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Full text of "Final environmental impact statement on the Uintah Basin synfuels development v. 2"

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Prepared by 
Bureau of Land Management 

February 1983 

/i4f M^ 

State Director, Utah 




Draft EIS Comments) C-l 






R-A Maps R-A-l 

A-l Enercor-Mono Power P.R. Springs Project A-l-1 

A-2 Geokinetics Lofreco and Agency Draw Projects .A-2-1 

A-3 Sohio Asphalt Rtdge Tar Sand Project A-3-1 

A-4 Socioeconomics A-4-1 

A-5 Air Quality Analysis Methodology A-5-1 

A-6 Visual Resources Management Methodology A-6-1 

A-7 Uncommitted Mitigation Measures A-7-1 

A-8 Review and Evaluation of Applicants' Proposed Erosion 

Control and Reclamation Programs A-8-1 

A-9 Endangered Species Act Compliance A-9-1 

A-10 Energy Efficiency A-10-1 

A-ll General Measures for Grants and Permits A-ll-1 







Public Hearing Testimony and Comment Letters C-2 

Particles Remaining Airborne from a 

Ground-Level Release. C-29 

Maximum 24-Hour Average SO2 Concentrations in Various 
Class I Areas Due to Synfuel Development in the Uintah, 

Parachute Creek, and Piceance Creek Basins C-197 

Emission Estimates for Selected Noncriteria Pollutants C-217 



Figure Page 

C-l Paraho River Intake Structure and Pumping Station C-23 



The Bureau of Land Management (BLM) consulted with many governmental agencies, 
private organizations, and individuals during the development of the Draft and 
Final Environmental Impact Statement (EIS). Initially, BLM formed an EIS 
steering committee, an interagency advisory group composed of federal, state, 
local, and Ute Tribe officials. This group followed the progress of the EIS 
and provided input on various issues during the EIS process. 

Private citizens, organizations, and additional governmental agencies were 
involved at two stages - during the scoping process and the Draft EIS review. 
Public scoping meetings held in Vernal and Salt Lake City, Utah, and Rangely, 
Colorado, during August 1981, involved citizens and groups in identifying the 
significant issues that should be addressed in the EIS. (A detailed report on 
the scoping process, EIS Scoping Report: Uintah Basin Synfuels Development , 
can be obtained from Bureau of Land Management, Vernal District, 170 South 500 
East, Vernal, Utah 84078. Public hearings held in the same communities during 
September 1982 provided an opportunity for citizens and groups to publicly 
express their comments on the adequacy and accuracy of the Draft EIS. In 
addition, written comments were solicited during the 60-day public review 
period (August 18 through October 19, 1982). 

The oral testimony from the public hearings and written comments were 
considered in preparation of this Final EIS and are responded to in this 

Federal decisions on the synfuel project rights-of-way applications will not 
be made until at least 30 days after the Environmental Protection Agency (EPA) 
Final EIS Notice of Availability has appeared in the Federal Register . 
During that 30-day period, written comments on the Final EIS may be submitted 
to be considered in the decision process. 

Persons and groups from whom oral and written comments were received are 
listed on Table C-l. Following this listing is a copy of substantive 
comments made at public hearings that were not duplicated in a follow-up 
letter, and all comment letters received. (Copies of the complete public 
hearing transcripts, along with attendance lists, are available for public 
review at the BLM offices in Salt Lake City and Vernal, Utah.) Responses to 
the comments appear after the respective oral testimony or comment letter. 


Table C-l 
























Bob Nicholson 

Charles Cameron 
Dennis Montgomery 

Merrill Mecham 
Gaylon Cook 
George Fosdick 

Peggy Rector 
Mark Bubriski 

Peter Hovingh 
Dorothy Harvey 


W.E. Mclntire 

Peter Hovingh 
Fred Hempel 

Peter Hovingh 
Peter Hovingh 
Robert Dudiak 
Robert Lee 
Dorothy Harvey 
William Dixon Shay, 
James Devine 
Robert Matuschek 

Helen Rob i son 
Harry McCarthy 


Vernal City and Uintah County 

Ute Indian Tribe 
U.S. Bureau of Indian Affairs, 

Fort Duchesne Agency 
Uintah County Commission 
Cathedral Bluffs Shale Oil 

Town of Rangely, Colorado 
Rio Blanco County (Colorado) 

Board of County Commissioners 
Intermountain Water Alliance 

U.S. Dept. of Health & Human 

Services, Region VIII 
Wasatch Mountain Club 
U.S. Federal Highway 

Administration, Region 8 
Utah Nature Study Society 
Intermountain Water Alliance 
Sohio Shale Oil Company 
Syntana-Utah Project 
Intermountain Water Alliance 
Tosco Development Corporation 
U.S. Geological Survey 
U.S. Dept. of Housing and 

Urban Development, Region 

Humane Society of Utah 
Synfuels Engineering and 

Development, Inc. 


Table C-l (continued) 

















Stephen Ellis 

Mark Bubriski 

Robert He i stand 

George McMillan 
Peggy Rector 
Henry Cuch 

Floyd Wopsock 
Scott Matheson 
David Deisley 
Diana Bender 
Rusty Lundberg 
Clark Johnson 

Carse Pustmueller 
Lorraine Mintzmyer 

John Plog, Alan Dresser 
Thomas Forsgren 
Robert Yuhnke, Richard Hughes 
George Brown 

Phyllis Fox 

Frances Green 
Dennis Sims 
D.A. Dennis 

Frank Lisella 

Michael San Miguel 
Frank Knell 

State of Colorado 

Rio Blanco County Dept. of 

Paraho Development 


U.S. Soil Conservation Service 
Town of Rangely, Colorado 
U.S. Bureau of Indian Affairs, 

Uintah and Ouray Agency 
Ute Indian Tribe 
State of Utah 

Union Oil Company 
Geokinetics, Inc. 
U.S. Fish and Wildlife 

Service, Colorado-Utah 

Area Office 
State of Colorado Natural 

Areas Program 
U.S. National Park Service, 

Rocky Mountain Regional 


Colorado Dept. of Health 
Utah Power and Light 
Environmental Defense Fund 
U.S. Minerals Management 

J. Phyllis Fox Consulting 


National Wildlife Federation 
Town of Dinosaur, Colorado 
U.S. Army Corps of Engineers, 

Sacramento District 
Center for Disease Control 
Friends of the Earth 
Mono Power Company 
U.S. Bureau of Reclamation, 

Upper Colorado Regional 



T^TT^T- ';."' ■:-.::.,;,.: 

Table C-l (concluded) 





R.E. Greffenius 
Gay! on Cook 
Robert Davies 
Don Peach 
Steven Durham 

George Oslund 


U.S. Forest Service 

U.S. Department of Energy 
Town of Rangely, Colorado 
U.S. Environmental Protection 
Indian Health Service 



Many people who presented oral testimony at a public hearing also submitted a 
written comment letter. Comments that were duplicated in a letter are not 
reprinted and responded to here. All comments presented at the Vernal hearing 
and the majority of the comments presented at the Rangely and Salt Lake City 
hearings were duplicated in follow-up letters from the speakers. They are 
responded to in the letter section as identified on Table C-l. The following 
comments were not duplicated in a follow-up letter. 

COMMENT H-l-1 : "The residents of Uintah County generally will command 
support of Synfuels' development in their county. We recognize that relying 
heavily on foreign countries for America's needed energies supplies is a very 
precarious situation. The City and County Planning Commissioners and the 
County Impact Council believe that the projected population growth and 
attendant problems can be adequately managed with the assistance of the energy 
development companies. The above-mentioned groups, as well as county 
residents in general, are concerned that our water, wildlife, and other 
natural resources be properly managed and protected. However, various laws 
and state and federal agencies exist to manage these resources, and local 
government entities have little or no jurisdictional authority over such 
resources. Therefore, my comments will deal with our biggest concern: 
managing socioeconomic impacts. Uintah County, Uintah County School District, 
Vernal City, Naples, City, Ballard City, and the various water and sewer 
districts in the county are concerned about the potential impact on our 
schools, roads, water and sewer systems, parks, police and fire systems, and 
housing facilities. Managing the socioeconomic impacts from the potential 
population growth will require a strong commitment from the energy development 
companies to be responsible for mitigating their direct and indirect impacts. 
We believe that with the new Vernal to Bonanza highway, and in light of the 
population distribution experienced by the Bonanza Power Plan work force, that 
the Ashley Valley area will receive possibly as much as 90 percent of the 
population growth from the proposed fuel developments." Bob Nicholson, Vernal 
City and Uintah County Governments. 

RE SPONSE : The views expressed will be considered in the decisionmaking 
process. The socioeconomic impact analysis in the EIS confirms the comment 
that significant population growth would occur in the Ashley Valley area. 

COMMENT H-l-2 : "On page 33 of the summary, mention is made of Utah law 
S.B. 170, regarding the required socioeconomic impact statement and 
alleviation plan which must be filed by major developers with state and local 
governments. Reference is made to the 'process of mitigation plan preparation 
and approval' by industry, state, and local government officials. Under S.B. 
170, as it presently exists, no formal approval of the impact alleviation plan 
is required from state and local government before a project gets underway. 
We hope that industry will willingly assume their mitigation 
responsibilities. With the cooperation of industry, we feel that new growth 
can be managed in a way to benefit both the present and future residents of 
Uintah County." Bob Nicholson, Vernal City and Uintah County Governments. 


RESPONSE : S.B. 170, passed by the 1981 Utah Legislature, requires a 
socioeconomic impact and alleviation plan to be filed with the Utah Department 
of Community and Economic Development. It is correct that no formal approval 
is required. While S.B. 170 has no regulatory control to require companies to 
establish a mitigation plan that complies with the wishes of local and state 
government, it is assumed that industry will willingly undertake its 
responsibility to mitigate the negative impacts the projects may cause. 

The Summary has been revised to clarify that the mitigation plan would not 
require approval. 

COMMENT H-3-1 : "As a matter of public record, we are requesting a review 

period for public comment on this document (Ford, Bacon, and Davis Native 

American Study) before the issuance of the final impact statement." Dennis 
Montgomery, Bureau of Indian Affairs, Fort Duchesne Agency. 

RESPONSE: In response to the request, a two-week period (10/5/82-10/19/82) 
was granted to BIA and other involved agencies for reviewing the draft 
supplemental Indian study, since the document was not completed in time for 
results to be incorporated into the Draft EIS. This was followed by a 
discussion of comments with interested parties in Vernal on October 22 1982 
in which BIA participated. 

The supplemental Indian study has been incorporated in its entirety into the 
Final So cioeconomics Technical Report and pertinent results have been 
incorporated into appropriate sections of the Final EIS. There will be a 
30-day period after issuance of the Final EIS to receive comments on items in 
the EIS, including results of the Indian study. 

COMMENT H-4-1: "I would like to express the appreciation of the residents 
of Uintah County and the Uintah County Commission to the Bureau of Land 
Management for holding this public hearing in Uintah County among the people 
who will be most affected by the decisions that you make at the conclusion of 
this process. This specific draft environmental impact statement combines the 
cumulative impacts and an analysis of the environmental consequences of nine 
proposed specific site projects in Uintah Basin with presently approved and 
on-going projects. This is a first of its kind and certainly exceeds the 
normal processes used to demonstrate compliance with the spirit and purposes 
of the National Environmental Policy Act and the regulations of the council on 
environmental quality. Information accumulated by this EIS will be of extreme 
value to all who are concerned with and responsible for the future environment 
and economy of this area. We have examined and studied the material submitted 
in the draft EIS and accompanying supplemental technical reports and agree and 
support the analysis and conclusion set forth in the draft statement. The 
analysis in the EIS suggests that the most challenging consequence of the 
development of the Synfuels Project would be orderly growth management and a 
paved highway system. The Uintah County Commission is fully aware of the 
challenge of providing orderly growth management and the necessity of paved 
dust-free highways if we are to maintain air quality and essential traffic 
facilities. We believe Uintah County has demonstrated its understanding of 
this broad challenge first by the construction of a first-class paved highway 
interconnecting the Vernal area, White River Shale Plant, Bonanza, Deseret 
Power Plant, Greater Red Wash, and close connections to the Paraho and Syntana 


proposed project sites. This highway will hold down the particulate matter 
that is essential to maintain acceptable air quality, provide access to 
adequate housing, complete community services, and relieve substantially all 
the impact pressures on our good friends to the east. The Uintah County 
Commission believes they have demonstrated that their role is to manage the 
growth and allow and encourage private industry to provide housing and service 
facilities, which private industry has done adequately to more than meet the 
needs of the expected near-term growth." Merrill Mecham, Uintah County 

RESPONSE : BLM appreciates the cooperation it has received from Uintah 
County. The County's efforts to plan for and manage area growth are 

COMMENT H-4-2 : "From the socioeconomic impact side, the county's 
transportation plan substantially isolates seven of the proposed synfuel 
projects from the Colorado area, and distributes their impacts into the Uintah 
and Duchesne existing communities. We believe the population distribution 
used in the EIS is reasonable. However, the latest monitoring reports from 
the Deseret Power Plant, Bonanza and White River Shale indicate that the vast 
majority of the employees are choosing the Vernal area for their residence." 
Merrill Mecham, Uintah County Commission. 

RESPONSE: BLM is aware that Vernal is now receiving most of the growth 
associated with energy development and believes that the Vernal area would get 
the majority of growth from synfuel development. However, because of the 
sheer magnitude associated with the synfuels development addressed in the 
EIS, Vernal would be strained to accommodate all of the growth and some 
spillover would occur into other communities such as Roosevelt and Rangely. 

COMMENT H-4-3 : "The regional cumulative analysis of all nine Synfuel 
projects adequately addresses the threshold level and socioeconomic 
constraints and mitigation measures that are reasonable and probable to allow 
for the eventual production of almost one-half million barrels per day. 
Uintah County agrees and supports these findings and conclusions and suggests, 
that with experience and improved technology, this level of production could 
be substantially exceeded. In conclusion, we believe the approach used by the 
BLM to combine the known and expected impacts from all industries into one 
statement is essentially a desirable approach and provides the communities, 
the public and industry with guidelines of some real value for both present 
and future planning. We commend you for your foresight and efforts in 
assembling this assessment." Merrill Mecham, Uintah County Commission. 

RESPONSE : The views expressed will be considered in the decision-making 


COMMENT H-6-1 : "With regard to air quality, the modeling effort is to be 
commended in that several state-of-the-art models were used to cover the range 
from site-specific to regional results. Furthermore, a range of uncertainty, 
up to a factor of ten, was cited in the modeling result. All too often, 
unrealistic worst cases are assumed for model input in other EISs which are 
too far removed from reality— yielding results showing violations of air 
quality standards as the bottom line. And the public has the right to 
understand these, the uncertainty in these modeling results and that it's not 
an absolute number. And you're to be commended that it's an EIS with 
foresight with this factor of ten. We have examined work by others regarding 
three or four cases of oil-shale industry carrying capacity in barrels per day 
in the Piceance Basin using today's conservative and approximate models, all 
of which appear to limit daily production to less than 800,000 barrels, 
consistent with the general results of the present EIS." George Fosdick, 
Cathedral Bluffs Shale Oil Project. 

RESPONSE : The views expressed will be considered in the decision-making 

COMMENT H-6-2 : "As the oil -shale industry matures, the need for more 
realistic and accurate models in rough terrain and better understanding of 
regional meteorology will be fulfilled. This, in turn, will remove some 
present-day model conservatism and raise the carrying capacity lid to more 
realistic values, still in presence of significant deterioration compliance. 
The non-modelers reading this draft environmental impact statement need to 
understand this fact. 

The draft environmental impact statement points up the unresolved issue of 
long-range pollutant transport across state boundaries which, in this case 
because of prevailing westerlies, means transport of pollutants from Utah into 
Colorado. Inasmuch as this tends to worsen the carrying capacity lid in 
Colorado, the states of Utah and Colorado need to mutually face up to this 

Up front, to the resolution of the issue, we will require more complete 
meteorological and air dispersion experience specific to the sites and regions 
along with model validation, and I know that we don't have budget in BLM, we 
don't have budget in EPA, we don't have budget in the State of Utah, and we 
don't have budget in industry, but believe me, if we don't stick together on 
this, we're all going to hang together. 

It's a great, big, expensive deal, and in hundreds of thousands of dollars, 
and it's a long lead time and we better get on with the models and the 
regional meteorological studies so when we're up against the stops like the 
State of North Dakota is right now, we have the model and the meteorological 
to meet it." George Fosdick, Cathedral Bluffs Shale Oil Project. 

RESPONSE : A cooperative effort between developing industry and agencies 
responsible for various aspects of air quality would be \/ery useful to develop 
an adequate meteorological data base and employ the most appropriate, 
validated, and cost-effective production tools for both the NEPA and 
regulatory process. This would enable the most efficient development and use 
of synfuel resources within the constraints of environmental compatability. 


Lacking this, regional impacts may be so conservatively estimated that 
development is prohibited on the one hand, or underestimated, creating 
significant environmental impacts on the other. 

COMMENT H-6-3 : "...the draft environmental impact clearly states that the 
present particulate violations in the town in the region are due to fugitive 
dust in the absence of any oil shale industry. 

It is not clear, however, that modeling results for fugitive dust from unpaved 
roads and other sources for the applicants would fully utilize the required 
application of best available control technology. The required BACT, as it's 
called, reduces emissions to approximately 50 percent by regular application 
of water as a control device or to 20 percent of their uncontrolled value by 
regular application of dust palliatives." George Fosdick, Cathedral Bluffs 
Shale Oil Project. 

RESPONSE : The estimate of emissions from unpaved roads within the project 
sites, for the most part, took into account fugitive dust controls (road 
watering, etc.) on project roads because the synfuel companies PSD 
applications stated that such controls would be carried out. However, 
watering and dust suppressants are not likely to be feasible for all (or a 
majority) of unpaved roads in the region due to cost or other considerations. 
Where the applicant did not specify such controls or the control was not 
feasible, the emissions were modeled and analyzed. 

COMMENT H-6-4: "Furthermore, it appears that fugitive dust particulates 
were not settled out according to Stokes Law, which admits heavy dust 
particulates settle out quickly, close in to the emissions source." George 
Fosdick, Cathedral Bluffs Shale Oil Project. 

RESPONSE : The commenter's statement is true. Large particles were not 
settled out and, hence, TSP impacts may be overstated. See also the response 
to Comment 6.2. 

COMMENT H-6-5 : "Furthermore, plume rise associated with fugitive dust is 
low, also contributing to its settling close in. Applicants are required to 
utilize revegetation and reclamation practices to limit dust on both raw and 
spent shale piles. There may very well be an acreage limitation on the 
unrevegetated portion of such piles." George Fosdick, Cathedral Bluffs Shale 
Oil Project. 

RESPONSE : The commenter's statement concerning plume rise is correct. 

Land disturbance and exposed areas would be kept to a minimum. Effective wind 
and water erosion control measures, such as crop residue mulches, rock 
mulches, surface roughness, and slope length reduction measures would be used 
to protect disturbed and exposed areas until vegetation cover can be 
reestablished. No specific acreage limitations are identified for the 
unvegetated portions. However, applicants would reclaim areas in stages 
concurrent with project construction activities and operations to minimize the 
size of exposed areas. 


Refer to Section R-4.A.4, Soil and Reclamation. 

COMMENT H-6-6: "The C-b Tract has successfully utilized busing to the 
reduce vehicular traffic from commuter centers. Over 70 percent of our 
personnel utilized these buses. Such utilization reduces air emissions 
substantially. Busing for commuter purposes was not utilized in the draft 
environmental impact statement modeling, at least that I could uncover." 
George Fosdick, Cathedral Bluffs Shale Oil Project. 

RESPONSE : Busing and carpools for commuting purposes would be successful 
methods of reducing vehicular emissions from transportation of project 
employees. These were not used in the EIS analysis as it is not certain to 
what extent they would occur. Additionally, it would be the secondary 
population increases indirectly related to the growth in the synfuel industry 
which would result in the vast majority of future vehicular emissions. 

CCT ?? W T H ~ 6 ~ 7: " In view of a "IT of the above mitigation measures which 
would have been utilized to reduce particulate concentrations, but apparently 
were not used in the modeling results of the draft statement, we submit that 
all or most of the anticipated exceedances in the tables for Class I areas 
probably would vanish." George Fosdick, Cathedral Bluffs Shale Oil Project. 

RESPONSE : Particulate emissions projected by oil shale developers were 
used in the analysis. To the extent that gravitational settling would reduce 
plume concentrations, particulate concentrations in the report are considered 
to be conservative, upper-bound estimates. See also responses to Comments R-l- 
3, R-l-4, R-l-5, R-l-6, and 6.2. 

COMMENT H-6-8: "Point No. 2. Apparently linear interpolation between the 
morning and afternoon upper air data — that is, you have an afternoon 
sounding and a morning sounding and they linearally interpolate this— was 
utilized in the modeling. This large uncertainty in meteorological data 
points up the need for basin-wide, hourly, real-time meteorological networks 
in the Uintah and Piceance basins utilizing Doppler acoustic radars or their 
equivalent for an extended time period, say one year. 

A need for an improved validated regional air diffusion model also exists, for 
both short-term and annual runs at reasonable run costs. If you don't watch 
yourself in this regard, you pay the gross national product to make a model 
run and nobody can quite afford that." George Fosdick, Cathedral Bluffs Shale 
Oil Project. 

RESPONSE: BLM concurs. The present meteorological data base is very 
fragmentary and is one of the large uncertainties in pollution dispersion 
modeling, not only in the Uintah and Piceance basins, but throughout much of 
the West where energy development and related NEPA and PSD processes are or 
would be occurring. 


COM MENT H-6-9 : "Point No. 3. It needs to be pointed out that some 
non-EPA-guideline models were used for the analysis. Furthermore, a 
demonstration of model validation—there's two models in particular that are 
used by SAI, the complex terrain wind model and regional transport model- 
neither of these were demonstrated to be validated for the basin in question 
in the draft statement." George Fosdick, Cathedral Bluffs Shale Oil Project. 

RESPONSE ; See the response to Comment 30.42. The discussion in both the 
Air Quality Technical Report and the Final EIS have been expanded to further 
quantify the fact that the air quality analysis performed for the EIS was done 
under the requirements of NEPA. It was not performed for the purpose of 
obtaining a PSD permit and would not satisfy the requirements of that process. 
The text was further clarified to recognize that some non-EPA-guideline models 
were used for the analysis. 

COMMENT H-6-10 : "Point No. 4, and the final point. The draft statement 
alludes to exceedances of the PSD near Tract C-b due to C-b emissions, and I 
can assure you that we put that in its most recent PSD application, which was 
later withdrawn, but nevertheless, when it was put in, no such exceedances 
existed. So I would suggest that the statement be softened in that regard." 
George Fosdick, Cathedral Bluffs Shale Oil Project. 

RESPONSE : BLM recognizes that the currently postponed Cathedral Bluffs 
project would not be permitted unless the responsible PSD permitting agency is 
convinced on the basis of approved modeling approaches that PSD increments and 
ambient air quality standards would not be exceeded. The Final EIS has been 
expanded to discuss this further as it related to the Cathedral Bluffs 
proposal . 

COMMENT H-8-1 : "We do have some concern about the potential for a 
threshold level to be reached where the multiple development of projects could 
impose difficulties on local governments to adequately and orderly manage the 
population growth and the potential impacts." Mark Bubriski, Rio Blanco 

RESPONSE : It is recognized that the utilization of percentage growth 
rates is a judgmental method for analyzing impacts since the quantity and 
quality of a community's existing infrastructure is variable. However, for 
reasons of consistency of the analysis, a 10 percent growth rate was used as 
the significance criteria. It is assumed that impacts can and would be felt 
on some of a community's infrastructure prior to reaching a 10 percent growth 
rate but that at this point a threshold would be reached that would tax the 
ability of most communities to manage growth. 

COMMENT H-8-2 : "The EIS states that the Rangely school system now operates 
at 52 percent capacity and can handle substantial growth. The Rangely school 
system is presently feeling the effects of growth. There are tentative plans 
being considered, or at some point in the near future, to build an additional 
elementary school and an addition to the middle school. To assume that 
current capacities are adequate is incorrect." Mark Bubriski, Rio Blanco 


RESPONSE : EIS data on Rangely was derived from the Colorado Cumulative 
Impact Task Force draft community profiles. This data source was used at the 
request of the Colorado Department of Local Affairs and the Colorado State 
Bureau of Land Management to ensure consistency with the Federal Oil Shale 
Management Program EIS (BLM 1983) and other Colorado studies^ The school 
enrollment data and capacity data was for 1981. It is true that the 1982 
school enrollment figures show a substantial increase in Rangely, Colorado, as 
a result of the Western Fuels project. 

COMMENT H-9-1 : "...One of the first questions I have is, when you measure 
energy efficiencies of these operations, you have taken an input and divided 
it by output times a hundred and I was wondering; is this standard procedure 
for measuring—it would seem like you would want to put input divided by 
output plus input times a hundred. I am not sure of this. I have a hard 
time of taking a ratio and calling it a percent." Peter Hovingh 

RESPONSE : The standard formula for energy efficiency is the energy "out " 
divided by energy "in," times 100 (Section R-4.A.13). This is discussed in 
more detail in the Energy Analysis Handbook for Preparation of Oil Sh ale 
Development Environmental Impact Statements (BLM 1982a). 

COMMENT H-9-2 : "...Another concern of mine was revegetation and I was not 
sure after reading this impact statement whether revegetation was going to be 
natural events or whether it was actually going to be reseeded or— and 
planted." Peter Hovingh 

RESPONSE: Revegetation would be accomplished through the reseeding and 
planting of adapted native species and using applicable effective measures and 
techniques to provide a vegetative cover that would withstand the arid climate 
and soil conditions typical of the area (Appendix A-8). 

COMMENT H-9-3 : "...I had a hard time—20 years revegetation or 10 to 40 
years for full growth. I am not quite sure of the effectiveness of the 
revegetation and I would like more information on that." Peter Hovingh 

RESPONSE : The time periods identified in the Draft EIS refer to the time 
required for certain vegetation types to achieve full growth. The longer 
period relates to shrub types and trees (Appendix A-8). 

COMMENT H-9-4: "There was, again, some concerns in that you would mention 
the Gibson and Linhurst 1982 effects of acid precipitation on the North 
American continent and you didn't mention any publishers and I was wondering 
where one could get hold of such documents." Peter Hovingh 

RESPONSE: A complete bibliographic citation for this report has been 
added to the reference list. 

COMMENT H-9-5 : "...I think there was one other reference you had listed, 
Turk and Adams 1982, and there wasn't anything in the reference on that." 
Peter Hovingh 


RESPONSE : The bibliographic citation for the Turk and Adams study has 
been added to the Final EIS References section. 

COMMEN T H-9-6 : "Again, I am very interested in acid rains and we keep 
hearing that there is no baseline data on acid rains and yet there is an awful 
lot of material known." Peter Hovingh 

RESPONSE: Acid deposition has been of growing concern since the 1970s, and 
assessmen t of environmental effects is still in the very early stages. The 
majority of work on effects has been conducted in the northeastern United 
States and southeastern Canada. Much less information is available for 
western environments where ecosystems are much different relative to soil pH, 
buffering capacity, precipitation amounts and distribution, and vegetation 
types. As discussed in response to Comment H-9-8, there is a monitoring 
network which was organized in 1978 and presently has 100 stations in 42 of 
the 50 states. In addition, there are a number of studies presently underway 
in the West, some of which have been cited in the EIS (Section R-4.A.2). me 
discussion in the Final EIS (Section R-4.A.2) has also been expanded to 
include additional data. 

COMMENT H-9-7: "...One of the comments you make in the paper— its' s on RG 
20 and watersh ed soils which alkaline, containing alkaline or bicarbonate to 
buffer or neutralize incoming acid deposits — lakes and streams would all I be 
acified and aquatic news will be less susceptible to the harm. I think this 
is quite false at this time. 

When you are taking acid rains and using the rain store for buffering, it 
releases calcium and a lot of your heavy metals— aluminum, lead— and they come 
into the streams in a very toxic force and this toxicity does have a great 
effect on aquatic communities without changing the pH. I think this is quite 
well -documented in some of the acid rain literature." Peter Hovingh. 

RESPONSE* While it is true that some loss of minerals and mobilization of 
trace elements may occur as the result of natural weathering and leaching 
processes, these processes can be greatly accelerated by change in pH toward 
qreater acidity. The presence of calcium in soils formed from highly 
fossilferous sediments, limestones, dolostones, etc., provides carbonate 
minerals which constitute the acid-neutralizing (buffering) capability of the 
soil and, therefore, its resistence to pH change. The commenter is referred 
to the following references, as cited in the references section, for -more 
detail (Gibson and Linhurst 1982, Norton et al. 1982, Turk and Adams 1982). 

COMMENT H-9-8 : "One of the things I am wondering, again, in acid rains, is 
will there be any mitigations for monitoring? I can-the EPA says there is no 
baseline data and I would like very much to see baseline data in tne 
Intermountain West. I understand there is quite a bit of biological 
monitoring at the Rocky Mountain Biological Station in Colorado. I understand 
that there aren't any instruments measuring acid rain in Utah and l c °uia 
easily envision if this oil shale comes really to full bloom with all tne 
commitment to a coal development is that we need established monitoring ot 
acid rains in, say, Cedar Breaks, Alta, Logan, and perhaps Vernal, just to 
find out where the acid rains are coming from and to get good baseline data. 
Peter Hovingh 


RESPONSE : Two major networks designed to measure precipitation chemistry 
exist in North America. These are the Canadian Network for Sampling 
Precipitation (CANSAP) organized in 1977, and the National Atmospheric 
Deposition Program (NADP) organized in 1978. The NADP is supported by the 
Bureau of Land Management, National Park Service, Environmental Protection 
Agency, U.S. Geological Survey, National Oceanographic and Atmospheric 
Administration, state agencies, electric utilities, and the wood products 
industries. Each of these stations is located at a site that is selected to 
be representative of the region. At the present time, the network consists of 
100 stations representing 42 of the 50 states with plans to expand to 150 
sites. At the present time, there is one station in Utah operated by the BLM. 
BLM has plans underway to install an additional two stations in Utah in fiscal 
year 1983. 

COMMENT H-9-9: "...When it comes to some of your wildlife things you do 
mention amphibians and reptiles. One aspect that's misunderstood about 
amphibians is, because they can go out on land, they don't need water and 
therefore they can readily rehabit any disturbed area and this is— some 
amphibians can do this. The great spade-foot toad can do this. In fact, the 
spade-foot toad lives in disturbed soil as long as there is some water around 
for breeding. But the other amphibians that are mentioned in Stephen's Guide 
to Amphibians and Reptiles of the Western United States do require permanent 
water for breeding and one of my concerns is, that if you remove this 
permanent water, you may greatly affect the distribution of these amphibians, 
wiping out a population for a hundred miles around." Peter Hovingh 

RESPONSE: No permanent water would be removed through the implementation 
of the synfuels projects. There is virtually no chance that these species 
would be eliminated by the projects. 

COMMENT H-9-10 : "...Some of these amphibians are very localized. I note 
that there is no current status of distribution of amphibians in Utah and for 
that matter, the Intermountain region, Nevada, Idaho, and Utah. It would be 
very useful to know about the amphibian distribution in the oil shale region 
to know what is being affected before it disappears." Peter Hovingh 

RESPONSE: The EIS analysis does not predict any significant effects to 

amphibian species (Section R-4.A.5). However, distribution of amphibians 

in Utah can be found in Vertebrate Wildlife S pecies (Utah Division of 

Wildlife Resources 1981). — 

COMMENT H-9-11 : "There is another concern of recreation on the White 
River. You talk about the water-oriented activities that the construction 
crew and the people who work on-site will greatly appreciate, the White River 
Reservoir, and yet I would certainly like to know if they would appreciate 
canoeing. I wonder where these people are going to come from that they won't 
know about canoeing." Peter Hovingh 

RESPONSE: The potential impacts of the White River Dam are addressed in 
detail in the White River Dam Project EIS (BLM 1982b). 


COMMENT H-9-12: "There is mention of salinity— increased salinity and how 
much it costs; $4,720,000 annual. I would certainly like to know who pays 
this. And one of the side aspects of acid rains is that if it neutralizes 
alkaline soil that means there would be an acid increase, salinity In the 
region. Maybe perhaps the question is, are we producing more salinity in the 
Colorado River system than we are removing from the Colorado River system 
under the present programs." Peter Hovingh 

RESPONSE : The correct estimate of damages to downstream users is $472,000 
per mg/l increase in salinity at Imperial Dam, California. This is not an 
annual assessment or payment, rather it is an estimate of damage primarily 
from crop loss and increased pumping costs to flush salt from the soil. 
Because of this, these damages are shared by many downstream users. 

COMMENT H-9-13 : "...One of the things I have done here is I have prepared 
a table comparing the various oil shale companies with their capacity per 
year, barrels of oil; water consumption per year, barrels of oil produced per 
acre-foot of water consumed; surface disturbance. I guess that would be total 
surface disturbance per barrel of oil produced, per acre of disturbed soil; 
and the sulfur dioxide emission against barrels of oil produced per year per 
kilogram of sulfur dioxide released per hour. If the state were interested 
in selecting good industry in the oil shale field they certainly have a tool 
here to handle. The tar sands would go down the drain very fast. Magic 
Circle would stand out quite prominent. If they were concerned about water 
use, being the second dry state in the nation, they would certainly eliminate 
all' projects that waste water and, of course, in this state, one doesn^t 
concern about industry wasting water, it's as long as one keeps California 
from getting it." Peter Hovingh. 

(Note: Table referred to in this comment is reprinted with Comment Letter 5.) 

RESPONSE : The views expressed will be considered in the decisionmaking 

COMMENT H-9-14 : "But one of the big concerns, of course, with all of tnis 
water in use, is that the river runners are going to be left stranded more 
and more often." Peter Hovingh 

RESPONSE : There would be no noticeable effects to river running on the 
Green or Colorado rivers as a direct result of the proposed synfuels 
development. Indirectly, however, the White River, as it exists today, would 
be different due to the construction of the White River Dam and subsequent 
regulated flows. The impacts of the White River Dam are analyzed in detail in 
the White River Dam Project EIS (BLM 1982b). See also the response to Comment 


COMMENT H-10-1: "It is imperative that oil shale and tar sands development 
and growth of eastern Utah takes place that invaluable and irreplaceable river 
resources be addressed. The historical approach to management of Utah's water 
resources, one of constructing dams on ewery river as the only means of 
supplying water, is not acceptable to many Utah citizens. Development of 
surface waters first, neglect of conjunctive water management using available 
ground water supplementally, and failure to address and include conservation 
of water to reduce demand and water use— all of which practices contribute 
unnecessary depletion of our rivers— is no longer tenable." Dorothy Harvey 
Intermountain Water Alliance. 

RESPONSE: The water model that was used in this study addresses water use 
as proposed by the applicants. The issue of using surface water versus ground 
water or of requiring certain conservation measures is an issue that is 
considered by the State Engineer during the application process. It is not 
intended that this EIS evaluate Utah State water policies that may be set by 
the State Legislature, State Engineer, or State Division of Water Resources. 

COMMENT H-10-2: "Both the Bureau of Reclamation and GAO, General 
Accounting Office, document the availability of already-stored water both in 
Flaming Gorge and in Lake Powell. Utah's share of Flaming Gorge is 452,000 
acre-feet of unsold water. It is almost— there is over 900,000 acre-feet of 
unsold water in Lake Powell. 

What are we waiting for? Why isn't this water used? Why is the water not 
released from Flaming Gorge down to the Green to be pumped by industry? If we 
need more than that, why is no exchange made of some of this available stored 
water in Lake Powell and that to be released from Flaming Gorge?" Dorothy 
Harvey, Intermountain Water Alliance. 

RESPONSE : The water that is stored in the Colorado River System is 
intended to ensure that uses at downstream points are met, based upon compact 
and international agreements. The net effect of using Flaming Gorge storage 
water rather than flowing water from the Upper Colorado River Basin would not 
change the salinity increases nor would it change the depletions at the inflow 
to Lake Powell. It would simply shift the burden from the White River to the 
Green River or another source. See also the EIS Preface concerning the 
position of the U.S. Bureau of Reclamation and the Utah Division of Water 
Rights on the availability of Flaming Gorge water. 

COMMENT H-lO-3 : "Information on ground water resources in the draft EIS on 
ground water sources appears to be inaccurate, since apparently it is taken 
from U.S.G.S., Division of Water Resources hydrology in the northern Uintah 
Basin, not the south. U.S.G.S. ground water studies for the southern basin 
are not completed or completely reviewed. This study was completed and it was 
sent for review two years ago and there is some need to revise the modeling so 
it s still not reviewed. What this means is not all data is available to the 
public." Dorothy Harvey, Intermountain Water Alliance. 


RESPOMSE : The EIS ground water resource information is based on the USGS 
hydrology for the northern basin. The survey's southern Uintah Basin report 
is not available. However, according to U.S.G.S, this report will not change 
the description of the occurrence of ground water, nor the effects on ground 
water as predicted in the EIS. 

COM1ENT H-10-4 : "Since impacts on ecosystems of the rivers involved in 
supplying water for synfuel development cannot be pre-determined without more 
precise management recommendations which address criteria required to maintain 
flows and kinds of flows for river recreation, the EIS is remiss and 
inadequate. It is essential that the agencies and industries participating in 
this kind of energy development evaluate the hydrological requirements which 
meet recreationists' needs and use such information as a basis for planning 
their water requirements." Dorothy Harvey, Intermountain Water Alliance 

RESPONSE : The EIS states that flow reductions would range from to 30 
percent on the White River, to 4 percent on the Green River, and about 1 
percent at the inflow to Lake Powell. Significant impacts would result if 
reductions in flow exceed 10 percent (significance criteria identified in 
Chapter R-4). There would be no noticeable effects to river running on the 
Green or Colorado rivers. However, the White River as it exists today would 
be different due to the construction of the White River Dam and subsequent 
regulated flows. This point has been clarified in Section R-4. A. 8. Also, 
please see the recreation discussion in the White River Dam Project EIS (BLM 
1982b). That EIS has been incorporated by reference and is available from the 
BLM Vernal District and the BLM Utah State Office. 




h- • 





Office of the 

Principal Regional Official 

Region VII I 

Federal Office Building 
1961 Stout Street 
Denver CO 80294 

September 17, 1982 

Mr. Lloyd Ferguson 
District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 84078 

Dear Mr. Ferguson i 

We have reviewed the DEIS on the Uinta Basin Synfuels Development. 

As discussed in this DEIS, the impact of the synfuels development on 
certain countieB in Utah and Colorado will be very significant, par- 
ticularly in Utah. In general, an adverse effect on housing, education, 
mental health and social services, and community services is projected. 
The projected demand for additional social workers, for example, is 
high where shortages of trained staff already exist. Given the status of 
Federal/State budget constraints, the prospects for increased staffing in 
the effected communities are very limited. 

The DEIS ii. eluded an appendix entitled "Uncommitted Mitigation Measures, " 
which would address potential environmental effects of the proposed de- 
velopment. It is suggested that the synfuels projects provide direct 
assistance in housing, law enforcement, Indian job training, funding for 
social workers, etc 

We encourage an approach that would result in specific synfuels project 
commitments to the above, given the decreasing availability of Federal/ 
State financial resources. 

Sincerely yours, 

U.S. Department of Health and Human Services, Region VIII 


The types of direct assistance suggested to be provided by synfuels 
applicants are listed under the Socioeconomics section of Appendix A- 
7, Uncommitted Mitigation Measures. Although the BLM would encourage 
the applicants to work with the affected communities and groups to 
alleviate social and economic problems, we have no legal authority to 
require their commitment to specific socioeconomic measures. 
However, the State of Utah's S.B. 170 mandates a socioeconomic 
mitigation process in Utah that requires applicants to work with 
potentially affected communities to deal with shortfalls in community 
service and facilities associated with development. 


E. W. Mclntire 
Director, ROFEC 









Mr. Lloyd Ferguson, District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 84078 

Dear Mr. Ferguson: 

Concerning the Draft Environmental Impact Statement on the Uintah 
Basin Synfuel s development: 

The Wasatch Mountain Club 1s actively Involved 1n river recreation. 
Withdrawals of water from rivers without planning for river recreation 
destroys recreation opportunities 1n Utah. River-related recreational 
activities In arid regions have greatly increased in the last decade 
while the number of river miles have declined drastically. Furthermore 
the exlstln flows of rivers have left river runners stranded on the 
rocks because of low waters and water consumption upstream. 

It Is noted that water resources are not being plannned' in the Draft 
EIS. It 1s noted that all the projects adjacent to ana south of the 
White River have preferred alternatives from the White River no matter 
how close these projects are to the Green River and the abundance of 
stored water in Flamming Gorge Reservoir. Since the Draft EIS assumed 
the construction of the White River Dam and Reservoir, it 1s obvious 
to the reader that all water consumption thin must come from the 
White River whether or not the source 1s the best source. It is even 
more clear that this is the case when 30% of the White River will 
be consumed by the Synfuel s projects while the Impact on the Green 
River would be less than 2t. Obvious rivers, river recreation, and 
riparian habitat was not planned for in the Draft EIS. 

Because of the importance of river recreation for members of the 
Wasatch Mountain Club and for many others who live throughout the 
country, the Wasatch Mountain Club urges that 1n the granting of the 
right-of-way permits and other permits, that only permits to those 
synfuel s projects be given which are the least destructive to the land, 
to the air, and to the riparian habitat. Furthermore the Wasatch 
Mountain Club urges that no waters be withdrawn from streams and rivers 
that are 1n excess of It of the average flows. Additional water for 
synfuels must be obtained from the numberous existing reservoirs. 

Conservation Director 
Wasatch Mountain Club 



Wasatch Mountain Club 

2 1 The impacts from the proposed White River Dam Project are discussed 
in the EIS for that project. The White River Dam is the proposed 
source of water for most of the synfuels projects described here. 
Information from the White River Dam Project EIS (BLM 1982b) has 
not been duplicated here, but it is referenced and is available to 
the readers and decisionmakers. 

The Uintah Basin Synfuels EIS addresses potential impacts to river- 
recreation in the various Chapter 4 Recreation sections; impacts to 
riparian habitat are addressed 1n the Vegetation, Soils, and 
Reclamation sections and Wildlife sections. 

The alternatives of obtaining water from the Green River are analyzed 
for each of the site-specific projects. Please refer to the EIS 
sections related to the following alternatives: 

Enercor— Green River Alternative Supply System 

Green River Southern Loop Alternative Water Supply 

Magic Circle— Proposed Action 

Green River Alternative Water Supply System 

Paraho— Bonanza Power Plant Alternative Water Supply System 

Syntana-Utah— Green River Alternative Water Supply System 

Tosco--Green River Section 23 Alternative Water Supply System 

2.2 The views expressed will be considered in the decision-making 










555 ZANG STREET, BOX 253«6 

October 1, 1982 


U.S. Federal Highway Administration, Region VIII 



U.S. Department of the Interior 

Bureau of Land Management 

Mr. Lloyd Ferguson, District Manager 

170 South 500 East 

Vernal, Utah 84078 

Dear Mr. Ferguson: 

Thank you for the opportunity to review your Draft Environmental Impact 
Statement on Uintah Basin Synfuels Development. While the document appears 
to be well constructed and covers the impacts of the synfuel projects, we 
have the following comments. 

There appears to be no 11st of those agencies consulted during preparation of 
this document nor a 11st of those agencies who will review 1t and the final 
document. Since there apparently will be significant highway and road 
impacts from the proposed development, we would encourage that you work 
closely with the Utah Department of Transportation (UD0T) and affected county 
highway agencies in the review of this draft and the development of a final 

Page R-4.8 indicates that the impact to roads would be considered significant 
if the Level of Service dropped to Level "D" as defined 1n the AASHTO 
Capacity Manual. Current highway design practices dictate that roads be at a 
Level of Service "B". We again encourage close coordination with UDOT and 
county highway agencies to assure proper highway capacity for the proposed 

The document recognizes the significant impacts on the highways caused by the 
development but does not specify mitigation measures to alleviate these 
conditions (i.e., what measures would be required, by whom, when, to what 
degree). These measures should be included in the final document. 



Fred Hempel 


Consultation and coordination Mas discussed In Appendix R-E of the 
Draft EIS. Utah Departaent of Transportation and the affected county 
governments were requested to review the Drift EIS and also will 
receive copies of the Final EIS. 

BLH appreciates the commentor's point that roads are designed at a 
Level of Service "B." The rationale for using Level of Service "0" 
for existing roads as the breaking point for a significant Impact is 
that, by definition, this Is the point at which deficiencies become 
critical (American Association of State Highway and Transportation 
Otrlcials 1965). BLM agrees that close coordination with Utah 
Division of Transportation Is tiaportant (see response to Cessent 

Mitigation of highway impacts is addressed in Appendix A-7, 
Uncoirmitted Mitigation, and Appendix A-ll, general Measures for 

Grants and Permits. 






721 Second Avenue 
Salt Lake City 
Utah 84103 

11 October 1982 

Mr Lloyd Ferguson, District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal , Utah 84078 

Dear Mr Ferguson: 

Concerning the Draft Environmental Impact Statement on the Uintah Basin 
Synfuels Developments: 

Utah Nature Study Society is an organization dedicated to the understanding 
of natural worlds, promotion of education of nature study, and to the wise 
use of natural resources. 

We note that natural streams are becoming a rare habitat and ecosystem In 
arid regions. It 1s noted that the preferred alternative of all users (except 
Sohio which is too far from the White River) of water 1s the White River even 
when one user prefers the Green River (Magic Circle). Is this wise use of 
water resources to Impact one river by over 25% whereas a second river (the 
Green River) is Impacted less than 42? Furthermore by withdrawing water from 
the White River one impacts the Green River anyway. It seems that wise use 
of water and preservation of a unique and rapidly diminishing ecosystem 
(desert riparian) would dictate the use of the Green River water directly. 
Or has the State of Utah told you that only White River water could be used 
for synfuels just so the State of Utah could rationalize the use of taxpayers 
monies for the costly studies on the White River Dam? 

The White River Dam Final Environmental Impact Statement only allowed for 

75 000 acre-feet of water to be used from the White River (Biological Opinion). 

Is'not the 103,000 acre-feet of water in the high level scenario exceeding 

the use as dictated by the Biological Opinion? By utilizing the data 1n Table 4-2 

(White River Final Environmental Impact Statement) and increasing the usage 

to 103 000 acre-feet, it seems that during December and January the flows 

would be reduced to less than 250 cfs. For December the flows in an average 

year woudl be 231 cfs and in January the flows would be 229 cfs. Then if one 

proceeds to Table 4-3 of the Final Environmental Impact State on the White 

River it seems that the flows would be reduced every month to less than the 

250 cfs instead of the proposed July, August, and September as stated 1n Table 

4-3 The major flaw in the Biological Opinion is that the flows are adjusted 

to what enters the reservoir. If oil shale developments occur in Meeker and 







and Rangely as suggested in the Draft Environmental Impact Statement for the 
Synfuels Developments, depletion of the White River above the reservoir would 
be severe- allowing for no protection of the endangered species of fish. 

Consequently Utah Nature Study Society asks that: 

1) the Final Environmental Impact Statement for the Synfuels Program 
1n the Uintah Basin Include a table for the flows below the dam 
with 103,000 acre-feet consumption of water from the White River 

(a Table similar to Table 4-2 1n the Final White River Environmental 
Impact Statement). 

2) the Final Synfuels Environmental Impact Statement Include a table 
comparable to Table 4-3 1n the Final White River Environmental 
Impact Statement for flows below the dam with 103,000 acre-feet 
of water consumption occurring 1n the White River. 

3) That the Final Environmental Impact Statement for the Synfuels 
Program include a Table showing the flows of the White River below 
the dam with 103,000 acre-feet of water consumption for a 25% 
draught year (flows half way between the mean and year 1977). 

4) the Final Synfuels Environmental Impact Statement Include a table 
for flows below the dam with 103,000 acre-feet of water consumed 
1n Uintah Basin synfuels developments from the White River and 
for the proposed synfuels developments in Colorado that would 
use the White River water. Both average year and 25% draught and 
year 1977 should be used. 

We still suggest that a better alternative is to allow the White River waters 
to be used, if necessary, for the construction phase of the synfuels developments 
and to pipe all the operational uses of water from the 10-times larger Green 
River together with the huge Flamming Gorge reservoir for backup. If the oil 
shale industry wants .a reliable source of water, the Green River is the only 
source of water that can be considered reliable. Reliability of course includes 
many factors as a system already in operation and acceptible by many people 
who use the waters for recreation. 

the Synfuels Developments included 
step forward. However 1n 
h are alkaline (containing 
lyze incoming acid deposition, 
dly and aquatic communities 
be noted that neutralization 
ich 1) poisons the biological 
gical communities of necessary 
f calcium from limestone 
ems. If the phosphate content 
these communities will die. 

The Draft ^Environmental Impact Statement for 
a section on acid rains. This is certainly a 
R-G-20 it is stated, "In watershed soils whic 
limestone or bicarbonate) to buffer or neutra 
lakes and streams will be acidified less rapi 
will be less susceptable to harm." It should 
of alkaline soils solubilizes many cations wh 
communities directly or 2) deprives the biolo 
nutrition. For example, the solubilization o 
changes the phosphate content 1n aquatic syst 
is limiting for biological communities, then 
This occurs without changes in pH. 

We have heard that conservation pools in reservoirs in Utah are very common. 
We also understand that during draught, the conservation pools in Utah are 
not used by wildlife but are drawn down for municipal and industrial and 
agriculture uses. If this is so, what is the value of conservation pools? 
Utah Nature Study Society would like a record of conservation pools during 
1977 draught to determine if the conservation pool of the White River 
Reservoir is a meaningful procedure to preserve the minimal flows. We would 
also like to know what is the life-expectancy of the conservation pool 
with the high degree of siltation that the reservoir will receive. 


4.6 It is noted that Parahoe-Ute project will dispose of waste in side canyons 

of the White River. It is proposed that dams (barriers) will be used to 
keep the waste from entering the White River. Who will maintain these dams 
after Parahoe-Ute pulls out of the operations? What will these barriers 
look like from below? What will a water pumping station look like? 

47 It is noted that Tosco White River Source will use a 3 inch screen. What 

will pass through the 3 inch screen? How will the 3-inch screen affect 
aquatic life during low water? What portion of aquatic life in the White 
River will pass through the 3-inch screen? 

4.8 It is noted that reclamation of the waste lands could only be successful 

with a highly successful Federal and State compliance program. Who pays 
for this compliance program? Who will assure that reclamation will be complete? 
Will reclamation withstand draught? Does the reclamation program actually 
include reseeding or natural revegation (tumbleweeds, halageton, and dandelions)? 
How much water will be required for successful reclamation of waste lands? 

These are some of our concerns. It is useful to be able to compare the 

various projects in the Uintah Basin. The Draft version is a good version 

with the exception of requiring all the users in the region to use White 

River water just so the State of Utah can build its dam and pay off 

a Water Developer. 



Peter Hovingh / 

President, Utah Nature Study Society 

Utah Nature Study Society 

4.1 The views expressed will be considered in the decisionmaking 
process. Also refer to the response to Comment H-10.1. 

4.2 The following responses correspond to the four items enumerated in 
the comment. 

1) A memorandum of agreement has been completed regarding fish and 
wildlife conservation measures associated with the White River Dam 
Project. That agreement Is between BLH, U.S. Fish and Wildlife 
Service,, Utah Board and Division of Water Resources, Utah Division 
of Wildlife Resources, and Utah Department of Natural Resources 
and Energy. Copies of that agreement are available on request to 
the BLH Vernal District. The agreement outlines water flow 
release provisions consistent with the biological opinion for the 
White River Dam project. 

(2 and 3) These two items refer to the driest period on record and 25 
percent of the driest period on record, respectively. This EIS 
made a modeling effort to predict flows from the applicants' and 
Interrelated projects far into the future. Changes in flows are 
given In Section R-4.A.3 for 1983, 1985, 1990, 1995, and 2000. 
These changes are shown graphically in Figure R-4-4. This 
establishes a water consumption trend. 

In the modeling that BLH did for this EIS, a computer run was made 
that represented drought conditions. This run was not used as the 
basis for determining impacts, because it was thought to 
overemphasize the worst case. For this EIS, worst case is defined 
as all the applicants withdrawing water from the same source 
(rather than withdrawing during a drought year). Therefore, this 
EIS presents two worst cases - Maximum White River Development and 
Maximum Green River Development. Also, maintaining a 250 cfs 
minimum flow as agreed to for the White River Dam Project would 
result In mitigation of most drought year impacts to less than a 
worst case. 

4) The data presented in this EIS considers significant water use 
Impacts in Colorado on the White River. Baseline water use is 
projected to increase considerably from 1985 to 1950 (Figure R<-4- 
4). Part of this represents oil shale, agriculture, and other 
water development in Colorado. 

In summary, the BIN chose to show changes in flows based upon two 
situations: Maximum Green River and Maximum White River 
Development. This was done due to the long time span of this 
project and due to Its complexity. 

».3 The Green River Maximum Development case used In the water resources 
analysis assumed maximum use of the Green River by the synfuels 
projects (Section R-4.A.3). The views expressed in this comment will 
be considered in the decisionmaking process. 





4.4 Available calcium in the soil solution from natural weathering and 
leaching processes can interact with phosphorous to nuke phosphorous 
unavailable for uptake by plant roots. This can lead to a 
phosphorous deficiency whicn, if severe enough, can cause the demise 
of tiie organism. An example is phosphorous and iron deficiencies of 
roses planted close to co-terete structures such as house 
foundations. Calcium availability froii the lime in concrete can 
reduce phosphorous and iron availability for root uptake, leading to 
chlorosis, necrosis, or even death of the plant. 

The role of calcium from highly calcareous soils and related 
buffering capacity is a different matter as discussed in response to 

Comment H-9-7. 

4.5 The concerns raised in this comment relate to operation of the White 
River Dam. Please refer to the White River Dam US (BLM 1932b) for a 
discussion of the information known about sedimentation and the use 
of conservation pools in drought years. 

4.6 The dams and spent shale pile would be constructed on private land 
owned by Paraho. Paraho would maintain them. 

Figure SS-1 gives a general idea of what the barriers would look 

A plan view and cross section of Paraho's river intake structure and 
pumping station is shown on Figure C-l. 

4.7 Fish, twigs, and similar sized materials would pass through. The 
only aquatic species that would experience significant effects from 
the intake structure would be the fish species discussed in Section T- 
4. A. 5 under the heading. Threatened or Endangered Species. 

4.8 Appendix A-8 discusses the applicants' erosion control and 
reclamation programs. The applicants are committed to the total cost 
of reclamation. The state and federal agencies involved would have 
monitoring, inspection, and certification responsibilities requiring 
time and costs that would be reimbursed by the applicants. 
Inspection and certification would be determined by landowner or 
authorized agency official. 

The reclamation programs include reseeding to adapted native 

Revegetation is based on use of adapted native species and use of 
applicable and effective measures to provide a vegetative cover that 
would withstand the arid climate and soil conditions typical of the 
area. Supplemental water (source from process) would be used mainly 
in the leaching process associated with preparing a suitable plant 
growth condition in the upper layer of the spent shale piles. This 
amount of water required has not been quantified. 


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Box 1713 

Salt Lake City 

Utah 84110 

12 October 1982 
Mr Lloyd Ferguson, District Manager 
170 South 500 East 
Vernal , Utah 84078 

Dear Mr Ferguson : 

Concerning the Draft Environmental Impact Statement for the Uintah 
Basin Synfuels developments: 

In reviewing the Data in the Draft Environmental Impact Statement, 
the Intermountain Water Alliance has compared the various developers 
of synfuels with respect to: 

1) the barrels of oil produced per year per acre-feet of 
water consumed (column 2) 

2) the barrels of oil produced per year per acre of disturbed 
surface for the project's life (column 3) 

3) the barrels of oil produced per year per kilogram of sulfur 
dioxide emitted per hour (column 4) 

Table 1 summarizes the data. In each case the large the number, the 
greater Is the productivity of oil in relation to the stress the 
development places upon the environment. Intermountain Water 
Alliance is concerned about the inefficiency of oil production in 
relation to water consumption, in the deterioration of natural 
water courses due to poor land reclamation and great land 
disturbances, and to the deterioration of aquatic resources due to 
acid precipitation. 

From this data we note: 

1) tar sands development has much more impact on water, land 

and air than oil shale development 

2) there is a ten fold difference amoung various oil shale 
processes in their consumption of water 

3) there is a- six fold difference among various oil shale 
processes in their disturbance of the terrain 


there is a 240-fold difference among the various oil 
shale processors in the emissions of sulfur dioxide into 
the air 

5) (not listed) there is only about a two fold difference 
in employment among the various synfuels processors 

•f Iftah't vitar roaourcoa lo 



The Intermountain Hater Alliance nots that the Draft Environmental 
Impact Statement lists Enercorainbow, Enercor-Mono Power, Paraho-Ute, 
Syntana-Utah, Toxco, and White River Oil Shale Corp as requiring their 
water from the White River. We also see that the State and the Bureau 
of Land Management are trying to coerce Magic Circle into taking water 
from the White River instead of the Green River. 

For water resources we note: 

Duchesiie River 
White River 
Green River 

average annual flow 




High level 
(acre- feet/year 



* Includes the 105,000 acre-feet from the White River 

Both the Duchesne River and the Green River have an abundance of stored 
and unused and uncommitted water in reservoirs. The White River is 
still an unregulated river the runs the natural cycles. Consumption of 
water from the White River assumes that a dam will be built and will 
be built by state funding and taxes. 

We then note that taking water from the White River and assuming the 
STate of Utah will build the dam that the Bureau of Land Managements 
preferred alternatives will: 

1) destroy the White River for canoe and rafting recreation 

2) destry the riparian habitat along the White River for 
wildlife and the Fremont Cottonwood ecosystem 

3) impact the Green River by removin g 105,000 acre-feet 

By pumping water from the Green River the synfuels industry would only 
impact the Green River by a small amount. By pumping water directly from 
the Green River and having the equivalent amount of water released from 
Flamming Gorge might not impact any river. The Intermountain Water Alliance 
has supported this last notice. 

The Intermountain Water Alliance ask if: 

1) the destruction of the White river and the Impaction on 
the Green River is President Reagans new water policy? 

2) the destruction of the White River and the Impaction on 
the Green River is the Department of Interiors new water 
pol icy? 

3) the destruction of the White River and the impaction on 
the Green River is the Bureau of Land Managements new 
water pol icy? 

4) or is the destruction of the White River and the impaction 
on the Green River the continued policy of the State of 
Utah in water resource management? 

5.3 The Intermountain Water Alliance wonders just how the preferred alternatives 
were arrived at and why did the Bureau of Land Management assume the White 
River Dam would be built? Was this same assumption present when the Bureau 
of Land Management formulated the Draft Environmental Impact Statement and 
the Final Environmental Impact Statement on the White River Dam and 
Reservoir? Is the the purpose of the Environmental Impact Statement to 
determine the effect on lthe environment and the mitigation of these effects 
in the least destructi ve manner? 






The Intermountain Water Alliance notes that Sohio, Syntana-Utah, Tosco-Utah, 
Enercor-Rainbow, and Enercor-Mono Power will require 430.1 megawatts of 
electricity. This electrical demand will require an additional 6800 acre-feet 
of water for these projects (assuming the ratio of 3000 megawatts requires . 
50,000 acre-feet of water - Intermountain Power Project requirements). We also 
note that whenever large blocks of electrical energy is required in Utah, the 
rates for all customers, including residential and commercial users, increases. 
Furthermore, if industry does not use what was built for them, either by 
strikes, or by shut-downs, the cost of that capacity is then spread among 
the existing customers. 


5 5 why does Parahoe-Ute wish to put its spent oil shale and terrain waste 

in the steep side canyons of the White River? Would it not be better for 

Parahoe-Ute and Syntana-Ute combine their spent oil shale solid waste 



5.6 With the exception of the water resource analysis and the preferred 

alternatives of water resources, the Bureau of Land Management has put 
together a good document that for the first time describes some of the 
combined effects of large scale synfuels development. We think that 
the water analysis either is non-existent or that the Bureau of Land 
Mnanagement was told what to say so that J. Bingham can build his dam. 

Sincerely, t » J 

Peter Hovingh, Board of Trustees 
White River consultant 

Intermountain Water Alliance 

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Intermountain Water Alliance 

5.1 Generally, the statements made in the comment are true. However, it 
should be recognized that there are some differences in what is being 

In the case of water, some projects upgrade the oil more than others 
and some generate steam for on-site power production, both of which 
change the water use. 

The acres of disturbed lands depends on what the company has proposed 
to do. The disturbance depends on things such as length of water and 
product lines (and whether any other pipelines are proposed); how 
much the spent shale will be spread out versus how high it will be 
stacked; and similar factors. 

The sulfur dioxide figures are for controlled emissions, not 
necessarily what the different processes put out. 

5.2 Impacts of the White River Dam are discussed in the White River Dam 
EIS (BLM 1982b). Impacts of the proposed synfuel development to 
canoeing and rafting are discussed in this EIS in Section R-4.A.8; 
impacts to riparian habitat and the cottonwood ecosystem are 
discussed in Sections R-4.A.4 and R-4.A.5. 

The Department of the Interior has adopted a "good neighbor" policy 
to increase cooperation with state and local governments. The policy 
gives emphasis to making federal decisions in consultation with 
governors, county commissioners, and various elected or appointed 
local governing bodies. With specific regard to water resources, the 
policy recognizes the primary authority of the state to allocate 
water resources and the role of the state in major water planning 
functions . 

The Department of the Interior is emphasizing the primacy of state 
water law and increased state responsibility in managing, planning, 
and financing water projects. 

5.3 The practicality of obtaining water from a number of sources 
(including the Green River) for synfuels development was analyzed in 
the White River Dam EIS (BLM 1982b). A decision was made upon 
completion of that document to issue the State of Utah a right-of-way 
for construction of the dam. At this time, it appears to be a viable 
project, and BLM has no reason to believe it will not be built. 
Based on this information, BLM's preferred alternatives are to obtain 
water from this reservoir. 

5.4 The additional power requirements and the demand for water have been 
analyzed in the Moon Lake Power Plant Project EIS (BLM 1982c). 

5.5 The proposed location of the disposal site is on private land owned 
by Paraho. Current federal law does not allow disposal of spent 
shale on federal land, outside of federal oil shale lease areas. 
This restricts project sponsors, like Paraho, whose private land is 
surrounded by federal land, limiting the options for disposal sites. 

5.6 The water system changes predicted to occur due to the proposed 
synfuels development are presented in Section R-4.A.3. As is 
evident, both flow and salinity would change at several points. 
These results came from inputs based upon current water useage and 
projected future useage. The results reflect the plans of the 
various applicants. 




October 14, 1382 


TELEPHONE (801) 326-3700 

Mr. Lloyd Ferguson, District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, UT 84078 

Dear Mr. Ferguson: 

Sohio Shale Oil Company would like to thank you Jar this 
opportunity to comment on the Draft Environmental Impact Statement 
which the BLM wrote for the Uintah Basin Synfuels Development. In 
general, the Draft EIS is well-written and thorough in its cover- 
age of the pertinent issues. 

We do, however, offer the following comments and technical 
corrections which we feel would make this EIS more accurate and 
more complete: 

Air Quality : 



An error was found in the publication, "Air Quality 
Impact Analysis or Synthetic Fuel Development in the 
Uinta Basin," (Table 4-1, P. 4-9). Sulfur dioxide 
emissions from Sohio' s project are listed as being 373 
kg/hr. We believe that the maximum SO2 emission rate 
from this project would be 55 kg/hr and the average 
emission rate would be 31 kg/hr. On P. R-4-26 of the 
UBS DEIS, the following statement is made: " — The 
sulfur dioxide concentration increases to dinosaur 
and Colorado National Monuments would be largely from 
the conceptual projects (Sohio and Geokinetics respec- 
tively)..." If we are correct, the SO2 impact on 
these two areas from the Sohio project will probably 
be shown to be insignificant. 

P. R-4-32 Total suspended particulates (TSP): In this 
section, it is stated that the Sohio project will ex- 
ceed the Class II increment for TSP a distance away 
from the plant site. It is speculated that both the 
Dinosaur National Monument and Uinta and Ouray Indian 
Reservation may be affected. Since the majority of 
the TSP emissions from the Sohio project are fugitive 
(95%), it is unlikely that the TSP impact on these two 
locations will be significant. Only the TSP emissions 
from process operations (34.2 kg/hr) should be used to 
calculate the impacts on distant locations. Most of 
the fugitive emissions will settle within the plant 
site boundaries. 







P. R-4-61 Surface Mining Disturbances: In this 
section, the Sohio project is labeled as a "tar sand 
strip mine." Strip-mine techniques will not be used 
on the Sohio project. The phrase should be changed 
to either "tar sand surface mining operations" or 
"tar sand open pit mining operations." 

P. R-4-75 Livestock Grazing: The third paragraph 
in this section states that impacts could be signifi- 
cant to two individual operators who use the allot- 
ments on state lands where open pit mines and plant 
sites proposed by Sohio and Geokinetics would be 
located. Later in the paragraph, it is stated that 
the overall impact is insignificant. Since this is 
the case, it should be stated first that there will 
be no significant impact. 

p. r-4-90 Table R-4-27: The last item in this table, 

"Oil From Tar Sand Strip Mines," should be changed to 

either "Oil From Tar Sands Open Pit Mines" or "Oil 
Prom Tar Sand Surface Mines." 

Socio-economic : 

o The Uintah School District has spent more than it has 
received in revenues in the last two years. Since they 
do not have any debt, did they finance this deficit 
from a previous surplus? If so, what is the status of 
their surplus account presently? 

o The socio-economic benefits of the project are not 

Tosco Shale Oil Product Pipeline : 

o An eventual localized oil "glut" could develop if all 
projected shale oil plants in Utah came on line. 
Reversal of Chevron's pipeline to move excess volume 
to Rangely would only be able to accommodate a fraction 
of this excess. Therefore, your study should investi- 
gate the impacts of a pipeline leading east. Because 
of the limited product demand and the limited refinery 
capacity in Salt Lake City, this would be a more long 
term solution. 



Appendix R-A (Maps) : 

o On Map R-A-3, in Section 32 of Range 22 East, Township 
5 South, you have incorrectly identified land being 
owned by the federal government when in fact Sohio 
Shale Oil Company owns feel title to this land. 



6.10 o Is the hunting income of $3.7 million per year used in 
that study realistic? 

e .,.. I o Fiscal pressures on communities are anticipated by the 
study yet the cities seldom receive a growth rate of 
more than 10 percent per year. Are these fiscal pres- 
sures inherent in the present structure or are they 
actually caused by this anticipated growth? 

Again, we appreciate the opportunity to make these comments. 
If you have any questions concerning these comments, please do not 
hesitate to contact me. 


Robert L. Dudiak, Manager 
Program Services and 
Community Development 

Sohio Shale 011 Company 

6.1 Emission data for the Sohio project were developed from the most 
recent information available when the study began--a letter dated 
December 28, 1981, from Mr. R.L. Dudiak, Sohio, to Mr. J.D. Edwards, 
BLH. The major emission point contributing to the maximum SC7 
emission rate for the 20,000 barrel/day facility was the steam 
generator reported at 361 kg/hr (796 Ib/hr, excluding SO? 
emissions). BLH recognizes Industry plans are evolving and that the 
emission data for several of the projects are continually changing. 
It Is uncertain from the eminent whether the 31 to 55 kg/hr values 
represent a proposed revision to the figures given originally. 
Section R-4.A.2 has been expanded to recognize the later emission 

6.2 The fugitive particulate matter emissions from the Sohio project are 
primarily from ground level sources including truck hauling, storage 
piles, and other operations affected by wind erosion. For the high- 
level scenario, total particulate matter emissions consist of truck 
hauling on roads (81 percent), storage piles (14 percent), and steam 
generation (5 percent). 

The effect of particulate gravitational settling on ambient 
concentrations can be evaluated if the particle size distribution 1s 
known. However, very little is known about the specific size 
distributions of particles emitted from the proposed synfuel 

Since gravitational velocities are proportional to the square of the 
particle diameter (Stokes Law), large particles can settle out rather 

To evaluate the effect of gravitational settling, the fraction of 
particles remaining airborne from a ground-level release were 
calculated. This fraction can be calculated as follows: 

J I 



This fraction Mas evaluated for three particle sizes — 6, 10, and 20 
urn, having gravitational settling velocities of 0.19, 0.75, and 4.8 
cm/s, for a 2.5 m/s wind and neutral (Pasquill 0) stability. The 
results are shown in Table C-2. 


Table C-2 


Fraction of Particles Remaining Airborne 
6 um 10 urn 20 urn 























Source: Systems Applications Inc. 1983. 

Thus, if the synfuel TSP emission inventory is primarily particles less 
than 10 um, the model calculations, assuming no gravitational settling, 
are not particularly conservative. If, however, a significant fraction 
of the emission inventory is greater than 20 um, one would expect the 
model calculations to be quite conservative. 


Section R-4.A.4 has been revised. 

6.4 This paragraph in Section R-4.A.5 has been rewritten to clarify the 
intended meaning. 

6.5 Table R-4-27 in Section R-4.A.13 has been revised. 

6.6 Uintah School District officials indicated that deficits for 1979 and 
1980 (Socioeconomics Technical Report, Table R2B-24) were financed 
from a previous surplus. Their surplus account had a balance of 
$1,029,646 at the end of 1981. 

6.7 The primary benefits of the proposed synthetic fuel projects within 
the Uintah Basin EIS communities are in the area of increased job 
opportunities, increased personal income, and increased revenues from 
taxes. Section R-4.A.1 and Table R-2-1 cite the increase in job 
opportunities and increased per capita personal income as a result of 
the proposed projects. An analysis of revenues and expenditures is 
considered by the BLM to be in the realm of mitigation planning and, 
thus, the purview of state and local government. 

6.8 The potential for an oil glut is speculative. Present trends 
indicate that production of crude oil within the Uintah Basin will 
begin to decline around 1985, about the time production of shale oil 
would begin. However, the EIS analyzes product pipelines to carry 
oil east and west. New pipelines to the east are preferred by Magic 
Circle, Syntana-Utah, and Tosco. New pipelines to the west are 
proposed by Magic Circle (as a second preferred route) and Tosco (as 
an alternative). Only two applicants, Magic Circle and Paraho, 
propose to tie into the Chevron pipeline, and for Magic Circle, this 
is only one of three paths the shale oil could follow. 

Refinery capacities, market locations, additional product pipelines 
and other future marketing-related needs are briefly noted in the 
technical report on the Tosco Salt Lake City Alternative Pipeline 
(BLM and FS 1982). The impacts of these or other similar facilities 
would be analyzed in detail and documented when and if they are 

6.9 Review of the BLM land records in the Utah State office indicate that 
the E 1/2 and the NW 1/4, Section 32, Township 5 South, Range 22 
East, was passed from federal ownership to a state grant in 1896. 
These same sections were again verified on April 12, 1962, as being 
State of Utah lands. As the BLM does not track subsequent title 
changes, after the original patent, Sohio could now hold fee title to 
this land without our land status reflecting it, which is why it 
would still show as State of Utah lands. The records show that the 
SW 1/4 is pending application for a state grant but has not left 
federal ownership yet. It would, therefore, still show as public 
land on the land status map. 

6.10 All hunting income data are based on figures furnished by the Utah 
Division of Wildlife Resources and are assumed to be correct. 


6.11 The fiscal pressures that accompany rapid growth ire the product of 
lag time between the demand for services generated by growth and the 
time that new facilities are constructed and begin to generate tax 
revenues. Although such pressures exist within the present 
community, any additional stress from more rapid growth will 
accentuate the problem. It is for this reason that the Uintah Basin 
communities are expected to receive fiscal stress. 






R. E. LEE 
(713) 63I-BB7B 

Syntana-Utah Project 

Quintana Minerals Corporation 



October 14, 199 2 

Mr. Lloyd Ferguson 
District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 84078 

Re: Comments on Draft Environmental Impact Statement 

on the Uintah Basin Synfuels Development; 1792-UBS 

Dear Mr. Ferguson: 

Syntana-Utah believes that the draft Environmental Impact 
Statement (EIS) on Uintah Basin Synfuels Development is an am- 
bitious undertaking that generally complies with the requirements 
of the National Environmental Policy Act. We believe further, how- 
ever, that the tone of the draft EIS, especially as regards the 
socioeconomic impacts associated with the proposed development, 
is unduly negative. Substantial benefits that will result are in 
some instances either ignored or subjectively devalued. To object- 
ively describe the impacts associated with the proposed development, 
the EIS should recognize the significant benefits that will result. 

