife. Sulfate 467 430 320 80 None of the aquifers meets drinking water aSee reference IIsl bDala not avadable standards. Special problems are encoun- SOURCE Off Ice of Technology Assessment tered with boron, which in one sample of lower aquifer water exceeded the drinking water 34 standard by a factor of 320. Also, the aver- Water Quality Regulations age fluoride concentration in lower aquifer water is about 28 times the drinking water 35 Regulations for the maintenance of surface standard. Dissolved solids concentrations in and ground water quality have been promul- the lower aquifer range from a level that gated under the Clean Water Act and the would satisfy drinking water standards (500 Safe Drinking Water Act. They are imple- mg/1) to over 40,000 mg/1, A concentration of 36 mented at the Federal and State levels, to- 63,000 mg/1 was reported for one sample. gether with additional State standards. In the “I’he grounci water resources of the Piceance basin are de- following discussion, the provisions of these scribed in ch. 9. The bedrock aquifers are separated by the oil shale deposits of the !vlahogany Zone. Alluvial aquifers are Acts that are of particular significance to oil genera]ly found near the surface in valley walls and floors. shale are emphasized.

63-898 0 - 80 - 20 298 . An Assessment of Oil Shale Technologies

The Clean Water Act be monitored and regulated with some precision, and they are suited to the application of The objective of the Federal Water Pollu- control devices. Nonpoint sources are sites tion Control Act (FWPCA) is “to restore and from which there is uncollected runoff. Exam- maintain the chemical, physical, and biologi- ples are irrigated fields and waste disposal cal integrity of the Nation’s waters. ” In 1972, areas. They present regulatory and techno- FWPCA was amended to establish a complex logical difficulties, and as a result, they are program to clean up the Nation’s waterways subject to less stringent legal controls. by limiting the effluents of all classes of polluters. These limits were to be tightened until FWPCA established a complex regulatory the ultimate goal of no pollution discharge scheme to control pollution from industrial into navigable waters was achieved. The min- point sources: ing industry had difficulties meeting the re- ● by July 1977, all nonmunicipal polluters quirements of this program. Congress re- must use the “best practicable pollution sponded to these problems, and to the recom- control technology currently available” mendations of the National Commission on (BPT); public sewage works must use Water Quality, by further amending the Act secondary treatment; in 1977. The amended Act, now called the ● by July 1983, nonmunicipal point sources “Clean Water Act” refined FWPCA’s regula- must use the “best available technology tory scheme for point sources and empha- economically achievable” (BAT), munici- sized the control of toxic effluents. EPA, the pal sewage treatment plants must use Army Corps of Engineers, and the States are the “best practicable waste treatment responsible for implementing and enforcing technology;” this Act. ● special effluent standards for toxic pol- The goals of the Act are: lutants must be met prior to the 1977 deadline; ● the discharge of pollutants into naviga- ● new facilities must use the “best avail- ble waters shall be eliminated by 1985; ● able demonstrated control technology;” wherever attainable, water quality and which provides for the propagation of ● special restrictions, based on ambient fish, shellfish, and wildlife and for rec- water quality standards, must be used if reation in and on water, shall be the national effluent standards will not achieved by July 1, 1983; ● meet water quality targets in a given discharge of toxic pollutants in toxic basin. amounts shall be prohibited; and ● a major R&D effort shall be made to de- The 1977 amendments changed this frame- velop- the technology necessary to elimi- work: the July 1977 BPT deadline was ex- nate the discharge of pollutants into the tended until April 1, 1979, for point-source navigable waters, the waters of the con- polluters who demonstrated a good-faith ef- tiguous zones, and the oceans. fort to achieve compliance, and the BAT provisions were completely revised. Industrial To achieve these goals, emissions stand- point-source pollutants were divided into ards are to be set to limit discharges from three classes—toxic, conventional, and nonpoint and nonpoint sources, and ambient conventional. Each is treated differently. standards are to be established for the quali- Toxic pollutants cause death, disease, behav- ty of surface waters. ioral abnormalities, cancer, genetic muta- Effluent standards. —Different ap- tions, physiological malfunctions, or physical proaches are used for control of point and deformations in any organisms or their off- nonpoint sources. Point sources release a col- spring. Sixty-five toxic pollutants must meet lected stream of pollutants through sewers, the BAT standards by July 1, 1984; others pipes, ditches, and other channels. These can must meet BAT standards within 3 years Ch. 8–Environmental Considerations ● 299 after effluent limitations are established. Table 54.–Effluent Limitations for Petroleum Refineries Using Conventional pollutants include biological Best Practicable Pollution Control Technology (BPT) oxygen-demanding substances, suspended (pounds per 1,000 bbl of feedstock) solids, fecal coliform, and changes in pH. Average of daily values They are subject to the application of “best Maximum for for 30 consecutive conventional control technology” by July 1, Effluent characteristic any 1 day days shall not exceed 1984. In general, this standard is less strin- Biochemical oxygen demand (BOD 5 ) 192 102 gent than the BAT standard. Nonconvention- Total suspended solids 132 84 al pollutants—those classified as neither tox- Chemical oxygen demand 136 70 011 and grease 60 32 ic nor conventional—will be subject to the Phenolic compounds 014 0068 BAT standards no later than July 1, 1987. Ammonia as N 83 38 Sulfide 0124 0056 Specific limits on these effluents must be Total chromium O 29 017 adhered to by individual polluters. In prac- Hexavalent chromium 0025 0011 tice, effluent limitations are developed by pH Must be within the range of 6.0 to 90 EPA for each industry. No discharge of any SOURCE E R Bales and T L Thoem feds j Pololoo Coflrro GUAInI-e lo, 0 .Wk Lle~eoo pollutant from a point source is allowed un- menl Append/x Envlro!lfnenldl ProtectIon Agency Cinclnnaft Ohio July 1979 0 D 9 less a National Pollutant Discharge Elimi- nation System (NPDES) permit has been the following wastewater management proce- granted. To obtain a permit, the polluter must dures: meet the applicable effluent limitations, tech- sour water stripping to reduce NH3 and nology standards, and water quality goals. H2S; Permits are obtained from EPA or from the in- ● segregation of sewers; dividual States, if they have taken over the ● no discharge of polluted cooling water; regulatory role. Cancellation of permits for and noncompliance is one method of enforcing the oil, solids, and carbonaceous wastes re- Act, because without a permit, many industri- moved just prior to discharge. al operations cannot be carried out. It should be noted that permits do not simply recapitu- The BAT standards illustrated in table 55 late the effluent guidelines; additional ambi- were defined using additional treatment ent standards may also be imposed. Table 55.–Effluent Limitations for Best Available Technology Special attention is given to new sources Achievable (BAT) for Petroleum Refinery Facilities and to sources that discharge into publicly (pounds per 1,000 bbl of feedstock) owned treatment works. In practice, performance standards for new sources are often Effluent Iimitations equivalent to the 1983 BAT limitations devel- Average of daily values Maximum for for 30 consecutive oped for existing industries. Any new source Effluent characteristic any 1 day days shall not exceed that complies with an applicable standard of Biochemical oxygen demand performance is not to be subjected to more (BOD 5 ) . 32 2.6 stringent standards during the first 10 years Total suspended solids. 3.0 26 Chemical oxygen demand 168 134 of operation. 011 and grease 060 0.48 Expected effluent limitations for oil shale Phenolic compounds 0015 0010 Ammonia as N. 20 15 facilities.—EPA has not yet developed stand- Sulfide . 0066 0042 ards of performance for oil shale facilities. Total chromium 015 0.13 Hexavalent chromium, 0.0033 0.0021 However, standards have been established pH Must be within the range of 6.0 to 9.0 for petroleum refining, which has several SOURCE E R Bales and T L Thoem {eds I f%luton Coofro/ Gwddnce Pm 0// 5?M/e Deve/op- similarities. The BPT standards shown for pe- rnenf Appendix Enwronmental Protect(on Agency Cincinnati Ohio July 1979 p troleum refining in table 54 were based on c1 11 300 An Assessment o/Oil Shale Technologies methods now practiced by some petroleum for interstate waters. FWPCA required State refineries. These methods include: standards for intrastate waters as well. EPA will develop the standards if a State fails to ● use of air cooling rather than wet cooling towers; do SO. ● reuse of sour water stripper wastes; The ambient standards are the basis for ● reuse of cooling water in the water preventing the degradation of presently clean treatment plant; waterways. The regulations provide, without ● using treated wastewater as coolant qualification, that “No further water quality water, scrubber water, and in the water degradation which would interfere with or treatment plant; become injurious to existing instream water ● reuse of boiler blowdown as boiler feed- uses is allowable. ” Thus, if a stream is suit- water; able for the propagation of wildlife; for swim- ● use of closed cooling water systems, ming; or for drinking water, then it must re- compressors, and pumps; main suitable for these uses. Because small ● use of rain runoff as cooling tower make- increases in pollutant loads may not be incon- up or water treatment plant feed; and sistent with protecting a possible present use, ● recycling of untreated wastewaters the States are allowed to decide whether “to wherever practical. allow lower water quality as a result of NSPS for petroleum refineries, based on a necessary and justifiable economic or social combination of BPT and BAT standards, are development. ” Such decisions cannot be ap- shown in table 56. New sources must meet plied to waters that constitute an outstanding discharge standards that reflect the greatest national resource (e.g., national parks, wil- degree of effluent reduction which the EPA derness areas), and they cannot allow water Administrator determines to be achievable quality to fall below the levels needed to pro- through application of the best available dem- tect fish, wildlife, and recreation. onstrated control technology, process altera- tions, or other methods including, where Before a State can issue a discharge per- practicable, zero discharge systems. mit it must have a program for reviewing and revising its water quality standards. EPA es- Federal ambient water quality stand- tablished the following guidelines for State ards.—The Water Quality Act of 1965 re- review and revision: quired the States to adopt ambient standards ● standards must be reviewed every 3 Table 56.–New Source Performance Standards for Petroleum years and revised where appropriate; Refineries (pounds per 1,000 bbl of feedstock) ● standards must protect the public health Effluent Imitations and welfare, and not interfere with Average of daily values downstream water quality standards; Maximum for for 30 consecutive existing standards must be upgraded Effluent characteristic any 1 day days shall not exceed where current water quality could sup- Biochemical oxygen demand port higher uses than those presently

(BOD5 ) 147 7.8 Total suspended solids. 9.9 6.3 designated; Chemical oxygen demand ~ ~ 104 54 ● existing standards must be upgraded to 011 and grease 4.5 2.4 achieve FWPCA’s 1983 goal of fishable Phenolic compounds 0.105 0.051 Ammonia as N 8.3 3.8 and swimmable waters, where attain- Sulfide 0093 0042 able. Attainability is to be determined by Total chromium ., 0220 0.13 environmental, technological, social, ec- Hexavalent chromium. 0.019 0.0084 onomic, and institutional factors; and pH ., Must be within the range of 60 to 90 ● existing water quality can degrade in SOURCE E R Bales and T L Thoem (eds I Po//uOofl CofMro/ Gwdance for Od Sha/e L7eve/op only specific instances, for example, if menl Append/x Environmental Protection Agency Clnclnnatl Oh[o July 197[1 p 012 existing standards are not attainable Ch. 8–Environmental Considerations . 301

because of natural conditions such as raw water uses (except contact recreation) leaching. without treatment, but with coagulation, sedimentation, filtration, and disinfection prior to Once an ambient standard is established, a use as domestic water supply. Temperature State must identify stream reaches for which limitations are also imposed. The water quali- the 1977 effluent limitations are not suffi- ty criteria for class CW are shown in table ciently stringent. For such areas, the State 58. In addition, Utah, like Colorado, has an must determine the total maximum pollutant antidegradation policy. loads that will allow the ambient standard to be met, This information is used to set more Table 58.–Utah Water Quality Standards stringent effluent standards. for Stream Classification CW Current State standards for Colorado and Parameters Criteria for CW streams Utah. —In Colorado, streams may be assigned Radioactive and chemical Drinklng water standards to one of four categories. Drainage from lease Settleable solids. 011, floating solids, Free from taste, odor, color, and toxic tracts C-a and C-b would discharge to the por- materials, turbidity, etc tion of the White River from the mouth of the Total coliform bacteria Less than 5,000 units per 100 Piceance Creek to the Colorado/Utah State milliliters Fecal conform bacteria Less than 2,000 units per 100 line. This area is in Colorado’s water cate- milliliters gory B2. These waters are suitable, or are to pH 65 to 85, no Increase >0.5 Biochemical oxygen demand (BOD ) Less than 5 milligrams per Iiter become suitable, for customary raw water 5 Dissolved oxygen >6.0milligrams per liter purposes (e.g., irrigation, livestock watering) Temperature Maximum 680 F except for primary contact recreation, * The SOURCE E R Bates and T L Thoem (eds I Polluf(on ComroI Gufdafice to{ Oh Shd,e Oeve/oj water quality criteria for category B2 are ment Appendtx Enwronmental Pro fecllon Aqenc~ Clncnnaf Ohio JIJY 1979 p listed in table 57. Colorado also has an anti- 021 degradation policy applicable to all streams. Proposed State standards.—FWPCA re- Utah has 11 stream classifications, Two quired the States to designate areawide pol- streams in and around oil shale tracts U-a lution control planning agencies. The Colora- and U-b, Evacuation Creek, and the White do West Area Council of Governments and River, are classified as CW (i.e., warm water the Uinta Basin Council of Governments have fisheries). Their waters are suitable for all been designated for the oil shale region. These agencies are to plan, promulgate, and *Prim:~rV ronttirl rerrc:)tifjn includes sw imrnin~, water ski- ing. and diving. implement a program designed to protect surface water quality. Stream classifications Table 57.–Colorado Water Quality and water quality standards are to be devel- Standards for Stream Classification B2 oped. The multiple-use classifications proposed for streams, which may supersede ex- Parameter Criteria for B2 streams isting classifications previously discussed, in- Settleable solids floating solids Free from clude: taste, odor, color and toxic materials ● Class I—aquatic life, water supply, Oil and grease Cannot cause a film or other discoloration recreation, and agriculture: Radioactive material Drinking water standards ● Class II—water supply, recreation, and Fecal conform bacteria Geometric mean less than 1,000 agriculture; units per 100 milliliters ● Turbidity Cannot increase more than 10 Class III—recreation and agriculture; units and pH 60 to 90 ● Class IV—agriculture. Temperature Maximum 900 F Change Streams 50 F The respective water quality criteria are Lakes 30 F shown in table 59. The classifications and the SOURCE E R Bates and T L Thoem (eds I Po/JufIorI ConfroI Go(dance for 01/ Sbd/e De,e)op quality criteria will apply to all streams in the rnenl Append/x Environmental Prolecl(on Agenc j Clnc(nnatl Ohio JuIy 1979 p D 20 oil shale region. 302 ● An Assessment of 011 Shale Technologies

Table 59.–Proposed Water Quality Criteria for Designated Uses

Parameter Water supply Aquatic life/ wildlife Recreation Irrigation Livestock a — — Alkalinity as Ca CO 3 ., ., . – 30-130 mg/l Aluminum-total ...... – 0.1 mg/l . 5.0 mg/lb, 20.0 mg/la C 5.0 mg/la Aluminum-dissolved ... ., – 0.1 mg/la — — Total ammonia as N, ., ., ., ., 0.5 mg/la — — — — Unionized ammonia as N . – 0,02 mg/l — — — Arsenic-total ., ., 0.01 mg/l 0.05 mg/l — 0.1 mg/l 0.2 mg/ld Barium-total, . 1,0 mg/l — — — Beryllium-total ., ... – 1,1 mg/l — 0.1 mg/lb, 0.5 mg/lC d — Boron ., ., . . ~ ~ ~ ., 1.0 mg/la — — 0,75 mg/le 5.0 mg/ld Cadmium-total ... ., ., ., ,0,01 mg/l 0.003 mg/l — O.O1b, 0.05 mg/lC 0.05 mg/ld Chloride-total. 250 mg/l — — — Chromium-total . . . 005 mg/l 0.3 mg/lf — 0.1 mg/lb, 1.0 mg/lC d 0.1 mgll Fecal coliform ., ., 2,000/100 ml f 2,000/100 mla 200/100 ml 1 ,000/100 ml 1 ,000/100 ml Color, ., ... ., ., .75 color unitsa — — — Copper-total. . ., ., .1.0 mg/l 0.030 mg/l — 0.2 mg/lb, 5.0 mg/lC 0.5 mg/ld Cyanide...... , . ., .020 mg/l 0.005 mg/l — 0.2 mg/l 0.2 mg/1 Hardness ., ., ., ., ., – — — — — Iron-total. ., ., . – 1.0 mg/l — 5 mg/lb, 20 mg/la C — Iron-dissolved ., ... ..03 mg/l 0.3 mg/la — — — Lead-total ., 0.05 mg/l 0.03 mg/l — 5 mg/lb, 10 mg/lC f 0.1 mg/1 Manganese-total ...... 0,05 mg/l 1,0 mg/l — 0.2 mg/lb, 10 mg/lC d — Manganese-dissolved ., 0,05 mg/l — — — Mercury-total. ., ...... 0,002 mg/l 0,00005 mg/l — 0.00005 mg/la Molybdenum-total — — — 0.01 mg/lb, 0.05 mg/lC 0.5 mg/1 Nickel-total ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ – 0.1 mg/l — 0.1 mg/lf — Nitrate-tl, 10 mg/l — — 100 mg/l NO, + NO, 100 mg/1 Dissolved oxygen .. ~ ~ ~ ~ ~ ~ ~ ~ 40 mg/lf 5.0-6.0 mg/l min. 2,0 mg/l min. 2.0 mg/l 2.0 mg/1 pH ...... 5.0-9.0 6.5-9.0 6.5-9.0 4.5-9.0 a — Phenols ~ ~ 0.001 mg/l 0.001 mg/l — — a — — Total PO4 -P ., ~ ~ ~ ~ ., – 0.025 mg/l - Iakes Phthalate esters – 0.003 mg/l — — — PCB ., ., – 0.000001 mg/l — — — Selenium-total ., . 0.01 mg/l 0.05 mg/l — — O 5 mg/1 Silver-total. ., ., . . 0.05 mg/l 0,0001-0,0025 mg/lg — Silver-dissolved – 0.0001 mg/l — Sodium ., ., ~ ~ .270 mg/la h — — — Sulfate-total. ., . ., ., ., 250 mg/l — — — — TDS ., ., 500 mg/la — — (1) 3,000 mg/la TSS ... ., ., ., – 25 mg/l-medianj — — — H 2 S (undissociated) ., ., ., 0.05 mg/l 0.002 mg/l Temperature ...... , – (k) — — Zinc-total. ... . 5.0 mg/l 0.03 mg/l — 2,0 mg/l 25 mg/ld

Unless otherwise mdtcaled the recommended cr!tena correspond with proposed State standards hMaxlmum concentration for a moderately restricted sodwm diet aCWA 208 recommendation only (no proposed State standard) Iwaler from which no detrimental effects WIII usually be nohced 500 mg/1 bCon11nuou5 Irrlgatlon, atl sods (match WOCC proPosed State standards) Water which can have detrimental effects on sensdwe crops 500-1000 mg/1 cshofl.~erm {rrlgatlon, neutral to alkaline fme Iexlured soils Waler that may have adverse effects on many crops and requires careful management dFor agrlcultura[ uses the WOCC except In a few Instances dld not dlshngulsh between lrrl9a- prachces f ,000-2000 mg/1 tion and hvestock uses The CWA 208 attempted 10 distinguish the differences Therefore, under Water fhat can be used for folerant plants on permeable SOIIS wlfh careful management hvestock there are numerous differences between 208 and WOCC numbers Under Irrlgatlon The prachces 2,000-5000 mg/1 lower recommended crlterla match Wf3CC numbers IValue represents maxtmum Increase In amblenf concentraflon due 10 discharge eLong.term Irrlgatlon on sensltwe crops kC,old water maximum IS 200 C, warm water maximum IS 30° C, and both Categories hmlt temper- fDlffers from proposed State standards ature changes to 3° C gLlmitlng concentration dependent on hardness

SOURCE E R Bates and T L Thoem (eds I Po//uf/orI Cmrfro/ Gu/darrce for 01/ Sfra/e Oeve/oprrrerrl Append/x, Enwronmental Protection Agency, Clncmnal{, Ohio. July 1979 pp D-29-D-30

The Safe Drinking Water Act of 1974 gram for ground water protection. It is administered by EPA and by the States. This Act protects drinking water systems through primary and secondary ambient The primary standards are intended to standards, monitoring programs, and a pro- protect health to the extent feasible, given the Ch 8–Environmental Considerations ● 303 restraints of existing treatment techniques Table 61 .–Proposed Secondary Drinking Water Regulations and their costs. Interim standards were is- Pollutant Proposed level Principal effects sued by EPA during 1975 and 1976 and were Chloride 250 mg/l Taste put into effect in June 1977 (see table 60). Color 15 color units Appearance These standards established both maximum Copper 1 mg/l Taste, fixture staining Corrosivity (Noncorrosive) Deterioration of pipes, unwanted contaminant levels and monitoring require- metals in drinking water ments for 10 inorganic and 6 organic chemi- Foaming agents O 5 mg/l Foaming, adverse appearance cals, radionuclides, microbiological contami- Hydrogen sulfide O 05 mg/l Taste, brown stains on laundry nants, and turbidity. A study by the National and fixtures Manganese .005 mg/l Taste, brown stains, black Academy of Sciences of the health effects of precipitates drinking water contaminants is to be the basis Odor 3 threshold Odor for revised primary standards. The study was odor number pH ., .. 65-8.5 mg/l Corrosion below 65. incrusta- completed in June 1977, but the revised tions, bitter taste, lowered standards have not yet been issued. germicidal activity of chlorine over 8.5 Secondary standards, published in 1977, Sulfate 250 mg/l Taste, Iaxative effects deal with contaminants that affect the odor Total dissolved solids 500 mg/l Taste, reduction in Iife of hot water and appearance of water but do not directly heaters, precipitation in cooking affect health (see table 61). They are not fed- utensils erally enforceable and are only guidelines to Zinc 5 mg/l Taste the States. The States may include monitoring SOURCE E R Bales and T L Thoem teds I Po//ufIorI Conlrol Gwdance for 0/1 S/We Uevekm rr?er?f Append/x Enwronmen[al ProtectIon Agency Clnclnnafl Ohio July 1979 0 requirements in their laws and regulations. D 33

Ground Water Quality Standards Table 60,–Primary Drinking Water Standards (mg/l) Federal.—The Safe Drinking Water Act Maximum concentration Inorganic chemicals (except fluoride) applies to deep-well injection of waste into Arsenic 005 aquifers with less than 10,000 mg/l TDS that Barium 10 are, or could become, sources of public drink- Cadmium 001 ing water. Seepage from pits, ponds, and la- Chromium 005 Lead 005 goons is not regulated at this time. Mercury 0002 Nitrate (as N), 100 Colorado. -No specific standards have Selenlum 001 been promulgated for ground water quality. Silver. ., 005 However, the basic standards applicable to Fluoride (degrees Fahrenheit) all other State waters do apply. Regulations 537 and below 24 are being developed that will limit the dis- 53.8to 583 ., 22 charge or injection of some contaminants. 584 to 63.8 20 63.9 to 70,6 1.8 Permits are now required for injection wells, 70.7 to 792 16 and they will be required in the future for 79 3 to 90.5 14 wastewater disposal in pits, ponds, and la- Chlorinated hydrocarbons Endrln 0.0002 goons if there is a possibility of discharge to a Lindane 0.004 ground water system. Methoxychlor 0.1 Toxaphene 0.005 Utah.—Utah also has no special standards Chlorophenoxys for ground water. However, ground water is 2, 4-D (2, 4-dichlorophenoxyacetic acid). 0.1 2, 4, 5-TP (Silvex) 0.01 considered part of the State waters, so general water quality standards do apply. Dis- SOURCE E R Bates and T L Thoem (eds ) Po//u1/on Comrol Gwdaoce for 011 Shale Develop menf Append/x Enwronmental Protecllon Agency Clnclnnall Ohio July 1979 pp D- charges to sources of potable water must not 32-D-33 cause the water quality to exceed drinking water standards. 304 ● An Assessment of 0il Shale Technologies

