Introduction

Oil shale deposits in the United States are among
the richest and most extensive in the world. (Principal
deposits are shown in Figure 1.) Total identified
resources of medium and rich shales in the Nation
are estimated at 2 trillion equivalent barrels (320
billion equivalent cubic meters) of oil. The Green
River formation alone—which covers an area of
17,000 square miles (44,000 square kilometers) in
Colorado, Utah, and Wyoming—contains an estimated
1.8 trillion equivalent barrels (280 billion equivalent
cubic meters) of oil. About 600 million barrels (95
billion cubic meters) is considered recoverable by
currently known technology.

This environmental assessment report conveys the U.S.
Environmental Protection Agency's (EPA’s) under-
standing of and perspective on oil shale development.
For government agencies, private developers, and
others involved in the oi! shale industry, the report
provides a source of basic information as well as

a means of identifying EPA’s concerns and interests
relative to oil shale development. The report:

@ Summarizes available information on oil shale
resources

@ Summarizes major air, water, solid waste, health,
and other environmental impacts

@ Analyzes applicable pollution control technology

@ Provides guidance for sampling, analyzing, and
monitoring emissions, effluents, and solid wastes
from oil shale processes

The report emphasizes those environmental impacts
and control technologies that EPA believes will
be of major importance.

Section 7 in the more comprehensive report, Envi-
ronmental Perspective on the Emerging Oil Shale
Industry (EPA 600/2-80-205a), and the companion
appendix volume (EPA 600/2-80-205b) contain
materials not included in this environmental assess-
ment. Section 7 provides a technical review of major
retorting methods and their probable emissions,

The Piceance Basin in Colorado, with recoverable
oil shale resources estimated at 500 billion equivalent
barrels of oil

effluents, and solid wastes. The appendixes com-
prise technical and data reviews:

@ Appendix A. Status and Development Plan of the
Oil Shale Industry

@ Appendix B. Procedures for Ambient Air Monitoring

@ Appendix C. Environmental Monitoring Activities—
Past, Present, and Proposed

@ Appendix D. Applicable Federal, State, and Local
Legislation, Standards, and Regulations

@ Appendix E. Quality Assurance Bibliography

@ Appendix F. Federal and State Permits Required
for Operation of an Oil Shale Facility



All criteria pollutants can be expected to be emitted
from processing and combustion of shale oils. Arsenic
and heteroatomic components of shale oils may

also pose health problems.

Other Effects

Some radioactivity will be released to the atmosphere
during oil shale mining and processing. Radioactive
elements will be contained in dust emissions, fine
particulate emissions, process water discharges, and
leachate from spent shale disposal piles. Some radon
gas will be released directly.

Noise will be created during oil shale development by
processing plant construction and operation, community
expansion, mining, and water reservoir operation,

and by construction and operation of pipelines,
transmission lines, roads, and railways. Because oil
shale development sites are, characteristically, a
reasonable distance from population centers, the
impacts of noise are expected to be negligible.

Social and economic impacts of development are
expected to be fairly severe because known oi! shale
reserve sites are remote and sparsely populated.
Population centers in the oil shale area are basically
tural. The introduction of oil shale development

will significantly increase the numbers of people who
use the towns, creating higher demands on local
municipal services such as fire and police protection,
schools, hospitals and health care, and on local
utilities such as electricity, water, gas, and sewage
treatment. The new industry will, however, also bring a
higher financial base to the area by creating more
primary and secondary employment and, therefore,
will increase local tax revenues.



Recommendations and Conclusions

@ Providing adequate water quantities

@ Maintaining air quality so as to protect health and
welfare

@ Minimizing detrimental land disturbances to
preserve adequate habitat for wildlife

@ Protecting valuable socioeconomic, cultural,
historical, and aesthetic values

Source standards and ambient standards will apply to
individual oil shale facilities and to an oil shale
industry. The ambient standards most directly affect the
industry as a whole, rather than any individual facility,
in that the Piceance and Uinta Basins (and the Colorado
River Basin) have a finite carrying capacity for air
and water pollutants. Although attempts have been
made to determine how large an oil shale industry
could be without exceeding this carrying capacity,
success has been limited because data are scarce and
comprehensive predictive efforts rare. Obviously,
facility siting is a major factor in making this de-
termination.