In particular, the proposed synfuels development will lead 
to increased jobs, taxes, and disposable income. The infusion of 
these funds should result in a net benefit to all aspects of the 
local economy and should improve the standard of living of those 
currently residing in the affected area. Moreover, the quality 
of life of those people who move into the area as a result of the 
proposed projects will be improved in many respects because those 
people will find new or improved employment. We do not believe 
this increase in the standard of living should be considered an 
adverse impact as the draft EIS tends to imply. 

Furthermore, the proposed development also will have signifi- 
cant positive effects on the nation as a whole. Not only will there 
be energy produced from these plants that can be used by the nation 
at a time when there are substantial imports from unreliable foreign 
sources, but also the basis of a whole new industry will be established. 
These projects will commercialize the synthetic fuel business, providing 
a domestic technological capability in a new, commercially viable 
synf uel industry . 





Mr. Lloyd Ferguson 

In addition to these general comments, Syntana-Utah submits 
the following comments on particular sections of the draft EIS. 

Draft Technical Report, Pages 1-55 through 1-82 

There is no introduction to the fiscal section and the purpose 
of the information presented is unclear. In addition, "mill levy" 
is not defined and there is no information on what assessment ratio 
is used for valuino property. The mill levy reported on pages 59 
and 60 is 16.63. However, the mill levy in table R2B-23 on page 
75 is 16.36. The values reported in the text for taxes collected 
are not supported by the table, and there is no way to multiply 
the assessed valuation by the mill levy to reach the reported taxes 

Page R-3-1 {Regional Affected Environment) 

The introduction to Chapter R-3 discusses some of the effects 
of oil shale development. One effect not discussed is the possible 
decrease in oil and gas production. 


Population & Employment 

Page R-3-2 - The 10% threshold population figure is based 
on studies indicating that an annual population increase of 10% 
or greater stresses communities 1 ability to meet the needs of that 
population. The population numbers in this DEIS area based on peak 
construction and operation years for the projects and are cumulative 
rather than annual population increases. While the cumulative 
increase in population for the duration of the project may be greater 
than 10%, the annual increase may not exceed the threshold level. 
Appropriate planning, however, could mitigate any potential negative 
impacts . 

Page R-3-6 - The draft EIS indicates there is a 52% unemploy- 
ment rate for reservation Indians due to the lack of economic oppor- 
tunities. This figure of 52% is misleading. In fact, the available 
data indicates that only 86 Utes out of 1860 are actively seeking 
employment — a real figure of less than 5%. In any event, the 
employment opportunities that would result from the proposed projects 
could have substantial positive impacts on Indian unemployment. 









Mr. Lloyd Ferguson 

Page R-4-14, R-4-21 -- Increased employment in the area could 
have positive impacts on the reservation Indians. Tribal finances 
could improve and increased wages and employment opportunities would 
be available for those with the needed job skills for the various 
projects. Although not all reservation Indians may now have the 
necessary skills to qualify for the anticipated opportunities, train- 
ing could be provided for them to be qualified by the time jobs 
are available. 


Pages R-4-15, R-4-17, S-5-2 - The increase in population would 
bring about an increased need for housing. This increased need, 
however, should beneficially affect the housing construction industry 
resulting in a corresponding increase in employment. 

Government Services 

Pages R-3-13, R-4-20 - The positive impacts from increased 
taxes generated by the projects should be discussed. The antici- 
pated problems of timing in meeting population growth demands (i.e., 
housing, schools, etc.) could be resolved with the prepayment of 

Quality of Life 

Pages R-4-23 f S-5-3 - The classification of potential impacts 
on the quality of life as negative is highly subjective. The quality 
of life may well be improved through diversity in population and 
also through the increased money supply. The population diversity 
will offer increased learning opportunities. The problems of housing, 
education, etc. will be mitigated by the increase in revenues. This 
section arbitrarily concludes that change necessarily is bad. 

Safety and Health 

Page R-4-106 (Table on Occupational Hazards Associated with 
Oil Shale Development) - This table attempts to summarize occupa- 
tional hazards associated with oil shale development. We believe 
that the medium level of risk values assigned to the refining category 
are incorrect. Refining is one of the lowest hazard areas in all 
manufacturing, and all the classifications should be low. In addition, 
there is no basis for believing that retorting would be worse than 
refining. Finally, the EIS should take into account proposed controls 
by the Occupational Safety and Health Administration (OSHA) that 
further control the risks and hazards that may exist. 







Mr. Lloyd Ferguson - 4 


Table R-2-1 (page R-2-3) - The land required for the proposed 
projects presently is not used by recreationalists. It therefore 
is not clear how the listed recreational acreage would be affected. 

Pages R-4-81, R-4-83, R-4-85 - Increased use of recreational 
facilities will lead to increased expenditures and thus an increase 
in taxes. There will be increases in hunting and fishing licenses 
and this could, for instance, help fund the fish hatchery. There 
could also be an increase in the number of facilities (camping and 
other forms of recreation) . Assuming that two hours is the maximum 
people will drive for recreation, it would be useful to know the 
distances from the population centers to the recreation area. The 
Flat Tops Wilderness Area, for example, is more than two hours away 
from Vernal (see also Table R-3-15) . 

Table R-3-15 (page R-3-47, 48) - The table does not show the 
distances from the population centers to the recreation areas. It 
would be useful to know how many people visit the areas annually. 

Page R-3-49 - The visitor use data should be put into pers- 
pective. The information presented here should somehow be separated 
into use levels, i.e., very low use (as in paragraph one), low to 
moderate, etc. 

Page R-4-9 - In discussing the impacts to recreation and using 
the term "public" it would be useful to know how many people con- 
stitute the "public." It is implied that a sample was taken to 
determine the impacts to recreation and it would be desirable to 
know the number of respondents polled. 


Pages R-4-22, R-4-67 - Increased expenditures in the area 
should make possible increased wildlife. There would be money 
generated from license fees which could be used for restocking, 
increased management, better law enforcement, etc. 

Air Quality 

Page R-3-22 - There is no indication of the distances from 
the proposed projects to the listed Class I areas. It would be 
useful to know the location of the park and wilderness areas and 
the prevailing wind direction to determine possible air quality 
impacts by the proposed projects. 








Mr. Lloyd Ferguson 

Page R-4-33 (Combined Applicants' Impacts) - The information 
presented that Vernal and the Indian Reservation would be signifi- 
cantly impacted by air emissions from the Syntana-Utah Project is 
not supported by the data presented on page R-G-2. Wind directions 
shown on the figures indicate that neither Vernal nor the Indian 
Reservation would be significantly affected since both occur up- 

Page R-4-40 and Page R-4-41 (Acid Deposition) - The presenta- 
tion on acid deposition is irrelevant. Four separate statements 
are made that the data is "inconclusive", and that "very little 
is known" about the chemistry and transport of the sources. A 
report pertinent to these statements was prepared by Mr. Alan W. 
Katqenstein for the Edison Electric Institute which appeared in 
"Green Lands" titled "An Updated Perspective on Acid Rain." 

The table on page R-5-5 tries to summarize overall 
benefits and trade-offs in a number of areas with regard to these 

Page R-5-5 

projects. Ke believe that many of these determinations are misleading 
or incorrect. 

Contrary to the table, road quality should improve because 
of the additional tax base that will support improved road develop- 
ment and because improved roads will be needed due to their greater 
use and the increase in population. Cultural resources should be 
improved rather than decreased since few now exist and a wider 
variety will be present upon completion of the projects. Agriculture 
quality and quantity should increase rather than decrease because 
of the increased irrigation potential that results from the improved 
infrastructure. Paleontological resources also should improve because 
of improved access in the area. 

Outdoor recreation will be improved in that there will be 
more parks and better access. Therefore, more people will be able 
to take advantage of the resources. The analysis in the draft EIS 
raises the broader philosophical question of the value assigned 
to increased public use. In our view, the improved ability of the 
public to use a resource improves the resource and is a positive 
benefit. Unfortunately, the EIS seems to assume that, in most 
instances, increased accessibility to the general public is a 
detriment rather than a benefit and that "the quality of recreation 
experiences" of the few is superior to increased numbers of positive 
experiences for the many. The EIS should at least acknowledge that 
the value judgment assigned to increased public use is open to 
different interpretations. 

Page SS-1 (Site Specific Analysis Introduction) 

The statement of need for these projects should be expanded 
to reflect the important national interest in their completion. 






Mr. Lloyd Ferguson - 6 - 

As Congress declared in the Energy Security Act, Public Law 96- 
294, Section 100, the achievement of energy security for the United 
States is essential to the health of the national economy, the well- 
being of the citizens, and the maintenance of national security. 
The Act itself was passed ". . .to utilize to the fullest extent 
the constitutional powers of the Congress to improve the Nation's 
balance of payments , reduce the threat of economic destruction from 
oil supply interruptions and increase the Nation's security by re- 
ducing its dependence on imported oil." 42 U.S.C. § 8701(b) (1). 

Congress found that these purposes can be served, among other 
things, by: (1) demonstrating at the earliest feasible time the 
practicality of commercial production of synthetic fuels from 
domestic resources employing the widest diversity of feasible 
technologies; (2) fostering the creation of commercial synthetic 
fuel production facilities of diverse types with the aggregate 
capability to produce from domestic resources in an environmentally 
acceptable manner the equivalent of at least 500,000 barrels of 
crude oil per day by 1987 and at least 2 million barrels of crude 
oil per day by 1992; (3) encouraging private capital investment 
and activities in the development of domestic sources of synthetic 
fuel and fostering competition in the development of the nation's 
synthetic fuel resources; and, (4) fostering greater energy security 
in reducing the nation's economic vulnerability to disruptions in 
imported energy supplies. The plants that are the subject of this 
EIS in the development of the synfuels industry and the Uintah Basin 
are precisely suited to meeting these Congressionally-mandated goals. 

Page S-3-1 - The introduction to the chapter says that only 
resources which are significantly affected are discussed. The 
Syntana-Utah section does not consider paleontology in the area 
to be significantly affected. However, information presented on 
pages R-3-57 and R-4-89 disagree with this and says that all proposed 
projects would be in contact with one or both of two main fossil 
formations and that there would be unquantif iable losses to these 

Pa ge S-3-1 (Socioeconomics) - This section implies the Syntana- 
Utah Project is close to the Uintah and Ouray Indian Reservations. 
In fact, the project is over 16 air miles and over 30 road miles 
from the reservation. 

Page S-3-3 (Wildlife) - The section pertaining to bald eagles 
is unsupportive. Our investigations have uncovered no winter roost 
trees on or near the Syntana-Utah site. 

Cumulative Impacts (Chapter S-5) Conclusions in this section seem 

to be inconsistent and fail to include the positive impact that 

the proposed facility will have on the surrounding area. Population 






Mr. Lloyd Ferguson 

7 - 

and employment as well as the demand for goods and services clearly 
will increase should the project go forward. However, the increase 
in tax revenue generated by the project would largely mitigate any 
negative impacts. 


Page R-L-l and R-L-2 (Energy Analysis) - The Energy Analysis 
on Page R-l-1 and R-12 discusses the increased energy consumption 
by the addition.- 1 population of the area. The draft EIS fails to 
note that this increased population consists of people who are 
using energy some place else prior to coming to the project. That 
energy consumption is simply being transferred, not created. There 
may be some increase in energy use by these individuals because 
of the increase in their standard of living. However, we do not 
view this as necessarily being an adverse impact. Finally, the 
whole purpose of this project is to produce more usable energy. 
Therefore, the energy consumption is but a small investment in a 
much greater energy production. 

We appreciate the opportunity to make these comments and 

commend the BLM for its substantial efforts in preparing the draft 

EIS. We hope the BLM will consider our comments in the preparation 
of the final EIS. 

Very truly yours , 



Robert E. Lee Jr 


Syntana-Utah Project 

7.1 Increases in job opportunities, personal income and tax revenues are 
beneficial aspects of the proposed synfuel projects in the Uintah 
Basin. Section R-4.A.1 and Table R-2-1 show the increase 1n 
employment opportunities and Increase in per capita personal Income 
as a result of the proposed projects. Local g ove r wan ts would be 
called upon to provide additional service and facilities to meet the 
needs of additional people in the area. Ctreftri planning trauM be 
regulred to ensure that funding Is available to provide the 
additional infrastructure needs to coincide with the development . 
Communities could be better off or worse off depending on how well 
the new growth is accommodated through the planning and mitigation 

People who are directly employed by the synfuels companies or benefit 
through increased business activity may be better off. Others in the 
community (i.e., those on fixed incomes and those in non-energy 
sectors such as agriculture) may be worse off. In summary, there are 
beneficial and adverse effects of synfuels development on communities 
and individual residents. Whether the standard of living of 
residents in the affected communities is improved depends on how they 
share in the benefits (jobs, income, service) and costs (taxes, 
change in life styles, etc.). Also see the response to Comment 6.7. 

7.2 The proposed developments have the potential for increasing the 
nation's energy independence. When any of the projects become a 
reality, they will form the initial basis for establishing a 
commercial synthetic fuel industry. These points are made in the 
Need for Project section of the Site-Specific Analyses Introduction. 

7.3 The mill levy figures shown on 1-59 and 1-60 are incorrect and should 
be 16.36 as shown in Table R28-23. Multiplying the assessed 
valuation by the mill levy in several of the tables yielded property 
tax amounts close to but not the exact amounts shown in the tables. 
To rectify these minor differences would require checking the source 
in the State Auditors Office or checking with the respective counties 
but would not subsequently change the fiscal profile for an 
individual governmental entity. The mill levy is the amount (one 
mill equals one-tenth of a cent) imposed by a legal taxing authority 
against the assessed valuation of taxable property within the 
geographic bounds of the taxing unit to obtain revenues needed to 
provide the designated services. The assessed valuation data were 
obtained for the major governmental units, but no attempts were made 
to obtain or determine the assessment ratios used in valuation of the 
real property. The assessment ratios used for valuing property can 
be obtained from the county assessors. 

7.4 The Chapter R-3 introduction states the EIS assumption that oil and 
gas development will continue at a similar rate of growth antil 
approximately 1985 and then will have a slower or diminished rate of 
growth (State of Utah 1983). (The decreased oil and gas production 
would not result from the synfuels development.) This projected oil 
and gas impact is included in the baseline. 




7.5 The cumulative increases in population (Table R-4-12) over the 
respective baseline populations in 1985 and 1995 are greater than 10 
percent, although the annual increase for some entities does not 
exceed the threshold level. Appropriate planning would be needed to 
mitigate potential negative impacts associated with rapid population 

7.6 The 52 percent figure is for those "not employed, able to work." The 
5 percent figure is correct if Job Service methods are employed. If 
Indian preference hiring is used, then the employment opportunities 
would reduce unemployment. 

7.7 Increased employment in the area could have positive impacts on 
tribal employment. However, since fewer than 10 members of the tribe 
are employed in the oil and gas industry, it is not likely that 
synfuels development would appreciably improve the tribe employment 
picture. Training programs would improve chances for employment. 
This is identified in Appendix A-7 as a recommended, but as yet 
uncommitted, mitigation measure. 

7.8 Increased housing demand would have a beneficial effect on the 
housing construction industry with a corresponding increase in 
employment. This point has been clarified in Section R-4.A.1 and 
each of the site-specific sections 5.A.I. 

7.9 The fiscal pressures that accompany rapid growth are the product of 
lag time between the demand for services generated by growth and the 
time that new facilities are assessed and begin to generate 
revenues. Although such pressures exist within the present 
structure, any additional stress from more rapid growth would 
accentuate the problem. It is for this reason that the Uintah Basin 
communities are expected to receive fiscal stress. Prepayment of 
taxes is one approach that has been utilized in other rapid growth 
areas for offsetting anticipated problems of timing in meeting 
population growth demands. 

7.10 Economic development and industrialization activities result in 
communities receiving benefits such as increased employment and 
income opportunities. These changes are widely seen as positive and 
are forecast in the various Chapter 4 Socioeconomics sections in the 

Simultaneously, however, population growth of the scale expected with 
a single project or several projects in the Uintah Basin can result 
in local social changes and disruptions of the sort discussed in the 
Quality of Life sections. Such changes are not universally seen as 
benefits. These changes are discussed to provide the reader with a 
more complete review of the entire array of consequences. 

7.11 Table R-4-30 is based on a similar table included in An Assess ment 
of Oil Shale Technologies (Office of Technology Assessment ISSO ) . 
This is the most complete, up-to-date source of information BLM is 
aware of. OSHA requirements and MSHA requirements would further 
control and reduce risks. See Appendix A-7 for details on this 

7.12 The land affected by the proposed projects is used primarily for 
dispersed recreation opportunities such as off-road vehicle use, 
rockhounding, dispersed camping, sightseeing, and hunting (primarily 
for small game animals, although some deer and antelope hunting is 
also known to occur). Along the river bottoms of the White and Green 
rivers, river running (rafting, canoeing, f loatboating), fishing, and 
hunting are the predominant recreational opportunities. (Refer to 
Section R-3.A.8 for additional details.) 

7.13 Although there would be increased use of recreational facilities and 
licenses with increased expenditures and thus an increase in the tax 
base, there is no guarantee that these new funds would be used in the 
affected counties. For example, the Utah Division of Wildlife 
Resources is not obligated to spend funds in Uintah County for a new 
fish hatchery. These new funds could be used in a Utah county not 
affected by oil shale and tar sand development. 

The intent of Table R-3-15 is to depict those major recreational 
attractions within the secondary zone of influence. All of the areas 
listed are within a two-hour driving distance from either Vernal, 
Roosevelt, Westwater, Utah, or Rangely, Colorado. The Flat Tops 
Wilderness Area is within a two-hour driving distance from 

According to the Council on Environmental Quality regulations for 
preparing EISs (Section 1500.4(b)), EISs are to be analytic rather 
than encyclopedic. Including the distance from each of the 
population centers and visitation statistics for each recreation area 
identified in Table R-3-15 would not significantly add any major 
analytical conclusions or enhance understanding of impacts. 

7.14 It is difficult to place value on the magnitude of existing 
recreation resource use within the secondary zone of influence and 
compare this against potential future use assuming proposed synfuels 
development. The region is known to have nationally significant 
recreational value (Dinosaur National Monument, High Uintas Primitive 
Area, water-oriented opportunities on several lakes and streams in 
the region). However, the predominant recreation use is for 
dispersed recreation. To compare the amount of recreation use 
occurring on BLM public lands to another regional area becomes a 
relative question. For example, if one were to compare the amount of 
recreation use occurring within the Uintah Basin secondary zone of 
influence on BLM public lands with the California Desert (15.4 
million visitor use days) then visitation in the Uintah Basin would 
be considered very low. However, when comparing other regions of the 
nation having fewer visitations than the Uintah Basin secondary zone 
of influence, visitation in the Uintah Basin region could be 
considered high. 

7.15 The term "public" is used in a generic sense, referring to local, 
state, regional, or national population, depending on the issue. For 
example, impacts to a river with potential Wild and Scenic River 
status are not only of local concern, but also have state, regional, 
and national implications. Increased demand on municipal recreation 
facilities is a local and state "public" concern. 


Surveys were not taken to determine significance of recreation 
impacts. The determinations were made based on scoping and other 
public contacts and professional expertise. 

7.16 The expenditures generated by increased population are not all 
license fees. The bulk of the expenditures are monies to local 
retailers that do not return to the Division of Wildlife Resources. 
In spite of increased license revenues, more people generally means 
less habitat (refer to Section R-4.A.6) and a resulting lowered 
overall wildlife population base. No studies to our knowledge 
support the commenter's statement. Also see the response to Comment 

7.17 Distances and directions of the Class I areas from the proposed 
developments have been added to Section R-3.A.3. 

7.18 The information presented on Draft EIS page R-4-33 was not intended 
to imply Syntana-Utah would significantly affect Vernal and the 
Indian reservation but rather that the impact, considering all seven 
applicants' proposed projects, would be significant. Although BLM 
agrees that winds do not often blow toward the reservation from the 
Syntana-Utah site (easterly winds), winds from the Syntana-Utah site 
toward Vernal commonly occur (southeasterly winds). 

7.19 Many uncertainties related to acid deposition and its potential short- 
term and long-term effects in the environment still remain. These 
uncertainties include knowledge related to wet and dry acid formation 
and deposition, and environmental effects related to any specific 
acid deposition rate. This is particularly true in the West, where 
ecological components are, in many cases, significantly different 
than those of the East and Northeast, where much of the effects work 
has been done thus far. These uncertainties, however, do not argue 
for ignoring the problem as a potential impact in the West and, more 
specifically, what may or may not be the impact from acid deposition 
resulting from synfuel development in the Uintah Basin. The purpose 
of the discussion in the EIS is to make the public aware of the 
uncertainties and recognize the analysis as a conservative first 
approximation because of the uncertainties. The final answer as it 

• applies to synfuel development in the Uintah Basin, if it occurs, 
will be ground truth resulting from monitoring and study as 
development takes place. 

7.20 Table R-5-1 has been revised based on the information provided by 
this commenter and others. Those mitigations committed to have been 
assumed in the analysis. However, where mitigation has not been 
committed to, the analysis has been affected, even to the use of 
worst-case analysis in some instances. For example, while the 
additional tax base could support road development or parks 
construction, there has been no commitment that roads or parks would 
be improved. 

Outdoor recreation has been modified to better indicate the benefits 
and trade-offs. 

As used in this document and, therefore, this table, cultural 
resources means archaeological and historical resources. Cultural 
amenities for fine arts and humanities are considered to be a 
component of socioeconomics and are considered in the analysis of 
quality of life and service infrastructure. 

7.21 The section on project need has been revised. 

7.22 Although development of the Syntana-Utah project would result in an 
unquantif iable fossil loss, this loss is not predicted to be 
significant. This conclusion was reached based on studies done in 
the area by Utah Division of State History (Madsen 1981; Madsen and 
Nelson 1980). 

7.23 Section S-3.A.1 was not intended to imply that the Syntana-Utah 
project area is "close" to the Uintah and Ouray Indian Reservation. 
However, the Syntana-Utah project would have socioeconomic effects 
beyond the actual project site which would also include the Uintah 
and Ouray Indian Reservation. Section S-4.A.1, Uintah and Ouray 
Indian. Reservation, states that primary and secondary effects could 
be felt by the Ute Tribe and references Section R-4.A.1 for 
discussion of those impacts. 

7.24 According to maps and data furnished by the Utah Division of Wildlife 
Resources (current as of 12-9-81), there are general bald eagle roost 
areas near the Syntana-Utah site. 

7.25 Refer to the response to Comment 6.7. 

7.26 The energy consumption by the additional population would be 
transferred, not created. However, local energy needs would increase 
as people relocate from other areas and, therefore, would cause local 
and regional impacts even though national needs remain the same. 

The energy analysis used is a standard method presented in the 
Energy Analy sis H andbook Fo r Preparatio n of Oil S hale Develop ment 
Environmental Im pact Statements (BLM l9~82a)". This method allows one 
to compare a project in Utah with one in Kentucky, for example, on 
equal terms; it is not necessarily an adverse impact. 



324 Judge Building 
8 F.ast Broadway- 
Salt Lake City, Utah., 84111 

David Becker, 
Director U. of U. 
Outdoor Program 


Peter Hovingh 
UttUi Nature 
Study Society 

Trout ■ 


Ken «1 








,ir*J County 
fater Supply, 

'tountain Council , 
Fed. of Fly 
c i shernen 

September 23, 1982 



Lloyd Ferguson, District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 81078 

Dear Mr. Ferguson: 

I would like to make comments at this hearing 
on Synfuels development in the Uinta Basin on behalf of Inter- 
mountain Water Alliance. My name is Dorothy Harvey and I am 
Coordinator of this organization which is dedicated to wise 
management of Utah's water resources in the broad public 
interest. Such management recognizes changes in society which 
includes uses of water to provide aquatic and terrestrial 
habitat for fish and wildlife as well as provides hydrological 
flows for river recreation - floating, canoeing, kayaking. 

This statement will be submitted in more 
detail to BLM before October 19. fnU cLJtvJi i* n^vo ivioL^jLn A^u..) 

Even though some of Utah's rivers have national 
recognition and enjoyment, Utah is one of the few remaining 
western States which has no instream flow legislation to allow 
water to remain in rivers for fish, wildlife and recreation uses. 
Utah has no designated Wild and Scenic Rivers. This oversight 
does disservice to certain Utah citizens and taxpayers who 
have a legitimate interest in Utah's rivers although these are 
not recognized as beneficial. 

The number of river recreationsts running rivers 
alone has increased dramatically since World War II. Both 
commercial and non-commercial uses make significant widespra*^ 
contributions to local, state and national economies. Let me 
quote some 1981 figures. 

For the Green River stretch which includes the Oreen through 
Dinosaur National Monument and portions of the Yampa there 
were some 10,000 commercial and non-commercial patrons and 
11 commercial operations supporting this. 

For Desolation Canyon, In the Oreen, there were 5,371 patrons; 
2911 private, and 2163 commercial, with 26 outfitters. 

For Westwater portion of the Colorado River, there were 
9,097 people; 5,751 private, and 3,712 commercial, with 20 
outfitters dependent for their livelihoods on use of this 

The National Park Service reports that 1,538 people, commercial 
and private , floated Dinosaur National Monument . 11 outfitters 
operate here . 

" * citizens irroup dedicated to "lee use of Utah water resources In the brosd public Interest with 
citizen Involvement In water nollcv decisions for environmentally Bnd -eononlesllv sound wanar.«eent. . " 


River runners in Canyonlands National Park in 1981 numbered 5,761 - 
both commercial and private, with 17 outfitters providing the opp- 
ortunities . 

file Park Service gives a figure of 13, 117 commercial and private 
river runners in the Stand Canyon with 22 outfitters. 

Considering monies spent by commercial patrons to be, 
conservatively, $200 for a five day river trip - the economics for 
such a run down Desolation Canyon amounts to nearly one half a 
million dollars. We have no figures to present at this time on the 
economics from the private sector for any of these river reaches. 
This would be dollars spent for food, gasolene and other services 
to and from rivers as well as for equipment . 

Of importance, also, in river recreation enjoyment 
is the presence of birds and mammals associated with floodplain and 
riparian vegetation sustained by the river. Ttiese western cold desert 
river ecosystems are unique. The flora and fauna provided through 
their functions, some now endangered, is of considerable significance 
to recreationists and scientists, alike. 

This information is detailed here In order to rein- 
force mandated responsibilities of land and resource management 
Agencies, such as the Bureau of Land Management. While western water 
law requires use of a State's water for beneficial purposes, there Is 
in fact considerable leeway in the actual policies and practices by 
which this water is used. and managed. We are finding that Utah's 
practice of developing all surface waters first (storage from rivers 
by dams and reservoirs) is not necessarily the needed or only solution 
fcr industrial water supply. We know that Utah neglects conjunctive 
water management; utilizing available ground water sources where the 
quality of the ground water will suffice for some Industrial processes, 
is neglected in State planning. We know that conservation of water 
to reduce uses of water - recycling, pricing incentives, adoption of 
water saving fixtures in homes and businesses - is an unexplored field 
in the State. We know that available water Is already stored in 
Colorado River Storage Projects on the River. Large quantities 
remain unsold in both Flaming aorge and In Lake Powell - even though 
a Justification for construction of thes* storage facilities was one 
of meeting Upper Basin states needs for Water. Why is this water still 

This statement is an introduction to Information we 
are submitting on the issue of the proposed White River Dam to supply 
water for oil shale development. The White River Dam issue exemplifies 
the points we wish to make for consideration in the BLM Draft EIS on 
Synfuel Development . 

1. Information presented at the Conference on Water and Energy . 

Technical and Policy Issues . Pittsburgh, Pennsylvania, May 21-26, 
1982 and at Fort Collins, Colorado, June 28-30, 1982, demonstrates 
that more information on aquifer sources in the Upper Colorado 
River Basin is needed but that both industry and States hare the 
technologies to manage ground and surface water sources conjunct- 
ively In ways which can preserve instream flows for fish, wild- 
life and recreation and serve industry at the same time. 







The Issue of water supply in this region is really not one of 
shortage of water; it is unwillingness of State water managers 
to coordinate all criteria for water supply - biological as well 
as beneficial uses - with and among all interested entitles. 

2. The White River Dam Pinal EIS did not address all available water 
supply alternatives. It therefore did not supply the public all 
information needed to conclude that water stored by a dam on the 
White River Is not necessary and that destruction of the White 
River ecosystem Is unnecessary. 

3 . The BLH has a mandated responsibility to manage for preservation 
of riparian and aquatic (and migratory) habitat associated with 
rivers flowing through Its lands under PLPMA without regard for 
the politics of water management . The BLM also has mandated 
responsibilities for management of recreation on lands under Its 
Jurisdlbtlon. In the case of the White River and the proposed 
dam, the BLM was negligent and remiss in carrying out Its mandated 
responsibilities. In bowing to perceived constraints on Its manage- 
ment options, the BLM supported perpetuation of existing State 
water management policies and practices - even though these are 

ill advised and unnecessary. Neither State or Federal entities 
are bound to support subsidization of water supply for Industry. 

Since the BLM Draft EIS on Synfuel Development 

continues to support the need for a dam on the White River to support 

an oil shale Industry, we are submitting the following information 
as our comment. 

1 . The statement of the Environmental Defense Fund on the availability 
of water for oil shale development without a dam to the Corps of 
Engineers on the issue of granting a 401 dredge and fill permit. 

2. A letter to Governor Matheson, signed by nearly 50 organisations 
and individuals, asking his reconsideration of the proposed dam 
in light of information presented by EDP and in light of actions 
and procedures perceived to have taken place by the public in the 
development of the proposed dam. 

Thank your for this opportunity to submit a 
statement for consideration in preparation of the Synfuel Development 


Dorothy Harvey w 


July 23, 1982 

Colonel Paul F. Kavanaugh 

District Engineer 

Department of the Army 

Sacramento District, Corps of Engineers 

650 Capitol Mall 

Sacramento, CA 95B14 

Re: Comments in Response to Public Notice No. 7845: 
Utah Board of Water Resources-White River Dam 

Dear Colonel Kavanaugh, 

The Environmental Defense Fund (EDF) has reviewed the public 
notice and the environmental impact statement for the placement 
of fill material in the White River and its adjacent wetlands in 
order to construct the proposed White River Dam Project. EDF's 
review shows that 1) the record establishes no need for the water 
•in the Uintah Basin, 2) that other water supply alternatives are 
both reasonably available and less environmentally destructive, 
and 3) reasonable alternatives were not addressed by the EIS. 
Therefore, on the record made to date, it would be arbi trary)capri- 
cious and an abuse of discretion for the Corps to issue a permit 
for the White River Dam Project. EDF respectfully requests that 
the permit be denied. 

1. The Record Contains No Evidence Establishing A Need for Water 
in the Uintah Basin. 

The stated purpose on the proposed White River Dam is to pro- 
vide a -way of delivering some 75000 acre-feet annually to the hiiihly 
speculative oil shale industry. To date, while several companies 
nave indicated a general "expression of interest" in obtaining 
water for its proposed project, not a single company is close to 
constructing a commercial oil shale or tar sand facility. 

...... A brief review of the corporate proposals indicates that: the 

il ?,niX er Shalc Com P an y whic h has expressed an interest in obtain- 
ing 13000 to 26000 ac-ft. a year has placed its plans on the "back 
burner (Rocky Mountain News, July 11, 1902), the TOSCO Sand Wash 
unit is currently delayed as TOSCO searches for another partner 
(press release by TOSCO, May 7, 1982), the Magic Circle facility has 
indicated an intention to use groundwater even thouqh the las indi- 
cates there is insufficient groundwater available (Resubmittal to 
the Synthetic Fuels Corp. by Magic Circle, May 31, 1982, p. 5-30) 
the Paraho Development Corp. is attempting to bid for loan support 

UOi Arapsho, Avr„uf llm,t.k.. r ., MMUC! '£*(•«,>, ., ,.. Ma) 

OHKI.S IN. NKW VOKH. NY IN„l,„wJ llrivlquu.l.™!. mMMkilMt IT; UMIKKI.KY. Cft, IWNUIKa K* I..JUKK at 

Colonel Kuvanuu^li 
July 23, 1982 
Page 2 

from the Sythetic Fuels Corporation and their funding is uncertain 
(Rocky Mountain News, July 11, 1982),Sytana -Utah proposes a phased 
plan not to begin until 1986 (FEIS, p. 7), the Encccor-Mono plan for 
tar sands development calls for a demonstration module in order to 
determine success before commercial development (FEIS, p. 7) ,and 
finally, the Ute Indian Tribe has concluded that irrigation is not 
economically feasible (Ute Indian Irrigation Project, McKee and 
Morgan, 1978) . Such a limited record to demonstrate need for water 
storage is wholly inadequate for the Corps to conclude that there 
is an actual need for water resources at the rate of 70,000 to 
75,000 acre feet per year. 

The Utah Water Resources Board has adopted a policy requiring 
pre-purchase commitments from prospective users prior to commencing 
construction of the project. Dan Lawrence, Utah Director of Water 
Resources, recently reported to the Utah Board that the negotiation 
of pre-purchase commitments had been terminated because of questions 
of need for the project water. To date, Utah has obtained no firm 
commitments to purchase water from the project. 

Similarly, the FEIS prepared by the BLM fails to identify any 
commitments to purchase water from the project. Comment 56.2 notes 
this deficiency in the E1S record. The response identifies no com- 
mitment to purchase water from the project. 

Thus the EIS record, and as far an wo are aware, the record of 
this permit proceeding, contain nothing more than gross estimates 
of water uses associated with various projects, ami speculation that 
a) each project will go forward, and o) that water will be obtained 
from the White River dam rather than other sources. In addition to 
not being willing to make firm commitments to purchase project water, 
many of the projects for which water is said to be needed have not 
applied for or obtained necessary approvals or permits under other 
environmental laws. Neither have they obtained financing to com- 
mence the respective projects. 

Given the long-history of false-starts in the oil shale industry, 
the recent withdrawal of major project sponsors, the denial of Syn- 
fuel Corp. financing for some of the Utah applicants, current high 
interest rates and low world market prices for liquid fuels, and 
combined with the failure of the supposed users 'to make any 
firm commitments to purchase project water, there is no reasonable 
basis in the EIS record or the record'of this proceeding for the 
Corps to find a need for the proposed project. Accordingly, it 
would not be in the public interest and would be arbitrary and 
capricious for the Corps to issue a permit for the project at this 

II. The Record Establishes That Other Practicable Alternatives Will 
Have Less Adverse Impact on the Aquatic Ecosystem. 

The EPA guidelines governing the issuance of fill permits re- 
quire that 

,.n-j dis;?i:arg^ .iT cH(.hU|>kI c»r fill lintori '.1. 
it" there is a pract Lt:ul«l v uLU'i Lvi* to 

■:|nM l»- l 

Colonel Kavanaugh 
July 23, 1982 
Page 3 

discharge which would have less adverse impact on the 
aquatic ecosystem, so long as the alternative does not 
have other significant adverse environmental consequences. 

40 CFR S 230.10(a) . 

The EIS record clearly demonstrates that construction of the 
dam will have adverse impacts on endangered species by severely 
limiting remaining habitat. In addition, the dam will cause signi- 
ficant changes in water quality, stream bed stability, reverine 
habitat and result in the loss of wetlands both in the flood pool 
and along the river below the dam. The comparative listing o£ 
impacts in Table 2-1 of the EIS identifies no other alternative with 
equally severe impacts. 

In addition to the impacts of the dam documented in the EIS, 
EDF is filing for the record a recent study, "Impact Assessment 
of the White River Dan "(April, 1982), by Ecosystem Research Insti- 
tute which provides further documentation for the conclusion that 
the dam will likely result in eutrophication of the reservior and 
possibly cause heavy metal accumulations which will adversely 
affect downstream water quality. The "Impact Assessment" is marked 
Exihibit I. 

The EPA guidelines create a legal presumption that "practicable 
alternatives to the proposed discharge which do not involve a di re- 
charge into special aquatic site are presumed to have less adverse 
impact on the aquatic ecosystem, unless clearly demonstrated other- 
wise". 40 CFR § 230.10(a)(3). In this case, all the alternatives 
considered in the EIS except No. 3 do not involve either the dis- 
charge of fill into wetlands or the loss of wetlands. They must 
each therefore be presumed to have less adverse impact on the aquatic 

The only question, then, is whether the alternatives are prac- 
ticable. Both alternatives 2 and 5 are practicable, and 4 maybe 
depending on how one construes current water allocations. Alter- 
native No. 5 is not subject to the water rights questions that might 
threaten the practicability of No. 4 . Alternative No. 4 would entirely 
eliminate the anticipated adverse impacts on the Wlii te River , while 
drawing on water stored in a project which has already caused dam- 
age to the ecosystem of the Green River system. The EIS concludes 
that Alternatives 4&5 are capable of delivering sufficient water to 
meet the projected demand for 75,000 ac.ft./yr. The EIS also con- 
cludes that the incremental costs of this alternative compared to 
the dam "would cause a minimal increase in the costs of producing 
oil shale." Response 56.8. Alternatives 4&5 are also consistent" 
with current plans to pump 18,000 ac.ft. directly from the Green 
River to provide wate*" for the Moon Lake elect rie power plant near 
Bonanza. Thus, even if the Corps determines that the alleged de- 
mand for water is real and not speculative, Section 404 of the Act 
and regulations governing the issuance of fill permits prohibit 
the issuance of a permit in this case bocauso a le.-;r. harmful. 

Colonel Kavanauyh 
Jilly 23, 1982 
Page 4 

practicable alternative is available to meet the alleged needs on 
which the proposal is based. We note that EPA's final comment on 
the EIS supports our conclusion by recommending the selection of 
alternative No. 4 "as a more environmentally preferable solution 
to provide the necessary water for the emerging Uintah basin Syn- 
thetic Fuels industry." S. Durham to L. Ferguson, July 22, 1982 
(Exihit II) . 

In -addition to Alternatives 4&5 EPF believes there is ample 
evidence to support a finding that regional groundwater sources 
are available to supplement direct diversions from the White River, 
thus allowing a determination that alternative No. 2 is also prac- 

As the EIS indicates there is currently just over 500,000 acre- 
feet of water available during normal years from the White River. 
Also, somewhat unique for western rivers, the baseflow is higli com- 
pared to peak flow, and low flow occurances are not frequent due to 
the contribution from groundwater. The delivery of 70000 uc-ft.per 
year could be assured from direct flow from the W hi te River during 
many average years, and supplemented by pumping from regional aqui- 
fer and alluvial flow during the short periods uf low flow condi- 

It is k 
the primary 
field to obt 
1992 (under 
EDF has rece 
tiall'y great 
earlier. Th 
conclusion t 
volume to me 
matter, EDF 
data regardi 
date. These 
are at least 
River during 
to meet the 

nown that the White River Shale Company which could be 
user of this water, plans to install an alluvial well 
-in this reliable source for its facility use until 

ts most optimistic development schedule).* In addition, 
ived information from reliable sources that additional 
tests conducted by VTN on the Ua-Ub site show substan- 
er flows of groundwater on site than had been reported 
le EIS relies on the earlier VTN findings to support the 
hat groundwater might not be available in sufficient 
et projected needs. Prior to a final decision in this 
believes Corps has a duty to request any additional 
ng groundwater flows which have not been reported to 
data may well demonstrate that groundwater supplies 
adequate to supplement direct diversion from the White 
low flow periods, even though it may not be sufficient 
full demand of a fully developed industry. 

In further support of 
supplies. Magic Circle has 
Synfuels Corporation that 
by pumping from on-site aq 
in conjunction with the re 
vide the evidence to resol 
regarding the volume and q 
Creek aquifers. If local 
the costs of pumping from 
and the adverse impacts as 

the presence of adequate groundwater 
reported in its May 1982 submittal to the 
it believes it can meet its water needs 
uifers. These new data, when analyzed 
cent VTN results at Ua-Ub may well pro- 
ve some of the uncertainties in the Kir, 
lunlity of both the Bird's Nest and Douglas 
groundwater reserves are adequate, then 
the Green would be substantially reduced 
iociated with depletions from the Green 

Reported in the preliminary draft Uintah n.nsin KIS. 

Colonel Kavanaugh 
July 23, 1982 
Page 5 

under option 5 would be eliminated. As discussed below, tne ground- 
water alternative as well as other dam sites on the White were not 
adequately addressed in the EIS, and should be before the Corps makes 
a final decision. On the basis of 40 CFR § 230.12(a) (3) (iv) , we 
therefore request that you investigate further the question of whether 
adequate groundwater supplies are available, and in the interim either 
deny the permit or withhold action on the ground that there does not 
exist sufficient information to make a reasonable judgment that Alter- 
native No. 2 is or is not a practicable alternative to the dam. Such 
an investigation is justified if you do not decide that Alternatives 
4 or 5 are practicable alternatives because there is already new 
evidence which provides reasonable cause to believe that substantial 
groundwater supplies exist., and it will not require a protracted 
effort to obtain and evaluate such new data as may have become avail- 
able since the preparation of the EIS record. 

III. The EIS Record Did Not Consider All Reasonable Alternatives, 
and Is Not Adequate to Sustain Final Agency Action Under 
S 404 and NEPA. 

The EPA guidelines identify as practicable alternatives those 
which 1) do not involve the discharge of fill material and 2) dis- 
charges at other locations. 40 CFR § 230.10(a)(1). The regulations 
require that such alternatives be considered by the Corps through 
the NEPA process. Where the "NEPA documents may not have considered 
the alternatives in sufficient detail, may be necessary to supp- 
lement these NEPA documents with this additional information." 40 
CFR S 230.10(a) (4) . 

The EIS record fails to consider at least three alternatives 
which are sufficiently reasonable to justify more careful examination 
than that given in the EIS. These include: 

A) The option discussed above which would allow direct pumping 
from the White River supplemented by available groundwater 

B) The USBR Watson site; and 

C) A single dam site in Colorado, such as the Yellowjacket site, 
designed and managed to meet the water needs of all antici- 
pated industrial development in the White River basin, both 
in Colorado and Utah. 

A. The Groundwater Supply Option. 

The EIS summarizes available data regarding groundwater quantity 
and quality. FEIS, p. 15. The use of groundwater was considered only 
as a source of the total 70,000 ac.ft. projected demand. Given the 
assumption that the entire demand would have to be met by groundwater 
supplies, the EIS concluded that the Douglas Creek member of the 
Green River formation "appears to contain a reasonable amount of fair 

quality water " Civen the measured ("low rates rrom the Douglas 

member, it was concluded that al.-mt ?0 to 3ll wi-lls wi.ul.-; ho iil -d -I 
to meet the Full projected dom.i.Kl. Tliun, I lie Klii "uu.,i i; .-. 

Colonel Kavanaugh 
July 23, 1982 
Page 6 

sufficient water is available, but that the supply would be scattered 
and such large rates of withdrawl would probably cause depletion. 

Comment 56 proposed that the EIS consider using identified ground- 
water supplies as a short-term supplement to water drawn primarily 
from the White. This option was not considered. It would appear., how- 
ever, from the limited data presented that groundwater supply from the 
Douglas member alone should be more than adequate to meet short-term 
needs during the critical flow periods on the White. Historically, 
the critical flow periods do not occur every year, and usually last 
for weeks or a few inonthr,. During the 1977 worct-c^sc, the EIS report:. 
that 39,000 ac.ft. would have been required to supplement the tlow 
available from the White to meet both minimum downstream flow require- 
ments and the full projected industrial uses. In more typical low 
flow years, only 5,000 to 10,000 ac.ft. would be required from ground- 
water supplies. Dur ing hi- flow years and the months in low- flow 
years when groundwater is not required, recharge would occur. Thus 
significantly lower total withdrawls of groundwater and periods of 
no withdrawls should substantially eliminate concerns over depletion 
of water available from the Douglas member. Given available data, 
it would appear that the Douglas is more than adequate to serve as 
a supplementary supply during the anticipated 30 year project life 
of the oil shale projects. 

In addition, the EIS does not provide an adequate evidentiary 
basis for rejecting the Birds Nest aquifer as an additional source 
of industrial water. In the brief summary provided, supply from 
the Birds Nest aquifer was rejected because the quality "is unsuit- 
able for domestic, commercial or agricultural purposes." This 
bald T unexplained statement is not adequate as a factual basis for 
dismissing the Bird's Nest Aquifer as a source of supply for many 
of the water uses intended by the oil shale industry. Substantial 
volumes of water will be used for dust suppression and quenching 
of the hot spent shale. Neither of these activities require the 
use of high quality water. A proper evaluation of the groundwater 
supply option should evaluate the suitability of the Birds Nest 
quality for those and similar uses. It would certainly make no 
environmental or economic sense to build a species-threatening dam 
to provide high quality water for road dust suppression when other 
suitable supplies are available. 

Furthermore, new data developed by VTN Colorado, Inc., and 
Magic Circle (see discussion above) may serve to further amplify 
our knowledge of the groundwater resource so as to provide additional 
evidence showing the suitability of the Douglas and Birds Nest 

Failure to carefully consider the potential for groundwater as 
a secondary source to supplement White River flows is a major de- 
ficiency of the PKlS. This deficiency become:; part iculatly glaring 
in view of the specific request that such an analysis bo performed. 
Comment 56. Until such an analysis is completed, the EIS record 
is not. legally sufficient to sur.tain I inal agc-wy action on tlw* permit 

Colonel Kavanaugh 
July 23, 1902 
Page 7 

B. The USBR Watson site. 

This option and other sites up-river to the Colorado stateline 
were not addressed as alternatives. The FEIS dismissed them with 
the conclusion that "the other dam sites appeared to offer no envi- . 
onmental advantages over the applicant's proposed site, and were, 
therefore, not considered in this EIS." No further discussion was 
presented to support this conclusion. 

The enclosed "Impact Assessment" (Exhibit I) suggests that 
eutrophication of the reservoir is related to high inputs of 
phosphorus , nitrogen and organics from the Mancos & oil shale for- 
mations. Similarly it is reasonable to assume that some of the 
metals measured in the White River by the investigators is derived 
from those formations. Assuming these formations contribute con- 
taminants which will cause or aggravate eutrophication, and are the 
source of metals which can be expected to accumulate in the reservior , 
then substantial environmental benefits would be obtained from shifting 
the dam site upriver to a location which would less likely be influ- 
enced by runoff from the critical formations of concern. Siting 
options selected tb avoid the adverse consequences identified in 
the "Impact Assessment" should be considered prior to a final decis- 
ion on the permit. 

C. A Single Damsite Designed to Meet All the Industrial Water 
Needs of the White .liver Basin. 

In the cumulative impacts section, the FEIS makes passing refer- 
ence to the diversion of 90,000 to 172,000 ac.ft. of water from the 
White River in Colorado to support oil shale development. There is 
no discussion, however, of where or how those diversions will be 
made. Clearly, development of the White River in Colorado will in- 
clude some storage facilities. A permit has already been processed 
for the Taylor Draw Project. Other projects, such as the Yellowjacket , 
have been under consideration by the Colorado River Conservation 
District for many years. 

Each of these projects, if undertaken, will have impacts on the 
environment of the White River Basin, including cumulative impacts 
on the riverine habitat, endangered or threatened species and total 
wetland losses. EPA guidelines require that the cumulative impacts 
of projects on the aquatic ecosystem be evaluated. 40 CPU § 230.11(g). 
Similarly, NEPA also requires an analysis of the cumulative impacts of 
related developments on an effected region. 40 CFR S 1508.25, and 
K leppe v. Sierra Club , 427 U.S. 390 (U»76) . In this case, both the 
effected region and the resource to be developed are clearly de fined 
by the natural boundaries of the river basin. 

Given your legal duty to not approve a project if a less envir- 
onmentally harmful "practicable alternative* is available, and your 
obligation under NEPA to evaluate all reasonable alternatives, it 
would be inappropriate for you to make a final decision on this 
permit without first undertaking the cumulative impact analysis re- 
quired by law. 



CO-LOnel Kavanaugh 
July 23, 1982 
Page 8 

This issue was raised 
In response, DLM contended t 
sible because "water use com 
Utah & Colorado and the wate 
to other purposes." This is 
perform the cumulative irapac 
is intended to provide an an 
reasonable options so as to 
NEPA on its head by arguing 
(i.e. no compact), therefore 
believesthis is clearly cont 

n comments on the EIS (comment 56) . 
hat such a project would not be fca- 
pacts have not been developed between 
from such a dam could be obligated 

not an adequate reason for failing to 
t analysis required by law. NEPA 
alysis of the environmental impacts of 
guide decision-making. DLM has stood 
that because no decisions have been made 

no analysis should be performed. EDF 
rary to the spirit and letter of NEPA. 

The very fact asserted by the BLM, i.e., that water from an up 
river reservoir could be diverted to other uses than the proposed 
Uintah Basin developments is subject to dispute and requires analys 
before any conclusions can be made. First, it would appear that if 
Corps denied a permit for the White River dam in favor of a single 
White River storage project, the Corps could impose discharge rcqui 
ments as a condition of the permit to ensure that the express purpo 
of the project are met. Second, it is clear from a „ analysis of the 
data contained in the Water Resources Council report (Colo. UNR, 1979 
that Colorado's diversions from the White will be constrained by it 
obligations under the 1948 Upper Has in. Compact because of other div 
sions already planned or completed on other tributaries of the Colo 
ado. Given these constraints, it would appear that the 172,000 ac. 
of diversion estimated in the FIUS is certainly an upper bound for 
future consumption in Colorado. Bee Exhibit III. Given this pract 
cal limit on water use in the White, it would appear that a single 
project in the Dasin to meet both Colorado's & Utah's legitimate 
needs is more than feasible. 





For the above-referenced reasons, EDF objects to the issuance or 
a S 404 permit for the White River Dam Project at this time. The 
project should be denied because there is no proven need for the water, 
and because practicable alternatives which would cause substantially 
less harm to the aquatic environment are available. Jn the alternative, 
a final decision on the project should be withheld until a supplement al 
EIS is prepared which addresses the alternatives outlined above. 

Thank you for your consideration of these comments. Please pro- 
vide written notice of the action you take on this, matter. 

>l'eft 'Hi Ynhi 
Regional Counj 

cc: Stephen Durham, Regional Administrator, EPA 
Lloyd H. Ferguson, District Manager, 111M 
Dan Lawrence, Director of Water Ke::oiu ces (IIT) 
Deo Hanson, Stale Eng i ii.'.m (IIT) 
Honte I'ascoo, u. rector , Ik>|m. tmonr ut Natural If. 


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324 Judge Building 
8 Hast Broadway 
Salt Lake City, Utah., 84111 

August 30, 1982 

Governor Scott Matheson 

State Capitol 

Salt Lake City, Utah 

Dear Governor Matheson: 

We, the signers of this letter, wish you 
to know that we approve of and commend your strong stand In 
determining an acceptable site for nuclear waste disposal. We 
applaud your appreciation of the significance of Canyonlands 
National Park as an outstanding scenic and geologic wonder. 
We share your concern that there be no hurried and inadequately 
studied decision to locate the nuclear dump In the vicinity of 
this Parkland in Utah. However, we would like to see the State 
give equal consideration to other resource areas, less exotic 
perhaps, but of great value to the public. 

We are referring to the White River and 
the Issue of constructing a dam on It for water supply for an 
oil shale Industry. Because the whole story of alternatives 
has not been told, there are still many contradictory positions 
being taken about the necessity for the dam, between the State 
water planners, the Bureau of Land Management, the Bureau of 
Reclamation, the oil shale industry, biological researchers, 
and the public . The Issue needs to be resolved by evaluating 
all up-to-date information, some not stated In the EIS, and 
doing so openly and honestly with no hidden agendas - a situa- 
tion which has not characterized many past procedures. (Docu- 
mentation enclosed.) 

We Justify this letter to you on the basis 
of our support for both facts and conclusions presented by the 
Environmental Defense Fund as stated In their comment to the 
Corps of Engineers on the granting of a 101 Permit for dredge 
and fill purposes on Bureau of Land Management land. We will 
be quoting from their statement and information and enclose 
a copy of their documents (July 23, 1982). 

Environmental Defense Fund (EDF) statement: The record 
establishes 1) no need for the water in the Uintah Basin, 
2) that other water supply alternatives are both reasonably 
available and leas environmentally destructive, and 3) that 
reasonable alternatives were not addressed by the EIS". 

This is contrary to positions being main- 
tained by State water developers, the State Engineer, and by 
Jay Bingham. The position of Mr. Bingham la reported in a 

* * altttana frroaip dedicated to *!•» <■• or Utah < 
dttltrn invnlvawc* taa tMrt jaUra lnlat>a» r a- 

of Otah vftt*r rotfiwrcai 

In tha> arnai •v.fcllc tntaroat with 



Oovernop Matheson '• 

White River 
August 30, 1982 

Deaeret News article (Enclosed). Mr. Bingham was former Director, 
Division of Water Resources, where planning for the dam was initia- 
ted. After retirement from that Agency, his company was awareded 
the contract to design the dam without competitive bidding. 

The White River Ecosystem 

Biologists consider the White River and its 
Basin to be an Irreplaceable desert/riparian ecosystem which sustains 
a remarkable diversity of wildlife species, some whose habitat is 
endangered. Over 126 bird species use the riparian, cliff and up- 
land bench habitat - a unique bird watching area. Nutritious bottom- 
land forage for nursing does of the White River deer herd contributes 
to the high fawn survival rate. Peregrine falcon were recently seen 
In courtship behavior along the cliffs. Golden eagles nest in cotton- 
woods on the floodnlain. The presence of river beaver and waterfowl 
swimming with their young delight the canoeist and kayaker who run 
this beautiful western river canyon. River runners have spotted 
some of the thousands of sandhill cranes overhead which migrate and 
roost along sandbars along the Qreen River from Stewart Lake (Jensen 
area) and south to Ouray Refuge. Whooping cranes, raised by the 
sandhills at Grays Lake Refuge, Idaho, al30 stop along thi3 stretch 
of the river. One spent two summers at Pelican Lake, not 13 miles 
away from the White. This of ecosystem sustains remnants of 
once prolific native fish Buch as the Colorado squawflsh, now endang- 

River runners use this river for recreation 
from early spring until well into September - contrary to the posit- 
ion maintained by Temple Reynolds, Director, Department of Natural 
Resources. He states It is runnable for only 60 days of the year 
and, in any event is not worth savine. This opinion is not supported 
by the fact the the entire White River, 100 miles in Colorado and In 
Utah, was on the Wild and Scenic Rivers study list prior to its re- 
moval without public knowleged by then Director of Outdoor Recreat- 
ion, James Watt. It was removed sometime prior to 1975-1976 after 
oil shale tracts Ua and Ub were located' along it on BLM land. 

Impacts from the Dam Construction 

Of all the alternatives for water supply, 
construction of the White River dam will be the most destructive of 
these natural resources. "The dam will cause significant changes in 
water quality, stream bed stability, riverine habitat, and result 
in loss of wetlands both in the flood pool and along the river below 
the dam. Tfte EIS clearly demonstrates that construction of the dam 
will have adverse impacts on endangered species by limiting remain- 
ing habitat." (EDI') 

Wo Demonstrated Need for the White River Dam 

It Is our position that this cold desert 
river ecosystem in its natural state should not be destroyed when 
there is no demonstrated need for the water to be stored by the dam. 

Oovernor Matheaon 
White River 

August 30, 1982 

Environmental Defense Fund states : 

1. "The White River Shale Company, which could be a primary user 
Of this water, plans to install an alluvial field to obtain 
thlB reliable source for its facility use until 1982 (under 
its most optimistic development schedule)." 

2. "Magic Circle has reported in Hay J.982 In submittal to the 
Synfuel Corporation, that It believes it can meet Its water 
needs by pumping on-site aquifers even though the EIS indi- 
cates there is insufficient groundwater available. Informa- 
tion indicating there are substantial sources of useable 
ground water is not In the EIS." 

3. "Moon Lake electric power plant near Bonanza plans to pump 
18,000 acre feet of water directly from the alluvium of the 
Oreen River." It 1b the understanding of Intermountaln Water 
Alliance, unverified, that this company wan denied opportunity 
to purchase unsold water out of Flaming Gorge. 

4 . Geokinetica, working with Bhale oil Just south of the White River 
in the Book Cliffs, uses little water in its process. In fact, 
its process produces water as a by-product and will have a pro- 
blem of disposal. 

No Demand for the Water 

Environmental Defense Fund states that 
"no single company is close to construction of commercial oil shale 
or tar sands facilities or is pre-purchaslng water. 

1. The White River Shale Project plana are on the back burner. 

2. Tosco Sand Waeh Unit is currently delayed as Tosco searches for 
another partner . 

3. Magic Circle is attempting to bid for loan support from the 
Synfuels Corporation and their funding la uncertain. 

1. Sytana-Utah proposes a phased plan not to begin until 1986. 

5. Enercor-Mono plan for tar sands development calls for a demon- 
stration module in order to determine success before develop- 
ment. (We understand that existing Canadian tar sands product- 
ion Is in economic trouble.) 

6. The- Ute Indian Tribe has concluded that irrigation is not 
economically feasible. 

7. Dan Lawrence, Director, Department of Water Resources, recently 
reported to the Water Board that the negotiation of pre-purchase 
commitments had been terminated because of questions of need 
for the project water. 

Governor Matheson 
White River 
Aueust 30, 1982 


The EIS fails to identify any committments to purchase of 
water from the project." 

Reasonable Alternatives 

I. "round Water 

Recent ground water tests by VTN on Tracts 
Ua and Ub show that local ground water reserves exist in sub- 
stantial volume and quality in. the Blrd3 Nest and Douglas Creek 
aquifers. (EDF) 

In the EIS, ground water sources were pre- 
sumed 1) to be inadequate in volume, 2) to be of unusable quality, 
3) to present unsurmountable problems in their development, and 
h ) ground water was considered onl^as a sole water supply. New 
evidence, based on VTN studies, indicates that (a) substantial 
ground water supplies do exist, and (b) that their development 
will not require protracted effort. (EDF) 

II. P umping Water fr o m the W hite River and Supplement ing Supply from 
ijro und~Watcr Sources : Conj unctive Tjater M an agement 

(This alternative was not considered in the EIS) 

In calculating the special hydrologlcal char- 
acter of high and low flows of the White River, the Environmental 
Defense Fund has determined the following information: 

1. That ground water can be a secondary source to supplement 
pumping from the White River during critical flow periods. 

2. That the 39,000 acre feet of ground water stated In the EIS 
as being required for instream flows and full Industrial 
uses is a miscalculation. 

3. That, in fact, only 5,000 to 10,000 acre feet would be re- 
quired from ground water. During hlgh-dow years and the 
months in low-flow years when ground water is required, 
recharge would occur. Thus, significantly lower total 
withdrawals of ground water and periods of no withdrawals 
would substantially eliminate concerns over depletion of 
water available from the Douglas Creek aquifer. Given 
available data, It would appear that the Douglas is more 
than adequate to serve as a supplementary supply during 

the anticipated 30 year project life of the oil shale projects. 

No Consideration Given to Use of Low er Quality Water for Industrial 
Purpose s' (Conjunctive Water Management) 

Substantial volumes of water will be used 
for dUBt suppression and quenching of the hot spent shale. 
Neither of these activities require the use of high quality water 
from the rivers. Yet, in the EIS, the suitability of the Bird ' 3 
Nest aquifer source for domestic , 'commercial and agricultural 


Governor MatheBon 
White River 
August 30, 1982 

purposes was rejected. 

It would certainly make no environmental 
or economic sense to build a species-threatening dam to pro- 
vide high quality water for road and du3t suppression when 
other suitable supplies are available. (EDP) 

IV. Pump Water from the Green River 

A. Alluvium 

Moon Lake electric power plant near Bo- 
nanza plans to pump 18,000 acre feet of water from the 
alluvium of the Green to assure it a steady water supply. 

B. Green River Water Released from Flaming Gorge (IWA Data) 

The Bureau of Reclamation stated in the 
EIS, and clarified by letter, that significant amounts of 
unsold water already stored in Flaming Oorge Reservoir" can 
be released down the Green River to a pumping station.** 
(Documentation enclosed.) 

Amount State in EIS 500,000 acre feet 

Amount Available (Affirmed by Letter) 
Of 1,000,000 a f aqulred by the * 
Bureau to develop Flaming Gorge (1958) 
Present Estimated Yield for sale 1,001,000 a f 

For Utah 452,000 a f 

For Wyoming 352,000 a f 

For future usee of Colorado River 

Storage Act Purposes 200,000 a f 

Dee Hansen, State Engineer, refutes Bureau 
Information in the EIS stating that all 500,000 a f of Flam- 
ing Gorge water Is required for development of the CUP and 
for Irrigating Leland Bench (part of compensation to the Ute 
Tribe for deferring use of their water for development of the 
Bonneville Unit, CUP). Neither the Bureau's or our calcula- 
tions verify need for 500,000 a f of water for these purposes.*** 
Leland Bench is not yet authorized. Moreover, Mr. Hansen 
tells us if we want White River water for fish, wildlife and 
recreation purposes, we must purchase it. 

* The Federal government is not recouping costs of constructing 
water projects by sale of developed water: "Changes In Federal 
Water Project Repayment Policies Can Reduce Federal Costs" - 
GAO Report, August 7, 1981, CED-81-77 
** Protection of the Blue Ribbon fishery below Flaming Oorge Dam 
with additional water releases Is required. 
*** The State Engineer has not clarified his position for us. 

Governor MatheBon 
White River 
August 30, 1982 


C. The State of Utah Contract for Flaming Oorge Water and 
Sell to Industry 

If the State f Utah want3 to retain 
rights to the water and make dollars on sale of It to 
Industry, It might duplicate actions of Wyoming In contract- 
ing for sale of water from Fontanelle Heservolr for resale 
to Industry. This Bureau of Reclamation Information Is 
stated below. 

The following are existing contracts for Fontenelle Reservoir water: 

1. Master agreement with the State of Wyoming for 60,000 acre-feet per year 
at §38,000 per year. Water under this contract has been assigned as follows: 

a. Contract between the State of Wyoming and Sun Oil Company - not to 
exceed 25,000 acre-feet per year at S4.50 per acre-foot. 

b. Contract between the State of Wyoming and Pacific Power and Light 
Company - not to exceed 3 5,000 acre-feet of which 18,000 acre-feet is 
currently being delivered in accordance with incremental increases as 
agreed by contract at 56.50 per acre-foot. 

2. Second master agreement with the State of Wyoming for an additional 60,000 
acre-feet at 5503,000 per year. Several requests have been made to the State 
for use of this water. None of the requests have been approved. 

This Alternative was not considered In the EIS. 
V. Other Alternatives Wot Considered In the F.IS 

A . T he Bureau of Reclamation Watson Site ( EDF ) 

"The enclosed independent research pre- 
pared by Eco system Researc h Institute* suggests that eutro- 
phlcation of the White River Reservoir at the proposed loca- 
tion la related to high Inputs of phosphorous, nitrogen, 
and organlcs from the Mancos and oil shale formations. Sub- 
stantial environmental benefits would be obtained from shift- 
ing the dam site uprlver to a location which is lees likely 
to be influenced by runoff from these critical formations 
and their contaminants. 

B . Single D ams lte on White Riv er to Me e t Industrial Develop - 
ment : -gu *~c au of Land Managemen t Position Is Based on Faul ty 

NEPA requires evaluation of cumulative 
Impacts from a project development. Proposed or likely 
diversion from the White River in Colorado of 90,000 to 
172,000 a f of water for oil shale development will have 
Impacts on the White River Basin environment, including 

•"Impact Assessment of the White River Dam" 
for White River Shale Corporation 

April 198?, prepared 

Governor Matheson 
White River 
August 30, 1982 

cumulative Impacts on riverine habitat, endangered and threat- 
ened species, and total wetlands losses. EPA guidelines re- 
quire that cumulative impacts of projects on the aquatic eco- 
syBtem be evaluated. NEPA also requires an analysis of the 
cumulative lmacts of related developments of a region. Both 
the arfected region and the resource to be developed are 
clearly defined by the natural boundaries of the River Basin. 

BLM has erroneously taken the position in the 
EIS that in the absence of any interstate compact on water 
rights to White River water, no such analysis is required. 
EDF believes that this is clearly contrary to the spMt and 
letter of NEPA. 

Serlou3 Degradation of Reservoir and Downstream Water Qu ality 

Documentation of Ecosyst e m Research Inst itute 
of expected degradation of water quality of a White River Reservoir 
reinforces conclusions from existing studies of the serious problems 
which are developing in Lake Mead and in Lake Powell. Research 
papers presented at a Utah State University Conference on "Aquatic 
Resources Management of the Colorado River System"* (Nov. 16-18, 1981, 
Las Vegas) gave advance warning of fish survlvlal problems In Lake 
Head as well a3 potential accumulations of toxic and carcinogenic 
elements Impounded in silt behind C.len Canyon Dam. There is evidence 
of additional salt build-up in this silt resulting from formations of 
new salt producing compounds .Some conditions are energy supply related. 

We have here, then, an issue of degradation of 
the auality of water to be delivered to downstream users. We have an 
Issue of perpetual maintenance of bodies of stored water, some of 
enormouB length and depth. We have an iss ue of costs to redr ess al_l 
these conditions. When these storage facilities were proposed and 
developed," neither the water quality problems or their possible magni- 
tude were seriously addressed, let alone the issue of who is going t o 
pay the ultimate costs in perpetuity . 

Intermountain Water Alliance and signers of thl3 
letter believe we have presented serious discrepancies and ommisslons 
of Information in the premises Justifying construction of the White 
River Dam. We see in the Salt Lake Tribune, September N, 1932, that 
construction of the Wh ite River Dam Is to be delayed du e to_s\over 
than an tic ipated d evelopme nt of the State's oil s ha le reaour cfisT We 
believe that you, Governor Matheson, representing? the public Interest, 
must take the issues of reasonable alternatives into consideration - 
now that there is adequate time to review them - and reverse the long 
history paving the way for the dam construction without presenting 
all relevant facts. 

Very truly yours , 

Dorothy Harvey, Coordinator 

Office of Water Research and Technology, Department of Interior 
Utah Water Research Laboratory, Utah State University 




History of White R iver Da m Development Procedures 

1. In the leaning of Tracts Ua and Ub under President Nixon's 
"Project Independence", these were located along the White River 
on Bureau of Land Management land . 

2. Prior to 1975 or 1976, then Director of Outdoor Recreation, Jame3 
Watt, withdrew the river from the Wild and Scenic Rivers study lls„ 
without public knowledge. This included the 100 mile length In 
Colorado and In Utah. 

3. At early hearings as well as at a 1977 meeting of the Oil Shale 
Development Committee* both the public attending who valued the 
natural resources and biologists were Incensed at the posture of 
unwillingness on the part of proponents or both oil 3hale develop- 
ment and construction of the dam to consider alternatives. 

■l . Jay Bingham was director of the Department of Water Resources 
where the dam was planned. After leaving the Department, his 
company was awareded the contract todeslgn the dam without com- 
petitive bidding. He has since publicly supported the necessity 
for the dam, knowing full well alternatives exist. 

5. A year and a half after U.S.O.S. ground water studies were suppos- 
edly completed, and were "under review" In Denver or, Washington, 
the studies have still not been released. 

6. Even though ground water research on Tracts Ua and/or Ub was buna 
reported to U.S.G.S. ni "steady flow of ground water", this Infor- 
mation was abruptly concluded. 

7. The State Division of Wildlife Resources initially carried out 
the research to determine the presence of Colorado squawrish in 
the White River. Even though sauawflsh were known to migrate up 
to the Colorado portion of the River, the State Agency concluded 
that squawrish were not present. The same research methodologies 
were available to them as to U.S. Fish t Wildlife Service who later 
Established the use of this River by souawri3h.' (There are still 
unanswered questions as to total habitat requirements in the Green, 
the White and the Yampa.oT all four endangered fish: Colorado 
squawflsh, Humpback chub, Razorback sucker , Bonytail chub. Their 
habitat has disappeared since construction of the high dams on 

the Colorado J 

8. Information on the safety of the White River Dam was suppressed. 
We still have obtained no verification that a new design Is safer 
although this Information was requested from the State Engineer. 

9. In order to assure preparation of a fully adequate E1S, a citizen 
had to prepare a document, at her own expense ($600 for printing 
and mailing to Agencies and Interested parties). Rumors were 
around that State money was being passed under the table to DLM 
to control information included or excluded. 

10. A competent fisheries biologist, BLM, was transferred out to the 
Forest Service - probably Tor participating, as State Director ' 
of the Utah Fisheries Society In decisions arfectlng ln3tream flows. 
Ihe transfer occurred sometime after the report appeared or U.S. 
risn. and Wlldllle Service documentation of the presence or squawrish 


In the White River. 


11. As early as 197 'I, in the Escalante Case, Professor William Lock- 
hart, University of Utah Law School, made an appeal to the State 
Engineer, Dee Hansen, to develop rule making procedures available 

to his office to allocate wa ter in t he broa d pu blic InterVsT." 

Professor Lockhart made this" appeal twice 3ince~Tag!an~fhi1r - 3pring) , 
Mr. Hansen was asked to make this administrative regulation by 
early in June - and has still not done so. We have a very real 
question whether such action on his part Is being delayed' pending 
construction of a White River Dam. 

, . The role of citizens in this Issue 13 not 

one of trying to obstruct development of an oil shale Industry. Today 
citizens are placing different values on some kinds of natural resources 
and are seeking alternatives to traditional development answers to pro- 
blems of land and water uses. We feel cheated when "insiders" use their 
power to exclude or try to circumvent viable citizen positions. 

Sincerely , 

Dorothy Harvey 
IWA Coordinator 


t, tffa 




(/£fzz //W</ \ 

Water Chairman 
Utah Audubon 

Chairman, Utah Chapter 
Sierra Club 

Sierra Club 

■phe Wilderness Society 

Utah Public Lands Office 

Mokl Mac 

River Expeditions 

Ken Sleight, Director 
Utah Chapter 
Western River Guides 
Association, Inc. 

Don Naff River Co} 

Chester Morris 

Peter Hovlngh, Director 
Utah Nature Study Society 
Wasatch Mountain Club 
Intermountaln Water Alliance 

Western Whitewater Mapping. 

Utah Association of 
Neighborhood Councils 



Myrtle Steele, Board 
Intermountaln Water Alliance 
Metnber-Ultah Audubon 
Bird Watcher 

S+onefly Society 

of -the 

Wasatch Fly Fishing Club 

Ka. + h Ice r\ 

^J3^~ — 


fit* F- 1 i h Of ^v^ <f *~\ 


Piute Creek 
Outfitters, Inc. 

^ £l '~} yJ *f L 

//^t£^ i #...-1:.J.. v*-***-*} 


tfue£n_ } ^ttens? •%• \ ***** &***», <**»•«%& 


-S<u«t«_ C/iu-) , Cff.' 



oss7 /. / 'S* W<r~n 

.» — .An* I 


Intel-mountain Water Alliance 

8.1 BLM concurs that river recreation use is an important aspect and that 
the increasing use trend focuses needed attention on this aspect of 
resource management. The data provided in the comment substantiates 
the magnitude of the amount use throughout the region. 

It is noted, also, that this matter was the subject of considerable 
discussion during the environmental impact statement process for the 
proposed White River Dam project. That project is not the prime 
subject of the Uintah Basin Synfuels Development EIS, but it is 
indirectly involved since it is a potential water source for several 
of the synfuels project. Therefore, the White River Dam Project EIS 
is incorporated by reference; however, there is no intent to re- 
analyze that project. 

It is not intended that this EIS evaluate Utah State water policies 
which may be set by the State Legislature, State Engineer, or State 
Division of Water Resources. 