Implications of Water Pollution Control Standards mosis, electrodialysis, thickening, and evap- and Regulations for Oil Shale Development oration. As indicated above, the primary objective Chemical treatment devices use chemical of the Clean Water Act is to eliminate the properties or chemical reactions to remove discharge of pollutants into navigable waters contaminants. Such systems can destroy haz- by the late 1980’s. In order to accomplish this ardous substances that are not amenable to objective all potential polluters, including oil conventional physical and biological systems. shale developers, will be required to apply For oil shale wastewaters, the most impor- BAT, BPT, and NSPS. Point source discharge tant devices are those that could oxidize or- is well-regulated under the Act, and it is ex- ganic compounds or reduce salt concentra- pected that oil shale developers would comply tions. Included are ion exchange, wet air oxi- with the stipulations promulgated in regard dation, photolytic oxidation, electrolytic oxi- to NPDES. As will be discussed in the follow- dation, and direct chemical oxidation. ing section, the pollution control technologies that are being applied to oil shale wastewater Biological treatment devices contact a effluents are designed for zero discharge. waste with a population of micro-organisms However, in some instances (e.g., excess wa- that digest its organic contaminants. By con- ter from mine dewatering) it will need to be trolling the size of the population, and by ad- discharged back into surface waters or rein- justing oxygen and nutrient levels and equal- fected into underground aquifers. In this izing the conditions of the entering stream, it case, water will have to be treated to meet is possible to develop and acclimate micro-or- the standards stipulated under the NPDES ganisms that can nearly eliminate many haz- permit system or by the Safe Drinking Water ardous organic compounds. Biological treat- Act for reinfection—that is surface and ment systems can be divided into two groups: ground water quality criteria and water use classifications will have to be maintained as ● aerobic processes (such as activated stipulated by the States and EPA. In addition, sludge, trickling filters, rotating biologi- it is expected that oil shale facilities will have cal contractors, aerated lagoons, com- to meet NSPS comparable to those developed porting, and stabilization ponds) in for petroleum refining facilities. which the population is maintained under oxygen-rich conditions and the or-

ganic compounds are decomposed to CO2 Technologies for Control of Oil Shale and water; and

Water Pollution ● anaerobic processes (such as digestion) in which oxygen levels are relatively low Treatment of Point Sources* and the organic compounds are de- Contaminants may be removed from waste- graded to CO and methane gas. water by physical, chemical, or biological Treatment systems.—Most devices can re- means. For complex wastes, a series of de- move some but not all contaminants. In a vices using each of these principles will be treatment system, different wastewaters are necessary. sent to different devices, each of which re- Physical treatment devices apply gravity, moves a specific type of pollutant, The rela- electrical charge, and other physical forces tionships among contaminants, the streams in to contaminants to remove them from waste- which they are likely to occur, and the treat- water. Typical operations are gravity separa- ment processes of choice are shown in table tion, air flotation, clarification, filtration, 62. Although all contaminants may be found stripping, adsorption, distillation, reverse os- in nearly all streams, the streams associated with each contaminant have been limited to *De!ails of the various technologies are described in app. D. those in which concentrations will be high Ch. 8–Environmental Considerations 305

Table 62.–The Types of Contaminants in Oil Shale Wastewater ments. Mine drainage water may contain only Streams and Some Potential Processes for Removing Them dissolved solids. . . , Contaminant Stream Potential process The removal efficiencies, reliabilities, Suspended solids Mine drainage Clarification adaptabilities, and relative costs of some Retort condensate Filtration Cooling tower blowdown point source control devices are summarized Oil and grease Retort condensate Gravity separation in table 63. This information comes almost en- Gas condensate Emulsion breaking tirely from experience in other industries. Coking condensate Few of the technologies have been tested with Dissolved gases Retort condensate Steam stripping Gas condensate oil shale wastewaters, and none has been Coking condensate tested in the complex treatment trains that Dissolved inorganics Mine drainage Chemical oxidation will be necessary to deal with the wastes that Retort condensate Ion exchange will be encountered in commercial-scale oil Gas condensate Reverse osmosis Cooling tower blowdown Adsorption shale plants. The degree of adaptability of Ion exchange regenerants Evaporation each technology is particularly important Dissolved organics Retort condensate Solvent extraction because it indicates the likelihood that the Gas condensate Adsorption technique will transfer without difficulty to Coking condensate Biological oxidation Hydrotreating condensate Ultrafiltration the oil shale situation. Reverse osmosis Wet air oxidation Most suitable technologies.—The follow- Trace elements and Retort condensate Chemical oxidation ing technologies appear most suitable: metals Gas condensate Ion exchange Adsorption ● for oil and grease: dissolved air flotation Trace organics Retort condensate Ultrafiltration or coalescing filters; Gas condensate Reverse osmosis ● for dissolved gases: air or steam strip- Upgrading condensate Adsorption ping; TOXiCS Retort condensate Chemical oxidation Gas condensate Incineration ● for dissolved organics: rotating biologi- Upgrading condensate cal contractors or trickling filters for Sanitary wastes Domestic service Biological treatment first-stage removal, carbon adsorption,

SOURCE R F Probsleln H Gold and R E Hicks Wafer Reauwernertfs Po/kJ//on Effects and or wet air oxidation for polishing; Costs of Wafer Supp/y and Trealrnen( for the 0// Sha/e /ndusfry prepared for OTA by ● or Water Purlflcatlon Associates October 1979 for suspended solids: pressure multimedia filtration; ● for dissolved solids: reverse osmosis for first-stage removal, clarification for sec- enough to require removal prior to discharge ond-stage, and ion exchange for polish- or reuse. 37 38 ing; and ● for sludges: filtration and evaporation. Many of the devices listed in table 62 have been tested individually on oil shale wastewa- Costs.—Control costs depend on the oper- ters and have been found to provide some de- ating characteristics of the oil shale facility gree of control. 39-50 Of great importance is the and on the treatment methods selected. The performance of these units when combined to only published cost estimates were prepared form a “treatment train” for a specific for the Department of Energy (DOE). These wastewater. A separate train—consisting of estimates, upgraded for OTA to include the several individual treatment devices in cost of treating excess mine drainage water, series—will be needed for each stream be- appear in table 64. Total treatment costs cause, in general, each will contain different range from about $0,25 to $1 .25/bbl of shale types of contaminants, Each contaminant will oil syncrude. The low estimate applies to require a different type of removal process. aboveground retorting plants; the high to MIS For example, retort condensates may contain facilities in ground water areas. Although suspended solids, oil and grease, dissolved sizable, the control costs should not them- gases, organics, inorganic, and trace ele- selves preclude profitable operations. 306 ● An Assessment of Oil Shale Technologies

Table 63.–Relative Rankings of the Water Treatment Methods

Contaminant Technology Removal efficiency, % Relative reliability Relative adaptability Relative cost 011 and grease Dissolved air flotation 90 Very high Very high Medium Coalescing filter 99 High High Medium Clarification 80 Very high Very high High Dissolved gases Air stripping 80 High High Medium Steam stripping 95 Very high High Medium Flue gas stripping 95 High Medium Medium Biological oxidation High Medium Medium Low Dissolved organics Activated sludge 95 BOD/40 COD High Medium Low Trickling filter 85 BOD High Medium Low Aerated lagoon 80 BOD Medium Medium Low Rotating contactor 90 BOD/20-50 COD High Medium Low Anaerobic digestion 60-95 BOD High Medium Medium Wet air oxidation 64 BOD/74 COD Medium High Very high Photolytic oxidation 99 BOD Medium Very high Very high Carbon adsorption 99 BOD Medium High Medium Chemical oxidation 90 BOD/90 COD Very high Very high High Electrolytic oxidation 95 BOD/61 COD Medium Very high High Suspended solids Clarification 50 High High Medium Pressure filtration 95 High High Medium Multimedia filtration 95 Very high High Low Dissolved solids Clarification Low except for metals High Medium Medium Distillation 99 Medium Low Very high Reverse osmosis 60-95 Medium Medium Medium Ion exchange High High Low High Electrodialysis 10-40 Medium Medium Very high Sludges Thickening Product 6-8% solids Very high High Medium Anaerobic digestion Low High Medium Medium Vacuum filtration Product 20-35% solids High High High Sludge drying beds Product 90% solids Medium Low Medium Evaporation basins Product 95% solids Very high Low Low Filter press Product 35% solids Very high High High Aerobic digestion Low Low Low High

SOURCE Adapted from 4ssessrnerU of 0// Sfra/e Rerorf Wasfewa(er Trealrneru and ConVo~ Tec/rno/ogy, Hamllfon Standard Owlslon of Uruled Technologies July 1978 pp 2-12 to 2-24

Table 64.–Estimated Costs of Water Pollution Control in torts. For an aboveground retorting facility, Oil Shale Plants ($/bbl of shale oil syncrude)a the leaching problem may be reduced by dis- Above- Above- posal of the solid wastes in canyons, and cap- -ground ground MIS/ turing and treating any leachate that does oc- Wastewater stream direct indirect MIS aboveground cur. (See figure 61. ) It is hoped that the Gas condensate $0.11 $0.13 $0.45 $0.31 Retort condensate – — 0.13 0.09 moistened and compacted spent shale will be Upgrading impermeable to the flow of water. The top of condensate 0,12 0.12 012 0.12 the pile will be covered with topsoil or Excess mine drainage ., . – — 0-0.55 0-0.55 another growth medium that will be perme- Total . . ., $0.23 $0.25 $0.70-1.25 $0.52-1.07 able but that will not contain substantial aplants produce 50,1NI btjltd Of syncrude Aboveground plants are assumed to be not located In quantities of soluble contaminants. Any ground water areas Cost estimates include operating expenditures and capital amorhzatlon They also include nonwastewater costs such as botler feedwater treatment costs leachates that reach the catchment basin SOURCE R F Probste!n, H Gold and R E Hicks, Wafer Requwernerrk, Po//u(/on Effecls and would be treated. This method may be effec- Cosk O( Waler Supp/y and rreatrnerrl for the 00 Sha/e /ndus/ry, prepared for OTA by tive Waler Purlflcatlon Associates, October 1979 during the lifetime of the facility.

Control of Nonpoint Sources Tests of these control strategies have not simulated conditions of commercial-scale dis- The major potential nonpoint sources are posal piles, and past research investigations leachates from aboveground storage of raw are limited in their applicability. Questions or spent shale and from abandoned in situ re- persist concerning shale pile permeability, Ch 8–Environmental Considerations ● 307

Figure 61 .—An Aboveground Spent Shale ations, they might serve as a primary method Disposal Area for reducing leaching. Several uncertainties prevent assessing the feasibility of this ap- ‘+\ proach. For example, the mineral complexes \’ -- produced in the field would have to remain in- 1 soluble for long periods of time even if the Processed Shale = retorts were backflooded. Also, to eliminate -— Disposal Pile \’ leaching, all of the spent shale in the retorts Leachate Ditch -- $ would have to be insoluble. Because control ; + \\ of MIS retorting is difficult, portions of the

\\ retorts may not become hot enough to pro- Drainage~~ D!tch , q%// . , ,\ duce the insoluble complexes. Control of re-

/’ torting temperatures in TIS processing is y{//)’)’y”Leachate Ditch even less certain. Since there would be mas- ‘/ ‘/ sive amounts of waste, increased percolation ‘ / //;/ / / / /’ by ground water, and thus greater leaching .— - ‘ /,$? ///’.?-#/ // )/ ,/ / Q potential, these uncertainties may mandate /// -—— Leachate Catch Basin ;:::~&4/////7T~/ the adoption of retort abandonment strate- — Retention Dam gies. —-.:”&/ il ---–– l\ \ Retorted shale can form a cement-like ma- \\, Emergency Spillway terial if it is properly prepared, and water ‘\ \ ‘~. slurries of finely crushed retorted shale could \ / ‘\ be injected into burned-out retorts to fill void :&b‘\( \\ \ areas and to make the spent shale imper- SOURCE: Surface Mining of Non-Coal Minerals, National Academy of meable to water flow. To prevent leaching, Sciences, Washington, D C., 1979, p. 126, the cement formed from the injected slurry would have to have very low permeability; erosion potential, reclamation effectiveness, otherwise, the cement itself might produce a and the balance between erosion and soil pro- troublesome leachate, thereby compounding duction rates. Water and leachates may per- ground water pollution, Distributing the slur- colate into underlying alluvial aquifers. * ry uniformly within the retort may also prove These effects need careful monitoring at difficult. pioneer commercial facilities. Another approach would be to pump fresh- The efficacies of these control strategies water through the retort to intentionally after site abandonment are even less certain. leach out the soluble components. The leach- Long-term monitoring and custodial care may ates could be treated and then reinfected on a be required to assure that contaminants are downgradient from the retorts. It is possible not released from the catchment basin as a that leaching could be accelerated in this result of dam failure or extraordinarily heavy way, but the process might be costly and time- rainfall or snowfall, consuming and the technology has yet to be For in situ processing, laboratory experi- developed. ments indicate that high temperatures con- “Hydrologic barriers” might be used to vert soluble solids in spent shale into insolu- prevent or control the flow of water into the ble mineral complexes. If such temperatures retort area, thereby preventing the disper- could be achieved in commercial-scale oper- sion of leachates. One possibility is drilling a continuous series of holes around the retort *rI’here are other techniques as well, For example, preleach- area and filling them with a cementitious ing of spent shale, capillarv brakes, and covering spent shale with open pit overburden, See the section on land reclamation slurry. By itself, this technique may not be ful- in this rhapter for more detail. ly effective since the retorts may be in aqui- 308 . An Assessment of Oil Shale Technologies fers in which water moves vertically. The ef- Treated cooling tower wastewater could fectiveness could be increased by cementing be reused after dilution with other treated (grouting) the retorts to seal their more per- streams. Treated gas condensates are also meable zones and fractures. suitable for cooling water because they should have low concentrations of inorganic Another possibility would be to divert a contaminants and volatile organics. Retort major portion of the ground water flow condensates could also be used after their around the retort area. In this “hydraulic by- dissolved substances are removed. pass” option, artificial channels or barriers would capture most of the ground water flow- Water quality criteria have not been estab- ing toward the retort area, direct it around lished for dust control, shale disposal, or the area, and then return it to the ground wa- revegetation, but water similar to river water ter system. would probably be acceptable. It should be possible and practical to treat gas conden- Ultimate Disposition of Wastewater sates to this level. Treated retort condensates should also be acceptable, although success- At present, no developer plans to discharge ful treatment has yet to be demonstrated. wastewaters to surface streams; rather, the Steam raising, for example, with the thermal final wastes will be disposed of by recycling, sludge system, is at present a more reliable evaporation, and reinfection. In the future, option. These condensates (either treated or consideration may be given to treating and untreated) could also be used as a slurry discharging all surplus process waters. This medium for grouting in situ retorts. Tests would be much more expensive than treat- would be needed to determine if the waste- ment to industrial standards, but it would re- water contaminants were truly immobilized duce the impacts of development by augment- so that they could not be leached by ground ing stream flows in a water-short region. If water. this option is adopted, water treatment needs will increase significantly and highly efficient Evaporation treatment methods will be necessary. Most of the wastewaters will be disposed Recycling of in dust control and in the waste disposal piles. The sludges and concentrates from Present developer plans call for treating wastewater treatment will also be added to and recycling wastewaters whenever practi- the disposal piles. In essence, this converts a cal. This depends only on the ability of waste point source of pollution, which would be treatment systems to purify the wastewaters highly regulated under existing laws, to a so that they could be reused in other portions nonpoint discharge, which is not well-regu- of the process. Nearly all of the wastewaters lated at present. However, the treated waste- could be reused after appropriate treatment waters would be quite different from the raw for cooling tower makeup, for dust control, streams described in table 51. For example, for shale disposal, for leaching, for revegeta- most of the NH3 and H2S will have been re- tion, and for generating steam that could be moved from the gas condensates and recov- injected into either aboveground or in situ re- ered as byproducts. The CO2 will also have torts. As discussed previously, efficient, reli- been removed and vented to the atmosphere. able, adaptable, and cost-effective methods The concentration of NH3 could be further re- appear to be available for the major contami- duced by biological treatment and by using nated streams. Their capability of treating the treated condensates as cooling water. the wastes to discharge or reinfection stand- The small quantity remaining may be useful ards is not relevant as long as the streams are as fertilizer for reclaiming the waste disposal to be recycled. areas. Most of the potentially harmful organ- Ch. 8–Environmental Considerations 309

ic compounds could be removed by biological Monitoring Water Quality treatment and the more resistant ones by adsorption. However, some organic matter is Because much surface water comes from likely to reach the shale disposal area. It is ground water discharge, it is necessary to not known whether the organics will remain monitor both surface and ground water to locked within the shale pile or will be help prevent environmental damage. Moni- leached. toring provides a continuous check on compliance with regulations, a record of changes re- Similar treatment could be used for the resulting from development, and a measure of torting and upgrading condensates, although the effectiveness of pollution control proce- the chemicals in the retort condensate could dures. pose some special treatment problems. If thermal sludge systems were used, both the inorganic and the nonvolatile organic contam- Surface Water Monitoring inants would be reduced to a stable sludge Surface water monitoring should include: suitable for disposal in a sanitary landfill or in a hazardous-waste disposal area. The vola- ● instream sampling and chemical anal- tile organics would be entrained in the steam ysis to detect and characterize pollut- and subsequently incinerated in the retorts. ants of point and nonpoint origin: ● detection of spills and faulty contain- Reinfection ment structures that could result in accidental discharges; Reinfection may be legally allowed if the ● measurement of streamflows to assess quality of the injected water is at least as effects of dewatering operations and high as that in the affected aquifer. Injection consumptive uses; and of condensates or other highly contaminated ● measurement of aquatic biota to deter- wastes would not be permitted without a high mine the changes resulting from develop- degree of treatment, However, mine drainage ment, water might be reinfected if it had not been degraded by evaporation or chemical change A monitoring program is defined by the while on the surface. Otherwise, it first number and location of sampling stations, the would have to be treated or diluted. parameters measured, the sampling frequency and collection methods, the accuracy and Until commercial-scale oil production be- precision of the analytical techniques, and gins, essentially all mine drainage water will the quality assurance safeguards. Tradition- require disposal, probably by reinfection. It is al monitoring methods may not be well-suited generally assumed that the chemicals in the for the oil shale situation. The uncertain drainage water would not cause significant pollutant release rates and pathways and the changes in the quality of the source aquifers. wide variations in regional water quality, However, water quality could be degraded complicate the development of a suitable pro- because of the increased ground water flow, gram and limit the use of conventional tech- the exposure of new mineral surfaces by niques. fracturing, and the changes in underground microbial populations. If such changes oc- The number and location of sampling sta- curred, the treatment or disposal conditions tions depend on the objective of the monitor- would have to be adjusted to compensate for ing program. For example, if the objective is them. 51 This might include treating the drain- to detect changes over an entire basin, the age to a purity higher than that of the source stations would be located in the lower aquifer. reaches of major tributaries. They could de- 310 An Assessment of Oil Shale Technologies tect major changes but would be unable to Ground Water Monitoring pinpoint their cause. In contrast, stations near pollution sources could both measure Observation wells are used to detect the local effects of pollutant discharge and trends in water quality and to measure the ef- identify the source. An oil shale program fects of operations such as wastewater rein- could include stations on major streams, as fection. The locations of the monitoring sta- well as on the minor tributaries that drain tions should be selected according to: each development site. Special stations are ● the locations of the potential pollutant also needed near solid waste disposal areas sources; to detect leaching. ● the geology and hydrology of the site to The selection of chemical, physical, and be monitored; biological parameters to be measured will be ● the probable movement and dispersion based on the types and concentrations of pol- of pollutants underground; and lutants that might be discharged, the ease of ● the potential for hydrologic disturbances analysis, and the characteristics of the water of, for example, dewatering wells. in the affected streams and aquifers. The EPA has developed a monitoring methodology possible parameters include the concentra- for the oil shale area.52 The important con- tions of the pollutants themselves as well as siderations are: the levels of “indicator” parameters that provide a measure of the potential environmental ● the identification of potential pollutants; ● disturbance. These include pH, dissolved ox- the definition of hydrogeology, ground ygen, hardness, temperature, flow rate, and water use, and existing quality; ● the characteristics of the aquatic biota. the evaluation of the potential for infiltration of wastes by seepage; Biological parameters are especially useful ● the evaluation of pollutant mobility in because they reflect the stability and re- the affected aquifers; sponse of the ecosystem. Aquatic organisms ● the priority ranking of pollution sources are natural monitors of water quality since based on the mass, persistence, toxicity, they respond in a predictable manner to the and concentration of the wastes; their presence of most types of pollutants. Changes mobility; and their potential for harm to may indicate problems that are not easily water users; and detected by direct measurements of water ● the design and implementation of pro- quality. For example, heavy metals and some grams for near-surface aquifers, deep organic compounds tend to concentrate in the aquifers, and injection wells. biota. Their levels in the tissues of certain fish could help predict pollution concentra- The siting of wells for near-surface aquifers tions that are not readily measurable in the is extremely important. They should be water itself. Communities that could be moni- placed down the ground water hydraulic gra- tored include invertebrates, fish, algae, and dient (i.e., “downstream”) from possible pol- bacteria. lution sources such as reinfection wells, reservoirs, and disposal piles. The wells should The sampling frequency can also vary. allow sampling from different depths, and the Ephemeral tributaries, for example, could be chemical and physical parameters should be monitored only during periods of heavy rain- selected according to hydrological character- fall or snowmelt; mainstream tributaries istics as well as the properties of potential could be monitored continuously. Frequent pollutants. Deep aquifers should be moni- monitoring of all possible parameters would tored near dewatering wells, in situ retorts, be very expensive and time-consuming. and reinfection wells. Monitoring of salinity, Therefore, priorities must be established on TDS, and water level should be emphasized. the basis of cost, utility of the data, and the Monitoring deep aquifers in the Piceance potential for severe environmental impacts. basin is especially difficult because the — —