In evaluating any permit application for a prospective
oil shale developer, the logic is and will be as follows:
First, the proposed pollution control equipment

must represent best contro! technology as defined
by EPA. Second, controlled residuals must not violate
ambient standards,

The concept of Best Available Control Technology
(BACT} for air emissions control has been defined
as the maximum degree of reduction determined case
by case, taking into account energy, environmental,
and economic impacts and other costs. Standards

of Performance for water effluent contro! must reflect
the greatest degree of effluent reduction achievable
through application of the Best Available Demon-
strated Control Technology, Best Available Technology
Economically Achievable (BATEA, or simply BAT)
processes, operating methods, or other alternative: a
standard permitting no discharge of pollutants
should be included wherever practicable. In establish-
ing performance standards EPA shall consider the
cost of achieving the effluent reduction, any non-
water-quality environmental impact, and energy re-

quirements. Although disposal standard practices have
not yet been defined for oi! shale solid waste

disposal, it appears that the concept of Best Engineer-
ing Judgment ({BEJ) will be used. Factors associated
with BACT and BAT will presumably help define BEJ.

Because industrywide performance standards do

not exist for oil shale, all permit applications are
evaluated case by case in terms of BACT and BAT.
After applying BACT and BAT criteria, the permit
writer assesses the impact of residuals on ambient air
and water. If applicable Prevention of Significant
Deterioration (PSD) increments or stream standards
are predicted to be violated, better control than

that prescribed by BACT or BAT must be employed.
More stringent controls may be accomplished by
reevaluating the economic and energy costs associated
with BACT or BAT. Because it appears that PSD
Class | air quality increments may limit the ultimate
size of the industry, EPA Region VIII has encouraged
potential oil shale developers to provide controls better
than BACT to maximize oil production from the area.

In the June 7 and June 14, 1979, issues of the
Federal Register, Parts 121-125 of 40 CFR provide
guidance on strategy and procedures for National
Pollutant Discharge Elimination System (NPDES)
permitting. These regulations include critical definitions
of terms such as “navigable waters.” (In essence,
navigable waters are any flowing waters, wetlands,
or impoundments.) Moreover, the NPDES permit

for a new source is now required before the source is
constructed. Finally, if an Environmental Impact
Statement (EIS) is necessary, a final NPDES permit
may not be issued until a final EIS has been issued.
tn the past, EPA has encouraged oil shale developers
to apply for NPDES permits even if they expect no
discharge. The developer is then in a more advantageous
position in case of future enforcement actions.



Recommendations and Conclusions

Shale oil production will combine a number of
processing operations on one site: mining, ore
Preparation, retorting, gas treatment, refining, and solid
waste management. The scale of operation will be
massive. Consequently, the rates at which point source
and fugitive pollutants are generated will require
strict control. Potentially applicable control technolo-
gies employed in related industries—such as petroleum
Production, stone crushing, cement manufacture,

and electric power generation—may not be directly
transferable to shale oil production because of process
mixes and integration.

The environmentally problematic effluents and wastes
from oil shale operations have not been thoroughly
characterized. In some cases, adequate sampling
and analysis methods have not been developed,
validated, and standardized. In a commercial operation
the byproducts of retorting usually be processed
in some further way before their characteristics

as potential pollutants can be identified and control
technology developed. Site- and process-dependent
pollutants, particularly trace organics and inorganics,
may have the greatest potential impact on health and
welfare. Finally, refining shale oil into end use products
may result in increased emissions of toxic compounds.

Control technologies for treatment of off-gases are
generally believed to be adequate, but they need

to be demonstrated for key pollutants in off-gas streams.
Additional studies are needed, however, to characterize
off-gases from both in situ and surface retorting
processes because of the potential for release of
toxic trace elements.