Tosco Development Corporation 



October 14, 1982 

Mr. Lloyd Ferguson 
District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 84078 

Re: Uintah Basin Synfuels Development — 
Draft Environmental Impact Statement 

Dear Mr. Ferguson: 

Tosco Development Corporation (Tosco) formally submits the 
following comments to the draft Uintah Basin Synfuels EIS (DEIS) 
prepared by the Bureau of Land Management (BLM) : 

With very little supporting explanation, the BLM has 
recommended a proposed alignment for rights-of-way required for 
access roads, water supply systems and power transmission lines 
immediately northeast of the Sand Wash Shale Oil Project which is 
completely inconsistent with the general location of the 
rights-of-way for these facilities recommended in Tosco' s 
Technical Report. Tosco has also been orally notified that a 
similar recommendation has been made for the alignment of the 
product pipeline, despite the fact that the DEIS states that the 
BLM had accepted Tosco 1 s preferred alignment. The right-of-way 
corridor recommended by the BLM would, without exception, require 
Tosco to relocate all of these rights-of-way to areas beyond the 
jurisdiction of the BLM within the boundaries of the Uintah and 
Ouray Indian Reservation. For the reasons set forth below, Tosco 
believes that the BLM's recommended changes in alignment are both 
inappropriate and inadvisable. 

A comparative analysis of potential environmental impacts 
reveals no significant difference between the BLM's preferred 
alternatives and Tosco' s preferred alternatives. A table 
detailing environmental impacts of the two alternatives 
abstracted from the Technical Report and DEIS is appended 
hereto. This analysis demonstrates that the total disturbed 
acreage, as well as the visual and recreational resource impacts, 
of the alternatives are comparable. 



Mr. Lloyd Ferguson 
October 14, 1982 
Page 2 

BLM's discussion of the preferred alternatives in the DEIS 
corroborates this conclusion. At page T-4-32, BLM states that 
the "effects to all resources from this alternative [i.e. BLM's 
preferred alternative for the access roads] would be similar to 
those of the proposed action." On page T-3-7, it is stated that 
the alternative water system right-of-way preferred by BLM has an 
affect on the environment similar to Tosco' s proposed action. On 
page T-3-8, the BLM notes that the environmental effects of the 
BLM's preferred transmission line right-of-way do not vary 
significantly from Tosco's preferred alternative for the 
following resources: socioeconomic, air quality, water 
resources, vegetation, soil, agriculture, transportation 
networks, recreation, wilderness, cultural resources, mineral and 
energy resources, and existing land use plans. 

The only apparent justification for the BLM's recommendations 
is the inconsistency between Tosco's preferred alignment and the 
land use classifications set forth in the BLM's existing 
management framework plans (MFP's). The BLM's recommendations 
however, are subject to the same objection. As indicated in the 
DEIS, the BLM's recommended right-of-way locations for 
transmission lines and the water supply system are also 
inconsistent with the provisions of applicable MFP's (note page 
T-4-18, page T-4-27, Table T-2-1, and Table T-2-2, DEIS) . 
Although the DEIS does not clearly state whether the BLM's 
preferred alignment for access roads is consistent with existing 
MFP's, we assume that they are not. In summary, it would appear 
that existing MFP's will have to be amended to accommodate either 
the BLM's recommended, or Tosco's preferred, right-of-way 
alignment. Tosco believes, based on the considerations noted 
below, that any future amendments to the MFP's should accommodate 
Tosco's preferred corridor location. 

As indicated previously, the BLM's recommended alignment 
crosses the Ute Reservation. This action has been taken in the 
absence of any effort to communicate with the Tribal governing 
body and, apparently, without the Tribe's concurrence. In 
Tosco's opinion, the BLM's tentative decisions on corridor 
location may intrude upon the jurisdictional prerogatives of the 
Tribe. Unless the corridors identified by the Tribe according to 
its land use planning policies are consistent with the BLM's 
proposed corridors, corridor planning by energy project sponsors 
in the vicinity of BLM and Tribal lands will become extremely 
difficult. Because the BLM has no control over right-of-way 
definition within Indian lands, we believe it is unwise for the 
BLM to plan rights-of-way on public land based on any 
preconception of how corridors may be located within the 
reservation until it has coordinated its actions with the Tribe. 

Mr. Lloyd Ferguson 
October 14, 1982 
Page 3 

9-3 Tosco 1 s proposed corridor locations are also more consistent 
with multiple use planning principles applicable to federal 
lands. We believe that it is the obligation of the BLM and the 
Department of the Interior to promote mineral development, as 
appropriate, on public domain lands. Included in this obligation 
is the responsibility to provide adequate transportation and 
utility corridors in the vicinity of federal mineral reserves on 
land within the BLM's jurisdiction to allow for the development 
of these reserves. The preferred right-of-way locations analyzed 
in Tosco's Technical Report are as important to the viability of 
development plans for federal oil shale reserves in the central 
Uintah Basin as they are to the development of Tosco* s state 
leases. For this reason, Tosco strongly recommends that the BLM 
concur with Tosco' s preferred right-of-way locations and that 
exisiting MFP's be amended accordingly. 

Very truly yours, 

Tosco fltaveiofcment Corporation 



William Dixon Shay, Jr. 





Visual Class 


Access Roads 



12 acres significantly 
affected (Class III) . 
Within 1/2 mile 
of Green & White^ 

for water 


Section 17 



70 ac VRM Class II 
27 ac VRM Class III. 
2 miles outside of 
BLM proposed corridor. 

1 mile of 
Wild +■ Scenic 





r 6 73 ac VRM Class II 
( & 20 ac VRM Class III. 
i 6 acres VRM Class II 
C 6 acres VRM Class III. 

1/2 mile 
either side 
of White 

Pipeline 4 



Considered sane as 

same as below. 





12 acres significantly 
affected (Class III) 
(6 within Reserva- 
tion) . Within 
1/2 mile of Green + 
White River Zones . 

of bridge. 
13 miles of 
White River 
affected for 
Wild + Scenic 
tion. Devil's 
Rock House. 




70 ac VRM Class II 
27 ac VPM Class III. 

Sane as above. 



Length Acres 

Visual Class 



Tosco Development Corporation 




9 mi. outside of 

BLM proposed 


6 acres VRM Class II, 

6 acres VRM Class III. 

Contrast w/ 
from power 
trans, and 
roads. 1 
mile of 
River 7 
affected . 



TOTAL 1406 

Pipeline crosses 
White River (1 mile) . 
64 ac Class II 
6 ac Class III. 

1 900 - BLM calculated using the wrong number for western access route 
(251 acres instead of 218 acres) . 

2 Statement p. T-4-32 that the land affected by alternative access roads 
would not differ from Tosco" s choice; and on p. T-l-28 - mentions less 
disturbance and fewer potential problems at single river crossing point. 

3 p. t-4-13, impacts from White River Section 17 alternative stated as 
similar to Tosco' s choice. In addition this alternative conflicts with 
BLM's Bookcliffs Management Framework Plan. (2 miles outside of proposed 
corridor) . 

p. T-3-7, affected environment similar to proposed action. 

4 Product pipeline not considered in EIS; north-south segment same as 
S. L. C. pipeline and east-west segment same as other Rangely route 
except for 2 miles (p. T-l-28) . 

5 P. T-3-8, Statement areas affected do not vary significantly from 
Tosco's choice (including recreation and land-use). 

P. T-4-22, Conflicts with existing MFP cited, 1/2 mile of White River 

6 Data from two different tables in Draft EIS. 

7 P# t-4-16, one mile where north lines crosses River and one mile where 
south line crosses river. 

8 P. T-3-5, "Devil's Rock House" within 1 mile of proposed transmission 
line (and product pipeline and eastern access road) . 60 acre-parcel 
nominated in 1975 for "outstanding natural area, "still under consideration 
by BLM. 



BLH's preferred alternatives were developed to be as consistent as 
possible with existing land use planning decisions, one of the most 
Important being the protection of the scenic corridor along the White 
River. These preferred alternatives are not necessarily the same as 
may result from decisions on actual locations for the rights-of-way. 
Right-of-way grants can only be issued after the analysis of all 
alternatives has been completed, the Final EIS published, and a 
record of decision executed. At that time, full consideration will 
be given to all available Information so that, should a right-of-way 
be granted. It will be environmentally acceptable as well as usable. 

BLH's recommendations as to preferred corridor locations were 
intended to be as consistent as possible with existing land use 
plans. BLM recognizes that the Ute Tribe's approval is needed before 
any linear facility can be built across tribal land. It is 
understooding that a land use plan for the Uintah and Ouray 
Reservation is being prepared at this time. When this planning 
progresses to a point that corridors common to both entities can be 
identified, every attempt will be made to do so. 

Refer to the response to Comment 9.1. 






United States Department of the Interior 

RESTON, VA. 22092 

In Reply Refer To: 
EGS-Ma1l Stop 423 

OCT 1 4 1982 



District Manager, Bureau of Land Management 
Vernal, Utah 

Assistant Director for Engineering Geology 

Subject: Review of draft environmental statement for Uintah Basin 
Synfuels Development, Utah and Colorado 

We have reviewed the draft statement as requested In the notice from 
the State Director. 

The statement should assess more thoroughly the potential ground-water 
Impacts for projects Involving the oil shale resources of the Uintah 
Basin, particularly Impacts on the Douglas Creek aquifer which Hes 
below the Mahogany zone (p. T-4-7). Analyses from a recent deep drilling 
and testing program Indicate that ground water 1n the Douglas Creek 
aquifer within the Interior of the basin has a total dissolved solids 
content on the order of 1,000 milligrams per liter. Water from the 
shallower Bird's Nest aquifer, which lies above the Mahogany zone, has 
about 10,000 milligrams per liter of total dissolved solids 1n the 
Interior of the basin (Holmes, W.F., 1980, Results of test drilling 
for ground water 1n the southeastern Uinta Basin, Utah and Colorado: 
U.S. Geological Survey Open-file Report 80-951, p. 1, 34). Water In 
the confined Douglas Creek aquifer 1s under considerable hydrostatic 
pressure and In places has a plezometric surface more than 100 feet 
above land surface (Holmes, W.F., 1980, op. dt. , p. 34). The statement 
should address the significance of the removal of confining. Impermeable 
shale layers overlying the Douglas Creek aquifer and should evaluate 
the potential for Impacts from: (1) mixing the waters of the two 
aquifers; (2) loss of pressure in the Douglas Creek aquifer; and 
(3) changes in water quality In the Douglas Creek aquifer as a result 
of 1n-s1tu methods 1n the overlying oil shales. 


vames F. Devlne 

U.S. Geological Survey 

10.1 The oil shale zone to be mined is believed to be separated from both 
the overlying Birds Nest and underlying Douglas Creek aquifers by a 
sufficient thickness of relatively impermeable layers so that mining 
would not encounter water from either aquifer. This does not exclude 
the possibility, believed to be remote, of encountering an 
unpredictable fracture zone or fault extending to either aquifer 
which Is sufficiently open to transmit water. Should this occur, 
measures such as dewaterlng and use of the intruding water, or re- 
Injection would Mitigate any Impact. 






s ^5 


U.3.D«uMUmntol Homing nidUrtur 
Denver Raglonal/Arsa Office. Region VIII 
Executive Tower Bulking 
1405 Curtis Street 
Denver. Colorado 90202 

October 15, 1982 

Mr. Lloyd Ferguson 
District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, UT 84078 

Dear Mr. Ferguson: 

Thank you for the opportunity to review and comment on the draft 
Environmental Impact Statement (EIS) for the Uintah Basin Synfuels 
Development Impacting the areas of northeastern Utah and northwestern 

Your EIS has been reviewed with specific consideration for the areas 
of responsibility assigned to the Department of Housing and Urban 
Development (HUD). This review considered the proposals compatibility 
with local and regional comprehensive planning and Impacts on urbanized 
areas. Within these parameters this EIS 1s found adequate for our 

If you have any questions regarding these comments, please contact 
Mr. Carroll F. Goodwin, Area Environmental Officer at (303) 837-3102 or 
FTS 327-3102. 

Robert J. Hatuschek 

Office of Regional Coinnunlty 
Planning and Development, 8C 


Department of Housing and Urban Development, Region VIII 

11.1 The views expressed in this letter will be considered in the decision- 
making process. BLM appreciates the assessment that the EIS is 
adequate for the needs of the U.S. Department of Housing and Urban 









4613 South 4000 West 
P.O. Box 20222 
Salt LakeCity, Utah 84120 
Phone 968-3548 

October 15, 1982 

Mr. Lloyd Ferguson, 

District Manager 

U.S. Bureau of Land Management 

170 South 500 East 

Vernal, Utah BW?8 

Dear Mr. Ferguson, 

The following letter expresses the views and concerns of the 
Humane Society of Utah in regards to the E.I.S. for Uintah Basin 
Synfuels Developement. 

These projects are primarily experimental in nature. It is 
unknown if Iobs of habitat for 35-plus years is a reasonable trade- 
off with relationship to the projects worth in energy developement. 
Loss of habitat affects all aspects of the impact to this area and 
its wildlife. 

We find a definite lack of information concerning the following 
areas. These should be better defined, examined and evaluated in the 
final draft of this E.I.S. . 

1) Wildlife has been described very generally (i.e. small mammals, 
birds, raptors). There are few specific species mentioned or con- 
sidered. With the exception of Syntana, there are no wildlife pop- 
ulation counts. This is needed to estimate loss to wildlife. 

2) There are no impact details concerning power lines needed for 
these projects. Such power lines would have a large impact to the 
raptors in the project areas, unless properly constructed. 

3) The Tosco Sand Wash has resting areas for the Whooping Crane. 
There is no indication of where these areas are or how they will be 

k) Mention was made on page R-3-^, that there were 100 wild 
horses in the project areas. No further information is provided as 
to the location of these animals or the possible impact to the animals. 


Gifts and Bequests to the Society are deductible for income and estate tax purposes. 

October 15, 1982 
Mr. Lloyd Ferguson 
Page 2 


12.7 | 

12.8 | 



5) There are three related projects that are mentioned (R-B, H-C, 
R-d). There is no impact information on these projects. These pro- 
jects should not be considered without a draft of their proposed 
impacts . 

6) Grouse habitat is listed as unqualifiahle with no explanation 
of M unqualifiable H . 

7) There is possible habitat for the Black-footed ferret. It is 
unknown if the ferret exists in this area. This should be evaluated 
because of its endangered Btatus. 

There was considerable projected loss of wildlife due to poaching 
and harrassment. This problem could be reduced though the use of the 
Uintah and Quary Indian requirement restricting the carrying of weapons. 
This requirement is on page SS-A-8. This restriction could be used 
by all the project companies and their employees. This would definite- 
ly limit poaching and harrassment. 

The Humane Society of Utah objects to the massive loss of life 
to Songbirds, Mourning doves and small rodents. The total percentage 
of animals affected is not large, but we find the potential numbers of 
dead and/or injured to be staggering. 

All five projects list alternatives for water useage. They in- 
clude use of White River, Green River or ground and well water. We 
would oppose the diversion of water from either river, because of the 
adverse affects and possible loss to the three endangered aquatic 

Your review of these concerns is appreciated. 


Helen D. RobiBon . 
Senior Investigator 





Humand Society of Utah 

1Z.1 Although these projects are somewhat experimental, they are serious 
comnercial efforts. One of the purposes of an EIS is to point out 
trade-offs to the decision maker. It is up to the decision maker to 
decide whether the trade-offs are reasonable. The point of view 
expressed in this comment will be considered in the decision-making 

12.2 In most cases, numerical estimates of wildlife population losses are 
not available. The Utah Division of Wildlife Resources cannot census 
the various wildlife species (with the possible exception of 
pronghorn) to get more than a population trend. Therefore, the 
Division does not estimate total populations. Estimates of losses 
caused by the applicants' projects cannot be reliably made because of 
the present levels of knowledge about wildlife populations. 

12.3 It is currently standard practice for power lines to be constructed 
to minimize raptor electrocution. Chapter 1 (Section 1.0.1) of each 
site-specific project discussion states that power lines would be so 

12.4 Neither the Fish and Wildlife Service nor the Utah Division of 
Wildlife Resources identifies the Sand Wash area as a resting area 
for whooping cranes. 

12.5 Because of the small number of feral horses in the Uintah Basin and 
the large area they occupy, no impacts are anticipated to these 
animals. For a more complete inventory of feral horse range, see 
Range Management Allo tment Status Report , Bonanza Planning Unit, 
Vernal District (BLR 1981b): 

12.6 The three projects referred to in the comment are conceptual at this 
time. Their impacts were analyzed to the extent possible in the 
regional part of the Draft EIS (referred to as the Nine-Project 
Cumulative Analysis in the Final EIS). Supplemental environmental 
assessment of these projects will be required when project designs 
are more complete and specific actions on the right-of-way 
applications are requested (EIS Preface). 

12.7 The word used in the Draft EIS (page M-4-11) is "unquantif iable." 
Unquantif iable means that a number cannot be determined for the loss, 
but that a loss would occur. 

12.8 The black-footed ferret is discussed in Section R-3.A.5. 

12.9 BLM has no authority to regulate carrying of firearms on state or 
private lands. As noted, this mitigation measure would be included 
in tribal authorizations. Each company would determine the necessity 
and enforceability of such mitigation as a matter of company policy 
for employees on all lands (state, public, and private). 

12.10 The views expressed will be considered in the decision-making 






a subsidiary of Magic Circle Energy Corporation 

October 12, 1982 

Mr. Lloyd Ferguson, District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 84078 

Dear Mr. Ferguson: 

Synfuels Engineering and Development has reviewed the Draft Environmental 
Impact Statement for Uintah Basin Synfuels Development for Magic Circle Energy 
Corporation. On the whole, we are impressed with the high level of competence 
reflected in the Draft EIS, and are pleased with the favorable recommendations 
regarding our proposed Cottonwood Wash oil shale project. However, we believe 
that the final EIS could be improved by .incorporation of the following suggest- 
ions. We recognize instances in which data regarding our plans were not made 
available to BLM in sufficient time for incorporation in the Draft EIS. We 
also realize that a few of our comments relate to subjective aspects of the EIS, 
and we are submitting comments on these aspects to help ensure that BLM has the 
opportunity to consider all sides of such issues. Our comments, with references 
to specific pages in the Draft EIS or the supplementary technical reports (Re- 
ference 1 through 3), are grouped by subject matter. 

1. Air Quality - From the standpoint of the Cottonwood Wash project, the 
main problem with the air quality section of the Draft EIS is the background 
air quality assigned to the Cottonwood Wash site. For eomple, the baseline 
data given in Table M-4-2, page M-4-6, are in conflict with monitored data de- 
termined by the Utah Bureau of Air Quality (Reference 4) to be representative 
of the Magic Circle site. Comparative data are presented below, with all values 
expressed in units of ng/m^. 

EIS (Table 6-13) MONITORED 


Sulfur dioxide 

Total Suspended Particulates 


Carbon Monoxide 















1667 Cole Boulevard, Building 19, Suite 400, Golden, Colorado 80401 (303) 238-5304 



Page 2 

Mr. Lloyd Ferguson 

The values of most concern are those for TSP, which according to the 
EIS, are near or above ambient air quality standards. Actually, according 
to monitored data, TSP levels are well within state and federal ambient air 
quality standards. Therefore, statements such as that given on page M-4-7 
regarding "the high existing levels" [of TSP] are inconsistent with monit- 
ored data, and should be deleted or modified. 

The second paragraph of par. M-3.A.2 (page M-3-1) should be revised to 
read : "Drainage flows would carry emissions to the northeast." The meteoro- 
logical characteristics of the site are described in Reference 6. 

The footnote to Table M-l-5, page M-l-20, should read: " a Based on max- 
imum expected daily emissions during peak operation." 

The second and third paragraphs of par. H-4.8 (page M-4-18) together 
with associated portions of Table M-2-2 (page M-2-3), unfortunately were 
based upon preliminary estimates which were changed significantly as de- 
sign progressed. It is recommended that the following changes, which are 
consistent with page 280 of Reference 7, be made: 

"By using the small-scale Paraho retorting process, air emissions 
would be virtually the same as those identified for the proposed 
action. (Emission rates for both processes are identified on Table 
M-l-5.} Air quality impacts of this alternative are summarized in 
Tables H-4-5 and M-4-6, which show that no NAAQS or PSD increments 
would be exceeded. Visibility impacts would be similar to those of 
the proposed action. 

Water consumption for the small-scale Paraho retorts with water re- 
covery would be approximately the same as that of the proposed 
action (540 ac-ft/yr)." 

Air Quality 

TABLE M-2-2 


174 kg/hr of SO, 
68 kg/hr of TSP 
974 kg/hr of N0 X 
24 kg/hr of THC 
56 kg/hr of CO 
(PSD incremental 
limitations and NAAQS 
would be met for al 1 
pol lutants) 


174 kg/hr of SO 2 
69 kg/hr of TSP 
974 kg/hr of N0 X 
24 kg/hr of THC 
56 kg/hr of CO 
(PSD increment consump- 
tion and NAAQS impacts 
would be same as for 
proposed action) 

Note: ... kg/hr 

Kilograms per hour (maximum)... 

sulfur dioxide; TSP = total suspended particulates 








Page 3 

Mr. Lloyd Ferguson 

2. Vegetation and Wildlife - Certain portions of the Draft EIS could 
lead to gross misunderstanding of the vegetation and wildlife characteristic 
of Cottonwood Wash. Specifically, Figure R-3-1 (page R-3-29) implies that 
the Magic Circle site consists of about 40 percent Pinyon-Juniper vegetation 
type. Actually, the site contains neither pinyon nor juniper nor most other 
vegetation characteristic of the type. Surveys conducted by a local consult- 
ant, Bio-Resources, Inc. (Reference 5) show that the entire site is best char- 
acterized as mixed-desert shrub. 

Although Cottonwood Wash lies within a broad area classified as "high- 
priority year-long pronghorn antelope" habitat (cf . Table R-4-20, page R-4- 
63), studies by our wildlife specialists (Ref. 5) have shown that the Cotton- 
wood Wash site has little or no present or potential use as a year-round p-ong- 
horn antelope nabitat. In fact, the site is almost totally devoid of big-game 

Several other portions of the EIS give the impression that the site contains 
significant riparian acreage. Riparian vegetation comprises plants that are 
normally associated with surface flowing water. Except for runoff occasionally 
flowing through Cottonwood Wash, there is no surface flowing water on or in the 
immediate vicinity of the site. To minimize confusion, it might be best to 
classify Riparian areas with subscripts to distinguish between on-site riparian 
(greasewood) and corridor riparian areas. 

This change would help clarify Table R-3-1 1 (p. R-3-35). For example, the 
peregrine falcon, being a bird hawk, is found where prey are found, i.e., in 
riparian and aquatic habitats, not in the mixed-desert shrub areas unless these 
areas are immediately adjacent to Riparian areas. Also, mule deer are transient 
on the Magic Circle site, which is not a preferred habitat for any big game. 

The misunderstanding extends to the statement on page M-4-8 that "... 
20 to 75 years would be required to return brush and tree species to pre- 
construction height and population densities." No trees are found in the 
area to be disturbed. We recommend the statement be changed to read "...20 
to 25 years would be required to return vegetation to preconstruction height 
and population densities." 

Also, please note that Table R-3-10 erroneously indicates that Magic Circle's 
access road traverses riparian as well as mixed-desert shrub vegetation. In 
fact, the 0.75-mile access road traverses only DS-type vegetation. 

Also, no sage grouse have been seen on site during year-round surveys* so 
it is difficult to understand the statement on page M-4-11 "... 277 acres of 
the substantial value, year-long sage grouse habitat would be disturbed by 
project activities." 


Page 4 

Mr. Lloyd Ferguson 

3. Energy Efficiencies - The BLM analysts did a good job with very 
limited data in attempting to estimate the energy efficiency of the Magic 
Circle project. We were unaware that such calculations were being made, 
and hence did not supply all the data needed for a thorough, consistent anal 
sis. We originally selected the Improved NTU/T 3 process in part because of 
its relatively high energy efficiency (computed on a different basis from 
that used by BLM), as shown in the following tabulation. 





Paraho, Direct 63.0 

Union SGR-3 02.7 

Tosco II 62.3 

VMIS 61.9 

Union B 61.4 

Superior, Direct 61.1 

Galoter 60.7 

Paraho, Indirect 60.6 

Petrosix 60.2 

Kiviter 52.7 

* 25.6 GPT Utah Shale 
As part of our review of the Draft EIS, we have computed overall energy 
efficiency using the methods outlined and referred to in the Draft EIS, and 
recommend that the following changes be made: 
On page R-4-92, for "Magic Circle" summary 

As written is: 







Should be: 







On page M-4-17, delete the second paragraph. 

On page M-4-17, change the small table to read as follows: 

Net Output 69.925 

Energy in Shale (111.400) 

Other Fuels Used ( 1.408) 

Indirect Energy ( 5.222) 

Infrastructure ( 8.461) 


Total Input 
Percent Efficiency 


On page R-L-3, opposite "Magic Circle" and under "Hydropower," change 
"1.134E13." to "1.134E12." Under "Totals," change "1.866E13" to "8. }61E12." 

The major differences between the Draft EIS data and assumptions and 
the project plan are these: 




Page 5 

Mr. Lloyd Ferguson 

1. Power Plant. The BLM analyst assumed, on the basis of inaccurate 
information on page M-l-15, that the powerplant used off-gas as its sole 
fuel, with total power generation of 108 MW and excess power of 44 MW. Act- 
ually, the plant burns both off-gas and raw shale tines, and produces an 
average output of 314 MW and an average excess of 200 MW. 

2. Spent Shale. The analyst assumed 18.42 E6 tons/year of spent shale. 
The project estimate is 16.75 E6 tons per year. 

3. Underground Crushing. The analyst used the standard factor of 8 
percent loss of fines. Actually, all fines are burned in fluidized bed 
combustion unit rather than being lost, and are expected to amount to 12 
percent of mined tonnage. 

4. Infrastructure. The BLM analysis appears to be incorrect by a factor 
of 10 in the use of the "hydropower" factor. 

5. Total External Energy as Resources in Ground. As noted in the guide- 
lines referred to in the E1S, on-site power developed from the principal oil 
shale resource does not require any entry under this heading, because it comes 
from resources within the basic "trajectory." The BLM analysis in effect doubly 
accounts for energy expended in extracting this portion of the principal energy 

13.13 | 

6. Water Supply. The BLM analyst used peak water consumption rather 
annual -average consumption in his calculations. 


7. ANFO usage. The BLM analyst used a standard factor. The project es- 
timate is somewhat higher. 

8. Diesel consumption for underground mining. The BLM analyst used the 
standard factor, which is based on underground haulage by truck. We used the 
project estimate, which is based on transport by conveyor. 

9. Energy in Materials for etort. The BLM analyst appears not to have 
divided the total materials requirement by the expected life of 20 years, as 

advocated in the guide book. 

4. Mining and Processing Details 

a. The depth of the underground mine (item 1, par. M-l.C-1) is 
1500-1900 feet, rather than 880 feet. 

b. Full production (p. M-l-9) is scheduled for 1990, not 1988. 

c. The first sentence on page M-l-15 should be: "When f 

duction is underway, the Magic Circle project would generate (by b 
shale fines and low-Btu gas) approximately 200 megawatts of electi 
that could be exported to the uti ', .ty grid." Table M-l-4 (page M 
should be revised accordingly 

ull pro- 
ic power 




Page 6 

Mr. Lloyd Ferguson 

d. Paragraph M-l.E.l (page M-l-15) should be revised to raad: 
"This alternative would be identical to the proposed action except that small- 
scale Paraho retorts with water recovery would be used instead of Magic Circle's 
Improved NTU/T 3 retorts." 

e. On page M- 1-12, the phrase "...the retorting process's complete 
carbon utilization..." should read "... the retorting process's carbon utiliza- 

f. The first sentence of second paragraph under "Improved NTU/T 3 
Process" on page SS-15 should be changed to: "The Improved NTU/T 3 process 
can be visualized as consisting of two identical retorts which operate in 
alternating retorting and cooling modes as shown in Figure SS-3." 

g. Page SS-4, last sentence, states: "It is this substance which, 
when heated to about 900 degrees Fahrenheit, emerges from the rock as a slow 
flowing liquid that can be converted to a synthetic crude oil." This state- 
ment is incorrect since the kerogen is naturally occurring organic polymer 
which is thermally cracked to produce products. 

This statement could read: "The kerogen is thus a naturally occurring polymer 
which when heated to about 900°F in the absence of oxygen thermally decomposes 
to produce liquid, gas and residual carbon. The liquid is a crude oil type 
material similar to naturally occurring crudes but requires upgrading prior to 
refining in a conventional refinery." 

h. The first paragraph beginning on page SS-18 mentions Fischer 
For a typical shale, Fischer assay will yield something like the follow- 

as say . 


Residual Carbon 



To arrive at a Paraho process yield of 103%, one would compute (weight of oil 
plus weight of gas) / Fischer assay oil. 

To be correct, one should compute the results as: 1) wt. of oil produced/Fischer 
assay oil (normally about 88-92% for Paraho) or 2) (wt.of oil plus wt. of gas 
produced) /(Fischer assay oil plus gas) 

The corrected yield would be: 

103% * -i|| = 82.9% or 83S of the energy in the form of gas and oil as 

produced by Fischer assay. 

5. Water Consumption and Wastewater 

a. Although average water consumption is about 540 ac-ft/yr, waste 
water will amount to 52.3 ac-ft/yr rather than 540 ac-ft/yr as indicated on 
page M-l-13. The remainder is lost to evaporation or is discharged to the 
atmosphere in the stack gas. 





Page 7 

Mr. Lloyd Ferguson 

6. Benefits and Trade-offs - We recognize the comparative difficulty 
in assessing the positive versus the negative impacts of energy development 
in any area. Without mitigation, negative impacts of various types are certain 
to occur. With proper mitigation techniques, the costs of which could easily 
be met by the use of revenues from the proposed projects, many or most of these 
potentially negative impacts could be turned into positive impacts. The EIS 
authors appear to have taken the viewpoint that, since implementation of appro- 
bate mitigation measures is not assured, it is proper to assume they will not 
be implemented. Conversely, Magic Circle believes that the preponderance of 
evidence (e.g., the reclamation plans noted in the EIS, the socioeconomic mit- 
igation measures instituted by Uintah Basin projects that are currently under 
way, the provisions of SB170, and the project mitigation plans such as that 
outlined by Magic Circle in Fort Duchesne and Vernal on September 8, 1982) is 
that appropriate mitigation measures will be taken. Accordingly, we believe 
that Table R-5-1 should be revised as follows: 

TABLE R-5-1 

Quality or Quantity 
Increase Decrease Va 




Oil/Energy Production 

Oil Shale/Tar Sand Resources 

Oil Shale/Tar Sand Reserves 

Employment Opportunities 

Income Levels 

Local Prices and Wages 

Service infrastructure Needs 

Public Revenues 

Quality of Life 

Air Quality 

PSD Increment Availability 

Vi sibi 1 ity 
Water Quality 
Vegetative Production 
Wildlife Populations 

Traffic and Transportation 
Road Quality 
Outdoor Recreation 
Wi lderness 

Cultural Resources/Facilities 
Paleontolgical Resources 



ri able 
ipac t 

¥ b] 

v a] 





Page 8 

Mr. Lloyd Ferguson 

Footnotes - Table R-5-1 

a] Most indicators commonly used to describe this resource/item are likely 
to improve with proper planning and use of project revenues, but would likely 
deteriorate in the absence of such measures. 

b] Traffic increase expected; transportation indicators may improve or deter- 
iorate, depending upon use of project revenues. 

c] Accessibility of non-renewable cultural resources likely to increase; in- 
crease in cultural facilities (those devoted to fine arts, humanities, and broad 
aspects of the sciences) likely as consequence of population growth and increased 
public revenues. 

7. Environmental Impacts 

a. Land Spills. Pages R-4-97 and R-4-98 mention the possibility of 
a rupture of the proposed Magic Circle product pipeline within the marsh area 
of the Ouray National Wildlife Refuge. Actually, the pipeline does not pass 
within a mile of the Refuge, as can be seen from Figure R-A-3 of EIS Appendix 
R-A. If the Refuge should be expanded to include part of the path of the pro- 
posed pipeline, and if the intent to expand in such a way were made public in 
sufficient time for Magic Circle to change the route of the proposed pipeline, 
we would be happy to do so. We certainly would not knowingly endanger the 
Refuge, even though the potential for such a rupture is very small and our 
spill prevention and control system would minimize the spill if a rupture were 
to occur. 

b. Disturbed acreage. On Table M-l-1, page M-l-6, the access road 
mileage and acreage should be moved to the "State of Utah" column, as can be 
seen from Map M-l-1 on page M-l-7. 

Footnote h on Table M-4-3 could be added to Table M-l-2, page M-l-17, to 
clarify the duration of land disturbance for the spent shale pile. 

c. Visual Resources. The statement on page "■1-3-6, to the effect that 
"The project area is not viewed from highly sensitive areas, other than from the 
two rivers..." may be misleading. The project site is not visible from any 
point along either river. 

In the EIS report negative references (e.g., page M-4-14) are made to in- 
take structures required to utilize water from the Green River. These struct- 
ures are assumed to detract from the scenic appearance of the river. Magic 
Circle has taken into account these negative impacts and has elected to drill 
wells in the alluvium some 100 to 200 feet back from the river's edge. Since 
the river is some 6 to 10 feet below the level of the wells and the pumps will 
only extend 3 to 4 feet above the ground level, it is probable that one cannot 
see these structures from the water level. In addition, there are trees and 
underbrush between the intakes and the river's edge, further obscuring these 
"small" pumps. 



Page 9 

Mr. Lloyd Ferguson 

Also, approximately 2 miles north of these hidden intakes there exists 
an old bridge structure not in use. This existing structure is visible from 
the water and has already produced a negative impact on the scenic beauty. 
Therefore, we believe the comments in the report are unjustified for the 
Magic Circle project. 

d. Threatened or Endangered Species. The note regarding the bookless 

cactus (page R-4-58) should be expanded to note that the cactus is usually found 

on the Green River Formation, not the Uintah Formation as on the Magic Circle 

Very truly yours, 


rlr. Hafry E. McCart/y 
Project Manager of the 
Cottgnwood Wash Project 






1. Draft Environmental Impact Statement, Uintah Basin Synf uel s 
Development, Bureau of Land Management, August 1982. 

2. Draft Technical Report, Air Quality, Uintah Basin Synfuels Develop- 
ment, Systems Applications, Inc., August 1982. 

3. Draft Technical Report, Uintah Basin Synfuels Development, Socio- 
economics (two volumes). State of Utah, August 1982. 

4. Letter, Brent C. Bradford, State of Utah, Division of Environmental 
Health, April 5, 1982. 

5. Flora and Fauna of the Cottonwood Wash Project Area, Bio-Resources, Inc. 
Logan, Utah, September 1982. 

6. Representativeness of Off-Site Meteorological Data for the Utah Cotton- 
wood Wash Oil Shale Project, Uintah County, Utah, VTN Consolidated, Inc. 
Irvine, California, December 1981. 

7. Commercial Shale Oil Production from the Utah Cottonwood Wash Project, 
Project Description, Magic Circle Energy Corporation, July 14, 1982. 



Synfuels Engineering and Development, Inc. 

13.1 The texts of the Air Quality Technical Report and the Final E1S have 
been modified to take into account appropriate monitoring data as it 
relates to TSP background analysis. 

13.2 Section 6.2 of the Air Quality Technical Report states, "Drainage, 
flows in the local area would carry emissions to the north and west." 
This statement is supported by the wind field modeling performed by 
Systems Applications Inc., for drainage flow conditions (see Figure 2- 
5, Air Quality Technical Report) which shows flow to the north toward 
the White River then turning westward toward the Green River. The 
VTN analysis considered topography only in the immediate vicinity of 
the site and would be applicable only for near ground-level releases 
of pollutants. For elevated releases, such a stack releases, 

mesocl imatological rather than microclimatological winds need to be 
considered due to the higher plume height and greater transport 

13.3 The Table M-l-5 footnote has been revised. 

13.4 Section M-4.B and Table M-2-2 have been revised to reflect the new 

13.5 Figure R-3-1 has been revised. 

13.6 Table R-4-20 is based upon general distribution maps furnished by the 
Utah Division of Wildlife Resources. Under the broad classification, 
islands or voids within the larger areas ar» not broken out. Impact 
analysis in Section M-4.A.5 indicates that Magic Circle project 
activities would disturb only 0.7 percent of this type of habitat, 
which is an insignificant impact. 

13.7 The riparian vegetation type as described for this project Includes 
the narrow riparian zone (floodplains of intermittent streams) of 
greasewood plant communities of the mixed-desert shrub type and 
bottomland sagebrush of the pinyon-juniper/mountain shrub type 
(Section R-3.A.4). 

13.8 Section M-4.A.4 has been revised. 

13.9 Table R-3-10 has been revised. 

13.10 Based upon sagegrouse distribution maps furnished by the Utah 
Oivision of Wildlife Resources (1981), a line demarking substantial- 
value, yearlong sagegrouse habitat goes through the southern portion 
of the lease site. 

13.11 The analysis used for the "hydropower" factor was, in fact, 
incorrect. This error stemmed from a mistake in the Energy Analysis 
Handbook (BLM 1982a) and has been corrected. 


With the new information provided, all the energy calculations have 
been recomputed, using the same method for all comparisons. Using 
the same assumptions used for the other projects, "Other Fuels Used" 
was calculated to be 3.980 trillion Btu's/year, which would only 
change the final efficiency 0.1 percent. One of the factors (product 
pipelines) used in the "Indirect Energy" calculation was low by a 
factor of 10. This resulted in a final efficiency of 52.9 percent 
rather than 55.3 percent as calculated by the comnenter. 

Section M-l.C.l has been revised. 

13.13 Section M-l.D.l has been revised. 

13.14 Section M-1.D.2, Table M-l-4, and Table R-l-10 have been revised. 

13.15 Sections M-l.E.l and M-4.B have been revised accordingly. 

13.16 Section M-1.D.2 has been revised. 

13.17 The Site-Specific Analyses Introduction has been revised. 

13.18 The Site-Specific Analyses Introduction has been revised. 

13.19 The Fischer Assay (FA), termed "the standard for the oil shale 
industry," is designed to assay the oil potential of geological 
deposits. It is not designed for process control nor process 
evaluation.. Yet, traditionally, the calculation "oil field, volume 
percent Fischer Assay" is used. The product split between oil and 
gas in the Fischer Assay does not relate to any known oil shale 
retorting process. The Fischer Assay is a laboratory test; heat is 
transferred through the reactor wall; it is a batch process in which 
the energy products are separated by cooling to degree C. 
(Heistand 1979) 

To calculate product yield, the following equation was used along 
with data supplied by the applicant. 

Product yield, % assay = 100% x (0 R + Gr) / (0/\ + Gft) 


Or + Gr = oil retort + gas retort = 123 
°A + G A = oil assay + gas assay = 126 


Product yield, % assay = 100 % x 126/123 = 102.4*. 

13.20 Section M-1.D.2 has been revised. 

13. Zl Table R-5-1 has been revised based on the Information provided by 

this commenter and others. Those mitigations committed to have been 
assumed in the analysis. However, where mitigation has not be 
committed to, the analysis has been affected, even to the use of 
worst-case analysis in some instances. National Ambient Air Quality 
Standards (NAAQS) have been added to Air Quality in order to fully 
address air quality changes. Water quality and vegetative production 
analyses indicate minor instances of improvement over present 
conditions but overall probable decrease in quality and production. 
Outdoor recreation has been modified to better indicate the benefits 
and trade-offs. As used in this document and, therefore, this table, 
cultural resources means archaeological and historical resources. 
Cultural amenities for fine arts and humanities are considered to be 
a component of socioeconomics and are considered in the analysis of 
quality of life and service infrastructure. 

13.22 A rupture of the Tosco Salt Lake City Alternative Product Pipeline 
rather than the Magic Circle product pipeline could affect the Ouray 
National Wildlife Refuge. This error has been corrected in Section R- 
4. A. 15 of the Final E1S. 

13.23 Tables M-l-1 and M-l-2 have been revised. 

13.24 The confusion may relate to the use of the term project area, which 
is defined as the lease area and all rights-of-way required for the 
proposed action (Site-Specific Analyses Introduction). In this case, 

erf the rights-of-way for the proposed action pipeline to Roosevelt would 

(N3 cross the White River and then the Green River near their 

confluence. The proposed action water pipeline would cross the White 
River and terminate at the Green River near the confluence of the two 
rivers. The proposed action product pipeline leading eastward would 
cross the White River on the Tosco lease area. 

13.25 Sections M-1.D.2 and M-4.A.8 have been revised to include the 
information provided about the wells and pumps. The amount of 
underbrush screening between the river and well and pump structures 
would determine the degree of impact. Concerning the old bridge 
structure, should the Green River be designated as a Wild and Scenic 
River, the bridge could be removed if it is found to diminish the 
river running experience. The bridge could also be considered to 
enhance the river running experience based on its historic value. 

13.26 This information has not been added to the EIS, because it does not 
alter nor enhance the impact assessment. The plant on the Magic 
Circle property is the only hookless cactus that has been located in 
the area of influence. 





Department ol Local Affairs y^3i 


Pal Ralliff. Director 

October 15, 1982 


Mr. Lloyd Ferguson 
District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 84078 


Dear Mr. Ferguson: 

Uintah Basin Synfuels Development 
Draft Environmental Impact Statement 

The Colorado Clearinghouse has received the above-referenced Draft Environ- 
mental Impact Statement and has distributed it to interested state agencies. 
Comments received from the Colorado Natural Heritage Inventory, Colorado 
Department of Highways, Colorado Historical Society, Colorado Geological 
Survey and the Colorado Division of Water Resources are enclosed for your 

Thank you for the opportunity to review this matter. 



Stephen 0. Ellis 
Chief Planner 

Office of the Governor 
Department of Highways 
Colorado Historical Society 
Department of Natural Resources 

1313 Sherman Street, Room 520, Denver, Colorado 80203 (303) 666-2156 


1550 Lincoln Street. Room 106 
Denver, Colorado 80203 
(303) 866-5887 




DATE: 13 OCTOBER 1982 





Pq. R-3-43, Table R-3-11 

Razor-back sucker ( Xyrauchen texanus ) 

State of Colorado. 

is considered Endangered by 




Pq. R-3-32 
Sclerocactus glacus 
Category 1 plant. 

is a Listed Threatened species, not a 

Chapter S-2, Pq. S-4-18 

This proposed alternative could have a negative impact on 
Raven Ridge, a registered Colorado Natural Area. This Natural 
Area should be considered in the document. Raven Ridge is also 
a proposed BLM Area of Critical Environmental Concern (ACEC). 



The Atrip! ex confertifolia / Elymus ambiquus plant community, 
a plant community of Special Concern for the State of Colorado, 
occurs 5-15 miles east of Rangely. This endangered vegetation 
type could occur in the project area in Colorado on Green River 
shale substrata. 




Grand Junction. Colorado 81502 
(303) 242-2662 

October 12, 




Mr. Stephen O. Ellis 

State Clearinghouse 

520 State Centennial Building 

1313 Sherman 

Denver, CO 80203 


Dear Mr. Ellis: 

The Department of Highways District Office has reviewed the 
Uintah Basin Synfuels Development Draft EIS and has the 
following comments . 

14.6 Jt is apparent from reviewing the Draft EIS that the cumulative 
impacts to the State highway system {and county roads) will 
be both significant and adverse — particularly to SH 64 
between Rangely and Dinosaur. SH 64 would go from a Level of 
Service of C to D, E or F even with the low scenario of energy 

We would note that there appears to be some erroneous traffic 
volume figures and level of service information presented in 
Tables R-4-24 and R-4-25. There would also be increases in 
congestion, accidents, road damage, deer/vehicle accidents 
and other adverse factors associated with increased traffic 
and heavy loads. 

To mitigate these impacts at least three major funding options 
are available , which are: 

1. Earmark a certain percent of the revenues (taxes) 
paid to the State from energy development companies 
to go for roadway improvements (state and 
county) . 

2. Require that energy development companies 
contribute to an escrow account for roadway 
improvements on a percentage basis , according to 
their size (impact) and as they come on line. 

3. Set up a special funding program at the federal 
level to pay for improvements resulting to 



Mr. Stephen O. Ellis 
October 12, 1982 
Page 2 

roadways which are impacted by the various 
federal leasing/subsidy programs. 

Of the above three options, the State can immediately use the 
first two options to mitigate energy development impacts. 

However, in the short term and to insure the mitigation of 
site specific impacts, all energy developments will be required 
to comply with the new State Access Code and fund improvements 
to the State highway system that result directly from their 
development projects (i.e./ replacement of substandard bridges, 
intersection channelization and signalization, adding climbing 
lanes, etc.)- But, it should be noted that these improvements 
will do nothing to improve or maintain an entire section or 
roadway or reduce accidents or congestion. 

We appreciate the opportunity to review this document. 

Very truly yours, 








Mo s ton/Sturm 






The Colorado Heritage Center 1300 Broadway Denver, Colorado 80203 
September 17, 1982 

Mr. Stephen 0. Ellis 

Principal Planner 

A-95 Clearinghouse 

523 State Centennial Building 

1313 Sherman Street 

Denver, Colorado 80203 

RE: Uintah Basin Synfuels Development, #82-116. 

Dear Mr. Ellis: 

The majority of the above proposed project is to take place 
in Utah, However, several pipelines may traverse parts of Colorado. 
Cultural resource surveys should be completed in those areas in 
Colorado where ground disturbing activities will occur. 

All cultural resources located in the impact area must be 
evaluated in terms of the National Register criteria, 36CFR60.4. 
The effect of the project is then determined for all those cultural 
resources eligible to the National Register. The above is done in 
consultation with this office. 

If this office can be of further assistance, 
Compliance Division at 866-3392. 

please contact the 





Arthur C. Townsend 

State Historic Preservation Officer 





DENVER, COLORADO 80203 PHONE (303)839-2611 


SEP 1C 1982 

Division of Locaf Government 

September 15, 1982 

Mr. S. 0. Ellis 

Colorado Clearinghouse 

Colorado Division of Local Government 

1313 Sherman St., Room 523 

Denver, CO 80203 

Dear Mr. Ellis: 

Re: Uintah Basin Synfuels Development, Draft EIS (EIS #82-116) 

He have received and reviewed this subject document. 

Because most of this EIS concerns impacts to be made in the Utah part 
of the oil-shale-development area, we think that a detailed review of 
this document by us is unnecessary and out of place. However, the 
effects of Utah oil -shale development will be felt in some extreme 
western Colorado communities and the assessment of these effects in 
this document, which make up only a small part of it appear, in our 
opinion, to be adequate. 



to. iW, 


/.fames M. Soule 
^Engineering Geologist 



Story of the past . . . key to the future 



Slate Engineer 



1313 Sherman Slreel-Roorn 818 

Denver. Colorado B0203 

(303) 866-3581 

October 14, 1982 

8 OCT 15 1982 

Division ol Local Government 


TO: Stephen 0. Ellis, State Clearinghouse 

FROM: Hal D. Simpson, Assistant State Engineer 

SUBJECT: Uintah Basin Synfuels Development, Draft Environmental Impact 

As requested, our office has reviewed the above referenced Draft Environmental 
Impact Statement. We believe the environmental impact statement is well pre- 
sented and adequately addresses the issues that concern our office at this 
stage of planning. 


cc: Wes Signs, Div. Eng. 

State of Colorado 

14.1 BLM appreciates the Colorado Clearinghouse coordination efforts. The 
comments provided were considered in revising the EIS. 

14.2 The comment is correct. However, it is net anticipated that the Utah 
projects would affect this species in Colorado. 

14.3 This error in Section R-3.A.1 has been corrected. 

14.4 Information about the Raven Ridge Natural Area has been added to 
Sections S-3.B and S-4.D. 

14.5 The plant community of special concern identified in the comment lies 
outside the area to be affected by the proposed projects and has not 
been identified within the affected area. 

14.6 It is unclear which data are erroneous. The numbers were checked and 
no errors were found. These data were obtained from Utah Department 
of Transportation (Traffic on Utah Highways 1977, 1979, and 1981) and 
Colorado Department of Highways (Colorado Traffic Volume Study 1980) 
to Tables R-4-24 and R-4-25. 

Section R-4.A.7 has been revised to include the other types of 
impacts that would be associated with increased traffic. 

The suggested mitigation has been included in Appendix A-7, 
Uncommitted Mitigation. 

The information regarding the requirements of the Colorado Access 
Code has been added to Section R-4.A.7. 

14.7 Surveys would be completed before BLM would permit disturbance on 
public land. BLM would coordinate any survey in Colorado with the 
State Historic Preservation Officer. 

14.8 BLM notes the assessment that the EIS analysis of impacts to western 
Colorado communities is adequate. 

14.9 BLM notes the assessment that the EIS adequately addresses the issues 
that concern the Office of the State Engineer. 






Rio Blanco County CourthouM 

Post offic* Box see 

Mteker, CO 61641 

f»3) 876-5061 

October 12, 1982 

Mr. Lloyd Ferguson 
District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, UT 84078 

Dear Mr. Ferguson: 

Thank you for the opportunity to comment further on the Uintah Basins 
Synfuels Development Draft Environmental Impact Statement. Enclosed are 
Rio Blanco County Colorado's comments and concerns regarding certain assumptions 
and findings in the EIS. I would also like to bring to your attention that 
those sections of the EIS directly pertaining to the Town of Rangely and the 
Districts in the Rangely areas have been forwarded to them directly for their 
review and comment. We will be submitting shortly a joint letter outlining 
our collective comments and concerns. 

On behalf of Rio Blanco County I would like to concentrate my comments 
specifically to assumptions made and data included in the sections on work- 
force allocations and population projections. 

I would first like to address the assumptions and findings of the "spatial 
allocation model" and the UPED model referred to in the EIS. The model does 
not appear to take into account that with the current advent and continuation 
of residential and commercial development now occurring in Rangely, Colorado 
(housing, shopping and recreation) that there will be more liklihood of Rangely 
becoming a more competitive and more attractive town for people to reside in 
and commute from. The EIS states that the Bonanza-Range ly road is insufficient 
to accommodate heavy levels of traffic and that county (Uintah) officials have 
indicated that they will not maintain this road for use by commuter traffic. 
Although, presently this road on the Utah side is in need of repair and main- 
tenance, Rio Blanco County has just this summer spent $200,000 improving the 
road from the Colorado border to Highway 64 just north of Rangely. The map 
referred to in the EIS as Map R-l-1 omits entirely the existence of the Bonanza- 
Rangely road. Any potential worker population allocation to Rangely depends 
considerably on the access provided by this road. 

Mr. Ferguson 
Page 2 




The "impedence factor" that the EIS attributes to this road does not take 
into consideration the possibility that as both synfuel projects Syntana-Utah 
and Paraho Development go into construction in the next couple of years, these 
companies themselves may opt to assist in improving and maintaining that small 
segment of the Bonanza-Rangely road that is close to their projects in Utah. 
This possiblity should not be ignored given the proximity of both Syntana and 
Paraho to the Colorado border and if improving the road would prove to be 
beneficial in planning transportation needs of their respective commuting work- 

On the same note the recently published Electric Power Research Institute 
February 1982 report "Socioeconomic Impacts of Power Plants" has some interestin 
observations regarding the utility of gravity models such as the spatial 
allocation and UPED models use in the Uintah Basin EIS. 

The report states: 

"Gravity models should not be used without a substantial 
amount of field work in the areas in order to assess the 
capability and desire of communities to attract and house 
construction workers and induced employees." 

In summary on this subject Rio Blanco County feels that the Uintah Basin 
Synfuels Development Draft EIS is substantially underestimating the potential 
population and workforce allocation in Rangely and therefore underestimating 
the coinciding impacts that would be felt. 

Regarding specific data and assumptions on population impacts made in the 
draft EIS Rio Blanco County questions the statement made on page 11-6 of the 
Socioeconomic Technical Report stating that "The impacts for Rangely are not 
significant using the criterion of an impact of 10% or greater as being signi- 
ficant". I believe the 10% figure is taken from a Jack Gilmore study that 
attributed certain impacts under certain conditions as significant at 10-15%. 
The Uintah Basin EIS interpretation of Mr. Gilmore's assessment is misleading. 
After discussion with Jack Gilmore and his associates and a closer reading of 
the report that the 10% figure is taken from^ it is apparent that impacts 
are greater in smaller rural communities where the basic infrastructure is 
nearer capacity. For any small community the rate of growth and corresponding 
"significance" as related to impact is entirely a function of that town's 
ability to absorb the growth and associated impacts. 

On the same subject of population impacts the Draft Technical Report 
Volumn II Socioeconomics states that the impacts for Rangely will not be 
significant using the criterion of 10% or greater as being significant. My 
concern with this statement is that it conflicts directly with the State of 
Utah's Impact Mitigation Law that stipulates 5% growth as its criterion for 
significant impact. Given that the State of Utah's Office of State Planning 
had a direct role in preparing the Draft Uintah Basin Synfuel EIS there appears 
to be a serious conflict in establishing a consistent growth impact criteria. 




Mr. Ferg 
Page 3 

Also, with regard to population impacts in the affected communities and 
counties I refer to Tables R-4-4 and R-4-6 on pages R-4-12 and R-4-16 re- 
spectively in the EIS. Table R-4-4 according to the UPED model projects a 
1985 baseline population of 3,193 for Rangely with an applicant (projects) 
increase of 577 for an 18.1% increase and an interrelated project increase 
of 82 for a cumulative increase of 659 people or a 20.6% increase. Similarly, 
in Table R-4-6 Housing Demand the UPED model shows a baseline household number 
in Rangely of 1,116 in 1985 with an applicant increase of 196 or 17.5%. With 
the interrelated project household demand included this number is increased 
by 28 for a cumulative total of 224 additional households needed and a 
corresponding 20. 1% increase for Rangely. 

Both of these tables appear to be substantially different in their data 
projections and conclusions from the data and assumptions made in the Draft 
Volumes 1 & 2 Technical Reports on Socioeconomics that show significantly 
lessor impacts for Rangely. Again, the statement that Rangely will not be 
significantly impacted based upon the 10% impact criterion seems to be 
seriously at odds with the conclusions reached in both Tables R-4-4 and R-4-6. 

Additional comments will be forthcoming regarding specific sections of 
the Draft EIS that more directly effect the Town of Rangely and the various 
special Districts in and around Rangely. 

Thank you for the opportunity t 
Draft EIS. 

:o comme 

;nt on the Uintah Basin Synfuels 


Mark Bubriski 


Department of Development 

Mr. Brad Barber 

Office of State Planning Coordinator 

State of Utah 

Rio Blanco County Department of Development 



BLM received comments on the Draft EIS from the Town of Rangely. 
They are letters 18 and 43. 

The Spatial Allocation Model (SAM) used in 
projections does take into account current 
availability of commerical and service acti 
In fact, the SAM model's main objective is 
economy and how it interacts with other are 
information concerning the future growth of 
activity in Rangely, the State of Utah has 
projections provided by the State of Colora 
projections (without synfuels development) 
Rangely's planned commercial and service de 
attractiveness of Rangely as a residential 
accounted for. 

allocating synfuels impact 
data concerning the 
vity in the Rangely area, 
to simulate the local 
as in the region. For 
commercial and service 
relied upon baseline 
do. If these baseline 
have adequately captured 
:velopment, then the 
community has been 

Another input into the spatial allocation model is the of a 
gravity model which examines distance between communities and new 
basic employment opportunities (e.g., the synfuels plants) and the 
size ofa community which serves as a surrogate for the 
attractiveness of the community. In examining distances to be used 
in the gravity model, highway engineers indicated that the road from 
Bonanza to Rangely could not accommodate large volumes of traffic. 
Therefore, the distance along the more indirect route to Rangely was 
used in calibrating the gravity model. This is not to say that 
workers will not use the Rangely-Bonanza road, but, rather, that the 
gravity model be calibrated based on the better transportation link 
which could accommodate large volumes of commuter traffic. 

It is conceivable that the Bonanza-Rangely road could be improved. 
However, it could not be assumed that the road would be improved. In 
fact, the Uintah Basin Transport ation Study (Van Wagoner and 
Assoc.iatesT^b'O) lists numerous transportation project improvements 
for the Uintah Basin over the next decade. No mention of plans to 
upgrade, improve, or maintain the Bonanza-Rangely road is found in 
this study. 

If the road is improved and the gravity model recalibrated, it would 
somewhat alter the projections, with increased traffic to Rangely. 
However, this change would not create a significant difference, 
because this was only one of many assumptions used in developing 
these projections. The Ashley Valley will continue to be the 
dominant attractor of population because of Us size, the 
availability of retail and service activity, and its'current 
investment in infrastructure. 

It should once again be noted that the gravity model is only one 
input into a much more comprehensive "Spatial Allocation Model." The 
inherent weaknesses of a gravity model are understood, and it is 
realized that there is no ideal technique for distributing impacts. 
All the communities in the area of influence have the desire to 
attract growth and are investing in infrastructure to accommodate 
growth. However, given the resources made available for this aspect 


of the modeling effort, the gravity model is acknowledged for its 
ability to incorporate important fundamental location factors. (For 
full discussion of all models used to project impacts, please see 
Appendix H of the Socioeconomics Technical Report (State of Utah 

The purpose of Map R-l-1 is to show the generalized location of the 
proposed projects. The Bonanza-Rangely road is shown on the three 
more detailed maps of the Uintah Basin (Maps R-A-1-, R-A-2, and R-A- 
3). However, because of the concern expressed, it has also been 
added to Map R-l-1. 

15.3 Substantial impacts have been projected for Rangely. Under any 
scenario, oil shale development is likely to double the size of 
Rangely and create a significant impact to the community. The 
statement in the footnote of Table SSA-4 (Socioeconomics Technical 
Report) that Rangely is not significantly affected is in reference to 
individual projects, which alone do not significantly affect 
Rangely. However, cumulative impacts definitely would significantly 
affect the community of Rangely under any scenario or under any 
definition of significance (see population figures for Rangely in the 
E1S, Table R-4-4). 

The 10 percent significance criterion was established by BLM based on 
a Denver Research Institute (1975) study by Gilmore and Duff. This 
study identified 10 percent as a general threshold level in which a 
govennent's ability to meet increased service demands breaks down 
(EIS Section R-3.A.1). The rate of growth and capacity levels of 
basic infrastructure have a direct bearing on a community's ability 
to absorb growth (or change) and associated impacts. The population 
and household site-specific impacts projected for Rangely and 
Dinosaur are presented in Table SSA-4 in the Socioeconomics Technical 
Report, even though they are less than 10 percent. 

15.4 In regard to the comments concerning Tables R-4-4 and R-4-6, it 
should be noted that population growth rates can differ with 
household growth rates. This occurs because, as evidence has shown, 
in-migrants from energy development are'younger and many times have 
differing household sizes than existing populations. Tables R-4-4 
and R-4-5 are not inconsistent. 

Given the available time and modeling techniques, the impacts from 
synfuels development on Rangely have been projected as objectively as 
possible. No bias is present simply because the communities lie in 
the State of Colorado. The latest available empirical evidence 
supports the EIS projections. The Bonanza Power Plant monitoring 
system indicates, out of a work force of 659, that no employees live 
in Rangely. The White River Shale Project indicates, out of a work 
force of 41 employees, only 3 employees or 7 percent are living in 
Rangely. The EIS projections for Rangely fall well within the range 
indicated by this data. 






October 18, 1982 

Mr. Lloyd Ferguson, District Manager 
U.S. Department of Interior 
Bureau of Land Management 
170 South 500 East 
Vernal, UT 84078 

Dear Mr. Ferguson: 

Paraho's Development Corporation feels that the Uintah 
Basin Synfuels Development Draft Environmental Impact 
Statement is generally well-written. Paraho's enclosed 
comments include: 

"Additional information concerning alternatives 
that have been presented in the Paraho-Ute 
Technical Report, and 

"General comments regarding the DEIS. 

We trust these comments will be helpful to the BLM, and 
are looking forward to the completion of the FEIS on schedule. 
Thank you for the opportunity to review and comment on the 

'Robert N. Heistand 
Vice President of 
Environmental Affairs 


183 INVERNESS DRIVE WEST • SUITE 300A • ENGLEWOOD, COLORADO 80112 • (303) 094-4949 - TWX: 910 931 2537 





Page No. 
1. xxvii 


4. R-l-1 


5. R-l-5 


The preface should recognize that 
the EIS presents site- specific and 
cumulative impacts in sufficient 
detail such that right-of-way and 
§ 404 (dredge and fill) decisions 
can be made for the projects 
analyzed on a site-specific basis. 

The "proposed action" of BLM and the 
Corps relating to the Paraho-Ute 
Project, should include all rights- 
of-way and permits (§ 404) now 
covered by the EIS. 

Potential Land Exchanges . Paraho 
Development Corp. should be identi- 
fied as the fourth applicant which 
has identified potential exchange 
areas in the site-specific section 
of the EIS for the Paraho-Ute proj- 
ect. (See Site-Specific Alterna- 
tives Section). Maps R-A-l, R-A-2 
and R-A-3 should be revised to show 
the additional lands described in 
the Paraho Site-Specific Alternative. 

Paragraph 2 of the Overview states 
that alternatives to the proposed 
projects are not included in the 
Regional Cumulative Analysis. We 
would suggest that the BLM include 
an analysis of a "no action alterna- 
tive" based on the assumption that 
the proposed actions for all of the 
applicants projects would be denied. 

Paragraphs 1 through 3 on the refer- 
enced page describe the "interrelated 
projects" included in the Regional 
Cumulative Analysis. Throughout the 
DEIS, it is unclear which interre- 











R-3-42 and 
R-3-43 and 


R-3-57 and 


lated projects are considered in the 
"area of influence" with respect to 
a particular resource. The BLM 
should clearly identify those speci- 
fic projects considered in its 
analysis of each resource being 
impacted in the EIS. 

The chart on page R-3-35 is deceiving 
as it would suggest that the identi- 
fied terrestrial and aquatic species 
have in fact been located on lands 
to be utilized by the projects 
identified. Section R-3.A.5 on page 
R-3-34 should state more clearly 
that the wildlife and aquatic species 
identified on the chart have not 
necessarily been located on the 
sites for the projects identified. 

Threatened and Endangered Species . 
Paraho, on the basis of its baseline 
data, is aware of no basis for the 
absolute worst case analysis con- 
tained in this section. If BLM has 
data which supports or requires such 
an analysis, that data should be 

Water-Oriented Activities. 


those river segments which have been 
recommended for inclusion in this 
system and which are pending further 
action, the EIS should note the 
authority of the Department of 
Interior or the Department of Agri- 
culture to impose appropriate safe- 
guards in the area in the event it 
is subsequently included in the 

Existing Land Use Plans . Please 
specifically describe the method by 
and time frame within which BLM land 
use management framework plans would 
be amended to avoid land use con- 
flicts with decisions made pursuant 
to this EIS. 





The last sentence of the third 
paragraph is inaccurate. It reads 
that "(t]he increment limits for 
these state categories are the same 
as the PSD Class I, II, and III 
increments for sulfur dioxide." 
While this is true for Class I and 
Category I increments, the Class 1 1 
increments differ from the Cate- 
gory I I increments, and the annual 
and 24-hour Class III increments 
differ from those of Category III. 

Since the draft does not predict the 
NAAQS to be exceeded in the areas of 
Flat Tops and Mount Zirkel, the 
phrase on the fourth to fifth line 
of the third paragraph, "it is pos- 
sible that significant impacts could 
occur," should be clarified or de- 

In the first full paragraph on this 
page, the draft states that EPA has 
notified the public that "secondary 
emissions do not include any emis- 
sions which come directly from a 
mobile source." Further, on page 
R-4-120, third paragraph, the draft 
states that " [n)ot all of those 
(secondary) emissions would neces- 
sarily be considered by EPA to 
consume increment . " Throughout the 
regional analysis for TSP, however, 
BLM assumes that emissions from 
mobile sources should be included in 
determining consumption of incre- 
ment. The BLM should resolve the 
inconsistency, preferrably by delet- 
ing the category of mobile sources 
from secondary impacts . See Tables 
R-4-12 and R-4-39. 

The DEIS describes a series of 
visibility analyses not only for 
Class I areas, but also for other 
areas of special concern, such as 









the Dinosaur and Colorado National 
Monuments, the Unitah and Ouray 
Indian Reservation, and the proposed 
High Uintas Wilderness Area. The 
draft should clarify that neither 
the federal nor state air acts 
require any visibility protection 
for other than Class I areas. Since 
none of the areas of special concern 
are Class I areas, the DEIS is much 
more conservative in analyzing 
visibility impacts than is currently 
required under federal or state law. 

Tables R-4-7 In the regional analysis, Tables 
to R-4-12 R-4-7 through R-4-12 and Pages 
and Pages R-4-34 through R-4-39 contain con- 
R-4-34 to centrations due both to the baseline 
R-4-39 andto the secondary growth effects 

of the projects . However, there is 
no mention in the report of develop- 
ment of a 1990 "no-action" emission 
inventory. Therefore, it must be 
assumed that some of the concentra- 
tions present from baseline sources 
are again included in the secondary 
concentration impacts. This addi- 
tive effect contributes to the large 
impacts estimated in these tables . 

R-4-56 The first sentence in the last 

paragraph on the referenced page 
should be revised to read as fol- 
lows: "loss of vegetation from 
construction and spent shale dis- 
posal piles would be temporary, 
since reclamation and revegetation 
practices would be initiated as soon 
as reasonably practicable after 
disturbance . . . '' It would be 
incorrect to state, that in all 
cases, reclamation and revegetation 
practices would be "intensively" 
initiated within one year after 
disturbance . 

R-4-92 Please describe the method by which 

the BLM arrived at the energy effi- 








ciency input and outputs identified 
in Table R-4-28 on the referenced 

No-Action Alternative . Please 
describe further how the no action 
alternative would be "intended to 
accommodate further definition (or 
firming up) of actual energy demands 
. . . as well as additional defini- 
tion of interrelated projects in the 
Uintah Basin." The meaning of this 
sentence is unclear. 

Table SS-2 contained on the refer- 
enced pages suggests that all pro- 
jects will require the permits 
identified on the Table unless 
otherwise noted. Paraho will not 
require the following permits and 
the Table should be revised to 
indicate the same : 

a) Resource conservation and 
recovery permit for treatment, 
storage or disposal of hazard- 
ous wastes; 

b) Permit for reinjection of mine 
water from either the EPA or 
Utah Department of Health; 

c) Air space permit and air space 
obstruction clearance from FAA; 

d) Permit to cross federal-aide 

e) Section 10 permit for struc- 
tures or work in or affecting 
navigable waters; 

f) Well drillers permit; 

g) Burning permit during closed 
fire season; 







h) Permit to treat hazardous waste 
issued by State Bureau of Solid 
and Hazardous Waste. 

The DEIS does not contain a discus- 
sion of the increased tax base for 
the impacted communities. Estimates 
of the increased tax base and the 
benefits associated therewith are 
appropriate for inclusion in the EIS. 

Throughout the DEIS and Air Quality 
Technical Report the word "baseline" 
frequently includes Moon Lake emi s- 
sions. These emissions would not be 
included within baseline under the 
PSD program because they consume 
increment. Including Moon Lake 
within the baseline in the vicinity 
of Paraho-Ute results in the over- 
predictions of 44 ug/m 1 TSP annual 
average and 175 ug/m 1 TSP 24 hours 
average. Monitored data from the 
Paraho site indicate that the TSP 
annual average actually is less than 
20 ug/m' and the 24 hour average 
less than 75 ug/m ] . 

Paraho has filed for most of the 
permits required for construction. 
Several of these applications have 
been approved. A list showing the 
status of permits is as follows and 
the EIS should be revised to reflect 
the same: 


Application Date 
Main Access Rd. May 1981 

Anticipated Approval 
Feb 1983 

Oil Pipeline 

Sept 1981 



Application Date 


Camp Access 

Rd. (Nov 1982) 


(Nov 1982) 

Exploratory Drilling 

July 1980 
Dec 1980 
Aug 1982 

Approved Aug 1980 
Approved Jan 1981 
Approved Sept 1982 


May 1982 

Anticipated Approval 
Nov 1982 

Hazardous Waste 

May 1982 

June 1982 
Generator Number 


(Oct 1982) 

Anticipated Approval 
Apr 1983 


Nov 1981 

Anticipated Approval 
Nov 1982 


Mar 1982 

Anticipated Approval 
Nov 1982 

Solid Waste 

May 1982 

Approved June 1982 
Approved Sept 1982 
(Operations ) 

Dam & Impoundments 

(Dec 1982) 

Alter Natural Stream 

May 1982 

Approved June 1982 

Wastewater Disposal 

(Dec 1982) 

Drinking Water 

(Dec 1982) 

Labor Camp Sanitation 

(Dec 1982) 

Building Permit 

(Dec 1982) 

Floor Service Sanitation {Dec 1982) 


22. P-l-9 


Construction, Operations, Mainte- 
nance, Abandonment. Insert after. 





"The general construction procedures 
that would be followed for this 
project are : " 

"- All construction procedures 
would be in compliance with 
local. State, and Federal regu- 

Surface disturbance would be 
restricted to areas only 
required for construction. 

Construction precautions would 
be taken during adverse weather 
conditions . 

Off-road vehicle travel would be 

As conditions require, eroision 
control devices e . e. dikes, 
berms, and bank stabilization 
would be implemented to control 
and minimize soil erosion. 

Upon completion of construction 
activities, all disturbed areas 
not required for permanent 
surface facilities would be 
reclaimed and revegetated in 
accordance with the reclamation 

Other construction procedures that would 
be implemented in order to minimize 
adverse environmental impacts are : 

During rights-of-way and site 
preparation, areas of surface 
disturbance would be minimized. 

Topsoil would be removed, stock- 
piled and protected. Topsoil 
would be replaced as soon as 
reclamation and revegetation 
measures can be implemented. 



23. P-l-13 










Measures to insure successful 
revegetation would be imple- 
mented such as, soil condition- 
ing, fertilizing, seed bed 
preparation, and suitable mulch- 

Disturbed areas would be seeded 
with adapted and/or native plant 
species . 

A maintenance and monitoring 
program would be implemented to 
ensure successful revegetation." 

Project Components . Add the 
following new paragraph: 

" Above Ground Fines Storage 

Raw shale reject materials would be 
stored on Section 32. The storage 
area presently is a natural, 
bowl-shaped depression that faces 
towards the south and has a storage 
capacity of approximately 17 million 
cubic yards. The present elevation 
of the topography surrounding the 
storage area ranges from 5700 feet 
on the north to 5400 feet on the 
south. The final elevation of the 
shale fines pile would be approxi- 
mately 5700 feet. " 

480,000 mmcfd should be 480 mmcfd. 

385,000 mmcfd should be 385 mmcfd. 

Natural Gas: 29,000 mmcfd should be 
29 mmcfd. 

Socioeconomics . Paraho believes 
the majority of socioeconomic 
impacts resulting from the Paraho - 
Ute project would occur in Uintah 
County, with some in the Colorado 
area . Much less impact is expected 





28. P-3-1 

29. P-3-3 

30. P-3-4 


in Duschene County and the Uintah 
and Ouray Indian Reservation. 
The condition of the road between 
Bonanza and the Colorado state line 
would not preclude commuter travel 
on this road. Although Paraho 
agrees with BLM's conclusion of 
reduced population allocation for 
the Colorado area we do not feel the 
road condition is the major cause. 
We feel a major factor will be the 
existing infrastructure available in 
the Vernal area (stores, shopping 
centers, restaurants, churches, 
etc . ) . Residence profiles of the 
American Gilsonite workforce and 
Bonanza Power Plant construction 
workforce confirm the BLH population 
impact projections. 

Water Resources . Specific descrip- 
tions of the affected water bodies 
should be included in this section. 

Threatened or Endangered Species . 
Although the U.S. Fish and Wildlife 
Service has indicated that several 
federally listed species could occur 
in the project area, this section 
should specifically note that no 
species have, in fact, been located 
on the Paraho-Ute site. 

Cultural Resources . This section 
should be revised as follows: 

" Prehistory 

The Paraho project area lies within 
the Uintah Basin of the Colorado 
Plateau as described in Section 
R-3.A.10, Cultural Resources. The 
lease tract and approximately 9 
miles of access road, pipeline and 
utility corridor were surveyed by 
Nickens and Associates (Tucker 1980; 
Tucker 1982). No prehistoric sites 


were identified by them in these 
areas . The survey report concluded 
that the Paraho project area was 
rarely used by prehistoric peoples. 
This conclusion is supported by 
other work in the area that corre- 
lates in low site density with 
desert shrub vegetation ( Jones and 
MacKay 1980; Larralde and Chandler 
1981). No prehistoric sites were 
found along the White River in the 
Paraho lease area. 