Ch, 8–Environmental Considerations ● 311 ground water flows through fractures and Need for Reliable Data on Wastewater Quality faults and not through the more common uniformly porous media, A further complication Reliable data are lacking on the charac- is the different permeability of adjacent teristics of the gas, retort, and upgrading strata. Even flow rates are hard to measure condensates from all of the proposed de- in a fractured-rock system, and it is difficult velopment technologies. The data should be to properly site the monitoring stations. obtained with pilot plants that integrate several streams and several control devices and The monitoring of surface and ground wa- that simulate commercial-scale conditions. ter quality is exemplified by the program on In commercial plants, wastewaters may be Federal lease tract C-b that has been under- mixed and the interactions of contaminants way since 1974. The sampling schedule and from the different streams will affect treat- water quality parameters are listed in table ability. Therefore, analyses of separate 65. Thirteen surface water gauging stations streams are not sufficient. have been constructed: nine on ephemeral More reliable estimates are needed of the streams and four on perennial drainages. quality and quantity of the mine drainage Nine springs and seeps are also monitored. water that will be encountered in specific Temperature and conductivity are measured areas. This information would help determine continuously at all stations on the perennial how the water would have to be treated for streams. Dissolved oxygen, pH, and turbidity surface discharge, and would allow a com- are measured continuously at several of parison to be made between surface dis- these stations; other parameters are meas- charge and other disposal methods. ured monthly, quarterly, or semiannually. Studies of leachates are also needed; in Water levels in alluvial aquifers are meas- particular, on their ability to penetrate the ured continuously at 18 test wells. Conduct- linings of disposal ponds and catchment ba- ance, pH, temperature, and dissolved oxygen sins. will be measured monthly. The quantity and quality of water in the deeper bedrock aqui- Need for Assessing Control Technologies fers are measured at 17 wells in the upper aquifer and 14 in the lower aquifer. Samples Although individual methods have been are obtained for water quality twice a year, tested successfully on a small scale, the per- and water levels are measured monthly. Wa- formance of an integrated treatment system ter quality is also measured in reservoirs, has yet to be evaluated with actual effluent waste disposal piles, and mine sumps. streams. This could be done, for example, by testing relatively inexpensive pilot-scale systems as part of a retort demonstration pro- Information Needs and R&D Programs gram. These tests would help determine, for example, if the dissolved organics in retort Insights into the water quality impacts of condensates can be adequately controlled oil shale development have been obtained with a series of conventional treatment proc- from laboratory and pilot plant studies, from esses. The distribution and control of trace a few field tests in the Piceance basin, and elements could also be assessed. from experience in related industries. Addi- tional measurements and R&D programs are Need for Cost Information needed to help reduce the level of uncertainty. Uncertainties will remain, however, until According to present estimates, wastewa- experience has accumulated from commer- ter treatment costs are expected to be only a cial-sized modules and plants. small fraction of the total cost of shale oil pro- —— —— — -.. —

312 An Assessment of Oil Shale Technologies

Table 65.–Sampling Schedule Summary for Surface and Ground Water Monitoring Program at Tract C-b During Development Phase Surface water Seeps and springs Ground water Alkalinity ., ... M(Z), Q(O,PC) o Q(Al), SA(Aq) Ammonia ., ., ~ ., M(Z)Q(o,PC) Q Q(Al), SA(Aq) Arsenic. ... ., ., . ., ., M(Z)O(o,PC) Q Q(Al), SA(Aq) Barium . ., ... ., — — (Lisa Beryllium ... Q — A(AI) Bicarbonate ...... ,. .,, ,,, ,., M(Z) Q(o,PC) — — BAD. , .,.,.,,...... ,,.. . . . — Q SA(Al), SA(Aq) Boron ., ., ., . M(Z~Q(o,PC) Q Q(Al), SA(Aq) Cobalt. .,..,.,,, .,, ,, ..,,.,,..,,. — — SA(Aq) Color ., .,, .,, ,, .,, ..,.... .,,,,,, — — — COD...... Q Q Q(Al), SA(Aq) Coliform, total and fecal ., .,,.,,,,,. ., o s — Conductivity, specific, ,,. ,, . M Q(AI) Copper. , .,, .,... ,.,.,, . . Q Q Q(Al), SA(Aq Cyanide ..,.,,. .,, ,,, ..,.,, ,,,., Q — — Dissolved oxygen .,,.,. M(Z)Q(o,PC) M M(AI) Fluoride ., ., ., . M(Z), Q(o,PC) Q Q(Al), SA(Aq Hardness ,. .,.,, ,’,”’”. — Q Q(Al), SA(Aq Iron — Q Q(Al), SA(Aq Lead. ...’.., , .,,,, ‘, Q Q Q(Al), SA(Aq) Lithium. ,.,, ,.,, ,,..,,. Q Q Q(Al), SA(Aq) Magnesium, ,.,’...... M(Z), Q(o,PC) Q O(Al), SA(Aq) Manganese, ,,, M(Z) Q(o,PC) Q Q(Al), SA(Aq) Mercury. ., . . . . ., ., Q Q Q(Al), SA(Aq) Molybdenum .,.., ...... ,,, Q Q Q(Al), SA(Aq) Nickel. , ,,. ,., ..., ,. — Q Q(Al), SA(Aq) Nitrate ...... ,,. M(Z~Q(o.PC) Q Q(Al), SA(Aq) Nitrogen (Kjeldahl), ,.,,. M(Z), Q(o,PC) Q Q(Al), SA(Aq) Odor .,,, — — — Oil and grease, , , .,,, ,,. Q Q Q(Al), SA(Aq) Phosphate, , ...,, ,,. M(Z~Q(o,PC) — — Pesticides. .,... ,.., ,,. — . SA(Aq) Phenol ,.. ,,,. .,,. .,,, Q Q A(Al), SA(Aq) Potassium, ., ., ., ..., ., ., M(Z), Q(o,PC) Q Q(Al), SA(Aq) Radiation, alpha .,, ,,, ,,, Q s SA(Al), SA(Aq Radiation, beta ., ., Q s SA(Al), SA(Aq Sediment ,.. ,. ,“. M(Z), Q(o,PC) — — Silica ..,,, ,,. ,.., .,,,, M(Z), Q(o,PC) — — Sulfate ,. ,, ....,, M(Z), Q(o,PC) o Q(Al), SA(Aq) Sulfide o — — Suspended solids — — — Turbidity. . . . ,. .,.,,,, ,,, ,,,,.., — — — PA, ,, ., ..,.,.,, ..., ,,, M(Z), Q(o,PC) M,Q M,Q(AI) Total dissolved solids. . ,, ,. M(Z), Q(o,PC) Q Q(AI) Water level ., — — MESA Stream flow. ,, ...... ,’ M(Z) Q(o,PC) Q,SA,A — Water temperature .,.. M(Z) Q(o,PC) M,Q M, Q(Al), SA(Aq) Dissolved organic carbon ., ., M(Z) Q(o,PC) s SA(Al), SA(Aq) KEY A =AnnUa~y (Z) =Maorgaglng slationson~ SA = Semiannually (o) =Aflgagmg stations except major stahons S= Semimonthly (PC) =F?ceance Creek gaging stations O =Ouarferiy (Al) =Alluwal wells M =Monlhly (Aqj =Oeepaquders SOURCE E R Bales andT L Thoem(eds ) Pollution Con/ro/Gu/dancelor Oti Sha/e Deve/oprnerrl Apperrd/ces /o the l?ewsed L%a/(Reporl, comptiedby Jacobs Envwonmental Orw~onfor Envvonmental Protection Agency C{nclnnah Ohio July 1979 pp C-84-C-85 duction. However, inadequate attention to Lower cost treatment options should also water management could seriously impede a be explored. For example, the thermal sludge project’s construction and operation. Thus, system could significantly reduce treatment water treatment although not costly by itself costs by raising steam directly from process could ultimately cause substantial cost esca- condensates. Another promising procedure lations. is the removal of dissolved organics from Ch. 8–Environmental Considerations ● 313 treated condensates in the cooling water cir- development of reliable models and test- cuit. ing them under simulated worst case conditions, such as massive failure of a Discharging suitably treated wastewaters (especially excess mine water) to surface containment structure; and streams should be investigated as a mecha- research on the restoration of aquifers nism for supplementing the region’s scarce disturbed by in situ processing, water resources. Some of the contaminants in the treated wastes may require special atten- Current R&D Programs tion, and means to remove them should be ex- Below is a partial listing of the ongoing and plored. proposed R&D programs by the Federal Gov- ernment and the private sector: Need for Evaluating the Potential Impacts Under EPA grants, Colorado State Uni- of Effluent Streams versity is studying the water quality Information is needed on the impacts of the within the oil shale areas, the leaching pollutants on the environment. In particular, characteristics of raw and retorted oil research is needed on the effect of the leach- shale, and the surface stability and wa- ing of spent shale and other solid wastes on ter movement in and through disposal salinity, sediment loading, temperature, nu- piles. Specific objectives include devel- trient loading, and microbial populations of oping procedures for assessing the quan- surface waters. This work should address the tity and quality of surface and subsur- impacts that might occur both during the face runoff from solid waste piles. operation of a facility and after the facility’s Under an EPA contract, TRW and DRI useful lifetime. are studying the environmental impact of oil shale development, including an evaluation of technologies for waste- Specific R&D Needs water control. DOE’s Office of the Environment is as- Research is needed in the following speci- sessing water quality aspects of the fic areas: Paraho process. ● characterization of the wastewaters, es- DOE and the State of Colorado are devel- pecially for the presence of trace metals oping a program related to water pollu- and organic chemicals produced by each tion from MIS retorting. retorting process; Under EPA contracts, the Monsanto Re- ● determination of the applicability of con- search Corp. is investigating the treat- ventional treatment methods to oil shale ment of retort wastewaters and is study- wastewater and development of new ing the potential of in situ retorting for treatment methods if necessary; air and water pollution. ● determination of the changes in ground The National Bureau of Standards, in co- water quality and flows resulting from operation with EPA and other agencies, mine dewatering; is developing methods for measuring the ● development and demonstration of meth- environmental effects of increased ener- ods to prevent leaching of MIS retorts by gy production. ground water; In its oil shale program management ● studies to simulate and test the percola- plan, DOE has proposed to: tion of rainfall and snowmelt through —assess the effect of mine and retort spent and raw shales and native soils backfilling on ground water quality; and to assess resulting leachates; —study the leachability of raw and ● standardization of leachate sampling spent shale and the effect of disposal techniques; on surface and ground water quality;

6 3-89B ‘ - 80 - ? : 314 An Assessment of Oil Shale Technologies

—investigate the need for long-term should be well-suited to oil shale processes. It care of surface disposal areas; and is less certain that the conventional methods —design a solid waste disposal plan for would be able to treat wastewaters to dis- a commercial MIS facility. charge standards because they have not been ● The National Science Foundation is tested with actual oil shale wastes under con- sponsoring work to characterize the conditions that approximate commercial produc- taminants in spent shale and to develop tion. Furthermore, no technique has been techniques for managing them. demonstrated for managing ground water ● EPA is preparing a pollution control leaching of in situ retorts, nor has the ef- guidance document for an oil shale in- ficacy of methods for protecting surface dis- dustry, that will consider all aspects of posal piles from leaching been proven. It is surface and ground water quality. not known to what extent leaching will occur, but if it did, it would degrade the region’s Findings on Water Quality Aspects of water quality. Oil Shale Development Although control of major water pollutants from point sources is not expected to be a Water quality is of major concern in the oil severe problem, less is known about control shale region, especially in regard to the of trace metals and toxic organic substances. salinity and sediment levels in the Colorado Research is needed to assess the hazards River system. Oil shale development has the posed by these pollutants and to develop potential for water pollution, the extent of methods for their management. Other labora- which will depend on the processing technol- tory-scale and pilot plant R&D should be fo- ogies employed, the scale of operation, the cused on characterizing the waste streams, types and efficiencies of the pollution control determining the suitability of conventional strategies used, and the regulations that are control technologies, and assessing the fates imposed. of pollutants in the water system. Such work Surface discharge from point sources is is underway; its continuation is essential to regulated under the Clean Water Act, and protecting water quality, both during the op- ground water reinfection standards are being eration of a plant and after site abandon- promulgated under the Safe Drinking Water ment. Act. Solid waste disposal methods may be subject to the Toxic Substances Control Act Policy Options for and the Resource Conservation and Recovery Water Quality Management Act. The general regulatory framework is therefore in place, although no technology- For Increasing Available Information based effluent standards have been promulgated for the industry under the Clean Water Options for increasing the overall level of Act. information regarding pollutants, their effects, or their control include the evolution of Developers are currently planning for zero existing R&D programs, the improved coordi- discharge to surface streams and to reinject nation of R&D work by Federal agencies, in- only excess mine water. Most wastewater creasing or redistributing appropriations to will be treated for reuse within the facility; agencies to accelerate their surface and untreatable wastes will be discarded in spent ground water quality studies, and the pas- shale piles. The costs of this strategy are low sage of new legislation specifically tied to to moderate, and development should not be evaluating water quality impacts. For exam- impeded by existing regulations if it is imple- ple, pioneer plants receiving Federal assist- mented. ance could be required to monitor water qual- A variety of treatment devices are avail- ity effects, with particular emphasis on non- able for the above strategy, and many of them point discharges. Procedures for implementa- Ch. 8–Environmental Considerations . 315 tion could be similar to those for the existing ty about environmental regulations that is Federal Prototype Leasing Program. Mecha- now deterring developer participation. How- nisms for implementing these options are sim- ever, the standards would have to be careful- ilar to those discussed in the air quality sec- ly established to assure that they were both tion of this chapter. attainable at reasonable cost and adequate to protect the environment. Mechanisms for im- For Developing and Evaluating plementing improved regulation of nonpoint Control Technologies discharges include extension and modification of the Surface Mining Control and Recla- The Government could expedite the avail- mation Act for oil shale, special controls reg- ability of proven controls by accelerating its ulating nonpoint discharges under the Clean efforts to design, develop, and test treatment Water Act, or applying the Resource Conser- technologies for oil shale wastewaters. To be vation and Recovery Act waste disposal most effective, this work would have to be standards to low-grade/high-volume mate- coordinated with private efforts to develop rials. the oil shale processing methods. This could be done under cost-sharing arrangements, in- For Ensuring the Long-Term Management of cluding tests at the sites of retort demonstra- Waste Disposal Sites and Underground Retorts tion projects. (EPA is presently conducting a program for retorting wastewaters under a These areas may require monitoring for contract with Monsanto Research Corp. ) many years after the projects are completed. Long-term management could be regulated For Developing Regulatory Procedures under the Resource Conservation and Recov- ery Act, which allows EPA to set standards The present approach could be followed in for the management of hazardous materials, which regulations evolve as the industry and including mining and processing wastes. No its control technologies develop, An approach such action has yet been taken by EPA, but could also be used in which standards would Congress could direct it to do so. Congress be set that would not change for a period of could also require the developers to guaran- say, 10 years, after which they could be ad- tee such management by incorporating ap- justed to reflect the experience of the indus- propriate provisions in any bill encouraging try. This would remove most of the uncertain- oil shale development.

Safety and Health Introduction ● the health and safety hazards associated with oil shale operations; Anticipating occupational and environmen- ● the environmental risks if contaminated tal health and safety hazards is an important air and water are released; consideration in the development of an oil ● the applicable Federal health and safety shale industry. Anticipation and planning, es- laws, standards, and regulations; pecially in the early phases of the industry, ● the control and mitigation methods that should guide efforts to reduce health and could be applied to these risks; safety risks and costs to society. To bring at- ● the issues regarding the coordination of tention to known hazards, and to point out po- monitoring and education efforts; tential ones, this section covers the following ● the R&D needs; and subjects: ● the policy options. 316 “An Assessment of Oil Shale Technologies

Safety and Health Hazards may expose miners to risks that are not experienced in other underground mining ac- Occupational Hazards tivities. The hazard of mine flooding is not unique to oil shale, nor would it be encoun- Workers will be exposed to a number of oc- tered in all oil shale mines. However, it could cupational safety and health hazards during be severe in mines that are developed within the construction and operation of an oil shale ground water areas. While the mining zones facility. Many of these hazards—such as would be dewatered before mining could be- rockfalls, explosions and fires, dust, noise, gin, there could be flooding if the pumps and contact with organic feedstocks and re- failed. fined products —will be similar to those associated with hard-rock mining, mineral proc- Retorting and refining.—Potential hazards essing, and the refining of conventional petro- associated with the retorting and upgrading leum. However, due to the physical and chem- of shale oil include explosions, fire and heat, ical characteristics of shale and shale oil, the bumps and falls, electrocution, and handling types of development technologies to be em- hot liquids. However, the degree of risk for ployed, and the scale of operations, oil shale workers involved in the processing of oil workers might be exposed to unique hazards. shale and its derivatives would not be ex- They will be discussed as follows: safety haz- pected to be so high as in mining. ards that might result in disabling or fatal ac- The processes involved in retorting and up- cidents; and health hazards stemming from grading (e.g., materials handling, crushing, high noise levels, contact with irritant and solids heating and cooling, waste disposal, asphyxiant gases and liquids, contact with and the handling of hot and hazardous liq- likely carcinogens and mutagens, and the in- uids) are generally similar to those used in halation of fibrogenic dust. other operations such as mineral processing (e.g., limestone calcining, roasting of taconite SAFETY HAZARDS and copper ores, and leaching) and conven- Mining.-The similarity of hard-rock min- tional petroleum refining. Although no com- ing to underground or open pit oil shale min- parative study has been undertaken, there ing makes it possible to project likely occupa- are few unique features associated with re- tional safety risks. During mining, accidents torting, upgrading, and refining that would result from rock and roof falls, explosions justify expecting higher worker safety risks and fires, bumps and falls, electrocution, than those in similar industries. heavy mining equipment, and vehicular traffic. Hard-rock mining is a high-risk occupa- HEALTH HAZARDS tion; fatalities are five times more frequent in Mining. —During oil shale mining, as dis- the mining and quarrying industry than in cussed in the section of this chapter on air manufacturing. The frequency of disabling quality, hazardous substances including sili- injuries from underground mining (excluding ca dust will be generated by blasting and the coal industry) is two and a half times 53 drilling. In addition, blasting, raw shale han- higher than from manufacturing. Mining dling and disposal, and other activities at the coal is even more dangerous. minesite will produce fugitive dust. Silica- While most hazards to oil shale miners containing dusts are noteworthy because would be similar to those experienced by they have been the single greatest health haz- hard-rock workers, some are unique to oil ard throughout the history of underground shale. A number of the oil shale facilities are mining. Silica is highly toxic to alveolar planning to use MIS processes in which part macrophages—’’scavenger” cells that move of the deposit is mined out and the remainder about on the inside of the lung and engulf and is then rubbled and burned underground. The remove foreign particles that might damage high temperatures and fires involved in MIS the lung. Silicosis, “shalosis,” and chronic Ch. 8–Environmental Considerations ● 317 bronchitis* are among the diseases that may United States and England,58 and in gold result from the inhalation of oil shale dust. miners in South Africa. 59) A survey conducted by the U.S. Public In another study, postmortem examination Health Service (USPHS) between 1958 and of 30 Estonian oil shale workers who died of 1961 found excessive dust levels in 6 out of 67 accidents and various other diseases60 found inspected mines. 54 The chest X-rays of 14,076 that all had pulmonary fibrosis and one- miners employed in 50 hard-rock mines indi- fourth displayed classic silicotic nodules. * An cated that 3.4 percent had silicosis. ss ** examination of 1,000 Estonian oil shale These measurements were made before mod- workers failed to reveal any cases of pneumo- ern mine hygiene practices were required by coniosis, a pulmonary disease caused by in- the relatively recent occupational safety and haled dusts. However, the workers had been health regulations and a more recent study involved in the industry for only 5 to 14 years. undertaken by the Mining Safety and Health Twenty years of exposure are usually re- Administration showed marked improve- quired for the symptoms of the disease to be ments in mine dust levels. This study exam- detected by a chest X-ray. Because Estonian ined 22 hard-rock mines, 8 of which were in- industrial hygiene standards are not known, cluded in the USPHS study, and found none of the Estonian studies can only suggest an asso- them in violation of the dust standards, 56)** * ciation between oil shale mining and lung disease. The Estonian studies provide no infor- Although few studies have been under- mation about the risk levels to be expected in taken on the direct association between oil mines maintained under U.S. health and safe- shale mining in the United States and the in- ty standards. cidence of lung disease, there are studies on the prevalence of lung disease in oil shale Studies of occupational diseases among oil miners in Estonia. Estonia mined 25 million shale miners in the United States have been tons of oil shale in 1973, and has had oil shale limited because relatively few people have operations for several decades. While the re- worked in the industry. A study was under- sults of the Estonian studies are more intrigu- taken involving miners from the oil shale re- ing than convincing, they do suggest an asso- search center at Anvil Points, Colo., which ciation between oil shale mining and pulmo- has operated intermittently since 1946. nary fibrosis—an increase in the amount of Eighty-six workers were identified, but only fibrous material in the lung. One study also 39 of them had been exposed to oil shale for indicated that chronic bronchitis was 2 to 2-1/2 one or more years. Those 39 were compared times more prevalent in 189 Estonian oil shale with 26 other workers from the facility (e.g., miners than in a similarly aged control popu- office workers, administrators) who had not lation.” (A similar degree of excess bronchitis been directly involved in the mining opera- has been observed in coal miners in the tions. Results showed a twofold higher incidence of pneumoconiosis in the oil-shale exposed population. However, the interpreta- *Sili~osis is a ~is~blin~ fibrotic disease of the lungs caused by inhalation of silica dust and marked by shortness of breath. tion of these results is complicated by the fact “Shalosis” is a disease of the lungs and is related to specific ex- that most of the oil shale miners had previous- posures of oil shale mine dust. It resembles silicosis: its ex- ly worked in uranium-vanadium mines or mill- istence as a specific disease remains to be proved. Inflammation of the bronchial tubes, or anv part of them, is known as bron- ing operations which are known to be causes chitis. of pneumoconiosis.61 Further evaluation of **The 3.4 percent is probably a low estimate; generally sick these populations was not performed because individuals who have left the work force or moved for health and other reasons are under-represented in such surveys. If of the age of the workers, their varying levels such individuals had been examined the incidence of silicosis of exposure, and their limited experience in might have been higher. oil shale mining. ***This study is expected to be released in the near future along with a companion study undertaken by the National Insti- tute of Occupational Health and Safety which examines the *Silicotic nodules are small lumps on the surface of the lung health status of miners from 22 hardrock mines. formed as a response to deposition of silica specks. 318 ● An Assessment of Oil Shale Technologies