It will be especially important to control particulates
from mining and handling operations by use of
suppression systems. Water sprays, along with wetting
agents and organic binders, need to be evaluated
for use at the points of emission as well as on
haulways and ore piles. In-mine localized particulate
removal by modular wet scrubbers, electrostatic
precipitators, or baghouses needs to be evaluated.
For example, whether electrostatic precipitators

can be used to contro! particulates from mining and

crushing operations will depend on characteristics

of the dust. Raw oil shale dust resistivity has not
been adequately investigated. Additional studies

are needed, especially with respect to fine particulate
control.

Because of the absence of a full-scale oil shale
industry, the adequacy of control technologies for
handling oil shale wastewaters is still questionable.
Some oil shale developers contemplate using retort
water to moisten retorted shale for dust control and to
aid compaction. If the retort wastewater is used in
this manner, the hazardous and toxic constituents
might migrate to local surface and ground water supplies.

Modified in situ oil shale processing will generate
more wastewater than can be consumed by process
reuse. Subsurface injection or surface discharge
may be necessary. Wastewater constituents may
include hazardous organics (polycyclic materials,
phenolics, amines) and inorganics (arsenic, molyb-
denum, vanadium, boron, among others). Control
techniques must be developed, therefore, to ensure
effective removal of these constituents before
wastewater disposal.

Little is known about the movement of ground water
into and through abandoned chambers of modified
in situ operations. To date, only speculations have
been made about the leaching of such chambers by
ground water. Consequently, laboratory studies
should be conducted to determine probable leaching
rates and concentrations of organic and inorganic
constituents. These studies should be supplemented
by field monitoring of existing and near-future in situ
retorting operations.

The disposal of solid wastes resulting from oil shale
mining and processing is a major environmental
concern. Retorted shale could present problems of
surface and ground water degradation if pile stability
and impermeability are not maintained. All research
and monitoring programs to date have dealt with
relatively smal! quantities of retorted shale. Potential
problems, such as mass stabilization of shale piles
and maintenance of an impervious layer below

plant root zones, can likely be identified and solutions
found only by creation of a large pile from commercial-
scale processing.



water pollution is not unique to oil shale extraction
and processing, but may require careful control because
of the magnitude of site activities. Collection and
impoundment of runoff will likely be necessary.

Solid Waste

The solid wastes resulting from oil shale processing
present one of the major environmental problems
associated with commercial development. Shale-
derived solid wastes will include fines from raw shale
crushing and conveying, mined raw shale waste, and
processed (or retorted) shale. Together these wastes
constitute most of the process solids requiring
disposal. Other solid wastes will depend primarily on
the pollution controls employed and on the extent

to which crude shale oil upgrading is carried out

in conjunction with retorting. These wastes may include
shale oil coke, treatment sludges, and spent catalysts.

Disposal of surface retorted shale will involve transport
and surface emplacement of large quantities of
solids on a scale only rarely attained to date in the
mining industry. The spent shale will contain potentially
leachable salts and, in some cases, a carbonaceous
residue from retorting. If shale oil is upgraded

in conjunction with retorting, a disposal pile might
also contain spent catalysts, sludges, arsenic-laden
solids, and other plant wastes.

In light of the foregoing, it would appear that potential
hazards exist relating to:

@ Pile stability

@ Airborne particulates, odors, and organic vapors

@ Leachates, organic and inorganic, caused by
precipitation and ground water movement

@ Transfer of possible hazardous organics or trace
elements to the biosphere

@ Translocations of toxic substances to vegetation

Mass movement of disposal piles could adversely
affect water quality. Sediment and salts could be
added to local surface waters, or to catchment
structures. Changes in pile drainage systems caused by
slumping, and so forth, may encourage infiltration.

Loading spent oil shale from the retort onto trucks,
Anvil Points, Colorado

Vegetation may be difficult to maintain on a destabi
pile surface; as a result, surface wind and water
erosion may increase.