The general history of the area is 
included in Section § 3. A. 10, Cul- 
tural Resources. One historic site 
and three isolated artifact finds 
were recorded during the Nickens and 
Associates investigations (Tucker 
1980; Tucker 1982). Background 
information the historic site can be 
found in Russell (1980). 

The historic site is the remains of 
the Ute Oil Company shale retort 
facility, which is located on the 
north bank of the White River on 
Section 7, on the Paraho sub-lease. 
It was under construction between 
1917 and 1922, but never began 
operations due to a variety of 
financial, material and construction 
problems. It was the largest 
shale-retorting facility under 
construction at the time. 

The Ute Oil Company site is recom- 
mended for nomination to the National 
Register of Historic Places (Tucker 
1982) . 

The three isolated artifact finds 
contained glass fragments and tin 
cans. A purple glass fragment and 
three hole- in- top cans date the 







finds between I860 and 1920. The 
artifacts are probably associated 
with gilsonite mining or sheep- 
herding activities in the area." 

Paleontology . This section should 
be revised to read as follows : 

" Pa leonto logical investigations have 
been conducted for the Paraho pro- 
ject lease area, access roads, pipe- 
line corridor, and portions of the 
utility corridor. These investiga- 
tions located several vertebrate, 
invertebrate and paleobotanical 
fossil specimens in outcrops of the 
Uintah and Green River Formations 
(Madsen and Nelson 1980; Madsen 
1981). The fossils are not of 
scientific interest because they are 
poorly preserved and commonplace. 
Their presence, however, indicates 
that other, more important fossils 
may exist subsurface." 

The third line "Increment consump- 
tion including baseline" is mis- 
labeled, and should correspond to 
Table 6-1 in the AQTR, where it is 
specified this increment includes 
only Moon Lake Unit 1. Since this 
table gives increment consumption 
for Paraho only, this line should be 
left off. 

A footnote defining "baseline" would 
be helpful; the term should be used 
in a consistent fashion . 

Why doesn't "Paraho Impact" SO ? 

agree with "Paraho Increment con- 
sumption" on the previous table? 
Changing the 3- and 24-hour numbers 
on this table to 317 and 40 would 
make them agree and make the "Total" 
column correct. 




Groundwater . This section should 
be revised as follows: 

"The proposed mine shafts could 
encounter a more premeable zone 
of the Bird's Nest Acguifer. 
However, on-site coring tests in 
the mine zone were dry and the 
mine shafts will be sealed in 
any event. Therefore, dewater- 
ing of the mine will not be 
necessary. " 

Recreation . Identify, specifically, 
the three miles of the White River, 
described in the second paragraph, 
which will be "permanently lost" 
from further consideration as a 
national wild and scenic river. 
Further, state whether this river 
segment is presently included in 
the inventory for inclusion in the 
wild and scenic river system. If 
such river segment is not included 
in the present inventory, any refer- 
ence to the wild and scenic river 
system should be deleted. Finally, 
if reference to this three mile seg- 
ment of the White River must be 
included in this section, the abil- 
ity of the Department of Interior or 
the Department of Agriculture, as 
the case may be, to protect the area 
and the river, should it ultimately 
be designated for inclusion in the 
wild and scenic river system, must 
be noted. 

Cultural Resources . The Paraho 
project would cause land modifica- 
tion that could adversely affect 
cultural resources as described in 
Section R-4.A.9, Cultural Resources. 
The historic site of the Ute Oil 
Company retort will not be disturbed 
by any Paraho activities. The lease 
area and approximately 9 miles of 








38. R-I-l 

39. SS-A 

40. AQTR-2-15 

41. AQTR-4-31 
and 4-44 

access road, pipeline and utility 
rights-of-way have been surveyed for 
cultural resources in compliance 
with 36 CFR 800, E.O. 11593 and 
other historic preservation legisla- 
tion. The remaining rights-of-way 
would be surveyed and evaluated for 
significant cultural resources. 

There is a discrepancy between the 
Paraho emissions in Table R-G-l and 
those given on pages P-l-11 and 
P-l-26. The emissions in Table 
R-G-l are those assumed for the 
UBS-DEIS analyses. Table P-l-6 
corresponds to the approved PSD 
Paraho emissions after the UBAQ 1 s 
BACT analysis. Since modeled emis- 
sions are higher than permitted 
ones, results should be conservative. 

BLM should list mitigation measures 
for air quality impacts (for 
example, pave dirt roads, restrict 
wood stoves (page 5-127 AQTR), 
restrict off-road use, etc). 

The conditions specified in this 
Appendix should be recognized in the 
EIS as general and not site-specific 
or process-specific. They should be 
viewed as a basis for negotiation on 
a case-by-case basis. 

The last line on this page should 
read ". . .measured one mile from 
the proposed site. . ." 

The secondary emissions calculated 
from the use of dirt roads in the 
impacted counties seem high. The 
fugitive dust emissions from motor 
vehicles in Uintah County alone are 
estimated to be nearly 50,000 tons/ 
year in 1980 and over 100,000 tons/ 
year in 1990. The 1980 values may 
be part of the reason the baseline 
























STR 1-127 
and 1-176 

STR 1-130 
and 1-133 

STR 1-130 

levels are too high. However, the 
huge exceedances predicted for the 
future scenarios also imply that 
some estimates are too large; it 
seems reasonable that the more 
frequently used dirt roads in the 
area would be paved. These predic- 
tions give the report an overall 
negative outlook for the development 
of these projects, when it is 
actually a solvable situation. 

These sections should clarify whether 
the direct low or high-level scenario 
project impact, the interrelated 
projects impacts or cumulative 
impacts are being discussed. The 
DEIS fails to identify clearly which 
scenario is being considered. 

1% annual change numbers should be 
explained. It is unclear how these 
numbers were derived. 

The percentage of employees estimated 
to live in construction housing 
onsite during the high-level scena- 
rio (p. STR 1-176) is not consistent 
with the description in the text of 
75% camp residency (p. STR 1-127). 

The STR text (p. STR 1-133) should 
reflect the data in table R3A-2. 
The employment multiplier derived 
from the table is 1.7, which is not 
consistent with the 2.14 employment 
multiplier stated in the text. 

Employment Impact - Basic in 1987 
should be 7,950 per Table R3A- I on 
p. STR 1-125. 




47. STR 1-137 

SIR 1-178 

STR 11-68 
and 11-69 

Employment Impact - Basic in 1987 
should be changed to 7,800 per Table 
R3A-I on p. STR 1-125. 

Employment Impact - Basic in 1992 
should be changed to 12,915 per 
Table R3A-16 on p. STR 1-176. 

The numbers in the text do not seem 
to correspond to the numbers listed 
in Table P-3 . 





Madsen, J.H., Jr. 1981. Supplementary paleontoloq ical survey report 
for the Paraho-Ute project site, Uintah County, Utah. 

Montrose, Colorado: Nickens and Associates. 

Russell, P.L. 1980. 
New Jersey: 

History of western oil shale. East Brunswick, 
The Center for Professional Advancement. 

Tucker, G.C., Jr. 1982. A cultural resource inventory of lands for 
the proposed Paraho Commercial Shale Oil Project, Uintah 
County, Utah. M ontrose, Colorado: Nickens and Associates. 



Paraho Development Corporation 

16.1 While every effort is being made to coordinate the EIS effort with 
the environmental assessment needs of all agencies with authorizing 
actions {refer to the Authorizing Actions section of the Site- 
Specific Analyses Introduction), some agencies, such as the Corps of 
Engineers (agency responsible for granting Section 401 permits), 
require surveyed locations of facilities prior to making decisions. 
This EIS does not analyze impacts of surveyed locations, because this 
level of engineering detail currently is not available. When a 
surveyed facility location is identified, some agencies may require 
additional site-specific analyses. 

16.2 The meaning of tiie comment is unclear. The BLM-preferred alternative 
identified in the Draft EIS for the Paraho-Ute project was selected 
based on a review of the impact analysis presented for the proposed 
project and its alternatives. This EIS is not the document to 
specify whether the Corps of Engineers would grant a Section 404 
permit or the specific location of a permitted action. 

16.3 Rased on the new data provided to BLM during the Draft EIS public 
comment period, a new alternative (Additional Lands Alternative) has 
been analyzed in the Final EIS. The EIS Preface has been revised 
accordingly. However, because Maps R-A-l, R-A-2, and R-A-3 were not 
reprinted, the Additional Lands Alternative is only shown on Map P-l- 
2 in the Final EIS. 

16.4 The purpose of the Regional Cumulative Analysis (renamed the Nine- 
Project Cumulative Analysis in the Final EIS in order to correct the 
confusion created by the original term) is to analyze the impacts 
that would result should all the applicants' proposed projects and 
the interrelated projects planned for the Uintah Basin be developed. 
The concept of no-action does not relate to a cumulative impact 
analysis, only to no-action as one of a range of alternatives to the 
proposals. A no-action alternative has been analyzed for each of the 
site-specific projects (Section R-l.A, paragraphs 1 and 2). 

16.5 All the projects listed on Table R-l-2 and R- 1-3 were Factored into 
the analyses for all resources. However, due to the location and/or 
nature of some of the interrelated projects, the interaction for some 
resources was considered to be negligible or nonexistent. This point 
has been clarified in a note for Table R-l-3. 

16.6 A footnote has been added to Table R-3-11 in Section R-3.4.5 to 
clarify how the project determinations were made. 

16.7 The sections identified in the comment include general regional 
statements and are not site-specific. The only threatened and 
endangered species mentioned in the EIS as possibly being affected by 
the Paraho project are three fish species that might be affected by 
the water diversion (Section P-4.A.5). 

16.8 The authority of the Department of the Interior has been cited in the 
text as references NPS 1982, Fede ral Register 1980a, and provisions 
under the Wild and Scenic River Act. 

16.9 The land use planning amendment process and the EIS are being 
completed simultaneously. Both processes include notices of intent, 
public involvement, analysis of alternatives, and a decision upon 
completion. If a decision is made to amend the plan and issue the 
desired right-of-way grants, a notice will he published announcing 
that action. This is followed by a 30-day protest period after which 
right-of-way grants can be issued, if the amendment is not 
protested. Right-of-way grants could be issued as early as 60 days 
after publication of the Final EIS. For additional information, see 
43 CFR 1601. 6-3b. 

16.10 A correction has been made in the Chapter R-4 Significance Criteria 
section of the Final EIS to properly reflect the relationship between 
the federal PSD Class I, II, and III and Colorado Category I, II, and 
III. The Category II and III incremental limitations are more 
stringent as they appear in Colorado regulations promulgated in 
1977. Colorado law now restricts the enforcement of more stringent 
incremental limitations than those of the federal regulations. 
Therefore, the SOj increment limits enforceable by the State of 
Colorado are the same as the federal PSD Class I, II, and 111. 

16.11 The NAAQS and PSD limitations were used as guidelines for assessing 
significance of impacts, as discussed in the Chapter R-4 Significance 
Criteria section of the EIS. Because the range of uncertainty in the 
calculated ground level concentrations brackets the incremental 
limitations of PSD Class I, it cannot be said unequivocably that the 
PSD Class I limitation would be exceeded. Therefore, it was 
indicated that significant impacts could not be ruled out. If 
subsequent detailed modeling performed during the PSD permit 
regulatory procedures determined that the requirements were to be 
exceeded, the position of the Forest Service on the significance of 
the impacts would be determined before a permit could be approved or 

16.12 In their comments on the Draft EIS, the EPA (letter 44) and State of 
Utah (letter 21) have indicated that under current PSD regulating 
requirements, secondary emissions from the facilities are to be 
considered when calculating emissions from the source. The Federal 
Registe r notice of June 25, 1982, does not allow fugitive dust 
created by mobile sources to be excluded as secondary emissions. The 
notice specifies that only those emissions that come directly from a 
mobile source, such as tailpipe emissions, may be excluded. Under 
current regulations, therefore, it is not possible to exclude 
secondary emissions from increment consumption. This point has been 
clarified in Section R-4. A. 2 of the Final EIS. 

The EPA Region VIII also has indicated: 

The predicted National Ambient Air Quality Standards 
(NAAQS) and Prevention of Significant Deterioration 
(PSD) Class II increment violations for Total 
Suspended Particulates (TSP) would not be allowed to 
occur. However, the primary cause of the high TSP 
values appears to be windblown dust and this fact may 
allow for the use of a lower background TSP value when 



calculating air quality impacts from the proposed 
projects. Approval for the use of lower TSP 
background values would be given on a case-by-case 
basis when companies are applying for PSD permits. 
(All applicants siting in Utah would apply to the 
State for their PSD permits.) This approach is 
consistent with EPA's fugitive dust policy. A 
prediction of a NAAQS violation after discounting for 
rural fugitive dust would likely lead to a permit 
denial unless the company could find additional ways 
of reducing TSP emissions to bring ambient values down 
below the NAAQS. Other options exist for ameliorating 
PSD Class II violations including redesignation of the 
areas as Class III . 

16.13 It is true that present regulations provide visibility protection in 
Class I areas only. This is discussed in the Chapter R-4 
Significance Criteria section. The discussion of visibility impacts 
in Section R-4. A. 2 has been expanded to further explain Class I 
visibility protection and relationship to other Class II areas of 
special concern. 

3LM does not agree that the EIS is much more conservative in 
analyzing visibility impacts than is currently required under federal 
or state law. The Clean Air Act, Section 165e(3)(B), requires "... 
an analysis of the ambient air quality, climate and meteorology, 
terrain, soils and vegetation, and visibility at the site of the 
proposed major emitting facility and in the area potentially affected 

by the emissions from such facility " PSD regulations for state 

implementation plans also require a visibility analysis that is not 
restricted to Class I areas only ( Federal Re gister, Vol 43, No. 
118, page 26380, June 19, 1978). In add i t i on "the National 
Environmental Policy Act requires EISs to consider a broader range of 
issues that includes any potentially significant impacts to the 
environment, including those not required by other laws. 

16.14 Concentrations from baseline sources are not included in the 
secondary concentration impacts. Similarly, secondary impacts, 
generally emissions resulting from increased population, are not 
included in the baseline. The concentrations given under the heading 
"Increment Consumption Above Baseline" in Tables R-4-7 through R-4-12 
include primary and secondary emission impacts only from the 
applicants' and interrelated projects. Thus, no baseline sources are 
counted twice. 

16.15 Section R-4.A.4 has been revised. 

16.16 The energy efficiency inputs and outputs were derived using the 
procedures identified in the Energy Analys is Hand book for 
Prep aration of_ _0i_l__SJ^alj; _Deve ldpinen t Environmental Impact Statements 
(BLM 1982a)" (EIS Section R-4~ .A. 1317*" 

16.17 Predictions of future energy demands, in general, and demands for 
shale oil, in particular, have been questioned due to recent trends 
in energy consumption and economic growth. Denial of the requested 
rights-of-way would provide additional time for the strength of 
current trends to be analyzed. Additional time would also aid in 
identifying which of the interrelated projects listed in Tables R-l-2 
and R-l-3 were most likely to be developed. 

16.18 Tables SS-2 and SS-3 have been revised to clarify that Paraho would 
not require the permits identified in the comment. 

16.19 Projecting the increased tax base would be an initial step in 
projecting revenue levels. Similar projections of expenditure levels 
would also be needed to show the cost side of the fiscal analysis. 
Revenue and expenditure level projections are appropriate for 
inclusion in EISs. However, they were not made in this EIS, since 
this would be an integral part of the detailed mitigation process 
required under S.B. 170 in Utah. A discussion of the likelihood of 
long-term beneficial fiscal effects associated with the increased tax 
base has been added to Section R-4.A.1. 

16.20 The word "baseline" as used in the EIS is not meant to be the 
"baseline" defined in PSD regulations. The EIS baseline refers to 
the environmental conditions expected to exist without any of the 
applicants' proposed projects being developed (refer to the Chapter R- 
3 Introduction). 

It is true that the Moon Lake power plant consumes some of the PSD 
increment— about 1 and 0.02 ug/m3 for the maximum 24-hour average 
and annual average TSP concentrations, respectively, at the Paraho 
site. The assumed baseline TSP concentrations of 175 and 44 ug/m3 
were calculated on the basis of estimated TSP emissions, primarily 
from unpaved roads, and an empirical model that relates emissions and 
ambient concentrations. The Air Quality Technical Report and Final 
EIS Jiave been revised to use measured TSP baseline values near the 
Paraho site and other sites where such data are available. 

16.21 Section P-1.B.2 has been revised to include all permits that had been 
applied for as of November 30, 1982. 

16. ?.Z Section P-l.D.l has been revised to include the first six items 

identified in the comment. The last five items were not included, 
because they are identified in Appendix A-8, which is referenced in 
the EIS. 

16.23 Section P-1.D.2 has been revised. 

16.24 The numbers in Section P-1.D.2 have been revised. 

16.25 The Bonanza Power Plant and American Gilsonite employee information, 
as well as the relative complexity of the infrastructure and 
availability of resident-serving industries in Vernal, Rangely, and 
Dinosaur, were considered in developing the population impact 
projections presented in the EIS. Assumptions concerning the 
transportation network are only part of the input into the gravity 



model which, in turn, are only part of the input in the Spatial 
Allocation Model which is employed to allocate impact information on 
the regional economy (available retail and service activity) and the 
interactions between the sub-areas of the local economy. Vernal 
serves as the regional trade center and many goods and services are 
available in Vernal which are not available in the smaller 
communities . This fact definitely affects the allocation of total 
population impacts among the communities in the study area. 

It should also be noted that although the Vernal area is projected to 
receive the majority of the impacts associated with the development 
of the synfuels projects, the ability of Vernal to accommodate the 
enormous growth associated with the high or even the low scenario is 
questionable. Communities would have to assist in the accommodation 
of this growth. The Roosevelt area in Duchesne County, because of 
its size and availability of services, is likely to receive spillover 
from the Vernal growth, as would the communities of Rangely and 

16.26 Specific descriptions of the water bodies were not included in 
Section P-3.A.3 in order to reduce duplication of material within the 
EIS. The affected bodies are simply a smaller portion of the Green 
and White rivers, which are described in Section R-3.A.3. 

16. 27 Section P-3.A.5 has been revised. 

16.28 Section P-3.A.9 has been revised. 

16.29 Section P-3.A.11 has been revised. 

16.30 The line "Increment consumption including baseline" is correct. It 
corresponds to Table 6-7 of the Air Quality Technical Report. The 
line in Table 6-7 reading "Impact with Moon Lake Unit 1" gives the 
cumulative impact of Paraho and Moon Lake Unit 1. In this case, the 
time period of maximum impact from the Paraho project had very little 
impact at the same location as Moon Lake Unit 1. Therefore, the 
cumulative impact is only very slightly more than the impact 
considering the Paraho project alone. 

16.31 The "total" values were incorrectly given as "Paraho Impact." Paraho 
Impact should read 317 and 40 for 3-. and 24-hour concentrations. 
This has been corrected in the Final EIS. 

The use of "baseline" is discussed in the response to Comment 21.20. 

16.32 Section P-4.A.3 has been revised based on the information provided. 

16.33 The three-mile segment is the segment that would be affected by 
Paraho's proposed side canyon benching for the spent shale disposal 
site adjacent to the White River as described in Section P-4.A.8. 
Section P-3.A.8 refers the reader to Section R-3.A.8 which states, 
"The White River from the Colorado-Utah state line to its confluence 
with the Green has been identified as an Inventory River Segment 
which meets the criteria for study for inclusion in the National Wild 
and Scenic Rivers System (NPS 1982)." 

Under the provisions of the Wild and Scenic Rivers Act, the proposed 
side canyon benching could be considered incompatible with potential 
Wild and Scenic River designation for the three-mile segment in 
question. Actions on private lands, over which the Department of the 
Interior has no control, could preclude the indicated segment from 
inclusion in Wild and Scenic Rivers System; therefore, the Department 
of the Interior would not be involved In protecting river resource 
values with regard to Wild and Scenic River designation for this 
segment. The remaining 65 miles of the 68-mile inventoried segment 
could be eligible for inclusion into the Wild and Scenic Rivers 
System, excluding other proposed projects. Refer also to the 
response to Comment 16.8, above. 

16.34 Section P-4.A.9 has been revised. 

16.35 The emissions given in Table P-l-6 were not available when the air 
quality modeling was performed. BLM concurs that the analysis 
results are conservative because the assumed emission rates were 
higher than the 8ACT emission rates. The reason for the discrepancy 
in numbers included in Chapter P-l and Appendix A-5 (Draft EIS 
Appendix R-G) has been clarified in Appendix A-5. 

16.36 A section on air quality has been added to Appendix A-7. 

16.37 Appendix A-ll (Draft EIS Appendix SS-A) is intended to provide 
standard, not site-specific, provisions for mitigating impacts. Some 
of the measures may be negotiated with the permitting agency; 
however, the agencies who submitted these general measures did not 
indicate the need for negotiating these measures. Although these 
general measures are not' legally binding, they are typical of the 
type of mitigation that likely would be incorporated with the legally 
binding right-of-way grants and other permitting actions which 
typically have specific stipulations. 

16.38 Section 2.3 of the Air quality Technical Report has been revised. 

16.39 As discussed in Section, there is a large uncertainty in the 
estimates of particulate matter from unpaved roads; one reason for 
this uncertainty is that an unknown number of miles of road are 
likely to be paved in the future. However, BLM is unaware of any 
commitments to pave dirt roads in the region, and notes that the 
costs for paving a significant number of miles of road would he 
substantial . 

The best information from the Utah Department of Transportation was 
used to estimate baseline and future unpaved road emissions. 
Although these particulate matter emission rates are large, new 
information for estimating emissions is necessary to develop a 
revised emission rate for this source. 

On the basis of a comparison of observed and calculated 
concentrations in the Uintah Basin, our best-estimate calculation 
(using the empirical model described in Section 2 of the Air Quality 
Technical Report), may be too high by about a factor of 2. This 
conservatism may have resulted from overestimates of the TSP 

emissions or from the stated uncertainty of the model. Elevated TSP 
concentrations would probably not be observed far from unpaved roads; 
it is possible that the model estimates are overpredictions of 
typical ambient TSP concentrations. 

16.40 Within the Draft Socioeconomics Technical Report, pages 1-152 to I- 
174 cover only low-level scenario impacts as labeled. The high-level 
scenario impacts are discussed on pages 1-175 to 1-219 as labeled. 
The low-level or high-level project impacts, interrelated project 
impacts and cumulative impacts are given within specific tables 
(i.e., housing, education). 

16.41 The percentage annual changes in Table R2C-3 on page 1-98 reflect 
three different periods of analysis. The first column, % 1981/1979, 
reflects the annual growth rate between 1979 and 1981. The second 
column represents the annual growth rate between 1977 and 1979 and 
the third, between 1977 and 1981. 



16.42 Page 1-127 of the Socioeconomics Technical Report states that 
approximately 75 percent of the construction work would be housed in 
construction camps. This percentage applies to the low-level 
construction work force numbers on page 1-125 (1,430) and the high- 
level construction work force (2,075) on page 1-176. This 
information was derived directly from information provided by Paraho 
in a letter dated January 22, 1982. 

16.43 The employment multiplier discussed on page 1-133 is correctly 
calculated at 2.14. This multiplier is derived from the information 
in Table R3A-2 on page 1-130. The multiplier is derived by dividing 
total employment impacts (12,810) by basic employment (6,000). The 
2.14 multiplier may approximate 1.7, but it must be recognized that 
the process by which the multiplier concept works is a dynamic 
process and can increase over time. 

16.44 In Table R3A-2, basic employment for 1987 should be 7,950 per Table 
R.1A-1. Also, basic employment in 1990 should be 5,775. These errors 
have been corrected. 

16.45 Table R3A-6 is correct as is; the error lies in Table R3A-1. The 
Uintah Basin total for construction--non-camp should be 1,215, which 
makes total basic employment 6,430 for Uintah County. This error has 
been corrected. 

16.46 Table R3A-17 is correct as is; instead, the error lies in Table R3A- 
16. Total employment for 1992 should be 11,940. This error has been 

16.47 The text of the Socioeconomics Technical Report (Chapter P, Health) 
has been changed from two to one additional ambulance. 





una«j 9Mm 


0«p«r1nwnt o* 







P. 0. Box 11350 

Salt Lake City, Utah 84147 

October 14, 1982 

Lloyd Ferguson, District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 84078 

Dear Mr. Ferguson: 

We have reviewed the draft environmental impact statement on the 
Uintah Basin Synfuels Development prepared for the Bureau of Land 
Management August 1982. Following are our comments: 

1. On page xxxi and Table R-4-18, it is stated that 
there will be an increase of 5 mg/1 at Imperial Dam. 
The impact this will have on the Colorado River Basin 
Salinity Control Program needs to be addressed. 

2. The impacts on wetlands need to be addressed. On page 
R-4-73 the reduction 1n cropland is addressed, however, 
irrigation on these areas support wetlands both in crop 
fields and in return water areas. 

3. No mention is made of alternatives to obtaining water 
from the White River Dam. If any wholesale or supple- 
mental purchase of irrigation water rights were made 
the impact on agricultural land and associated wetlands 
could be significant. 

Thank you for the opportunity to comment on the Environmental Impact 

>\ Tn» got cSmm mi 

State Conservationist 


Vernon Hicks, Natl Environ. Speclst, Wash. DC 
Charles Lemon, Director, WNTC, Portland 
DaleHanberq, DC, Roosevelt 

U.S. Soil Conservation Service 

17.1 Changes in salinity are stated for several locations (Table R-4-18). 
The impacts that this will have on the Colorado River Basin Salinity 
Control Program will either be in dollars of damages or increased 
need to desalt water. Section R-4.A.3 identifies salinity would 
increase up to 8 mg/1, with a 1985 to 2000 average increase of 5 mg/1 
and explains a 1 mg/1 increase could cause damages of $472,000. 

17.2 No proposed project facilities would cross, or be located on, 
wetlands. The somewhat poorly drained areas bordering the irrigated 
croplands and occurring along the Duchesne, Uintah, and Green rivers 
are used mainly for pasture and hay production and are considered as 
cropland in this EIS. Refer to Sections R-4.A.6 and M-4.A.6 for 
discussion of impacts. 

17.3 The alternative of obtaining water from the Green River, either 
through direct withdrawal or purchase from a holder of an existing 
water right, was analyzed for each of the site-specific projects 
(Sections E-4.C, E-4.E, M-4.A, M-4.E, P-4.B, S-4.B, and T-4.D). 







P.O. BOX 580 


Phone 303/675-8476 




October 19, 1982 

Mr. David Moore 
Vernal District Office 
Bureau of Land Management 
170 South 500 East 
Vernal , UT 84078 

Re: Uintah Basin Synfuels Development Draft Technical Report, August, 1982, 
(Socioeconomics): Comments of Town of Rangely, Rio Blanco County, and 
Districts of Western Rio Blanco County, Colorado. 

Dear Mr. Moore: 

The Town of Rangely, Colorado wishes to convey the following comments relative 
to the Socio-Economic Technical Report for the Uintah Basin Synfuels Environ- 
mental Impact Statement , dated August, 1982, and submitted by the Utah State 
Energy Office. Appended to this letter are statements by Rio Blanco County, 
Rangely School District Re-4, Western Rio Blanco Metropolitan Recreation 
and Park District, and Rangely Junior College District. These statements 
supplement original testimony given by Rio Blanco County and the Town of 
Rangely at a hearing conducted in Rangely, Colorado on September 15, 1982. 
Our comments are specifically directed to the social and economic impacts 
projected for Rangely and Western Rio Blanco County. 

Data Collection and Analysis Methodologies 

A. Lack of Current Dates . 

Town, County, and Districts' staff acknowledge that no direct personal 
contacts were made during data-collection; phone surveys were the principal 
source of information. Data references do not accurately represent current 
population and housing conditions in Rangely and Rio Blanco County. There 
are no apparent references to the use of official documents. Some information 
provided by Town Staff has been inaccurately applied. Appended are copies 
of reports prepared through the Rangely Community Development Office which 
represents the most current data available. 

B. Lack of Uniform Analysis . 

The bulk of the socio-economic analysis is directed at Uintah and Duchesne 
Counties, Utah, and not toward Rangely. Almost without exception, Utah 
Counties and municipalities are analyzed with a degree of consistency which 
permits ready comparison in all areas of analysis; no such uniformity is 
afforded Rangely and Western Rio Blanco County. (One obvious example of 
this ommission is the lack of a fiscal profile for Rangely, beginning on 
p. 1-55). 

To further complicate the analysis, the report liberally combines Rangely 
and Dinosaur into "Colorado Impacts." Why are not Uintah, Duchesne, and 




Daggett Counties, and their respective municipalities similarly lumped 
into one category as "Utah Impacts?" Rangely and Western Rio Blanco 
County certainly deserve equitable consideration. 

The report lacks continuity in the utilization of data for the Town of 
Rangely/Dinosaur, or Rio Blanco/Moffat County data yet in other instances. 
Table R2B-1, for instance, provides data for the Town of Rangely only; yet, 
comparable Tables for Uintah and Duchesne Counties include unincorporated 





I Lastly, references are made in Table R2B-1 to information given by Rangely 
Town Staff for the Town of Dinosaur. The Town of Rangely has no data 
available relative to Dinosaur, and made that representation to the tele- 
phone interviewer. 

C. Special Allocation Model; UPED Model . 

The Town of Rangely wholeheartedly concurrswith comments of Rio Blanco 
County Director of Development Mark 8ubriski relative to the shortcomings 
of these Models and related assumptions (see attachment) as they apply to 
projected impacts from both the Syntana-Utah and Par a ho Projects. Equally 
applicable to those project impacts are comments directed by the Town of 
Rangely to the USGS Oil Shale Office on October 31, 1981, for the White 
River Shale Project (WRSP), (copy attached). The Uintah Basins report is 
guilty of many of the some shortcomings of the WRSP Development Plat report, 
and are referenced as follows: (References to WRSP) 

1.) Item #6, p. 4. No Cost/Revenue Analysis or Community Services 
Impact Analysis . Similarly, the Uintah Basin Study makes little 
attempt to deal with the tax lead time problems associated with 
the projected growth and no suggestions are made to handle 
the growth. 

More important is Rangeiys unique problem of interstate impacts 
due to U-a , U-b, Paraho, and Syntana-Utah operations. In the 
absence of any interstate sharing compacts between Utah and 
Colorado, how are any bonus and royalty payments to be directed 
to Rangely? Certainly, sales and property taxes are not expected 
to offset increased operational expenditures from both a direct 
and induced population. 

2.) Item #8, p. 6. Termination . Analysis for Paraho, Syntana, and 
White River are carried through projected peak development, but 
do not indicate when termination or phase-out might be anticipated. 
Phase-out programs should be addressed so that Rangely, and other 
impacted communities, can take the disappearance of these industries 
into account in long-range fiscal and community planning. 

3.) Item #10, p. 7. Housing Strategy . The Uintah study makes no 
reference to a housing program to accommodate new growth for 
Rangely. Western Fuels-Utah, Inc., and the Town of Rangely 
expended considerable time and effort in developing a Housing 
Strategy and housing agreement to mitigate against Western's 
impacts on both the permanent and temporary housing market. 
Similarly, strategies for White River, Paraho, and Syntana-Utah 
impacts need to commence immediately. 





D. Report Discrepancies . 

The report contains what we feel are serious and substantial misapplications 
of data, and apparent inconsistencies reflected between various sections of 
the report. The following are brief, sketchy notes on some of those 

1.) p. 1-26, Table R2A-7. Rangely population overstated for 1982. 
(We project approximately 950 units by the end of 1982) 1983 
projections appear valid. 

2.) p. 1-38 Table R2B-I. Source of number of Housing Units for 
Rangely/Dinosaur is indicated as John Pagini of the Rangely 
Staff. No information on Dinosaur is available, or has been 
dispersed through the Rangely office. Rangely and Dinosaur 
are communities which should be treated separately, as Utah 
communities are treated separately. Rangely's most recent count 
is as follows (as of July 31, 1982): 



492 (61%) 

Mobile Homes 
229 (28.4%) 

Duplex (units) 
34 (4.23!) 

Apartments (units) 
51 (6.3%) 

Temporary Housing 
17 - 11 M. H./6 RVs 

TOTALS: 806 permanent units; 17 temporary units; 100 motel units. 

TOTAL ALL UNITS - 923 units. 

Applying these figures to the study's criteria, the mix for Rangely alone 
is as follows (excluding RV units): 





Also, the report is consistently guilty of providing data for 
CCD's on some occasions, and data for municipalities at other 

3.) p. 1-39 Table R28-2. Information credited to Rangely Community 
Development Director Pagini has been inaccurately applied to the 
study. The information was apparently derived from a study 
entitled: "Survey of Existing Housing Stock and Other Structures 
in the Town of Rangely", prepared by Brent R. Snyder, Building 
Inspector, Town of Rangely, with the assistance of John Pagini, 
Community Development Director, Town of Rangely, dated February 8, 
1982. The following information, derived from this report, was 
submitted during the Uintah Basins telephone survey, and is outlined 
on p. 15 of the report (copy attached): 

Substandard Units 

Raw Number 

% of Total 

Mobile Home Units 



Recretional Vehicle Units 



Apartment units 



Duplex Units 



Single Family Units 










Of 801 permanet dwelling units identified at that time, 174, or 21.7% 
were judged to be substandard. 

No information was given to those conducting this study on the number 
of "new" units, nor was any attempt made to define the parameters for 
"new", "standard", "deficient", or substandard" units. It is also 
curious that the report chooses only to judge housing conditions for 
so-called "standard" units only; it seems that the condition of mobile 
homes and any multi-family housing are important factors in gaging 
overall community housing conditions, especially where the report has 
estimated the region's combined mobile home and apartment housing 
total at nearly 30% of total housing (p. 1-30). 

4.) p. 1-48 Table R2B-8. No breakdown of the number of books and 
square feet of space is provided for the Rangely Library - why 
is the information "not applicable" for Rangely, but applicable 
for other jurisdictions? 

5.) p. 1-61 thru 1-80. The report fails to treat Rangely and Dinosaur 
with fiscal analysis which parallel those presented for all Utah 
Counties, Municipalities, and Districts! 

6.) p. 1-84 thru 1-88. Section R2C Transportation - No mention is made 
of the Rangely Airport and pending expansion plans. Also, it should 
be noted that Colorado Air Freight Express provides passenger and 
freight service to Rangely. 

7.) p. 1-94. Characterizes road between Highway 64 to Bonanza as 
substandard. Does not consider fact that County has improved 
Colorado portion of road during 1982, expending $200,000. 

8.) p. 1-93. Transportation Data Chart. Provides poor information 
on Colorado Highways serving Rangely and Dinosaur. Does not 
address road leading from Highway 64 to Bonanza. 

9.) p. 141 CDD Level Impacts. Relative to the comment attributed 
to "local planners" concerning the distance from Bonanza to 
Rangely, and use of the Morman Gap Road, are "local planners" 
Rangely and Dinosaur officials, or Uintah County officials. 
Rio Blanco County has performed substantial improvements to the 
Colorado portion of the road. Secondly, Bonanza workers may be 
restricted from residing in either Rangely or Dinosaur by Company 
policy, and, therefore, should not be used as an indication that 
the road may not be utilized by others. 

10.) p. 1-144 Table R3A-11 and R3A-13 are inconsistent. 

11.) p. 1-147 The former alleges to represent community impacts for 
Rangely and Dinosaur CCOs while the latter represents impacts to 
incorporated areas. In both instances, the population is identical 
for both Cdds and incorporated areas while number of households 
for incorporated areas exceeds the total number projected for 
each CC0. 

12.) p. 1-163 & 164. Baseline projections are for 51 police officers 
serving Rangely. These figures are inconsistent with baseline 
population projections found in Table R2A-7 and how enforcement 
standards noted on p. 1-7. 









13.) p. 1-165. Similarly, projections for patrol cars are not 

consistent with the above-referenced baseline population and 
standards noted elsewhere in the report. 

14.) p. 1-183. Two County Impacts are combined, while Utah juris- 
dictions are addressed separately. 

15.) p. 1-186. Projections are for considerable induced worker impacts, 
but no direct construction worker impacts. This does not fall 
into generally accepted formulae for direct/induced worker ratios. 


. I- 191 & 193. Community and County impacts are freely inter- 
ixed; these impacts should be clearly separated by jurisdiction. 

p. I 


17.) p. 1-194. The analysis in this section fails to address High Level 
Scenario impacts for Rangely and Western Rio Blanco County. 

18.) p. 1-197. Baseline demand for students is listed as 5,293. This 
demand does not seem possible. If we assume that baseline pro- 
jections found in Table R2A-7 are accurate, total population is 
as 3,192; it is, therefore, highly improbable that 5,293 school- 
age individuals could be found in the Rangely area. 

19.) p. 1-200. Table R3B-19. Baseline data seems highly inaccurate 
for the same reasons as stated immediately above relative to law 
enforcement and school age populations projects. The same comment 
is applicable for p. 1-201, 202, 207, 208, and 215. 

20.) Volume II of the Socio-economic Impact analysis fails to make any 
mention of either Rangely or Rio Blanco County in their analysis. 
Particularly, we feel that analysis of Paraho and Syntana-Utah, 
which are situated in closest proximity to Rangely and Western 
Rio Blanco County, must address impacts to Rangely in the same 
manner as Duchesne and Uintah County, Vernal and Roosevelt impacts 
are addressed. 

In closing, we wish to emphasize the importance of making close personal contact 
with jurisdictions which might potentially be impacted, and to obtain and utilize 
official documents as credible data base. You will find that Rangely, Rio Blanco 
County, and various District officials are more than willing to devote their time 
to provide accurate and current data. For the Town's part, I can guarantee our 
participation and the fostering of open communication. 

Thank you for your consideration of Rangely's concerns. 

Very truly yours, 


Pejjsy' J- Rector- 



Attachments: A. Statement of Mark Bubriski, Rio Blanco County 

B. Statement of Western Rio Blanco Metropolitan Recreation 

and Parks District 

C. Statement of Rangely Public Schools 

D. Statement of Rangely's Junior College District 

E. Copy of letter to Peter A. Rutledge, USG5, from Peggy J. 

Rector, Mayor, Town of Rangely, dated October 31, 1981, 
relative to White River Shale Porject. 

F. Copy of Report entitled: "Survey of Existing Housing Stock 

and Other Structures in the Town of Rangely" 

G. Copy of report entitled: "Town of Rangely: Housing and 

Population Count, July 31, 1982" 
H. Copy of Report entitled: "Breakdown of Housing Units Currently 
under Construction, September 1, 1982" 



October 14, 1982 

Statement of Mark Bubriski, Rio Blanco County Director of Development 

Re: Uintah Basins Synfuels Development EIS 

On behalf of Rio Blanco Count y I would like to concentrate my comments 
specifically to assumptions made and data included in the sections on work- 
force allocat ions and populat ion project ions . 

I would first like to address the assumptions and findings of the "snatial 
allocation model" and the UPED model referred to in the KtS. The model docs 
not appear to take into account that with the current advent and continual ion 
of residential and commercial development now occur r ing in Range ly , Colorado 
(housing, shopping and recreation) that there will be more liklihood of Range ly 
becoming a more competitive and more attractive town for people to reside in 
and commute from. The EIS states that the Bonanza-Rangely road is insufficient 
to accommodate heavy levels of traffic and that county (Uintah) officials have 
indicated that they will not maintain this road for use by commuter traffic. 
Although, presently this road on the Utah side is in need of repair and main- 
tenance, Rio Elanco County has just this summer spent $200,000 improving the 
road from the Colorado border to Highway 64 just north of Rangely. The nap 
referred to in the EIS as Map R-l-1 omits entirely the existence of the Bonanza- 
Rangely road. Any potential worker population allocation to Rangely depends 
considerably on the access provided by this road . 

■ "•*» The " imped ence factor" that the EIS attributes to this road does not take 

into consideration the possibility that as both synfuel projects Syntana-Utah 
and Par a ho Development go into construction in the next couple of years, these 
companies themselves may opt to assist in improving and maintaining that small 
segment of the Bonanza-Rangely road that is close to their proj ects in Utah. 
This possiblity should not be ignored given the proximity of both Syntana and 
Paraho to the Colorado border and if improving the road would prove to be 
beneficial in planning trans porta t ion needs of their respective commuting work- 

On the same note the recently published Electric Power Research Institute 
February 1982 report "Socioeconomic Impacts of Power Plants' 1 has some interesting 
observations regarding the utility of gravity models such as the spatial 
allocation and UPED models use in the Uintah Basin EIS. 

The report states : 

"Gravity models should not be used without a substantial 
amount of field work in the areas in order to assess the 
capability and desire of communities to attract and house 
construction workers and induced employees . " 

In summary on this subj cct Rio Blanco County feels that the Uintah Basin 
Synfuels Development Draft EIS is substantially underestimating the potential 
population and workforce allocation in Rangely and therefore underestimat ing 
the coinciding impacts that would be felt. 



Regard ing spec if ic data and assumptions on population impacts made in the 
draft EIS Rio Blanco County questions the sta tcment made on page 11-6 of the 
Socioeconomic Technical Report stating that "The impacts for llangeiy ;irc not 
significant using the criterion of an impac t of 10% or greater as being signi- 
ficant". 1 believe the 10% figure is taken from a Jack Gilmore study that 
attributed certain impacts under certain conditions as significant at 10-1 57.. 
The Uintah Basin EIS interpretation of Mr. Gilnore's assessment is misleading. 
After discussion with Jack Gilmore and his associates and a closer reading of 
the report that the 10% figure is taken from^it is apparent that impacts 
are grea ter in smaller rural communities where the basic infrastructure is 
nearer capacity. For any small community the rate of growth and corresponding 
"significance" as related to impact is entirely a function of that town's 
ability to absorb the growth and associated impacts . 

On the same subject of population impacts the Draft Technical Report 
Volumn II Socioeconomics states that the impacts for Rangely will not be 
significant using the criterion of 10% or greater as being significant. My 
concern with this statement is that it conflicts directly with the State of 
Utah's Impact Mitigation Law that stipulates 5% growth as its criterion for 
significant impact. Given that the State of Utah's Office of State Planning 
had a direct role in preparing the Draft Uintah Basin Synfuel EIS there appears 
to be a serious conflict in establishing a consistent growth impact criteria. 

Also, with regard to population impacts in the affected communities and 
counties I refer to Tables R-4-4 and R-&-6 on pages R-4-12 and R-4-16 re- 
spectively in the EIS. Table R-4-4 according to the UPED model projects a 
1985 baseline population of 3,193 for Rangely with an applicant (projects) 
increase of 577 for an 18.1% increase and an interrelated project increase 
of 82 for a cumulative increase of 659 people or a 20.6% increase. Similarly, 
in Table R-4-6 Housing Demand the UPED model shows a baseline household number 
in Rangely of 1,116 in 1985 with an applicant increase of 196 or 17.5%. Uith 
the interrelated project household demand included this number is increased 
by 28 for a cumulative total of 224 additional households needed and a 
corresponding 20.1% increase for Rangely. 

Both of tlese tables appear to be substantially different in their data 
proj ections and conclusions from the data and assumptions made in the Draft 
Volumes 1 & 2 Technical Reports on Socioeconomics that show significantly 
lessor impacts for Rangely. Again, the statement that Rangely will not be 
significantly impacted based upon the 10% impact criterion seems to be 
seriously at odds with the conclusions reached in both Tables R-4-4 and R-4-6. 






P.O. BOX 1003 - RANGELY. COLORADO 81648 

October 13, 1982 

Town of Rangely 

John Pagini 

Conrnunfty Development Director 

P.O. Box 580 

Rangely, CO 81648 

RE: E.I.S. reports for Unitah Basin Synfuels and White River 
Oil Shale Project 

Dear John: 

I am writing in regards to the two E.I.S. reports. I will 
comment first about the White River Shale Project. The first 
problem is the figure of 203 acres of both developed and 
undeveloped land within the Parks and Recreation District in 
Rangely. Actually, the District presently owns 24.5 acres of 
developed parks and 21 acres of undeveloped land. The total is 
45.5 acres, which is far short of 203 acres. All assumptions 
made by them must be reevaluated with better figures. 

The Uintah Basin Synfuels E.I.S. is a totally different idea 
as far as the Parks and Recreation District is concerned. They 
create more problems than they answer. First, they use a figure 
on page 1-169 of 179. acres as a total demand for neighborhood 
parks. Where did they get that figure? Since I only now have 
45.5 acres both developed and undeveloped, that means they would 
owe me 133.5 acres by 1993. They then must have quite a model 
to choose from. Thats only 174 acres difference. 

The second problem I have is they Tump Dinosaur and Rangely 
together. We are in different counties and have nothing to 
do with each other. They don't pay our bills or build our 
parks and vice-versa. 




John Pagini 
October 13, 1982 
Page 2 

The next question I have is where did they get their baseline 
projections? With regard to this question, (1) Where did they 
get their figures? (2) How can you develop an E.I.S. over the 
phone? (3) If you can lump Rangely and Dinosaur together, then 
why not lump Vernal and Roosevelt together? (4) When did these 
people come to Rangely and how did they develop these figures? 

This statement is typical of the energy people. Why do anything? 
They already have it covered. We want everything free and will 
give nothing. I guess the old axiom 1s true in this case, "Figures 
lie and liars figure." I hope my point has been made concerning 
this study. At least, White River Shale came to talk to us. 

Thank you for your consideration in this matter. 


Mb&h-*$lA /0 **~ n * n ~ a 

Richard Simmons 





AccedKed Through CWxado Department ol EduCaion Conuaci - May. 1974 


BSTflCT HO. K-4 


Town o & Rangely 
Attn : John Pagini 
P. 0. Sox 580 
Rang £■£(/, CO 8)648 




Vean Ma.. Pagini: 

In negafid to co 
Project, I have, 
capacity at the 
4 (town on 1-41 , 
enrollment oar 
52 pe.fice.nt a& 
enrollment i& v 
Oufi elementary 
* ft own in the ht 
■in the 6 enior k o{ thi-6 
to ou.A building 
higher than &ho 

mmenti regarding 
i eve hat comment 4 
high Achoo-C i& 3 
Became o & thi& 
utilization l& fia 
houtn In the. &tudy 
ery cto&e to tota 
student poputatlo 
udy , and we cu/ifie 
Igh , up fafiom the 
lncrea& e in enfio 
capacity and our 
vin . 

the White 

to make, 

80 6tu.den 

and our 
nning muc 
Our j 
I capacit 
n i& now 
ntly have 
152 4hown 
llment we 
pupil te 





h hig 


y at 

320 n 

o ve-t 

In t 



K Oil Shale 
r dtiign 
ot the 500 

hen. than the 

ot 2 11 a* 

200 6tudent& 
he 6tudy. 

fiatio lb 

Please pa&6 -ffte4e comment* on to the pnopeti authoA.ltle.b . 

Sincerely Voun, 

'Gene Vountf, Ed.p< 



Colorado Northwest Comnuni ty College is located in Rangely. Northwestern 
Colorado, served by CNCC encompasses an area approximately 8,800 square 
miles, or about 8.5 percent of the Colorado Land Area. 

Although the tax supporting Rangely Junior College District encompasses 
only the western half of Rio Blanco County, the institution serves a 
three-county area composed of the counties of Rio Blanco, Moffat, and 
the western section of Routt County. CNCC is designated by the State 
Board for Community Colleges and Occupational Education assumes the re- 
sponsibility for providing the assessment of needs and instruction for 
the defined service area. 

Colorado Norhtwestern Community College confers Associate Degrees in 
General Studies, Liberal Arts, specialized vocational programs and 
awards certificates in occupational program certificates. The post- 
secondary instruction programmed through the service area includes 
degree and certificate offerings and avocational individual-interest 

Unique programs that are programmed at the college include Aviation 
Maintenance Technology {2 year certificate), Aviation Flight (Associate 
Degree), Dental Hygiene (Associate Degree), Instrumentation Technology 
(Associate Degree) and Petroleum Technology (Associate Degree). 

Presently, the campus facilities total 13 which include classroooms, 
laboratories, housing, athletics and maintenance. The community college 
is pursuing an expansion plan that would address the needs of student 
life and curricular programs. 



The Uintah-Duchesne County area is able to offer post -secondary education and training 
on a fairly large and diverse scale. Utah State University Extension Service teaches 
courses in Vernal and Roosevelt. Also, various Certificates of Completion can be earned 
through the Vocational Centers in Vernal and Roosevelt. The degrees or completion 
certificates that are offered through these institutions are listed in Tables VII— 1 and 
VII-2. Enrollment for the Extension courses is approximately 380 students, while the 
Uintah Basin Area Vocational Center has approximately &60 enrolled. These programs 
have already begun to focus their training programs on skills which will be needed in 
the shale oil industry, as well as on medical and other fields which wilt have increased 
demand locally as energy- related growth proceeds. 

Colorado Northwest Community College is located in Rangely. This— -tnstmnkm— Is 
operated a* a special district covering the entire western side of Rio Blanco Counry. 

The community college is pursuing an ambitious expansion plan, including construction of 
a dormitory, athletic facilities and academic buildings totaling over $8 million by 1 984. 


Baseline growth in the study area will present employment opportunities for increasing 
numbers of local workers in the oil and gas industry. This will require continued growth 
of post-secondary training programs in oil field related skills. 

As the White River 5hale and other synfuels projects proceed, many of the jobs they 
create will require specialized training. Some of these positions during project 
construction stages will be of short duration and will necessitate bringing in temporary 
workers from outside the area. However, most others, particularly during project 
operation, will be more permanent and, therefore, more attractive to natives of the 
area. It will be important to have the training programs available locally, especially 
for these long-term jobs, so that local residents can fill many of the available positions. 

Attention should also be given to maintaining the variety and quality of those post- 
secondary educational programs which are not associated directly with the energy 
rf-^ustry. These programs could be an important leisure time outlet for the energy 
voricers and their families. 




Table VIM 




Bachelors Degrees 


Health, Physical Ed., Recre 

Animal Science 

Instructional Media 





Business Administration 

Office Administration 


Outdoor Recreation 

Dairy Science 


Distributive Education 

Secondary Education 

Elementary Education 

Social Work 



Family and Human Development 

Special Education 


Theater Arts 

General Education 

Wildlife Science 

Master of Arts Decrees 



Elementary Education 

Business Administration 


Business Education 

Secondary Education 


Special Education 


Table VO-2 




Area of Study 

Certificate Offered 

Allied Health: 

Emergency Medical Technician 

State Certificate Emergency Med. Tech. 

Licensed Practical Nurse 

One-year Certificate of Completion 

Nurses Aide Program 

Certificate of Completion 

Prenatal Workshops 

Red Cross Card 


Accounting Clerk 

One-year Certificate of Proficiency 

Administrative Secretary 

Two-year Certificate of Proficiency 

Automotive Service Station 


One-year Certificate of Proficiency 


One-year Certificate 

Business Manager 

Two-year Certificate of Proficiency 

Clerk, General 

One-year Certificate of Proficiency 

Clerk, Typist 

One-year Certificate of Proficiency 

Fashion Merchandise & Interior 


One-year Certificate of Proficiency 

Marketing and Sales Manager 

One-year Certificate of Proficiency 

Real Estate 

One-year Certificate of Proficiency 


One-year Certificate of Proficiency 


One-year Certificate of Proficiency 

Trades and Industry: 

Antique Custom Riflesmith 

Certificate of Proficiency 

Automobile Mechanic 

Two-year Certificate of Proficiency 

Automotive Specialist 

One-year Certificate of Proficiency 

Automotive Spellperson 

One-year Certificate of Proficiency 

Cabinet Millwork 

One-year Certificate of Proficiency 


Two-year Certificate of Proficiency 


Certificate of Proficiency 

Diesel and Heavy Duty Mechanic 

Two-year Certificate of Proficiency 

Farm Equipment Repair 

Certificate of Proficiency 

Architectural Drafting 

One-year Certificate of Proficiency 

Mechanical Drafting 

One-year Certificate of Proficiency 

Leather Work 

One-year Certificate of Proficiency 


One-year Certificate of Proficiency 

Shoe Repair 

One-year Certificate of Proficiency 

Materials Handling 

Certificate of Proficiency 

Motorcyc.e Repair 

Certificate of Proficiency 

Outboard Motors -5c Small Engine 


One-year Certificate of Proficiency 

Welding, Industrial 

Two-year Certificate of Proficiency 

Welding Specialist 

Certificate of Proficiency 

Welding, Gas 

One-year Certificate of Proficiency 

(i.L'<. m-£) 


Area of Study 


Voc. Cert. 



Aviation Technology (Pilot Training 


Aviation Maintenance Technology 
(Air frame & Power plant Mechanic) 


Dental Hygiene 


Instrumentation Technology 



Office Occupations 



Petroleum Technology 


General Business 


Mathematics/Physical Science/ 
Ceo logy 


Physical Education 



Pre-Veter inary 


Liberal Arts 



Community Development/Human 


AAS Assoc Late of Applied Science 
Voc. Cert. Vocational Certificate 

AS Associate of Sc ience 
AA Associate of Arcs 



P O BOX S80 


Phone 303/675-8611 

Whit*. RWtttO"- S"h*lc 

October 31, 1981 

Mr. Peter A. Rutledge 

Deputy Conservation Manager 

U.S. Geological Survey 

Oil Shale Office 

Suite 300 

131 North 6th Street 

Grand Junction, CO 81501 

Dear Mr. Rutledge: 

The Town of Rangely, Colorado wishes to make the following 
comments on the Detailed Development Plat (DDP) for the 
White River Shale Project (WRSP) for federal lease tracts u-a 
and U-b in Uintah County, Utah. Specifically, the Town wishes 
to concentrate on the social and economic impact study which 
was prepared as a supplement to the Detailed Development Plan, 
which is intended to descri be the potential social -economic 
i mime lis Lha l may rcsu 1 L fr«.iii Lhc construction and opera t ion 
of the WRSP. The study uncer review is by Gibbs & Hill, Inc. , 
and assigns the total impac t to Uintah County, Utah, and 
Rangely, Colorado. 


P ropo sed Ac t i on 

The White Rivei Shale Project is a joint venture of Phil lips 
Petroleum Company, Sohio Shale Oil Company, and Sunoco Energy 
Development Co., to construct and operate an oil shale mine and 
retort facility on tracts U-a and U-b. It is our understanding 
that the joint venutre is or will soon be called the "Whi te 
Riv,er Shale Oil Corporation" . For purposes of our review, 
we will continue to refer to white River Shale Project or WRSP. 

"White River Shale Project; Community and Infrastructure Support 
Study", Gibbs & Hill, Inc., August, 1981. 

Mr. Peter A . Rut ledge 
October 31, 1981 
Page Two 

The entire project is intended to be a phased development over 
an approximate 2 5- year period from time of development to ter- 
mination. The time frame goes from 1982 to 2007 in the following 
three phases : 





















Modular Operations 15,000 (1986) 

Construction Peak 57,000 (1989) 
Population Peak 

Commercial Opera- 106,000 (1993) 


The total direct WRSP employment is expected to peak at 5, 08 3 
workers in 1989, including 3,797 construction workers and 1,286 
operation workers. By 1994, the construction work force is pro- 
jected to be phased out and the operation work force is projected 
to reach 3,353. 

II Population Projections and Distribution 

Gibbs & Kill used an attraction-constrained gravity model in an 
attempt to project the likely distribution of direct incoming 
population between Uintah County, Utah, and Rangely, Colorado. Under 
the Gibbs & Hill gravity model, about 76 percent of the direct 
incoming population was assigned to Uintah County , and , more 
specifically, the Ashley Valley which encompasses Vernal, Utah; 
and 24 percent of the direct incoming population was assigned to 
Rangely , Colorado. white River Shale Project induced population 
distribution was assigned only to these two locations. 

In addition , WRSP intends to develop a construction camp on the 
site which is expected to house as many as 2000 "singles" during 
the 1982-1993 construction period. Gibbs & Hill assigned 50 
percent of the singles or bachelors in the construction work 
force to the camp, and the reminaing 50 percent was distributed to 
Rangely and Ashley Valley in a 24 - 76 ratio. 

Mr. Peter A . Rut ledge 
October 31, 1981 
Page Three 

III. Summary of Issues and Concerns by the Town of Rangely 

The Town of Rangely wishes to make the following 15 points as they 
relate specifically to Rangely on the social-economic analysis 
supplemental material to the Detailed Development Plan for the 
White River Shale Project: 

1. No In-depth Analysis . Secondary sources are used to 
a considerable degree. There were few personal contacts with Rangely 
local government officials and use of official documents (e.g., 
audits and budgets) is virtually non-existent. Such an approach 
means that qualitative analysis and insight into the operational, 
budgetary, and political processes that are unique to Rangely are 
not taken into account. Ashley Valley and Uintah County are 
given much more in-depth analysis. This shortcoming should be 
corrected in further analyses. 

Uintah County 

social-economic analysi 
fically, the Ashley Val 
holds true with respect 
the fact that the Gibbs 
24 percent of the WRSP 
population at the opera 
ulation growth is doubl 
shortcomings are detail 
Appendix A for a compar 
in Gibbs & Hill with re 

Emphasized . As stated, the bulk o 
s is directed at Uintah County, and 
ley, not Rangely. The same conclus 
to mitigation statements. This de 
£, Hill Gravity Model shows Rangely 
population impact or approximately 
tional stage starting in 1994. The 
e Rangely' s current size. The spec 
ed in paragraphs 3, 4, and 5 below 
ison of what was covered and not co 
spect to Rangely versus the Ashley 

f the 



if ic 


3. Direct Impact Only Covered . The Town of Rangely believes 
that one of the most serious shortcomings of the study is the fact 
that only the social-economic effects of the direct population are 
covered for Rangely. Indirect population impact added to direct 
impact means that 4,000 instead of 2,000 population will need to 
be served in Rangely. The fat:t that indirect population is not 
taken into account skews the entire effects analysis. There 
appears to be an assumption that somehow the existing population 
will, in fact, satisfy the secondary employment base and that, 
therefore, service and inf rastructural requirements of the 
secondary population will be ninimal. In short, there would be 
no in-migration of secondary population. Indirect population impact 
was taken into account for the Ashley Valley. 

Mr. Peter A. Rutledge 
October 31, 1981 
Page Four 

4. Extrapolation of Ashley Valley Data . In most instances 
the only way in which data for Rangely is derived is to extrapolate 
comparable data given for the Ashley Valley. We find this to 

be extremely cumbersome and the comparables not necessarily inter- 
changeable . 

5 . Comparison of Planning Standards . Existing , comparable, 
and Gibbs & Hill proposed planning standards for projecting service 
needs of the WRSP are developed for Ashley Valley and some, but 
not nearly as many, are developed for Rangely. The standards for 
Ashley Valley cover housing type mix and dwellings per acres; 
community support facilities; recreation; and utilities. These 
standards are intended to present measurement factors for deter- 
mining land area needs for schools, housing, public service 
employment, flow rates for water and wastewater treatment, etc. 
Ashley Valley ratios give a basis "for determining by local 
planners and managers which of the comparative planning standards 
are applicable to Ashley Valley — they serve as a basis for 
measuring the relative adequacy of the existing service level. 

In summary, what are shown and discussed at length for Ashley 
Valley are: 

a. Existing planning ratios ; 

b. Comparative or optimal planning standards; and 

c. Proposed standards, as customized by Gibbs & Hill. 

The Town of Rangely believes that similar detail and scope of 
planning analyses should be accorded Rangely where one quarter 
of the WRSP projected population will reside. 

6 . No Cost/Revenue Analysis or Community Services Impact 
Analysis. Chapter 4.0 and accompanying tables set out local 
governments ' budgets and tax base for Uintah County. Where is 
the comparable date for Rangely? What is the fiscal impact of 
the WRSP on Rangely? Though tax lead time is recognized as 

a problem, there are no suggestions for mitigating the problem . 
It is generally claimed that Rangely' s existing inf rastructural 
capacity will be sufficient to handle the new growth. The 
following statement from Gibbs & Hill effectively sums up how 
new growth will be handled and funded by the public sectors: 

Mr. Peter A. Rutledge 
October 31, 1981 
Page Five 

The capacity of Ashley Valley and Rangely to raise 
the present level of services and to accommodate the 
increased needs will be enhanced by the increased 
revenue generated by tho incoming populations . The 
general tax base growth in Ashley Valley will be 
supplemented by the monoy that Uintah County will 
receive from WRSP ' s bonus and royalty payments, 
much of which can be sued for local impact mitigation 
needs. (emphasis added) * 

Bonus and royalty payments from the WRS 
State of Utah to the Ashley Valley, but 
since there is presently no mechanism f 
fail to see how increased sales tax and 
sources of revenue for Rangely, will of 
expenditures, resulting from a construe 
force and the attendent indirect popula 
provide the bonding capacity necessary 
provement requirements of the new popul 
of f -set expenditures this needs to be s 

P may be distributed by the 

probably not to Rangely 
or interstate sharing. We 

property tax, the principal 
f-set increased operational 
tion and permanent work 
tion increase, much less 
to meet the capital im- 
ation. If revenue will 

Will there be positive fiscal balances for Rangely School District 
UK-4 , Rio Blanco County, and special districts affected by the WRSP' 

There are special circumstances created when the 
base is located in one state and must be address 
governmental entities located in another state 
with respect to the WRSP and Rangely. Capital a 
standards , developed by the State of Colorado, e 
$10.8 million dollars is required for capital co 
$1.0 million per year is required for operations 
for each 1000 new residents in order to provide 
services . Operations and maintenance go on, of 
for the life of the project, while capital costs 
time expenditures either before , during , or af te 
arrives. Part of the on- going operation costs a 
the new capital improvements . With approximatel 
coming to Rangely by 1989 or 1990 as a result of 
incumbent upon the White River Oil Shale Corpora 
when, or whether a positive or break-even public 
will be achieved in Rangely by the various gover 
involved, since about $40 million of capital pro 
required to serve this new population plus an an 
about $4.0 million over the life of the project. 

industrial tax 
ed by local 
such as the case 
nd operational 
stimate that about 
sts and another 

and maintenance 
necessary government 

course, each year 

are considered one 
r the population 
re for maintaining 
y 4,000 new residents 

the WRSP, it is 
tion to show how, 

fiscal balance 
nmental entities 
jects may be 
nual outlay of 

This total dollar 

2 Ibid . , Page XVII. 




Mr. Peter A. Rutledge 
October 31, 1981 
Page Six 

amount, plus such issues as tax lead time and bonding capacity 
are very real concerns for Rangely and other governmental bodies 
in Colorado. Unless such issues are addressed, the other options 
available for the Town of Rangely are higher taxes and service fees 
for current residents, a cutback in existing service levels, and 
a deferral of planned capital improvements , or any combination of 
the three. 

Both a co st/ revenue analysis and a community service impact 
analysis is necessary. It is unacceptable to merely state, as 
in Gibbs & Hill, that increases in earnings in Rangely will amount 
to $31.3 million by 1994. How does that translate into tax 
dollars to maintain the public fiscal balance? 

7. Federal Leasing Provisions . The Gibbs & Hill social- 
economic analysis is not required under the terms of the U-a 

and U-b federal shale oil leases, nor is mitigation required. The 
Town of Rangely believes that future oil shale federal leases 
should contain requirements for social -economic identification 
and mitigation. Such requirements would be particularly helpful 
in the case of interstate impact situations, such as the U-a 
and U-b tracts. 

8. Termination. Unless other shale oil resources are 

developed in the 
2007. There shou 
programsso that c 
not suddenly left 
and elaborate soc 
The termination 
analysis as well 
very minimum, the 
local government 
based industry in 
long-term debt 

mean time, the WRSP will end about the year 
Id be addressed termination or phase out 
ommunities such as Rangely and Vernal arc 

as ghost towns, with extensive, expensive, 
ial and economic structures and infrastructures . 
ssue should be addressed in the social-economic 
as provided in future leasing programs . At the 

bust or down cycle should be analyzed so that 
can take the disappearance of a natural resource- 
to account in long-range community planning, 
nd fiscal planning. 

9. Gravity Model and Monitoring . The Grav 
in Appendix F of the Gibbs & Hill analysis, shows 
about 24$ of the population and the Ashley Valley 
model assumes that even though Rangely is closer 
the latter overcomes the distance deterent by the 
vantages of a larger community. As recognized in 
this could change. The only way the Gravity Mode 
over time is through a monitoring program such as 
developed by the State of Colorado for the Cumula 
Committee or the Moon Lake Power Plant Project co 
Western Fuels agreement. This is especially true 
Rangely and Ashley Valley were used as potential 
in the Gibbs & Hill report. 

ity Model contained 
Rangely getting 
about 76?, . The 

than Vernal , 
perceived ad- 
Gibbs & Hill 

1 can be verified 
the one being 

tive Impact 

incident to the 
since only 

settlement sites 

Mr. Peter Rutledge 
October 31, 1981 
Page Seven 

10. Hous ing Strategy . There is no housing program to accommodate 
the new growth for Rangely, nor even a recognition that the need for 
one may exist, other than to make brief mention of the problem 
Rangely will have with temporary housing during the construction 

peak. Strategies for this most complex public-private issue need 
to commence almost immediately. 

11. Cumulative Impact . There is no cumulative impact in- 
formation on Rangely so such statements as the following on 
page XVI are not accurate: "Because of Rangely' s existing 
facilities, no additional schools and only 
may be required" . 

9 additional teachers 

12 . Overstating Rangely's Current 
existing capacity is overstated in many 
on page 7-28 it is stated that Rangely w 
capacity of 4.32 million gallons per day 
treatment plant will have a capacity of 
in both instances that sufficient existi 
will be more than enough to take care of 
pact. We are unaware of firm plans for 
case of water treatment or wastewater tr 
l In ilt'lVrri.-tJ eapi Ui 1 | >r« n.| contained i 
agreement. We suggest that the capacity 
in conjunction with the Town Manager and 
officials on a face to face basis. Only 
elusions be drawn. 

Capacity ■ Rangely's 
instances. For example, 
ill have a water treatment 

and the sanitation 
1 . mgd . It is asserted 
ng and planned capacity 

the WRSP population im- 
expansion in either the 
eatment, other than 
i LllU Wi-:.Lt-Tn I -'in- I ii 
analysis be done again 
other responsible local 
then can accurate con- 

What does the public sector do i f 
financial obligations are made, particularly long-term capital 


No Oil Shale. 

debt, and tho project fails to materialize or is stopped after 
the Phase I prototype stage? 

14. Campsite S-E Impact . Due to the construction campsite's 
proximity to Rangely, it is likely that the Town will experience 
impact on services (police, social services, etc.). It is 
suggested that operational rules and regulations be reviewed by 
the Town prior to their adoption by WRSP. 

15. water Rights . Uy Phase III of the project, according 
to the Detailed Development Plan, consumptive water use will 
approximate 31 cfs, taken in all likelihood from the White River 
or the White River Reservoir if built. The Town of Rangely is 
concerned about the potential adverse impact that such consumptive 
use might have on the Town's water rights, particularly its 


Mr . Peter Rut ledge 
October 31, 1981 
Page Eight 

28.5 cfs rights. This problem is not addressed in the Detailed 
Development Plan, the Gibbs & Hill social-economic supplement, the 
Draft EIS for the white River Dam Project, or any other document 
to the Town ' s knowledge . We believe that an analysis of the 
WRSP and a cumulative impact analysis of other known or potential 
energy users on Range ly water rights is essential if the Town 
is expected to handle substantial energy population growth. 
Tor instance, Gibbs & Hill projects Rangely population to be 
approximately 12,000 by 1994. Are Rangely' s water rights adequate 
to handle such growth? Or wiLl upstream and downstream senior 
consumptive users effectively impede the Town 's ability to meet 
the projected growth? The Town of Rangely believes that it is 
in the interest of the white .River Shale Project and the Bureau 
of Land Management to water supply capabilities and 
limitations of the Town of Rangely. 


As a closing note, we wish to point out that officials of the 
White River Shale Project have already met with a member of the 
Town Council, the Town Manager, and myself in an effort to start 
an essential dialoque between the corporation and the. 1 oca 1 
[|OveriuiK.-nLiii entity moat a f i ccLciI by the WRSP. We can only hup<_- 
this effort is maintained on an on-going basis and extended to 
include other local governments involved in Colorado . For the 
Town's part, I can guarantee our participation and the fostering 
wherever possible of such communication. The contents of this 
statement should form a basis of the issues that local government 
industry need to address jointly in the ongoing effort. 

Thank you for your time and consideration of Rangely ' s concerns. 

Very truly yours, 





Rangely Service Units Needed 
(Direct Impact Only) 
Not Covered or Inadequately Covered in Gibbs & Hill 

(Areas shown as not covered at all for Rangely but were covered 
for Vernal are asterisked (*) ) 

1. Housing - no strategy was included or, indeed, recognized for 
shortfall in temporary and permanent housing. 

2. Water: 

a. Supply - water rights and effect of White River Dam consump- 
tive use. 

b. Storage - no detail. 

c. Distribution - no detail. 

d. Treatment - assumes 4.32 mgd capacity. 

3. Waste Water Treatment - assumes 1.0 mgd and excess capacity. 
*4. Solid Waste Collection 

5. Solid Waste Disposal 

*6. Natural Gas 

7. Electricity 

8 . Telephone 

*9. Social Service - youth, adult, drug and alcohol, mental health, 
family, day care. 

*10. Recreational Facilities - urban-type and outdoor. 

*11. Transportation (not covered at all) 

a. Impact on Rio Lilanco County road system. 

b. Transportation alternatives to WRSP. 

c. impact on Rangely Streets and Alleys 



Planning strategy for new growth, e.g., temporary housing 
during peak years versus steady state years - how to even 
out, qualitative growth factors in service units not 

Air quality impact (DDP) on Colorado, Rio Blanco County, 
and Rangely. 

Rio Blanco County impacts completely ignored -- road system, 
social system, operations, land use planning and capital needs . 

Schools - (cumulative impact analysis not taken into account) . 

Community College - not mentioned at all . 




Prepared by 

Brent R. Snyder 

Building Inspector 

Town of Rangely 

with the assistance of 

John D. Pagini 

Community Development Director 

Town of Rangely 

Presented to the Board of Trustees 

of the Town or Rangely 

February 8, 1982 

Field Observations Conducted: 
January 23-22, 1982 
January 28-29, 1982 





This report has been prepared in response to the 
request of the Town Manager that a survey be made of the 
existing housing stock and other structures that may be 
found in Rangely. The survey was intended to provide the 
municipal government of the Town of Rangely with a basis 
for establishing a program of' enforcement of the Town's 
building and sanitary codes. It was also anticipated 
that the survey would provide a data base for the so- 
licitation by the Town of housing rehabilitation grants 
from appropriate state and federal agencies. 

We feel that the survey results also demonstrate, 
however, that one or more "slum or blighted areas," as 
those terms are defined at Colo. Rev. Stat. SS 31-25- 
103(2), (7) {1977 Repl. Vol. 12), exist within the Town 

1/ The cited statutory sections provide that: 

"'Blighted area' means an area 
which, by reason of the presence of a 
substantial number of slum, deterio- 
rated, or deteriorating structures, 
predominance of defective or inadequate 
street layout, faulty lot layout in re- 
lation to size, adequacy, accessibility, 
or usefulness, unsanitary or unsafe con- 
ditions, deterioration of site or other 
improvements, unusual topography, defec- 
tive or unusual conditions of title ren- 

of Rangely, and we therefore present these survey results 
to the Board of Trustees in an effort to inform the Board 
of Trustees in its determination whether an urban renewal 
authority should be established in the Town of Rangely. 
We stress that the survey results are conserva- 
tive, being based only on exterior observations. Also, 

dering the title nonmarketable, or the 
existence of conditions which endanger 
life or property by fire and other 
causes, or any combination of such fac- 
tors, substantially impairs or arrests 
the sound growth of the municipality, 
retards the provision of housing accom- 
modations or constitutes an economic or 
social liability, and is a menace to the 
public health, safety, morals, or wel- 
fare in its present condition and use. 