A separate study of employees at the same ratory cancers was greater than the percent- facility between 1974 and 1978 found no ad- age in the white male populations of Colorado verse health effects.62 An examination of the and Utah.68 Whether oil shale exposure con- death certificates of 167 oil shale workers un- tributed to the higher incidence is unclear, dertaken by the National Institute for Occu- and the incidence rate among miners was not pational Safety and Health (NIOSH) failed to higher than that of the white male population reveal any association between oil shale ex- in the United States. posure and respiratory diseases.63 Because of the limited number of workers studied, their A cancer morbidity study undertaken by relatively short exposures to oil shale mining, the Rocky Mountain Center for Occupational and Environmental Health found more cyto- and in some cases their exposures to other logical atypia* in the sputum and urine of oil kinds of mining, no firm conclusions can be drawn from these studies. shale miners than among controls, but no association was found between exposure and Some animal studies have demonstrated skin diseases. These data will be further relationships between oil shale exposure and studied to identify any associations between respiratory diseases, but the results conflict such abnormalities and occupational ex- with those of other experiments, making it posures. Animal studies undertaken to date difficult to draw conclusions. One study indi- have not demonstrated that oil shale dust is cated that Estonian oil shale had a weak fi- carcinogenic. brogenic* action in rats; both oil shale and spent shale ash produced pulmonary fibrosis A third potential health hazard to oil shale in white rats after the dusts were deposited miners is exposure to excessive noise levels, into the trachea.64 Another study reported particularly in underground operations car- pulmonary effects when Syrian hamsters ried out in relatively confined spaces. Noise were exposed via intratracheal administra- arises from numerous sources such as boost- tion or inhalation to finely ground oil shale er fans, pneumatic drills, blasting, conveyors, dust and retorted shales.65 66 Increased alveo- and mining machines. The Bureau of Mines lar microphage activity was also noted. The studied 19 pieces of diesel-powered mining same study found that retorted shale dust equipment and found only 2 had noise levels was associated with inflammation, and fre- below the current standards (90 decibels), quently caused increases in the fibrous mate- and one of these exceeded the standard in an rial in the lung (fibrosis] and excessive underground environment. One study esti- growth of cells that line the lung cavities (epi- mated that of the 37,000 workers employed in thelial hyperplasia). However, a 2-year study 650 metal and nonmetal mines, approximate- with rats, which evaluated the effects of raw ly 14,000 (38 percent) were exposed to diesel- or spent shale dust instilled intratracheally in powered equipment noise levels greater than multiple exposures over an 8-month period, the standard.** Of these, 2,430 (17 percent) were overexposed on a time-weighted-aver- found essentially no pulmonary fibrosis. The 69 investigator considered the results to be neg- age basis. Evidence indicates exposure to ative. 67 noise from a large number of mining machines would produce hearing loss if the ex- Another area of concern is the possible exposures exceeded 8 hours per day.70 Higher posure to carcinogens (e.g., polycyclic aro- short-term noise exposures may occur during matic hydrocarbons—PAHs) and trace elements that might be produced during mining. *Cytological atypia are premalignant cell types observed in The NIOSH mortality study mentioned earli- the examination of the body fluids. er found that the percentage of oil shale **A major health issue is the long-term effect of diesel smoke workers who had died from colon and respi- exposure in underground mining environments. The National Academy of Sciences is conducting a study in this area which will be released in the near future. The health implications of *A fibrogenic substance is conducive to the generation of diesel equipment used in underground oil shale mines is un- fibrous materials in the respiratory tract. known at this time. Ch. 8–Environmental Considerations 319

blasting. High noise levels are a potential haz- Refined Scottish shale oils were known to ard not only to hearing, but to the cardiovas- be carcinogenic, but the disease was largely cular and nervous systems as well, and pose preventable by personal cleanliness. It is be- a safety hazard. lieved that the disease occurred because the Retorting and refining.—Retorting oil workers wore the same clothes on the job day shale at high temperatures forms PAH-con- after day. The clothing was rarely, if ever, taining carcinogens of which 3,4-benzo(a)py- laundered, and eventually it became impreg- rene (BaP) is the most studied. PAHs are a nated with shale oil. Contact between the major potential health hazard for retorting soaked clothing and the areas where cancers and refining workers in the oil shale industry occurred was nearly continuous during each because of their carcinogenicity. The prob- working day. This factor, coupled with the lems that might be encountered in oil shale re- fact that daily bathing was rare, undoubtedly fining are similar to those of conventional oil contributed to the high incidence of cancer. refineries, where liquids and gases are trans- Two Estonian studies have shown an asso- ported in airtight pipes under strict mainte- ciation between oil shale processing and nance to detect and repair leaks. cancer. A study of 2,003 Estonian oil shale Crude oil contains an enormous variety of workers with a total of 21,495 person-years potentially hazardous compounds, Even more exposure during the period between 1959 are produced during refining. Work crews in- and 1975 found a significant excess of skin cancer (fivefold for females and threefold for volved in inspection, repair, and maintenance 73 are the most likely to be exposed to PAHs. males). An unusually high incidence of Other hazardous substances found in crude stomach and lung cancer was found among oil include chlorine, sulfur, nitrogen, and persons in the rural areas of Estonia where heavy metals (e.g., vanadium, arsenic, nickel, the oil shale industry is located. ” There is no and cobalt). Toxic contaminants evolved dur- information on the working conditions in Esto- ing the refining process include H S, hydro- nian oil shale operations; nor are data 2 available on the ambient concentrations of gen chloride, hydrochloric acid, SO2, sulfuric acid, methane, ethane, methanol, nitric acid, shale-derived pollutants in the vicinity of the NO , mercaptans, CO, and benzene. plants. It is therefore impossible to relate the X Estonian experience to problems that might The high rate of cancer of the scrotum be encountered in the United States. found in 19th century chimney sweeps and mulespinners* is of historical interest be- Evaluating chemical carcinogenicity in ani- cause it indicates that long exposure of scro- mal experiments is an accepted method for tal skin to PAH-containing oils and soots can predicting carcinogenicity in humans. Inves- cause cancer. In addition to scrotal cancer, tigations that tested the carcinogenicity of oil cancers of the skin, lung, and stomach have shale and shale oil in laboratory animals are also been observed after latent periods of up shown in table 66. A conclusion that can be to 20 years following exposure to PAH-con- drawn from these studies is that shale oil is a taining substances. While the known carcino- carcinogen when painted on animal skins. gen BaP was identified in Scottish shale oil,71 The experiment conducted by Biology Re- a study found only a low incidence rate (less search Consultants (ref. 80 in table 66), in than 0.1 percent per year) of skin cancer for which hairless mice were bedded in raw or 5,000 Scottish oil shale workers between spent oil shale, found no carcinogenic hazard. 1900 and 1922.72 However, this study did not examine the oil shale extracts (e.g., shale oil tar and coke) with which carcinogenicity has been associated. *Mulespinners were workers who lubricated the “mules” (spindles) in the Scottish spinning and weaving industry. Shale- Both the Kettering Laboratory (ref. 79) and derived lubricants were commonly used in this industry. Eppley Institute (ref. 81) studies conclusively 320 ● An Assessment of Oil Shale Technologies

Table 66.–Animal Studies on the Carcinogenicity of Oil Shale and Shale Oil

Organs Nature of study Ref a Materials tested examined Tumerous animals/animals exposed Skin painting study of mice, rats, and rabbits 75 Scottish shale OilS “green 011’ skin 9/100 ‘‘blue oil’ skin 1 2/100 ‘‘unfinished gas oil’ skin 1/50 ‘‘Iubricatmg oil skin 3/50

Skin painting of mice 76 CHCI 3 extract of Scottish oil shale skin 0/20 Scottish shale oil skin 6/10 Skin painting of mice 77 Shale oil skin 1,284/10,000 Skin painting of mice 78 Shale oil skin (35%-90% tumerous) Composite petroleum control skin (0%-8% tumerous) Skin painting of mice (Kettering study) 79 Crude shale oil skin 39/40 Hydrotreated oil skin 5/37 BaP control skin 27/27 Exposure to shale dust (Biology Research 79 Oil shale powder skin 0/12 Consultants) Oil shale powder lungs 2/24 Spent shale powder skin 0/12 Spent shale powder lungs 1 /24 Powdered corn cobs (control) skin 0/1 2 Powdered corn cobs (control) lungs 6/24 Skin painting of mice (Eppley study) 79 Benzene extract of shale oil coke skin 48/50 TOSCO II effluent skin 1 /50 Benzene extract of raw shale oil skin 0/50 Benzene extract of spent shale skin 6/50 Benzene control skin 0/50 None (control) skin 0/100 Intratrachael Instillation in hamsters (Eppley 79 Raw oil shale (b) 0/100 study) Spent shale (b) 0/100 Shale 011 coke (b) 0/100 TOSCO II effluent (b) 0/ 100 BaP control (b) 27/1OO Saline control (b) 0/ 100 None (control) (b) 0/200 aSee reference list bResplratory system SOURCE Wllham Rom et al OcCuPdllOflallEflVlfOflmeflldl Healfh and .SaletY Aspecfs of a CO~rrJerCW 0// Wale lmlWy prePared for OTA by Rocky Mountain Center for Occupational and Enwronmental Health Unwerslty of Utah Oecember 1979

show that crude shale oil, shale oil tars, and Table 67.–Benzo(a)pyrene Content of Oil Shale and shale coke have carcinogenic properties, Its Products and of Other Energy Materials which may be related to their BaP content. Substance BaP concentration, p/ba The second Eppley study (ref. 82), which in- Raw oil shale ., . ., . . . 14 vestigated respiratory system carcinogeni- TOSCO II retorted shale, ., ., 28 city, found no effect. This contrasts to the TOSCO II atmospheric effluent . . ., 140 TOSCO II retort coke. 129 skin exposure experiments. Whether or not Raw shale oil from Colorado, ., ., ., 3,200 oil shale and its derivatives are less of a Hydrotreated shale 011 (0.25% N2) ., 800 Hydrotreated shale 011 (0,05% N ) ., threat to the respiratory system than to the 2 690 Coal ., ., ., 4,000 skin deserves further study. Libyan crude 011 ., 1,320 Although BaP may not be the only carcino- Asphalt from conventional crude 10,000-100,000 gen in shale oil and its products, it is probably aParis per bllllon SOURCE R M Coomes Carcmogenlc Tesflng of 011 Shale Materials TweMh 0// Sha/e Syrr- the most potent. The study summarized in poswm Proceedings Golden Colo The Colorado School o! Mines Press November table 67 shows that hydrotreating shale oil 1979 Ch 8–Environmental Considerations . 321

significantly reduces its BaP content,’{ Such a refinery workers was attributed to the reduction should be reflected in a lessening of “healthy worker effect;” i.e., employed work- its carcinogenicity, This predicted effect of ers are healthier on the average than the gen- hydrotreating was confirmed by the animal eral population. Respiratory cancer in- tests of the Kettering experiment (ref. 79, creased with increasing exposure to aro- table 66). matic HC, but was still lower than found in the general population (SMR of 79.9). The Estonian epidemiological studies and the animal studies show that crude shale oil, On the other hand, two epidemiological shale oil tars, and shale coke are all car- studies published by Canadian investigators cinogenic. Most of the studies to date suggest showed an increased cancer risk for refinery that carcinogenicity is restricted to the skin. workers. In a group of 15,032 male employees Occupational skin diseases from exposure to who worked for the Imperial Oil Co. between certain industrial oils have long been a prob- 1964 and 1973, there were 1,511 deaths. lem, as was seen in the case of the scrotal Eighty percent were ascribed to circulatory cancer among chimney sweeps, One study system disease and to malignant abnormal showed that the effects of oil contact with the growths (neoplasm). Mortality from all ma- skin range from acute inflammation to kera- lignant neoplasms in the exposed group was tosis (pitch warts which are regarded as a greater than in the nonexposed group. Can- premalignant skin change.)84 Studies of oil cers of the digestive and the respiratory sys- shale retorting workers in the United States tems increased with duration of employ- in the early 1950’s did not reveal any prob- ment. 87 lems with occupational skin disease, but 85 A further study examined 1,205 men who workers were exposed for a short time only. had been employed for over 5 years by Shell 88 A synergistic relationship has been found Oil Canada in East Montreal, { Their mortali- between the ultraviolet radiation in sunlight ty rate was compared with death rates for and coal-tar pitch volatiles in causing skin the Province of Quebec. The study group was diseases. A similar synergism might cause oc- relatively small, and only 108 deaths were cupational skin diseases in oil shale workers observed. An increased incidence of cancer on the Colorado plateau, where ultraviolet of the digestive system (SMR of 117) was not radiation levels are higher than at lower ele- statistically significant, and there was no vations. evidence of excessive lung cancer (SMR of 35.4). An excess of brain cancer was found Refining shale oil will be similar to other among those who had been exposed less than refining operations. Available epidemiologi- 20 years, but it caused only three of the cal studies do not lead to clear-cut conclu- deaths. sions about relationships between working in refineries and cancer. A retrospective mor- Societal Hazards tality study sponsored by the American Petro- leum Institute that covered 17 U.S. oil refin- Air pollutants include particulate, gases, eries and over 20,000 workers was reported and trace-metal vapors. Particulate which in 1974,86) The study group included every contain absorbed PAH can be carcinogenic. worker employed in the refineries for at least The sulfur and nitrogen-containing emissions one year between January 1, 1962, and De- are respiratory irritants. Among the sulfur- cember 31, 1971. A 94-percent followup was containing pollutants, the effects of acid obtained. There were 1,165 deaths; 1,145 sulfates, sulfuric acid, and S02 dissolved in death certificates were obtained. The stand- aerosols are the best documented. All three ardized mortality ratio (SMR) for all causes of are irritants and can make breathing diffi- death among refinery workers was 69.1 com- cult. In addition, some epidemiological evi- pared with the base rate of 100 for the U.S. dence relates chronic bronchitis and respira- male population. The lower death rate among tory diseases to SO2 and to particulate con- . — —— —— ————. .

322 ● An Assessment of Oil Shale Technologies

centrations in the air. Oxides of sulfur and ni- The severity of these hazards will depend trogen, transported from industrial areas, on many factors. Many of the risks could be may cause acidic rainfall that may reduce the very small if they are anticipated, and if ap- productivity of forest vegetation and kill fish propriate control strategies are designed and by increasing the acidity of lakes and followed. If caution is not employed, or if

streams. NOX oxides can react with HC in the there are catastrophic failures in the control

atmosphere to produce O3, photochemical systems during or after plant operation, dam-

smog, and acid rain. Airborne NH3 may cause age could be severe and long lasting. headaches, sore throats, eye irritations, coughing, and nausea in humans. Summary of Hazards and Their Severity Among the trace elements that may be emitted, mercury, lead, cadmium, arsenic, The safety and health hazards that might and selenium are considered to be potential be associated with oil shale mining, retorting, air and water pollutants. Arsenic is a car- and refining are identified in figure 62. They cinogen, which when inhaled or ingested in are ranked according to their known poten- large amounts, may also cause peripheral tial to cause injury or death. As shown, min- vascular disease and neuropathy. * Mercury ing has the highest potential for accidents, is a special problem because its vapors can due to risks from rockfalls, explosions, mov- pollute the air and earth many miles from the ing equipment, and general working condi- plantsite. It can also contaminate surface tions. There were two fatalities during the streams and ground water aquifers. It can mining of over 2 million tons of shale and the enter the food chain through the actions of production of over 500,000 bbl of shale oil. micro-organisms, and can also pose a risk of The accident rate has been one-fifth that for irreversible neurological damage to humans all mining, and much lower than that for coal who eat fish that have been contaminated by mining. However, this record was achieved in mercury in streams. small-scale experimental mines that employed, for the most part, experienced hard- Leachates from aboveground disposal rock miners. Whether safety risks will in- areas and burned-out in situ retorts also pose crease or decrease as mining activities are potential problems. PAHs, salts, and metals expanded cannot be predicted. Risks might may dissolve in surface streams and ground increase as the work force expands to include water and infiltrate public drinking water inexperienced miners and as large, rapidly supplies. Water-soluble salts in spent shale moving mining equipment is used. On the contain as much as 40 percent of the total other hand, the large mines proposed for oil benzene-soluble organic matter. All of these shale plants may reduce risks because of the materials can be dissolved in water and dis- additional room in which to maneuver ma- persed through soils. The exact nature of the chines. threat posed by these materials to human health is unknown since, for example, PAHs Fires and explosions are also identified as are found throughout nature. However, the a hazard in mining. Although no severe fires PAH content of spent shale leachates (up to have occurred to date, laboratory studies in- 100 to 1,000 times higher than is found in nor- dicate that airborne shale dust can propagate mal ground or surface water) is a matter for a methane explosion. Methane has been concern. Fluoride, if released in excessive found in low concentrations in some oil shale amounts in contaminated water, may cause deposits, especially those in the saline zone of fluorosis (reduced bone strength and debilita- the Piceance basin. Oil shale dust is, how- tion) and mottle tooth enamel. ever, far less explosive than coal dust. Dust is a major health hazard. Its effect on *Neuropathy refers to pathological changes in the the respiratory system is well-known. Exces- peripheral nervous system. sive noise is also a recognized hazard. Cancer Ch. 8–Environmental Considerations ● 323

Figure 62.—Summary of Occupational Hazards Associated With Oil Shale Development

Relative Ranking

Occupational Risks Potential Effect Mining Retorting Refining

Accidents Injury or death A

Fires and Injury or death explosions mnn

Hearing loss or Noise neurological damage

Dust Lung disease

Dust Dermatitis

v Chemical Cancer Exposure

Chemical Dermatitis Exposure [ 1 I I I

Chemical Poisoning Exposure I I I

Chemical Irritant gases Exposure 4.

KEY:

- Higher level of risk D Medium level of nsk

a Lower level of nsk

SOURCE Off Ice of Technology Assessment 324 An Assessment of Oil Shale Technologies from oil shale mining has not been identified and Health Administration (OSHA) under the as a major hazard. Although the carcinoge- Department of Labor. Most OSHA standards nicity of oil shale dusts and crude shale oil promulgated under the Act pertain to safety, has been demonstrated by some invesigators, e.g., walking and working surfaces, fire pro- insufficient information and the conflicting tection, and personal protective equipment. results of other studies prevent a determina- In addition, health standards have been pro- tion of the severity of the risk. However, the mulgated to limit worker exposure to hazard- incidence of diseases in other industries in- ous chemicals and physical hazards, such as dicates that exposure to these materials noise and crystalline silica. could be hazardous. Worker health should be carefully monitored if health damage is to be OSHA recently published a policy for the avoided, and prevention techniques im- identification, classification, and regulation proved, as the oil shale industry develops. of toxic substances posing occupational carcinogenic risks. Under this policy, a sub- Retorting is regarded as having medium stance shown to cause cancer in two animal risks in all areas. This ranking primarily studies can be classified as a “category I“ reflects the low level of knowledge about carcinogen and regulated to control worker retorting and its health and safety effects. exposure to the lowest feasible levels. However, the large variety of substances that Whether any two of the positive carcinoge- will be encountered in retorting (from raw nicity results mentioned in table 66 are suffi- shale dust to trace-element emissions) may cient to cause a category I classification pose as yet undetected health hazards. Of awaits NIOSH review. special concern is the possibility of carcinogens in shale oil and its derivatives. The Federal Mine Safety and Health Possible synergisms in MIS operations (which combine mining with retorting) could in- Amendments of 1977 (FMSHA) crease the level of risk. These amendments apply to all metal and In contrast, shale oil refining is regarded nonmetal mines. They prescribe health and as posing no special hazards in many areas safety standards “for the purpose of the pro- and only moderate risks in the others. This is tection of life, the promotion of health and because most of the problems that will be safety, and the prevention of accidents. ” associated with shale oil processing should FMSHA established the Mine Safety and be similar to those experienced in convention- Health Administration (MSHA) in the Depart- al petroleum refining. ment of Labor, and directed the Secretary of Labor to develop, promulgate, revise, and en- force health and safety standards for work- Federal Laws, Standards, ers engaged in underground and surface min- and Regulations eral mining, related operations, and preparation and milling. In addition, each mine oper- This section discusses the Federal laws ator is to have a mandatory health and safety and standards applicable to oil shale occupa- training program. FMSHA also authorized tional health and safety, and some aspects of the Secretary of Labor to require frequent in- environmental health. Other laws which gov- spections and investigations of mines: at least ern specific impacts on air, water, and land four times a year in the case of underground are discussed elsewhere in this chapter. mines, and at least twice a year in surface mines. Records of mine accidents and expo- Occupational Safety and Health Act of 1970 sures to toxic substances are to be maintained by mine operators. This Act was passed to assure every working person “safe and healthful working condi- Section 101(a) of FMSHA requires that tions;” it established the Occupational Safety standards on toxic material or harmful physi- Ch. 8–Environmental Considerations ● 325 cal agents be set to “most adequately assure should be noted that if specific operations are . . . (on the basis of the best available regulated by other laws (e.g., Clean Air Act, evidence) that no miner will suffer material Clean Water Act) their authority would prob- impairment of health or functional capacity ably take precedence over regulations pro- (even if such miner has regular exposure to mulgated under TSCA. TSCA regulations the hazards dealt with by such standard for would be promulgated only when regulations the period of his working life). ” NIOSH has under the other Acts failed to remove a haz- the responsibility to determine when the ma- ard. Also, chemicals that are not sold in com- terial or agents are toxic at the concentra- merce are considered “R&D substances” and tions found in the mine. are exempt from some of the requirements Warning labels, protective equipment, and under the Act. control procedures are to be employed “to Under TSCA, EPA must require industry to assure the maximum protection of miners. ” give notice 90 days prior to beginning the Medical examinations and tests, where ap- manufacture of any new substance that is not propriate, are to be provided at the opera- listed on EPA’s Inventory of Existing Chem- tor’s expense to determine whether a miner’s icals. EPA can also require industry to test health is adversely affected by exposures. the toxicity of chemicals already in commerce that may pose an unreasonable risk to human Memorandum of Understanding Between health or the environment. Shale oil and its OSHA and MSHA refined products are included in the inventory list and therefore are not subject to pre- Because of the overlapping jurisdiction be- market regulations, but testing can be re- tween OSHA and MSHA, an interagency quired under other sections of TSCA if the agreement was executed on March 29, 1979, Administrator of EPA determines such sub- to allocate the responsibilities for mining stances may pose an “unreasonable risk” to safety between the two agencies. The agree- health or the environment. ment established that as a general policy, un- safe and unhealthful working conditions on Control and Mitigation Methods minesites and in milling operations would come under the jurisdiction of MSHA. Where Some of the oil shale’s health and safety these do not apply, or where no MSHA stand- hazards can be reduced by using the pollution ards exist for particular working conditions, control technologies described elsewhere in OSHA and its regulations would apply. this chapter. Others will require specific in- Where uncertainties arise about jurisdiction, dustrial hygiene controls. The three major the appropriate MSHA District Manager and control methods are: OSHA Regional Administrator (or the respec- ● tive State designees in those States with ap- worker training programs, including an proved mine-safety plans) shall attempt to intensive training program for new work- resolve the matter. If they cannot do so, the ers and refresher courses for workers issue will be referred to the national offices throughout their careers; of the two agencies. If the issue cannot be ● the design and maintenance of safe resolved at that level, it will be referred to the working environments; and Secretary of Labor for a final ruling. ● health monitoring programs, including examinations and recordkeeping. The Toxic Substances Control Act Initial training programs and refresher of 1976 (TSCA) courses are required by OSHA and MSHA. These agencies also promulgate standards TSCA covers the manufacturing, process- for working environments. Health inspections ing, distribution, use, and disposal of chemi- are sometimes included in OSHA/MSHA rou- cal substances in commerce. However, it tine inspections, and special health inspec- 326 ● An Assessment of Oil Shale Technologies tions can be made if the agencies determine physical agents such as ionizing radia- that a serious health hazard exists. At pres- tion, heat, and noise stress; ent, exchange of worker-health information ● evaluation of devices for controlling among companies is not required, although worker exposure, such as hermetic some companies, especially in the coal mining seals, ventilation equipment, and per- industry, have organized such programs to sonal protective equipment; provide data regarding occurrences of black ● environmental monitoring to determine lung among miners who change jobs within ambient levels of PAHs, trace elements, the industry. and other potentially harmful substances; Summary of Issues and R&D Needs ● determination of the pathways followed by PAHs, salts, toxic trace elements, and Issues other substances; and ● additional controlled animal experi- The effect of the scale of operation of fu- ments to determine the toxicity, muta- ture oil shale facilities on worker safety is genicity, and other characteristics of the still unknown. As indicated previously, the oil raw materials and products encoun- shale industry to date has a good safety rec- tered in oil shale processing, and evalua- ord. It is not clear whether or not this record tion of their synergistic interrelation- can be maintained in large facilities and in a ships. large industry. A mechanism that would aid in all of these The protection of worker health and safety studies, and in other ones that evolve as the in an industry that is developing with great industry is created, would be an oil shale speed is also a major concern. To prevent un- health registry or central repository for the due risks, it is important that the health haz- health records of oil shale workers. These ards of oil shale and its related materials be data would aid in the statistical work needed identified, and that appropriate measures be to detect extraordinary health trends among employed for their control. the workers. These, in turn, could be related to working conditions and used to improve R&D Needs preventive and protective measures. Research is needed in the following areas in order to improve the understanding of the Current R&D Programs potential effects of oil shale development on the workers and on the public: The following is a partial listing of the health and safety R&D projects now under- ● additional data gathering and analysis way both in the private sector and by Govern- are needed on the health effects of par- ment agencies. ticulate generated during oil shale mining and processing. Studies should in- ● Tosco is studying the fire and explosion clude: a) identification of absorbed potential of oil shale mining and process- PAHs; b) determination of particulate ing. size distributions; c) evaluation of the ● The American Petroleum Institute is risk of fibrogenicity and carcinogenicity; studying the effects of oil shale on fe- d) ranking of the unit operations in terms tuses by exposing pregnant rats to raw of their degree of risk; and e) determina- and spent shale dust and shale oil. tion of their health effects on nearby ● EPA is performing or contracting work communities with respect to, for exam- through 10 of its laboratories to support ple, chronic bronchitis; the regulatory goals of the agency and to ● characterization of worker exposure to ensure that an oil shale industry will be PAHs, other chemical hazards, and developed in an environmentally accept- Ch 8–Environmental Considerations ● 327

able manner. The EPA Cincinnati labo- Policy Considerations ratory is studying the handling of raw shale and the disposal of spent shale. Air The major issue surrounding the health pollution, wastewater characteristics, and safety aspects of oil shale development is and water treatment methods are also the paucity of information on the nature and being studied and evaluated. The Las severity of the health effects of oil shale, its Vegas laboratory is attempting to design derivatives, waste products, and emissions. and implement an optimal wastewater The effect of the scale of operation of oil treatment system. The Athens, Ga., labo- shale facilities on worker safety is also un- ratory is characterizing retort effluents known. Policy options for addressing these and developing instrumentation and con- issues follow, trol systems. Biological and health effects studies are being conducted at the Inadequate Information Gulf Breeze and Duluth laboratories; these are designed to determine path- Additional study is needed to determine the ways by which HC enters the food chain, effects on human health of the various chemi- to characterize the aquatic life in the oil cal substances and particulate encountered shale region before oil shale develop- during the mining and processing of oil shale ment occurs, and to determine the car- and its products and wastes. Such informa- cinogenic, mutagenic, and fetal effects tion would be useful in identifying and miti- of oil shale and its derivatives and gating long-term health effects on workers wastes. EPA is also preparing pollution and the public. It would also be useful in set- control guidance documents for the oil ting new standards for worker health and shale industry. safety. Options for increasing the amount of DOE is conducting source characteriza- information include expanding existing R&D tion studies to determine emissions prop- programs; coordinating R&D work by Federal erties and their health effects. Included agencies; increasing appropriations to agen- is an extensive program for sampling re- cies to accelerate their health effects studies: tort liquids, solid products, and wastes. and passing new legislation specifically call- Streams to be sampled include mine vent ing for study of the health and safety aspects gases, mine air, retort water, raw and of oil shale development. Methods for imple- retorted shale, process water, and par- menting these options are similar to those de- ticulate, Biological testing will be con- scribed in the air quality section of this ducted to include short- and long-term chapter. animal exposure tests and medical and epidemiological studies of oil shale work- Health Surveillance ers. ● The U.S. Department of Agriculture is Collection and maintenance of oil shale sponsoring work related to the social workers’ health records in a health registry consequences of oil shale development would facilitate hazard identification and and the revegetation of solid waste dis- planning to reduce risks. The registry might posal areas. be located in a regional medical center, with ● The National Science Foundation is or without Federal agency input. Funding sponsoring projects to characterize the could be provided by Government, labor, or contaminants in spent shale and to de- the oil shale developers, or by a cost-sharing velop techniques for managing them. arrangement between these groups. The reg- ...