Because no large disposal piles have been constructed
to date, little is known about pile stability in real
situations. Further, most of the work to date has dealt
with carbonaceous shales; decarbonized shales, from
which the organic content has been burned off, are
likely to differ significantly in stability and leaching
properties.

To control fugitive dusts, and to provide moisture for
compaction and stabilizing the disposal piles, retorted
shale will be wetted before transport and disposal.

It is not known whether wetting will be sufficient

to minimize particulate emissions at the scale of
operations contemplated at each site. The character-
istics of the spent shale and the micrometeorology
at a given site are among the pertinent variables.





Pollution Control Technology

necessary to provide for collection, treatment, and
reuse of this leachate.

Process-generated solid wastes—such as spent
catalysts, lime sludges, coke, and other solids from
water and wastewater treatment systems—may contain
toxic substances. Disposal of these wastes by burying
them in the spent shale pile would be likely to in-
crease the levels of toxic pollutants in the spent
shale leachate. It may be possible to dispose of some
process wastes along with the spent shale if it is
demonstrated that the wastes do not themselves
produce a leachate or promote production of additional
pollutants in the spent shale leachate. A preferred
method of handling potentially toxic spent catalysts
would be to return them to the manufacturer for
regeneration and subsequent reuse.

It may be possible to dispose of surface-retorted
spent shale by returning it to the mine, backfilling either
with dry spent shale or with a spent shale slurry.
Because of the potential for chronic leaching, it is
recommended that spent shale not be returned to a
wet mine; leachate problems would be more easily
controlled on the surface than in a subsurface environ-
ment. Returning dry spent shale to a dry mine,
however, would create support, decrease subsidence
potential, and reduce surface spent shale storage

by about 60 percent. In any case, mine disposal of spent
shale should not be considered viable until it has
been critically investigated to ensure that leachates will
not degrade ground or surface waters.

Leachate will contain water-soluble organic and
inorganic solids. Because of its expected poor quality,
leachate from surface disposal piles will probably be
collected behind dams constructed for the purpose
and located slightly downstream of the toe of the
pile. An impermeable base should underlie the pile,
and drains should be included to pick up the leachate
and discharge it at the collection point. For modified
in situ oil shale operations, it will probably be necessary
to minimize water flow through the retorts and
collect and treat as necessary any leachate. Most of
the ions present in leachate are also present in
various flue gas desulfurization process liquids;
therefore, it could be possible to use the leachate on
site for removal of sulfur dioxide from flue gas streams
of surface retorts. The leachate problem could also

be reduced by leaching the soluble minerals from the
raw shale feed before retorting and passing the
retorted shale through a spent shale burner to remove
residual carbon and organics.

Modified in situ retorting, conventional underground
mining, and possibly true in situ retorting may pose
fracturing and subsidence problems unless subsidence
control technology is provided. For conventional
underground mining, some control technology exists
that could probably be modified and applied to the
specific hydrologic and geologic environment

of a particular underground oil shale mine. Backfilling
mine voids with spent shale could provide additional
support, though ground water pollution could be a
concern. Special attention would be needed to avoid
long-term problems from weakening of pillar strength
by spalling and weathering. For modified and perhaps
true in situ retorting, the key to controlling subsidence
or fracturing of surrounding strata will probably lie in
learning to control rubblization and in developing a
technology that will provide pillars adequately sized
and appropriately spaced to support overlying strata.

Other Controls

Other process controls include those necessary to
reduce storage tank emissions, biological sludges,
tank bottom sludges, and separator sludges. Fioating-
roof tanks and internal floating covers reduce both
diurnal breathing losses and filling losses associated
with fixed-roof tanks. The technology is well developed,
having been used in the petroleum and chemical
industries. Internal floating covers are preferable in
sites having high wind, rainfall, or snowfall because
they are protected from the weather.

Refineries limit or reduce sludges and other solid
wastes primarily through source control. Source contro!
techniques involve idéntifying and monitoring
sources of oil, water, and other contaminants and then
implementing inplant operating procedures to intro-
duce less water into drains, to recover oil and water
from solid wastes, to decrease the amount of con-
taminants in oily drainage, and to reduce the oil content
of API separator solid waste.