"'Slum area* means an area in which 
there is a predominance of buildings or 
improvements , whether residential or 
nonresidential, and which, by reason of 
dilapidation, deterioration , age or 
obsolescence , inadequate provision for 
ventilation, light, air, sanitation, or 
open spaces, high density of population 
and overcrowding, or the existence of 
conditions which endanger life or prop- 
erty by fire or other causes, or any 
combination of such factors, is con- 
ducive to ill health, transmission of 
disease, infant mortality, juvenile de- 
linquency, or crime and is detrimental 
to the public health, safety, morals, or 


it must be made cleat that the survey results have been 
determined primarily on the basis of the informed judg- 
ment of Brent Snyder, the Town Building Inspector. It 
is also important to note that although we determined, as 
a result of our survey, that a significant number of the 
structures in Rangely are substandard, it is also our be- 
lief that many more structures in Rangely could be iden- 
tified as substandard if a thorough house-to-house survey 
were conducted and interior plumbing, wiring, heating, 
and construction features could thereby be evaluated. 

Nevertheless, the principal conclusion of the sur- 
vey is that of a total of 801 dwelling units within the 

Town limits, fully 174 of them, or 21.7%, are clearly 

2/ Mr. Snyder is a certified building inspector; a cer- 
tified plumbing inspector; a certified electrical in- 
spector; a certified mechanical inspector; a certified 
plans inspector; and a certified combination inspector. 
Mr. Snyder is also the recipient of a special certificate 
of achievement from the International Conference of Build- 
ing Officials — he is one of only approximately 20 per- 
sons who have been so honored. 

3/ For example, on February 5, 1982, an explosion of as- 
yet-unknown origin destroyed a single family house lo- 
cated in a neighborhood that we had previously deemed to 
be devoid of substandard units. 

4/ There are 475 single family units, 30 duplex units, 
229 mobile homes, 60 apartment units, and 7 recreational 
vehicles used as permanent dwelling units within the Town 
limits. This total of 801 units does not include the 22- 
25 motel units that are presently being used as dwelling 
units by the same persons for indefinite periods of one 
month or more. 

substandard in some respect.— Furthermore, the substan- 
dard housing units are not segregated into discrete areas 
within the Town; with a few exceptions, substandard units 
can be found in almost every neighborhood in Rangely. 

In addition to evaluating obvious housing stock, 
we have also determined that of the 100 motel units that 
are available for occupancy in Rangely, 22 to 25 of them 
are continuously occupied by the same individuals for in- 
definite periods of one month or more. To the best of 
our knowledge, only five of these 22 to 25 units can be 
classified as having kitchenettes. Therefore, the 17 to 
20 motel units that may not be classified as having kit- 
chenettes and that are occupied by the same persons on an 
indefinite basis should also be considered to be substan- 
dard dwelling units, because they lack basic cooking 
facilities . 

Finally, of the 114 existing structures in Rangely 
that are not used as dwelling units, we have determined 

5/ The breakdown of substandard housing units is as 

Single family 57 

Duplex units 4 

Mobile homes 85 

Apartment units 21 

Recreational vehicles 7 

TOTAL "174" 

that at least 14, or 8. IS, are also substandard in some 
respect (primarily noncompliance with the Flood Plain 
Ord i nance ) . 


The survey of existing dwelling units and other 
structures in Rangely (see attached data sheets, which 
constitute Exhibit "A") was conducted on January 21, 22, 
28 and 29, 1982; the photographs that supplement the sur- 
vey were all taken on January 21 and 22, 1982. 

A number of specific criteria, all of which are 
detailed below, were relied upon for the determination in 
every instance that a dwelling unit or other structure is 
substandard. In this regard, all judgments relating to 
(1) structural inadequacy, (2) susceptibility of struc- 
tures or lots to major subsidence or erosion, (3) inade- 
quacy of infrastructure, (4) susceptibility of structures 
or lots to drainage problems, (5) compliance of struc- 
tures with applicable housing and building codes, (6) 
susceptibility of structures to condemnation as nui- 
sances, and (7) the non-cost-effectiveness of rehabil- 
itation of deteriorated structures, are based solely on 
exterior observation. 

Because minute inspection was not made of each 
structure, and because interior inspection was not made 
in any instance, all determinations were made on a very 
conservative basis. If there was any doubt whether a 
structure was deficient in any regard, it was deemed not 
to be deficient for the purpose of this survey. 

Flood prone structures were classified on the 
basis of general field observations relative to the 100- 
year flood plain that has been identified in Rangely by 
the United States Department of Housing and Urban Devel- 
opment. Structures identified in this survey as deficient 
with respect to their location within the 100-year flood 
plain do not include those structures which appeared to 
us to have been "flood proofed" or to have been elevated 
so as to be in general compliance with the existing Town 
of Rangely flood plain ordinance. Flood-prone structures 
that have been identified in this survey therefore exhib- 
ited one, or more, of the following deficiencies: 

1. Mobile Homes: (a) not elevated to, or 
above, level of 100-year flood plain zone; or (b) not 
tied down to guard against flotation; or (c) apparent 
that utilities of identified unit not "flood proofed." 


I— « 


2. Single-family/multiplex: (a) same as 1(a) 
and 1(c) above; or (b) apparent that identified unit has 
full or half basement. 

3. Other structures: (a) not elevated to, or 
above, level of 100-year flood plain zone, or (b) appar- 
ent that identified unit not "flood proofed." 


The criteria described below are the criteria that 
were used in compiling the data sheets that comprise 
Exhibit "A" to this report. 

A. Structural Inadequacies . Determination of 
deficiency based on visible foundation or external wall 
cracking; visible evidence of settling; or "racking" of 

B. Code Compliance . Determination of deficiency 
based on judgments relating to compliance with the Uniform 
Building Code and local ordinances. Host judgments re- 
lated to lack of sanitary facilities, or to accumulation 
of trash and other debris or refuse around existing 
structures . 

C. Cost-Effectiveness of Rehabilitation . Deter- 
minations of deficiency made on this basis are extremely 
conservative, because of subjectivity of judgment involved. 

Structures so identified have very serious, obvious 
structural defects. 

IL Condemnation as Nuisances . Determination of 

deficiency based on definition of "nuisance" in Uniform 
Building Code. Most observations were based on extreme 
deterioration, accumulation of junk and debris, and lack 
of adequate sanitary facilities (e.£. , all of the 
recreational vehicles used as permanent dwelling units 
are susceptible to condemnation on this basis). 

E. Flood Plain . Determination of deficiency ex- 
plained in detail above. 

Li Susceptibility to Major Subsidence or Erosion . 

Determination of deficiency based on visible evidence of 
cracking, or "racking"; susceptibility to erosion was 
also judged on the basis of historical localized drainage 
problems which have affected buildings. Moreover, where 
the outfalls of major drainageways were located so as to 
cause probable erosion to structures, these structures 
were assumed to be susceptible to subsidence or erosion. 

<L= Inadequate Infrastructure . No fixed structures 

could be judged deficient due to lack of sewer, water or 
fuel facilities. All of the recreational vehi- 

cles used as permanent dwelling units were determined to 
be deficient with respect to this criterion, however. 

- 9 - 

All other infrastructure inadequacies related to narrow- 
ness of roads, or difficult circulation patterns by which 
dwelling unit or structure was served. 

H. Unpaved Roads . Self-explanatory. 

I . Inadequate Lots . One or more recreational 
vehicles used as permanent dwelling units were determined 
to have poor accessibility to Route 64; several fixed 
structures that are situated abutting or immediately ad- 
jacent to the Route 64 right of way were also judged to 
be deficient . 

J. Inadequacy of Drainage . Determination of de- 
f ici ency based on same justification for Susceptibility 
to Erosion, as described above. 


A. Total housing stock within town limits : 

Single-family units 
Mobile home units-^/ 
Duplex units 
Apartment units 
Recreational vehicle units^/ 







6? Based on 1980 census data. Town of Rangely utility 
billing records, and recent Building & zoning Permit 
records . 

2/ Includes eight temporary mobile home sitings. 

8/ Mostly unlawful sitings. 


B. Other surveyed structures: 

Hotel units!/ 

institutional structures^!/ 


C. Dwelling units (and percentage) in need of 
structural repair, as viewed from the exterior only. 

Apartment units 
Duplex units 
Single-family units 

Percentage of total dwelling units 





D. Number and percentage of dwelling units that 

are not in compliance with applicable housing or building 

codes (without regard to the need for structural repair) : 

Mobile home units 
Recreational vehicle units 
Apartment units 
Duplex units 
Single-family units 

Percentage of total dwelling units 






57 Units set aside as permanent or semi-permanent dwell- 
ing units — addressed separately in Section I of this 
report . 


_I. e^ , all principal structures not used as dwelli 



- 11 - 

E. Number and percentage of dwelling units and 

other existing structures that are so deter iorated that 

rehabilitation thereof would not be cost-effective : 

S ingle-family units 5 

Apartment units 21 


Percentage of total dwelling units 3.2% 

Other structures 2 

Percentage of total of all other structures 1.8% 

Total dwelling units and other structures 28 

Percentage of total of all dwelling 3.1% 
units and other structures 

F. Number and percentage of dwelling units and 

other structures that are subject to condemnation as 

nu isances: 

Mobile home units 1 

Recreational vehicle units 7 

Apartment units 21 

Single-family units 7 

Percentage of total dwelling units 4.5% 

Other structures 2 

Percentage of total of all other structures 1.8% 

Total dwelling units and other structures 37 

Percentage of total of all dwelling 4.0% 
units and other structures 

- 12 - 

G. Number and percentage of dwelling units and 

other structures that are not in compliance with the 

existing Flood Plain Ordi nance: 

Mobile home units 5 3 

Recreational vehicle units 1 

Duplex units 2 

Single-family units 2§_ 

Percentage of total dwelling units 10.6% 

Other structures 12 

Percentage of total of all other structures 10.5% 
Total dwelling units and other structures 97 

Percentage of total of all dwelling 10.6% 
units and other structures 

H. Number and percentage of dwelling units and 
other existing structures that are on sites where the lot 
or the improvements thereon are susceptible to major sub- 
sidence or erosion problems : 

Mobile home units 14 

Recreational vehicle units 1 

Apartment units 21 

Duplex units 2 

Single- family units 7 


Percentage of total dwelling units 5.6% 

Other structures 1 

Percentage of total of all other structures 0.9% 

Total dwelling units and other structures 46 

Percentage of total of all dwelling 5.0% 
units and other structures 

- 13 - 

I. Number and percentage of dwelling units and 
other structures that are served by inadequate street, 
sewer, water, or heating facilities: 

Mobile home units 
Recreational vehicle units 
Duplex units 
Single-family units 

Percentage of total dwelling units 

Other structures 

Percentage of total of all other structures 
Total dwelling units and other structures 
Percentage of total of all dwelling 
units and other structures 







J. Number of dwelling units and other existing 
structures that may not be reached except by use of un- 
paved roads: 

Mobile home units 
Recreational vehicle units 
Duplex units 
Single-family units 

Percentage of total dwelling units 

Other structures 

Percentage of total of all other structures 
Total dwelling units and other structures 
Percentage of total of all dwelling 
units and other structures 









- 14 - 

K. Number and percentage of dwelling units and 
other existing structures that are inadequate with re- 
spect to size, access to light, or proximity to Highway 

Recreational vehicle units 4 

Single-family units _3 

Percentage of total dwelling units 0.9% 

Other structures 

Percentage of total of all other structures 0% 

Total dwelling units and other structures 7 

Percentage of total of all dwelling 0.8% 
units and other structures 

L. Number and percentage of dwelling units and 

other structures that are sited on lots that suffer from 

chronic problems of inadequate drainage: 

Mobile home units 14 

Recreational vehicle units 1 

Apartment units 14 

Single-family units 4 

Percentage of total dwelling units 4.1% 

Ot;her structures 3 

Percentage of total of all other structures 2.6% 

Total dwelling units and other structures 36 

Percentage of total of all dwelling 3.9% 
units and other structures 




% of 













Substandard Units 

Mobile home units 
Recreational vehicle units 
Apartment units 
Duplex units 
Single-family units 

Primary Conclusion: Of the 801 permanent dwelling 
units within the Town of Rangely, 174, or 21.7%, are sub- 
standard in some respect that evidence conditions of 
"blight," as statutorily defined. 

Respectfully submitted, 

Brent R. Snyder "7 
Town Building Inspector 

Dated: February 8, 1982 


Other conditions contributing to blight . Refer- 
ence to Exhibit "A" photographs: Nos. 14, 22, 28, 29, 
31, 35A, 36A, 8A, 11A. 

During the survey, certain other factors were also 
identified as contributing to blight, although these fac- 
tors could not be quantified in terms of the count of 
dwelling units and other structures. These factors in- 
clude vacant lots and portions of commercial/industrial 
lots which are badly littered with refuse and other 
debris . 

Furthermore, one example of extreme physical 
structural impact also fails to fit into the statistical 
format that was adopted. We refer to a defective foun- 
dation on Lot No. 26, Hillcrest Subdivision. In this 
instance, the residence has physically shifted off the 

Other Evidence of the Demand for Increased Supply 
of Safe and Sanit ary Housing . Reference to Exhibit "A" 
photographs: Nos. 9B, 10B, 11B, 12B, 4A, 5A. 

The demand for housing in Rangely is so great that 
some persons have apparently been forced to site recrea- 
tional vehicles, and other makeshift accommodations, in a 
random and generally uncontrolled fashion in the vicinity 



of Range ly , albeit outside of the Town limits. Although 
some such units may be fully self-contained, it may be 
determined that a majority of them do not possess even 
the most basic sanitary facilities. The numbers and 
types of such units identified during the survey are as 
follows: (a) 22 recreational vehicles (various types, 
could accommodate various numbers of persons) ; and (b) 
one army tent (may accommodate up to 10-12 persons) . 


Data Sheets for Survey of Existing 

Housing Stock and Other Structures 

in the Town of Range ly 




Town of Rangely 


July 31, 1982 

A.) Count as of June 26. 1981: 

Sinqle-Family Mobile Homes Duplex Apartments 

Temporary Housing 

460 220 30 60 

(15 Bldg) (10 Bldgs) 

59.7% 28.6% 3.9% 7.8% 



B.) Count as of July 31, 1982: 

Sinqle-Family Mobile Homes Duplex Apartments Temporary Housing 
+30 (new) +8 (new) +4 (new) +6 (new) +11 (Mobile Homes) 
+ 5 (annx) +1 (annx) -15 (demol ) + 6 (R.V.) 

- 2 (demol) 

Balance +32 

6/26 Tot. 460 


1 (fire) 



- 9 

+ 17 








(61%) (28.4%) (4.2%) 
GRAND TOTAL: 806 (823 with temp.) 



(1.4% ) 

Vacancies as of 8-28-82: 

2.836 persons/household (1980 census) 

2.836 x 806= 2,286 
2.836 x 823= 2,334 (with temp.) 
less 11 vacancies x 2.836= 2,303 (w ith temp) 
2,255 (without temp) 

Breakdown of Housing Units Currently Under Construction 
September 1, 1982 

60 units - Sagewood West Apartments 

20 Sagewood West (single family) 

3 Hank Wilson (single family) 

3 Lifestyle Homes (single family) 
2 Lorain Brady (duplex) 

2 Bill Ward (duplex) 

4 Neiberger Construction (single family) 

2 Tamarron Subdivision (Mark - single family) 
24 Senior Citizens (Housing Authority) - attached 
I The Ridges (Caruso) - single family 

121 Units 

Breakdown of Pending Housing Units Currently Under Consideration 
September 1, 1982 

1 unit 



- Neiberger Construction - final plat approval 
(3 duplexes - Kuck) final plat approval 
(124 single family; 164 multi family) Western Fuels - final 

plat approval 
Townhomes (Redwood Estates) - preliminary sketch plan approval 
The Ridges - townhomes - Benchmark Homes - pending 
Townhomes - Kirk Hill - pending 
100 RVs; 252 mobile homes; 144 mul ti -fami ly ; 162 single-family 

Titus - pending - schematic only. 
Tamarron Subdivision - final plat approval 

1,137 Units 





Town of Rangely, Colorado 

18.1 The Socioeconomics Technical Report and the EIS data for Rangely and 
Dinosaur came from the Colorado Cumulative Impact Task Force 
community profiles. This source was identified by the Colorado 
Department of Local Affairs as its preferred source for accuracy and 
consistency with other on-going analyses such as the Federal Oil 
Shale Management Program EIS (BLM 1983). The Colorado State BLH 
concurred with this source to avoid duplication and limit costs. 

18.2 The projections of growth from the proposed projects in the Uintah 
Basin are forecast to occur primarily within Uintah and Duchesne 
counties in Utah. The analysis of Uintah and Duchesne counties is 
more detailed for this reason. See also the response to Comment 

18.3 When accomplishing impact projection, the Colorado communities were 
treated exactly as Utah communities and the methodology was applied 
equally. Community-specific projections can be found in Tables R2A- 
7, R3A-13, R3A-27, R3A-42, R3A-45, SSA-2, and SSA-4 of the 
Socioeconomics Technical Report. These projections allow comparison 
with other communities throughout the technical report. The Colorado 
area was an area derived for modeling purposes similar to the CCD's 
in Utah (the Utah CCD's also contained several communities). The 
"Colorado Area" was used, because it was believed that the impact 
would be centered in this area, which consisted of the Rangely CCD 
plus the town of Dinosaur. The 1980 census was used to establish the 
calibration data for this area; no uncomparability should be created 
by using such a designation, because allocations between counties and 
communities were accomplished and can be found in the tables listed 
above. In all cases, Rangely was given equitable consideration in 
the impact projection efforts. 

18.4 Table R2B-I has been modified in the Final Socioeconomics Technical 
Report to portray housing data for Rangely and Dinosaur, 
respectively, based on data submitted with comments received from 
both communities. 

18.5 Dinosaur and Rangely dwelling unit data in Table R2B-I have been 
separated to show data for each community in the Final Socioeconomics 
Technical Report. This is based on additional housing information 
submitted by Rangely and Dinosaur with their comments. The sources 
of the data are shown on revised Table R28-I. 

18.6 The BLM perceives that cost/revenue analysis of community services is 
an integral part of mitigation, and, thus, the purview of state and 
local government. For this reason, such analysis is not part of this 
EIS nor the accompanying Socioeconomics Technical Report. 

The assessment that federal bonus and royalty payments from tracts U- 
a and U-b would be distributed by the State of Utah to the Ashley 
Valley rather than Rangely is valid. It is also true that in the 
absence of an interstate sharing mechanism, Rangely would not share 
in the royalty payments to the State of Utah from the Paraho and 
Syntana-Utah projects, which are situated on State of Utah lands. 

18.7 Anticipated project life for Syntana-Utah is 30 years and for Paraho, 
10 years as shown in Table R-l-1. An Additional Lands Alternative 
(described in Section P-1.E.4), which would extend the life of the 
Parhb project for 20 additional years, has been added to the Final 
EIS. The Detailed Development Plan for the White River Shale Project 
projected a 25-year project life. However, additional oil shale 
reserves (federal and state) in the region provide a potential for 
extending the life of these and other proposed oil shale projects, 
depending upon economic and resource conditions after the year 2000. 

18.8 Housing strategy is a mitigation measure that the BLM perceives is 
within the purview of state and local government. It is assumed that 
the proposed projects will comply with state and local laws relative 
to socioeconomic mitigation. While the BLM does not consider itself 
as the appropriate agency to dictate those measures, BLM encourages 
the Town of Rangely to initiate discussions with White River, Paraho, 
and Syntana-Utah on potential housing strategies. 

18.9 Baseline projections for Rangely which appear in Table R2A-7, page I- 
26, were provided by the State of Colorado through the Cumulative 
Impact Task Force. 

18.10 The dwelling unit data furnished in the comment has been incorporated 
into Table R2B-1 in the final technical report. 

18.11 The housing numbers for Rangely have been changed in Table R2B-2 of 
the Socioeconomics Technical Report to show the existing conventional 
(single-family units) housing conditions from the Survey of Existing 
Housing Stock and Other Structures in the Town of Rangely prepared by 
Brent Snyder, Building Imspector, Town of Rangely, dated February 8, 

18. 1Z The Rangely Library presently has 12,000 books and about 3,000 square 
feet of space (a 900-square-foot addition is nearing completion) 
(Chambers 1982). Table R2B-8 has been amended accordingly. 

18.13 The Socioeconomics Technical Report presents summary fiscal data for 
Rangely and Dinosaur and for Moffat and Rio Blanco counties in 
Section R2B, Fiscal, Colorado Area, of the Socioeconomics Technical 
Report. It does not furnish fiscal profiles for the Colorado 
counties, municipalities, and school districts similar to those 
presented for Utah. 

18.14 Information about the Rangely airport has been added to Section R2C 
of the technical report and Section R-3.A.7 of the EIS. 

18.15 Information about the improvements to Colorado Highway 64 has been 
added to Section R2C of the technical report and Section R-3.A.7 of 
the EIS. 

18.16 Information concerning Colorado Highway 64 (between Dinosaur and 
Rangely); Colorado Highway 139, the Douglas Pass Road, (between Loma 
and Rangely); and County Road 21, the Mormon Gap Road (between 
Colorado Highway 64 and Bonanza, Utah) has been added to the 
Transportation Data Chart. 



18.17 All language referring to local officials has been removed in the 
Socioeconomics Technical Report, Transportation sections. BLM is 
unaware of any company policy for any of the applicants' proposed 
projects that would restrict workers from residing in Rangely or 

18.18 Tables R3A-11 and R3A-13 are not inconsistent; they portray different 
information. Table R3A-11 shows population and employment impacts by 
county census division, while Table R3A-13 shows population and 
household data by community. The number of households for 
incorporated areas does not exceed that projected for the CCD, as no 
household projections were completed by CCD. Instead, employment 
information was provided for each CCD in Table R3A-11. 

18.19 Given a 1985 projected baseline population for Rangely/Dinosaur of 
3,194, a baseline demand of 49 (rather than 51) is too high, based on 
the law enforcement standards of two police officers per 1,000 
population. However, the low-level scenario impact of two police 
officers for the increased population of 1,176 is consistent with the 
law enforcement standard. 

18.20 This same rationale as identified in the response to Comment 18.19 
(above) would apply to the patrol car projections. The baseline 1s 
in error but the impacts are valid based on the standards. 

18.21 Table R3A-21 does illustrate the total Colorado impacts. However, 
Table R3A-27 shows these impacts are allocated to communities in the 
same manner as Utah communities. 

18.22 Table R3A-24 shows employment impacts for Colorado. It is true that 
only induced employment impacts occur in Colorado and not direct 
employment impacts. This is due to the fact that employment is 
measured by place of work and all synfuels development jobs analyzed 
in this EIS occur within the boundaries of Utah. 

18.23 Refer to the response to Comment 18.21. 

18.24 Housing impacts for Rangely/Dinosaur are not addressed on page 1-194 
nor in Table R3B-16 in the technical report. Housing impact data for 
Rangely/Dinosaur are presented in Table 4-6 in the EIS and, for 
consistency, have been added to Table R3B-16 in the technical 

18.25 The baseline demand of 5,273 students for Rangely in 1985 is 
incorrect, given a baseline population projection of 3,192 for 
Rangely in 1985. This error has been corrected in Section R3B of the 
final technical report. However, the high-level scenario impact of 
205 students in 1985 is valid, and would translate into a need for 8 
additional teachers (205 divided by 25) as shown on Table R3B-18. 

18.26 While the baseline demand for hospital beds is inaccurate based on 
the combined baseline population projections for Rangely and Dinosaur 
in 1985, the high-level scenario impact of two hospital beds is 
valid, based on the combined project related population increase of 
1,176 for 


Rangely/Dinosaur (hospital bed standard - 2 beds per 1,000 
population). The baseline demand error has been corrected in Section 
R3B of the final technical report. 

18.27 The impacts from individual projects on Rangely and Rio Blanco County 
are discussed in Section II in Tables SSA-1 through SSA-4. As noted 
in these tables, none of the individual projects by themselves would 
create a 10 percent increase in Rangely population over the expected 
baseline growth. Because of the 10 percent significance criteria 
used, no further site-specific analysis was done on the community of 

18.28 Selected data furnished with the comments has been utilized in 
revising sections pertaining to Rangely in the Socioeconomics 
Technical Report and EIS. BLM appreciates and encourages the 
submittal of additional data from any entity involved in review of 
these documents. 

18.29 This statement was also submitted to BLM in the form of a letter. 
Refer to Letter 15 for responses. 

18.30 The analysis procedures and standards utilized in the White River 
Shale Project EIS differ from those used in the Uintah Basin Synfuels 
Development EIS. The 203 acres of developed and undeveloped land 
within the Parks and Recreation District in Rangely is a projection 
for the year 1993 based on a standard of "65 acres of park land per 
1,000 people." This standard was derived by the Colorado Department 
of Local Affairs. Although the Parks and Recreation District in 
Rangely currently has 45.5 acres, the projected population increases 
by the year 1993 would require an addtional 157.5 acres to keep pace 
with forecasted demand, utilizing the Colorado Department of Local 
Affairs standard. 

18.31 Population baseline and impact projections (Table R-4-4) and Housing 
Demand baseline and impact projections (Table R-4-6) present data for 
Rangely and Dinosaur separately. Employment baseline and impact 
projections (Table R-4-5) combine the Rangely and Dinosaur portions 
of Rio Blanco and Moffat County under the heading of Colorado Area. 

Several of the tables in the Infrastructure section of the Draft 
Socioeocnomics Technical Report that lumped Rangely/Dinosaur data 
together, have been split out to present data for each in the final 
techical report. (See Tables R2B-1, R2B-2, R2B-3, R2B-8, R28-9, R2B- 
10, R2B-11). 

(1) Baseline population projections were obtained from the State of 
Colorado Cumulative Impact Task Force data base. Infrastructure data 
were obtained from city, county, school, hospital, police, and sewer 
district officals as shown in the footnotes to each table. As 
discussed in the preceding paragraph, data in several of these tables 
were revised, refined, or disaggregated between Rangely and Dinosaur 
based on additional data furnished with comments on the Draft EIS. 

(2) While an environmental impact statement cannot be developed over 
the phone, it is possible to obtain some data and sources of data 
over the phone, often saving time and money. 

(3) See the first paragraph of this response concerning the lumping 
of Rangely and Dinosaur. 

(4) The State of Utah personnel working on the Socioeconomics 
Technical Report were in Rangely in February and March 1982. The 
baseline figures were developed from information obtained from the 
Colorado Cumulative Impact Task Force data base and the various 
officials listed in (1), above. 

18.32 The intent of the Uintah Basin Synfuels Development EIS and its 
supporting technical reports is to present, to the best of our 
knowledge, the most up-to-date and factual information for public 
review and comment. The highest code of ethics, in support of the 
public interest, is demanded, fin unbiased and objective approach for 
impact analysis is required, while utilizing the latest state-of-the- 
art scientific methods and procedures. There are no secondary or 
hidden motives behind this EIS or its supporting technical reports. 

18.33 The design capacity of Rangely High School is 380 per the October 12, 
1982, letter from Superintendent Young. This would make the present 

O capacity of the Rangely Public Schools 980 rather than 1,100 

1^ (Socioeconomics Technical Report Table R2B-3). Using the 1981 

enrollment figures (1981 was used for all school analysis) obtained 
from school officials results in operation at 52 percent of design 
capacity in 1981, or 48 percent excess capacity rather than 52 
percent as shown in the text (Section R-3.A.1). This has been 
changed. Using the 1982 enrollment figures furnished by 
Superintendent Young results in operation at 71 percent of design 
capacity in 1982. This confirms a substantial increase in the 1982 
school enrollment for Rangely as a result of the Western Fuels 



United States Department of the Interior 



Ki.rt l>urlir«m . I'lah 81CI26 
(801) 722-2406 Ext. 


Land Operation 

October IS, 1982 



Mr. Lloyd Ferguson, District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 84078 

Dear Mr. Ferguson: 

We have reviewed your Draft Environmental Impact Statement (EIS) on the 
proposal Uintah Basin Synfuels (Oil Shale and Tar Sand) projects and 
alternatives dated August, 1982 (1792-UBS, U-910) . 

General Comments : 

It is the opinion of this agency that this draft does not 
adequately address the secondary impacts which will result 
following the partial or overall development of the Uintah 
Basin The socioeconomic resources are of main concern to 
the Ute Tribe followed by air quality, soils, agriculture, 
vegetation, water quality and wildlife. As you are aware, 
the topics just mentioned have been of great importance to 
the Ute Tribe and have yet to be address fully to the 
satisfication of the Tribe and Agency. The Bureau of Land 
Management {BLM) commissioned a special project to detail 
the socioeconomic impacts that may occur to the Uintah and 
Ouray Reservation because of the proposed development. 
However, the Ute Tribe is concerned that this document will 
not be included properly and in supporting context in the 
final EIS. We strongly suggest that the Ford, Bacon & Davis 
Utah, Inc. document be included in its entirety within the 
body of the final EIS. 

Specific Comments : 

p-3-L, Regional Affected Environment . Paragraph 1. "the area 
described for a particular element is referred to as the area 
of influence, which is the area that would be significantly 
affected, either directly or indirectly, by the proposed projects". 
What criteria was utilized to make the determination "area of 
influence" for these projects? We feel that the entire Ute 
Indian Reservation will be significantly affected and should be 
more specifically addressed as to the adverse impacts. 







r-3-1. Regional Affected Environment . Paragraph 2. It is stated 
"Energy Development, primarily oil and gas development, has already 
changed the environment of the Uintah Basin in a significant manner". 
Is this impact irreversible? What cumulative impact will the synfuels 
development have on this already significant change in the Uintah 

R-3-1. Hi gh-Level Scenario . Paragraph 2. The communities of Myton, 
Ballard, "vernal, and Roosevelt are listed in the area of influence, 
however, there is no mention of the predominantly Indian Community 
e.g. Fort Duchesne, Whiterocks. Randlett, and Ouray„ Is there reason 
for the oversight as we feel these communites are within the area of 

R-3-1. High-Level Scenario . Paragraph 2. Last sentence. The discussion 
here establishes that the project utilized a Denver Research Institute 
Study, identifying 10 percent as a general threshold level. The State 
of Utah recognized the need for mitigation for projects resulting in a 
5 percent growth rate, which constitutes evidence of probable impact. 
By failing to address this the draft EIS has possibly eliminated areas 
of probable impact. 

R-3-3. High-Level Scenario. Socioeconomics. Last paragraph. We agree 
that there are distinct difference between socioeconomic statistics and 
that methods used to project impacting to non-reservation entities do 
not reflect actual reservation conditions, situations and needs. 
Therefore, why weren't research techniques developed that would address 
conditions, situations and needs for the reservation? We feel the 
statement "it is nut possible to fully quantify baseline data and baseline 
projections for all aspects of the reservation's socioeconomic environment 
that would be affected" is true. Contained in same paragraph, last 
sentence, how can there be discussion on baseline conditions on the 
reservation where " specific baseline data is unavailable ?" 

r-3-3. Population and Employment . Paragraph 5. "To qualify as an 
enrolled tribal member of the Ute Indian Tribe, a person must have at 
least 5/8 part, insert Ute here, Indian Blood. 

R-3-5. Baseline Population by Community . Table R-3-2. The UPED model 
excludes Indian communities. He feel that Indian communities should be 
listed and address through-out the EIS. 

r-3-9. Baseline Housing Demand by Community . Again, Tribal communities 
are not included in table. 

R-3-10. Government Servi ces and Facilities 

Education. The entire section 

ry serious existing problem which will only become more 
intense with the proposed development. We recommend additional study as 
to the conditions creating this event and what recommended action needs to 
be taken to correct this condition before it get worse. 








R-3-12. Government Services and Facilities . Law Enforcement. 
Paragraph 1. "The area of influence presently requires expansion 
of existing jail facilities; there is also need for additional 
police officers , etc. " With these increases in service there is 
also the economic factor to support Law Enforcement. The question 
is: What mitigation is being offered by the proposed developers to 
financially support these expansions? The burden should not be 
imposed on the federal government or tribe? 

R-13-12. Government Services and Facilities . Fire Protection. The 
statement as presented in regards to Ute Tribe is incorrect. The 
Bureau of Indian Affairs is responsible for all fire prevention and 
suppression on the reservation. The Ute Tribe provides equipment 
which is manned by B.I. A. Employees. By verbal agreement with the 
towns of Neola, Tridell, Lapoint, Myton and Roosevelt the party 
nearest a fire will respond regardless of the Indian or Non-Indian 
status of the property owner, i.e. if an Indian's home was on fire in 
Neola, the Non-Indian fire department will respond and will provide 
initial attack until B.I.A.'s units arrive and they will provide 
support. We feel this area needs additional study,, 

R-3-13. Government Services and Facilities, Water . Paragraph 2. It 
should be stated that Roosevelt purchases culinary water from the 
Ute Tribe, and experience water shortage problems especially in the 

summer months. 

R-3-13 a Government Finances . There is no mention in this section as 
to how the Ute Tribe finances its governmental operation. We feel 
additional study is needed in this area in that the tribe does not 
assess on income tax or property tax upon its members. The tribal 
government is financed from income derived from tribal resources. A 
basic understanding of tribal finances is needed before impacts and 
mitigation can result. 

R-3-15. Other Sections, Hunting, Fishing, and Nonconsumptive use 
Expenditures . Paragraph 1, last sentence. The cited Section R-3.A.4, 
Wildlife is incorrect. That cited Section is Vegetation and Soils. 
The correct Section is R-3.A.5, Wildlife. 

R-3-16 Quality of Life, General Comment . It is our viewpoint that 
the majority residents of the Ute Indian Reservation would not be in 
favor of large industrial sites in close proximity to their reservation 
for several reasons. These include, but are not limited to, air quality, 
agriculture, hunting and fishing recreation, changes by man to the earth 
and education of the Indian people. 

R-3-23. Water Resources, Surface Water . This section does not provide 
sufficient water chemistry data in which to assess environmental impact. 
The total Dissolved Solids and Suspended Solids will be increased due 
to construction activity. Measures to limit and protect the rivers from 



run off by the activity need to be addressed in much greater detail. 
Soil Conservation Service is sponsoring a 20 million (+) dollar 
project to reduce salinity in the Colorado River Drainage. 

R-3-25. Ground Water . Paragraph 2. It is stated "there is approximately 
300,000 ac-ft/yr. of potential ground water supplies available for use 
in the Basin". Does this statement imply that the project will require 
any or all of this water? 


R-3-27. Vegetation Types, Riparian . "The riparian type of vegetation 
occupies approximately 6,150 acres, which is less than 1 percent of the 
area of impact". What protection is being taken to protect all riparian 
areas? What mitigation is offered if any of the riparian habitat is 





R-3-32. Threatened and Endangered Species . Paragraph 2. The Statement 
"Category 1 and Category 2 plant species that have been located in the 
region, and could be affected by the applicant's proposed project" should 
provide more detail. What has resulted from Section 7 consultation with 
the U.S. Fish & Wildlife Service? What recommendations to remove and 
reestablish these species have been offered, if any? 

R-3-33 S oils . Paragraph 2. Your statement "Revegetation is difficult 
for most of the soils in the region...." What impact will this offer to 
the overall reclamation program? 

R-3-34. Wildlife; Habit at_ Types. This entire section was addressed 
quite well, however, it did not address fully the impact the Synfuels 
development will have on wildlife populations and habitat. Moreover, it 
discussed only consumptive species and loss of habitat. 

R-3-42. Threatened or Endangered Species . The section should address 
procedures taken in regards to Section 7 consultation as required by 
the Endangered Species Act„ What impact on nesting, feeding and resting 
areas will be Synfuels Development have on these species? This area 
will need to be studied further. 


R-3-44. Transportation Networks . It should be mentioned that the Uintah 
and Ouray Reservation will have to be considered as far as right-of-ways, 
road improvement, maintenance and expansion of rights-of-way are concerned 
prior to crossing reservation lands. 



R-3-46. Recreation. Paragraph 3. The statement "Due to lack of 
information, baseline projections on recreation within the Uintah and 
Ouray Indian Reservation cannot be made". We feel that the impact of 
recreation from the projected increases in populations in the area of 
influence needs further study to adequately address this issue. 


Visitor Use Data. This section could be addressed with further 








R-4-2. Impact Significance Criteria/Socioeconomics . Paragraph 2. This 
paragraph justifies the need to include, "A Socioeconomic Assessment of 
Uintah Basin Synfuels Development on the Uintah and Ouray Reservation; 
by Ford, Bacon & Davis Utah Inc., October 1982 in complete form within 
the body of the final Environmental Impact Statement. We strongly 
recommend that this assessment become , in full context , part of the 
final EIS. 

R-4-65„ High-Level Scenario-Wildlife . This section attempts to justify 
the loss of habitat, reduction in wildlife populations, loss of winter 
range, movement of animals into adjacent areas with below carrying capacity 
numbers , increased poaching activities , reduction in income to the region, 
harassment on animals already in a stress situation , mortiality to small 
burrowing rodents is okay because natural population turnover occurs 
rapidly, reducation of ring-necked pheasant, loss of nesting habitat for 
morning doves, sage grouse populations receiving harassment from project 
personnel watching or trying to take pictures of strutting grounds. Due 
to the fact that all the above cited areas will be impacted, what mitigation 
does the synfuels development offer to compensate for these losses? Moreover, 
the indirect impact the Uintah and Ouray Reservation will inherit from 
illegal activities has not been addressed or mitigation offered. The tribe 
will have to hire more law enforcement people (rangers, too) and eguipment 
to handle this secondary impact. Where will the funds be derived from to 
manage the results of economic development by synfuels development? This 
issue is of great concern to both the Ute Tribe and B.I. A. 

R-4-69. High-Level Scenario-Wildlife, Reptiles and Amphibians . There 
appears to be much speculation here without any specific research or 
studies backing the statements. We would suggest before you automatically 
write off populations of unknown species and population densities that you 
first find out exactly what species are there and their numbers. To suggest 
the unknown populations would quickly be replaced has to be substantiated. 
Moreover, without scientific data, how can you speculate by saying "no 
significant impacts to these species are anticipated". 

R-4-69 „ High-Level Scenario-Nonconsumptive Uses . The Ute Tribe is not 
mentioned through-out the High-Level Scenario-Wildlife portion in this 
section as well as other sections under the heading. The second paragraph 
discusses poaching and it's "adverse impact on a $20 million a year 
re-newable resources". Who plans on reimbursing the Uintah Basin Communities 
for this loss in revenue? 

r-4-70. High-Level Scenario-Wildlife - Threatened or Endangered Species . 
Paragraph 1. Because of the significence of loss of the black-footed 
ferrets due to destruction of their food source and habitat, we strongly 
suggest further study of the prairie dog colonies for signs of black-footed 
ferrets prior to destroying this habitat. 


Conclusion : 

We are extremely concerned that since the Ute Indian Tribe is not afforded the 
protection of Law under S.B. 170, and that proposed development is not on 
reservation lands , they will not receive compensation for secondary adverse 
impacts from Synfuels Development. Until a means for compensation is developed 
the Bureau of Indian Affairs must support the no action alternative. 

The opportunity to comment of this draft EIS is appreciated. If Bureau comments 
need clarification, please contact Mr. Dennis Montgomery, Acting Land Operation 
Officer, who is assigned the responsibility of coordinating the Bureau efforts 
in this matter. 

Sincerely yours. 


Henry _^7 Cuch 

Acting Superintendent 




U.S. Bureau of Indian Affairs, Uintah and Ouray Agency 

19.1 The Ford, Bacon, and Davis study has been included in the 

Socioeconomics Technical Report. Information from this report has 
also been included in summary form in pertinent sections of the Final 

19. Z The area of influence for a particular element encompasses the area 

to which impacts of the proposed projects can be traced. The 
determination was made by the principal author or contractor for that 
element, based on generally accepted standards or the author's 
professional expertise. (Refer to the List of Preparers for names of 
authors and contractors.) 

An additional study of impacts to Native Americans has been completed 
(refer to the response to Comment 19.1). The EIS discussion of 
impacts to the reservation has been expanded based on the information 
provided by the study. 

19.3 The socioeconomic impact of oil and gas development is primarily 
related to population and would vary as oil and gas development 
induced population varies; therefore, this impact is not 
irreversible. Other resource impacts, such as effects on vegetation, 
visual resources, and air quality, would have both reversible and 
irreversible impacts; those changes that have already occurred are 
probably irreversible. 

The cumulative impacts of the nine applicants' projects on baseline 
conditions (described in Chapter R-3) are discussed In Chapter R-5 
and summarized 1n Chapter R-2. 

19.4 The Uintah and Ouray Indian Reservation is definitely in the area of 
influence; projections of Impact were developed by the UPED and SAM 
models for the Roosevelt and Uintah-Ouray County Census Divisions, 
which encompass the majority of the reservation, including the 
communities of Fort Duchesne, Whiterocks, Randlett, and Ouray. 
However, no community-specific allocations of these projections were 
completed for these communities, because no economic and demographic 
information was readily available from which to do so. Census 
demographic information used for the calibration of the UPED model is 
available only for incorporated communities. The supplemental Indian 
study, which is included in the Final Socioeconomics Technical Report 
and summarized in the Final EIS, addresses reservation-specific 
projections more completely. 

19.5 The 10 percent criterion is based on a standard generally accepted 
within the professional socioeconomic community (for example, the 
Denver Research Institute (Gilmore and Duff 1975)). This figure 
represents a general threshold where a government's ability to meet 
increased service demand breaks down. Even so, much of the Final EIS 
data gives growth figures well below the 10 percent threshold to 
enable possible impacts to be assessed. All areas, regardless of the 
level of impact, are included in this study. The 5 percent threshold 

figure used by the State of Utah is for its mitigation purposes. 
Mitigation measures will need to be addressed by each synfuel 

19.6 Based on the results of the Ford, Bacon, and Davis study, Section R2D 
of the Socioeconomics Technical Report and the Native American 
sections in the Final EIS have been expanded. Wherever possible, 
baseline information is quantified; it is qualified where specific 
data is unavailable. 

19.7 Section R-3.A.1 has been revised to clarify Ute Indian blood is 

19.8 The Final Socioeconomics Technical Report, Section R2D, Indians, 
explains how the UPED model was used to obtain data for the Final 
EIS, in which the Indian communities are addressed more thoroughly. 

19.9 Housing demand data for the reservation is included in the figures of 
Table R-3-3. For explanation, see the response to Comment 20.59. 

For disaggregation of these data, please see the appropriate site- 
specific sections 4.A.1, Section R-1.A.1, Housing, or the 
Socioeconomics Technical Report, Section R2D. 

19.10 As indicated by the comment, the pre-existing conditions are 
addressed in Section R-3.A.1. CEQ regulations do not require 
analysis of the creation or correction of these pre-existing 
conditions. However, the effects of the proposed projects on these 
pre-existing (baseline) conditions are discussed in the EIS. Impacts 
are outlined Section R-4.A.1 and detailed in the 
SocioeconomicsTechnical Report, Section R-3. Uncommitted mitigation 
measures, which are the prerogative of the individual company or an 
authorizing agency, are suggested in Appendix A-7. 

19.11 Uncommitted mitigation measures pertinent to the Ute tribe are found 
in Appendix A-7. The Governor of Utah is on record as supporting the 
intent of SB170, related to the Ute tribe. As noted in the EIS 
Summary (Unresolved Issues, Socioeconomics), mitigation may be 
negotiated between the tribe and project developer, but are 
considered an unresolved issue. Also, federal agencies cannot 
require socioeconomic mitigation; that is the purview of state and 
local government. 

19.12 The information provided was used to revise Sections R-3.A.1 and R- 
4.A.1 concerning fire protection on the reservation. BLM greatly 
appreciates the help provided by Dennis Montgomery in revising these 

19.13 Sections R-3.A.1 and R-4.A.1 have been revised to clarify that 
Roosevelt purchases water from the Ute Tribe and that the State of 
Utah has awarded Roosevelt $4 million to develop its own water 
sources. (Wells are now being drilled). 







19. ZO 


Section R-3.A.1 (Tribal Jurisdiction and Finance) has been revised to 
clarify this point. 

The incorrect cross reference in Section R-3.A.1 has been corrected. 

The magnitude of the impacts to the reservation are addressed in 
various parts of the EIS and in Chapter R2D, Indians, of the 
Socioeconomics Technical Report. These concerns will be considered 
by the decision maker. 

The tribe is doing a study on this issue now. 
data will not be available this year. 

Unfortunately, the 

Total dissolved solids (salinity) and suspended solids (sediment) are 
expected to be increased slightly due to construction. However, as 
discussed in Section R-4.A.4, compliance with the applicants' 
reclamation plans is expected to keep this impact short-term and 
insignificant. Similarly, some soil materials would be loosened due 
to construction in floodplains and potentially would add to the 
sediment supply. Compliance with the reclamation plans is also 
expected to keep the impact short-term and insignificant. 

This section describes the environment in which the proposed actions 
would occur. The statement in question was not meant to imply any or 
all of this water would be required. 

Riparian areas disturbed by project activities are expected to be 
successfully revegetated with implementation of the intensive 
reclamation program outlined in Appendix A-8. These areas are 
usually the more favorable areas for revegetation due to more 
favorable soil conditions and the additional moisture they receive 
due to position on the landscape (refer to revegetation discussion in 
Section R-3.A.4). 

Section 7 Consultation has been initiated with the U.S. Fish and 
Wildlife Service. Their Biological Opinion has been Included in 
Appendix A-9 of the Final EIS. It was not available to print in the 
Draft EIS. 

To achieve successful erosion control and reclamation on lands 
disturbed by project activities in the Uintah Basin (an area subject 
to unfavorable climate and soil conditions) could require an 
intensive reclamation program with implementation of applicable, 
effective measures and a strong compliance program. Refer to 
Appendix A-8. 

19.22 Nongame species are discussed in Section R-3.A.5. 

19.23 Refer to the response to Comment 19.20. 

19.24 A statement that the Uintah and Ouray Reservation should be 
considered regarding rights-of-way has been added to Section R- 
3. A. 7. 



19.25 No information regarding recreation visitor days is provided, because 
no data are available. However, baseline data and impact analysis 
are incorporated where possible. For example, Section R-3.A.8 
identifies 2,703 fishing permits at the Bottle Hollow Reservoir, 90 
campsite units at the Bottle Hollow Resort, and the Ute Indian Tribe 
Wilderness Area of the Hill Creek Extension. 

Regional and site-specific recreation impact analysis on Ute Indian 
lands also are addressed based on available data. For example, 
Section R-4.A.8 discusses access, camping, and wilderness impacts on 
tribal land. Section M-4.A.8 analyzes Magic Circle product pipeline 
impacts on the Bottle Hollow Resort and Section T-4.A.8 discusses 
controlling ORV use and hunting impacts on tribal lands due to the 
Tosco project. 

Additional visitor use data was analyzed and is in the project 
files. The information presented in the EIS was felt to be the data 
needed to understand cumulative environmental consequences of the 
nine projects. 

Refer to the response to Comment 19.1 

Indirect impacts to wildlife in the area of influence (which includes 
the Uintah and Ouray Reservation) are discussed in Section R-4.A.5. 
The discussion indicates that increases in poaching and other illegal 
activities would increase in all portions of the region at the same 
rate, including reservation lands. BLM has no authority to require 
any mitigation on state, private, or Indian lands. 

The statement that more law enforcement people and rangers would have 
to be hired is correct. At the present time, there are no provisions 
for funds or other mitigative measures to assist in solving these 

19.29 Reptile and amphibian species lists for the area are available from 
the Utah Division of Wildlife Resources and were used to prepare this 
section. To our best knowledge, no research data presently are 
available to give density estimates. Since the 36,911 acres of 
herpetological habitat that would be disturbed by the various 
projects make up about 2 percent of the total habitat in Uintah 
County, a straight-line projection would indicate that significant 
impacts to indigenous populations of reptiles and amphibians are not 

19.30 The Uintah and Ouray Indian Reservation is included in the baseline 
conditions discussed in Section R-3.A.1. Since the reservation is 
included in baseline calculations in the Socioeconomic section, other 
sections that use this baseline data do not specifically break out 
the reservation. 

BLM is not aware of any plans to reimburse the reservation or the 
county for their portions of the estimated $4 million a year loss to 
Uintah County caused by anticipated impacts to wildlife. Further, 
BLM has no knowledge of any program to reimburse any entity for these 
types of losses. 

19.31 Section 7 consultation procedures described in the Fish and Wildlife 
Service's Biological Opinion (Appendix A-9) provide for this. 

19.32 The views expressed will be considered in the decision-making 








Uintah and Ouray Agency 

lite Indian Tribe 

P.O. Box 190 

Fort Duchesne. Utah 8*03*5 


October 18, 1982 

Mr. Lloyd Ferguson, District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 84078 

Dear Lloyd: 

Please find attached the response of the Ute Indian Tribe on the Uintah and 
Ouray Reservation concerning the draft Environmental Impact Statement prepared 
for development of the Uintah Basin Synfuel Resources. We wish to compliment 
the BLM for the preparation of the Air Quality section of the DEIS. We cannot 
hold the same compliment for the socioeconomic section as it does not adequately 
address those impacts that will befall the Tribe and the reservation. Without 
the inclusion into the body of the Draft EIS of the additional socioeconomic 
study being prepared by Ford, Bacon and Davis Utah, Inc., we do not have a 
working decision-making document to use in planning a management strategy for 
the Impending development of synthetic fuel resources in the Uintah Basin, 
as is required by the National Environmental Policy Act. 

We, therefore, must go on record as being in opposition to any acceptance of 
the Uintah Basin Synfuels Draft Environmental Impact Statement until such time 
as this statement Is corrected to accurately identify the impacts that may 
and will affect the Ute Indian Tribe on the Uintah and Ouray Reservation. 



The Dratt Uintah Basin Syu fuels Development Environmental Impact Statement 
(EIS) w.ts reviewed. Although some significant Issues of concern are identified 
by the Ute Tribe, the Bureauof Land Management (BUI) has made progress in 
recognizing the impact ot synfuels development on the Uintah and Ouray Indian 
Reservation. The Draft EIS indicates that tribal environmental and socioeconomic 
resources can be impacted by the proposed development. Given that the use 
of regional data and regional analyses could overshadow and ignore local 
impacts, the tribe feels that some of the localized impacts to the reservation 
from the proposed development could be understated in the document. 

Information on air quality, soils, vegetation, and, to a lesser degree, wildlife 
will be very useful to the tribe in making decisions about our future. However, 
information on important water quality, water quantity, and socioeconomic areas 
is not of sufficient quality to make such decisions. The issues on water quant it 
water quality and socioeconomics have been made previously for the Preliminary 
Draft EIS, and are still unresolved. 

The Ute Tribe acknowledges that the BLM has commissioned a special contract 
to correctly address socioeconomic concerns and impacts of synfuel development 
pertaining to the Ute Indian Tribe and the Uintah and Ouray Reservation. 
However, due to the lateness by BLM in providing this study, the Ute Tribe 
is concerned about the ability to Incorporate this new data into the proper 
places within the Uintah Basin Synfuels Development Final Environmental Impact 
Statement. Response to comments on the draft EIS placed In the final EIS does 
not comply with the requirements of NEPA in addressing environmental conditions 
of an area. 

The tribe would like to particularly acknowledge the efforts of the BLM to 
address the tribe's air quality concners. The process used by the BLM in 
resolving air quality issues should have been used for the other issues of 

These comments are offered by the Ute Tribe on the Draft EIS in the continuing 
spirit of cooperation and in a furthering effort to produce a document which 
provides quality, useable information to decision makers. 







General Comments ; 

The air quality components of the Draft EIS for the Uintah Basin Syn fuels Development 
were reviewed. Pursuant to earlier comments made by the trio?, the document 
attempted to address most of the issues raised by the tribe. The dv -e; .-on methodology 
used seems to be adequate, appropriately subscribing to sound scientific principles. The 
tribe commends the BLM for the open and responsive approach taken Li addressing the 
tribe's air quality concerns. The following comments are made iii order to resolve the 
remaining issues in the Draft EIS. 

The regional analysis performed is adequately performed, but may icoerstate maximum 
worst-case local impacts. Regional scale air quality analysis can oniv be used :n the 
general sense in making decisions concerning the cumulative air quality "carry capacity 11 
of proposed development. This is particularly true in areas where the terrain is 
complex. Accordingly, the general regional approach used in the EIS ii not compatible 
with the existing regulatory decision process used by the F.PA aft" state agenc-ns in 
permitting air pollution sources. Recent data would indicate that the r:e;ional modeling 
approach used may not be as conservative as those more local scale nodels used by the 
regulatory agencies for PSD permits. 

The use of a short-term meteorological record taken from the Whits River Oil Shale 
Project site may not reflect the worst-case meteorological conditions that could be 
expected at sites located in different terrain. Again, regulatory Bget-ci ts usuallv reouire 
the collection and use of site-specific meteorological data in the modeling approacn used 
by permit applicants. 

Therefore, the results of this regional analysis, using generalized short-term date, may 
not necessarily coincide with the results of analyses required by permitting agencies who 
ultimately make key air quality decisions. The tribe recommends that this issue be more 
directly discussed in the Final EIS. 

Specific Comments: 


R-l-14 R.l.C The low scenario for development may not reflect realistic 

air quality impacts associated with a lower bound estimate of 
development in the area. An across-the-bonrd decrease of 
emissions may underestimate the actual emissions inherent in 
a total basin-wide production of 248,000 bpsd scenario. 

R-3-1 2 The statement that "Energy Development, primarily oil and 

gas development, has already changed the t-nvironment of the 
Uintah Basin in a significant manner" needs eo be quantified. 
Does this statement apply to air quality? 

a:r duality 




R-3-17 R-3.A.2 

The use of 1978 and 1979 upper wind data needs to be 


correlated with long-term climatological data to determine 
the representativeness of the data. Of particular interest is 
the question of whether this data represents a typical or 
worst-case year (This comment also applies to other short- 
term data records used in the air quality analysis). 

R-4-25 R-4.A.2 

An explanation of the rationale for the elimination of the 


Arches National Park Class I PSD Area as an area of interest 
is needed. Many of the projects in the Uintah Basin are 
closer to Arches than to the Flat Tops Wilderness Area. 

20.11 j 

R-4-27 Table R-4.7 

An explanation on how the air pollution concentrations at the 

various locations were derived would be helpful. 

R-4-125 Table R-4.40 

The units for Table R-4-40 need to be included. 

Specific Comments on Draft Air Quality Report: 


4-60 2 

The use of the COMPLEX Model for calculating S0 2 

concentrations needs to be clarified. 


4-61 2 

An explanation of what GPM modeling results (regional or 
subregional) were used in the tables and figures is needed. 
Also, are the results of the GPM subregional analysis 
different from the regional analysis? 


The calculated worst dayfs) for the regional GPM model are 


in the summer. Intuitively, one would expect worst-case 

meteorological events to occur in winter. A winter worst- 

case RTM analysis addressing Class n impacts would be 

helpful. Of particular interest would be the air quality 

impact to the areas east of the oil shale development in the 

Uintah Basin. 

5-8 P 

The applicant's PSD modeling results for the Moon Lake #2 


and White River oil shale projects should be included for 
comparison purposes. 


5-103 Table 5-2 

The maximum Class n SO« impact in the third row of data 
seems to be less than that identified for the Uintah and Ouray 

Indian Reservation. This needs to be explained. 


20.19 I 







General Comments : 

The Draft EIS does not provide adequate surface water data or criteria upon which an 
assessment of potential environmental impacts can be made, particularly in the area of 
development. Minimal information is presented with respect to groundwater systems 
tnd, thus, no conclusion with regard to potential impacts can be made. The only water 
quality parameter presented is salinity, which cannot be used e.s the ?o)e basis for 
determining or quantifying impacts. 

No information is presented on the water model used. Stream segments are not 
Identified, nor their representative importance with respect to the study area discussed. 
An arbitrary baseline water condition is generated and unsupported. 

Numerous unsupported and subjective statement are made throughout the document. 
Supportive data should be presented. 

The evaluation of water impacts as presented does not consider periods of low-flow 
(worst-case conditions), nor is it clear that the interrelationships of the White and 
Duchesne Rivers with Green River were fully considered. 

Specific Comments : 


xxxi Preface The statement that "under the high-level scenario, water 

would be utilized at a rate of about 36,000 ae-ft/yr from the 
White River and about 32,000 ac-ft/yr from the Green River" 
is misleading. The above values represent the maximum 
quantities of water that could be withdrawn from the 
respective rivers, either as a primary or alternate source, and 
does not represent the actual water demand for the nine 
proposed projects totaling 40,870 ac-ft/yr (35,900 ac-ft/yr 
from the White River and 4,970 ac-ft/yr from the Green 
River, table R-l-B). 

The reported average salinity increase of 5 mg/1 ($2.36 
million per year in damages, assuming constant 1982 dollars, 
pg R-4-54) at Imperial Dam for the years 1983 to 2000 
indicates the proposed developments, plus baseline changes, 
plus interrelated projects '.vill have an impact outside the 
area of development. Is this an acceptable impact? 






Regardless of the orojected salinity change at Imperial Dam, 
the question of potential water quality impact in and 
surrounding the area of development remains. Are the 
salinity levels as projected for the White and Green Rivers 
(table R-4-18) representative of the area of development 
and are such changes acceptable from a water use 
standpoint? It is suggested that the Utah Water Quality 
Standards, Wastewater Disposal Regulations, Utah State 
Division of Health, Part n , be used as a measure of impacts 
and/or constraints to water use due to the proposed 
development. Additionally, water quality criteria developed 
by the U.S. Environmental Protectioin Agencv— specifically 
Water Quality Criteria, 1972, EPA-R3-73-033, March 1973, 
and Quality Criteria for Water, 1976, could be used as a 
measure of the suitability of the water for designated or 
potential uses. 



R-1-I5 Table R-l-8 

R-2-3 Table 12-2-1 


Note C indicates water is withdrawn from the Green River 
for the White River Shale Project. J c this correct? 

Groundwater requirements of 3,800 ac-ft/yr (as indicated in 
table R-l-8) should be included under cumulative impact. 

R-4-7 Water Resources It is stated that a 10% flow decrease for any individual 
stream would be significant based upon experiences of 
critical flow decreases, but there is no indication that the 
Impact of water withdrawal during low-flow (worst-case) 
conditions were evaluated. 

During low-flow water years, such as 1977 when total annual 
flow in the White River at mouth measured 403,700 ac-ft, 
the respective project and cumulative flow reductions would 
be 8.9% and 25.5%. The average White River flow of 
479,600 ac-ft/yr (table R-3-8) would be reduced only 7.5% 
(35,900 ac-ft/yr, table R-l-8) due to proposed project 
development, but would be reduced 21.5% (103,000 ac-ft/yr, 
table R-l-8) due to cumulative development. Would a 21.5% 
reduction in flow be considered significant? 

R-4-7 Water Resources It is stated that "significant impacts also were considered to 
result if salinity would be increased". Table R-4-18, pg R-4- 
52 show sizeable increases in salinity in the White River and 
Green River due to both baseline increases and projected 
development. Are significant impacts thus projected to 





Salinity increases and, thus, significant impacts are also 
projected at Imperial Dam. 

R-4-45 Water Resources The Green River and White River reaches used in the 
Colorado River Simulation Computer Model, or as modified 
for this evaluation, should be shown graphically or at least 
described. Up to the modeling effort it appears that flow 
and salinity data for the Green River at Green River and the 
White River at mouth (near Ouray) are used to represent 
conditions in the project area. For modeling purposes it 
appears that while the White River at mouth is still used, 
the representative site for the Green River has been shifted 
to the confluence with the Colorado River. The Green River 
at the confluence with the Colorado River is not 
representative of water quality or quantity in the proposed 
project area. 





Water Resources 
& Table R-4-16 



The 1983 baseflow conditions for the White River and the 
Green River are significantly higher than the flow data 
presented in Table R-3-8. If the flow data for the Green 
River reflects baseline conditions as measured at the 
confluence with the Colorado River it is not representative 
of the project area. 

The changes in baseline conditions with time for both the 
White River and Green River in table R-4-16 are not 
consistent with the project baseline depletions in table R-4- 

No data is presented to support the 1983 baseline salinity 
values shown in table R-4-18. What is the source of the 
baseline salinity (TDS) values? 

Maximum White River 
R-4-46 Development It is stated that current depletions on the White River are 
37,000 ac-ft/yr. USGS Water Resource Data for Utah (1977) 
states that there are diversions for irrigation of about 
37,800 acres above the station (093069001. Allowing a 
minimum of 3 feet of water per acre per year would imply a 
current depletion of about 113,000 ac-ft/yr from the White 
River. Has there been a significant reduction in the 
quantity of land irrigated with water from the White River? 



anere) C 


"e^eta'.f' a. soils and .-eelamation i-s»ies are generally satisfactorily identified in the 
DKiS, 7*- st of the previous comrner.'* made o« the tribe in the Preliminary Draft E1S 
w?re ac!..;'-?^'td. The following ppftcif'e comments for the remaining unresolved aspects 
of the D'.ilS j»r2 offered. 


Specific C 







The vegetation types should be depicted on a map to show 
location of each and extent. 




The land use for each vegetation type should be discussed. 




The source of information used to group the soils is not 
referenced. The soils should be delineated and classified in 
accordance with a conventional classification system. 




The "detailed soil surveys" mentioned here should have been 
used to describe the soils in the DEIS. 




The cash value of crops and livestock should be presented. 




Reclamation of disturbed land is assumed to be successful 
upon "implementation of erosion control and reclamation 
programs," compliance with— reclamation plan—," and 
"compliance with— requirements and stipulations—." The 
enforcement mechanism for the aforementioned should be 
discussed. It should include inspections, reclamation 
performance bond, and penalties. 




Cash value of the crops should be presented. 




The assumptions presented here regarding successful 
reclamation are based on a compliance program. The 
enforcement procedures in the event of noncompliance 
situations were not addressed. Enforcement m easures should 
include inspections, reclamation, performance bond, and 




Replace the word "would" in the sentence "The following- 
applicant and landowner" with the word "may". 




The statement is made that "The compliance program would 
be conducted by the authorizing agencies and landowners for 
their lands." What is the mechanism by which the authorizing 
agencies and landowners can deal with operators who violate 


the compliance program? A method of deterring i 
providing for assessment of penalties for violators should 




General Comments: 


Wildlife resource evaluations made in the DEIS are adequate for regional impact 
assessment. However, information presented may be too general to fully evaluate 
the potential site specific impacts of the proposed projects. Specific inadequacies 

o The adjacent Uintah and Ouray Reservation wildlife resources should 
be given specific mention since they will be impacted from the 
proposed projects. 

o References to the effect that "Impacts will be insignificant due to 
the ratio of impacted lands to the total region" should not be made. 
Site-specific impacts could be significant on the Uintah and Ouray 

o Corridors within the Uintah and Ouray Reservation need to be fully 
assessed before adequate determination of impacts can be made. 

o Mitigation for Uintah and Ouray Reservation wildlife resources needs 
to be addressed, including financial aid for wildlife management 
and enforcement. 

Specific Comments: 




R-3-36 6 


The small flowing streams and intermittent small tributaries 
may not support any fish but would still be important to other 

This sentence makes no reference to the Uintah and Ouray 
Reservation, which depends heavily on the revenues derived 
from their recreation programs to manage the Ute Tribal Fish 
and Wildlife Department (fishing, camping, and small-game 
hunting). Section R-3, A-l does not discuss the importance of 
the monetary value of the wildlife resources to the Uintah and 
Ouray Reservation. Proposed population increases will probahly 
cause the Ute Tribal Business Committee to close and/or restrict 
camping, fishing, and small-game hunting to non-members of the 
Ute Indian Tribe'. 

The statement "Therefore, project disturbance would not cause 
significant adverse impacts to deer habitat" should not be 
made until site-specific studies (particularly adjacent Co 
proposed project areas) have been made. Any impacts to a 
key wintering area could be significant particularly if deer 
numbers and habitat are already limited within site-specific 
areas. Site-specific studies will be necessary in order to 
determine impact mitigation measures to protect the big game 
resources of the Uintah and Ouray Reservation. 








The numbers 359 and 1,335 under the column "Limited Value 
Year-long" should be placed across from the "D^er" instead 
of the "Elk" row. 






Same as the comment on page R-4-62 , paragraph 6 , except Ear 

Same as above except for elk. 

Site- or corridor-specific impacts could be significant. 

Same as above. 

Same as above. 

"Non-game fish" referenced in this paragraph should be 
accompaned with a non-garoe fish species list. 

The ring-neck pheasant is reported as common near RandleLl , 
which is located along the proposed product pipeline. 

Sage grouse habitat within the Uintah and Ouray Reservation 
need to be fully assessed before impacts of the product 
pipeline can be determined. 

Same as above except for chukars. 

Impacts to the reservation's wildlife resources could be 






General Comments : 

The assessment of regional and project-specific socioeconomic effects has been 
conducted rigorously and in accordance with generally accepted "state-of-practice" 
methods for the counties and communities within the Uintah Basin. While there are some 
methodological and conceptual problems associated with these assessments (e.g., the 
study uses a 10 percent growth criterion of impact in contrast to the State of Utah's 
requirement that 5 percent growth constitutes evidence of probable impact), a rigorouslv 
quantitative investigation was conducted of the levels of growth from synfuel 
development and the effects of this growth on the economies and infrastructures of the 
counties and communities in the Basin. 

Unfortunately, no such comparable investigation was conducted for the largest 
identifiable entity in the Uintah Basin: the Uintah-Ouray Reservation. First, the 
reservation— in contrast to the analysis of air quality issues in the draft EIS— was not 
treated as a separate comprehensive entity for socioeconomic impact assessment 
purposes. Secondly, as demonstrated by the specific comments and observations which 
follow, no quantification of either the levels of growth or the effects of prospective 
growth on the reservation and its government has been provided. Instead, broad 
generalized comments are offered that lack both statistical and data foundations and 
exist in marked contrast to both the analyses done for other jurisdictions and commonly 
accepted "state-of-practice" procedures for socioeconomic investigation. Without 
question, the failure of this document to treat comprehensively the Uintah-Ouray 
Reservation as an entity that may be impacted by regional synfuels development and to 
attempt to quantify the socioeconomic effects in a manner even reasonably consistent 
with the levels of analyses presented for other, smaller entities undermines the intent of 
the NEPA. 

The Ute Tribe has worked throughout the EIS process with the authors of the 
socioeconomic study. They have devoted, freely and willingly, their time and the data in 
their possession to and in making possible the best possible assessment of impacts on 
their reservation. These efforts are extensively documented. Unfortunately, the efforts 
extended by the Ute Tribe are not reflected in the assessment performed of 
socioeconomic impacts on the reservation. 

Given ,the substantial failures of the socioeconomics sections to address reasonably the 
impacts on the reservation, it may require a full year to bring the assessment of 
socioeconomic impacts on the reservation up to acceptable standards comparable to 
those used in assessing other jurisdictions. It is strongly suggested that this process begin 

Specific Comments : 



Three unresolved aspects of the socioeconomic portion of the 
EIS are mentioned. The second is a description of the 




unresolved issues from the standpoint of the Ute Tribe. This 
description is incomplete and should include the following: 

o The need for a complete consideration of the impacts 
on the entire reservation in which the reservation is 
treated as a separate and sovereign entity; 

o An enumeration of services and facilities offered and 
used by the tribe; 

o A description of the population growth— both Indian 
and non-Indian — on the reservation; 

o Distribution of this growth within the reservation 
including incorporated and unincorporated 

communities (Roosevelt, Ft. Duchesne) and other 
geographic areas; 

o A complete description of how this is done; 

o Inclusion in the analysis of all indirect basic, and 
induced economic activity and employment resulting 
from regional and site-specific activities; 

o An accounting of the effects of direct synfuels, 

indirect basic, and induced economic activity, 

employment, and population on all Indian-used and 
Indian-provided services; and 

o An assessment of the effects of direct, indirect, and 
induced growth on special conditions related to the 
management and governance of the reservation 

- unauthorized 

squatting within reservation 

- special traffic problems on the 1-40 corridor 
through the reservation and related public safety 
and security issues. 

- housing needs. 

- general government needs. 

- police and fire impacts. 

- school requirements. 
water and sewer needs. 

- solid waste disposal issues. 







It is stated that specific narrative is included in this EfS to 
"clearly present information pertaining to the reserva- 
tion ..." However, none of the prospective information 
described in the preceding comment is presented for the 
reservation as a separate entity. 

The figures comparing low and high scenario impacts on 
population, employment, and service needs fail to indicate: 

o Which years are compared and whether these arp 
annual or cumulative data; and 

o Whether these figures related to the direct effects of 
synfuels and do not include indirect and induced 
effects. If these "multiplier" impacts are not included 
in these totals, the figures are meaningless. It is a 
long and well-established principal in socioeconomic 
impact assessment that the growth impacts associated 
with any given project or projects include: the direct 
population and employment associated with the 
facility (direct); the incremental growth in other 
regional industries and firms as a result of the 
demaands for goods and services from the impacting- 
facility (indirect); and, the increase employment and 
population resulting from the expansion of retail, 
commercial, service sectors as a result of the 
increased personal incomes arising from employment 
at the facility and the incremental employment at the 
indirectly expanded firms and industries. 

For a region as large as the Uintah Basin it is not 
unrealistic to expect that direct construction 
employment of 10,000 people may lead to a secondary 
(indrect plus induced) growth impact of another 
10,000-12,000 jobs. Thus, the total regional 

employment impact would be appropriately designated 
to be 20,000-22,000 persons. 

The areas of influence for socioeconomics do not include the 
reservation as a separate entity. Instead, only smaller and 
non-sovereign entities such as counties and communities are 
considered. Failure to include the Uintah and Ouray 
Reservation in the "Regional Affected Environment" of the 
DEIS severely limits it as an environmental impact planning 
and decision document. Data difficulties, as pointed out on 
page R-3-3, paragraph 2, in no way excuse the omission of 
consideration of the effects of regional synfuels development 
on the reservation. Instead, they need to be resolved. 

The tribe disagrees with the use of the 10% criteria value as 
indicating acceptable impacts. It would seem that the rate of 
growth that can be accommodated in an area is a function of 
the area itself. More importantly, the state of Utah in the 
Impact Mitigation Plan specifies the use of 5% as the 


R-3-3 to 





R-4-14 to 


indicator of potential impact. The use of 10% would 
understate the number of potentially impacted areas in the 
stcte when the state's own criteria is used. Shouldn't the 
designation of impact areas conform to state standards? If 
the answer is yes, the entire analysis of socioeconomic 
impacts will have to begin from a baseline specification of all 
areas meeting this criteria. 

Throughout the section describing baseline conditions, 
specific results are reported only for Utah and Colorado 
counties and communities. Comments on conditions on the 
Uintah and Ouray Reservation are superficial end, more 
importantly, cannot be related to the data reported for these 
other entities— many of which lie within the borders of the 
reservation. Thus, a strong impression of double-counting is 

In this section dealing with the impacts of the high-level 
scenario, the UPED model was used to project population and 
employment and its spatial allocation to counties and 
communities. No attempt has been made to identify the 
reservation as a separate entity within the model with the 
result that none of the quantitative estimates produced by 
the model permit impact estimates for the reservation as a 
whole. See, for example, Tables R-4-4 and R-4-5 in which 
population and employment projections produced by the 
model are reported for all separately analyzed entities and no 
estimates of reservation impacts are provided. 

The evaluation of impacts on specific services and facilities 
within the Uintah Basin is again done on a county and 
community basis. There is no quantitative consideration of 
reservation-specific impacts. Instead, broad generalizations 
about impacts on the reservation are made without support of 
analysis. The level of this analysis is totally inconsistent with 
that presented for the counties a^d communities. 

As an example, consider the section on new household growth 
(R-4-15 to R-4-17). Table R-4-6 describes in detail the 
housing demands resulting from the projects in absolute 
numbers and percentage terms for the counties and 
communities. For example, the town of Rangely, Colorado 
currently has 1,116 households and that as a result of high- 
level scenario growth the number of households will increase 
by exactly 224 or 20.1% in the year 1985. 

No such figures are presented for the reservation. Instead, 
the observation is made of the housing and household impacts 
on the reservation; "There is currently a housing shortage on 
the reservation. " Any new growth on the reservation would 
seriously exacerbate this shortage" (page R-4-17, paragraph 
2). This statement is obvious, but does not provide any 





E-4-1 & 2 

decision maker with quantifiable information on the 
magnitude of the potential problem. 