328 ● An Assessment of Oil Shale Technologies istry location could be the focus of regular standards are necessary to protect worker meetings to exchange health and safety in- health and safety. In addition, sampling meth- formation and to disseminate basic scientific ods should he in place to monitor exposures. findings that apply to the oil shale industry. Worker-Education Campaigns Exposure Standards Worker education is already a part of the As information about chemical health haz- mining industry. Information about newly ards is developed and analyzed, NIOSH and identified risks should be conveyed to work- MSHA should determine whether exposure ers as soon as possible.

Land Reclamation Introduction tion from underground mining and in situ development could affect aboveground condi- An oil shale industry will use land for actions through subsidence in the mined-out cess to sites, for facilities, for mining, for re- areas. But this might not happen until long torting, for oil upgrading, and for waste dis- after operations at the site have ceased. posal. The extent to which development will affect the land on and near a given tract will Oil shale plants must be built to comply be determined by the location of the tract; the with the laws and regulations that govern scale, type, and combination of mining and land reclamation and waste disposal, Never- processing technologies used; and the dura- theless, there will still be effects on the topog- tion of the operations. Comparatively little raphy (ultimately the terrain could be modi- land will be disturbed by the retorts and up- fied to a landscape unlike the original) and on grading facilities themselves, but much larger wildlife (through changes in forage plants areas will be disrupted by mining activities and habitats). In addition, unless appropriate and waste disposal operations, particularly if control methods are developed and applied, the deposits are developed by open pit mining as required by law, the large quantities of in conjunction with aboveground retorting, raw and retorted shale could pollute the air which produces retorted shale as a process with fugitive dust and the water with both waste. runoff and the effluent that has percolated through raw shale storage piles and waste It has been estimated that a l-million-bbl/d disposal areas. Solid wastes such as cata- industry using aboveground retorts would lysts, water treatment sludges, and refinery process approximately 600 million tons of coke, will be produced in relatively small raw oil shale per year, and would require the 3 amounts, but will contain toxic components disposal of approximately 10 billion ft of that could degrade water quality unless prop- compacted spent shale. Less of the surface erly controlled. Similar care will be needed to would be disturbed by in situ retorting, al- remove, store, dispose, and revegetate the though the surface would nevertheless be dis- large amounts of overburden that will be turbed by drill pads. However, the disturb- handled in open pit mining operations. ance would be different and less drastic than from an open pit operation. At the same time, Several avoidance and mitigation strate- the amount of subsurface disturbance for a gies have been proposed to minimize the over- given level of oil production would be in- all land impacts of oil shale development. Oil creased because, although with an in situ shale plants, access corridors, and disposal process relatively little oil shale is mined, oil areas could be sited to avoid esthetic deteri- recovery rates are lower and some leaner oil oration and improve the feasibility of land shales would be retorted. Subsurface disrup- reclamation and revegetation programs; and Ch 8–Environmental Considerations ● 329 mining and in situ retorting could be designed gated governing oil shale mining, processing, to decrease surface subsidence or reduce its and waste disposal, rate. In addition, most development plans Each State in the oil shale region has rec- propose to protect existing wildlife habitats lamation laws that apply to all mining opera- and migration routes, where possible, and to tions. USGS has regulations that control oil enhance the characteristics of adjacent shale operations only on Federal lands. In ad- areas to promote wildlife readjustment. Rec- dition, the Department of the Interior (DOI) lamation and revegetation techniques have established environmental stipulations gov- been developed and tested on a small scale erning lands under the Prototype Oil Shale over limited periods of time for aboveground Leasing Program that include additional spe- solid waste disposal, and backfilling mines cific reclamation standards. The Surface has been suggested to reduce the quantity of Mining Control and Reclamation Act solid material that must be disposed of on the (SMCRA), passed in 1977, provides a system surface. of comprehensive planning and decisionmak- As with air and water control methods, a ing needed to manage land disturbed by de- number of uncertainties surround the feasi- velopment. However, the Act applies only to bility of methods for minimizing land disturb- coal, and the detailed reclamation standards ance and its effects on wildlife. At issue are promulgated under it may not be appropriate the feasibility of land restoration and revege- to oil shale in all cases. However, it provides tation techniques, and the adequacy of strat- a guide to measure the strictness of other egies to control the leaching of solid waste laws applicable to oil shale for matters that and raw shale piles. The methods for dispos- are not specific to coal. ing of solid wastes by backfilling mines and for controlling leachates from solid waste dis- The Colorado Mined Land Reclamation Act posal piles and underground retorts were dis- is administered by a board and division with- cussed previously in the water quality sec- in the Department of Natural Resources. It tion. In this section the reclamation and re- requires permits for each mine operation, vegetation of processed shales on the surface stipulates application procedures and crite- are examined. ria for permit approval, requires surety (e.g., performance bonds), and sets procedures for enforcement and administration. The Act’s Reasons for Reclamation performance standards are similar in concept to those established by the Federal Coal The primary purpose of reclaiming the sol- Act. They are not, however, as detailed since id wastes is to reduce their detrimental ef- they must apply to all minerals from oil shale fects. These include: changes in the land- to sand and gravel (except for coal, which has scape, the disruption of existing land uses, been amended to correspond to the new Fed- the loss of the biological productivity on a eral requirements); and, in some cases, they given land surface, and the degradation of air are not so strict. For example, an operator and water quality by erosion and leaching. In may choose the postmining use of affected addition, secondary impacts such as fugitive land; whereas, the Federal standard requires dust would affect not only the immediate area approval of such use by the permitting au- but adjacent areas as well. thority according to strict criteria. Also, an operator may substitute other lands to be re- Regulations Governing Land Reclamation vegetated if toxic or acid-forming materials will prevent their successful vegetation, and In order to ensure that mining operations the mitigation of such conditions is not feasi- will incorporate reclamation concepts and ble. Mining would probably be prohibited minimize adverse effects, legislation has been under similar conditions by Federal stand- passed and regulations have been promul- ards, if they were applicable to oil shale.

63-898 L - 80 - 22 330 ● An Assessment of Oil Shale Technologies

The Utah Mined Land Reclamation Act is quired “best available control technologies” administered by the Board of Oil, Gas, and to minimize all environmental damage. Mining. It provides for various powers of the board, administrative procedures, surety, In summary, while reclamation is required and enforcement. However, the Utah law only under State laws, there are no performance establishes general reclamation goals and standards specific to oil shale. Regulations does not set detailed environmental perform- vary and are not so strict as the general re- ance standards as do SMCRA and the Colora- quirements of the Federal coal law. There are do law. These goals include minimizing envi- additional requirements that pertain to Fed- ronmental degradation or “future hazards to eral leases. public safety and welfare” and establishing “a stable ecological condition comparable Reclamation Approaches with . . . land uses. ” They are open to broad discretionary interpretation by the Oil, Gas, Several reclamation approaches can be and Mining Board. used to reduce the deleterious effects asso ciated with the disposal of spent oil shale. The Federal standards that do apply to oil These include returning surface wastes to shale are limited to Federal lands;* they do mined-out areas; the chemical, physical, or not govern operations on private land, and vegetative stabilization of processed shale; are in no way comparable to the detailed and combinations of these approaches. standards that apply to coal under SMCRA. For example, 30 CFR 231.4 establishes very general goals requiring reclamation to Reducing Surface Wastes “avoid, minimize or repair” environmental Mine backfilling was discussed in the sec- damage. Specific details must be set by site- tion on water quality. As was indicated, the specific leases. It is not applicable to true in disposal of wastes underground will be more situ oil shale methods using boreholes and expensive than surface disposal, but there wells, thus will not govern spent shale leach- could be less surface subsidence caused by ing for this technology. Part 23 of title 43 the collapse of overburden materials above authorizes, but does not require, the Bureau the mined-out rooms. of Land Management (BLM) District Manag- ers to formulate reclamation requirements and USGS Mining Supervisors to set stand- Chemical or Physical Stabilization ards for mine plans. One approach that can be used to reduce More important are specific lease stipula- erosion on disposal sites is to use chemical or tions. Environmental stipulations have been physical methods to stabilize the processed included in the Prototype Oil Shale Leases shale. Chemical stabilization may be short governing operations on current Federal term—from a few months to a couple of lease tracts. The reclamation and revegeta- years—or longer term. Short-term methods tion performance standards that are included consist of spraying biodegradable chemicals take into account the experimental nature of on the surface; these reduce wind and water the program. For example, lessees are given erosion by binding particles together. Such 10 years to demonstrate a necessary revege- chemicals have been used along with revegetation technology; however, operations must tation to achieve temporary stability.89 The cease if such technology is not developed. The chemicals do not appear to inhibit seed germi- lease and the environmental stipulations are nation; however, they are expensive and, at administered under the broad discretion of best, temporary. the Area Oil Shale Supervisor, who has re- Longer term stabilization consists of add- *About 70 percent of the oil shale land, containing about 80 ing materials such as emulsified asphalt or percent of the resources, is federally owned. processed limestone to induce chemical reac- Ch. 8–Environmental Considerations ● 331 tions that harden the mixtures. Hardening ically pleasing, and restrict the future uses of can be accomplished by wetting of shales the land. processed at high temperatures, followed by compaction. The hardened products have the Vegetative Stabilization advantages of relatively high resistance to Vegetation offers the most esthetically erosion and reduced leaching of soluble salts pleasing and productive means of stabilizing into the ground water. Their disadvantages waste materials. It also allows for multiple are that they are esthetically unattractive land use. In addition, vegetation theoretically and cannot support vegetation unless covered offers a means of continually adapting to the by a suitable plant growth medium. The long- changing environmental conditions that are term effects of chemical stabilization are at likely to occur on the disposal site over time. present unknown. Vegetation will also reduce the overland Erosion can be reduced physically by cov- flow of water and sedimentation during in- ering the processed shale with a layer of tense storms by increasing the permeability rocky material. Like the chemical ap- of the soil. This will increase the infiltration proaches, physical methods inhibit the estab- of water, thus reducing surface water and lishment of a vegetative cover, are not esthet- pollution and flood hazards. Vegetative cover

Photo credit OTA staff

A variety of plant life will be required for revegetation of spent shale areas 332 ● An Assessment of Oil Shale Technologies will tend to ameliorate micro-climatic condi- The characteristics of processed shales tions and also reduce wind erosion and ex- that make them undesirable as a plant tremes in soil temperatures. growth media are:

● small particle size (texture), which encourages erosion; and compaction or ce- Combinations of Stabilization Methods mentation, which results in low permea- Perhaps the most effective means of stability to water and poor root penetration; bilizing waste piles will be combinations of ● high pH (i. e., high alkalinity), which discourages plant growth by making essen- approaches such as hardening the processed tial nutrients insoluble and therefore un- shales by chemical means and then establishing vegetation on a friable soilcover atop the available; ● high quantities of soluble salts, including solidified wastes. The vegetative stabilization elements toxic to plant growth that in- of soil-covered spent shale appears to be the hibit water and nutrient uptake; and preferred reclamation approach because the ● the dark colors of some spent shales, chemical and physical properties of proc- which absorb solar radiation thus pro- essed shale make it much less amenable to ducing high temperatures that inhibit supporting plant growth that resembles the seed germination and dry the soil diversity and density of the present natural vegetation ecosystems. through evapotranspiration. The characteristics of spent shale from several processes are summarized in table 68 and discussed below. The Physical and Chemical Characteristics of Processed Shale Texture The physical and chemical characteristics Raw shale that is finely crushed, as in the of the processed shale are determined by the TOSCO II process, produces a fine silty spent source of the raw shale; its particle size after shale that is highly susceptible to erosion. crushing; and the retorting parameters such However, if the shale is coarsely crushed as as temperature, flow rate, and carbonate de- in the gas combustion processes, a coarse- composition, which vary with different retort- textured spent shale is produced that is less ing processes. susceptible to erosion. The resistance to wet-

Table 68.–The Chemical and Physical Properties of Processed Shales

Processing Process temperature Color Texture a Salinity b pH TOSCO II ., . . . ., . . . . LOW Black Fine 18 9.1 Gas Combustion . . ., ., ., . . High Gray Coarse 14 8.7 Paraho Directly heated. ., ., ., ., High Gray Coarse 7 12,2 Indirectly heated . . . . ., . . . Low Black Coarse 10 12,3 Union “A” retort ...... High Gray Coarse 3-4 11,4 ‘‘B’ retort ., ... ., Low Black Coarse 13 8.5 Lurgl-Ruhrgas ., ., ., . . Low/high Gray Fine/coarse 3-7 11-12 aFl”~.[~Xlu~@ processed Shales are predornlrranlly smaller Ihiln 2 mm while coarse-[ extured processed shales are r)redomlnantly larger than 2 Inrn bThe electrical ~OfrdUCtlVltY (rnrnhO/Crn) of a safuraled extract preparedfrOrn spent shale Partlclw sfnaller than p mm SOURCE Planf Resources Inshwie The free/arrrallorI oJProcessed O// Shale, prepared for OTA, January 1980 Ch 8–Environmental Considerations ● 333 ting of the spent shale originally produced in 3:1 was found to be the maximum allowable the TOSCO process90 91 has been overcome by for slope stability.” introducing steam in the last step of the proc- Water diversion and sediment and drain- ess. Spent shales produced by retorting at age catchments are proposed to collect mate- higher temperatures have not been reported rials washing off site in order to prevent their as resistant to wetting, entering the aquatic ecosystem. It is likely The capacity of spent shales to retain that sediment basins will require long-term water is moderate. Infiltration rates on fine- maintenance to prevent their filling up and textured spent shale (TOSCO II) range from releasing toxic substances. 92 93 near zero to as high as 3 to 4 cm/hr. Those Furrowing, pitting, and gouging are other for uncompacted coarse-textured spent shale 94 useful methods of surface manipulation. Shal- are higher. Rates of from 2 to 4 cm/hr will be low furrowing on the contour cuts down on sufficient for the surface runoff to be ab- erosion losses. Pitting and gouging not only sorbed from most low-intensity storms but not control erosion but also act as a moisture col- from high-intensity ones that occasionally oc- lector.’” They are particularly useful in dry cur during the summer. Moistening and com- areas and where vegetation is dependent on pacting the spent shales may achieve close to snowmelt. A variation of gouging is accom- zero infiltration rates which could be impor- plished by using a land imprinting machine.’” tant for reducing the leaching of salts into the On soil-covered processed shales, the depth ground water. Compaction is more desirable of the depressions will be determined by the for spent shales deep in the pile, beyond the thickness of the soil cover necessary to pre- plant rooting zone; uncompacted materials vent the processed shale from being exposed. may be preferable near the surface directly under the topsoil layer. Mulches of various types have been used both to establish vegetation and to reduce the 99 Erosion Control temperature of the soil surface. Hydro- mulch, applied at a rate of 1,500 lb/acre is Because small particle size encourages one that is preferred in some studies. 10’) How- erosion, erosion control is needed to prevent ever, it is expensive and, in some cases, has sediments and toxic elements from entering been reported to provide little beneficial ef- the aquatic ecosystems downstream, or the fect on already established stands. ’()’ A increase of dust in the air. Additionally, ero- cheaper natural mulch applied at a rate of sion removes the surface layers that encour- 3,000 lb/acre,102 such as native hay or straw, age plant growth, which take time to develop. is more likely to be used, but it must be taken from a certified weed-free field to prevent in- The steepness of the slopes, their length, troducing weedy species. It is uncertain that the drainage provided, control structures, the sufficient mulch will be available, especially density of vegetation on the slopes, and the weed-free hay, for an oil shale industry of 1 types of spoils and soil materials on the site million bbl/d within 10 years. will affect the extent of erosion. Mulching, surface manipulation, and the timing of top- Straw or hay mulches often need to be sta- soil placement, followed by the immediate es- bilized by the addition of emulsified asphalt tablishment of vegetation, will usually reduce (300 gal/acre), ’03 or by crimping into the soil. erosion rates.95 Flatter or shorter slopes will Rock mulches have been found to be superior also aid in erosion control. The recommended to barley straw with respect to plant survival design slope of 4: I (horizontal: vertical) with and growth. 104 Excelsior type materials, are 20-ft benches every 50 ft of vertical rise is also very effective, but they are costly and at- considered prudent and necessary. A slope of tract rodents. ’05 . .

334 ● An Assessment of Oil Shale Technologies

Cementation Another means of assisting plants to survive in nutrient-deficient soils is by inocu- Processed shales retorted at high temper- lating them with selected strains of fungi that atures and then moistened harden within produce mycorrhizae. Mycorrhizae are struc- about 3 days in a reaction similar to that tures that combine the plant root and a fun- which takes place in cement. 106 The product of gus to increase the survival and growth of spent shale cementation is still susceptible to plants in nutrient-deficient soils by increasing weathering, and the reaction generally takes nutrient uptake and resistance to a variety of place deeper in the waste pile where the stresses. process is accelerated by compaction, heat, and high pressure. If shale hardened by this Free-living soil microbes are expected to process were to be exposed by erosion, it begin recolonization of the disturbed area. might prove to be impenetrable to moisture They will be valuable in fixing nitrogen from and plant roots. the atmosphere and recycling organic forms. How soon this will begin is not known. It is Alkalinity known, however, that wetting and drying stored topsoil deteriorates the conditions fa- Processed shales retorted at temperatures vorable to such microbes. For this reason, 0 0 of about 500 C (900 F) are less alkaline (pHs prior to use topsoil should be deeply buried to ranging from 8 to 9*), than those retorted at prevent the wetting and drying that occurs 11 1 750° to 800° C (1,400° to 1,500° F) (pHs of 11 near the surface. to 12). In general, the higher the alkinity of its Plant species used to reclaim spent shales leachates, the lower the concentrations of possibly will require inoculation with mycor- soluble salts in the processed shale. At higher rhizal fungi to enhance their growth and sur- pHs many plant nutrients are insoluble, and vival. 112 Colonizing species on disturbed lands plants will generally not grow in a strongly al- are often nonmycorrhizal. 113 It has also been kaline soil medium. found that with increasing soil disturbance or If processed shales are to be used directly the addition of processed shale, the ability of as a growth medium, their alkalinity must be the soil to be infected with mycorrhizal fungi reduced. This can be done by leaching follow- decreases. The most successful revegetation ing deposition and proper compaction, or by species become mychorrhizal only late in adding costly acids or acid-formers. 107 Expo- their establishment. There appears to be no sure to the atmosphere over a period of sever- significant effect of the seed mixture, the fer-, al months to several years will reduce it natu- tilizer, the mulch, or irrigation on a soil’s po- rally. tential for mycorrhizal infection following its disturbance. 114 Nutrient Deficiencies Salinity Spent shales have been shown to be highly deficient in the forms of nitrogen and phos- Because spent shales are often quite salty, phorous available to plants. 108 Therefore ni- they present major problems for establishing trogen and phosphorus fertilizers need to be vegetation, and for the water quality from added. These can be applied at any time of surface runoff or drainage through them. 115-120 year but spring fertilization has been recom- High concentrations of salt in the soil media mended to prevent burning and to reduce fer- restrict water and nutrient uptake. * These tilizing weedy species. 109 It will probably be can only be lowered by leaching with supple- necessary to fertilize with nitrogen for sev- mental water. eral years until the ecosystem begins to fix 110 and recycle its own nitrogen. *Electrical conductivity is a measure of a soil’s salinity. A *PH is a means of expressing acidily or basicity. It ranges conductivity of 4 mmho/cm is considered saline, and above 12 from 1, highly acidic through 7, neutral, to 14, highly alkaline. mmho/cm, highly saline. Ch. 8–Environmental Considerations ● 335