Pollution Control Technology

only a few parts per million compared to quantities
of thermally generated NO,. Thermally generated NO,
can best be controlied by demonstrated combustion
modification techniques. If crude shale oi! is used as
process fuel, control of both SO, and NO, emissions
could be necessary if process heaters are needed

to meet the same New Source Performance Standards
as those for industrial boilers. Full hydrotreating
would be more cost effective than flue gas treating,
if on-site refining is included in the shale oil facility.

Hydrocarbon emissions will result from direct pre-
heating of raw shale, and will need control. Thermal
incineration is probably the method of choice.

Hydrocarbons and carbon monoxide resulting from
incomplete combustion will be emitted by the boilers,
furnaces, heaters, and diesel equipment associated
with oil shale development. With proper maintenance,
emissions from these sources are not considered large;
however, high background levels have been reported
in some areas, and any additional contributions

from process operations will be a cause for environ-
mental concern. Hydrocarbon and carbon monoxide
emissions can be held to a low level by proper design,
operation, and maintenance of external and internal
combustion equipment.

Wastewater Treatment

The quantity and quality of water available, methods
of water use, and disposal criteria will dictate the
pretreatment, internal conditioning, and wastewater
treatment necessary at each oil shale processing site.
Wastewaters from oil shale processing will contain
dissolved and suspended solids, oil, trace elements
and metals, trace organics, toxics (carcinogens),
dissolved gases, and sanitary wastes. The major
wastewater sources are given on page 7.

Individual waste streams have not been characterized
adequately to make firm treatment or control technology
judgments regarding which unit processes should be
apptied to which waste streams. Nonetheless, some

ideal processing schemes have been envisioned and
discussed. The size of the treatment unit will depend on
the wastewater volume to be treated at a specific
site and on the concentrations of pollutants to be
removed. The basic operating approach will be to
concentrate the pollutants for ultimate disposal or
containment so that clean water can be recycled or
discharged.

Wastewaters that contain dissolved solids (more than
1,000 milligrams per liter) and suspended solids,
and that are essentially free of oil and trace organics,
can be collected and flow-equalized in large holding
lagoons before treatment. Oily wastewaters (more than
10 milligrams of oil per liter) from all wastewater
sources should be collected and processed by American
Petroleum Institute (API) separators or similar equip-
ment before receiving further treatment. Wastewaters
contaminated with trace elements and metals should
be essentially free of oil and dissolved solids to allow
them to be treated separately. Trace organic wastewater
volumes are not expected to be large, but these
wastewaters will contain highly diverse types of organic
pollutants. Toxic wastewater volumes are expected
to be small, but advanced treatment and control will
be needed for the concentrates collected. Specific
controls and treatment will be necessary for waste-
waters from scrubbers that absorb common oil shale
process gases—such as hydrogen sulfide, ammonia,
and carbon dioxide—before the water is reused or
discharged. Sewage and water treatment plant releases
should be considered for separate treatment and
disposal.

The amounts and qualities of water to be expected
from mine dewatering are not known, and they will
depend on the site. In contrast to some earlier
characterizations of surface retorting operations as
large water consumers, true and modified in situ
developments may produce a surplus of water that will
have to be treated and discharged or reinjected

into aquifers.



Environmental Impacts.

The refining of crude shale oil will produce a number
of potentially adverse environmental effects, primarily
as a result of atmospheric emission. Data have not
been developed on the quality and quantity of these
emissions. Such data may indicate a need for further
study and for development of new control technology.

Water Quality

Water is necessary to the development of an oil shale
industry. Water will be needed for dust control
during mining and crushing, for gas cleaning and air
Pollution control, for cooling, and for moisturizing
retorted shale. Upgrading crude shale oil, on-site
power generation, and revegetating disturbed land and
retorted shale disposal areas will also consume

large quantities of raw water. The water needs per
unit of net product will necessarily depend on the
mining, retorting, and upgrading methods used. In
general, in situ methods are expected to consume less
water than conventional mining and retorting.