The section (R-4.B.1) covering the socioeconomic impacts of 
regional synfuels development associated w'th the low-level 
scenario does not mention the reservation. Instead, in the 
introduction to this section is found this singular reference to 
impacts from low-level development on the Uintah-Ouray 
Reservation: "Effects on the Ute Indian Tribe would be 
similar to those discussed for the high-level situation with no 
appreciable differences in magnitude of impact." The reader 
is reminded that effects discussed for the high-level situation 
with respect to new households and consequent housing 
demands were that a serious shortage exists which ma" get 
worse. No where can it be found how many new households 
might be expected and how many housing units may be 

With respect to the treatment of the socioeconomic impacts 
from site-specific projects, no data is presented to indicate 
whether impacts will occur on the reservation. Instead, the 
reader is told to refer back to section R-4.A.1 for a 
description of the impacts related to the reservation from 
regional development but to remember that " — they would be 
much less in magnitude for a (specific) project alone." 





The reference to Uintah and Ouray Tribal Requirements 
should not be construed as the only issues of concern for the 
tribe. The tribe may wish to develop at a later date 
environmental requirements for such development. 
Currently, the tribe is considering the development of a 
Tribal Review Process for on-reservation development. 




ute Indian Tribe 







Refer to the response to Comment 19.1. In addition, a Department of 
the Interior EIS is not a decision-making document. It provides 
information to the decision maker. All the factors considered in the 
dec is ion -making process are documented in a decision document, which 
is separate from the EIS. 

BLM acknowledges the Ute Tribe's concerns. Additional information on 
impacts to the tribe has been added to the Final EIS. 

The views expressed will be considered In the decision-making 
process. The specific concerns raised are addressed in subsequent 
comments. The special Indian study has been completed and the 
results have been Incorporated In the EIS. 

It is true that the approach used In this study is considerably 
different from that used for regulatory permitting activities by the 
EPA and some state agencies as indicated in the Draft EIS and further 
expanded in the Final EIS (Chapter R-4, Significance Criteria and 
Section R-4. A. 2). The analysis was performed for the purpose of NEPA 
and not for the purpose of obtaining a PSD permit and would not 
satisfy that process. The objective of the analysis was to provide 
the BLM decision maker with information to understand trade-offs 
involved in the right-of-way decision which must be made. The 
analysis was developed utilizing what BLM (and Systems Applications 
Inc.) considered to be the best and most appropriate existing data 
base and state-of-the-art modeling techniques available at the time 
the study was begun. The site-specific analysis 1n the EIS has been 
compared with available PSD analysis as additional source information 
and an effort was made to make the overall analysis as compatible 
with the regulatory decision process as possible through coordination 
with the EPA and appropriate state regulatory agencies. Existing and 
subsequent PSD permit studies using more intensive site-specific 
analysis on a case-by-case basis may result in different 
concentration estimates as more refined data become available. 

The commenter's statements are correct, as discussed in response to 
Comment 20.4 above. Chapter R-4, Significance Criteria, and Section 
R-4. A. 2 have been expanded to more directly discuss this concern. 

The low-level scenario assumed a reduction in production from each of 
the applicants' proposed projects. This resulted in a reduction of 
emissions from each project. Because emission rates per bpsd of 
production vary by project, total emission rates for 248,000 bpsd 
also vary depending on the combinations of projects assumed. If some 
projects produced at full potential while other projects were not 
built, emission rates and spatial distribution of impacts would be 
different than assuming all projects are operating, but at a reduced 
level. However, because there is no accurate way for BLM to guess 
which projects would actually be built, reduced production rate from 
each project was determined to be the most reasonable way to 
construct a low-level scenario. While emissions may be 
underestimated, it is equally likely that emissions are 



20.7 The baseline characteristics of the Uintah Basin, including the 
effects of oil and gas development, are described in detail in this 
chapter (Chapter R-3). The negative effect that oil and gas 
development has had on air quality is part of the measured baseline 
conditions to which the proposed projects and the interrelated 
projects are added in order to determine cumulative effects. 

20.8 Examination of wind and persistence roses for a number of years 
indicated that 1978 and 1979 were not atypical years. Whether or not 
they are worst-case years cannot be determined without modeling all 
of years. However, the results of other years are not expected to be 
significantly different. The narrative in Section R-3. A. 2 has been 
expanded to include this qualification. 

20.9 Refer to the response to Comment 30.44. 

20.10 The air pollutant concentrations at the locations shown in Table R-4- 
7 are derived from the regional scale GPM model runs. The maximum 3- 
hour average S0;> concentrations estimated at the grid point closest 
to each town or within each Class I or special concern area was 
determined from the one year of modeling results. The high number in 
each range of values is the actual modeled results. The low number 
is a factor of 10 less to account for expected model conservatism. 
This method of using a range of concentrations is discussed in detail 
in Section 5.1 of the Air Quality Technical Report. 

20.11 The units of measurement have been added to Table R-4-40. 

20.12 The use of COMPLEX I is described in Section 4 and Appendix C of the 
Air Quality Technical Report. 

20.13 The values given in the tables in Chapter 5 of the Air Quality 
Technical Report were obtained from the regional GPM analysis. The 
values given in Chapter 6 (site-specific analysis) are from the 
subregional results. The square (110 x 110 km) figures in Chapter 5 
are subregional results, while the rectangular (180 x 268 km region) 
figures represent the regional scale results. 

Comparisons of impacts predicted in the subregional GPM with the 
regional GPM applications revealed differences of only about 20 
percent near the boundaries of the subregional grid. Closer to the 
emissions sources, differences were greater due to differences in the 
treatment of stability and terrain/plume interactions. 

20.14 Three additional RTM model analyses have been made since the 
publication of the Draft EIS and the Draft Air Quality Technical 
Report to further define the relationship between the GPM analysis 

and the RTM analysis. Three scenarios were selectively chosen with 
the assistance of the EIS Air Quality Technical Advisory Coirun i ttee. 
The three scenarios chosen for the RTM runs were: 

- Maximum sulfur dioxide concentrations determined by GPM in the Flat 
Tops Wilderness Area (Class I) 

- Maximum sulfur dioxide concentrations determined by GPM in the 
Dinosaur National Monument (an area of special concern) 

- Impacts in the Uintah Basin and an area of special concern, the 
Uintah and Ouray Indian Reservation during a wintertime stagnation 

The results of these three additional analyses have been added to the 
existing RTM analysis and are discussed in the Final Air Quality 
Technical Report and the Final EIS (Section R-4.A.2). 

20.15 These comparisons have been added to Section 5.8 of the Air Quality 
Technical Report. 

20.16 Technical Report Table 5-2 has been revised and the changes reflected 
in EIS Section R-4.A.2. 

20.17 The water model measures two parameters - flow and salinity. These 
parameters are the basis for determining the impacts. Flows would 
begin to change where the water is withdrawn (some 30 different 
points). Similarly, salinity would slowly change progressively 
downstream. The changes in flow and salinity represent a continuum 
of change beginning in the mountain uplands and terminating at the 
mouth. Not only is it impractical to think of impacts in certain 
small areas, it is also impossible, because adequate gauges do not 

Ground water discussions are purposely brief, because ground water 
use is so small. The analysis and presentation in the EIS (Section R- 
4. A. 3) corresponds to the magnitude of the determined impact. Table 
R-l-8 shows potential ground water use to be 3,800 ac-ft/yr. When 
compared to the potential of withdrawing 103,000 ac-ft/yr from the 
White River (same table), the relative importance of the two water 
systems is put in perspective. 

Salinity is the only quality parameter that is discussed in detail, 
because it is' the only one that is expected to change. To estimate 
changes in other quality parameters would be highly speculative. 

20.18 The water model that was used in this study is the Colorado River 
Simulation System as maintained by the Bureau of Reclamation. EIS 
Section R-4.A.3 cites a source for summary information about this 
mode 1 . ' 




Measuring quantitative changes can only be made at existing gauging 
stations which, generally, are at the confluence of major streams and 
at the inflow and outflow of reservoirs. Therefore, the effects of 
the applicants' water withdrawals are evident at the first downstream 
gauging station. These gauging points are given as column headings 
on Table R-4-16 and discussed throughout the text. 

The baseline condition is not arbitrary. It is maintained by the 
Bureau of Reclamation and serves as the standard for water 
development plans in the Colorado River Basin. The Bureau of 
Reclamation has a staff of engineers and scientists that continually 
update the model based upon development in the basin and gauge data. 

20.19 The water resouces impact analysis is intended to be objective and is 
based on the best available data. 

20.20 Three model runs were made based on a wet year, a normal year, and a 
dry year. The data and results for the normal year were presented in 
the EIS. In this EIS, worst-case was determined to be all projects 
withdrawing water from the White River (Maximum White River 
Development) or all projects withdrawing water from the Green River 
(Maximum Green River Development), not withdrawal from a combination 
of sources during a drought year. This is a valid worst-case 
situation, because water withdrawal would be some combination of the 
two sources. (See also the response to Comment 20.18.) 

20.21 The statement in the Preface has been clarified. 

20.22 Determining the "acceptability" of an impact is not the purpose of an 
EIS; rather it is to analyze and discuss impacts that would occur. 
Because the proposed developments utilize public lands, these impacts 
are discussed to inform the public and the decision maker. It will 
be the BLM decision maker's responsibility to consider these impacts 
when deciding to grant or deny rights-of-way on BLM-administered 

As with any numerical model, parameters are measured at points. In 
the case of this model, measuring points for salinity are the 
confluence points of major drainages. These points show definite 
increases in salinity, which represent significant impacts, 
particularly in a river system that already shows salinity 
increases. Again, the acceptability of the salinity increases is not 
the point; rather, the point is impacts would occur and would require 
some type of desalting to restore water quality to prior conditions. 

The Utah standards or EPA standards were not used as a significance 
criteria, because it was determined that any increase in salinity 
levels would represent a significant impact. 

20.23 This statement is correct. Both the White and Green rivers are 
potential water sources for the White River Shale Project. 

20.24 Table R-2-1 has been revised. 

20.25 The water flow figures that were used in the modeling represent 
impacts assuming average year of projected flows. These projected 
flows are somewhere between average and worst-case due to the 
following reasons: 

1) Worst-case is represented by the two development scenarios - White 
River Maximum Development and Green River Maximum Development 
(refer to the response to Comment 20.20). 

2) Due to rounding off water use figures to the nearest thousand, 
approximately 3,000 ac-ft/yr more went into the model than is 
actually projected to be used (for example, Magic Circle's 
proposed use of 540 ac-ft/yr was rounded to 1,000 ac-ft/yr). 

3) Water estimates shown to be used for municipal and industrial uses 
and agriculture are generous. 

4) The water model considers every project operating at maximum 
capacity - the probability of this, given current economic 
conditions, is remote. 

Due to these reasons, figures for impacts assuming low flow (drought) 
were not given in the EIS; however, they are available upon request 
from the BLM. 

Based on the stated impact criteria (Chapter R-4, Impact Significance 
Criteria section), a 21.5 percent reduction in flow would be 

20.26 Significant impacts are projected to occur. 

20.27 The Green and White rivers are shown on a number of EIS maps, 
including Map R-A-l (Appendix R-A). In order to show a change in 
flow or salinity, a stream gauge is needed. In this study area, the 
gauges (and the resultant available data) are at the confluence of 
the White and Green rivers, at the confluence of the Green and 
Colorado rivers, at the inflow to Lake Powell, and at Imperial Dam. 

These are major landmarks, and due to the wide geographical 
distribution, it was not thought necessary to show these locations on 
a map. 

The change in flow and salinity of the Green River at the confluence 
with the Colorado River is representative of the changes in the 
project area. At the confluence, the incremental change in flow and 
the differences in salinity are shown. These can be compared with 
existing data to determine changes due to the applicants' projects, 
other related projects, or both as is done in Section R-4. A. 3. 




20.28 The 1983 baseline flow conditions were developed by a hydrologies! 
model that the Bureau of Reclamation uses. The baseline model run 
entered existing stream gauge data, and based upon current trends, 
created a baseline from the present to the year 2000 (Section R- 
4. A. 3). The changes in flow and salinity shown in this report are 
representative of the changes caused by additional water use from the 
applicants' and interrelated projects. Where they are reported is 
not significant; rather, the amount of change which can be directly 
attributed to increased water development in the upper portions of 
the basin is significant. 

The data on Tables R-4-16 and R-4-17 are consistent. Differences in 
depletions and flow do not necessarily mirror each other. Depletions 
change in a predictable manner, because people have control over 
them. This is not the case for flows, because flows are caused by 

The 1983 baseline salinity values were determined by the flows that 
were created by the above-mentioned hydrological model. 

20.29 The 37,000 ac-ft/yr depletions discussed in the EIS would occur above 
the gauge-recorded data that are shown in the USGS records. The 
37,000 ac-ft/yr represent current water depletions as maintained for 
the Colorado River Simulation System. There is no evidence to 
indicate that the number of acres irrigated has changed. 

20.30 The extent of vegetation types and the amounts disturbed are 
identified in Table R-4-19 for the high-level scenario and Table R-4- 
41 for the low-level scenario. A map'would not appreciably enhance 
the reader's understanding of the impacts. 

20.31 Land use for vegetation types is discussed in Section R-3.A.5, 
Wildlife (habitat type), and Section R-3.A.6, Agriculture (livestock 

20.32 All the soil surveys used were conducted and prepared in accordance 
with the National Cooperative Soil Survey Program, USDA, Soil 
Conservation Service (EIS Section R-3.A.4). 

20.33 The detailed soil surveys were used to evaluate potential impacts and 
would be used by the applicants to determine applicable reclamation 
measures as stated in the EIS (Appendix A-8). 

Identifying the complete soils inventory would be very voluminous and 
would detract from the more significant information included in this 
section. In keeping with CEQ guidelines to reduce bulk, only 
information which contributes to the reader's understanding of the 
impacts was included. 

20.34 The impact to agriculture (cropland and grazing) is the predicted 
annual cropland and cropland production loss as identified in Tables 
R-4-23 and R-4-42 and the loss of AUMs for livestock grazing (Table R- 
4-22). Information from these tables was used to compute the total 
cash value loss to agriculture as identified in Section R-4.A.1 
(Other Socioeconomic Impacts, Agriculture). Cash loss for specific 

crops was used to determine the total cash value loss. However, 
because CEQ guidelines state that EISs should not be encyclopedic or 
include unnecessary detail, the economic loss data was not presented 
by crop 1n the EIS. 

20.35 Refer to Appendix A-8, Maintenance and Monitoring section. 
Inspection, monitoring, and certification of successful revegetation 
and erosion control would be determined by the landowner or 
authorized agency official. It is not within the scope of the EIS to 
discuss the enforcement mechanism, including inspections, reclamation 
performance bonding, or assessment of penalties for violation of 
compliance, because enforcement is predicated on decisions not yet 
made, which are to be based upon the EIS and related documents and 
data. In the event of noncompliance or any other violations, the 
authorizing agency official or landowner would take appropriate 

20.36 Refer to response to Comment 20.34. 

20.37 Refer to response to Comment 20.35. 

20.38 "Would" more correctly expresses the meaning intended. Should a 
right-of-way be granted, BLM and the Forest Service are committed to 
stipulating these guidelines. The applicants have committed to 
implementing these guidelines on other lands subject to any 
modification deemed necessary by the landowner. 

20.39 Refer to response to Comnent 20.35. 

20.40 Where impacts to the wildlife resources of the Uintah and Ouray 
Reservation are predicted to occur due to development of a site- 
specific project, they are presented in the EIS (for example, Section 
M-4.A.4). Additional information regarding habitat disturbance 
within corridors (Magic Circle and Tosco) that would cross the Uintah 
and^Ouray Reservation has been added to Sections M-4.A.5, T-3.A.5, 
and T-4.A.5. 

Habitat disturbances on a regional basis are anticipated to be 
insignificant due to the small percentage of each type of habitat 
that is disturbed. Site-specific habitat disturbances that occur on 
the Uintah and Ouray Reservation were analyzed in light of total 
amounts of habitat available. 

BLM has no authority to reguire mitigation measures on tribal lands. 
Any measures reguired by the Uintah and Ouray Indian Tribe would have 
to be stipulated by the tribe as part of a permit to cross the 

20.41 The commenter's statement is true. Discussions of additional uses of 
this habitat are included in the Section R-3.A.5 riparian habitats 
discussion and the Section R-3.A.5 aquatic wildlife discussion. 



20.42 The Ute Tribe was requested to provide all available data related to 
wildlife resources on the reservation. The tribe was able to furnish 
numbers of fishing permits and numbers of game bird hunting permits. 
No information was furnished to give data for total numbers of 
hunters, days hunted, expenditures per day, or similar data. 

20.43 On a regional basis, the statement is proper. From the standpoint of 
"habitat," total regional disturbances are a very small percentage of 
the available habitat to mule deer. Analysis of site-specific 
impacts has been done. The significant site-specific impacts are 
discussed in Section 4. A. 5 for each project. 

20.44 Table R-4-20 has been revised. 

20.45 Refer to the response to Comment 20.43. 

20.46 This chapter discusses nine-applicant cumulative impacts. Site- 
specific impacts are discussed under each specific project. 
Additionally, neither site-specific impact analysis nor analysis of 
impacts of the nine projects considered together show any adverse 
impacts from applicant projects to black bear, cougar, nongame 
mammals, or bird species. 

20.47 According to CEQ guidelines, an EIS is not to be encyclopedic. 
Therefore, long lists of species have not been included. Lists of 
species occurring in the area can be obtained from the Utah Division 
of Wildlife Resources. 

20.48 Section M-3.A.5 has been revised. 

20.49 According to sage grouse and chukar partridge distribution maps for 
Uintah County furnished by the Utah Division of Wildlife Resources, 
no sage grouse or chukar habitat is found along the product pipeline 

20.50 Impacts to wildlife within the area of influence, which includes 
portions of the reservation, are addressed in Section M-4.A.4. 
Section H-4.A.8 also addresses potential recreational wildlife 
related impacts upon the Uintah and Ouray Indian Reservation. 

20.51 Additional Uintah and Ouray Reservation data have been integrated in 
the final EIS based on the results of the Ford, Bacon, and Davis 
study of Native American issues. Please see the Final Socioeconomics 
Technical Report, Section R20, and the Socioeconomics sections of the 
Final EIS. 

20.52 BLM is well aware and appreciative of the time and effort that the 
tribe has given in helping develop the socioeconomics analysis. The 
Final EIS reflects the cooperative efforts that have been completed 
in the period between the Draft EIS and the Final EIS. 








A supplemental study was undertaken and the results of that study are 
summarized in the Final EIS. See also the response to Comment 19.1. 

Section R-3.A.1 enumerates the magnitude of migration into the Uintah 
Basin. Additional information that disaggregates the migration and 
impacts to the reservation has been added to Section R-4.A.1 of the 
EIS and Section R2D of the Socioeconomics Technical Report. The data 
addresses all the unresolved issues identified by the commenter. See 
also the response to Comment 19.1. 

The Final EIS treats that portion of the Uintah and Ouray Reservation 
most likely to be affected by synfuel development as a separate 
entity. Refer to Section R-4.A.1 and the various site-specific 
Socioeconomics sections. 

The years compared for the high-level scenario are 1985 for 
construction and 1995 for operation (Section R-l.B). For the low 
level scenario the years compared are 1985 for construction and 1993 
for operation (Section R-l.C). The results presented are 
cumulative. Comparison of the direct employment figures in Tables R- 
1-5 (High-level) and R-l-12 (Low-level) with corresponding employment 
figures in Table R-2-1 show that multiplier effects are included. A 
summary description of the Utah Process Economic and Demographic 
(UPED) Model, including the way the multiplier effects are 
incorporated into the UPED Model, is given in Appendix A-4 of the 
EIS. A more detailed description is presented in Appendix M of the 
Socioeconomics Technical Report. 

The Final EIS and Socioeconomics Technical Report attempt to 

disaggregate data to make the influence on reservation communities 

easier to assess. Please see the appropriate Socioeconomics 

The 10 percent criterion is based on a standard generally accepted 
within the professional socioeconomics community. For further 
detail, refer to response to Comment 19.5. 

The analysis is consistent in utilizing the 10 percent significance 
criterion for impact assessment for both Indian and non-Indian 
entitities. Detailed data are available in the Socioeconomics 
Technical Report for various socioeconomics factors and entities, in 
the event that a different significance level criteria (i.e., 5 
percent) is utilized in the mitigation planning process 

Baseline data that are specific to the reservation are found in all 
subsections of Section R-3.A.1. The "relating" of the data presented 
for communities, counties, and the reservation should be approached 
cautiously; data are presented separately for these three units, 
because they are separate and distinct. The data presented for these 
three types of units are total for the unit; community data is a part 
of data for its encompassing county; reservation data is a part of 
data for any county, or community which encompasses or lies within 
the reservation. This is not double-counting, but rather 
disaggregation of data into separate but interrelated units. For 
example, any one person may be counted as a part of each of the 

populations of the reservation; of Unitah County and of the town of 
Ouray. Only if one tried to add the community data to the county 
data, to the reservation data would data be double counted and an 
incorrect total result. 

20.60 Tables R-4-4 and R-4-5 display, for comparison, different units of 
the set (Duchesne County, Uintah County, and other counties) and the 
reservation, having no subsets, is addressed only in the text. 
Impacts that are specific to the reservation are found throughout 
Section R 4.A.1, Socioeconomics. 

20.61 Information on baseline housing demand within the reservation has 
been added to Section R-3.A.1. 

20.62 Housing data have been added. Please see Sections R-3.A.1 and R- 
4.A.1, Housing, and the appropriate site-specific section for 
population and household demand increases. For full details, refer 
to the Socioeconomics Technical Report, Section R2D. 

20.63 Information on the projected population impacts to the main 
reservation areas has been added to Section 4.A.1 for each site 
specific project. 

20.64 The Uintah and Ouray Tribal Requirements section of Appendix A-ll has 
been revised to include this potential requirement. 










State of Utah 



841 14 

October 19, 


Scott M . Matiikhon 

Mr. Lloyd Ferguson 
District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 84076 

Dear Lloyd: 

1 am pleased to transmit the comments of the state of 
Utah on the Uintah Basin Synfuels Development Draft Environ- 
mental Impact Statement . As you know, this document is the 
culmination of a unique cooperative effort between the Bureau 
of Land Management and the state of Utah. The EIS Steering 
Committee, co-chaired by the state and BLM, and including 
representatives from affected federal agencies, local 
government and the Ute Indian Tribe, provides an effective 
forum for discussing issues related to the EIS process and for 
shaping the scope and content of the final document. 

Our involvement throughout the impact statement 
process does not relieve us from the responsibility to 
carefully review the document, providing comments which we hope 
will be reflected in the final environmental impact statement. 
This is particularly important in the area of socioeconomic 
impact evaluation. The state of Utah, under contract to BLM, 
provided a socioeconomic technical report, forming the basis 
for analysis of site-specific and cumulative socioeconomic 
impacts. Our comments in this area are primarily directed 
toward statements in the DEIS which are not consistent with or 
substantiated by our technical report. 

The draft environmental impact statement demonstrates 
that significant synthetic fuel development can proceed in the 
Uintah Basin without violation of existing environmental 
standards. We support that development and will work with 
local government, project developers and the federal government 
to encourage the development of synthetic fuel projects in a 
manner that will minimize environmental impacts or disruptions. 

Of course, at this point, it is not possible to 
accurately predict which projects may ultimately proceed to 
commercial development. In this context, the combination of 


Lloyd Ferguson 
October 19, 1982 
Page Two 

site-specific and cumulative regional analysis is particularly 
useful. However, as each proposal moves forward, it must meet 
applicable state permitting requirements. Thus, the DEIS 
should state that the document does not necessarily satisfy the 
information and permitting requirements of the state of Utah. 

Again, we appreciate the opportunity to participate in 
this effort and hope that our comments will be helpful in 
preparing the final environmental impact statement. 


Sincerely , 


SMM: jb 








General Comments 

° In several places in the technical report and the EIS it is stated that 
the Gaussian Puff Model (GPM) is conservative and an appropriate model 
to define the upper bound estimates of worst case impacts. Some rationale 
on why GPM should be considered conservative is provided; however, 
theory and assumptions do not validate that the model is conservative 
and there is no data that would suggest otherwise. 

° The Regional Transport model (RTM) was used only once due to cost 
considerations. We are not convinced that the meteorological conditions 
on the day the RTM was used was the worst case day. Other RTM 
calculations should be made to include at least the worst case winter 
time condition. 

° A disclaimer should be put into the introduction of the technical report 
indicating that the report and EIS are for general planning information 
and do not satisfy state, local, and federal rules for 
regulatory/permitting purposes. 

Draft Air Quality Technical Report 

° Page 1-2; It is stated that Flat Tops Wilderness Area is the only 
federal PSD Class I area in the study region. Arches National Park is 
as close to the Uintah Basin as is Flat Tops. Any potential impacts on 
Arches should be noted. 

° Page 2-15, Paragraph 2.3; The statement is made that "the measured 
long-term average concentrations of the criteria pollutants in the 
Uintah Basin are well within ambient air quality standards except in 
populated areas where windblown dust and emissions from dust and general 
roads cause routine exceedance of the standards". 

This is a very speculative statement. Perhaps the windblown dust 
contributes to other man-caused emissions that result in high 
concentrations, but dust and roads are not the only sources. Routine 
exceedances are not validated by state monitors on the Utah portion of 
the study area or on site monitoring. 

° Page 3-1, Paragraph 3.1; The federal hydrocarbon standard has been 

° Page 4-63, Paragraph 1; The GPM was run using stability D, which was 
assumed to be conservative. We do not agree that stability D is worst 
case and would like to see runs made of winter and more stable conditions 
for comparison. 








Page 4-66; Table 4.21 indicated RTM was used on 6 days. Clarification 
should be made to indicate the single day for which RTM was utilized. 

° Page 5-6; The concept of using a range of pollutant values has merit; 
however, the conclusion that the upper bound is defined by GPM, due to 
its conservatism, and the arbitrary assignment of reduction factors to 
the GPM predictions and calling those numbers the lower bounds is very 
troublesome. It is difficult to know how much trust and good faith one 
must have in order to accept the assumptions made in the use of GPM. 

Section 6, Site Specific Analysis 

° A further explanation should be made as to how the baseline concentrations 
were calculated (modeled values not measured). Tables 6-5, 6-8, and 
6-13 indicate the 24 hour baseline for Paraho, Magic Circle, and TOSCO 
exceed the NAAQS even before the projects are constructed. This does 
not agree with monitored data. 

D If SAI feels comfortable with the high background levels they have 
calculated, a stronger point should be made that the NAAQS are exceeded. 
It would also appear that the high values are not of major concern in 
the EIS since Page V of the Executive Summary states that all the site 
specific projects will be less than all applicable air quality standards 
and PSD increments. The Executive Summary and Section 6 are, therefore 
not consistent with each other. 

° It would be a great aid in reviewing Section 6 if an overlay were provided 
showing the company boundaries. 

Draft Environmental Impact Statement 

° Page R-4-33; It is not clear what sources comprised the secondary emission 
total. For instance, were company generated mobile sources considered 
as a direct or secondary source? Were emissions by company or contract 
vehicles on haul roads, etc., and all other sources which are necessary 
to plant operations considered as secondary emissions? Emissions that 
are caused by the source as a result of their routine operations are all 
direct sources whether they come from mobile or stationary sources 
(i.e. , haul trucks, front end loaders, etc. ). If SAI' s analysis 
considered these emissions to come from secondary sources, the conclusions, 
made throughout the document, that direct emissions are small and 
insignificant when compared to secondary sources is totally in error. 

° Additional study and clarification should be made concerning comments 
made in reference to the EPA Federal Register notice of June 25, 1982. 
This notice does not allow fugitive dust created by mobile sources to be 
excluded as' secondary emissions. The notice specifies that only those 
emissions that come directly from a mobile source such as tail pipe 
emissions may be excluded as secondary sources. Under current 
regulations it is not possible to exclude secondary emissions from 
increment consumption as stated in the EIS. 









Page R-4-37; The statement that Tables R-4-10 and R-4-11 show that the 
ambient air quality standards are exceeded in many locations is incorrect. 
The baseline concentrations in the tables were calculated and only 
provide a projection of concentrations, not a validation of exceedances. 

° Perhaps some comment should be made of the EPA rural fugitive dust 
policy that would allow elimination of high wind days in determining 
background concentrations. Otherwise, if the SAI predictions on NAAQS 
exceedances are true, the Synfuels areas would be non-attainment and the 
PSD rules would no longer apply. 

Page E-5-2, Paragraph E-5.A.2; The statement that cumulative PSD 
increment consumption shows no violation would occur is only true if 
secondary sources are assumed not to consume increments. Also, 
verification must be made by SAI that all project generated emissions 
including those from mobile sources were not included in their analysis 
as secondary sources (see earlier comment). The same comments apply to 
the other site specific projects. 

° Page M-4-4, Table M-4-1; This table shows Magic Circle increment 

3 3 

consumptions for S0 ? 24 hour as 32 ug/m , annual 1 ug/m , and 24 hour 

TSP less than 32 ug/m 3 , and annual TSP less than 4 ug/m . The table 

shows the increment consumption including baseline as 33, 1, less than 

32, and less than 4, respectively. Does that mean that the baseline 

concentrations are the difference in these numbers? (i.e., 24 hour SO^ 

33 - 32 = ug?) These numbers are not even close to the baseline numbers 

given for Magic Circle in Table 6.5 of the technical report or Table 

M-4-2 in the EIS. The same questions applies to Tables M-4-5, 5-4-1, 

and T-4-1. 

Water Quality 

° The EIS states that the projects' consumptive water use may increase the 
Colorado River Basin salinity by 5 mg/1 at Imperial Dam. Therefore, the 
companies should investigate the use of intercepted groundwater from 
their mines and neighboring operations. Intercepted groundwater from 
American Gilsonite should be considered for Paraho and Syntana on a 
permanent basis in addition to the construction and start up phases. 

° In addition to the stated Water Pollution Control Committee construction 
permits, certification of Federal NPDES and DOE 404 (dredge and fill) 
permits must be obtained from the Committee. These requirements should 
be added to the EIS Table SS-3. In the certification of these federal 
permits, additional State recommendations on pipeline spill prevention 
and stream crossings may be specified. 

° The analysis of the Vernal sewer system seems to be incorrect. The 
state has only approved a sewerage system for 20,000 people and not 









40,000 as reported in the EIS. Therefore, the Vernal sewer system would 
not be capable of handling the additional impact of the combined synfuel 
projects. This apparent contradictory evaluation of the sewerage system 
capacity needs to be resolved and the correct evaluation stated in the 
final EIS 

Solid and Hazardous Waste 

° Page E-l-15; The EIS states that for the Enercor Rainbow Proect the 
major solid waste generated would be spent tar sand which would be mixed 
with the scrubber sludge waste and deposited back into the mine and that 
no known hazardous wastes are to be generated. This statement seems 
unsupported in 1 ight of the fact that the other projects expect to 
generate hazardous waste. 

Hazardous and toxic wastes for the Paraho Project would be transported 
and disposed of in an approved off-site location, yet the specific 
quantities and wastes are not addressed by the BLM in this EIS. 

° The site specific description of the Syntana Project states that the 
wastewater would be treated using the "Chevron wastewater treatment 
system". The details of this system were not outlined. The non-hazardous 
sludges , "green coke" from the retorting process , and general garbage 
would be mixed into the spent shale pile. The initial layer of spent 
shale would be compacted to produce an impervious layer. A clay layer 
might be preferable in preventing leachate from reaching the groundwater. 


General Comments 

Scope of the analysis is far more extensive than any previous EIS reviewed 
to date. The implications and impact analysis drawn from the data could 
have been expanded. Generally, however, the length and depth devoted to 
socioeconomic issues represents a marked improvement over the standard 
EIS treatment. Hopefully, the document will help to establish a stronger 
precedent in thoroughly addressing socioeconomic issues in further 

A key assumption employed by BLM is the manner in which "significant 
impact" is defined. We recognize the practical importance of establishing 
a percentage growth ceiling for purposes of conducting the analysis; but 
the assumed definition of "significant impact" requires one important 
caveat. It is the existing infrastructural and fiscal capacities of any 
community which really define a community's capacity to absorb growth. 
Consequently, the significance of demographic changes, when analyzed in 
isoloation from those conditions characterizing the fiscal and 
infrastructural capabilities, may result in inadequate identification of 
relevant issues. 

It is assumed that many direct project employers will reside in work 
camps on-site. It should be noted that occupancy in on-site work camps 
often is below predictions made by companies, and consequently, community 
impacts can be underestimated. This has been documented in several 
instances throughout the West. Construction and work camp populations 










should require close monitoring, and some sort of company policy developed 
to help insure that the assumed occupancy actually occurs. Otherwise, 
community impacts will have been understated in the EIS. 

° The EIS document does not identify any mitigation measures which might 
be undertaken to manage growth in the region. We understand that the 
decision not to include mitigation proposals was based on practical 
considerations and constraints of time and money. Reference should be 
made to the Utah Resource Development Code (63-51-10) which will require 
all of the proposed projects to submit to the Department of Community 
and Economic Development and affected local governments a socioeconomic 
and fiscal impact statement as well as a plan to alleviate impacts. 

Population and Employment 

° (-4-11; The report indicates that the cumulative impact of the High 
Scenario is 33,930 in 1985 and 72,857 in 1995. According to the 
Socio-Economic Technical report, these numbers should be 32,005 and 
67,868 respectively. 

° R-4-11; The DEIS defines the area of Socioeconomic influence as being 
Duchesne, Uintah Counties, Dinosaur and Rangely, Colorado. However, the 
indicated total impact of 26,973 in 1985 and 47,906 in 1995 includes the 
Grand County impacts. The cumulative impacts without Grand would be 
22,941 and 43,943 respectively. 

° R-4-11; Again the area of influence is misrepresented. Population 
increases without Grand County should be 73.4% and 100.5%. 

° R-4-12; The impact of interrelated projects for Grand County should be 
915 not 4915. This wrong figure is also used in the area of influence 
total for interrelated projects. Also the cumulative increase for 
Dinosaur should be 1744. The table also indicates that the remainder of 
Rio Blanco Moffatt County has some impact when in fact all Colorado 
impact was projected only for the communities of Rangely and Dinosaur. 
The source for the table should read 'Utah State Planning Coordinator's 
Office 1 . 

° R-4-13, Table R-4-5; The percentage increases for the area of influence 
for 1995 should be 73.4 and 100.5% rather than 54.6 and 74.5%. Also the 
source should read 'Utah State Planning Coordinator's Office'. 

* R-4108, Paragraph 4; According to the DEIS the cumulative impact of the 
Low Scenario plus interrelated projects is 27,904 in 1985 and 14,905 in 
1993. According to the Socio-Economic Technical report this impact 
should be 25,169 and 24,593 respectively. 

R-4-111, Table R-4-32; The applicants increase for Uintah County should 
be 9641 not 4641 and the cumulative impacts should be 15,085 not 14,085. 
Also the percentage increases for Uintah County should be 81.1% and 
126.8% rather than 72.6% and 84.4%. 

T-l-31; Personnel numbers for the construction workforce for the Tosco 
project do not agree with documented numbers for this project and those 
used to compute the Econ-Oemographic impacts. 





3 P-5-2, S-4-1; A telephone conservation with Brad Barber is cited as 
reference as the rationale for the allocation of population. The 
socio-economic technical report includes a lengthy discussion of the 
assumptions and methodology used in making population allocations. It 
would provide a better reference to cite the appropriate page(s) in the 
Socio-Economic Technical report (page 141-147). 

R-2-2, Table R-2--1; Construction/operation figures presented yearly per 
capita income data; they appear to look more like average monthly wage. 
Figures are not consistent with those in the technical report. The 
source of the BLM's figures is unknown as well as the underlying 
assumptions used in making those calculations 

R-3-6, Paragraphs 4 & 5; There is no description as to how average per 
capita income was calculated. The figures presented do not come directly 
from the technical report and attempts to use data provided in the 
technical report fail to generate the same average per capita incomes 
cited when using the defined area of influence to be Duchesne and Uintah 
Counties in Utah and Rangely and Dinosaur towns in Colorado. The number 
cited include Grand County. For example, in paragraph 5 of the projected 
per capita income for the area of influence is stated as being $9,373 in 
1985 and $10,436 in 1995. These projected incomes could not be generated 
with the data provided in the technical report. (1) If an unweighted 
average from the area of influence were calculated using county per 
capita incomes, the results would be $11,065 per capita income in 1985 
and $11,597 in 1995. (2) If a weighted average per capita income were 
calculated based on county per capita incomes and county population 
projections, the result would be an average per capita income of $9,437 
in 1985 and $10,410 in 1995. (3) If a weighted average per capita 
income wer calculated based on county per capita incomes and county 
populations projections for only the towns of Rangely and Dinosaur in 
the Colorado counties, the results would be $8,961 in 1985 and $10,367 
in 1995. This would appear to be the most appropriate. 

This type of data problem occurs in the other sections calculating per 
capita income impacts on the following pages: 

R-4-14, R-4-15, R-4-11 - para. 3: A baseline 1985 per capita 
income firgure of $9,437 is cited. This is not consistent with 
the data on page R-3-6 because the definition of the area of 
influence is different. This creates confusion when citing two 
different baseline figures for the same year. 

Community Infrastructure Capacity 

° The Draft UBEIS doesn't generally deviate from the findings of the 
socio-economic technical report in the area of community infrastructure 
capacity. There are some misinterpretations of the data but overall 
they appear minor. The major deficiencies within the socio-economic 
section are a result of predetermined decisions by the BLM on the scope 
of the EIS. These deficiencies include the lack of a fiscal impact 
analysis of the proposed synthetic fuels project on local tax structures 
and the lack of any discussion on potential mitigation alternatives for 
the "significant" socio-economic impacts. These deficiencies, however, 
are the result of policy decisions that the state of Utah was already 










cognizant of at the outset of the EIS. Within the Draft EIS the 
following misinterpretation of data was found relative to community 
infrastructure impacts of synfuel development: 

° Page R-3-11; Medical data on the Rangely area has been misinterpreted. 
The projections forecast additional demand for hospital beds beyond the 
current utilization rate. This doesn't necessarily indicate the need 
for new beds at the Rangely Hospital but could be handled through 
improving the utilization rate or through the use of tertiary facilities. 
Forecasting of health care needs only shows the increased demand potential. 
It doesn't necessarily follow that the existing "acute care" hospital 
facilities within the area need to expand. The data also reflects the 
demand that is served by the tertiary care facilities along the Wasatch 
Front or in Grand Junction. It is impossible at this time to 
disaggregate the portion of the forecast that represents an overflow to 
the Wasatch Front for tertiary care. 

Further, this same misinterpretation is reflected in other areas of 
the socio-economic section of the DEIS. Demand for services is only one 
criteria in determining the level of services a community should offer. 
The availability of more sophisticated, tertiary services in a nearby 
metropolitan area often offsets a substantial amount of demand for 
community infrastructure. The Draft EIS doesn't differentiate between 
services that must be available at the local level such as water and 
sewer and those services which may be supplied to some degree outside 
the area. 


Mineral and Energy Resources 

" Section R-3.A.13 (page R-3-57) refers to hydrocarbons as oil shale and 
tar sands but only oil shale resources are identified. Also this section 
refers to hydrocarbons including oil, gas, and coal, but no information 
is available in this report on the resources nor their impact on the 

In this report, amounts of oil per ton, depth of zone to be mined, 
distances for transportation of water and distances for transportation 
of finished product are presented, but no details on these important 
factors are included. 

The State is concerned about the terminology used with reference to 
resources of hydrocarbons. In the petroleum industry reserves are 
usually recorded as barrels of oil in place rather than tons of ore to 
be mined and there is no reference to this terminology at all. 

° Most of the mineral and energy resources for the individual projects 
refer to section R-3.A.13 for identification. We cannot comprehend how 
one simple paragraph (R-3.A. 13) can be inclusive enough to be the guide 
to all the resources to this enormous area. 

° The Draft EIS contains little detailed information on the physiography, 
geology, hydrology, and soils of those areas of the Uintah Basin to be 







affected by synfuel development. As a result, the document is of limited 
use in evaluating the geotechnical considerations of importance to these 
projects, i.e. facility siting (both mine plants and new towns), waste 
disposal, geologic hazards, and the potential for ground water pollution. 
The brief and often cursory coverage given these subjects may in part be 
due to the project specific and often site specific nature of such 
considerations and the need for detailed investigations to adequately 
identify and characterize them. If such data is not to be provided in 
this generic EIS, it should be submitted and reveiwed on a 
project-by-project basis as synfuel development proceeds in the basin. 

° Reference is made to page R-J-l of the document under item (1) of 
"Assumptions." This implication of the text is that the Utah Mined Land 
Reclamation Act applies only to State-owned lands. For clarification, 
this Act's application is not merely to State-owned lands but "to all 
lands in the State of Utah lawfully subject to its police power", U.C.A. 

° In addition, a continual reference is made in Chapter R-J to the "Utah 
Land Reclamation Act". This Act, (40-8-1 et seq. ) is more properly 
referred to as the "Utah Mined Land Reclamation Act." 

Water Resources 

° Numbers used for water resources supply and projected use generally 
agreed with our own, but it should be recognized that estimates of 
consumptive use have been revised frequently and should not be taken as 
final. We appreciate particularly the caveats relating to the "Law of 
the River" introduced on page R-4-45. 

Wildlife Resources 

° The regional summary of environmental consequences for wildlife habitat 
(page R-4-62) concludes that 36,911 acres of mule deer habitat will be 
disturbed. Since this constitutes only two percent of the 2,318,560 
acres of total deer habitat, the conclusion is reached that this would 
not significantly impact mule deer. This constitutes an extremely 
simplistic assessment of impact. This approach to impact assessment 
fails to recognize that habitat value is not uniformly distributed 
throughout any area. Even within areas presently designated as critical 
habitat for particular species, there are undoubtedly some areas where 
wildlife traditionally concentrate more than others, and are thus more 
critical to the welfare of existing populations. Present information in 
the Bookcliffs is not adequate to clearly define such concentration 
areas; however, the Division of Wildlife Resources is presently conducting 
intensive studies for BLM that will provide the basis for defining the 
most critical habitats for big game. Future planning must provide 
protection for those areas. 

° The discussion of impacts on wildlife also fails to consider the 
cummulative effects of these proposed and interrelated projects, and 
past and present oil and gas development as was done in the air quality 
and socioeconomic sections. In our view, the potential impacts of the 
proposed and interrelated projects are definitely significant. When 









viewed in relation to past and present oil and gas development, they are 
highly significant. 

The statement is deficient in its treatment of mitigation, both on a 

regional and site specific basis. Mitigation measures should be identified 
and evaluated for minimizing and/or compensating for both direct and 
indirect effects of proposed projects. For example, range improvement 
of areas of critical habitat prior to project disturbance in such areas 
can offset some of the direct losses that will undoubtedly occur by 
providing increased forage on adjacent areas. Busing of employees from 
residential areas to mine sites can reduce the indirect impacts of 
increased traffic. Energy companies can do much, through training 
programs and firearms control, to create a greater respect for wildlife 
and reduce poaching. 

Cul tural Resources 

Page P-3-53; The draft EIS for the Uintah Basin Synfuels Development 
possibly presents a misleading assessment of site density to vegetaton 
zone relationships taken from Jones and Hackay (1980). It may be 
misleading as Jones and Mackay (1980) dealt with 990 recorded sites and 
the EIS states that an additional 1,300 sites have been recorded since 
the study in 1980. Adding the 1,300 sites to the 990 sites and then 
relating site type to vegetation zone may show a different density of 
site type/zone than what Jones and Mackay described (1980). Perhaps it 
should be mentioned in the EIS report that site density to vegetation 
zone will change from area to area; for instance, in a given area where 
both sand dunes and their associated vegetation zone and pinyon juniper 
vegetation zones exist there may be a higher density of sites associated 
with sand dune biota and a low density associated with pinyon juniper 
zone (Jones and Mackay state that there is [generally] a correlation 
between a higher site densi ty for pinyon juniper zones than other 
vegetation zones) (Holmer 1979; Chandler and Nickens 1979; Simms 1979). 

° The EIS states in several different sections (BLM: R-4-86. R-4-132. 
R-5-3) that the proposed projects will have a dramatic effect on the 
existing cultural resources; the high-level scenario having a greater 
impact (higher level of development and product ion) than the low- level 
scenario. Potential impacts to cultural resources include "... land 
modification, vandalism, and relic collection". It is believed that 
impacts "would affect al 1 known and unknown cul tural resources within 
the region 1 . Further, "Cultural resources are nonrenewable: consequently, 
the loss of any information could have a significant impact on efforts 
to reconstruct the prehistory and history of the region" (BLM 1982: 


The anticipated 8% to 10% loss of irrigated cropland within the Uintah 
Basin is referred to as a moderate adverse effect to the local area. We 
feel the statement and accompanying figures for values lost are misleading 
in at least three counts. First, the 1 inkage between the cropland 
sector and the livestock sector was ignored as is the connection between 
those two sectors and the various agriculture processing, distribution 



and marketing sectors. Since agriculture production is a primary economic 
activity, such linkages are very significant. Second, though the loss 
to the base may be 8 to 10% region wide, it will be a much greater 
percentage in localized areas such as Ashley Valley. Third, the 
cummulative effect of losses in the Uintah Basin, coupled with' similar 
impacts in other areas of the state, are resulting in a significant 
impact to Utah's total agricultural productivity. 

Page R-3-4 
leases to 

I, Section R-3.A.7 

Last paragraph. 

first sentence, change 

Page R-4-76, Section R-4.A.7; Third paragraph should read as follows: 
The roadway segment on U.S. 40 (Utah) from the County Line to County Road 
264 would be the most severely (affected , impacted ) dropping from C to F 
unless improvements were made. ...Adding the interrelated projects would 
make the traffic impacts worse and would cause the U.S. 40 section from 
County Road 264 to SR-88 to drop from a baseline of B to E under the 
cummulative situation. The SR-64 (Colorado) section from Rangely to 
Dinosaur would become unacceptable with the applicants' projects and 
interrelated projects, dropping from a baseline level of C to D. 

Page R-476, Section R-4.A.7; Fourth paragraph changes should read as 
follows: (second sentence) ... These are from the County Li ne to 
County Road 264 and Vernal to Jensen. 

Page R-4-79; Fifth sentence: ...From the County Line to Jensen 

Page R-4-127, Section R-4.B.7; First paragraph, fourth sentence should 
be changed to read: "The U.S. 40 segment from the County Line to 
County Road 264 would be reduced from a baseline level of C to F." 

Page R-4-131; First paragraph first sentence: "In 1995 , baseline levels 
of service remain acceptable except for the U.S. 40 (Utah) segments 
between the County Line and County Road 264..." Last sentence: "The 
U.S. 40 (Utah) segment between County Road 264 ..." 




State of Utah 










BLM appreciates the State of Utah's input throughout the EIS 

This information has been added to the EIS Preface. 

The Air quality Technical Report (Section presents the 
rationale for the judgment that GPM does indeed develop a 
conservative analysis of ground-level concentrations. There are no 
data that would suggest otherwise. Unfortunately there are 
insufficient data available at the present time in the study region 
to provide ground truth for the purposes of validating the model. 
This is also the case in the majority of rural areas of the West (see 
responses to Comments 30.46 and 30.47 for further discussion). 

Three additional days have been simulated with RTM. Please see the 
response to Comment 20.14. 

The fact that the EIS air quality analysis does not satisfy state, 
local, and federal rules for regulatory/permitting purposes has been 
clarified in the final technical report (Preface, page iii) and the 
Final EIS (Chapter 4 Significance Criteria section and Section R- 
4. A. 2). It should be noted, however, the EIS is not a planning 
document but rather analysis of environmental impacts. The EIS 
becomes part of the body of information used by the BLH decision 
maker in making the decision, in this case regarding rights-of-way 
authorizations. The EIS also is used by other decision makers as 
part of a body of information considered in other 
regul atory/permitting processes . 

Refer to the response to Comment 30.44. 

The Air Quality Technical Report (Section 2.3) and Final EIS (Section 
R-3.A.2) have been revised. 

The Air Quality Technical Report (Section 3.1) and Final EIS (Section 
R-3.A.2) have been revised. 

Only the regional scale application of GPM was run using constant 
stability. On a regional scale, persistent we 11 -organized flow is 
required to cause elevated 24-hour concentration impacts at distant 
receptors. These conditions are not typically associated with winter 
stable conditions. Furthermore, the use of Pasquill-Gifford Class D 
plume dispersion parameters should be representative of more stable 
conditions for elevated plumes in complex terrain. 

Table 4.21 of the technical report has been revised, 
have been performed for four two-day periods. 

RTM simulations 

It is commonplace in air quality modeling analyses to use a model or 
modeling approach known to be conservative to calculate numbers that 
are interpreted to upper-range estimates. With these upper ranges, 
one can separate possibly significant impacts from insignificant 
ones. It is known that air quality model estimates are uncertain, 

but if a modeling approach is designed to be conservative, it is 
likely that concentrations predicted by the model are upper ranges. 
Several reasons are presented in the Air Quality Technical Report 
(Section for the judgment that GPM is conservative. 
Estimates of lower ranges were made using factors of 10 and 4 below 
the GPM predictions; these estimates are not based on any hard 
scientific evidence, because there is no existing data base (and, 
indeed, few existing sources) in the Uintah and Piceance basins with 
which to evaluate regional model performance. These estimates are 
based on four RTM runs for worst-case episodes and the qualitative 
statements presented in the Air Quality Technical Report and in 
responses to other comments. 

21.12 These baseline values were calculated on the basis of an empirical 
model in the Draft Air quality Technical Report. In the final 
report, monitored data from the Tosco Sand Wash and White River sites 
have been used to represent baseline air quality in the Uintah 

21.13 Section 6 of the technical report has been revised. 

21.14 A lease area boundary overlay has been included in the Final Air 
Quality Technical Report 

21.15 Section R-4.A.2 has been revised to clarify what sources comprised 
the secondary emission sources. BLM agrees that emissions resulting 
from facility operations should be considered direct, rather than 
secondary, sources whether they are stationary or mobile sources. 
Therefore, mobile source emissions generated by the project 
applicants were identified as direct sources, and company vehicle 
emissions were not considered to be secondary sources. 

21.16 Additional discussion and clarification regarding the impacts of 
emissions from secondary sources has been added to Section R-4.A.3 in 
the Final EIS. Additional emphasis has also been made that from a 
regulatory standpoint, the use of the PSO increment would be decided 
on a case-by-case basis by the State of Utah when companies apply to 
the state for their PSD permits. 

21.17 Section R-4.A.3 has been expanded to provide this qualification. 

21.18 The EPA rural fugitive dust policy allows the discounting of days 
with high TSP concentrations if it can be shown that high 
concentrations are due to windblown dust, not project-caused 
emissions. Section R-4.A.2 of the Final EIS has been expanded to 
recognize this consideration. 

21.19 It is true that for each of the site-specific analyses, secondary 
emissions were not included in the analysis. Secondary emissions 
were included only in the regional impact calculations. 

21.20 Yes, the baseline concentrations are the difference in these 
numbers. The baseline in Table M-4-1, which compares increased 
concentrations to PSD increments, considers only PSD permitted 
sources that have begun construction (Moon Lake Unit 1). The 


baseline in Table M-4-2, which compares total concentrations to the 
NAAfJS, are modeled values and include all sources in the region such 
as cities and mobile sources, because these sources must be 
considered when comparing to the NAAQS. In summary, the Table M-4-1 
baseline includes PSD sources, while Table M-4-2 includes all 
pollutant sources to compare with the NAAqS. This also applies to 
Tables M-4-5, S-4-1, and T-4-1. 

21.21 The modeling effort presents results that are expected from the 
applicants' proposed action and alternative water sources. The 
concept of intercepting ground water has been considered as part of 
the White River Dam EIS, and it may be further considered by the 
applicants and various state officials. 

21.22 Table SS-3 has been revised. 

21.23 The sewer analysis in Section R-4.A.1 has been changed to reflect the 
state-approved sewerage system of 20,000 people for Vernal. The 
analysis evaluates sewer capacity in relation to this correction. 

21.24 Hazardous waste would be generated by some oil shale upgrading 
processes. Tar sand extraction is accomplished by using hot water 
and some solvents. Therefore, no hazardous waste would be 

21.25 The types of hazardous wastes and quantities to be disposed of have 
been added to Table P-l-7. 

21.26 The Chevron plant is a standard, extended aeration, package treatment 
plant, which would meet secondary treatment standards. 

Syntana-Utah's objective is to have an impervious layer. If this 
cannot be obtained with just shale, then clay could be used either by 
mixing with shale or by using it totally. 

21.27 BLM notes that the State of Utah finds the scope of the 
socioeconomics analysis to be acceptable. The impact analysis 
presented is summarized from the Socioeconomics Technical Report. 

21.28 The 10 percent change in population is used as a threshold factor for 
screening the counties and communities for inclusion within the area 
of influence for further impact analysis. The existing 
infrastructural and fiscal capacities for communities are considered 
concurrently with population changes in the impact analysis of 
various infrastructure components. 

21.29 The impact analysis is based on applicant projections of numbers of 
employees that would reside in on-site work camps. If actual 
occupancy falls short of projections, then some of the community 
impacts could be understated in the EIS. Monitoring of work camp 
populations and policies to ensure that assumed occupancy occurs 
could be incorporated into the mitigation planning required by Utah 
Law (S.B. 170). This uncommitted mitigation measure has been added 
to Appendix A-7. 






Mitigation that would be stipulated by governmental agencies are 
Identified in the Site-Specific Analyses Introduction and Appendix A- 
10, General Measures for Grants and Permits. Refer to Table SS-3 and 
item 1 under State of Utah in Appendix A-10. 

The numbers in Section R-4.A.1 have been revised to agree with the 
technical report. 

The area of influence for socioeconomics includes Grand County (for 
population, income, and employment) for the high-level scenario 
(Section R-3.A.1). Grand County has been added to the area of 
influence to make the definition of the area of influence 
consistent. Grand County population impacts are correctly included 
as shown in the area of influence totals in Table R-4-4. 

Grand County is included in the socioeconomic area of influence under 
the high-level scenario (Section R-3.A.1). The error in the 
definition of the area of influence on the cited page in Section R- 
4.A.1 has been corrected. 

Table R-4-4 has been corrected. 

21.35 Table R-4-5 has been corrected. 

21.36 The numbers in Section R-4.B.1 have been changed to be consistent 
with the technical report. 

21.37 According to Table R3A-5 of the technical report, the applicants' 
Increase for Uintah County should be 8,641 in 1993, and the 
cumulative impacts should be 14,085 (8,641 plus 5,444) as shown. The 
percentage increase for Uintah County is correct for the applicants' 
percentage impacts in 1993, 72.6 percent (8,641 divided by 11,895); 
the cumulative percentage impacts in 1993 should be 118.4 percent 
(14,085 divided by 11,895). The errors on EIS Table R-4-32 have been 

21.38 The personnel numbers for the construction work force for the Tosco 
project in Table T-l-4 correspond very closely with the work force 
estimates in Table 3.2.1 1n the Sand H ash Oil ShaleProject 
Description Technic al Report (Tosco 1982)". There are" differences of 
Tor 2 (e.g. , 3746Y rather than 3,460), well within the assumed range 
of plus or minus 25 percent of the actual number. 

21.39 The reference has been changed in Sections P-4.A.1, P-5.A.1, and S- 

21.40 The per capita income figures by construction/operation presented in 
Table R-2-1 »r& annual increases in per capita personal income. This 
has been clarified in the Final EIS. 



21.41 The average per capita personal income (PCPI) figures were developed 
using an unweighted average of the county per capita incomes, but did 
not include Grand County ((7161 + 7307 + 10,091 +9361 )/4 = 8606 
average per capita income for 1979). However, since Grand County is 
included in the socioeconomics areas of influence under the high- 
level scenario (Section R-3.A.1), several of these PCPI figures have 
been changed accordingly. The 1979 average PCPI for the 
socioeconomics area of influence (as defined) was $8,596. This is 95 
percent of the average income of Colorado and Utah (Section R-3.A.1, 
Personal Income). In 1985, the increased PCPI (in 1980 dollars) 
would be $10,637; in 1995, this would increase to $11,400 (Section R- 
3.A.1, Personal Income). Changing the baseline PCPI figures to 
incorporate Grand County requires changes in the Personal Income 
discussion in Section R-4.A.1. Using data from Table R3A-29, the 
effect of the applicants' proposed projects would raise the PCPI level 
to $17,730 in the area by 1985, as compared with the baseline 
projection of $10,637. This is a 67 percent increase (Section R- 
4.A.1, Personal Income). For 1995, PCPI within the area of influence 
would be lower, with a level of $13,040 as a result of the 
applicants' proposals. This compares to a baseline projection of 
$11,400 (Section R-4.A.1, Personal Income). 

21.42 Section R-3.A.1 has been revised to accommodate the concern about the 
interpretation of the medical data for Rangely. 

21.43 Oil shale resources are identified, because they are the principal 
hydrocarbon source in the Green River Formation and the resource that 
has an estimated tonnage. Quantities of oil shale are shown to 
display the difference between the amount of oil shale to be utilized 
(affected environment) and the amount of resource remaining after 
mining (environmental consequences). No attempt was made to indicate 
quantities of resources other than oil shale. 

The other hydrocarbons (oil, gas, and coal) are mentioned, because 
they occur in close association with the oil shale, generally below. 
They would not be mined and would not be affected by the various 
mining operations. 

21.44 Details about these factors are found in the Chapter 1 discussion of 
each site-specific project and the related technical reports. 

21.45 The petroleum industry records reserves as barrels of oil in place. 
However, the oil shale industry refers to reserves in terms of tons 
of ore. 

21.46 In keeping with CEQ guidelines to include only significant 
information rather than to be encyclopedic, the Mineral and Energy 
Resources section focuses on major resources of the area that would 
be affected. See also the response to Comment 21.43. 

21.47 The EIS contains the significant geotechnical data needed to 
understand the impacts of the proposed projects. Regional 
physiography is evident in Map R-A-l and on Figure R-3-1. 
Physiography of the proposed projects is shown on each project's map 
(located in the various Sections 1.A.2). Hydrology is described in 
the various Water Resources sections (Sections 3. A. 3) and Soils are 
described in the Vegetation and Soils sections (Sections 3. A. 4). In 
addition, each of the applicant's technical reports has a section 
devoted to geology and/or geotechnical site evaluation. Geotechnical 
design of mines is an ongoing process that will evolve as the 
applicants proceed with mining. 

The plans and designs for these projects are based on existing data 
and will be modified to accommodate unforeseen conditions if they are 
discovered. Mitigation measures are provided as foreseen. Right-of- 
way permit conditions include measures for compliance and provisions 
for mitigation of impacts discovered throughout the life of the 

21.48 Appendix A-8 (Draft EIS Appendix R-0) has been revised. 

21.49 Appendix A-8 (Draft EIS Appendix R-J) has been revised. 

21.50 Consumptive use figures, as well as all other project description 
data, included in the EIS are each company's best estimates based on 
current levels of project design. 

21.51 Each site-specific project analysis takes into consideration the fact 
that these are "islands" within broad habitat classification that 
would be affected by a site-specific project but are too small to be 
considered in an overall, nine-project analysis. When more areas of 
critical habitat are defined, more detailed site-specific analysis 
can be made. Future long-range planning must, as stated in the 
comment, provide management and consideration for these critical areas 
on a site-specific basis. 

21.52 Cumulative effects of proposed and interrelated projects are 
discussed in Section R-4.A.5. The introduction to Chapter R-3 
explains that past, present, and future oil and gas development was 
included as part of baseline conditions. 

21.53 These potential mitigation measures have been added to Appendix A-7, 
which includes measures that could be stipulated as part of a 
permitting process or committed to by an applicant. BLM has no 
authority to require habitat enhancement on the oil shale or tar sand 
lease areas, which are all located on state or private land. Where 
rights-of-way occur on BLM land, compliance with a reclamation plan 
to ensure the land returns to preconstruction densities and forage 
production would be required. 

21.54 Section P-3.A.9 has been revised to clarify the intended meaning. 




21.55 The comment notes conclusions reached in the EIS analysis. Such 
conclusions reflect the view that while some artifacts and other 
cultural information may be salvaged, time constraints and 
accidential damage (as well as increased disturbance from greater 
populations) may result in lost information. Expedited salvage 
archaeology is not necessarily the most effective long-term 

21.56 As discussed in Section R-4.A.6, the major agricultural concerns 
related to synfuel development are: (1) the loss of cropland and the 
accompanying production of crops, mainly livestock feed, and (2) 
grazing reduction. These are discussed and substantiated with 
realiable figures and reference sources. How this would affect 
individual farms and ranches is also discussed in this section. 

Effects on the total agricultural sector (local economy) are 
discussed in Section R-4.A.1 under Agriculture. 

The Ashley Valley is recognized as the area most strongly affected by 
cropland conversion, with accompanying acreage figures and 
percentages. All figures are based on a ten-year projection of land 
use change as determined by local groups 

It is not within the scope of this EIS to identify and discuss 
cumulative effects for the entire state of Utah. 

21.57 Sections R-3.A.7, R-4.A.7, and R-4.B.7 have been revised. 





422 1st Avenue »2 
Salt Lake City, UT 
October 18, 1982 

Mr. Lloyd Ferguson 
District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, UT 84078 

Dear Mr. Ferguson: 

I am writing in response to the Bureau of Land Management's 
(BLM) solicitation of public comments on the Uintah Basin 
Synfuels Development Draft Environmental Impact Statement 
(DEIS) . The comments I am submitting focus on the air 
quality, wildlife, wilderness, vegetation and soil and 
visual resources sections of the DEIS. In general, I am 
concerned that the criteria adopted by the DEIS to assess 
the environmental impact of the proposed action are 
inadequate and that the analysis of the environmental impacts 
of the proposed action is based on unwarranted assumptions 
and, as a result, that the DEIS fails to consider fully the 
environmental implications of the proposed action. 

Significance Criteria. Other than a general reference 
to subjective professional judgment, the DEIS does not explain 
the basis on which the significance criteria employed in 
its analysis were adopted. Consequently, it is not possible 
to determine whether destroying not more than 5 percent of 
the Uintah Basin's wildlife habitat, experiencing an increase 
in the harrassment of wildlife of 15 percent, decreasing the 
flow of either the Green River or the White River by 10 percent, 
or allowing 10 to 20 years for revegetation of the land dis- 
turbed by the proposed projects is reasonable. 

On the whole, the si 
a project that anticipate 
0.5 percent of the Uintah 
resources will be affecte 
impacts on the Uintah Bas 
considered significant, 
avoided a critical assess 
environmental impacts by 
criteria under which most 
consequences can be dismi 

gnificance criteria appear to permit 
s minimal resource development-- only 

Basin's recoverable oil shale 
d-- to impose extensive environmental 
in without those impacts being 
Thus, the DEIS appears to have 
ment of the proposed action's 
adopting permissive significance 

of the project's environmental 
ssed as being insignificant. 

Mr. Lloyd Ferguson 
October 18, 1982 
Page Two 




Air Quality. The discussion of the proposed action's 
impact on regional air quality is extremely vague. The 
potential impact reportedly ranges from virtually no change 
to consumption of half of the allowable Class II increment. 
The DEIS cites the complexity of atmospheric dispersion 
modeling, limited meterological data, lack of knowledge 
concerning the types of pollutants emitted by oil shale 
facilities and uncertainties concerning synfuel emission 
control technology as factors that make an assessment of 
air quality impacts difficult. Considering the high quality 
of the Uintah Basin's air resources and the potentially 
significant impact on those resources if the proposed action 
is approved, further discussion of those factors is essential. 

the processes and technology identified 
ific projects undoubtedly have been tested on 
The results of those tests should be 
DEIS so that BLM and the public have some 
r assessing the impacts that may result 
large scale unit. Similarly, a discussion 
and developing synfuels emission control 
reveal the strengths and weaknesses of 
and thereby permit BLM and the public to 
lution problems that technology cannot 


For example 
in the site-spec 
a smaller scale 
discussed in the 
factual basis fo 
from operating a 
of the exisiting 
technology would 
that technology 
identify the pol 
mitigate . 

Similarly, the conclusion that the impact of the proposed 
action on acid precipitation is difficult to assess 
obscures the need to consider carefully the impact of acid 
deposition before proceeding with the proposed action. The 
DEIS recognizes that the Rocky Mountain area, including the 
Uintah Basin, receives the least acidic precipitation in 
the nation. The link between sulfur dioxide and nitrogen 
oxide emissions and acid deposition also is recognized in 
the DEIS. Although the effect of acid deposition on plants 
and soils may be inconclusive as yet, the incidence of 
adverse impacts on aquatic ecosystems in Canada, the eastern 
United States and Sweden demonstrates that acid deposition 
presents a serious threat to the environment. 

The results of the analysis of the proposed projects 
on acid deposition reported in the DEIS indicate that the 
area around the proposed projects will experience acid 
deposition 5 to 10 times greater than background levels. 
The levels reported approximate those experienced in the 





Mr. Lloyd Ferguson 
October 18, 1982 

Page Three 

eastern United States. In view of the dramatic changes that 
have been observed in the aquatic ecosystems in the north- 
eastern United States and Canada, acid deposition levels 
approaching those of the eastern United States cannot be 
considered insignificant. Indeed, the DEIS states that 
a study of two lakes in the Uintah Basin revealed that the 
proposed action would increase the acidity of those lakes. 

If the proposed action succeeds in demonstrating the 
viability of a Uintah Basin synfuels industry and that 
development occurs , the impact of acid deposition will 
becoming increasingly severe as cumulative effects are 
reali zed. Absent evidence that acid deposition will not 
affect the environment adversely, approval of the proposed 
action must be understood to irrevocably and irretrievably 
affect the Uintah Basin environment . 

Vegetation -Soil. Throughout the DEIS the proposed 
action ' s impact on vegetation and soil is described as 
temporary and insignificant . That conclusion assumes 
complete and successful implementation of extensive re- 
vegetation and reclamation programs by the project participants . 
Conditions in the project area , however , make revegetation 
extremely difficult and expensive. Thus, the DEIS' assumption 
is unrealistic. Moreover, compliance with the revegetation 
and reclamation plans will be difficult, if not impossible 
to ensure because the projects are located primarily on 
non-federal land. 

The unreasonableness of the assumption that the proposed 
reclamation and revegetation programs will mitigate the 
impact of the proposed projects is revealed by the DEIS . 
Over 75 percent of the land area covered by the proposed 
action receives between 4 and 8 inches of precipitation 
annually. Yet, it is generally accepted that revegetation 
requires 12 inches of precipitation annually . The DEIS 
recognizes the inadequacy of precipitation in the area, 
citing a study that found that favorable seeding years occur 
as infrequently as once every 20 years. 

The lack of precipitation is compounded by the low 
inherent fertility of the soil found throughout the project 
area. Not only is the soil of poor quality, but it also 
is not very deep in most areas . The combined effect of these 
characteristics is illustrated presently by the fact that 
only 20 to 25 percent of the ground in the project area is 
covered by vegetation. 



Mr . Lloyd Ferguson 
October 18, 1982 
Page Four 

The revegetation problem is further exacerbated by the 
need to isolate over 10,000 acres of spent shale that will 
be generated by the proposed projects. The revegetation 
plans contemplate covering the spent shale piles-- that may 
be up to 500 feet deep-- with 12 to 18 inches of topsoil. 
The DEIS mentions, but fails to resolve the problem of 
acquiring enough topsoil to accomplish that task. The 
area's natural conditions make it highly unlikely that the 
quantity of soil required could be acquired from local 
sources without destroying the environment of the source 
area. The cost of transporting topsoil from other areas 
makes it unlikely that the project participants will be 
able to afford importing topsoil. 

Although the DEIS recognizes all of the problems associated 
with efforts to revegetate the land disturbed by the projects, 
it describes the loss of vegetation as temporary and 
concludes that revegetation and reclamation are expected 
to be successful. As the facts presented in the DEIS 
indicate, that confidence is unfounded. 

The likelihood that the revegetation plans will not 
be implemented as assumed in the DEIS has significant 
environmental consequences that the DEIS does not address. 
Absent revegetation, erosion will present a significant 
problem. The DEIS recognizes that windblown dust presently 
is a major source of air quality degradation. That condition 
would be exacerbated by the removal of the existing ground 
cover. In addition to posing a greater health threat, 
increased wind erosion would affect adversely the visual 
resources of the area . 

Destruction of existing ground cover also would result 
in greater water erosion, thereby increasing the silt burden 
of the area's rivers. Water erosion also would increase 
the possibility that contaminants from the spent shale 
piles would be washed into the area's ground water and rivers. 
Finally, the failure to restore vegetative cover would 
permanently eliminate valuable wildlife habitat. As a 
consequence, existing wildlife populations would be depleted 
and the likelihood of overgrazing on other range areas 
would be increased. 

The facts developed in the DEIS strongly suggest that 
the assumption that revegetation and reclamation plans will 
be implemented effectively and will mitigate the adverse 
impacts caused by destruction of the existing ground cover 
is untenable. The DEIS, therefore, should discuss completely 
the environmental consequences of the proposed action in 
the absence of revegetation and reclamation of the area. 




Mr. Lloyd Ferguson 
October 18, 1982 
Page Five 

Wildlife. The DEIS describes the impact of the proposed 
action on wildlife in terms of the percentage of wildlife 
habitat disturbed by the projects. Although the total 
acreages involved are characterized in terms of the quality 
of the range disturbed, the present analysis fails to consider 
the characteristics of the wildlife that inhabit the area 
and the availability of accessible substitute range for 
the displaced wildlife. That is, the DEIS does not assess 
the density, age or health of the existing wildlife population, 
the ability of other range to support an added population 
burden, or whether the location of the proposed projects 
interferes with migration patterns or mating grounds used by 
the existing wildlife population. Discussion of those topics 
Is necessary to assess the qualitative impact of the 
proposed action on the area's wildlife resources. 

Summary. The DEIS presents an inexplicably optimistic 
assessment of the environmental impacts of the proposed 
action on the Uintah Basin. The background facts contained 
in the DEIS strongly suggest that the determination that 
the majority of the environmental impacts will be insignificant 
and the assumption that revegetation of disturbed areas 
will be successful are unrealistic. A critical examination 
of the basis on which the significance criteria were selected 
and a thorough evaluation of the environmental impact on 
the area if the revegetation plans are not implemented 
are required to enable the BLM and the public to make an 
informed assessment of the environmental impact of the 
proposed action. 


David L. Deisley 


David Deisley 

22.1 The significance criteria for most resources were established based 
upon professional experience and judgment. These criteria have been 
used in other EISs and have been generally accepted. There are no 
universally mandated criteria for all environmental impacts such as 
those examined in this document. 

22.2 In some cases, small, laboratory-, bench-, or pilot-scale studies of 
the proposed synfuel processes and technologies have been performed. 
Information from such testing was generally used to help derive 
emission factors and control technology reductions for the "larger 
scale units" when data were available. However, the results from 
pilot-scale studies are often proprietary. Furthermore, scaling of 
data and manipulation of information from pilot tests are usually not 
appropriate methods for estimating emissions from larger units, 
because the data are not linear functions of the source processes. 
For these reasons, knowledge of refinery and related processes is 
often used for selecting emission factors and control efficiencies 
for synfuel processes. 

22.3 It must be recognized that there presently are no oil shale or tar 
sand facilities operating at a commercial-scale level. Synfuel 
emissions control technology is an evolving process and must address 
two key issues: (1) defining potential emissions from a given 
commercial-scale process, and (2) determining the best available 
control technology that could be employed for emission species 
determined to be significant from the standpoint of human health, 
welfare, and other air quality related values. One focal point for 
research and analysis of current and future efforts is the Department 
of Energy Oil Shale Task Force which consists of four national 
laboratories and two universities. 

Data on potential gaseous and particulate emissions are presently 
being obtained from a variety of sources, including the efforts of 
the Oil Shale Task Force as well as publications, detailed 
development plans and PSD permit applications, and reports by DOE and 
EPA. These data have limitations in that they are taken from pilot-, 
prototype-, or bench-scale experimental retorts and processes and, as 
such, must be used with caution when extrapolating to commercial- 
scale processes. Except for the major gaseous pollutants, most of 
the other types of emissions have been studied in either the Paraho 
process or one of the in-situ processes. These are all basically the 
direct combustion type. Fewer data are available on other basic 
types of retorting such as indirect heated processes (TOSCO II, Union 
B, and Lurgi), and fluidized bed processes such as Chevron. Thus, 
emissions from the full range of retorting processes and starting 
shales have not yet been fully characterized. Even in those 
processes which have been better characterized, uncertainties exist, 
particularly in the area of particulate and organic emissions. These 
emissions are strongly dependent on both the exact retorting 
conditions and on the types of abatement equipment which are 
operated. A rigorous evaluation of these types of air emissions must 
wait until operation of the first commercial retorts. 