Leaching essed shale leachates, selenium and arsenic are not cause for concern, but fluorine, Depending on the characteristics of the boron, and molybdenum are more serious. ’z] spent shales, about 5 acre-ft of water per Plants grown on processed oil shales and soil- acre will be needed for leaching and plant 122 covered processed shales in northwestern growth. This is based on a net requirement Colorado have been found higher in molyb- of 48 inches of leaching water and an 80-per- denum and boron than plants grown in ordi- cent irrigation efficiency. The actual supple- nary soil, although their selenium, arsenic, mental water needed will vary with annual and fluorine contents were moderate. 124 precipitation, evaluation, and aspect, To ensure adequate infiltration and to prevent erosion, it should be continually applied at low Excessive Heat rates (e. g., 2 to 3 cm/hr) and in a spray form. The color of the processed shale reflects Leaching will probably not be uniform over the amount of residual carbon on the retorted the entire surface, therefore surface monitor- particles. Black and gray processed shales ing and additional localized leaching may be are produced by low- and high-temperature needed. processes, respectively. The color influences the surface temperatures of the plant growth Toxicity media which, in turn, affects seed germina- High concentrations of boron in spent shale tion and the plant-water relationship. The can be toxic to plants. On the other hand, the dark-colored material warms up earlier in elements molybdenum, selenium, arsenic, the spring, inhibits seed germination more, and fluorine (also found in shale) are general- and creates drier soils than does lighter col- ly not toxic to plants. However, when these ored processed shale. Temperatures of up to 78° C (196° F) have been reported for the elements are taken up by plants, they can be- 125 126 come toxic to grazing animals. Susceptibility TOSCO II material. The color can be to such toxicity varies among animal species modified to a certain extent by the use of sur- as well as within a species. It is dependent on face mulches or a covering of topsoil-like ma- the concentration of the elements within the terial, which reduces many of the salinity and plant, the size of the animal, its daily diet, and alkalinity problems as well as the need for its general physiological condition. The condi- supplemental water. tions that encourage the uptake of these ele- Another temperature problem encountered ments by plants, and their resulting toxicity in the massive disposal of spent shales is that in animals are complicated and poorly under- the processed shales will probably go into the stood. Proper management should help to disposal pile at temperatures in excess of 40” avoid or alleviate the problems with livestock. C (98° F). This will create a heat reservoir, It This can be achieved by restricting livestock is not known how long it will take to cool, If a grazing to seasons when the elements are spent shale pile is warmer than normal soils present at low concentration in the plants, by within the area, the site would be drier than varying the mix of plant species to be used in expected because of the increased potential the grazing areas, and by feeding seques- for evapotranspiration. tering supplements to reduce the toxicity of the elements. The management of wildlife, however, is very difficult and problems will Use of Topsoil as a Spent Shale Cover persist in this realm. An alternative to revegetating directly on The dominant soluble ions in spent shale spent shale is the establishment of vegetation are sodium and sulfate, with abundant calci- on a cover of topsoil or topsoil-like over- um, magnesium, and bicarbonate also pres- burden material placed over the spent shale. ent. Of the trace elements identified in proc- Such a soil cover offers several advantages. — —

336 ● An Assessment of 0il Shale Technologies

Because it does not have the problems of high basins will also be useful in deciding what salinity and alkalinity, no supplemental water materials to use. It is doubtful that the capil- is required for leaching. The material is a lary rise of salts will be a problem unless soils more suitable medium for plant growth be- are continually exposed to saturated condi- cause it has greater water-holding capacity, tions. This might happen if improper engi- more nutrients, and promotes a more intimate neering of the disposal site created seeps or relation with plant roots. allowed pending. Economics and a possible lack of longevity are the primary disadvantages of using a soil Species Selection and Plant Materials cover. Additional costs would be incurred for segregating suitable materials from those The selection of plant materials to be used with undesirable properties, for transporting in reclaiming processed shale is determined and storing materials, and for surfacing over by several factors, the most important of the spent shales. In time, the natural geologi- which is species adaptability. Adaptability cal process of erosion may eventually cut (suitability) is intimately tied to the ability of a through the soil cover and expose the spent plant to complete its entire lifecycle, and to shale. An artificial soil profile using over- reproduce itself from year to year over a long burden materials between the topsoil and the period. The plant’s growth form, drought re- spent shale would greatly reduce, if not elimi- sistance or tolerance to stress, mineral nutri- nate, the problem. With proper management tion requirement, and reproduction charac- most erosion should be localized. However, teristics must all be considered. In addition to with improper management such as overgraz- being adapted to the growth medium, plants ing, reductions in vegetative cover could oc- must also be adapted to local temperatures, cur that would allow larger areas to be ex- elevation, slope, aspect, and wind conditions. posed. If erosion were gradual over a few They should be able to survive the weeds and hundred years, the vegetation possibly would animals that may invade the site. Palatability adapt to the thinning soil cover, and natural to livestock and wildlife as well as availabili- leaching and weathering could render the ty of seed and competition among species spent shale a more suitable growth medium. being planted are also important factors. Despite these disadvantages, the use of a soil cover will provide for the more rapid estab- In addition to the results of actual revege- lishment of a vegetative cover that will per- tation test plots, several information sources sist longer than would vegetation established and guides are available to assist in the selec- directly on spent shale. tion of species adapted to conditions likely to The depth of the soil cover needed will vary be encountered in oil shale reclamation.130-134 from site to site, but will generally range from These include the Plant Information Network 1 to several ft in thickness. 127 128 Soil surveys computerized data bank located at Colorado 135 of the Piceance basin indicate that sufficient State University. soil and soil-like material exists in the disposal sites, particularly those with deep alluvial In general, mixtures of various grasses, deposits, and this should provide adequate forbs, shrubs, and in some cases trees, are desirable because they offer a greater range cover material. 136 of adaptation. Mixtures may include spe- The selection of topsoil or topsoil-like over- cies adapted to each of the different microcli- burdens will have to be based on chemical mates, moisture levels, and soils. The results and physical analyses. This is important be- of using a well-planned mixture can be a fast- cause the soil types and their toxicities vary. establishing, long-term cover that is less vul- The treatment of the soil cover will be similar nerable to pests, disease, drought, and frost. to the treatments of soil used for the reclamation of surface-mined coal areas, about which Recommended mixtures used in test plots there is more knowledge.129 Soil surveys of the may include both indigenous (native) and in- Ch. 8–Environmental Considerations ● 337

troduced perennial species. In one study, a Seeding is best done in late fall or early mixture of native and introduced species dis- spring when soil moisture is high, although played the highest productivity and allowed the operation of seeding equipment in the the least amount of invasions by weeds.’}’ Al- spring may be hampered by wet soil condi- though a mixture of non-native species had a tions.’” Seeding rates may vary from 10 to 30 higher plant density, it also allowed the great- lb of pure live seed per acre depending on est invasion of weeds. 138 Weeds are undesir- slope and whether the seed is broadcast or able in that most are annuals (complete their drilled. Drier exposures and broadcast tech- lifecycle in 1 year) dependent on precipita- niques require more seed. tion; they are therefore an unreliable erosion control. They also compete with the more de- Another problem in propagating plants sirable perennial species (species that persist from seed is dormancy of seed. Extensive for several years) for water and nutrients. treatment of the seed may be required in These annuals are expected to disappear order to overcome it. For these reasons, vege- with natural succession over a few years. tative propagation is a necessary alternative to seed propagation for producing planting Species selection is complex and involves, stock of native species. in addition to considerations of the species itself, a tradeoff among many interacting fac- Containerized Plants 139 tors. These include: Federal, State, and lo- Container-grown plants have been success- cal reclamation requirements; rehabilitation fully used in several oil shale revegetation and land use objectives; the nature of the site; studies. 142-144 They offer several advantages the timing of the program; species compatibil- over seed: 145 ity; mechanical limitations in planting; seed and seedling availability; maintenance after they make efficient use of scarce seed or planting; and cost, seeds especially adapted for harsh sites, plant survival and growth are optimized by rapid root growth into the surround- Seeds ing soil, Planting seed by drilling or broadcasting is well-developed plants are generally able to withstand grazing or other stresses, a common way of establishing vegetation in a and reclamation plan. Seed is available commer- they can be inoculated with fungi just be- cially from collectors and seed companies. ’40 fore seeding to ensure the development While many commonly used seeds are availa- of mycorrhizae. ble from dealers under contract, procedures for cultivating wildland plants for seed pro- Container-grown plants can be hardened to duction have generally not been developed. the fluctuating and more extreme environ- Also, certain varieties of the native plant mental conditions they will encounter at the species may not be available from commer- revegetation site by gradually exposing them cial sources. Until reliable seed production to drier conditions and greater temperature techniques are developed (which may require extremes. The higher cost of container-grown up to 10 years), seeds for propagating native stocks is offset by their better survival rate. 146 plants will generally have to be collected They are recommended for fall or early from wildland populations. This may be a spring planting on harsh sites where estab- problem for a large oil shale industry, since lishment of seeds may be difficult or impossi- seed production from wildland populations ble due to erratic or low precipitation or can be unpredictable from year to year; some other environmental stresses. Bare root stock native species produce abundant seed crops is another alternative, but can only be used only in years when conditions are especially with sufficient soil moisture to ensure good favorable. root penetration into the growth medium. 147 ——

338 ● An Assessment of Oil Shale Technologies

Timing of Reclamation Cost of Reclamation Initiation of revegetation efforts will be Estimates of average reclamation costs delayed during the first 3 to 10 years of range from $4,000 to $l0,000/acre depending operation until sufficient waste materials on the site conditions and the land use to be have been compacted and require further achieved. If disposal is completely on the sur- stabilization. Disposal will likely begin at one face, this represents only about 1.4 to 4.4 end of a canyon and fill up in strips rather cents/bbl of shale oil for a 50,000-bbl/d oper- than gradually filling the entire canyon. This ation. will allow early stabilization of narrow strips of land thereby minimizing the size of active disturbance. Protection of the Reclaimed Site Once revegetation begins, reclamation The reclaimed areas should be protected needs will gradually increase as portions of by proper management and monitoring to en- disposal sites are prepared for planting. At sure that stability is maintained. Protection full production, reclamation needs would de- will be needed whenever the vegetation on pend on processing rates and method of dis- the site may be threatened by livestock posal. (See table 69.) (including feral horses), wildlife, invading weeds, or human activity. This can be done Complete filling of canyon disposal sites largely by controlling the degree of use. may take up to 30 years or more depending on processing rates and the sites’ disposal ca- The impact of livestock use on the erosion pacities. Early revegetation of narrow strips of revegetated spent shale is unknown; it is will permit the evaluation of reclamation possible that erosion of the finer processed techniques, and allow for any modifications shales on steep slopes could be substantial. that may be needed during subsequent reveg- Erosion from livestock use on soil-covered etation efforts. shales would be less of a problem. This as-

Table 69.–Estimates of Reclamation Needs Under Various Levels of Shale Oil Production

Production level (bbl/day)

50,000 50,000 b 100,000 250,000 1,000,000 Required annual disposal area (acres)c

— . 698-796 279-318 138-159 344-398 1,378-1,592 Water requirements (5 acre-ft/acre) 349-398 acre-ft/yr 140-159 acre-ft/yr 690-795 acre-ft/yr 1,720-1,990 acre-ft/yr 6,890-7,960 acre-ftlyr Fertilizer Nitrogen (80 lb/acre) 5,584-6,368 lb/yr 2,232-2,544 lb/yr t 1,040-12,720 lb/yr 27,520-31,840 lb/yr 110,240-127,360 lb/yr Phosphorus (80 lb/acre) 5,584-6,368 lb/yr 2,232-2,544 lb/yr 11,040-12,720 lb/yr 27,520-31,840 lb/yr 110,240-127,360 lb/yr Seed (30 lb pure Iive seed/acre) 2,094-2,388 lb 837-954 lb 4,140-4,770 lb 10,320-11,940 lb 41,340-47,760 lb Containerized plants (300/acre) 20,940-23,880 pits/yr 8,370-9.540 pits/yr 41,400-47,700 pits/yr 103,200-119,400 pits/yr 413,400-477,600 pits/yr Mulch Wood fiber ( 1,500 lb/acre) 104,700-119,400 lb/yr 41,850-47,700 lb/yr 207,000-238,500 lb/yr 516,000-597,000 lb/yr 2,067,000-2,388,000 lb/yr straw (3,000 lb/acre) 209,400-238,800 lb/yr 83,700-95,400 414,000-477,000 lb/yr 1,032,000-1,194,000 lb/yr 4,134,000-4,776,000 lb/yr w/asphalt binder (300 gal/acre) 20,940-23,880 gal/yr 8,370-9,540 gal/yr 41,400-47,700 gal/yr 103,200-119,400 gal/yr 413,400-477,600 gal/yr aAll numbers are approximate Actual needs will vary with aridity of the she (elevallon, slope, and aspecl) adapled planl Sr)ecles selected and SJrl arnertdrnenls rewed bASSumeS bo.percen! Cllsposal In underground rnlne Worklws CASSUMeS disposal ~lle 451 meters 11 so ft) deep Acreage esflrnales Were based on Po//uIIorI Conlro/ Gu(darrce for 0// S/ra/e Deve/oprnenl Environmental protection Agency. Clnclnnatl Ohio. JUIY 1978 P 3-68 SOURCE Plant Resources lnshtute The Rec/arna//orr ofl?ocessed 0(/ S/ra/e prepared for OTA January 1980 Ch. 8–Environmenlal Considerations ● 339 pect of postmining land use will require care- ● baseline studies that describe the eco- ful monitoring. Indirect methods for protect- logical characteristics of the existing en- ing a site against livestock include adding less vironment in the oil shale basins, and palatable species to the seed mixture, pro- ● characterization studies of processed viding salt blocks and permanent water sup- shale and the testing of reclamation plies away from the seeded areas, controlling methods. livestock numbers, herding, fencing, and, if necessary, repellents. l48 Data from both types of research are needed in designing, directing, and assessing past and future reclamation studies.

Baseline Studies A general description of the vegetation of the oil shale basins can be found in chapter 4. Additional descriptions that contribute to the baseline data are available for Federal lands from BLM’s Unit Resource Analysis151 and Management Framework Plans. 152 More specific vegetation inventories have also been made for site-specific areas within these basins such as transmission and pipeline corridors, Land classification systems have also been developed for the piceance basin,153 154 Eighteen phyto-edaphic units (plant-soil units) were identified. 155 The description of each Photo credit OTA staff unit provides information on soil, vegetation, Reclaimed sites will have to be protected from wildlife climate, aspect, and landform interpretations and hazards of land use. A section on reclamation considerations is provided to iden- Protection against wildlife will also be re- tify the most hazardous characteristics of the quired. This includes large herbivores as well unit (e. g., the potential for erosion and slump- as small burrowing animals such as pocket ing) that need special attention and care, par- gophers that can be expected to move into the ticularly after disturbance as a result of oil revegetated area. If not controlled, over- shale development. Management recommen- utilization of vegetation may occur and toxic dations and alternatives are supplied to over- compounds may be brought to the surface by come the identified limitations. burrowing animals. 149 Monitoring and subsequent management Other information on plant community re- must also ensure that refertilization, seeding, lationships (phytosociology) is currently being and additional control of erosion or weeds, gathered by Colorado State University for the are provided if necessary, Similarly, monitor- Piceance basin. This will help the land man- ing plant succession, productivity, and uti- agers and reclamation specialists to select lization should all be included in the reclama- the proper species to be used in reclamation. tion management plan. 150 Such studies are lacking for the basins in Wyoming and Utah, and few physiological studies have been conducted with existing Review of Selected Research to Date plant species at the proposed disposal sites or with plant materials to be used in reclama- Research undertaken on the topic of oil tion to determine their tolerance limits to the shale reclamation falls into two categories: various adverse conditions likely to be en- 340 ● An Assessment of 011 Shale Technologies countered. Little is known about the natural process. 163 During these studies the basic genetic differences that exist in native plant chemical data needed to design a reclamation communities. These might make the plants program were incorporated into greenhouse more or less adaptable to adverse environ- and small field plots (100 ft2). Revegetation mental conditions encountered in oil shale work on other processed shales, all of which reclamation. are coarser, had been confined to Union Oil plots planted in 1966 and Colorado State Uni- Reclamation Studies versity plots planted in 1973. In the late 1960’s and early 1970’s, larger field plots Investigations to determine the manage- (41,000 ft2) were built using many of the results ment needed to produce conditions favorable of the earlier experiments, including the ef- to the establishment and growth of plants on fects of soil supplements such as fertilizer processed shales were initiated by private in- and organic matter. dustry in the mid-1960 ’s. ’5’ These were based on previous knowledge developed by range Since the early 1970’s, studies have been managers, biologists, and numerous arid and conducted on disturbed soils without proc- semiarid studies, as well as other baseline in- essed shales to determine the establishment formation from the oil shale basins. of plant species, microbial activity, and long- Where possible, the sites for reclamation term successional trends. These studies were tests have been selected to simulate, as close- encouraged by the finding that the revegeta- ly as possible, the environmental conditions tion of soil-covered processed shales was to be encountered during the reclamation of more successful than revegetation directly on disposal sites used for large-scale production. processed shales. This was because the soil Sites have been selected in high- and low- cover does not have the adverse chemical and rainfall areas, with various combinations of physical properties of processed shale that slope, aspect, and processed shale materials. inhibit plant growth. However, most revegetation experiments have been hampered by a lack of processed Supplemental water has been used to es- shale. This shortage, coupled with the high tablish plants in most of the processed shale costs of transporting retorted shales to field revegetation studies. The addition of 10 to sites (in some cases from as far away as 13 inches of water during the first growing California), have restricted both the size of season with no subsequent irrigation has the test plots (2 to 5,000 ft2), and the type of resulted in the establishment of a vegeta- processed shale evaluated. tive stand and the persistence of adapted species for several years. The salt leaching To date, field studies using spent oil shales requirement (5 acre-ft of water per acre) is in as plant growth media have centered on the addition to this supplemental water. Only TOSCO II, Union “A” and “B,” and Paraho 157-162 limited success in seeding and transplanting materials. These studies show that with into spent shale without supplementary wa- intensive treatments plant growth can be es- 164 ter has been reported. However, establish- tablished directly on spent shales, although ment without supplemental water might be use of a soil cover is more successful. achieved by mulching with straw or hay and It is difficult to compare the results of allowing salts to be leached by natural pre- revegetation studies with the various proc- cipitation prior to seeding or planting, al- essed shales because the experimental de- though the time period required for this could signs varied so widely. Different plant spe- be unreasonable. Micro-watersheds consist- cies were used, and fertilizer, mulch, slope, ing of low-level diversion barriers or aspect, and soil cover also varied. Most of the mounded spent shale have also been pro- early (1965 to 1973) revegetation studies for posed and initiated to concentrate water for Colony used spent shale from the TOSCO II plant growth.165 Ch. 8–Environmental Considerations ● 341

Several researchers have worked on the Summary of Issues and R&D Needs problems of leaching soluble salts from the processed shales and the surface stability of Research to date has shown that with in- several retorted shales including TOSCO tensive management vegetation can be estab- II.166-172 It appears unlikely that salts will lished directly on processed oil shales. The migrate to the surface by capillary rise in primary requirements are the leaching of most areas of low precipitation. Only in areas high levels of soluble salts with supplemental where soils were saturated by supplemental water, the addition of nitrogen and phos- water was there temporary desalinization of phorus fertilizers, and the use of adapted surface layers. When the supplemental wa- plant species. However, the establishment of ter was discontinued, surface salinity began vegetation on spent shales covered with at to drop due to leaching from natural precip- least 1 ft of soil is preferred because it is less itation. From these studies a better under- susceptible to erosion and does not require as standing has developed of solutions to the much supplemental water and fertilizer. problem of establishing a self-sustaining Adapted plant species are required for either vegetative cover. soil-covered or spent shales. Several studies are continuing, and a new The long-term stability and the self-sus- 173 successional study has been initiated to taining character of the vegetation is un- evaluate the long-term feasibility of using known, but if sufficient topsoil is applied the processed shales directly as plant growth results of research on small plots indicates media and the influence of various depths of that short-term stability of a few decades ap- soil cover over spent shale. It has been set up pears likely. Monitoring and subsequent man- in the Piceance basin to obtain information agement must ensure that any necessary re- related to the reseeding of disturbed areas in fertilization, seeding, and erosion and weed order to reestablish a diverse, functional control be provided. The reclamation man- ecosystem in as short a time as possible. agement plan must also include monitoring Various seed mixtures, ecotypic varieties of plant succession, productivity utilization, and native species, microbial activities, seeding the presence of high concentrations of ele- techniques, fertilizer levels, irrigation, and ments toxic to plants and animals. mulching treatments are being evaluated. In addition, the rate and direction of plant suc- Whether or not the revegetation of spent cession is being monitored to identify signifi- shales is considered successful depends on cant trends in vegetation changes, and to de- the desired land use and the performance termine how these trends are influenced by standards applied to measure the success. the various treatments and practices, 174 For example, the reestablishment of vegetation that reduces erosion and is productive, Few studies have been conducted on raw self-sustaining, and compatible with sur- shale. This is because in the past it has been rounding vegetation might be considered suc- assumed that most raw shale of commercial cessful for livestock but not for wildlife use. quality will be retorted. Additionally, the raw The minimum requirements for vegetation oil shales are hard and resilient. When should be to stabilize the disposal sites so that mined, the shale fractures into coarse frag- the detrimental effects caused by erosion can ments that have extremely low water-holding be minimized. Where ecologically feasible, capacities, which renders them undesirable multiple land use of disposal sites should be growth media. For these reasons, it is likely encouraged. that raw shale of noncommercial quality would be buried deeper in the disposal piles Reclamation plans will have to be site spe- and not used as a growth medium, cific since environmental conditions vary 342 ● An Assessment of 011 Shale Technologies from site to site. Proper management will be be encountered in the reclamation of the required in all instances, if only to protect spent shales. This should include the plant communities in surrounding areas from identification of ecotypic variations, harm. Proper management is even more im- seed production by cultivating adapted portant in the reclaimed areas. If the vege- wildland plants, and research to deter- tative cover were completely lost, the nega- mine species performance under abnor- tive effects would increase. The conditions mal conditions (e.g., drought, salinity, would not be as severe as those without any and high temperatures); reclamation because they would be reduced ● the role and use of soil microbes and by restrictions in slope, catchment and diver- mycorrhizal fungi in soil building and sion dams, and other mitigation completed in plant growth. Successful reclamation the early stages of reclamation. will depend on developing a protocol to If revegetation completely failed, produc- select and/or maintain the essential tive land use would be severely reduced or mycorrhizal fungi in disturbed habitats eliminated. It is doubtful that, after once or to develop methods to reinoculate being reclaimed, conditions would deterio- these fungi in habitats where they are absent; rate to the point of eliminating all vegetation ● from a disposal site, although a natural suc- the plant succession for large areas of a cession of species would occur that would few hundred acres in size under natural favor those that had superior adaptability to and disturbed conditions, including the the harsh conditions. Weedy or unpalatable influence of animals on revegetated surfaces; species of less use to livestock and wildlife ● would undoubtedly invade the sites. the toxicity of elements such as fluorine, boron, molybdenum, selenium, and arse- The types of reclamation needs for a large- nic to plants and grazing animals. A pro- scale industry (1 million bbl/d) are similar to gram to monitor these elements should those generated for a small industry (50,000 be established on newly reclaimed areas bbl/d), but differ in the amounts of materials at least for the first few years; that will be required and the rates at which ● the probable heat retention within the they must be supplied. It is probable that disposal pile and its effect on reclama- shortages of adapted plant materials and as- tion timing and revegetation; sociated support materials (such as mulches ● the rates of erosion on large, reclaimed and greenhouse facilities) would occur at the areas of a few hundred acres in size. In- higher production rates. The problem is com- formation is needed on how much water pounded by the fact that demands for plant runs off the area following snowmelt in materials are increasing from other mining the spring and after high-intensity sum- operations such as coal and uranium. The mer storms, including how much sedi- severity of the shortages will depend on ment and soluble salts will be contained whether the oil shales are processed in situ or in the water; and surface retorted, and whether the processed ● the viability of vegetation on raw shale, shales are disposed of underground or on the surface. Surface reclamation needs will be somewhat less demanding with MIS process- Policy Options for the Reclamation of ing or with underground disposal of surface- retorted shales. Processed Oil Shales Research on the reclamation of processed For Increasing Available Information shales is continuing. Areas of major concern More information is desirable on reclama- requiring additional study include: tion methods and the selection of proper plant ● the selection and propagation of species species for revegetation programs. Options especially adapted to conditions likely to for obtaining this information include the Ch. 8–Environmental Considerations 343 evolution of existing R&D programs by the tivating specific wildland plants for seed pro- U.S. Department of Agriculture (USDA), EPA, duction have generally not been developed. and other agencies; the improved coordina- Also, seeds of certain native plant species are tion of R&D work by these agencies; increas- not commercially available. ing or redistributing appropriations to accel- A shortage of seeds could be a problem for erate reclamation and revegetation studies; a large oil shale industry. For example, the and the passage of new legislation specifi- USDA’s plant materials centers often require cally for evaluating the impacts of land dis- up to 15 years to identify and develop turbance. Mechanisms are similar to those adapted species for release to commercial discussed in the air quality section of this suppliers or to industry for trial plantings. chapter. Furthermore, the centers intentionally limit their activities so that they will not compete To Develop Reclamation Guidelines for Oil Shale with commercial producers. Thus, they have SMCRA provides for comprehensive plan- not developed mass production capabilities, ning and decisionmaking to manage disturbed nor have they adopted some of the more re- land. However, in general, the reclamation cent propagation technologies (such as micro- standards promulgated under the act are propagation, cutting, and fungal and bacteri- only appropriate for coal, but not necessarily al inoculation) that are used commercially. In for oil shale. Thus, new reclamation guide- order to meet the future demands of a large lines specifically for oil shale may be desir- oil shale industry, it may be necessary for the able, with standards for postmining land uses centers to expand their facilities and prop- that are ecologically and economically feasi- agation capabilities. This could be costly in ble and consistent with public goals. If the terms of facilities, technologies, and person- Act were amended to encompass oil shale, nel. Policy mechanisms for expanding cooper- Congress could direct that reclamation guide- ative agreements between the centers and lines be developed by DOI’s Office of Surface commercial producers need to be developed. Mining, either alone or in conjunction with These activities would not only benefit oil other agencies. Alternatively, Congress could shale, but also most other reclamation and pass new legislation calling for the prep- arid and semiarid revegetation projects as aration and implementation of reclamation well. guidelines for oil shale.