Most major developers have indicated that they
intend to discharge no wastewaters directly to surface
streams. Surface retorting process waters would be
reused, and perhaps ultimately applied to retorted
shale. Effects of extraction and processing activities
on local hydrology and water quality are therefore
likely to be indirect or incidental. The water pollution
implications of mine dewatering, of creating large
retorted shale disposal piles, and of abandoning
in-ground retorts have not been determined; these
actions could create major environmental impacts.

Because of the low concentration of compounds
in discharge waters, no acute or chronic effects on
aquatic biota in surface waters may result; however,
compounds of low solubility may be bioaccumulated
by some aquatic organisms and become toxic to other
aquatic organisms, birds, and man. Oil shale process
waters contain single-ring and polynuclear aromatics
that contain suspected carcinogens. If process
waters are discharged into the aquatic environment,
sediments may accumulate these compounds and
later release them slowly. Research is needed on
the degradation of these compounds and on their
potential for bioaccumulation in aquatic organisms.

Effects of extraction and processing activities on
existing water quality in the oil shale region will vary
with the geography and the season. Several streams
and shallow aquifers provide water suitable for use in
irrigation. tn lower oil shale aquifers of the Piceance
Basin and in the lower reaches of Piceance Creek,
however, water quality exceeds the dissolved solids,
fluoride, or boron criteria for domestic or irrigation
use. On or near the Utah lease tracts (Ua/Ub), only
the White River and the Bird's Nest aquifer contain
significant amounts of water. Water in the White River
is of suitable quality for use in irrigation except during
low flow in the summer.

Withdrawing good quality surface water and ground
water from sources in the upper Colorado Basin for
consumptive use in oil shale processing may result in
increased salinity levels in the lower Colorado River.
The full effect of withdrawal on the Colorado River is not
known, It is estimated, however, that an oil shale
industry producing 1 million barrels (160,000 cubic
meters) of shale oil per day will increase total dissolved
solids between 10 and 27 milligrams per liter at
Hoover Dam.

Aqueous wastes from oil shale processing can be
categorized broadly as originating from direct or
indirect sources. Wastewaters from direct sources are
those generated by unit operations or processes,
including:

e Retorting

e@ Upgrading

@ Some air emission control and gas cleaning
processes

@ Cooling and boiler water blowdowns

@ Water treatment

@ Mine dewatering

@ Sanitary disposal

Wastewaters from indirect sources include:

@ Leachate from retorted shale disposal areas

@ Runoff and erosion resulting from construction and
site use

@ Runoff resulting from mining and transport activities



Foreword

Introduction 1
Recommendations and Conclusions 3
Environmental Impacts 6
Atmospheric Emissions 6
Water Quality 7
Solid Waste 9
Health 10
Other Effects 11
Pollution Control Technology 12
Air Emission Controls 12
Wastewater Treatment 13
Solid Waste Controls 14
Other Controls 15
Sampling, Analysis, and Monitoring 7



aieifa Sas
PSL arse xcahse.:
ett a ates
See
Construction of mining facilities for commercial oil
shale development, Federal Lease Tract Cb in Colorado

When energy and material resources are extracted,
processed, converted, and used, the effects of related
pollution on our environment and even on our health
often require that new and increasingly more efficient
pollution control methods be used. The Industrial
Environmental Research Laboratory in Cincinnati

is engaged in developing and demonstrating new
and improved methods that will meet these needs
efficiently and economically.

This report provides a brief summary of a more
comprehensive report, Environmental Perspective on
the Emerging Oil Shale Industry (EPA 600/2-80-205).
The full report provides a preliminary overview of
environmental considerations related to the emerging
oil shale industry. The report and similar ensuing
reports are intended to develop the technical basis
for eventual regulations.