As data are obtained on commercial-size units, it will be possible to 
develop and select more efficient and cost-effective control 
systems. Most of the emphasis to date in control of emissions has 
been placed on the criteria pollutants such as sulfur dioxide, total 
suspended particulates, nitrogen oxides, hydrocarbons, and carbon 
monoxide. More uncertainty exists over potential emissions of toxic 
pollutants such as polyaromatic hydrocarbons (PAH). These PAHs are 
found in some petroleum streams. Potential emissions of some trace 
elements such as mercury and arsenic tend to be associated with 
particulate matter which places additional emphasis on efficient TSP 
controls. Even though there are no commercial-scale oil shale or tar 
sand facilities in operation at the present time, there are data 
available from similar processes which have extensive experience in 
emission control technology. For example, many of the mining 
operations for oil shale would be similar to mining activities for 
coal and other minerals. Products of retorting processes would be 
similar to those used in petroleum refining. 

Control of particulate emissions will be a major challenge to an oil 
shale project largely because of the magnitude of the solids handling 

Sulfur dioxide control appears to be a less significant problem, but 
sulfur recovery controls are expected to be the largest single 
category of air pollutant control expenditures for an oil shale 
plant. A commercial-scale oil shale facility, however, would be a 
less significant source of sulfur dioxide emissions than a moderately 
sized power plant meeting the New Source Performance Standards. 

Generally, typical control facilities that would be used in "a synfuel 
project will be adoptions of those that have been proven in mining, 
refining, and chemical processing. It still remains the case, 
however, that experience with a commercial-scale operation in synfuel 
emissions recovery is necessary to make actual assessments of 
emissions recovery effectiveness and efficiency. 

As discussed in the EIS in the regulatory permitting process, 
permitting agencies would apply best available control technology 
analysis to each facility, whether it employs the TOSCO II, Union, 
Superior, fluidized bed, or an in-situ process, and specify the 
necessary control efficiency required to meet applicable standards. 

The analysis in this Final EIS has used what, to our knowledge, is 
the best available data on emissions and emission source terms. For 
additional discussion, see response to Comment 22. 2. 

In the acid deposition section of the Draft EIS, the qualification as 
to the present uncertainties involved in any analysis of potential 
impacts from acid deposition was not intended to obscure the need to 
consider potential impacts as carefully as the present state of 
knowledge would allow. Rather, it was. intended to allow recognition 
by the public that there are indeed many unknowns in the data base, 
prediction tools, and effects assessment. In the absence of a more 
definitive data base, the analysis was intended to be conservative, 





as discussed in comment responses 30.53, 30.54, and 30.55. The acid 
deposition discussion has been expanded in the Final EIS (Section R- 
4. A. 2 and Appendix A-5). 

The assumption of achieving successful erosion control, reclamation 
and revegetation on land disturbance caused by project activities in 
the Uintah Basin is based on the intensive implementation and 
compliance with a realistic and effective erosion control and 
reclamation program. The effectiveness and reliability of the 
measures and procedures outlined for reclaiming for land disturbance 
caused by installation and construction of right-of-way facilities 
and plant facilities are based on research, field trials, and 
experiences of many years. Specific measures associated with surface 
mining and spent shale disposal areas are based on recent research 
and field trials. All practices and procedures identified are well 
documented and have been demonstrated to be reliable and feasible in 
making assumptions regarding effectiveness. (Refer to notes and 
references associated with Table A-8-2 and to erosion control 
treatment analysis in Table A-8-3). 

Compliance would be consistent on all lands since inspection and 
certification of successful erosion control and revegetation would be 
determined by the land owner or authorized agency official. 

Volumes of topsoil and suitable plant growth materials necessary for 
reclamation are available within the disposal areas. Detailed on- 
site investigation and special stripping and stockpiling procedures 
would need to be utilized. 

Section R-4.A.4 acknowledges that impacts to soils and vegetation 
would be significant if applicable erosion control and reclamation 
procedures are not implemented due to lack of compliance with 
approved plans or if adverse weather conditions (mainly heavy 
rainstorms) would occur during construction before erosion control 
measures could be installed. 

Since the applicants have committed to implement an applicable and 

effective reclamation program, it is unnecessary to present a 

complete impact discussion as though no reclamation program would be 

There are no data available on densities, sex, age, and health of 
resident wildl.ife species. In most cases, the Utah Division of 
Wildlife Resources does not collect these data. Fawning areas, 
strutting grounds, and similar areas are identified in a site- 
specific analysis if they would be affected. 

As discussed in the responses to Comments 22.1 through 22.7, the EIS 
analysis is intended to be an objective analysis based on the best 
available data. 




Union Energy Mining Division 

Union Oil Company of California 
2777 Crossroads Boulevard, Suite 100 
Grand Junction, Colorado 61501 
Telephone (303) 243-0112 


James S. Cloninger 

M*n*9*f of Adminlitrathn* S«rvic*i 




October 18, 1982 

Mr. Lloyd Ferguson, District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 84078 

Dear Mr. Ferguson: 

Union Oil Company appreciates the opportunity to comment on 
the Draft Environmental Impact Statement (DEIS) for Uintah 
Basin Synfuels development. Our comments revolve primarily 
around the DEIS's Air Quality Impact Assessment. 

We strongly support the use of ranges of values in the pre- 
sentation of potential impacts. This is a realistic approach 
which recognizes the uncertainty in results, and allows more 
informed planning to occur than presenting worst case impacts 
alone. The DEIS should have carried this approach further, 
however, clarifying the high degree of uncertainty inherent in 
quantifying particulate emissions from secondary sources. 

The summary document would also be more consistant if it acknow- 
ledged the discussion contained in the Air Quality Technical 
Report, Section 4.2, which recognizes the uncertainty in pre- 
senting the high impact end of the range air quality impacts. 
As stated in the Technical Report, the Gaussian Puff Model (GPM) 
yields results of a higher degree of uncertainty than the 
Systems Applications' Regional Transport Model (RTM) in "treating 
the dispersion of pollutants from many sources over large trans- 
port times and distances.". Therefore, using the results from the 
GPM to represent the high impact level introduces more uncertainty 
and is more conservative than necessary. 

Finally, the correct development scenario for Union Oil Company's 
Parachute Creek Shale Oil Project is 90,000 barrels per day, 
rather than the 50,000 barrels per day used. It is unclear whether 
the emissions from Union's mine, retorting, and upgrading 

Mr. Lloyd Ferguson, 
October 18, 1982 
Page Two 

District Manager 


facilities are all included in the emissions estimates. 
However, the totals appear to underestimate those emissions 
projected by Union Oil by a factor of between 2 and 7 depending 
on the parameter. We would be happy to meet with you to pro- 
vide more detailed information. 

Again, Union Oil Company appreciates the opportunity to comment, 
and would welcome an opportunity to discuss the items mentioned 
above. Please feel free to contact me or Terry Larson at (303) 


Diana O. Bender 
Environmental Coordinator 




Union Oil Company 

23. 1 Section of the technical report discusses the large degree of 
uncertainly in the estimate of particulate matter emissions for 
vehicle travel on class "D" roads. The report indicates a range in 
class "D" road activity of four to one on the basis of population 
increases. Furthermore, uncertainty exists in the emission factor 
for class "0" roads (discussed in Section For these 
reasons, it is projected that the estimate of future particulate 
matter emissions from travel on class "D" roads could vary by a 
factor of two, with the single estimate needed for modeling purposes 
(e.g., see category 470 in Table 4-14) representing approximately the 
midpoint of the range. 

23.2 The discussion of the expected conservatism of the GPM values has 
been expanded in both the Final Air Quality Technical Report (Section and the Final E1S (Section R-4.A.2), including the use of 
three additional scenarios which compare GPM results with those of 

While BLM agrees that RTM is a more sophisticated model and probably 
more realistic than GPM, RTM results are available for only a few 
days, while GPM results are for every day in a year. Thus, RTM 
cannot be relied upon solely for worst-case episodes. BLM does not 
concur that GPM is in all cases unnecessarily conservative. In some 
cases, RTM predicts higher concentrations at certain locations than 
GPM (see Final Air Quality Technical Report, Section 5). 

23.3 Emission values were developed by PEOCo for the Union oil shale 
facility on the basis of best available information at the time when 
the estimates were made. Since that time, Union's plans have changed 
from 50,000 to 90,000 barrels per day, but the Colony project, which 
was planned to produce 47,000 barrels per day, was cancelled. It is 
possible that the net effect on regional air quality of these two 
changes is nearly zero, because Union's emissions are larger and 
Colony's are smaller and both projects are located in the same 
portion of the Piceance Basin. 

The values for Union shown in Table 4-5 of the Draft Air Quality 
Technical Report were incorrect and not the values used in the 
modeling analysis. The numbers given in the Draft Air Quality 
Technical Report were about 3 to 7 times lower than those used in the 
modeling. The Final Air Quality Technical Report has the correct 
values for a 50,000 barrels per day facility. 



llttlRINt I IfjO INU. shale oil development and production 

582 north vernal avenue • po box 889 • vernal. Utah 84078 • telephone (801 ) 789-0806 


October 15, 1982 

Mr. Robert E. Pizel 
UBS EIS Project Leader 
Bureau of Land Management 
3rd Floor, East 
555 Zang Street 
Denver, CO 80228 

Dear Bob : 

Enclosed are a few pages of the DEIS containing changes 
that reflect data consistency between the written text of our 
project descriptions and the appropriate tables. Please incor- 
porate such changes into the final EIS. 

I hope the brief tour of our current research site proved 
to be of some benefit to you and those accompanying you. 

Sincerely yours , 

Rusty Lundberg 

Environmental Coordinator 

Enclosures (5) 

TABLE R-l-9 

High-Level Scenario 








Enercor (Rainbow) 
Enercor-Mono Power 
(P.R. Springs) 




%x * 


Magic Circle 















Combined Applicant Total 367,500 121,899,675 216,100 70,666,000 
Interrelated Projects 178.500 3 58,637,250 67,500 b 22,173,750 



180,536,925 283,600 92,839,750 

NOTE: tpsd = tons per stream day; tpy ■ tons per year. 

awhite River Shale Project. 

^Western Tar Sand and C and A Tar Sand Projects. 

* Set f»T)je*> pctscr-i^t.'evi y. )2_-c-5 - X*- SUowWl V>c woftjd 

W^eJr no sVwk »"S vn^tti r*" - V^e. UsPe.EU> prcfecH ar~ for- 
rWt -SecorvjWy ir\ 4;Vvi uiorU. [or- me, k^&w-y Onu^ fVti'ect-. 



TABLE R-l-16 


Low-Level Scenario 


Oil Shale 
tpsd tpy 




Enercor (Rainbow) 
Enercor -Mono Power 
(P.R. Springs) 

46 , 300 



30,000 9,855,000 

Magic Circle 

35,000 12,264,000 


20,000 6,570,000 





Combined Applicant Total 

26,630 8,180,850 
35,237 11,573,350 



146,867 48,445,200 



Interrelated Projects 

178,500= 58,637,250 



325,367 107,082,450 



NOTE: tpsd = tons per stream day; tpy = tons per year 

Mhite River Shale Project. 

Western Tar Sand and C and 
iroiweA . ; • 

A Tar Sand Projects. 

•A. fsv- sw^w-e. Y-.-Vo.ri- [mr /Vc^V i>«"^ 
\M oh-a-r- u»rV vv, V V^ S>"V\A- Oio sKa\«- 



In the construction of a true in-situ retort, a pattern of blast holes would 
be drilled from the surface through the overburden into the oil shale bed. 
The holes would be loaded with explosives and fired using a carefully planned 
blast system. The blast results in a fragmented mass of oil shale with a high 
permeability. The void space in the fragmented zone would come from lifting 
the overburden and producing a small uplift of the surface. 

The fragmented zone constitutes a true in-situ retort. The bottom of the 
retort would be sloped to provide drainage for the oil to a sump where it 
would be lifted by a number of oil production wells. Air injection holes 
would be drilled at one side of the retort and off-gas and oil production 
holes drilled at the opposite side. 

The oil shale would be ignited at the air injection holes and air injected to 
establish and maintain a burning front that occupies the full thickness of the 
fragmented zone. The front is moved in a horizontal direction through the 
fractured shale towards the off-gas wells at the far side of the retort. As 
the burn front moves from the air-in to the gas-out wells, it would burn the 
residual coke in the retorted shale as fuel . The burning front would heat the 
oil shale ahead of the front, producing gas and driving out the shale oil 
which drains to the bottom of the retort, where it would then flow along the 
sloping bottom to the oil production wells. The gas would be combustible and 
would be used for power generation. Progress of the burn front would be 
monitored by thermocouples set in thermocouple wel Is. 


There are no feedstocks contemplated for use at the plant site. 


The primary product for the proposed retorting operations would be 5,000 
barrels per stream day (bpsd) of shale oil per section of land. When all 10 
sections are in production in 1994 the maximum output would be 50,000 bpsd. 
The by-products from the operation of the proposed project would be the 
product gas which could be used for on-site energy production and water, part 
of which could be used as a viable resource (quantity of water equivalent to 
oil production). A pipeline to transport the shale oil to a refinery may be 


Each unit would use existing access roads. These existing access roads would 
be used to the extent possible, however Geokinetics may need to develop 
additional access to the sites. Utility and product pipeline corridors may be 
needed, but the needs have not been defined. 




Geokinetics also holds oil shale leases on 22,000 contiguous acres located in 
southern Uintah County, Utah. Over one billion barrels of shale oil are 
contained in this area. 

The proposal is to mine and surface retort 22,000 tons per stream day (tpsd) 
of oil shale from a 13-foot thickness containing between 28 and 33 gallons of 
oil per ton. Room-and-pillar mining would be used and the mine would probably 
be developed from an adit entrance. It is further proposed that the mine 
would facilitate subsequent secondary recovery of the remaining resource by 
means of controlled blasting and in-situ retorting of the pillars and of the 
lower grade oil shale located below the high-grade, mined-out bed. 


The site is located in Uintah County, in the northeastern portion of Utah 
(about 70 miles south of Vernal (Map R-l-2, back cover pocket). Approximately 
19,200 acres of this area was leased in April 1977 to Geokinetics by the Utah 
Shale Lands and Minerals Company; the remainder was leased in July 1978 from 
the State of Utah. This area is located in T. 12 and 13 S., R. 20 and 21 E. 
in the Agency Draw vicinity. 


The following processes would be used in this project: 

1) Room-and-pillar mining 

2) Mined shale transportation and crushing 

3) Surface retorting 

41 Spent shale disposal 

5) Waste gas treatment and disposal 

6) Secondary recovery by horizontal in-situ retorting 

The transportation and crushing of the mined oil shale would be done with 
conventional belt conveyors and jaw and gyratory crushers, respectively. 

Retorting may be performed by the P - a^ah c B it Meat process. 

Additional development would involve the blasting of mine support pillars and 
shale underlying the mined zone in preparation for modified in-situ 


There are presently no plans to construct or use feedstocks. 



(P*'»'ji.'H">* ">' Vm'' 



• See. *«*«> S>M."^pWovv f. i-C-a 
*f See. P«;«> Pko-.vW*"- ?■ B.-C-Z- 






Geoklnetlcs, Inc. 

24.1 As noted below, the changes have been incorporated in the Final EIS. 

24.2 Table R-l-9 has been revised. 

24.3 Table R-l-16 has been revised. 

24.4 Appendix A-2 has been revised. 

24.5 Table R-l-1 has been revised. 


.Kt'l.Y BEKEK TO: 


United States Department of the Interior 





SALT LAKE CITY. UTAH 84138-1197 

October 18, 1982 


TO: District Manager, Bureau of Land Management 
Vernal, Utah 

FROM: Area Supervisor, U.S. Fish and Wildlife Service 
Salt Lake City, Utah 

SUBJECT: U.S. Fish and Wildlife Service (FWS) Comments on the Uintah 
Basin Synfuels Draft Environmental Impact Statement (DEIS) 

The Uintah Basin DEIS has been reviewed for technical adequacy per- 
taining to how the proposed developments may affect wildlife resources. 
Most sections of the document were found complete, well organized and 
easy to follow. The site specific analyses provided good reference to 
the proposed action and adequately addressed the consequences and poten- 
tial losses of wildlife and habitat from the development on the sites. 
Also, the high-level and low-level scenarios allowed the reader to 
examine the proposal from different levels of development. This seemed 
appropriate considering the volatility of the current oil shale industry. 

The FWS ie most concerned that the DEIS does not adequately address the 
cumulative effects to wildlife in the Uintah Basin and mitigation for 
those potential losses. Our comments, therefore, will reflect these 
concerns and reiterate our position staterl in our April 21, 1982 review 
of the preliminary DEIS. 

The DEIS does not fully address the impacts of increased human population 
in the basin and their subsequent direct impacts on wildlife resources. 
In most respects, wildlife resources are limited by a small portion of 
the Uintah Basin (i.e. riparian habitat, critical deer winter range, 
critical summer range, etc.). The increasing human population will 
create more stress on critical habitats and attendent wildlife regardless 
of where the actual synfuels plants or mines will be. The acrea of 
habitat lost or disturbed from the proposed developments is only one 
measure of the cumulative effects to wildlife. These other off-site 
losses must be addressed. 


Only when off-site losses are recognized can off-site mi 
cumulative impacts of synfuels development be proposed, 
will, in turn, increase the demand for consumptive and n 
wildlife on public and private land in the basin. Unles 
are taken, more and more private land will be posted or 
users creating more demand on fewer areas and resources. 
have a snow-balling effect until virtually all private 1 
public access. This could result in economic and recrea 
sports as pheasant and quail hunting which occur almost 
lands as well as law enforcement problems from trespass 

tigation for the 

Population increases 
onconsumptive uses of 
s adequate measures 
closed for wildlife 
This situation can 
and is closed to 
tion losses from such 
total ly on private 

Big game and sport fisheries are an important natural resource in the north- 
eastern Utah region. In some areas, hunting and fishing pressures may already 
be at the highest point possible and still sustain the current population 
levels of fish and wildlife on the existing habitats. Increasing human 
populations in the Uintah Basin could raise the level of use beyond that 
point resulting in reductions in those current population levels. Increasing 
human population could raise the level of use beyond the point where those 
game species are self-sustaining. 

Increasing wildlife law enforcement, purchasing easements and access for 
recreation users, land exchanges, and land use changes to acquire or create 
high-value wildlife habitats are some ways to mitigate or avoid the afore- 
mentioned problems. 

A commitment to these types of programs should be spelled out in the EIS 
before any development, so all involved parties are aware of what is necessary 
to insure that the quality of wildlife habitat remains intact in the Uintah 
Basin. The FWS would welcome the opportunity to work with the Utah Division 
of Wildlife Resources, the county governments, the companies involved, and 
the BLH in developing this type of mitigation plan. 

This concludes our comments on the Uintah Basin synfuels draft EIS. 

Comments relative to threatened and endangered species is being provided by 
separate letter from our Endangered Species Field Office. 





U.S. Fish and Wildlife Service 

25.1 Each site-specific analysis has a section on cumulative impacts of 
human population increases on wildlife populations, habitat loss due 
to housing construction and similar factors. As stated in the 
comment, indirect impacts caused by people would be as great or 
greater than direct impacts caused by actual project construction and 
operation. This point has been re-emphasized in Section R-4.A.5. 

25.2 BLM has no authority to require these types of mitigation on lands 
other than federal lands. The mitigation measures mentioned are all 
valid, but cannot be required under present laws. 










Department of Natural Resources 
1313 Sherman Street, Room 718 
Denver, Colorado 60203 

Phone (303) 839-3311 

October 18, 1982 

Mr. Lloyd Ferguson, District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal , Utah 84078 

Dear Lloyd, 

We request your consideration of the following comments on the 
Uintah Basin Synfuels Development DEIS submitted by the Colorado Natural 
Areas Program, Colorado Department of Natural Resources. 

The Colorado Department of Natural Resources and the Bureau of Land 
Management have a memorandum of understanding which describes a process 
for the identification and protection of those areas managed by BLM which 
qualify as state natural areas (e.g., possess unique natural characteristics 
ofstatewide or national significance). 

Raven Ridge Natural Area 

Raven Ridge Natural Area, a 7840 acre site seven miles south of the 
Town of Dinosaur, is a registered Colorado Natural Area. Raven Ridge 
Natural Area contains unique and endemic plant communities, including 
Category II and special plant species. The "Morman Gap Alternative 
Natural Gas Pipeline" (S-4-18) plan would cross the Raven Ridge Natural 
Area, disturb the existing plant communities, and negatively impact the 
site. We recommend that this alternative not be implemented. The 
Colorado Natural Areas Program should be consulted prior to any development 
activity within the boundaries of the Raven Ridge Natural Area. 

Threatened and Endangered Species 

The razorback sucker ( Xyrauchen texanus ) is considered endangered 
by the State of Colorado (R-3-43). Appropriate steps should be taken to 
ensure its protection. 

Sclerocactus qlaucus (Uintah Basin hookless cactus) is listed as 
threatened; it is not a Category I species (R-3-32). 


Lloyd Ferguson 
October 18, 1982 
Page 2 

Aquatic and Terrestrial Ecosystems 

The Atriplex conferti f ol i a / Elymus ambiqus plant community is 
identified by the Colorado Natural Heritage Inventory as a plant 
community of special concern for the State of Colorado. This plant 
community occurs about 5-15 miles east of Rangely. This vegetation 
could occur in the project area in Colorado on Green River shale 

Thank you for your consideration of these conrnents. Please call 
me if you require additional information. 


Carse Pustmueller, Ph. D. 

Di rector 

Colorado Natural Areas Program 


State of Colorado Natural Areas Program 

26.1 Please refer to the response to Comment 14. 

26.2 Refer to .the responses to Comments 14.1 and 14.2. 

26.3 Refer to the response to Comment 14.4. 








. KKI'I.Y KKUlK Tl> 



United Stales Department of the Interior 



HMi J'j.rfVi Street 

P.O. Bin 2i>ZM7 

Denver, Culnradu HtH£23 

OCT 1 

To: District Manager, Vernal District Office, BLM 

From: Regional Director, Rocky Mountain Region 

Subject: Uintah Basin Synfuels Development EIS 

The National Park Service has reviewed the draft Uintah Basin Synfuels Develop- 
ment Environmental Impact Statement. These comments incorporate by reference 
NPS comments of April 22, 1982 (enclosed) on the preliminary draft EIS, many 
of which were not addressed , and remain of concern. 


The Bureau of Land Management's preferred alternative is to approve the rights- 
of-way necessary to implement all of the proposed site-specific projects. The 
preferred alternative is based on the assumption Cpg. xxxv) that "impacts due 
to the development of all the applicants ' proposed projects would be manageable 
assuming ... compliance with existing regulations". We disagree with BLM's 
selection of a full -development scenario aB the preferred alternat ive given 
that the EIS projects significant water quality , cultural , recreational and 
socio-economic impacts, and particularly since the EIS acknowledges the poten- 
tial for exceedances of Prevention of Significant Deterioration increments and 
violations of the National Ambient Air Quality Standards. 


Our primary concern with the recreation portion of the DEIS is that it only 
addresses the user 's perception of change in recreat lonal f acilities--it does 
not address the legislative and regulatory mandates for preservation of those 

The EIS should address the impacts of increased population growth on NPS units 
in the project area. For example, Increased population growth will likely 
place tremendous demands on Dinosaur National Monument's 135 front-country and 
35 back-country (excluding river) developed campsites, as well as on wilderness 
camping opportunities. The EIS should also Include a discussion of the revenue 
associated with the various recreation activities in the study area, and an 
analysis of the likely change in recreation revenue level if all projects 
proceeed as planned. 

We are concerned with the number of discrepancies in the DEIS regarding local 
recreational facilities which will be Impacted by population growth associated 



with project development. Page xxxi indicates that municipal recreation 
facilities and city park areas will likely become overcrowded and over-used as 
a result of large population increases, and page R-3-16 states that services are 
already strained by ail and gas development-induced growth and will likely be 
further stressed during the next few years. Thus we are puzzled by the numerous 
statements throughout the DEIS which refer to little or no impact resulting 
from the population increases associated with individual projects (pp. E-4-12, 
M-4-14, P-4-13). It seems contradictory that an increase of 1,000 workers for 
the Syntana-Utah project "could affect urban recreation facilities in Vernal, 
Range ly , and other surrounding communities" and yet population increases of 
over 5,000 people for the Magic Circle project "will not have impacts on local 
facilities In Vernal, Roosevelt, or Rangely". 


We are concerned that no mitigation measures for recreational facilities have 
been committed to. For example, the DEIS (pg. R-4-85) projects possible "serious 
adverse Impacts to the quality of the wilderness experience" at Dinosaur National 
Monument, but does not address possible mitigation measures for this impact. 
There Is ample precedent for provision of recreational facilities by project 
sponsors, and a development at this scale certainly warrants such consideration. 
The final EIS should Include a discussion of mitigation measures and commitments 
from local municipalities and /or project sponsors to provide adequate recreational 


The chart of recreational attractions (page R-3-4 7) should Include "proposed 
wilderness" for Dinosaur National Monument . Also, the EIS should note that the 
quality of river-rafting through Cataract Canyon in Canyonlands National Park 
could be affected by reduced flows In the Green River. Further, the references 
to the Dominquez-Escalante Trail on pages R-4-83 and T-4-29 shoul d be revised 
to note that a final study report on the Trail was sent to the Congress on 
April 28, 1982 recommending against designation as a unit of the National 
Trails System at this time. 


Air Quality 

The National Park Service has provided detailed air quality comments and recom- 
mendations to the Bureau on this project in writing on at least four occasions 
(4/22/82, 4/28/82, 5/3/82, and 6/17/82), and haB had frequent telephone conver- 
sations and meetings with the Bureau's air quality staff and SAI, the air quality 
consultant. Many of the concerns raised by the NPS throughout the development 
of the DEIS have still not been adequately addressed. In general we feel it 
is unnecessary to reiterate all of our previous comments , and instead refer 
the Bureau back to previous NPS memoranda detailing specific shortcomings of 
the air quality analysis. 


However, we again wish to go on record regarding our concern about the modeling 
efforts which were uBed in the analysis. As has been discussed in previous 
memoranda, we do not accept the theory advanced in the DEIS that the Gaussian 
Puff Model (GPM) which was used for the Initial air quality analysis "is recog- 
nized to be conservative", and that the Regional Transport Model (RTM) "la the 
more realistic" model, particularly when the analysis extrapolates the results 
of one RTM analysis, which was done for one 48-hour worst-case period, to all 
other scenarios analyzed in the report. We are therefore pleased that the BLM, 
at the request of members of the Technical and Policy Evaluation Committee, has 
agreed to do additional RTM runs to predict impacts on Dinosaur National Monument, 








the Flat Tops Wilderness Area, and the Ute Indian Reservation. The results of 
the additional modeling analyses should be included in the final EIS. We 
appreciate the opportunity to be involved in the additional analyses, and 
request an opportunity to review proposed revisions to the air quality sections 
of the document before the final EIS is published. 

The final EIS should also address the discrepancies In modeling results between 
analyses performed for BLM for this study and those performed for BLM's prototype 
oil shale EIS. 

Wild and Scenic River Designations 

We disagree with page E-4-12 of the EIS which states that construction of the 
White River Dam would eliminate the river from consideration as a National Wild 
and Scenic River. The segment of the White River under consideration is 68 
miles long, extending from the Green River to the Colorado/Utah State Line. 
Since the White River Dam project would involve only 13.5 miles of the river, 
as noted on page 2 of the FEIS for the project, it does not follow that this 
single project would result In elimination of the entire 68-mile segment from 
further consideration. 

Neither do we agree with the stance taken in the DEIS which assumes completion 
of the White River Dam project, especially since page xxxii notes that a certain 
degree of uncertainty still exists as Co when and if the project will be com- 
pleted. The DEIS, by assuming completion of the White River Dam, tends to 
minimize the degree of impact to the White River from the proposed synfuels 
projects, even though individual projects may cause significant adverse impacts 
to the river environment Independent of the Impacts which would result from 
the dam. The Information in the DEIS and Map R-A-l indicate that the Paraho, 
Tosco, and Syntana-Utah projects will Involve access roads, transmission lines, 
construction camps, and spent shale disposal In proximity to the river in areas 
not associated with the White River Dam project. The impacts from these projects 
could themselves result in the elimination of a portion of the White River from 
further consideration for a Wild and Scenic River designation, even if the White 
River Dam were not build. Should the dam and the synfuels projects all be com- 
pleted, adverse Impacts would result Co much more of the White River than just 
the dam and reservoir area. 

The Salt Lake City alternate pipeline route crosses Rock Creek in Duchesne 
County, which is also included on the final list of the Nationwide Rivers 
Inventory. We recommend that enforceable mitigation measures be adopted If 
this alternative is selected as part of the Magic Circle project. 

Historic/Cultural Resources 

The Salt Lake City alternate pipeline route also passes through Emigration 
Canyon, which has been registered as a National Historic Landmark In addition 
to its listing on the National Register of Historic Places. National Historic 
Landmarks have been designated as illustrative of significant events In the 
history of the United States, and as such should be preserved in their natural 
state to the greatest extent possible. The EIS should also recognize that 
Emigration Canyon is part of the Mormon Pioneer National Historic Trail. 
Installation of pipeline in the canyon should be in accord with the approved 
comprehensive plan for the trail (dated 9/81) which was approved and forwarded 




by the Secretary to the Congress In March 1982. We encourage project sponsors 
to take steps necessary to minimize visual and other Impacts to the historical 
integrity of Emigration Canyon. 

The DEIS indicates that cultural resource surveys have been carried out on 
portions of project sites, but that surveys have not been completed for all of 
the project lands. Such surveys should be completed prior to ground-disturbing 
activities, and preferably In time to be included In project planning prior to 
final approval. We recommend that the final EIS Include the results of cultural 
resource surveys and show evidence of consultation with the Utah State Historic 
Preservation Officer (page SS-A-6). 

We appreciate the opportunity to comment on the draft EIS. If you have any 
questions, or if we can be of further assistance, please contact Cecil Lewis 
of my staff at FTS 234-3067 or Mary Ann Crasser of the Air Quality Division at 
FTS 234-6419. 

c£a- 1- 

/ / (^l^C^>^n^^X^-^' 

L. Lorraine Mintzmyer 
Regional Director 




U.S. National Park Service, Rocky Mountain Region 

27.1 The analysis in the EIS determined that adequate mitigation would be 
available to allow all of the projects to proceed without doing 
serious damage to water quality, cultural, recreation and 
socioeconomic values. Proper stipulations and agreements must be 
included in the permitting process to assure that these safeguards 
are taken. This would be the responsibility of the various federal, 
state, and local agencies responsible for issuing the various 

The EIS does acknowledge that the potential exists for exceedances of 
the PSD increments and violations of the NAAQS. To state that the 
potential exists does not imply that violations cannot be avoided if 
the projects are developed. The possible exceedances include: (1) 
violations of Class II incremental limitations and NAAQS for 
particulates due primarily to emissions from unpaved roads, and (2) 
possible violations of- Class I SC7 limitations at Colorado portions 
of Dinosaur National Monument. 

Violations of particulate standards could be avoided by paving or 
chemical stabilization of unpaved roads that have significant traffic 
volumes. The potential violations of Class I SO? increments at 
Flat Tops occur only when considering high-level oil shale 
development in Colorado and Utah. The Colorado development scenario 
has the potential to violate the Class I increment without any Utah 
development considered. The Utah sources contribute only about 10 
percent of the total impact, the other 90 percent coming from 
Colorado sources. PSD increment use is currently allocated on a 
first come, first served basis. It is up to each company applying 
for a PSD permit to demonstrate it will not cause or add to an 
exceedance of the increments. Additional SO? control over what is 
assumed in the analysis may be possible and could reduce the 
potential for violating the SO2 PSD increments at Flat Tops. 

Although Colorado Category I limitations are enforceable in Colorado, 
it is presently unclear if sources located in Utah and permitted by 
the State of Utah are required to meet this provision of Colorado 
State law. This issue is being considered by the Governors of 
Colorado and Utah and has yet to be resolved. Utah sources must 
comply with PSD Class II SO2 increments in Colorado for which no 
violations were predicted. Additional SO2 control over what is 
assumed in the analysis could possibly prevent the Colorado Category 
I limitations from being exceeded at Dinosaur. 

27.2 It is unclear how legislative and regulatory mandates have been 
neglected. The Draft EIS addresses the following National Park 
Service legal mandates: (a) identifies various rivers as possible 
candidates for study for inclusion into the Wild and Scenic Rivers 
System; (b) identifies formal studies completed for the Colorado, 
Yampa, and White Rivers; (c) identifies the Dominguez-Escalante Trail 
under the National Trail System; (d) identifies potential problems 
with increased visitation to the Dinosaur and Colorado National 
Monuments and to Arches National Park; and (e) discusses potential 
National Park Service wilderness units. 

27.3 Potential impacts to the Dinosaur and Colorado National Monuments and 
Arches National Park related to increased visitation upon park 
values are discussed in Section R-4.A.9. 

Based on coordinated efforts with the National Park Service, DSC 
Office of Statistics, linear projections for park visitation were 
only available up to 1983. Under the worst-case scenario (all 
proposed projects proceed as planned) and prediction that visitation 
to the three National Park Service units within the secondary zone of 
influence would increase, recreation revenues (park entry fees and 
users fees) due to the project-related population growth in the 
region could increase substantially. It is the responsibility of the 
National Park Service to attempt to quantify this projected revenue 
increase, particularly in terms of future appropriations for these 
Park Service units, and update its linear projections beyond 1983 as 
well as incorporating the effects of new energy development growth 
within the Uintah Basin upon the National Park Service. 

27.4 When assessing the impacts of each site-specific project, the 
statements are correct that most impacts would not be long-term and 
significant. However, the point raised about the discrepancy in 
impact analyses between Syntana-Utah's project and Magic Circle's 
project upon municipal recreation facilities is valid. Text 
revisions have been made in Section M-4.A.8 so the Magic Circle 
impact analysis conforms with the other site-specific analyses with 
similar project-related population growth. 

27.5 One of the questions that has been of concern is what does the word 
"adequate" recreational facilities mean. The project sponsors are 
reluctant to define this word for various reasons including financial 
commitments and need for direction from local municipalities. 

Additionally, local municipalities are reluctant to commit to 
anything until they are certain that synfuels development will 
actually occur in the Uintah Basin and affect their communities. 
Therefore, the EIS includes only uncommitted mitigation measures for 
recreation and wilderness impacts (refer to Appendix A-7). 
Concerning possible mitigation for Dinosaur National Park, refer to 
Appendix A-7, Measure 1 under Wilderness and Measure 2 under 

27.6 Revisions concerning the proposed wilderness status for the Dinosaur 
National Monument and references to the Dominguez-Escalante Trail 
have been updated in Section R-4.A.8 of for the Final EIS. 
Concerning potential adverse affects upon river rafting opportunities 
through Cataract Canyon in Canyonlands National Park, the water model 
predicts no noticeable reduction in flow this far downstream; - 
therefore, no effects upon river running opportunities would occur. 





27.7 Anticipating the issues to be addressed in air quality, the limited 
meteorological data base and emission source term data from a new 
industry, and the need to push the state-of-the-art in regional scale 
modeling, BLM attempted to develop the air quality analysis with as 
much coordination between responsible state and federal agencies as 
possible. An informal air quality technical advising committee was 
established to provide a forum for discussion of issues, concerns, 
and analysis results. The NPS was asked to participate in the 
committee along with the U.S. Forest Service, EPA, lite Indian Tribe, 
and the Utah and Colorado State Air Quality Bureaus. This effort 
began with the development of the analysis of the scope of work and 
involved selection of the contractor to develop the analysis, and 
review and comment on the analysis results. This did indeed involve 
a number of meetings, phone calls, and considerable effort on the 
part of the committee participants (including the NPS). BLM 
attempted to be responsive to all comments throughout this process. 
It must be recognized, however, that all concerns could not be fully 
resolved to everyone's satisfaction. Ultimately, BLM had to make 
what were felt to be supportable decisions and proceed with the 

27. 8 Additional RTM runs have been performed and have been included in the 
Air Quality Technical Report (see response to Comment 20.14). BLM 
accepts the fact that the commenter does not recognize GPM as 
conservative and RTM as more realistic; however, the rationale for 
BLM's judgment that GPM is conservative is discussed in detail in 
Section of the Air Quality Technical Report. 

27.9 Because different models, meteorological conditions, and somewhat 
different emission sources and geographic regions were used for the 
two EIS studies, one could not expect identical results. BLM is in 
the process of comparing the two analyses. It should be noted that 
in the Final Prototype EIS, the air quality analysis has been refined 
by using more realistic meteorologic conditions and minor model 
refinements to more appropriately treat stagnated wind field effects 
on pollutant concentrations. 

27.10 Section E-4.A.8 has been revised to clarify that only 13.5 miles of 
the 68-mile segment of the White River identified in the final list 
of the Nationwide Rivers Inventory would be eliminated from further 
consideration as a potential Wild and Scenic River. 

27.11 Impacts of the White River Dam Project are assessed in another EIS 
(BLM 1982b). Rather than repeat information, this EIS refers the 
reader to the White River, Dam EIS for impacts due to that project. 

The impacts of project components located across or near the White 
River are discussed in the site-specific analysis of the project in 
question. The combined effects of all the applicants' proposed 
projects and other interrelated projects are discussed in the 
Nine-Proiect Cumulative Analysis (Draft EIS Regional Cumulative 
Analysis). The cumulative impacts of the nine projects upon future 
consideration of the White and Green rivers as National Wild and 
Scenic Rivers are discussed in Section R-4.A.8. 

27.12 The point where the Salt Lake City Alternative Product Pipeline 
crosses Rock Creek (Milepost 68, Map T-l-2) is not part of the 23- 
mile segment from the Ashley National Forest boundary to its source 
identified on the final list of the Nationwide Rivers Inventory. 
Therefore, no enforceable mitigation measures can be applied to Rock 
Creek based on its final list status. 

27.13 The National Historic Landmark status of Emigration Canyon has been 
clarified in Section T-3.H.9. 

Emigration Canyon's status as part of the Mormon Pioneer National 
Historic Trail is specifically discussed in Section T-3.H.8. 

27.14 Results of all project-related cultural resource surveys completed to 
date have been included in the EIS. As required by law, surveys 
would be completed prior to ground-disturbing activities. The BLM 
Vernal District Office has assumed full responsibility for the on- 
going consultation with the State Historic Preservation Officer 
Advisory Council (BLM 1981h). 








Richard D. Lamm 

Frank A. Traylor. M.D. 
Executive Director 


To: Bi 1 1 Wagner 

Bureau of Land Managment 

From: John Ploi/Alan Dresser 

Air Pollution Control Division 

Subject: Comments: Uintah Basin Synfuels Development Report 

Date: October 19, 1982 

1, Draft Environmental Impact Statement August 1982 

2. Draft Technical Report: Air Quality August 1982 

In the development of the emission inventory for the various study sources 
in Utah and Colorado, it is not clear from review of Table k-% in the Air 
Quality report if TSP emissions included fugitive emissions from ongoing 
mining and material handling activities. In general, neither document 
provides a break out of the various TSP emission sources; stack and fugitive 
emissions from construction-operational activities to make a determination 
if all emission sources were accounted for. It was also not possible to' 
compare the inventories used with other inventories available except on a 
total or summation basis. 

In this case emission rates are significantly 
different than those used in the Prototype Oil shale leases DEIS reviewed 
earl ier thi s year. 

Two significant sources in the study area in Colorado were omitted from the 
cummulative impact study; namely, Hack-Ute Power Plant and Southern Colorado 
Power Plant in Mesa County. It is also noted that two sources. Cathedral 
Bluffs and Superior in Colorado, S02 emissions used are in excess of the 
Colorado standard of 0.3 lb S02 per barrel of oil produced. 

The section on Site Specific Analysis in the DEIS reported significantly 
different emissions from some criteria pollutants than was used in the 
Air Quality report for Magic Circle, Paraho Ute, Geokinetics and Sohio. 
Minor differences were noted for some of the other sources. We feel the 
inventories used should be the same in both documents or the differences 

4210 EAST 11TH AVENUE DENVER.COLORADO 80220 PHONE (303) 320-8333 


28.7 j 

28.8 I 





Memorandum - Bill 
October 19, 1982 
Page 2 


The Air Quality report included Enercor PR Springs, but not Enercor 
Rainbow site, even though both sites were addressed extensively in the 
DEIS. Is there any reason for this omission? 

It was also noted that particulate emissions were not separated 
respirable and non-respi rabl e fractions. 

n the 

P. 2-k How were the upper air winds measured at Denver, Grand Junction, 
Salt Lake City, and Lander averaged? I assume the Grand Junction measure- 
ments carried more weight than the others. 

P. 2-7 How was the wind data at 150 m, 300m, 500m, and 1000m derived at 
the White River Oil Shale Project, Cathedral Bluffs, and Craig? 

P. 2-10 How was the stability at 500m determined at the above sites? 

P. V(>0 The report states for both Colorado and Utah facilities, the data 
collected at the site closest to the facility (C-a, C-b, U-a , or U-b) was 
used. If the closest monitoring site was in a significantly different 
terrain setting the sites whose terrain settings were most representative 
of that of the facilities were used. Were wind directions adjusted to 
reflect the valley orientation (and therefore drainage and up-valley 
flow) of the site being modeled? 

h-10 It would seem the upper air winds at 6000 feet above ground-level 
have too great of i nf 1 uence on the gr i dded wind field. Using winds at a 
lower level, closer to the effective plume height of emissions, might 
better represent the transport of pollutants. In many cases there will be 
some horizontal wind shear with height. 

P. 5-103, P. 5-1 10 The TSP impacts at Dinosaur National Monument are three 
times higher than those of SO2 , yet according to pages *i-9 and k-\2 SO2 
emissions are greater than particulate emissions. At this distance 
effective plume heights shouldn't have a great effect. Why the discrepancy? 

Chapter 6. It would have been helpful if the tables summarizing the PSD 
increment consumption by the 5 proposed oil shale facilities included a 
column giving the Class 2 increment consumption at receptors of maximum 
i mpact in Colorado. 

We look forward to reviewing the three additional RTM model runs which will 
provide additional information on "worst case" impacts at Flat Tops Wilderness 
Area and Dinosaur National Monument. Without these analyses it is impossible 
to comment further. 




Colorado Department of Health 

28.1 Table 4-8 is applicable to Utah area sources and excludes sources 
engaged in mining and material handling activities. No significant 
point sources for mining and material handling activities were 
located in Utah. PEDCo, however, included existing point source 
fugitive dust emissions from mining and material handling in the 
Colorado portion of the study region. 

Emission rates are different from those used in the Prototype Oil 
Shale EIS (and other reports) as a result of the evolving state of 
the oil shale industry's plans for development and changes in 
proposed processes. As a result, the two studies used different 
assumed production levels and proposed project development 
scenarios. There were also incorrect values in the summation table 
(Table 1-5) which have been corrected in the Final Air Quality 
Technical Report and the Final EIS. The values appearing in final 
documents were the emission source terms used in the modeling 
analys is. 

BLH air quality specialists in Colorado and Utah are in the process 
of comparing the two studies. 

28.2 It is BLM's understanding that the Colordo-Ute proposal for its South- 
West Project was for a 500-MW power plant with a preferred site at 
Hack, Colorado and an alternative site near Delta, Colorado. The 
Delta alternative site has been called both the Southern and 
Southwest power plant site. It is also BLM's understanding that 
Colorado-Ute has withdrawn from the project and has put the entire 
project on indefinite status, so the viability of a power plant at 
either site appears questionable at the present time. 

The emission source terms used for the Superior and Cathedral Bluffs 
facilities were approximately 0.55 and 0.48 lbs. per barrel, 
respectively, which was the best information available to PEDCo at 
the time their study began. To the best of our knowledge, PEDCo 
considered both of these facilities as retorting (Colorado limitation 
0.3 lbs/bbl)only, rather than retorting plus upgrading (Colorado 
limitation 0.3 + 0.3 equaling 0.6 lbs SO? per barrel). If the 
SOj emission estimates developed by PEDCo for Cathedral Bluffs and 
Superior in Colorado were found to violate Colorado SOg emission 
limits during permit reviews, then charges to each source would be 
necessary before the sources could be permitted. Using the PEDCo 
emission factors, the existing analysis is on the conservatively high 
side, and impacts would be reduced in relation to the differences in 
the assumed emissions in the EIS study and those actually permitted 
as a result of the regulatory process. 

28.3 The emission rates in Tables H-l-5 and P-l-6 for Magic Circle and 
Paraho are different than the rates given in the Air Quality 
Technical Report, because they were revised by the applicants too 
late to be considered in the air quality analysis. (See responses to 
Comments 16.35 and 30.27.) 





The Sohio emissions in Appendix A-3 are different from those given in 
the Air quality Technical Report only for particulate matter. The 
Air quality Technical Report used a revised number, and the Final EIS 
includes this revised particulate emission rate. 

The emission rates for Geokinetics are consistent. The EIS divides 
the emissions between the Agency Draw and Lofreco projects. The 
emissions in the Air Quality Technical Report are the combined 
emission rates. 

As explained in Section 4.1.1, the Air Quality Technical Report 
includes emissions from both the P.R. Springs and Rainbow sites. 

It is true that particulate emis 
respirable and non-respirable fr 
standards and incremental limita 
non-respirable) suspended partic 
non-respirable particulates may 
considering a standard for respi 
likely that additional health re 
by estimating impacts separately 
degree of uncertaintly would exi 
of non-respirable and respirable 
of particle size distributions. 

sions are not separated into 
actions. Current particulate 
tions are for total (respirable and 
ulates. Because respirable and 
have different health effects, EPA is 
rable particulates only. It is 
lated information could be obtained 

It is also noted that a high 
st in any estimate of the fractions 
particulates due to the uncertainty 

An unweighted vector-averaging procedure was used in the "composite" 

Wind data were determined from pilot (weather) balloon (pibal) or 
radar wind sounding (rawinsonde) measurements. 

Stability was determined from temperature gradient information and 
was classified by stability category using the Nuclear Regulatory 
Commission Regulatory Guide 1.23 criteria. 

If a facility is located in a valley oriented differently than the 
closest monitoring station, then the next closest monitoring station 
not located in a valley was used. 

The shear wind height is accounted for automatically within the 
model . 

28.11 It is not clear why the commenter feels that effective plume heights 
should not have a great effect at Dinosaur National Monument. BLM 
believes the higher TSP impacts are due to differences in emission 
density distributions and effective plume heights. 

28.12 This proposed addition to tables in Section 6 of the Air Quality 
Technical Report has been made. 




Utah Power & Light Company 


P. O. BOX 880 


801 636-4281 


October 20, 1982 

Mr. Lloyd Ferguson 
District Manager 
Bureau of Land Management 
170 South 500 East 

Vernal, Utah 84078 

Dear Mr. Ferguson: 

Utah Power & Light Company ("Utah Power" or "Company") is 
in receipt of that certain Draft Environmental Impact Statement 
("EIS") for the Uintah Basin Synfuels Development dated August, 
1982, and prepared by the Bureau of Land Management ("BLM"). We 
note in reviewing the same that the proposed power source for 
several of the projects is Deseret Generation & Transmission 
Co-Operative's ("DG&T") Bonanza Power Plant located in Uintah 
County, Utah. We take this opportunity to notify you that in 
our judgment DG&T nay not lawfully serve the Enercor, 
Enercor-Mono Power, Magic Circle, Tosco or Geokinetics projects 
("subject projects") for the following reasons: 

1. Utah Power has a franchise 
Certificate of Convenience and Necess 
Public Service Commission of Utah ("C 
Company to serve all of Uintah County 
Commission Certificate No. 1755 which 
Electric Association ("Moon Lake") th 
exclusively the electrical requiremen 
the attached Exhibit "A" and jointly 
electrical requirements in the area d 
Exhibit "B." Included within the exc 
Lake described in Exhibit "A" are the 
Paraho Projects . None of the propose 
within the joint service area of Utah 
Inasmuch as DG&T is neither franchise 
area in which the subject projects ar 

from Uintah County and 
ity No. 6492 from the 
ommission" ) authorizing the 

except as limited by 

grants to Moon Lake 
e right to serve 
ts in the area described in 

erve with Utah Power the 
escribed in the attached 
lusive service area of Moon 

proposed Syntana and 
d projects appear to be 

Power and Moon Lake, 
d nor certificated in the 
e located , rendering 

Mr. Lloyd Ferguson 
Page Two 
October 20, 1982 


electric service to them as specified in the EIS would be 
without right and contrary to law. 

2. Additionally, the Comm 
in Case No. 81-506-01 regarding 
the construction and operation o 
interfere with other existing ce 
the State of Utah and based upon 
construction and operation of th 
aforementioned projects from the 
direct conflict with the terms o 
would be in competition and inte 
certificated service territory o 

ission, in its Report and Order 
the Bonanza Plant , found that 
f the plant would not compete or 
rtificated public utilities in 

that finding , authorized 
e plant . Serving the 

Bonanza Plant would be in 
f the Order because such service 
rfere with the existing 
f Utah Power. 

Based on the above, Utah Power submits that DG&T may not 
lawfully serve the electrical needs of the subject projects and, 
accordingly, the EIS does not accurately represent the impact 
that may occur to the subject Federal lands insofar as power 
supply for the five aforementioned projects is concerned. 

If you desire further information regarding this matter or 
wish to discuss the same , please so advise . 

Very truly yours, 


cc: Roland G. Robison 
Merrill J. Millett 



Beginning at the Northeast corner of Township 3 North, Range 25 East, SLBM, 
beii.g the common boundary point between Utah, Wyoming, and Colorado, thence 
West along the Utah-Wyoming boundary to the Northwest corner of Township 3 
Kcrth, Range 24 East SLBM, thence South along the West line of Range 24 East to 
the Northeast corner of Section 12, Township 2 North, Range 23 East, SLBM; thence 
West along the North line of Sections 12,11,10,9,8,7, to the Northwest Corner of 
Section 7, Township 2 North Range 23 East; thence South along the West line of 
Section 7 to the Southwest corner of said Section 7, Township 2 North , Range 23 
East, SLBM; thence West along the South line of Section 12, 11, 10 of Township 
2 North, Range 22 East, SLBM, to the intersection of said line with the Green 
River in said Section 10; thence in a general Westerly direction along said Green 
River to the intersection of the Green River with the West line of Range 21 East, 
Township 2 North, SLBM, said point being further described as approximately the 
Southeast corner of the Northeast 1/4 of Section 24, -Township 2 North, Range 20 
East; thence South along the West line of Range 21 East in Township 2 North end 
Township 1 North to the intersection of said West Range line with the Boundary line 
between Daggett and Uintah Counties; thence Easterly along the Daggett-Uintah 
County line to the intersection of said county line with the North line of Township 
1 South, Range 22 East, SLBM, said point being furthei described as approximately 
the Northwest corner of the Northeast 1/4 Northwest 1/4 Northeast 1/4, Section 4, 
Township 1 South, Range 22 East, SLBM; thence East along the South line of 
Township 1 North across Ranges 22 E, 23E, 24 E, and 25 E, SLBM to the Utah- 
Colorado Boundary; thence North along the Utah-Colorado Boundary to the point of 

Also, beginning at the Northeast corner of Township 9 South, Range 25 East, 
SLBM and running thence West along the North line of Township 9 South of Ranges 
25 East and 24 East, SLBM, to the Northwest corner of Township 9 South, Range 

24 East, SLBM; thence South along the We£t line of Range 24 East, SLBM of Township 
9 South, 10 South, 11 South, and 12 South to the Southwest Corner of Tcwnship 12 
South, Range 24 East, SLBM; thence East along the South line of Township 12 South 
of Range 24 East and 25 East to the Southeast corner of Township 12 South, Range 

25 East, SLBM; thence North along the Utah-Colorado Border to the point of 

Also, beginning at the Northeast corner. Township 5 South, Range 23 East, 
SLBM, running thence South along the East line of Range 23 East, Township 5 South, 
and Township 6 South, to the Southeast corner. Township 6 South, Range 23 East, 
SLBM; thence East along the North line of Township 7 South, Range 24 East to the 
Northeast corner of Section 2, Township 7 South, Range 24 East, SLBM; thence South 
along the East line of Section 2, 11, 14, 23, '26, 35, to the Southeast corner Section 
35, Township 7 South, Range 24 East, SLBM; thence West along the South line of 
Section 35 and 34, Township 7 South, Range 24 East, to the Northeast corner. 
Section 4, Township B South, Range 24 East, SLEM,' thence South along the East 
line oi" Section 4, 9, and 16 to the Southeast corner Section 16, Township 8 South, 
Range 24 East, SLBM; thence West along the South line cf Section 16, 17 and 18, 
to the SouthweS'tcorner Section 18, Township 6 South, Range 24 East, SLBM; thence 

South along the Easi line of Section 24, Township 8 South, Range 23 East, SLBM 
-co the Southeast corner of said section; thence West along the South line of Section 
2-1, 23, 22, 21, 20, and 19, Townships South, Range 23 East and Section 24, 23, 
22, 21, 20 and 19 , Township 8 South, Range 22 East , SLBM; thence South along 
f he East line of Section 25 and 36, Township 8 South, Range 21 East, and continuing 
South until said line intersects with the White River being in the Northeast corner 
of Township 9 South, Range 21 East; thence Westerly along the White River across 
Township 9 South, Range 21 East, SLBM to a point where the White River intersects 
the East line of Township 9 South, Range 20 East being in the Northwest corner of 
Township 9 South, Range 21 East; thence South along the East line of Range 20 East, 
Township 9 South and Township 10 South to the Southeast corner of Section 13, 
Township 10 South, Range 20 East, SLBM; thence West along the Sou^h line of 
Section 13, 14, 15, 16, 17 and 18 to the Southwest corner Section 18, Township 
10 South, Range 20 East SLBM; thence North along the West line of Range 20 East, 
Township 10 South, and Township 9 South to a point approximately the Southwest 
corner Section 18, Township 9 South, Range 20 East, SLBM; thence in a Northwesterly 
direction along what is commonly known as the Pariette Draw, being in Township 
9 South, Range 19 East SLBM, to a point where said Pariette Draw intersects the 
South line of Township 8 South, Range 18 East, SLBM, said point being approximately 
Southwest corner, Section 36, Township 8 South, Range lSEast, SLBM; thence West 
along South line of Township 8 South, Range 18 East SLBM, and Township 8 South, 
Range 17 East, SLBM to the Southwest corner Township 8 South, Range 17 East, 
SLBM; thence North along West line of Township 8 South, Range 17 East, SLBM to 
the Northwest corner. Section 19, Township 8 South, Range 17 East, SLBM; thence 
Easterly to the Southeast corner Section 19, Township 4 South, Range 1 West, USM; 
thence North along the West line of Township 4 South, Range 1 West, USM to the 
Northwest corner of Township 4 South, Range 1 West, USM; thence West along the 
South line of Township 3 South, Range 2 West, and Township 3 South, Range 3 West, 
USM to the Southwest corner Township 3 South, Range 3 West, USM; thence North 
along the West line of Township 3 South, Range 3 West to the Northwest corner, 
Township 3 South, Range 3 West, USM; thence West along the South line of Township 
2 South, Range 4 West, USM and Township 2 South, Range 5 West, USM to the SW 
corner. Township 2 South, Range 5 West, USM; thence North along the West line of 
Range 5 W, Townships 2 South, 1 South, 1 North, 2 North, 3 North and 4 North to a 
point where said line intersects the Duchesne County line; thence Easterly along the 
Duchesne County line to a point wherr said line intersects the Uintah County line, 
said point being in Township 5 North, Range 1 West, USM; thence South along the 
Duchesne-Uintah County line to a point where said line intersects with the South line 
of Township 4 North, Range 1 West, USM; thence East along the North line of 
Township 3 North, Range 1 West, USM to the Northeast corner of said Township 3 
North, Range 1 West, USM; thence in a Southeasterly direction to the Northwest 
corner of Township 3 South, Range 19 East, SLBM; thence East along the North line 
of said Township to the Northeast corner, Township 3 South, Range 19 East, SLBM; 
thence South along the East line of Range 19 East of Township 3 South, Township 
4 South, Township 5 South, to the Southeast corner Township 5 South, Range 19 East. 
SLBM; thence East along the South line of Township 5 South, Ranges 20 East, 21 East 
and 22 East to the Southwest corner. Section 34, Township 5 South, Range 22 East, 
SLBM; thence North along the West line of Section 34, 27, 22, 15, 10 and 3, 
Township 5 South, Range 22 East to the Northwest corner. Section 3, Township 5 
South, Range 22 East, SLBM; thence East along the North line of Township 5 South, 
Range 22 Lost and 23 East to the Northeast Corner Township 5 South, Range 23 East, 
SLBM the point of beginning. 






Beginning at the Northeast Corner Township 1 South, Range 25 East, SLBM , 
which point is common to the Utah-Colorado Boundary, thence West along the 
North Boundary of Township 1 South, to a point where the said line intersects the 
Daggett-Uintah County line; said point being further described as being approximately 
the Northwest Corner NE 1/4 NW 1/4 NE 1/4, Section 4, Township 1 South, Range 

22 East, SLBM; thence in a Westerly direction along the Daggett-Uintah County line 
to a point where said boundary line intersects the center line of Township 1 North, 
Range 21 East. SLBM; thence South to the SW corner. Section 34, Township 1 South, 
Range 21 East, SLBM; thence East to the Northwest Corner Section 3, Township 2 
South, Range 22 East, SLBM; thence South to the SW Corner Section 34, Township 

4 South, Range 22 East, SLBM; thence East to the Northeast Corner Township 5 South, 
Range 23 East, SLBM; thence South to the Southeast Corner, Township 6 South, Ra.nge 

23 East, SLBM; thence East to the Northeast Corner Section 2, Township 7 South, 
Range 24 East, SLBM; thence South to the Southeast Corner Section 35, Township 
7 South, R^nge 24 East, SLBM; thence West to the Northeast corner Section 4, 
Township 8 South. Range 24 East, SLBM; thence South to the Southeast Corner 
Section 16, Township 8 South, Range 24 East, SLBM; thence West to the Southwest 
Corner Section 18, Township 8 South, Range 24 East, SLBM; thence South to the 
Southwest Corner Township 8 South, Range 24 East, SLBM; thence East to the 
Southeast corner Township 8 South, Range 25 East, SLBM; thence North along the 
Utah-Colorado Boundary to the point of beginning. 

Also; Beginning at the Northwest Corner Township 3 South, Range 5 West.USM; 
running thence East to the Northeast Corner Township 3 South, Range -4 West, USM; 
thence South to the Southeast Corner Township 3 South, Range 4 West, USM; thence 
East to the Northeast Corner Township 4 South, Range 2 West. USM; thence South 
to the Southeast Corner Section 24, Township 4 South. Range 2 West, USM; thence 
Westerly to the Northeast Corner Section 24, Township 8 South, Range 16 East, 
SLBM; thence South to the Southeast Corner, Township 8 South, Range 16 East, SLBM; 
thence West to the Southwest Corner Township 8 South, Range 16 East, SLBM; thence 
North to the Northwest Corner Section 31, Township 8 South, Range 16 East, SLBM; 
thence Westerly to the Southeast Corner Section 34, Township 4 South. Range 3 West 
USM; thence West along the South line of Township 4 South to a point where said 
line intersects the Wasatch-Utah County boundary being in Section 33, Township 4 
South, Range 12 West, USM; thence Northerly along the Wasatch-Utah County 
boundary to a point where said boundary intersects the North line of Township 3 South 
being in Section 6, Township 3 South, Range 12 West, USM; thence East to the 
Southwest Corner Section 33, Township 2 South, Range 12 West, USM; thence North 
to the Northwest Corner Section 4, Township 2 South, Range 12 West, USM; thence 
East to the Southwest Corner Section 34, Township 1 South, Range 11 West, USM. 
thence North to the Northwest Corner Section 3, Township 1 South, Range 11 West, 
USM; thence East to the Southwest corner. Township 1 North, Range 9 West, USM; 
thence North to the Northwest Corner Section 7, Township 1 North, Range 9 West, 
USM; thence East to the Northeast Corner Section 8, Township 1 North, Ranee 9 West, 
USM; thence North to the Northwest Corner Section 4, Township 1 North, Range 9 West, 
USM; thence East to the Northeast Corner Section 4; Township 1 North, Range 9 West, 

USM, being the common boundary point between Wasatch and Duchesne Counties: 
whence North along said county boundary to the Northwest Corner Section 3, Township 
2 North, Range 9 West, USM: thence East to the Northeast Corner Town ship 2 North, 
Range 8 West, USM; thence North along the East range line of Range 8 to a point 
where said line intersects the Duchesne County-Summit County line; thence Easterly 
along said boundary line to a point where said boundary intersects the East range 
line of Range 6 West in Township 4 North; thence South along said East line of 
Range 6 West to the Northwest Corner Township 3 South, Range 5 West, USM the 
point of beginning. 


Utah Power and Light Company 

29.1 The matter of service area jurisdiction apparently is subject to 

further discussion and debate between Utah Power and Light Company, 
Moon Lake Electric Association, and the appropriate regulatory 
officials. The comment provides pertinent information from Utah 
Power and Light Company. Also, BLH has been advised that on October 
2, 1981, Moon Lake Electric Association filed with the Utah Public 
Service Commission an application to place much of the territory in 
question Into Moon Lake's designated service area. Moon Lake 
Electric Association filed the application for a number of reasons, 
not the least important of which 1s the physical location of the 
Bonanza Power Plant and the proximity of Moon Lake's facilities to 
the area. 

The power sources listed in the E1S for each project are based on 
project descriptions furnished by the project sponsors. BLM has not 
revised that Information for the Final EIS; however, it is 
anticipated that project sponsors may need to revise their power 
source plans in the future, depending on the outcome of further 
regulatory discussions regarding service area jurisdiction. 
Supplementary environmental assessment may be needed at that time if 
any such changes necessitate new right-of-way alternatives. 


H] environmental defense 


October IB, 1982 

Lloyd Feguson 

Bureau of Land Management 

Utah State Office 

136 East South Temple 

Salt Lake City, DT 84111 

Dear Mr. Ferguson: 

Enclosed please fir.d a copy of our comments concerning the 
Draft Environmental Impact Statement of the UintahBasxr.^ynfuels 

comments are being 

and Friends of the Earth. 

acerely , 

REY : Ob 

Sober t E . Y u</nke 
Regional Counsel 


.(!&■'*' J /4's''-- 

Richard Hughes 
Legal Intern 

R.J. Gollen (NWF) 
K. Markey (FOE) 


. , „ , „ . Boulder. Colore 80332 « "03I 440-4901 

i^SSS NY m~* H=ad=u» r ,„ t VMSH.NGTOS. DC. B.HKELBr. C* ^-^a M BOOKER CO 


Environmental Defense Fund 

National Wildlife Federation 

Friends Of Earth 

Re: Uintah Basin EIS 

Submitted by: 

Robert E. Yuhnke 
Regional Counsel 

Richard Hughes 
Legal Intern 

October 18, 1982 


1. Introduction 

2. Executive Summary 

3 . The EIS fails to provide a proper alternatives analysis 

4. The EIS fails to provide a discussion of data sufficient to 

understand the alternatives or the impact analysis 

4.1 The EIS fails to provide a sufficient description of 

the existing environment . 

4.1.1 The data reported are unintelligible and 

unreliable . 

4. 1 .2 The methodology used to arrive at the reported 

data is not specified. 
4.1.3. Certain data, necessary to an understanding of 

the environment and the impacts are not provided . 

4.2 The EIS fails to provide a meaningful, reliable 

description of the current and projected emissions. 
4.2.1 The methodology used to arrive at the reported 

data is not specified. 
4-2-2 There is a failure to insure the scientific 

integrity of the emissions data. 
4.2.3- The emissions data used are i neons is tant with 

a worst case analysis. 
4-2.4 Certain data, necessary to an understanding of 
the emissions, are not provided. 

5. The EIS fails to provide sufficient description of, support 

for or insurance of scientific integrity of the computer modeling 


5.1 The EIS fails to conduct mandated worst-case studies. 
5.1-1 The "worst case" analyses are not pollutant 
specific . 

5.1.2 The "worst case" analyses are based on 
insufficient data . 

5.1.3 The "worst case" ana lyses make improper 
assumptions . The "worst case" visibility model makes 

assumptions about viewer orientation, time 
of observation and stability that are 
incompatable with a worst case analysis . 
5.1-3.2 The "worst case" ozone analysis make 

assumptions about background concentra- 
tions and trajectories which are incom- 
patable with a worst case analysis . 
5.2 The EIS fails to insure the scientific integrity of the 
modeling used. 

5.2.1 The EIS fails to provide a sufficient descrip- 
tion of the methodologies used. 
5.2.1-1 The emission consolidation method- 
ology is insufficiently described . 
5.2-1.2 The wind field randomization is 
insufficiently described. GPM mass loss and residual concen- 
tration methodologies are 
insufficiently described. EKMA upper level concentrations are 

insufficiently described. 
5.2.2 The EIS fails to provide insurance of scien- 
tific integrity by using methods contrary to 
current scientific understanding. Non- linear impacts are additive ly 

combined . Long-range impacts are not included in 
the modeling domain - The tiered used of CTWM, GPM and RTM 
leads to synergistic error and may 
involve incompatability . 

5-2.2.4 Comparisons are made between model 

predictions, rather than between pre- 
dictions and observations. 
5-2-3 The EIS fails to provide support for conclusions 
reached and methods used- 

5.2-3.1 There is insufficient support for the 
method of determining upper and lower 
bounds for concentrations . 
5-2.3.2 Conclusions reached concerning comparability of ir 
are unsupported and contradicted by 
the data reported in the EIS. 
5.3 The EIS fails to provide an insurance of the scientific 
integrity of the CTWM model. 

5.3.1 Characterization of regional wind direction was 
inaccurate . 

5.3.2 Temporal interpolation of regional wind 

direction yielded unrepresentative results - 
5-3.3 Characterization of the slope wind was inaccu- 
rate . 

5.3.4 Scaling and linear combination of windfields 
is mathematically unsound. 

5.3.5 "Verification" of CTWM is insufficient. 

5.3.6 To the index. 

5.3.6 Recommended Application of CTWM. 

5.4 Improper assumptions are made in the course of the 
modeling procedures . 

5.4.1 Fields known to vary spatially are assumed 
to be uniform. 

5.4.2 Acid deposition estimates rely on unfounded 
and unrealistic assumptions. 

5.4.3 Deposition notes fail to consider variation 
in preciitation rates. 

5.5 Models are used which are inappropriate for the appli- 
cation. (HC's) 

5.5.2 The EKMA Model is not properly applied in the 
oil shale region. 

6 . Summary 

7. Appendix A 









Int roduc t ion. 

Tha following comments are filed on the Draft Environmental 
Impact Statement for the Uintah Basin Synfuels Development on 
behalf of the Environmental Defense Fund (EDF) and its members. 
EDF is a charitable, non-profit, public membership organization, 
composed of scientists, lawyers, economists, educators and other 
concerned citizens dedicated to the protection and enhancement of 
human health and the environment through research and education 
and through judicial, legislative and administrative action. 
Organized under the laws of the State of New York, EDF maintains 
regional offices in Boulder, Colorado; Washington, D.C.; and 
Berkeley, California. EDF has 4R,B30 active members nationwide, 
of whom more than 1,000 reside in Colorado and Utah. 

The Draft Environmental Impact Statement for the Uintah 
Basin Synfuels Development, hereinafter called the Uintah DEIS, 
fails to meet the standards required by statute and regulation. 
The National Environmental Policy Act requires that the EIS 
provide information that is usefu l in restoring, maintaining and 
enhancing the quality of the environment.' 42 U.S.C.4332 (G). 
This EIS violates the usefulness requirement of the act. 

Federal regulations governing the preparation of EIS's re- 
quire that the statement "provide full and fair discussion of 
significant environmental impacts." 40 CFR 1592.1. Because of 
its failure to discuss several significant impacts, such as {1} 
the impact of secondary and hydrocarbon emissions on visibility 
and ozone formation, I?.} the impact of emissions on Class I areas 
and Colorado Category I areas other than the Flattops Wilderness 
Area, such as Dinosaur National Monument and Colorado National 
Monument, {3} the impact of emissions on hydrogen ion deposition 
{"acid rain"} in sensitive areas outside the so-called study 
area, and (4) tha impact of TSP emissions and secondary sulfates 
on the non-attainment area in Grand Junction the EIS cannot be 
considered a full discussion of significant impacts. Because of 
the one-sided nature of the discussion of model "conservatism" 
and the effect of model assumptions, the EIS cannot be considered 
a fair discussion. 

The regulations -specify the criterion by which the 
sufficiency of the discussion of the affected environment is to 
be judged. It must provide that information "necessary to under- 
stand the effects of the alternatives." 40 C.F.R. 1502.15. 
Because of a failure to provide more than a cursory, incomplete, 
unscientific, and, in some cases, unintelligible discussion of 
present regional air quality, current and projected emissions and 
projected impacts, the EIS does not provide information nacessary 
to an understanding of the alternatives. 

Nor does the DEIS offer an adequate set of alternatives. In 
terms of both national policy alternatives to expanded oil shale 
development and local siting alternatives which would result in 
significant differences in the air quality impacts of proposed 


(conl) | sou 



rces, reasonably available alternatives are not considered. 

Applicable federal regulations require that the "information 
must be of high quality. Accurate scientific ana 1 ysis. .. { is ) 
essential." 40 C.F.R. 1500-1. 

Agencies shall insure the professional integrity, including 
scientific integrity, of the discussion and analysis in 
environmental impact statements. They shall identify any 
methodologies used and shall make explicit reference by 
footnote to the scientific and other sources relied upon for 
conclusions in the statement. 

40 C.F.R. 1502. 24- 

These requirements are violated by the many instances of the 
failure to use sound scientific methods, to describe method- 
ology, to justify conclusions and to cite sources. 

2. Executive Summary 

The draft EIS for the Unitah Basin Synfuels Development does 
not comply with federal statutory and regulatory requirements. 
Its major deficiencies are: 

1. A failure to provide an adequate regional alternatives 

analysis . 

2. A failure to speci f y methodo logies or reconcile 

inconsistencies in the background air quality data and 
emissions data. 

3. A failure to provide important back round air quality 

data, and emissions data. 

4. Reliance on insufficient data and on improper 
assumptions when doing a worst case analysis. 

5. Failure to describe modeling methodologies sufficiently 
to allow a reviewer to understand and meaningfully 
comment on the analysis, 

6. The use of unscientific methods, improper assumptions 

and inappropriate models in the computer modeling of impacts . 

7 • One-sidedness in analysis of models results . 

The remainder of these comments will discuss these deficiencies 
in part icular . 

EDF requests that these deficiencies be remedied prior to 
release of a final EIS. Failure to corrct these deficiencies. 






we believe, will render the EIS record insufficient, as a matter 
of law, for the purpose of sustaining final agency action on the 
pending rights-of-way and other decisions which may be made in 
reliance on this EIS. 

3. The EIS fails to identify and analyze reasonably available 
alternatives . 

The alternatives identified for analysis in theDEIS are 
extremely limited and do not emcompass the scope of alternatives 
contemplated by NEPA. The deficiencies in the alternatives 
analysis are of two kinds: 1) the failure to consider alternate 
fuel sources as a substitute for oil shale development, and 2) 
the failure to consider the air quality impacts of alternate 
siting and technology options for projects not yet permitted or 
under construction, including the proposed C-ll and C-18 lease 
sites- The CEQ's NEPA regulations clearly outline the scope of 
the alternatives analysis. Together, 40 CFR SS 1502.14--16 
outline both the the types of comparisons to be made and the 
types of alternatives to be considered. 40 CFR S 1502.14 
requires that "agencies shall (a) rigorously explore and 
objectively evaluate all reasonable alternatives..." The 
alternatives and comparisons to be analyzed as identified in 40 
CFR S 1502.16 include, among others, 

(d) the environmental effects of alternatives..., 

(e) energy requirements and conservation potential of 

various alternatives and mitigation measures..., 

(f) natural or depletable resource requirements and 

conservation potential of various alternatives and 
mitigation measures; and 

(h) means to mitigate adverse environmental impacts... 