To Expand the Production of Seeds and Plant Materials While many common seeds are available from commercial dealers, procedures for cul-

Permitting Introduction the States to determine whether a prospective facility is able to meet specific require- During the past 10 years an increasingly ments under the law. The operation of an oil complex permitting system has been devel- shale facility requires well over 100 permits oped to assist the Federal, State, and local and other regulatory documents from Feder- governments in protecting human health and al, State, and local agencies. They include the welfare and the environment. Permits are the permits for maintaining the environment and enforcement tool established by Congress and for protecting the health and safety of work- 344 . An Assessment of 0il Shale Technologies ers, and in addition, those that would be regulations and statutes it has often been dif- needed for any industrial or commercial ac- ficult to know which agency must be con- tivity: building code permits, permits for the tacted, and which permits are required from use of temporary trailers, sewage disposal which entity. permits, and others. Of these, a few—the ma- The following discussion examines: jor environmental ones—require substantial commitments of time and resources. The ma- ● how various parties view the permitting jor environmental permits that must be ob- process; tained prior to the operation of an oil shale fa- ● the current status of oil shale developers cilit y are: in obtaining the needed permits; ● the time required for preparing and ● a PSD permit required under the Clean Air Act; processing permit applications; ● the disputes encountered so far in ob- ● an Air Contaminant Emissions permit required by the State of Colorado; taining such permits; ● the potential difficulties that might be ● a Special Primary Land Use permit— which is required for plant siting in Rio encountered by a developing oil shale industry; and Blanco County; ● ● possible policy responses to permitting a Mined Land Reclamation permit re- issues. quired by the State of Colorado; ● an NPDES permit required under the Clean Water Act; Perceptions of the Permitting Procedure ● a section 404 Dredge and Fill permit under the Clean Water Act if the operation The various parties interested in environ- affects navigable waters; mental permits for oil shale facilities have ● a Subsurface Disposal permit as re- widely divergent views concerning the effec- quired by the State of Colorado if water tiveness and problems of the permitting pro- is reinfected; cedure. Industry is concerned about the ● a permit for the disposal of solid wastes length of time it takes to obtain permits and generated by the facility required under the uncertainty of obtaining them. The envi- RCRA; ronmental community is watchful of the pro- ● testing of effects, recordkeeping, report- cedure’s effectiveness in enforcing the law; ing, and conditions for the manufacture and the regulators themselves are troubled and handling of toxic substances as stip- by their limited personnel and budgetary re- ulated under TSCA; and sources. ● an EIS as required by the National Envi- The high cost of oil shale projects makes ronmental Policy Act-if an oil shale plant unexpected delay costly, and industry is con- involves a major Federal action signifi- cerned with uncertain agency decision sched- cantly affecting the environment. ules or with unpredictable litigation that can The responsibilities for reviewing and ap- delay or prevent project construction. Fur- proving applications are distributed among thermore, some regulations and standards many Federal, State, and local agencies. Fed- have not yet been set because of a lack of suf- eral agencies include EPA, the Department of ficient knowledge about the impacts of shale the Treasury, DOI (including BLM and USGS), operations and the effectiveness of their con- the Department of Defense (e.g., the Army trol. Developers are particularly worried Corps of Engineers), and the Interstate Com- about the effects of new regulations (such as merce Commission. State entities in Colorado for visibility maintenance as part of the PSD include the Department of Health, the De- process) on process design and project eco- partment of Natural Resources, and the State nomics. They are concerned that new regula- Engineer. Because of varied and overlapping tions could necessitate costly retrofits to ex- Ch 8–Environmental Considerations . 345 isting plants or even the cessation of opera- are seldom made for public participation, and tions. For facilities under construction, the access is not provided to the information new regulatory requirements may mean rede- needed to evaluate the applications. They sign or addition of environmental control note that few agencies have an affirmative equipment or strategies. These uncertainties public involvement process. They find it is increase the risk that a project, once started, often difficult to follow and monitor agency may not be completed. Prospective develop- decisionmaking. ers also express their frustration over the The regulators feel overwhelmed by the in- lengthy and expensive procedures for prepar- creasing number of permits and by the com- ing permit applications (including monitoring plexity of the review. They believe that their and modeling requirements) to meet some en- personnel and financial resources are too vironmental statutes. This discontent is some- limited for the present caseloads and certain- times compounded by overlapping agency ly will be dwarfed by any rapid increase in jurisdictions and by repetitive paperwork. applications arising from an expanding energy industry, EPA’s Region VIII, for example, The environmental community asserts includes not just the oil shale region, but most that, given the complexity of oil shale opera- of the Western coal and uranium resources. tions, the extensive application and review procedures are necessary to fully assess envi- Regulatory personnel also contend that they ronmental impacts, the effectiveness of con- are handicapped by inadequate technical information about the technologies that they trol measures, and compliance with environmental law. They suggest, in fact, that agency must review and assess. enforcement of environmental laws is too often compromised by weak regulations and Status of Permits Obtained by by a lack of essential information on which Oil Shale Developers both to base permitting decisions and to en- force the conditions of the permits. Informed, The number of permits needed for a given meaningful public involvement in the process- facility depends on its site; on whether it in- ing of environmental permits is therefore pro- volves Federal land; on the scale, type, and moted by environmental groups to ensure combination of processing technologies used; that all points of view are represented in and on the duration of the operations. As agency proceedings. It is particularly impor- stated previously, the permits range from tant, these groups hold, that the technical those required for a temporary trailer to the analyses on which agency decisions depend major environmental permits required under are subjected to independent scrutiny. How- Federal and State regulations and standards. ever, they believe that adequate provisions Table 70 shows the status of the major per-

Table 70.–Status of the Environmental Permits for Five Oil Shale Projects

Regular open Project Type of tract EIS DDP approval PSD permit mining permit NPDES permit

a R IO Blanco Federal lease tract Final programmatic Yes For 1,000 bbl/d Yes 1st phase C-a Issued a Cathedral Bluffs Federal lease tract Final programmatic Yesa For 5,000 bbl/d Yes 1st phase C-b Issued a Long Ridge (Union) Private Not applicable Not applicable For 9,000 bbl/d Yes Not requiredb Colony PrivateC Not applicable Not applicable For 46,000 bbl/d Not yet applied Not requlredb Superior Private/Federald Not applicable Not applicable Not yet applied Not yet applied Not yet applied aLlllgallon proceeding over aopro JaI of the momhed DDP bThese operallofls do not plan 10 discharge 10 Surf aCe StreaMS cExchange of Federal land and plpellne rlgh[ of way otier BLM and ‘equesled ‘Land exchange requested SOURCE Office of Technology Assessment 346 ● An Assessment of 011 Shale Technologies

mits obtained by five oil shale developers. mits can take more than 2 years. The prep- These facilities are presently in different aration and review of the PSD application is stages of commercial development. The Rio perhaps the most comprehensive and time- Blanco, Cathedral Bluffs, Colony, and Superi- consuming step. Baseline air monitoring is re- or projects involve Federal land, while the quired, along with extensive dispersion mod- Union project is located on private holdings. eling to estimate the effect of the plant’s emis- DDPs for tracts C-a and C-b had to be ap- sions on the region’s air quality. Once this proved by USGS because they are part of the work is completed and an application sub- Federal Prototype Oil Shale Leasing Program. mitted to EPA, the approval process, as stipu- Four of the projects have already been lated under the law, can take as long as 1 granted PSD permits for their facilities. Note, year. However, EPA tries to rule on the appli- however, that with the exception of the Col- cation within 60 days, and to date an average ony project, only small-scale, first-phase con- of about 90 days has been required. (This in- struction air emissions have been approved. cludes internal staff review and a period for All of the facilities have to obtain Mined public comment. ) Land Reclamation permits. Rio Blanco, Cathe- It should be noted that a project would not dral Bluffs, and Union have all been approved necessarily be delayed by the full length of for commercial-scale modular operations. the permitting schedule, because other prede- Colony and Superior have not yet applied. velopment activities such as detailed engi- NPDES permits are required under the Clean neering design, contracting, and equipment Water Act if a plant discharges to a surface procurement could proceed in parallel, if the stream. So far Rio Blanco and Cathedral developer were willing to accept the risk that Bluffs have received such permits for the key permits might eventually prove to be un- first phase of their commercial development. obtainable.

The Length of the Permitting Procedure Disputes Encountered in The time required for preparing and proc- the Permitting Procedure essing a permit application depends on the The principal problems encountered to type of action being reviewed, the review pro- date are related to the needs of the regulatory cedures stipulated under the law, the criteria agencies for technical information, to differ- used by agencies to judge the application, and ing interpretations of environmental law, the amount of public participation and con- and, according to developers, to a lack of re- troversy. If Federal land is involved, then an sponsibility for timely action on the part of EIS will most likely be required. This process the agencies. may take at least 9 months after the developer applies for permission to proceed with Occidental’s application for a Subsurface the project. * Then the applications for the Disposal permit for its sixth experimental necessary construction and operation per- MIS retort on its property near De Beque, mits can be prepared and filed. In the case of Colo., was delayed for several months by the the current Federal lease tracts, additional Colorado Water Quality Control Commis- time was needed to prepare the DDPs for ap- sion’s consideration. (The commission had not proval by the Area Oil Shale Supervisor of required permits for the first five retorts. ) USGS. The commission was concerned about the potential for ground water contamination by the Once the requirements for an EIS and DDP abandoned MIS retorts and was not satisfied are satisfied, obtaining all of the needed per- with the evidence presented by Occidental

*The programmatic EIS for the Prototype Leasing Program that pollution would not occur. Additional took 4 years. Preparation of the draft EIS for the proposed Su- technical information was requested, and the perior land exchange required 2 years. commission insisted on a cooperative environ- Ch. 8–Environmental Considerations ● 347 mental monitoring and research program in- proval of DDPs that were submitted by the volving DOE, the State of Colorado, and sever- lessees in 1976. This dispute has thus far not al universities. The dispute was resolved delayed construction on the tracts, It does, when Occidental agreed to the program and however, exemplify the type of uncertainty the investigators were given access to Oxy’s that, the developers maintain, discourages site for sampling and experiments. them from initiating oil shale projects. The As work began on tracts C-a and C-bin late plaintiffs claim that no statement to date has 1977, soon after DOI approved the modified adequately analyzed the effects of these DDPs, a dispute arose among several environ- plans. Defendants believe that the 1973 pro- mental groups, permitting agencies, and the grammatic EIS appropriately evaluated the lessees over the timing of required permits. 1976 plans and the alternatives to their ap- EPA initially informed the lessees that air proval. The Federal district court agreed quality and State mining and reclamation with the defendants. The case was heard by permits would not be required until the min- the 10th Circuit Court of Appeals which also ing of actual in situ retorts began, The envi- ruled in favor of the defendants. ronmental groups maintained that construc- Other than these disputes, there have been tion commenced with shaft-sinking and con- no substantial interruptions that could be struction of the surface facilities needed for directly related to permitting. The only the MIS retorts. This work had already begun lengthy application review period involved and, according to the environmental groups, Colony Development Operation’s PSD air permits should have been in hand, They fur- quality permit. EPA did not expedite its re- ther contended that the interpretation of view of this permit because the applicant in- “commencement of construction” used by the dicated it was still inactive, awaiting more agencies evolved during meetings that were favorable project economics. In addition, 1- not open to public participation, year suspensions were requested in 1976 by EPA’s recently appointed Regional Admin- the lessees of the Federal tracts partially istrator subsequently redefined “commence- because the baseline air quality conditions on ment of construction” to mean collaring of the tracts exceeded the primary NAAQS for the shaft, an early activity in shaft-sinking particulate and the guideline for HC. How- operations, However, the State reclamation ever, the suspensions were granted for rea- agency maintained that the developers were sons not related to the permitting process. not responsible for the previous interpretation of the law, Therefore, operations could proceed, The State air pollution division post- Unresolved Issues poned the deadline for application submis- Although many precedents have been es- sion until the developers could submit the de- tablished, there remain unresolved issues tailed engineering plans required for an emis- that sustain a level of uncertainty that may sions permit, but did not delay the construc- discourage some developers from proceeding, tion. EPA issued the permit in an expeditious whether on private or Federal land. These un- manner and work was not significantly de- certainties may be more critical than those layed. Because a clear precedent was established, it is unlikely that this dispute will arise encountered thus far. Several regulations are still pending that may increase costs or force again. It took several months to resolve, but changes in the design of process facilities or activities on the tracts continued during this control technologies. They may also add to period. the control requirements. The pending regu- Finally, there has been protracted legal ac- lations include: tion between three environmental plaintiffs and DOI and the lessees of tracts C-a and C-b ● recordkeeping, reporting, and stipula- over the need for an EIS prior to DOI’s ap- tions governing the manufacture and 348 ● An Assessment of 01/ Shale Technologies

handling of toxic substances as required Attempts at Regulatory Simplification under TSCA; disposal practices and standards for sol- Several attempts are being made to simpli- id waste under RCRA; fy regulatory procedures. A case in point is emission and ambient air standards for the action of EPA’s Region VIII office to hazardous air pollutants under the streamline the PSD permit application pro- Clean Air Act as amended; cess. The office evaluated its experience with visibility protection requirements for processing such permits and found that in a mandatory Class I areas under the Clean few cases, there are long review times when Air Act as amended; the applicant was not in a hurry to obtain a possible application of the Safe Drinking permit because the future of the project was Water Act to the brackish ground wa- uncertain. An example is the application for ters of the Piceance Basin; and the Colony project, which has been sus- possible application of SMCRA, or simi- pended for several years. In other instances, lar Federal-reclamation laws, to noncoal delays resulted when the agency was deluged minerals. by permit applications prior to the enactment of new, stricter regulations. An example is Some environmental groups maintain that the situation that arose in 1978 when the the effects of development are so poorly un- derstood that development will entail signifi- older PSD regulations, which did not require cant risks. They believe that adequate regula- extensive baseline air quality monitoring, were replaced by new regulations that re- tions cannot be promulgated because knowl- quired monitoring for a l-year period. When edge is lacking about the severity of the risks and about the methods for their control. R&D this happens, the agency’s resources are and further experience with the industry’s overwhelmed and applications are delayed. operations may result in the implementation Other delays resulted when applications of new regulations that will further reduce were incomplete (information was lacking) or the economic attractiveness of oil shale proj- when the information that was provided was ects. This, however, is an uncertainty which deemed inadequate by the agency. The first is inherent in any new industry. informational problem could be easily reduced by a quick review of the application for Another problem that may emerge is completeness. The second is more difficult, whether regulatory agencies will be able to because it involves scientific and technical handle the increasing load of permit applica- judgment. It reflects, to an extent, the fact tions and enforcement duties. Budgets and that the oil shale processes are new technolo- personnel are limited, and the States in par- gies and their effects are not totally under- ticular have experienced difficulty finding stood. Standardized procedures are not al- and keeping competent technicians and pro- ways available for determining compliance fessionals. Increased oil shale operations, with the law. This difficulty could be reduced coal mining, oil and gas development, coal- by developing standard procedures wherever fired powerplants and synthetic fuel facil- possible. This has been done already in some ities, uranium mines and mills, and other min- areas of the PSD process where, for example, eral development in the region will further the developers are required to use standard tax their resources. The dissatisfaction ex- dispersion models authorized by EPA. pressed to date may be insignificant compared to that which is likely as agencies be- The Region VIII office recently issued a pol- come more overloaded. icy statement that addresses its efforts to im- Ch 8–Environmental Considerations ● 349 prove the permitting procedures. A key ele- studies have been conducted by EPA’s Region ment is designing a standard application that VIII office for the PSD process. The National defines the specific data needs and recom- Commission on Air Quality is conducting a mends procedures for obtaining the data. more comprehensive evaluation of alterna- There is also an effort to educate developers tive means for achieving the goals of the in using the application by holding public Clean Air Act with more manageable regula- workshops on the permitting procedure. Also, tory procedures. Similar studies could be at the Federal level, one focus of the proposed made of other laws and regulations. Energy Mobilization Board is to expedite agency decisionmaking and reduce the im- Increase the Resources of the pacts of new regulatory requirements that Regulatory Agencies may emerge after construction or operations begin. Increasing the personnel and financial re- The State of Colorado, with funding from sources of the Federal regulatory agencies DOE, is designing and testing a permit review would allow them to improve their response procedure for major industrial facilities that capabilities. The agencies could also provide will coordinate the reviews by Federal, State, technical assistance to the State and local and local regulatory agencies. The procedure regulators to aid in their decisionmaking is also planned to expand the public’s oppor- processes, However, a simple increase in tunities to become involved in all phases of agency funding, without a methodology for project planning and review. It is being tested coordinating the expanded resources, would with a controversial molybdenum project not guarantee that procedures would im- near Crested Butte, Colo. A handbook will be prove. developed on completion of the test. This may aid in applying similar methods to the permit- Improve Coordination Among Agencies and ting process for oil shale plants. * Between Agencies and the Public The permitting process might be improved Policy Options if coordinated reviews were conducted by the various agencies. This strategy would help to The policy options presented here range identify and reduce jurisdictional overlaps from working to better understand complex and to reduce personnel needs and paper- regulatory processes, through using the re- work loads, A major advantage would be the sults of such work to reduce the complexities, opportunity for sharing analytical responsi- to waiving the laws or regulations. This range bilities and results. The public hearings that encompasses actions over which there is little are required for many separate permits could disagreement through those which involve ex- also be consolidated. The strategy could be treme controversy. Few would argue that reg- patterned after the voluntary joint review ulatory procedures could be improved, while processes that are being developed in Col- many would resist changes that could result orado and other States. However, unless the in weakening environmental protections. approach were mandated, it is questionable Study the Causes of Permitting Delays that interagency cooperation would be significantly improved. Further study of the permitting procedure Another approach would involve the estab- could help to identify and eliminate some of lishment of a regional environmental monitor- the causes of regulatory inefficiency. Such ing system to determine baseline conditions within all areas to be affected by oil shale

“Colorado hopes this joint review process, which provides projects. The system could better character- for concurrent rather serial review of applications, will also ize baseline conditions than could individual, reduce the time needed for review. uncoordinated monitoring programs. It might 350 ● An Assessment of O// Shale Technologies reduce the duration and the cost of the ad- developers to integrate controls for the new vance monitoring programs that are required standards into their plant designs. If it is de- of permit applicants. Site-specific measure- sired to reduce developer risks, new stand- ments would still be required to characterize ards should be firmly established and not biological communities, soils, hydrology, and subject to change for an extended period. geology for projects involving Federal land. This may not be appropriate, since early ex- Baseline surveys could be conducted by Fed- perience with the industry may indicate a eral agencies on potential lease tracts to need to modify the standards to achieve the shorten the time between a leasing decision desired level of protection. In addition, they and commercialization. The cost of the pro- may be difficult to establish. Excessively lax gram could be included in the cost of the standards would not adequately protect the lease. Individual monitoring of stack emis- environment; excessively strict ones might sions, water discharges, and reclamation ef- unnecessarily preclude development. These forts would also still be needed as the proj- hazards are particularly applicable to setting ects proceeded. NSPS. Improved coordination of public participa- Another approach would be to simplify the tion might also shorten review time by reduc- permitting procedures themselves, based on ing controversy, political confrontation, and information from the investigations suggested litigation. Procedures might include advance under the first option. This would have the public notification of the status of permit ap- advantage of retaining the protection of the plications, the dissemination of technical in- existing laws while making it easier to comply formation and R&D results, and the more di- with them. However, problems (such as the rect involvement of the public in an agency’s uncertain status of applications in progress) decisionmaking process through, for exam- might arise during the transition from the old ple, workshops and public meetings. It is pos- regulatory system to the new. It is also often sible that increasing the public’s awareness difficult to isolate the substance of environ- of the characteristics of a project might lead mental protection laws from the implementa- to perceptions of greater risk. On the other tion procedures. Any proposed changes in the hand, education could lessen nonproductive procedures would need careful examination discussions and confrontations. In any case, it may be difficult to educate the public in the by the agencies, the developers, and the public. technical aspects that determine whether an application satisfies the standards. To main- A third approach would be to establish de- tain a high level of participation, some inter- tailed, standardized specifications for permit vener groups may seek financial and techni- applications. This would reduce the problem cal assistance. This would be controversial, of insufficient data being provided with the especially from the point of view of the devel- applications and the delays that would be opers. caused when agencies request the additional information they feel is necessary for a thor- Clarify the Regulations and ough review. Fully comprehensive standard- the Permitting Procedure ized forms are probably not possible, and some interactions after an application is sub- One option would be to expedite promulga- mitted will still be needed. tion of standards for visibility and hazardous emissions under the Clean Air Act, and to set A fourth option would be to have a mora- the as yet undefined NSPS for oil shale torium on new regulations until some of the plants. Additional regulations could also be actual effects of development are determined defined under RCRA, TSCA, and other laws. on the Prototype Program lease tracts. (Moni- These actions would eliminate many of the toring of environmental effects and develop- regulatory uncertainties and would allow the ment of control techniques is one of the major Ch 8–Environmental Considerations 351 objectives of the Program. ) A disadvantage is Limit the Application of New Environmental Laws that the regulatory uncertainties would re- and Regulations main. An advantage is that the regulations could be promulgated from a better knowl- Plants already under construction, or that edge base, are operating, could be exempted from the provisions of new environmental laws and regulations. This approach—’’grandfather- Expedite the Permitting Procedure ing ” —is embodied in the legislation for the Energy Mobilization Board. It would remove The proposed Energy Mobilization Board many of the regulatory uncertainties. How- would expedite permitting by negotiating a ever, it is surrounded with controversy be- project schedule with a developer and then cause new regulations might be needed to enforcing the schedule by making regulatory deal with problems that could not be discov- decisions if the responsible agency does not ered until after operations begin. Many of the do so within a specified period. Proponents of present laws contain provisions to exempt ex- this strategy point out the advantages of a isting facilities from new requirements. central authority that could provide a single These include either automatic exemption point of contact between the developer and clauses or economic criteria against which the regulatory system. Opponents feel that the new regulatory requirements must be such an authority would add another layer of tested. bureaucracy, would increase controversy over the projects that are expedited, and Waiving Existing Environmental Laws would ultimately not have substantial effects on permitting delays. This strategy would exempt a project from the provisions of some or all existing environmental laws and regulations that might delay Another method would be to limit the peri- or prevent its construction and operation. od during which litigation can be initiated This measure would remove virtually all of against a particular permitting action, This the problems and delays associated with the mechanism could be similar to that employed permitting. However, it would have serious in the case of the Trans-Alaska oil pipeline. It political, environmental, and social ramifica- would reduce the risk of agency actions being tions since it could arbitrarily preempt envi- subjected to legal challenges that could jeop- ronmental protection under the law. Further- ardize a project’s completion schedule. It more, the waivers might give an undeserved should be noted, however, that legal mecha- competitive advantage to the developers who nisms already exist in some specific laws to received them. The allocation of the waivers limit the period of litigation, The expediting would be highly controversial, The extent to strategy could extend this protection to most, which this action would speed the deploy- if not all, of the relevant statutes, ment of the industry is unclear. —.-.