The recently announced national synfuels program
relies on development of the oil shale industry.
We believe providing information on environmental
concerns and developing control technology in
concert with development of oil shale technology
will enable the establishment of a mature oi! shale
industry compatible with national environmental
goals without unnecessary delay.

Further information on the subjects of this report can
be obtained from the Energy Pollution Control
Division, Industrial Environmental Research Laboratory,
Cincinnati, Ohio 45268.

Bre Pap

Steven R. Reznek
Deputy Assistant Administrator for
Environmental Engineering and Technology

Po Cie

David G. Stephan

Director

Industrial Environmental Research Laboratory
Cincinnati



Technology Transfer { EPA 625/9-81-005 _}

Environmental Assessment

Perspective on the
Emerging Oil Shale Industry

January 1981

This report was developed by the

EPA Oil Shale Research Group

with assistance from the

Centec Corporation

for the

Energy Pollution Control Division

Industrial Environmental Research Laboratory
Cincinnati OH 45268



Sampling, Analysis, and Monitoring

One problem facing developers is sampling and
analysis of product and waste streams associated with
producing oil from oil shale. The methods that have
historically been used to analyze air and water
samples have been applied to oil shale effluents, but
without the straightforward results expected, Extra-
ordinary interferences and matrix effects apparently
make some methods ineffective. Many workers in the
field are addressing the problem of standardization
of methods for collecting, shipping, storing, and
analyzing samples. Intérlaboratory studies on many
different types of environmental samples will be
needed to validate those methods best suited for
consistent analysis of oil shale pollutants.

Effective monitoring through sampling and analysis is
expected to provide:

@ A baseline evaluation of conditions before devel-
opment

@ A record of changes from baseline conditions

@ A continuing check of compliance with environ-
mental regulations and laws

© Predictive capability for timely notice of developing
problems

@ Acheck on the effectiveness of mitigating procedures

Amonitoring program should include sampling of point
source effluents at and around the facility, non-
point-source effluents resulting from activity at the
mining, processing, and disposal sites, and accidental
discharges. Monitoring should begin with a baseline
survey; it should continue for the life of the project
and afterward as long as necessary to ensure compliance
with environmental regulations and laws and lease
stipulations.

An air-monitoring program should include on-site gas
and particulate analyses and a network of meteorolog-
ical and air quality measurement stations remote
from the processing site. It should also include upper
air studies and diffusion modeling to demonstrate
and ensure compliance with Federal and State

air quality standards.

Surface water monitoring should incorporate biological
monitoring as well as physical and chemical analyses.
Changes in aquatic biota may indicate subtle changes

in water quality characteristics before they are
detected by physical-chemical analyses for specific
pollutants or by indicator parameters such as dissolved
oxygen, pH, and hardness. Water monitoring should
be done both upstream and downstream: wet and
dry surface streams and springs and observation wells
should be monitored to detect ground water changes.

In @ water-monitoring program, non-point-sources
will probably receive greater attention than point
sources because of the difficulty of monitoring pollutants
emanating from shale piles, construction sites,
access roads, unlined catchments, and evaporation
ponds. Adding to this problem will be the possible
discharge of saline ground waters. Moreover, site
activities may resuit in reduced water flows and,
therefore, may affect already limited supplies of water
for agriculture, livestock watering, and other beneficial
uses.

In addition to spent shale, disposal sites will probably
contain raw shale fines, spent catalysts, sludges,

and process wastewaters. Surface erosion and leaching
of soluble salts and organic compounds will necessitate
extensive disposal site monitoring, particularly

of revegetation trenches, of the alluvium, and at the
toe of the pile where pollution is most likely. The
spent shale monitoring program particularly should be
designed to identify environmental problems in time
for corrective measures to be taken.

Monitoring programs and long-term studies should
also be undertaken for:

@ Revegetation

@ Terrestrial biology

@ Game management

@ Aquatic biology

@ Soil mapping and analysis

@ Toxicology

@ Trace elements in the ecosystem

@ Ecological interrelationships

@ Visibility

@ Scenic, archaeologic, paleontologic, and historic
values