352 An Assessment of Oil Shale Technologies

Chapter 8 References

‘Environmental Protection Agency, Trace E]e- 1hJ. C. Ward, G. A. Margheim, and G, O. Lof, ments Associated With Oil S~ale and Its Process- Water Pollution Potential of Spent Oil Shale ing, EPA-908/4-78-003, prepared by TRW and DRI Residues, report for the Water Quality Office, En- under contract No. 68-02-1881, May 1977, p. 2. vironmental Protection Agency, Colorado State 2T. C. Borer and J. W. Hand, Identification and University, Fort Collins, Colo., 1971. Proposed Control o~ Air Pollutants From Oil Shale 17National Academy of Sciences, Mining and Operations, prepared by the Rocky Mountain Divi- Processing of Oil Shale and Tar Sands—A Work- sion, The Pace Co. Consultants and Engineers, ing Paper Prepared for the Committee on Surface Inc., for OTA, October 1979, p. 38. Mining and Reclamation, Washington, D. C., 1979, ‘Environmental Protection Agency, Monitoring p. 89. Environmental Impacts of the Coal and Oil Shale 1%upra No. 5, Industries: Research and Development Needs, ‘gIbid. EPA-600/7-77-015, February 1977, p. 138. 2(}Supra No. 17, at p, 91. %upra No. 2, at p. 20. 21J. P. Fox, K. K, Mason, and J. J. Duvall, “Parti- ‘Denver Research Institute, Predicted Costs of tioning of Major, Minor, and Trace Elements Dur- Environmental Controls for a Commercial Oil ing Simulated In Situ Oil Shale Retorting in a Con- Shale Industry: Volume I—An Engineering Ana]y- trolled-State Retort, ” Proceedings of the Twelfth sis, prepared for the Department of Energy under Oil Shale Symposium (J. H, Gary, cd.), Colorado contract No. EP-78-S-O2-51O7, July 1979. School of Mines Press, Golden, Colo., 1979, pp. ‘Environmental Protection Agency, A Prelimi- 58-71, nary Assessment of the Environmental Impacts 22F. C, Hass, “Analysis of TOSCO II Oil Shale From Oil Shale Development, prepared by TRW Retort Water, ” paper presented at ASTM Sym- and DRI under contract No, 68-02-1881 (EPA-600/ posium D-199.33 on Analysis of Wastes Associ- 7-77-069), July 1977, P. 104. ated With Alternative Fuel Production, Pitts- 7Battelle Northwest Laboratories and Dames burgh, Pa., June 4-5, 1979, and Moore, Environmental Impact Analysis: Ap- 21E. W. Cook, “Organic Acids in Process Water pendix 13—Air Studies, prepared for Colony De- From Green River Oil Shale, ” Chemistry & Indus- velopment Operation, October 1973. try, May 1, 1971, p, 485. ‘Rio Blanco Oil Shale Project, Detailed Develop- “G. W. Dawson and B, W. Mercer, “Analysis, ment Plan Tract C-a: Environmental Protection Screening and Evaluation of Control Technology and Monitoring, vol. 4, March 1976. for Wastewater Generated in Shale Oil Develop- ‘Rio Blanco Oil Shale Project, Detailed Develop- ment,” Quarterly Reports, Batelle Pacific North- ment Plan Tract C-a: Environmental Protection west Laboratory, Richmond, Wash., January and Monitoring, vol. 3, May 1977. 1977-March 1979. ‘[statement by Terry Thoem, Environmental 25Water Purification Associates, A Study of Protection Agency, Region VIII, as reported in the Aerobic Oxidation and Allied Treatments for Up- minutes of the 25th meeting of the Oil Shale Envi- grading In Situ Retort Waters, contract No, EW- ronmental Advisory Panel, Grand Junction, Colo., 78-C-20-0018 with Laramie Energy Technology May 2 and 3, 1979, pp. 130-131, Center, Department of Energy, Quarterly Status I INational Commission on Air Quality, Report of Report, August 1979. the Atmospheric Modeling Review Panel of the 2%upra No. 14. National Commission on Air Quality, (preliminary 27Supra No. 21, draft), to be published in February 1980. %upra No. 22. 121bid. “National Academy of Sciences, Water Quality 1‘Ibid, criteria, 1972, Environmental Protection Agency “E, F, Bates and T. L. Thoem (eds, ), Pollution publication (EPA-R-3-73-033), Washington, D, C., Control Guidance for Oil Shale Development, re- March 1973. vised draft report, Environmental Protection 1{]Ibid, Agency, Cincinnati, Ohio, July 1979, p, 4-46. ‘lSupra No. 14, at p. 3-64. 15 Colony Development Operation, An Environ- ‘21bid. mental Impact Analysis for a Shale Oil Complex at “J. B, Weeks, et al., Simulated E~~ects of Oil- Parachute Creek, Colorado, vol. I, 1974. Shale Development on the Hydrology of Piceance Ch 8–Environmental Considerations 353

Basin, Ccdoraclo, Professional Paper 908, U.S. Geo- Reprints, vol. 15, No. 1, March-April, 1971, pp. logical Survey, Washington, D, C., 1974, p. 34. 21-25. “Ibid., p. 44. “Supra No. 14, at p. 3-44, “)Ibid,, p. 39. ‘)’ Ibid., p. 5-5o. ] “]Ibid., p. 40. ‘ National Safety Council, Accident Facts, stock Wupra No. 14. No. 021.57, Chicago, 1977. %upra No. 6. “R. H. Flinn, et al., Silicosis in the Metal Mining “A. L. Hines, The Role of Spent Shale in Oil Industry: A Reevaluation, 1958-1961, Public Shale Processing and tbe Management o-f Environ- Health Service, Pub. No, 1076, 1963. mental Residues, Department of Energy, report “Ibid. TID-28586, ERDA-Laramie Energy Research “)Personal communication with George Weems, Center, Laramie, Wyo., April 1, 1978. Supervisory Physical Scientist, Industrial Health ‘“B. W. Mercer, et al., “Assessment of Control Branch, Denver Technical Support Center, Min- Technology for Shale Oil Wastewaters, ’” paper ing Safety and Health Administration, Depart- presented at Environmental Control Technology ment of Labor, Jan. 22, 1980. Symposium, Department of Energy, November “1. P. Maripuu, Puusaar, “Spirographic and 1978. Roentgenofunctional Characterization of Pulmo- “lB. L, Harding and K. D. Lindstedt, et al., Re- nary Emphysema in Bituminous Shale Miners, ” moval of Ammonia and Alkalinity From Oil Shale Gyg. Tr. Prof. Zabol., vol. 15, No. 12, 1971, pp. Retort Waters, prepared for Laramie Energy 51-53. Technology Center, Department of Energy, con- ‘{{W. K. C. Morgan and N. Zapp, “Respiratory tract No. DE-AS20-78-ET-13096, April 1979. Disease in Coal Miners, ” American Review o.f I?es - “K. D. Lindstedt and E. R. Bennett, Report on piratory Diseases, vol. 113, 1976, pp. 531-559. Characterization and Treatment of Retort Waters ‘)OL. M. Irwig and P. Rochs, “Lung Function and From In Situ Oil Shale Retorting, Civil, Environ- Respiratory Symptoms in Silicotic and Nonsilicot- mental, and Architectural Engineering Dept., Uni- ic Gold Miners, ” American Review of Respiratory versity of Colorado, August 1977. Diseases, vol. 117, 1978, pp. 429-435. “Osmonics, Inc., “Application Test Report” ‘I(’V. A. Kung, “Morphological Investigations of (Study of the Application of Reverse Osmosis to Fibrogenic Action of Estonian Oil Shale Dust, ” En- Treatment of Oil Shale Wastewaters), report in vironment tal Health Perspectives, vol. 30, 1979, preparation for Laramie Energy Technology Cen- PP. 153-156. ter, Department of Energy, 1979. “W. E. Wright and W. N, Rem, “A Preliminary ‘“Water Purification Associates, A Study of Re- Report: Investigation for Shalosis Among Oil verse Osmosis for Treating Oil Shaie Process Con- Shale Workers, ” presented at Park City Environ- densates and Excess Mine Drainage Water, quar- mental Health Conference, Park City, Utah, Apr. terly progress report, prepared for Laramie Ener- 4-7, 1979. gy Technology Center, Department of Energy, con- ‘)’J. Rudnick and G. L. Voelz, “An Occupational tract No. DE-AC2O-79LC1OO89, September 1979. Health Study of Paraho Oil Shale Workers,”’ pre- “E. A. Ossio, et al,, “Anaerobic Fermentation of sented at Park City Environmental Health Con- Simulated In Situ Oil Shale Retort Water, ” Amer- ference, Park City, Utah, Apr. 4-7, 1979. ican Chemical Society Division of Fuel Chemistry “J. Costello, “Morbidity and Mortality Study of Reprints, vol. 23, No. 2, 1978, pp. 202-213. Oil Workers in the United States, ” Environmental “R. R. Spencer, Anuero&c Treatment o-f Waste- Health Perspectives, vol. 30, 1979, pp. 205-208, water Generated During Shale Oil Production %upra No. 107. (draft report), BattelIe Pacific Northwest Labora- ‘)7L. M, Holland, D. M. Smith, and R, G. Thomas, tory, 1979. “Biological Effects of Raw and Processed Oil %upra No. 24. Shale Particles in the Lungs of Laboratory Ani- %upra No. 25. reals, ” Environmental Health Perspectives, vol. ‘“B. Harding, et al., “Study Evaluates Treat- 30, 1979, pp. 147-152. ments for Oil-Shale Retort Water, ” Industrial ‘)’)L. M. Holland, W, D. Span, and L. L. Garcia, Wastes, September/October 1978, pp. 28-33. “Inhalation Toxicology of Oil Shale-Related Mate- “lA. B. Hubbard, “Method for Reclaiming rials, presented at Park City Environmental Wastewater From Oil Shale Processing, ” Ameri- Health Conference, Park City Utah, Apr. 4-7, can Chemical Society Division of Fuel Chemistry 1979. — —

354 . An Assessment of Oil Shale Technologies

85 b7R, A. Renne, J. E. Lund, K, E. McDonald, et al,, D. J. Birmingham, Interim Report on the Shale “Morphologic Effects of Intratrachially Admin- Oil Study, Public Health Service, Cincinnati, Ohio, istered Oil Shale in Rats, ” presented at Park City 1955. Environmental Health Conference, Park City, 8bTabershaw-Cooper Associates, Inc., A Mortal- Utah, Apr. 4-7, 1979. ity Study of Petroleum Refinery Workers, project ‘8Supra No. 63. OH-1, Medical Research Report No. EA-7402, b9B. T. Scheb, “Noise in the Mining Industry: Its American Petroleum Institute, September, 1974. Effects, Measurement, and Control, ” Proceedings 87N, M. Hanis, K. M. Stavraky, and J. L. Flowler, of the Symposium on Industrial Hygiene for A4in- “Cancer Mortality in Oil Refinery Workers, ” ing and Tunneling, American Conference of Gov- Journal of Occupational Medicine, vol. 21, No. 3, ernmental Industrial Hygieniests, Cincinnati, 1979, Pp. 167-174, Ohio, 1978. 88G. Theriault and L. Goulet, “A Mortality Study ‘[’M. Blick, et al., “Noise,” Medicine in the A4in- of Oil Refinery Workers, ’’Journal of Occupational ing Industries (J. M. Rogan, cd.), published by F. A. Medicine, vol. 21, No. 5, 1979, pp. 367-370. Davis, Philadelphia, Pa,, 1974, p. 244. 89M+ B. BIOCh and D. Kilburn (editors), proc- 711. Berenblum and R. Schoental, “Carcinogenic essed Shale Revegetation Studies, 1965-1973, Col- Constituents of Shale Oil, ” British Journal of Ex- ony Development Operation, Atlantic Richfield perimental Pathology, vol. 24, 1943, pp. 232-239. co., 1973. 72A. Scott, “The Occupation Dermatoses of the ‘(’W. R, Schmehl and B, D. McCaslin, “Some Paraffin Workers of the Scottish Shale Oil Indus- Properties of Spent Oil Shale Significant to Plant try, ” British Medical Journal, vol. 1, 1922, pp. Growth,” Ecology and Reclamation of Devastated 381-385. Land, vol. I (R. J, Hutnik and G, Davis, eds.), pub- 7JM. Purde and S, Etlin, “Cancer Cases Among lished by Gordon and Breach, New York, 1973, Workers in the Oil-Shale Processing Industry, ” PP. 27-43. presented at Park City Environmental Health Con- “’J. C. Ward and S. E. Reinecke, Water Pollution ference, Park City, Utah, Apr. 4-7, 1979. Potential of Snow~all on Spent Oil Shale Residues, “M. Purde and M. Rahn, “Cancer Patterns in prepared by the Environmental Engineering Pro- the Oil Shale Area of the Estonian Soviet Socialist gram, Department of Civil Engineering, Colorado Republic, ” Environmental i+ea)t~ Perspectives, State University for the Bureau of Mines, Laramie vol. 30, 1979, pp. 209-210. Energy Research Center, under grant No. 75A, Leitch, “Paraffin Cancer and Its Experi- 0111280, 1972, mental Production, ” British Medical Journal, vol. ‘zIbid. 2, 1922, pp. 1104-1106. “James R. Meiman, Infiltration Studies in the Pi- 7bI. Berenblum and R. Schoental, “The Differ- ceance Basin, Colorado, Thorne Ecological Insti- ence in Carcinogenicity Between Shale Oil and tute, technical publication No. 12, 1975. Shale, ’’British Journal of Experimental Pat~ology, ‘AIbid, 5 vol. 25, 1944, Pp. 95-96. ‘ Forest Service, Users Guide to Soils, Mining “C. C. Twort and J. M. Twort, “Classification of and Reclamation in the West, general technical Four Thousand Experimental Oil and Tar Skin Tu- report INT-68, Intermountain Forest and Range mors of Mice, ” Lancet, vol. 1, 1930, pp. Experiment Station, U.S. Department of Agricul- 1331-1335. ture, 1979. “J, M. Holland, et al., “Skin Carcinogenicity of “W. J. Culbertson, et al., Processed Shale Synthetic and Natural Petroleums, ” Journal of Oc- Studies: Environmental Impact Analysis, Appen- cupational Medicine, vol. 21, 1979, pp. 614-618. dix 5, Colony Development Operation, Atlantic 7YR. M. Coomes, “Carcinogenic Testing of Oil Richfield Co., 1974. Shale Materials, ” Twelfth Oil Shale Symposium ‘7 Supra No, 95, Proceedings, Golden, Colo., The Colorado School “R. M. Dixon, “Soil Imprinting for Increasing of Mines Press, November 1979. Land Productivity, ” presented at the 33rd Annual “)Ibid. Meeting of Soil Conservation Society of America, “Ibid. July 30-Aug. 2, 1978, Denver, Colo, Also printed in 821bid. the Journal of Soil and Water Conservation, 1978. ‘]Ibid. ‘gSupra no. 89. ‘“J. J, Zone, “Cutaneous Effects of Shale Oil,” ‘(WRio Blanco Oil Shale Co., Revegetation Pro- presented at Park City Environmental Health Con- gram 1978 Annual Report, submitted to Rio Blanco ference, Park City, Utah, Apr. 4-7, 1979. Oil Shale Co., Denver, Colo,, by NUS Corp., Den- Ch. 8–Environmental Considerations 355 ver, Colo., March 1979. 12]L. A. Richards (cd.), Diagnosis and Improve- II)]C. Wayne Cook, Rehabilitation Potential and ment of Saline and Alkali Soils, U.S. Department of Practices of Colorado Oil Shale Lands, progress Agriculture Handbook No. 60, 1954. report for period June 1978- May 31, 1979, pre- ‘221. F. Wymore, Water Requirement for Stabili- pared for the Department of Energy by Colorado zation of Spent Shale, doctoral dissertation, Colo- State University under contract No. EY- rado State University, Fort Collins, Colo., 1974, 76-S-02-4018, 1979. ‘z’D. D. Runnells, et al., “Release, Transport, I“zC. Wayne Cook, et al., Revegetation Guide- and Fate of Some Potential Pollutants, ” in Trace lines for Surface Mined Areas, Colorado State Elements in Oil Shale, report No. COO-4Ol 7-2, Envi- University, Range Science Department Science ronmental Trace Substances Research Program, Series No. 16, 1974. University of Colorado, Denver, Colo., 1978, pp. ‘()] Ibid. 49-97. ‘(”R. R. Ericsson and P. Morgan, “The Economic ‘“M. K. Kilkelly, et al., “Trace Elements in Feasibility of Shale Oil: An Activity Analysis, ” Plants Growing on Processed Oil Shales, ” in Bell Journal of Economics, vol. 9, 1978, pp. Trace Elements in Oil Shale, report No, 457-487. COO-4017-2, University of Colorado, Denver, Colo., “]5Supra No. 1. 1978, pp. 98-134. ‘(’t) Supra No. 96. ‘25 Supra No. 16. 11]71bid, ‘2hSupra No. 117. W5upra No. 90. ‘271bid, %upra No. 100. ‘28Supra No, 100. ‘loR. C. Woodmansee, et al, “Nitrogen in Dras- ‘2%upra No. 96. tically Disturbed Lands, ” Forest Soils and Land ‘30Fish and Wildlife Service, The Plant Informa- Use (C. T. Youngberg, cd.), Department of Forest tion Network: Volumes I-W, U.S. Department of and Wood Sciences, Colorado State University, the Interior FWS/OBS-77/38-41. Supporting com- Fort Collins, 1979, pp. 376-392, puter data base located at the Department of Bot- ‘]] Supra No. 101. any and Plant Pathology, Colorado State Univer- “zIbid. sity, Fort Collins, Colo. 11 ‘F. B. Reeves, et al,, “The Role of Endomycor- 1“C. M. McKell, et al., Selection, Propagation, rhizae in Revegetation Practices in the Semi-Arid and Field Establishment of Native Plant Species on West: A Comparison of Incidence of Mycorrhizae Disturbed Arid Lands, Institute for Land Reha- in Severely Disturbed vs. Natural Environments, bilitation, Utah Agricultural Experiment Station, American Journal of Botany, vol. 66, No, 1, 1979, Utah State University, 1979. pp. 6-13. 1‘zSoil Conservation Service, Plant Materials for “’Supra No. 101. Use on Surface Mined Lands in Arid and Semi- ‘}%upra No. 16. Arid Regions, U.S. Department of Agriculture “’Supra No. 90. handbook SCS-TP 157, Lincoln, Nebr. (in press). 1l’H. P. Harbert III, et al., Vegetative Stabiliza- ‘]’ Forest Service, User Guide to Vegetation, tion of Spent Oil Shales: Vegetation, Moisture, Mining and Reclamation in the West, general tech- Salinity and Runoff 1973-1976, 1978, nical report INT-64, Intermountain Forest and I l~H. p. Harbert 111, et al., ~YSimeter study on Range Experiment Station, U.S. Department of Ag- the Disposal of Paraho Retorted Oil Shale, Indus- riculture, 1979. trial Environmental Research Laboratory, Office ‘ “A. Plummer, et al., Restoring Big-Game Range of R&D, Environmental Protection Agency, Cincin- in Utah, Utah Division of Fish and Game publica- nati, Ohio (EPA-600/7-79-188), 1979. tion No. 68-3, 1968. IIqW. A. Berg, et al,, Vegetative Stabilization of l’5Supra No. 130. Union Oil Company Process B Retorted Oil Shale ‘%upra No. 133. 2975-1978, Colorado State University Experiment ‘%upra No. 101. Station, technical bulletin No. 135, 1979, “nIbid, 121)J. T, Herron, et al., Vegetation and Lysimeter ‘Y5upra No. 133. Studies on Decarbonized Oil Shale, Colorado State 1’OK. A. Crofts and C. M. McKell, Sources of University Experiment Station, technical bulletin Seeds and Planting Materials in the Western No, 136, 1980. States for Land Rehabilitation Projects, Utah Agri- 356 ● An Assessment 01011 Shale Technologies culture Experiment Station Land Rehabilitation Shale Committee, Summary of Industry Oil Shale Series No. 4, Logan, Utah, 1977. Environmental Studies and Selected Bibliography ‘“’ Supra No. 133. of Oil Shale Environmental References, Denver, ‘“2 Supra No. 101. Colo., 1975. 1“Supra No. 100, 15%upra No. 89. ‘“’N. C. Frischknecht and R. B. Ferguson, Reveg- “HJ. M. Merino, et al., “Reclamation of Spent Oil etating Processed Oil Shale and Coal Spoils on Shale,” Mining Congress ]ournal, vol. 63, No. 10, Semi-Arid Lands, interim report, EPA-600/ 1977, pp. 31-36. 7-79-068, Environmental Protection Agency, Cin- ‘%upra No. 117. cinnati, Ohio, 1979. ‘fWupra No. 118, ‘“R. W. Tinus, et al. (eds,), Proceedings of the “)lSupra No. 119. North American Containerized Forest Tree Seed- “)2Supra No. 120. ling Symposium, Great Plains Agricultural Council ‘(]] Supra No. 89. publication No. 68, 1974, ‘[)’ Ibid. ‘%upra No. 131. ““C. M. McKell, Achieving Effective Revegeta- ‘“71bid. tion of Disposed Processed Oil Shale: A Program ““Supra No. 132. Emphasizing Natural Methods in an Arid Environ- “’Supra No. 117. ment, Utah State University, Agriculture Experi- ‘%upra No. 132. ment Station Land Rehabilitation Series No. 1, “]Bureau of Land Management, Piceance Plan- 1976. ning Unit Resource Analysis, September 1970. ‘Wupra No. 16. “’Bureau of Land Management, White River ‘t)7Supra No. 89. Management Framework P~an, January 1972. ‘%upra No. 117. ‘s’K. C. Vories, A Vegetation Inventory and “%upra No. 90. Analysis of the Piceance Basin and Adjacent ‘%. C. Lipman, “Union Oil Company Revegeta- Drainages, master’s thesis, Western State Col- tion Studies, ” Environmenta~ Oil Shale Sym- lege, Gunnison, Colo., 1974. posium, Colorado School of Mines, Oct. 9-10, ‘“J. A. Tiedeman, et al., Phyto-Edaphic C~assifi- 1975, pp. 165-180. cation of the Piceance Basin, Colorado State Uni- ‘7’ Supra No. 119. versity, Range Science Department Science Se- “2Supra No. 118. ries No. 31, 1978. “]Supra No, 101. I“Ibid. “’Ibid. “’)Rocky Mountain Oil and Gas Association Oil