Taken together, EDF contends that significant alternatives 
are available and should be evaluated to compare the impacts of 
each alternative on 1) the environment, 2) energy resources 
consumed to produce the energy product and 3) the need for 
development of the resource given available conservation options. 
These alternatives wil 1 be addressed as "national policy 
alternatives," and "regional development alternatives." 

A. National Policy Alternatives. 

The Secretary of Interior has statutory contol over the 
leasing and development of all federal energy resources. His 
responsibi lities include the rate and geographic scope of 
leasing, on-shore and off-shore oil and gas leasing oil, shale 
and tar sands leasing. Each of these energy resources is subject 
to a separate statutory and regulatory scheme. But each will 
have significant impacts on the human environment, and each will 
contribute to the nation's total supply of liquid, gas and solid 


feels. Given the Secretary's control over the development of 
each of these resources, he is in a unique position to evaluate 
and compare the respective environmental impacts of each form of 
energy deve lopment, as we 11 as the energy costs and other 
economic impacts which will be associated with each form of 
energy development. 

Oil shale development will contribute mostly to the nation's 
supply of liquid fuels. The need for any additional oil shale 
development should be considered within the scope of the "no 
action" alternative. The current price of liquid fuels is 
largely the result of reduced wor Id wide demand. 1 / Reduced 
demand in the U.S. is, in part, a result of significant 
conservation in both the space-heating and transportation demand 
sectors. _2_/ Reduced domestic demand has continued the trend of 

lowered annual imports. 3_/ The reduced price has strongly 

influenced industry decisions to invest in synfuels projects, 
particularly oil shale.J / 

The directive in the CEQ regulations that conservation be 
treated as a reasonable alternative to the development of 
natural, depletable resources should be taken seriously by the 
Secretary. Conservation should be evaluated as an alterantive to 
additional oil shale development. At a minimum, the nation's 
need for liquid fuels should be evaluated, in light of the effects 
of 1) current lav; requiring substantial improvements in vehicle 
fuel efficiency by 1985, 2) reasonable programs for retrofitting 
residential and commercial structures with insulation and other 
energy-saving conservation measures, 3) adopting energy 
efficiency performance standards for new residential and 
commercial construction, and 4) the techno logical advances in 
secondary and tertiary oil production and coal liqui f ication. It 
makes no sense to invest in mammoth energy products which will 
have predictable adverse impacts on human health from air 
pollution, cause "acid rain" and associated impacts on land, 
water and wildlife resources, impair visibility and otherwise 
degrade pristine environments in order to make heat that escapes 
out the window. If conservation alternatives can reduce or 
eliminate the need for further oil shale development, they will 
be the most effective mitiga tion measures , and must be considered 
as reasonable a iternati ves under NEPA. The fact that 

conservation alternatives may not be within the jurisdiction of 
the Secretary is irrelevant. The CEQ regulations make clear that 
the alternatives analysis must "include reasonable alternatives 
not within the jurisdiction of the lead agency." 40 CFR 
1500.14(c) . 

1 ) Transportation 

A starting point for an adequate conservation analysis 
should be the opportunities for reducing consumption of liquid 
fuels in the private transport a tion sector. Energy policy 
justi fications for government support and expansion of oil shale 
development have been: to plug the capital drain from the United 
States; to reduce threats to national security; and to improve 




regional economic conditions. 5 / Rather than investing resource 
dol lars into oil shale deve lopment, these national security and 
energy efficiency improvement benefits may be more economical ly 
achieved by investing a fraction of the same capital into the 
U.S. automotive industry. Improving the efficiency of the U.S. 
vehicle fleet will meet energy policy objectives at a lower cost 
than oil shale development, while maintaining, if not raising the 
quality_JL_' of the natural environment and the economic health of 
the auto industry. 

Recent research shows that vast quantities of oil are 
available from automobi le manufacturers in Detroit. In an 
article published in Scientific American "The Fuel Economy of 
Light Vehicles" by Gray and VonHippel. b . ', the authors describe 
the technical feasibility of producing energy efficient 
automobiles which take into account demographic changes as well 
as evaluating improved automobile design by use of available best 
technologies and reasonably anticipated new technologies. — 1—> 
They suggest that a 60 mpg vehicle fleet, by 1995, is possible 
without major technological advances. _JL' By the year 2000, fuel 
consumption would be two-thirds that of 1980 or approximately two 

million (m) barrels/day (bbl/d)._2 ' These fuel savings would be 

roughly more than twice the energy content of the Trans Alaska 
Pipeline .JJ2_' 

The economics of improved automotive efficiency are quite 
favorable when compared to investment in oil shale development. 
A 1980 Congressional Budget Office (CBO) study estimates that the 
incremental investment necessary to improve fleet fuel economies 
to 40 mpg ranges from $10-$27.5 billion (b) f$i QftnK 11 / Savings 
resulting from a 4 mpg fleet, when compared to the 2 3 mpg 
standard, 12 / are -5mbbl/day in 1990, lmbbl/day in 1995, and 
close to 2mbbl/day in the year 2000.-- ■■■' 

By comparison, the U.S. Office of Technology Assessment 
(OTA) estimates that the cost of a lmbbl/day oil shale production 
facility could easily reach $456 ($1979) .«i£_/ Output is 
syncrude , which would then require additional energy and capital 
for conversion to useable liquid fuels. 

The comparison of investment alternatives is: a maximum 
investment of $27-5 b ($1980) to save 1 mbbl/d in 1995 of liquid 
fuels versus $45 b ($1979) to produce 1 mbbl/d of s yncrude . 15 / 

The policy go a Is of improved energy efficiency, reduced 
military tensions, improving regional economic conditions, and 
avoiding further degradation to the natural environment can be 
more economically achieved by revitalizing the U.S. automobile 
industry through judicious investment in efficiency improvements. 
These goals may or may not be achieved by public investment or 
pursuant to Congressiona 1 extensions of the fuel efficiency 
standards. But in either case, continued technological advances 
are likely to continue achieving redutions in consumption thereby 
keeping the price of liquid fuels in line with current real 
costs. At current prices, oil shale is not profitable. See OIA 


report. Absent evidence that the demand for liquid fuels cannot 
be met by other supplies, or that oil shale can become profitable 
in the near term, the Secretary should not risk the drastic 
environmental consequences that can result from increased oil 
shale development beyond that level currently planned by the 

2} Residential energy conservation 

Energy conservartion measures in existing residential 
dwellings offer great opportunities for improving end-use energy 
efficiency. A variety, of institutions have recognized the 
potential and made efforts to encourage or institute conservation 
programs. The U.S. Congress has directed DOE to develop the 
Residential Conservation Service (RCS) which sets guidelines for 
utility sponsored programs which wil 1 provide financing and 
installation of conservation and solar retrofit measures. JJL' 
Many major electric utilities have instituted conservation 
programs designed especially for existing homes. Pacific Power 
and Light (PP&L) and TVA provide free and comprehensive home 
energy audits as we 11 as information on finance arrangements and 
contractors to do the job. TVA offers interest free loans for 
conservation measures. The state of Oregon requires its 
utilities to finance retrofits themsel ves.JJ./ The major 
California electric utilities now offer zero and low interest 
loans as well as technical assistance to its customers. .JUL/ Even 
General Public Utilities Corporation, the principle owner of the 
Three Mile Island Nuclear power plant has most recently 
instituted a conservation program which includes energy audits 
and minor installation done free of charge. JL9_/ 

The growing trend of utility participation in residential 
and commercial energy conservation programs indicates their 
recognition of both the large technical potential to conserve 
energy as well as the economic attractiveness of conservation 
being the least cost alternative to pursue. Appendix A lists 
major utility sponsored conservation programs. 

3) Building performance guidelines 

Several research organizations have investigated the effect 
of implementing various energy efficient building guidelines. 
Their performance guidelines, which are usually expressed in 
kWh/ft.2,apply to the whole building and provide great 
flexibility in design and implementation. Important work has 
been done by U.S. Department of Energy (DOE); Lawrence Berkeley 
Laboratory (LBL); American Society for Heating, Refrigeration, 
and Air Conditioning Engineers (ASHRAE): and American Institute 
of Architects Research Corporation (A1ARC). 

In the DOE program minimized life cycle costs are the basis 
for the standards. A computer model is used to determine changes 
in heat transfer within the prototype unit for each measure 
added. The measures included in the model are designed to 
improve the thermal integrity of the building and be economically 





justifiable while maintaining, (or improving) human comfort. A 
comparison is made between the increased investment in energy 
conservation and the dollar (energy) savings during the life of 
the building. The energy requirements necessary to meet the 
efficient standards are referred to as the Design Energy Budget. 

In this model conservation measures are added in order of 
decreasing benefit cost ratio (i.e., the ratio of dollar savings 
in energy to costs of conservation measure) until the ratio is 
just equal to one. The Design Energy Budget is the energy budget 
that minimizes life cycle cost. It is described in terms of 
BTU/ft2/yr. The model prepares energy budgets for ditterent 
cities and building types. DOE has termed these energy budget as 
Building Energy Performance Standards (BEPS). They were issued 
in November 1979 in a Notice of Proposed Ru le-making on Energy 
Performance Standards for New Building ' 

Sensitivity of performance standards to different building 
parameters and their applicability to different housing types are 
two of many issues still subject to discussion. But in its 
evaluation, LBL shows that BEPS are relatively insensitive to 

st variation in house design 

21 / 

Although the DOE BEPS program was not implemented, the 
institutes and organizations listed above report that the 
technical potential for energy conservation in both residential 
and commerical buildings is very high.X^-' 

4) Other technological alternatives to oil shale development 

Equally important is an evauation of oil and gas drilling, 
including secondary and tertiary production techniques, and coal 
liciui faction as alternatives to oil shale development. Recent 
discoveries and new recovery technologies suggest that oil and 
qas development offers a much larger potential source of fuel in 
the near term than was considered likely only a few years ago. 
The rush to increased oil shale development may not be justified 
in the light of these discoveries. Oil shale projects already in 
the stages of advanced planning may be more than enough to meet 
current demand if traditional oil production rates can be 
sustained while conservation reduces demand. The air, water, 
soil and wildlife impacts of oil drilling and tertiary production 
techniques are substantially less than the impacts oil shale 
development will have on those resources. To the extent that oil 
reserves can meet more of the demand than anticipated a few years 
aqo the Secretary should consider whether oil shale development, 
and its attendant adverse impacts on the human environment, can 
and should be proportionally reduced. 

With respect to coal liqui faction, it is much less clear how 
the respective environmental impacts of coal and oil shale will 
trade off But given the minimal need for solid waste disposal 
in coal-based conversion technologies as compared with the 
massive volumes of spent shale which will be produced by even a 
modest level of oil shale development, it is quite possible that 



a careful analysis will show that, on-balance, coal conversion 
will have a significantly smaller impact on soil and water 
resources, although air quality impacts may be similar. In 
comparing coal liquif ication with oil shale, it is also important 
to consider the wide-range of siting options available to coal 
projects, whereas oil shale can be economically developed in only 
a few confined regions of the country. Thus the analysis should 
evaluate the opportunity to reduce the environmental impacts of 
coal-based conversion by siting policies which separate the 
projects from sensitive environmental areas (such as parks, 
wilderness, non-attainment areas, geological formations sensitive 
to acid deposition and domestic or agricultural water supplies) 
and avoid over-concentration of pollution sources. 

Finally, an analysis comparing various fuel supply and 
conservastion alternatives should include an evaluation of the 
rates of CO2 production associated with each. The evidence is 
rapidly growing to support the conclusion that C0 2 accumulation 
in the earth's atmosphere will have a dramatic, if not 
catastrophic, impact on the human environment. The scientific 
debate has generally shifted in recent years from whether there 
will be a "greenhouse effect," to how wide-spread that effect 
will be. Included in the likely affects will be reduced 
precipitation, reduced agricultural production and increased food 
shortages for a growing world popolation.il_' Given the 
probability of such large-scale impacts within 50 years or less, 
it is critical that modern industrial society begin the search 
for either substitutes to current carbon-fuel combustion energy 
sources, or carbon-based fuels that reduce the rate of C02 growth 
in the atmosphere. With this serious environmental problem in 
mind, alternate sources of fuel should be compared with respect 
to the amount of C0 2 formed by each process per unit of available 
energy produced. In addition, the economic and technical 
feasibility of the hydrogren fuel cycle should be considered as 
an alternate source of energy. 

B. Regional Alternatives: Siting Scale and Technology Options. 

The regional, cumulative impact study in this case is both a 
desireable and necessary part of the analysis. The proposed 
projects will be so large in scale and so geographicl ly confined 
that anything less than a regional analysis would fail to fulfill 
the purpose of making available "information useful in. ..main- 
taining. ..the quality of the environment." This is so because: 

{1} Owing to the confined area of development, interaction 
among pollutants is inevitable._21_/ 

(2) Influences of topography on meteorology [especially 
channelling and valley trapping 25/ w i 1 1 result in con- 
finement of plumes, making interaction of plumes more 
likely, and increasing the duration of reaction times. 
(See 5.6). 

{3} The proximity of sensitive areas {wilderness areas, low 
buffering-capacity lakes, f6/ ecologically sensitive 
tundra, etc) make it more likely that any synergistic 
interactions wil 1 have an adverse impact. [See 5. 4. 2. J. 

[4} The proximity of urban sources {notably. Grand Junction) 
make it likely that synergistic interactions will occur 
whose frequency and severity would not be noted if 
sources are considered one at a time. {See 5-2-1}. 



{5) The proximity of numerous major sources tourban areas, 
including a non-attainment area for TSP (Grand 
Junction) substantially increases" the liklihood that 
the cumulative impact of emissions will either cause or 
contribute to ambient concentrations in excess of 
national ambient air quality standards. 

Since regional analysis is a necessary part of this EIS, it 
must conform to the same regulations as other parts of the EIS, 
viz, the EIS must "rigorously explore and objectively evaluate 
all reasonable alternatives." 40 -C.F.R. 1502.14. We praise 

the BLM for undertaking the regional analysis in these 
circumstances, but we are disappointed that important, reasonable 
alternatives were not considered. 

In this case, the discussion of alternatives in the regional 
analysis is limited to two "scenerios." This approach is 
justified as fol lows : 

[nlormally, individual EISs would be prepared for each of 
the proposed projects, with each one containing a cumu lative 
analysis. In this case, all of the proposed projects were 
combined into one EIS and one regional cumulative analysis 
was prepared. Therefore, this part does not address 

alternatives to the proposed projects. Alternatives for 
each site-specific project are analyzed in the site -specific part 
of this EIS. 

The proffered two- scenario analysis is not an evaluation of all 
reasonable alternatives. The regulations specify that the 
analysis must include the proposed action, and the alternative of 
no action as well as all reasonable alternatives. 40 C.F.R. 
1502.2- The solicitation of contract for this project specifies 
consideration of a hi gh and low scenario in addition to 
consideration of the proposed action. Solicitation of Contract 
number YA 553-RFPI -1 05 4, paragraph 

In order to comply with federal regulations, the EIS must 
include consideration of: 

{1} the no action alternative 

{2) the proposed activity 

{3) all other reasonable alternatives to the action analyzed 




on a regional cumulative impact basis. 

This discussion of reasonable alternatives must include the 
cumulative and regional impacts of: 

a} alternative siting for major components of each project 

b] alternative production capacities {including a no 
development option for each project) and 

cj alternative process and emission control strategies for 
each project. 

Since the central goal of NEPA is to identify ways in which 
development can be achieved at the least environmental cost, 42 
U.S.C. 4331, that goal cannot be met without considering the 
cumulative impacts of selecting major alternatives which will 
affect regional air quality. Alternatives for the siting of 
major emitting facilities will likely have significant impacts on 
air quality. Local valley inversions and the frequent decoupling 
of val ley flows from regional air movement will result in fre- 
quent trapping of emissions from sources located below the eleva- 
tions where inversions typical ly form. Such trapping is also 
likely to contribute to high short-term concentrations of 
emissions below the "free" atmosphere. Numerous sources located 
in the same or adjacent valleys will contribute to cumulative im- 
pacts that could have severe effects on local air quality. Such 
effects are projected by the Prototype oil shale leasing DEIS 
recently released {July, 1982) by the BLM's Colorado State office. 

In contrast, locating major emitting sources close to ridge 
tops, above the elevation at which stable layers will most 
frequently form, will go a long way to avoiding the type of local 
effects which would result from lower elevation sites. Of 
course, there is a trade-off. Sources located at high elevations 
are more likely to contribute to higher concentrations of 
pol lutants in the sensitive wi lderness areas downwind which are 
generally more susceptible to sources at longer distances and are 
exposed to "free" atmosphere flows- 

The BLM has some important options at this stage of the process 
that can mitigate some of the most serious adverse impacts attribu- 
table to emissions of air pollutants. First, BLM can select alternate 
lease tracts which can influence the siting of major emitting facili- 
ties within the Piceance Basin. Second, BLM can impose lease conditions 
which impose siting restrictions, such as the elevation of the major 
emission points in relation to surrounding terrain. Because of the 
important differences in air quality- impacts which can arise from 
facility siting decisions, the significant siting options available 
to BLM at this stage of the leasing process should be evaluated to 
determine their air quality consequences. If NEPA means anything, 
it requires that real options available to the decision-maker which 
can be expected to have significantly different environmental conse- 
quences should be identified and compared. That analysis has not been 
done here . 

Terrain features and elevations within the federal oil shale 
region include significant variation's. Kithin that range of variation, 
modeling should be performed which evaluates valley trapping and 
inversion frequencies and durations in the area, and the impacts 
those phenomena will have on emissions from sources sited at different 
elevations. Similarly, rawinsonde and lower met data collected by 








oil shale developers in the region should be evaluated to determine 
whether higher elevation sites will produce significant increases In 
concentrations in the Class I area. From these comparisons, rational 
judgments can then be made regarding tract selection and lease conditions 
affecting stack heights. 

Two other major variables affecting air quality impacts are 
process technology and control technology. Different processes 
produce markedly different rates of emissions for equivalent product. 
This difference seems to be especially notable with respect to !IC 
emissions . 

As discussed in 4.2.2, the variations among emission estimates 
is not sufficiently explained. If the variations are due to differences 
in process technologies, the magnitude of these variations can be 
seen by normalizing the estimates in Table 4.1 of the A.Q.T.R. to a 
uniform production rate, say 50,000 bbl/da. 

50,00 bbl/da PRODUCTION RATES 

Emissions (kg/hr) 




Magic Circle 





so 2 





























If these rates reflect the emissions variations inherent in 
choice of technologies, then the historical changes in the technologies 
of choice (see 4.1.3) argue even more strongly for analysis of a range 
of operating conditions and technologies much broader than the " low" 
and "high" production scenerios analyzed in this DEIS . 

Similarly, different control technology options will achieve 
more or less emission reduction depending on the systems selected. 
The emission inventory used for the air quality analysis is not explains 
and therefore the reader cannot tell what assumptions were made regard- 
ing either the processes that will be used on the proto-type tracts, 
or the control systems to be installed. 


The modeling analysis for air 
to evaluate the air quality differ 
or decreasing emission rates withi 
available choices regarding proces 
would require a clear statement of 
and an assessment of available con 
shows that air quality impacts are 
emission rates that would ref;ult f 
then the decisionmaker should be i 
offered a choice of options as pa 
cind mitigating measures. 


quality impacts should attempt 
ences that would result from increasing 
n the range offered by reasonably 
ses and control technologies . This 

the processes under consideration, 
trol technologic r; . If the analysis 

sensitive to the variation in 
roni consi deration of these fac Lore , 
n formed of those differences and 
t of his con Rider a tion of alter na Lives 


4-0 The EIS fai Is to provide a discussion of data sufficient to 
understand the alternatoves amd impacts. 

4.1 The EIS fails to provide a sufficient description ofthe 
existing environment. 

Federal regulations express an interest in providing a 
sufficient description of the existing environment. However, it 
is made clear that the description must include those facts 
"necessary to understand the effects of the alternatives." 40 
C.F.R. 1502.15. The EIS fails to comply with this requirement in 
three ways. [l] Some data are reported in an unintelligible 
manner and are unreliable because of inconsistencies. {2} The 
methodology used to arrive at the reported numbers is not 
specified. The reader cannot be sure of the meaning of the 

numbers or the degree of reliance to be placed in them. [ 3 ] 
There is a lack of certain data which are necessary to form a 
minimally complete picture of the environment. These faults 
could be corrected with very little, in some cases with no 
expansion of the volume of the EIS. 

4.1.1 Some data reported are unintelligible and unreliable. 

A description of baseline concentrations of atmospheric 
pollutants is necessary to an understanding of the effects of the 
proposed projects. Baseline concentrations play a role : {1} in 
determination of compliance with the NA.AQS standards, 
particularly TSP attainment status in Grand Junction (see 3}, 
t2j as inputs for model determinations of effects — particularly 
for reactive species (ozone, S0 2 - visibility). {see 5.2.1}. The 
data reported in Table R-3-7 and R-3-6 fail to meet the 
regulatory requirements because 

(l) Table R-3-7 does not indicate units of measure. In a 

te lephone conversation on Sept. 17, 1982, SAI indicated 
that the GPM model was used for this purpose. This 
statement whould be confirmed in the Final EIS. Therefore, 
the figures are meaningless. 

{2j The reliability of the data is not indicated (instrument 
detection limits, reliability, accuracy, etc should be specified). 

{3} Completeness of the data is not indicated — the reader does 

not know if the figures represent the totality of the data 
recorded, or some excerpt (eg. ozone data are not shown to 
represent a full year's data or the years of data 
unavailable ) . 

( 4 J The representation of "mean" and "maximum 24 hour" in table 

r_3_7 i s n ot meaningful. The reader is unsure if they 
refer to the entire measurement period, instantaneous 

maxima, three-hour maxima, running averages etc. 

(5} The data are not presented in a format consistent with 
standards (by, e.g. expressing S0 2 as 3 hr ' 24 hr and 





annual values or reporting second highs for ozone) or con- 
sistent modeling efforts for use in comparison with modDl output 

To be useful in understanding the effects of the 
alternatives, the data should: 

1) be presented in a clear, comprehensible form, with all 
information necessary for understanding, including 
base represented, and the sampler 

units, the data 
locations ; 

2) show the reliability of the numbers; 

3) be presented with an indication of the methodology used. 
The completeness of the record should be stated and the 
terms ( e.g. "average" and "mean" should be defined. 

4.1.2 The methodology used to arrive at the reported data 
is not specified. 

It is stated in the Air Quality Technical Report, hereinafter 
referred to as AQTR, that annual average ambient S02 
concentrations were "modeled", using the regional emissions 
inventory. AQTR 2-27. In a telephone conversation on September 
17, 1902, SAI indicated that the GPM model was used for this 
purpose. This statement should be confirmed in the final EIS. 

4.1.3 Certain data necessary to an understanding of the 
environment and the impacts are not provided. 

The description of the affected atmospheric environment is 
so cursory and incomplete that it does not comply with the 
requirement that the statement provide that information 
"necessary to understand the effects of the alternatives." 40 
C.F.R. 1502.15. 

The description of the climate is exceedingly short R-3-17. 
Because the climate can be important in consideration of 
radiation (and thus ozone formation), natural particulates ( and 
thus visibility], vegetation (and thus turbulence) and other 
factors. Federal regulations require a more complete description 
of the climate. 

Because the distribution and amount of precipitation in the 
region is important to an understanding of the amount, 
distribution and effects of acid deposition (see 5.4.2 (acid 
rain), there should be a description of regional precipitation 
patterns. An understanding of precipitation and wet deposition 
is also essential to supplement the results of the RTM model. 
RTM is "applicable only during periods of no precipitation", AQTR 
C-36, because the only removal process modeled is dry deposition. 
Acid deposition is most significant as a long-term phenomenon 
with total average deposition being the rate of greatest concern. 
But short-term wet deposition events can have significant impacts 





on the most sensitive lake environments. If there is a 
significant possibi lity that the "wors t case" day wou Id have 
precipitation, {thus, increasing impacts from "rainout" and 
"wshout"}, then the full impacts have not been modeled by RTM. 
There can be no assessment of the probability of this occurance 
without a discussion of precipitation in the region. 

A minimal ly complete discussion of the environment should 
include an indication of the sources of climatological 
information used and their reliability. 

4.2 The EIS fails to provide a meaningful, 
description of the current and projected emissions . 

re 1 iable 

Federal regulations require that the EIS provide a "full and 
fair discussion of significant enverinmenta 1 impacts", 40 C.F.R. 
1502-1, and "insure the . . . scientific integrity of the 
discussion." 40 C.F.R. 1502.24. Estimates of impacts are 
greatly affected by emissions estimates. Regional workshop on 
air quality modeling, E.P.A., O.A.Q.P.S. p. 3. The EIS fails to 
comply with regulations because it (1) fails to specify the 
methodology used in arriving at emissions estimates, making it 
impossib le for the reader to understand the context of the 
numbers or evaluate their reliability, (2) fails to insure the 
scientific integrity of the data (3) fails to provide for a 
worst -case analysis, as mandated , (see 5.1) and (4) fails to 
provide data which are necessary to an understanding of the 
projected emissions. 

4.2.1 The methodology used to arrive at the reported data 
is not specified. 

In section 4 of the statement, there is a discussion of 
expected regional emissions. This discussion is important not 
only to an understanding of the type of action proposed, but also 
because these emissions projections provide an input for computer 
mode 1 ing of the impacts. There is a failure to insure the 
scientific integrity of this discussion because of insufficient 
discussion of sources of data and methodology. 

The projected emissions are said to be "developed on an 
average basis of operating conditions" p. 4-6. This statement is 
too vague to give a meaningful idea of the methodologies used. 
In a telephone conversation with Bill Oliver of SAI on September 
17, 1982, 'it was explained that this phrase means only that no 
attempt was made to account for emission variations in time 
resulting from such factors as weekday/ weekend or day/night 
production changes and not f ul 1 production, presumably .meaning 
"100 percent desi'gn capacity," was assumed. Neither was any 
consideration given to the probabi lity and effects of excess 
emissions from start-up/shut-down or ma 1 functions of control 
systems. These statements should be confirmed in the final EIS 
and documentation to support them should be provided. 

The emissions levels projected will be dependent on 








assumptions concerning the process and control technologies which 
will be used. Only one mitigation scenario is considered for 
each project. R-4-1. This is inconsistant with the requirement 
that the EIS analyze all reasonable alternatives to the proposed 
actions. 40 C.F.R 1502.14. The effective acceptance of whatever 
mitigation procedures are proposed by applicants is an abdication 
of this responsibility . 

The projects are anticipating first-phase retort start-up 
dates from 1883 (Magic circle) to 1994 (Syntana). The experience 
of previous oil shale projects has been that plans for siting, 
disposal, control technologies and even entire process 
technologies have changed in drastic ways in response to 
engineering test results, court decisions, changing regulations 
and economic conditions. See Dept- of Interior, Minerals 
'Management Service, 1982 Report on The Oil Shale Leasing Program, 
iii, 22, 29, 65-77 for a survey of some of these changes. Further, 
estimates of emission from a single process undergo changes as 
knowledge is gained and control technologies are developed. For 
example, compare estimates in A Preliminary Assessment of the 
Environmental Impacts from Oil Shale Developments, 1977, EPA- 
600/7-77-064 with the Uintah DEIS estimates. 

Since estmates of emission from processes projected to 
start-up in 1994 are tentative at best, a decisionmaker can only 
form an opinion concerning expected impacts if a range of 
operational conditions is used in mode ling. Indeed, 

consideration of a range of operating conditions is specified in 
Guideline on Air Quality Models, EPA-450/2-78-027, p. 28. 

Ther e is insufficient description of the source and 
development of the final emissions data. It is stated that 
applicant-supplied data was "reviewed (and) checked as 
appropreate". p.R-G-4. There is not even an indication of what 
criteria were used in this review. The reader is left with no 
real assurance that the data supplied was realistic (especially 
in light of certain inconsistancies; See 4.2.2). 

In a telephone conversation with Bill Oliver of SAI on 
September 17, 1982, it was indicated that the uncertainty for 
emissions in this study would be +/- 50 percent and that 
inventories tend to underestimate emissions. Given the 
impression of thoroughness and accuracy left by a reading of the 
EIS, a full and fair discussion in the final EIS should include a 
verification and documentation of these estimates, and 
consideration of the data which show that actual emissions tend 
to exceed inventories. 

Further, it is stated that inventories were completed using 
"engineering judgment." AQTR 4-8. To comply with the 

requirement of insuring professional and scientific integrity, 
there must be at least a speci fi cation of where, to what effect, 
and on what bases this "engineering judgment" was applied. 

In order to reduce cost and complexity of mode ling. 







"smaller" emission rates were consolidated into "fewer" emission 
points, "for cases in which this activity was technically 
justified," AQTR 4-8. To comply with requirements for 
specification of methodology, there should be some discussion of 
{ 1 } what were the criteria for "technical justification" 1 2) 
which sources were consolidated, {3} where these sources were 
placed, E4} with which pollutants these sources were identified 
and (5) the effect this method will have on all types of 
modeling. See 5.2.1. 

It is stated that "considerable judgment" was used to form 
an estimate of emissions from "conceptual" projects. R-G-4. 
While it is recognized that conceptual projects cannot provide 
exact emission estimates, "considerable judgment" is an 
insufficient description of the methodology used. It does not 
insure professional integrity. To comply with NEPA regulations, 
there must be some speci fi cation of El} sources of data, (2) 
cases in which "judgment" was used, [3} the type and extent of 
this "judgment" and [4} its probable accuracy, error bounds and 
effect on estimates of impacts. Without some indication of the 
non-speculative nature of the estimates, the numbers cannot be 
relied on by the publ ic for the purpose of preparing in formed 
comments on the reasonablness of the judgment made. Neither are 
the estimtes 'useful in restoring, maintaining and enhancing the 
quality of the environment", 42 U.S.C. 4332 [G}, because the 
reader cannot evaluate the range of possible estimates which 
might be reasonable if some assumptions are modified. 
Accordingly, neither the public nor the decision makers can 
assess the significance of the judgments underlying the estimates 
used in the analysis. 

4-2-2. There is a failure to insure the scientific 
integrity of the emissions data. 

Of the Utah baseline point sources identified, emissions 
from only two of these were explicitly considered. The others 
"were assumed to be covered adequately by the procedures used to 
derive the area source files." AQTR 4-11. However, there is no 
indication that any analysis was done to assure that this 
assumption was justified. To insure scientific integrity, there 
must be {1} a specification of what these "other" sources were, 
and (2} an explicit procedure to demonstrate that these sources 
were included in the area source files. 

Modern scientific and enginnering investigations are never 
conducted in a vacuum. The insurance of profess ional and 
scientific integrity requires that, as a minimum, there be an 
explanation of significant apparent inconsistencies between 
different parts of the statement or between the statement and 
prior relevant studies. 

The emission values reported in table 4-1 of the AQTR and 
used in the modeling for the Magic Circle project are generally 
lower than the values supplied by Magic Circle in a recent PSD 
application, especial ly the estimates for total hydrocarbons 


















(THC). These discrepancies are shown in table I. 

Magic Circle Emissions (kg/m) 

Source of data S02 

AQTR Table 4-1 147 

Magic Circle PSD 
Application-4/82 17 3.2 67.09 

Because effects of emissions are non-lineor, the final 
concentration cannot be simply scaled up to compensate for those 
discrepancies . This is particu larly true for the effects of 
hydrocarbons on visibility and ozone formation {see 5.5). To 
comply with. the requirements for a full and fair discussion of 
impacts, visibility and ozone analysis must be re-done, using the 
most recent estimates of emissions. 

If the data from table R-G-l .are normalized to a. 50,000 
bbl/d production rate, it is estimated that TOSCO will emit only 
10 kg/hr of CO and that Geokinetics will emit 15.7 kg/hr 
Normalized Emissions for the other 5 projects range from 7 2 kg/hr 
to 85.7 kg/hr. It is recognized that differences in processes 
wil 1 affect emission rates, but no such explanation is given for 
these large discrepancies. This failure to assure the scientific 
int.egrity of the estimates is particularly serious in the face of 
the previously noted failures to explain the methodology used in 
assuring the accuracy of the applicant's estimates. 

The estimated emissions from Utah projects for CO and WO are 
smaller than those estimated for Colorado oil shale projects 
[normal ized to Utah production rates) { compare table 4.5 with 
tables 4.1 and 4-2 in the AQTR). However emissions for S02 and 
particulates are significant ly larger for Utah projects than for 
Colorado projects. Similarly, it is unclear why the 1980 
Colorado baseline emissions totals (see AQTR table 4-6 scenario 
l) are significantly larger than Utah baseline area source 
emissions [AQTR table 4-18 ] . To insure scientific integrity, 
there must at least be some explanation of these apparent 
inconsistencies . 

analysis . 

The emissions data are inconsistent with a worst case 

EPA modeling guidelines indicate that emissions data are to 
be developed in such a way as to be compatable with a worst-case 
analysis, where that is to be done. Regiona 1 Workshop on Air 
Quality Monitoring, April 1978, EPA O.A.Q.P.S., p. 3-4- It is 
argued below that worst cases analysis must be done for this 
statement [see 5. 1 } .Howe ver , emissions are developed on an 
"average basis." Even considering the ambiguity of that term 







[see 4.2.1 ) , average emissions do not represent worst case 

conditions. To comply with regulations there should be a 

development of both average and f u 1 1 -capacity [worst easel 
emissions . 

4.2.4 Certain data, necessary to an understanding of the 
projected emissions, are not provided. 

In order to comply with the requirement for providing 
information "necesary to understand the effects of the 
alternatives", 40 C.F.R. 1502.15, there must be some discussion 
of the degree to which other planned projects depend on the 
development of oil shale projects. Without this information, the 
reader is unable to understand the effects of alternatives. In 
particular, the reader cannot understand what will be the effect 
if development does not take place, since the impact on non-oil 
shale projects is not discussed. A discussion of the no-action 
alternative is required (see S-3). 

The Department of Interior has proposed to lease two more 
prototype oil shale projects in Colorado. These tracts may 
produce up to 100,000 bbl/da of shale oil [DEIS for the prototype 
oil shale leasing program}. However, this potential source is 

not included in the Colorado source inventory, 
the requirement for a full and fair dicussion, 
these facilities must be included as a possible s 

MS . 

To comply with 
the emissions for 

5. The EIS fails to provide sufficient description of, 

support for or insurance of scientific integrity of the computer 
modeling used. 

5.1 The EIS fails to conduct mandated worst-case studies. 

A worst case analysis is mandated by the regulations if- 
Hi the information relevant to adverse impacts is essential to a 
reasoned choice among alternatives and is not known and the 
overall costs of obtaining it are exorbitant or (2) the 
information relevant to adverse impacts is important to the 
decision and the means for obtaining it are not known (e.g. the 

means for obtaining it are beyond the state of the artj 40 

C.F.R. 1502.22. The mandate applies in this case because (1)} 
predictions of concentrations of pollutants are important to the 
decision because development cannot occur unless a permit is 
issued for Prevention of Significant Deterioration, and 
applicants in this case wil be required to submit predictions of 
concentrations of pollutants; (2} the means for obtaining the 
relevant information (Viz.. accurate predictions of concentration) 
are beyond the state of the art of atmospheric modeling 
Guidelines on Air Quality Modeling EPA-45/l 2-78-027, p. 26, p. 15; 
Regional Workshop on Air Quality Modeling, April, 1981, EPa! 
OAQPS, p. 9. Modeling is not sufficiently accurate to inform 
decision makers or the public about the precise probabiities of 
pollutant concentrations. Largely for this reason, EPA explicitly 
recommends worst case analysis in complex terrain. Regional 





Workshop, p. 9. 

5.1.1 The "worst case" analyses are not pollutant-specific. 

The methodology for determining worst cases does not 
distinguish among the primary pollutants. CTWM and GPM are used 
to determine a single day for further worst case study for S02' 
NO and TSP. [AQTR fig. 4-5). This approach fails to recognize 
that conditions which are worst with respect to one pollutant may 
not be worst with respect to another. For example, particulates 
have a relatively high average deposition velocity and will tend 
to be important for short-range exceedances. S0 2 and NO have 
lower deposition rates and, thus, worst case scenarios for these 
pollutants might include longer range transport, chemical 
conversion, and impaction on distant, sensitive (class I) 
receptors. The requirement for a worst case analysis means that 
the determination of worst cases for these pollutants must be 
conducted independently, with consideration for the nature of the 
pollutant species. 

5.1.2 The "worst case" analysis is based on insufficient 
data . 

CTWM, which provides winds for selection of a worst case, 
uses only one year of data. The regulations require that the 
statement "shall include a worst case analysis and an indication 
of the probability or improbability of its occurance. ' 40 C.F.R. 

The requirement that the probability of occurance be 
indicated implies that the worst case analysis should not be 
limited to the worst observed case in a single past year, for 
th=n the probability of that case occurring would be meaningless. 
The worst case analysis must be intended to include the worst 
case reasonably forseeable (along with an indication of its 
probability) . 

Use of only one year of data also violates the EPA 
recommendation that five years of NWS data be used. Guideline on 
Air Quality models, EPA 450/2-78-027 p. 32. 

The data supplied to GPM, which forms the basis of the worst 
case analysis, consists only of hourly average wind fields. The 
CTWM/GPM is incapable of representing critical plume 
characteristics. This methodology is contrary to the EPA 
recommendation that: 

An analysis of worst case conditions should... consider such 
critical plume characteristics as looping, coning, limited 
mixing, fumigation, and aerodynamic downwash and plume 
impaction on terrain. Guideline on Air Quality Modeling page 

A full and fair discussion of the worst case should include 
explicit modeling of plume behavior. To comply with regulations 



there must be: 

[1} an analysis of at least five years of data to identify what 
the historical worst case of record has been and to allow a 
reasonable approximation of its frequency. 

[2} an analysis to determine whether the historical record 
provides data of sufficient duration to allow a conclusion that 
the historical worst case is the likely worst case, Guideline on 
Air Quality Modeling, EPA-4501 2-78-027, p. 9, and if it is not, 

( 3 ] a determination of the expected worst case, considering the 
regional meteorology, climatology and topography and the location 
of sensitive receptors. 

E4j an explicit mode ling of critical plume behavior, or a 
discussion of the likely effects of plume behavior on 
concentrations . 

5.1.3 The "worst case" analysis makes improper assumptions. The "worst case" visibility model makes assumptions 
about view or orientation, time of observation and stability that 
are incompatible with a worst case analysis. 

Visibility impacts we re mode led using the PLUVUE mode 1 . 
There is some question about whether this model is appropriate 
for the application (see 5.5}. Setting aside appropriateness, 
there are probl ems with the way in which PLUVUE was applied. In 
the regional haze analysis the observer site was chosen to be 
F 1 at tops Wilderness area. R-4-38. But the position of the 
observer within this region is not specified. This is of some 
importance because viewer orientation has an effect on predicted 
visual impacts. The viewer was assumed to be looking to the 
northwest. The flow was assumed to be from the southwest. The 
two source regions are specified only as the Unitah Basin and 
Piceance Basin. It would appear from this that the viewer 's 
line of sight is assumed to be approximately perpendicular to the 
plumeline. According to the PLUVUE user's guide, the magnitude 
of the visual impacts depends on the effective optical thickness 
of the plume, which varies depending on, among other things, the 
viewer orientation. Equation 15 on p. 16 of the user's guide 
indicates that the optical thickness is inversely proportional to 
the sine of the angle between the plume line and the line of 
sight. Thus, optical thickness [and thus visual impacts] wi 1 1 be 
minimized for a viewer looking perendicular to the plume line. 
To comply with the requirment for a worst-case analysis, the 
viewer orientation should be chosen to indicate the maximum 
visual impact a viewer at flattops will experience, i.e., looking 
from the wilderness toward the origin of the plume rather than 
across it. 

The observer is asumed to be present in mid-July. This date 
is chosen to represent the period of maximum visitor use. While 
it may be acceptable that periods of no use should not be 


analysed for impact, it does not follow that the maximum impact- 
will occur when maximum use occurs. One determinant of the 
predicted visual impact is the amount of ultraviolet solar 
radiation. PLUVUE user guide. U.V. flux is calculated only on 
the basis of latitude, longitude, date and time of day- The 
requirement for a worst case study means that calculation must be 
done when the largest visual impact might be expected viz, in 
late-June when there is a higher sun-angle and a longer day. 

Because SO2 conversion rates depend on, among other things, 
both uv flux and O3 entrainment, worst case mode 1 ing must 
represent an optimal balance such that dispersion {and thus O3 
entrainment] and maximum uv flux [at local noon] occur at periods 
of the plume's lifetime which will result in maximum 
concentration at the receptor time and location. Receptor time 
30.36 is chosen as 3 PM. There is no assurance that concentrations 

(COnt) would not be higher for a different assumption of receptor time- 
To assure true worst-case mode ling, there should be runs at a 
sufficient number of receptor times to asure that worst case 
modeling has been done. 

The worst-case scenario for regional haze is assumed to 
include class C stability [slightly unstable]. More stable 
categories [D and E] are c 1 imatologica 1 ly more common_±7_/ , and 
would produce less d i spe r s ion £§_/ • This is particularly 
important for mode ling of N0 X impacts since the so-called 
"thermal" N0 X reaction is second order and is thus particularly 
sensitive (for near- source impacts) to concentration and, thus, 
to stability. 

A worst case for N0 X analysis [see 5.1] must include 
specification of more stable D and E P-G categories. 

Because the SO2 conversion rate is related to relative 
humidity, a proper specification of methodology requires that the 
humidity used in the model be specified. The "worst case" ozone analysis makes assumptions 
about background concentration and trajectories that are 
incompatible with a worst case analysis. 

Ozone impacts were modeled by means of the EKMA model. EKMA 
was run assuming two "worst case" trajectories [AQTR 5-112]. A 
"high" and "low" background concentration was assumed. The "high" 
value for O3 was 0.66 ppm, or about 130 mg/M 3 . However, several 
30 37 previous studies have monitored ozone vales in the region in 

exess of 200 mg/M 3 - See, exhibit 4 . In contrast to these ozone 
measurements, the modeling assumptions for the "high background" 
scenario are not supported by any analysis of available evidence 
or citation to site studies. Thus, the conclusion that "oil 
shale development does not lead to exceedance of the ozone 
standard", AQTR 5-115, is not supported by the data and does 

not meet regulatory standards for EIS preparation. This is 
particularly true in light of the fact that "background air 
qua lity conditions tend to dominate these simulations . " AQTR 


50115. A full and fair discussion must include conclusions based 
on known occurances of high background ozone concentrations. The 
various speculations concerning the origin of these high ozone 
concentrations have included stratospheric incursions, long-range 
transport and unknown local sources. Despite the paucity of 
ozone data reported in the EIS, there is a multi-year multi-site 
record of ozone data available for analysis. Exhibit 5. A 
frequency distribution analysis of these data might go a long way 
toward providing an estimate of the probability that NAAQS 
standards would be exceeded because of new emissions from the oil 
shale region. Besides possible (linear) contribution to NAAQS 
exceedances, an understanding of the time-distribution of high 
ozone values is important. Thus an adequate assesment of the 
available ozone data sould be performed because: 

Jl}as noted the Uintah EIS modeling, results are dominated 
by background condition, AQTR 5-115; 

{ 2} background values are important "boundary" 
the EKMA model, See; 

conditions for 

{ 3 } the uncertainty of ozone concentration is exacerbated by 
the uncertain, but most likely elevated, concentrations 
of hydrocarbon which contribute to O3 formation. See 5.5 

Because of the mu ltiple reason that a knowl edge of 
background 0^ is important, the di cuss ion and analysis offered in 
the EIS is inadequate to "understand the effects of the 
alternatives." 40 CFR 1502-15. 

To be in compl iance with regulations, the EIS must 
contain an analysis of all available regional O3 data with a view 
towards quantitatively estimating the frequency with which given 
high levels of O3 have been mesured in the region. 

The application of EKMA in this statement was improper 
because it failed to comp ly with recommendations in the EKMA 
user's guide. EPA 450/4-80-027- The guide states that since 
EKMA is not a predictor of worst cases, but rather an empirical 

model, it should be run on the five worst cases cite . Even 

for the two trajectories actually run there is no demonstration 
that these represent the worst cases reasonably forseeable. To 
comply with the user guide and the requirement of worst case 
analysis, the EIS must include an analysis of at least five 
scenarios which are chosen to represent the worst forseeable 
ozone cases. In a telephone conversation on September 17, 1982, 
SAI indicated that the reference to recommended background 
conditions "Kiilus and Whitten (1981)." Should be an abstract to 
a paper by J. P. Kiilus intitled "Background Reactivity Estimates 
for Atmospheric Modeling Studies" presented in "XV informal 
conference on photo chemistry," Stanford, California, June 27- 
July 1, 1982- This statement should be verified in the final 

5.2 The EIS fails to insure the scientific integrity of the 
30.38 I modeling used. 






5.2.1. The EIS fails to provide a sufficient decription of 
the methodologies used. 

5.2-1.1 The emission consolidation methodology is 
insufficiently described. 

As noted above, 4.2.1, certain emission sources are 
aggregated in the model. Bill Oliver of SAI stated in a telephone 
conversation, Sept. 17, 1982, that no source was moved more than 
0.3 km, that ground-level and stack sources were never 
consolidated, and that "unusually large" sources such as the 
Sohio S02 source, were not consolidated. Those statements should 
be confirmed and documented in the final EIS. It is asserted 
that the consolidation results in over-estimates of 
concentrations, AQTR 4-61 and 5-2 to 5-3. However, such 
aggregation may result in under-es timates of concentration as 
well if [1] the sources are placed in a more exposed topography 
and are thus more quickly dispersed^ /; [2] the sources are 
placed at a high elevation, [e.g. ground-level TSP sources might 
have been aggregated with stack emissions, which may result in 
unrealistically high dispersion rates 2? ' ; [3] the sources are 
placed farther from sensitive receptors, (e.g. class I areas than 
their actual position). Bill Oliver in the phone conversation of 
September 17, 1982 indicated that no consideration was given to 
the relative topography of the source sites which were 
consolidated. These concerns are especially important because 
the EIS does not inform the reader which sources were aggregated, 
for what pollutants, and what locations were assigned to them. 

The requirement of a description of the methodology means 
that the EIS must specify the manner in which sources were 
consolidated, including a table or graph of the consolidation 
process and the criteria used to decide on which sources to 
consolidate, and must discuss the likely impact of this procedure 
on the results of the modeling. The wind field randomization methodology is 
insufficiently described. 

The winds used in the GPM were obtained from the complex 
terrain wind model AQTR 4-59 [see 5.3]. Since this model, in the 
so-called "composite" mode, predicts synoptic winds in only 16 
wind directions, AQTR 4-70, GPM winds were randomized about their 
predicted position to compensate for the lack of greater 
resolution AQTR 4-49. This method is unsatisfactory because: 

The resultant wind variability will be unrealistically 
large, thus unrealistically increasing horizontal dispersion. In 
a telephone conversation of Sept. 17, 1982. SAI indicated that 
the wind direction at the centroid of each puff was randomized 
independently. This statement should be revised and documented 
in the final EIS wind direction at one point is dependent air 
wind directions at other points because (a} advection of momentum 
affects wind direction downstream [bl points near each other are 
affected by similar pressure gradients, surface influences, air 




mass characteristics, etc. The assumption of independence ignore 
this effect and allows {a} two neighboring points to differ in 
U .D. by up to 12-1/2 % throughout the domain and {b } a single 
point to gave a wind direction ahift of up to 12-1/2 % each time 
step throughout the simulation. This results in much larger wind 
direction gradients than that observed in the real atmosphere. 
The puffs follow a more convoluted trajectory than they do in 
reality which can result in decreased estimates of concentration 
because ; 

(1} topographic continent effects such as channeling are 


stagnation points are less effective. 

There is no description of the amount of wind direction 
variability that resulted. The reader is unable to evaluate the 
importance of {l). Insurance of scientific integrity requires 
that any randomization of winds be calculated to duplicate the 
empirical , statistical wind variability characteristics in the 
region . 

5.2.1-3 G.P.M. mass loss and residual concentration 
methodologies were insufficiently described. 

GPM puff mass loss is modeled using a first order decay 
equation AQTR 4-101. The decay rate is dependent on chemical 
conversion rate and deposition rate parameters supplied by the 
modeler, AQTR C-25. However, values for these parameters are 
never specified. In telephone conversations on Sept. 17, 1982, 
and Sex^t. 20, 1980, Mark Yahkee of SAI stated that the commission 
rate was chosen to correspond to a 1-1/2% per hour conversion 
rate during the day and 0.1% conversion rate during the night. 
He also stated that the deposition rate was chosen to correspond 
to a 0-5 cm/Sec deposition velocity for TSP and a 1.0 cin/Sec 
deposition velocity for SC> 2 , using the mixing depth or a 
conversion factor. Their statements should be verified and 
documented on the final EIS- Because of the importance of the 
mixing height on this scheme, the values used should be specified 
on the description of the use of the GPM. 

5.2.1-4 EKMA upper level concentrations are insufficiently 
described . 






There is also a failure to specify methodology used in the 
EKMA ozone modeling. Since that model's concentrations are 
affected by entrainment of O3 and NO x from the upper model layer, 
the reader cannot make reasoned decisions on the basis of model 
results without knowing the values for upper level O3 and NO x 
concentrations input to the model. This is especialy true in the 
region under consideration, since [^undergoes wide fluctuations 
of concentration in the region, (section 5-1). Some of which 
might be related to entrainment from above, through the so-called 
" tropospheric folding" pheneomenon [see 5-1 3- To comply with the 
requirement for specification of methodologies, the values 
assumed for upper layer 3 and NO x concentrations must be given 
in the EIS. 

5.2.2 The 
understanding . 

EIS uses methods contrary to current scientific Non-linear impacts are additxvelly combined . 
Atmospheric reactions are known to be non-lineor in the sense 
that the impacts of two sources which combine may be made larger 
than the sum of the constituant impacts- But in two p 1 aces of 
the analysis, total impacts are calculated as simply the sum of 
the impacts of the constituants. 

For the plume discoloration analysis PLUVUE was run 
separately for each of the Unitah synfuels sources and some power 
genereration sources. The total impact was not estimated, but 
the impact of each source was presented separately. This method 
fails to make clear the impacts which may arise from interactions 
between the different sources, some of which are synergistic in 
nature. PLU V U E user's guide. Much of the predicted impact 
depends on chemica 1 transformations in the pi urae. The rate of 
these transformations depends on, among other factors, the 
proportions of different chemica 1 species present [e.g. the 
concentration of ozone ] . Thus, the impact of two interacting 
p 1 umes may be more than the sum of the parts. A full and fair 
discussion must include an explicit modeling of the impacts 
resulting from interaction of the plumes. 

There was a simil ar ommission in the ana 1 ysis of regiona 1 
impacts discussed the Air Qua lit y Technica 1 Report [ p. 5 ] . This 
analysis was done by conducting separate analyses of impacts of 
industrial growth and impacts of associated growth, AQTR 5-34A to 
5-34Q . Cumu 1 ati ve impacts were then taken to be the sum of 
these. This simple summation method fails to provide a "full and 
fair discussion" of the impacts, because impacts may be larger 
than the sum of individually considered parts. Conversion rates 
in pi umes are, as for ex amp 1 e, the con version of SO2 to SO a, may 
increase abrupt ly upon interaction with urban po 1 1 uti-on. JbSL f Tt 
resulting concentrations could be much larger than the sum of the 
separate 1 y considered concentrations. 

Insurance of scientific integrity requires that there be an 
exp licit consideration of the interactions of industria 1 growth 
and associated growth. Particularly, the interaction of Grand 


JU.4J I junction sources with oil shale sources must be explicitly 
(C0nt)| modeled. 

[| 5.2.2-2 Certain sensitive receptors are not inc 1 uded in 

the regional modeling domains. 

The regional modeling domain is shown in AQTR fig. 1-1. No 
justification is given for the choice of this par tic u lar mode ling 
domain. Many air born pollutants, particularly chemica 1 ly 
reactive po 1 lutants, have impacts hundreds of kilometers from the 
source._31_/ Indeed, the contract so licitation for this study 
stated an expectation that impacts would extend beyond the 
Piceance and Washakie basins. So licitation of Contract No YA 
553-RFPI-l 054, paragraph 4-1- This is pointed up by the finding 
of the supplemental Prototype EIS that there may be exceedances 
in the Mt. Zirke 1 area even when there are no exeedances at 
Flattops. Prototype DEIS Table 3-3. There is no explanation for 
the excusion of an explicit modeling of the impacts on Arches 
National Monument of the West Elk, Marnnn Bells, Black Canyon or 
Rawah areas. Although estimates are given for concentrations at 
Mt- Zirkel (AQTR Table 5-1) this area appears to be outside the 
modeling domain in fig 1-1, so that the numbers so not represent 
actual modeling results for Mt. Zirkel. Since only the western 
part of the F 1 at tops Wil derness is inc 1 uded in th domain, there 
is no assurance that impacts on the eastern part of the F 1 attops 
Wilderness will not be significantly higher. Indeed the 

Prototype DEIS indicated that plumes from the oil shale region 
may travel south of the wilderness area and then turn north so as 
to have an impact on the western half. Prototype DEIS fig. G-14. 
There is also an indication of a topographically forced 
stagnation point on the eastern side of F 1 attop, which can cause 
an accumu 1 ation of impacts on the eastern ha 1 f even though the 
western half is relatively unaffected. Prototype DEI 5 fig. G-67. 

The requirement of a "full and fair discussion " of impacts, 
40 CFR 1502-1. makes it necessary for the EIS to include 1] an 
explicit determination of the geographical bounds of the affected 
regions, particu 1 ar 1 y the regions affected by acid deposition 
[see 5.4.2]. 2] modeling of the impacts on a domain large 
enough to inc 1 ude these areas. The tiered use of CTWM, GPM and TRM leads to 
synergistic error and may involve incompatibility. 

An array of models is used to predict various types of 
impacts. The methodolgy of this system is displayed in AQTR fig. 
4-5- There are several problems with this scheme. 

The CTWM model is used as an input for the GPM modal which 
is used to determine a "worst-case" day for further modeling by 
the RTM. As discussed in this section [see 5.2-1.2,, 
5. 2. 2.1-,], each of these models has inconsistencies and 
problems in application. The tiering of several models, each 
with its inaccuracies and each used to provide a type of input 
for the next, can result in errors more serious than the errors 







in the individual models. For example, since only one "worst- 
case" day is modeled by the RTM, any inaccuracy in the GPU 
prediction of the worst case will result in a total failure of 
RTM to do a worst-case analysis. 

A further problem is that apart from model inaccuracies, the 
models may not be compatible, in the sense that GPM,even properly 
applied and initialized, may have a different "idea" of what a 
worst-case is, than RTM does. RTM may well predict higher 
concentrations for a case day that GPM predicted was far less 
serious than the predicted worst case day. Insurance of 
scientific integrity requires that 1] choice of a worst case for 
analysis by RTM be based, not only on their model runs, but on a 
knowledge of the air quality meteorology of the region, keeping 
in mind the characteristics of RTM, and what factors it weighs 
most heavily, [see 5.1]. 2] there be a discussion of synergistic 
error derived from, e.g., model sensitivity studies 3] there be 
an analysis of the compatabi lity of the modeling with respect to 
the worst case identification based on modeling theory, and 
knowledge of regional meteorology [see 5.5.1]. Comparisons are made between model prediction 
rather than between predictions and observations. 

On the basis of a comparison of GPM and RTM model results, 
the DEIS concludes that "GPM calculates considerably greater 
impact, than soes TRM at distances beyond about 25 to 50 km. 
Although this conclusion is characterized as "tentative", a far 
ranging scheme of setting upper and lower confidence limits on 
the modeling results is based partly on this conclusion. Since, 
as discussed on, these bonds have great effect on the 
prediction of probable violations, this conclusion is not treated 
as tentative at all. The conclusion is at best tentative, 
because; 1] different data were used as initial conditions for 

the two models, 2 ] as aknowledged on the statement, AQTR 5-3, a 
single run of each model is insufficient to make a comparison, 
and 3] comparisons between modes provides no information on the 
ability of either to predict reality. To present an accurate 
idea of the reliability of the models, there should be a 
comparison of the predictions of both models to measured 
concentrations in the region modeled. Regional Workshop on Air 
Quality Models, April, 1981, EPA, O.A.Q.P.S., p. 15; Guidelines 
on Air Quality Models p. 4. A comparison of the results of two 
models ignores the risk that both may be unrealistic. Insurance 
of scientific integrity and EPA guidelines require that model 
predictions be compared with real data for runs conducted over 
terrain reasonably similar to the region of interest and where 
verifying data exist. 

5.2.3. The EIS fails to provide support for conclusions 
reached and methods used. There is insufficient support for the method of 
determining upper and lower bounds for predicted concentrations. 



In an effort to discount the prediction of exceedances, the 
EIS sets upper and lower "bounds " on the prediction, basing these 
on the al leged conservativeness of the GPM model - 

Considering the lack of an effective demonstration that GPM 
is a "conservative" mode 1 for this application [ see 5.6], there 
is no basis for the procedure followed in the AQTR of setting up 
GPM predictions as an up per -bound for projected impacts. The 
lower bound is set as 1/10 of the GPM projections, AQTR 5-6. The 
on 1 y justification given for this methodo 1 ogy is the writers' 
"professional judgment", AQTR 5-6. Reference to "professional 
judgment " does not comp 1 y with the requirements that agencies 
"sha 1 1 make explicit reference. the scientific and o ther 
sources relied upon for conclusions" 40 CFR 1502.24. If there is 
any basis in the literature for the "professional judgment", it 
should be cited. If not, the rationale underlying the judgment 
should be explained. 





Even this thin justification is not given for the practice of 
using a factor of 2 as the error range for the TSP "empirical model" 
or a factor of 4 for annual concentrations. (AQTR fig. 5-2). The 
practice of setting bounds, though only sketchily discussed, is of 
great importance in the evaluation of impacts. It is concluded that 
for SO? at the Flattops, "if the upper-bound estimate were used, the 
Class I increments would be exceeded; if the lower bound estimate 
were used, the increments would not be exceeded." AQTR 5-105. Again 
"judgement" is applied, relying on the previously defined "error bounds" 
to conclude that the probability of exceedance at Fiattop and Mt. Zirkle 
is " sma 11". 

Since these "judgements" may have an effect on the choices of de- 
cision makers,, it is important that the scientific integrity of the 
proceedure be insured by providing support for the procedure. Insurance 
of scientific integrity means that the EIS must either justify by 
citation or scientific argument the setting of bounds, or must refrain 
from this procedure . Conclusions reached concerning comparability of model 
predictions are unsupported by and contradicted by the data reported 
in the EIS. 

When RTM predictions were compa 
the two "compare quite favorably for 
5-6 . This conclusion seems unjustif 
differences in the far-source runs 
source runs are still substantial, 
far-source models showed differences 
fig. 5—1. Intercomparison of models 
is of doubtful usefulness (see 5.2.1 
any weight to an insurance of scient 

red with GPM, it was concluded that 
near-source maximum impact." AQTR 
ied. Though better than the 600% 
the 20% differences in the near- 
Looked at in absolute terms , the 
in the range 5-17 ug/m -3 . AQTR 
without reference to measured data 
) . This procedure fails to lend 
if ic integrity . 

The requirement of insurance of scientific integrity makes it 
necessary for a comparison of model results to be made quantitatively. 
Any characterization of the comparison must be substantiated. 

5.3 The EIS fails to provide an insurance of the scientific in- 
tegrity of the CTWM model. 

The CTWM was used to provide wind field data to "drive" the GPM 
model. Rather than attempting to explicitly model wind directions for 
an entire year, a "composite" method was used as an expense-saving de- 
vice. AQTR 4-70 to 4-72. Because of the plethora of problems with this 
method, it is treated separately in this section. 

Briefly, the composite method 
upper and lower level wind fields 
compass directions. Additionally 
puted to represent 3 upslope and 3 
of the year was assigned one repre 
and one representative lower level 
based on synoptic and local wind d 
hourly wind field was taken to be 
ously computed upper level wind fi 
tive wind direction for that hour 

yields winds at two levels. Sixteen 
were computed, one for each of 16 
6 lower level wind fields were com- 

downslope wind regiems. Each hour 
sentative large-scale wind direction 

slope wind category. These were 
ata. As input for other models, the 
(1) for upper level winds , the previ- 
eld corresponding to the representa- 
(scaled to observed -ind speed) 



(2) for lower level winds, the vector sum of (a) the previously com- 
puted lower level wind field corresponding to the representative wind 
direction for that hour (scaled to observed wind speed) and (b) the 
previously computed wind field corresponding to the representative 
slope wind for that hour (scaled to observed wind speeds). 

5.3.1 Characterization of the regional wind field was inaccurate. 

According to a telephone conversation with SAI on September 17 , 1982 , 
upper air data from the four stations was taken at the 6000 ft. AGL level. 
This statement should be verified and documented in the final EIS. The 
four winds were then averaged to arrive at a single wind direction which 
was used to indicate one of the sixteen compass points . The problems 
with this method are : 

1) Winds at a given height AFL may not be representative of the 
winds which determine trajectories of plumes. This is so 

(a) the degree of "coupe ling" between upper and lower layers 
varies from station to station , particularly in complex 
terrain, so that the most representative level at one 
station is likely to be different from the most represen- 
tative level at another, and 

(b) the level most representative of trajectories in a region 
varies from day to day, depending an meteorolgical condi- 
tions . 





(2) The stations are removed from the study area and may not be rep- 
resentative of regional winds. Particularly Denver, being on the 
eastern side of the continental divide, is often under an entirely 
different synoptic pattern than western slope stations. 

(3) The averaging of four stations separated by many hundreds of 
kilometers may give a very misleading idea of the true wind direction 
characteristic of the region. For example, if four evenly distributed 
stations with uniform wind speeds reported N, S, E and W winds (as might 
happen if there were an ideal, closed high pressure area near the cen- 
ter of the region) , the vector average would indicate calm winds. 

(4) Characterization of the entire region by a single wind direction 
is an oversimplification of the data.-^ Even if there were no tech- 
nique-related problems of averaging the data, winds across a large 
region, above complex terrain cannot be characterized by a single vector. 
This complexity of the atmosphere is exactly why numerical modeling is 
necessary for an understanding of the regional transport. 

(5) Once an average is taken, the characterization is further coarsened 
by dividing all wind directions into one of 16 classes (for the 16 
compass points). There is no reason to believe that wind variations 

of less than 22 1/2 degrees are insignificant in a complex terrain 
region where sensitive receptor areas may occupy less than 22^ degrees 
at the distances involved. 

b.3.2. Temporal interpolation of regional wind direction yielaeu 
unrepresentative results. 

Since upper air data is taken only twice daily, the wind directions 
for intervening hours are arrived at by interpolation. According to 
a phone conversation with SM on Sept. 17, 1982, this was done by linear 
interpolation through the smallest angle. This statement should be 
verified and documented in the final EIS. The problems with this 
method are: 

(1) Then- is no reason to believe that wind direction shifts occur in 
a linear fashion. More abrupt wind direction shifts could contribute 
to "doubling back" of a plume on itself that would not be resolved by 
the interpolation method. 

(2) Significant wind direction changes occurring on a scale of less 
than twelve, hours would be missed. 

(3) Interpolation may give a misleading picture of actual wind direction. 
For example, if the twice daily reports indicate winds from the N and 
the SE, an interpolation will indicate a veering of the winds through 
the east, whereas the wind might have actually backed through a westerly 

5.3.3. Characterization of the slope wind was inaccurate. 

The representative slope wind assignment is made by comparing 
surface-level wind directions from the Ua-Ub tracts with the averaged 
regional upper air wind directions. The problems with this method are: 


(1) The methodology is not sufficiently defined. Left unanswered are 
such questions as: 

(a) are the surface winds hourly? 

(b) are the surface winds collected at 10 m height? 

(c) are comparisons made before assignment of upper air wind 
direction to the 16 compass points? 

(2) Slope winds measured at a limited number of sites may not be 
characteristic of the slope winds for an entire region, particularly 
since the sites were chosen to represent conditions at an individual 
project, rather than to be characteristic of the region. Slope wind 
direction and intensity will vary depending on local topography, vegeta 
tion cloud cover, etc. Further, it is conceivable that drainages from 
different slopes may combine if drainage flows begin at different l^imes , 
while drainages beginning simultaneously might miss each other. 

that modeling assumptions that assume slope flows to be temporarily 
uniform will fail to simulate certain "worst case" plume interactions. 

There is no assurance that six classes of slope flow are sufficient 
to resolve the intricacies of slope flows in complex terrain. Assurance 
of scientific integrity requires that sensitivity analyses be run to 
determine how many slope categories are necessary to resource important 
features . 

5.3.4. Scaling and linear combination of wind fields is mathemat- 
ically unsound. 

The wind model is run for the sixteen wind directions, and for 
the six slope wind regimes, assuming an arbitrary wind speed (10 m sec-1). 
For each hour of the year, the assigned upper air wind direction output 
is scaled to the observed wind speed and vector-added to the similarly 
scaled slope wind output. The problems with this method are: 

(1) Since there are only 96 possible synoptic/slope wind combinations 
for lower level winds and only 16 possible upper level winds, there may 
be insufficient resolution to model the complicated interactions that 
occur between synoptic and slope winds in complex terrain. 

(2) There is no theoretical reason to believe that winds can be broken 

down into slope and synoptic winds (in the way that they can, ir 
matically, be divided into, say rotational and irrotational tic 
Large and small scale flows interact in complicated non-linear ways, 
especially in complex terrain. A simple addition of separately modeled 
flows fails to account for those interactions which are so non-linear 
that the result cannot be predicted from the components (indeed, the 
very definition of "non-linear" implies that such ad ditxoD of components 
will not be generally accurate). While it may be true that elliptical 
partial differential equations can be combined linearly^ AQTR 4-72, this 
does not justify the procedure used 


this case because: 

The equation (eq. C-34, AQTR C-18) is a simplification of the 
general atmospheric equations of motion. Solutions to these 
general equations cannot be combined linearly. Linear combina- 
tions of solutions to simplified equations may easily bemore 
inaccurate than the sum of the inaccuracies of the constituant 

solutions . 



(b) The elliptical equation (eq. C-34, AQTR C-18) was not solved. 
Rather, the wind fields represent an approximation, AQTR C-21, 
to the solution of the finite difference analogue (viz. eq . 
C-35, AQTR C-18) of the elliptical equation. Thus, the wind 
fields are an approximation of an analogue to a simplification 
of the equations of motion. That equation 3-34 is a "linear" 
system says nothing about the linearity of the approximate 
solution to equation 3.35, much less about the behavior of 
the real atmosphere which is known to be non-linear. 

(3) There is no reason to believe that winds modeled at one wind speed 
can simply be "scaled up" to represent winds at another speed. Effects 
of wind speeds are also non- linear, which , by definition, implies that 
a simple scaling factor will not suffice. Higher wind speeds will affect 
such things as turbulence (and thus mixing height and stability), 
evaporation (and thus, convection) , deposition , channelling, etc. 

5.3.5. "Verification" of CTWM is insufficient. 

Because of the many problems, theoretical and practical with this 
method, there is a failure to provide insurance of scientific integrity 
of this method. The "comparison" with observations offered does not 
suffice for this purpose. This "comparison" has the following faults : 

( 1 ) Comparison of surface winds gives no indication of the reliability 
of upper level wind prediction . 

30.50 (2) Predictions of wind direction within 45° of observations (AQTR 4-72) 
(COnt) is not an assurance of the accuracy of the model. No statistical measure 
of reliability is given . No indication of the deviation of the 8% of 
the comparisons which were greater than 45° was given, nor was there any 
indication of how many of the comparisons yielded agreement within, say, 
22^° rather than 45°. 

(3) Prediction of wind speed within 30% is not an assurance of the 

accuracy of the model. Again there is no statistical index given of 

the reliability . There is no indication of whether the 16% of the 

predictions that were in error by 30% - 60% would result in under-or- 
over-predictions . 

Because of the lack of insurance of scientific integrity of the 
wind model, the results of the GPM model are suspect. Because the GPM 
model was used to determine worst-case days for RTM modeling, there is 
no assurance that RTM did, in fact, model a worst-case. Thus, the 
scientific integrity of the GPM when driven by the "composite" mode 
of the CTWM of the RTM on a day chosen by GPM is also open to serious 

5.3.6. Recommended Application of CTWM: 

To meet the requirement of insurance of scientific integrity, 
the CTWM should be applied in this manner: 

(1) Each hour of the year should be explicitly modeled. 

(2) Regional wind should be input to the model based on upper air 
station data characteristic of the synoptic situation. An evaluation 
of the daily weather maps could be used to determine what inputs, given 
the model characteristics, will result in the most realistic representa- 
tion of winds. 



30.52 ] 

(3) Local (slope) winds should be input to the model based on all avail 
able reqional wind stations and data available from oil shale sites in 
Colorado, as well as a knowledge of the characteristics of slope winds 
in complex terrain. 

(4) Regional and slope winds should be combined by the model. For 
example, input data could be modified to insure convergence of the 
approximate solutions (using, say a balance equation); known data points 
could then be held constant while the rest of the wind field is solved. 

(5) Temporal interpolation of the wind data should be done in such a 
way as to reflect the synoptic situation. Weather maps can be used 

to determine wind shifts that could be reasonably expected during periods 
for which no data are available. 

(6) The model should be verified against regional data. The results 
should be analyzed to provide some statisitcal measure of reliability, 
such as correlation coefficients. 

5.4 Improper assumptions are made in the course of modeling. 

5.4.1. Fields known to vary spatially are assumed to be uniform. 

For the regional scale applications, impacts were modeled by the 
GPM assuming a spatially uniform neutral stability for the entire 
region. AQTR 4-63. This assumption is unrealistic because: 

(1) Stability is known to vary spatially ,_2_8_' especially over complex 
terrain. 27 / 

(2) Many studies show that on an annual or seasonal basis in the region, 
the next most^ stable category (P-G category E) is more common than 
category D.- 

27 7 

The RTM was run assuming a uniform mixing depth for the entire 
region. -^.AQ TR 4-67. This is especially unrealistic over complex 

terrain as can be seen from the wide range of measured mixing depths 

for days 179-182 (AQTR table 4-21) . To the extent that low mixing heights 
were not represented, an assumption of uniform mixing height will result 
in an under-prediction of concentration, at least in some places, 
because the model assumes the atmosphere is vertically well-mixed in 
the mixing layer. Therefore, when the model mixing layer is unrealistic- 
ally deep, the model will predict excessive vertical dispersion of pol- 
lutants, thereby unrealistically reducing ground concentrations. 

The requirements of insurance of scientific integrity and a full 
and fair discussion mean that { 1) regional modeling should explicity 
simulate spatial variations in stability (2) regional modeling should 
use stability categories representative of the area, (3) spatially 
varying mixing heights should be calculated by, for example, interpolating 
from the four stations available {if this causes numerical instability 
problems, the field could be smoothed or "balanced"). 

5.4.2. Acid deposition estimates are not correlated with the sensitivity 
of receptor areas. 




Acid deposition is of particular concern in the intermountain West 
because of the extreme sensitivity (because of low buffering capacity) 
of many of the mountain lakes and streams, Lewis, Wm. H. 1982: Limno. 
Oceanoqr 27, 167-172. h full and fair discussion of significant 
impacts ' limit include a quantitative assessment of both wet and dry 
acid deposition. As discussed above, the analysis of acid deposition 
must include consideration of the effects of inversion trapping, 
valley drainage and other phenomena that can cause pollutant accumuia 
tion or prolong travel time. Because receptors vary widely in their 
sensitivity to acid deposition, impacts can only be assessed if b °th 
the rate of deposition and sensitivity of receptor areas are correlated 
Without a specific and reliable analysis of acid deposition impacts, the 
public and the decision maker cannot make a reasoned c. cision am ° n ^L j„ „. 
the alternatives without knowing what the impacts of projected emissions 
of acid-forming pollutants will be. 

Two extreme methods can be used to estimate the amount of total 
acid sulfur deposition occuring in a region. These methods braces, 
fro^ above and P below the true value of sulfur deposition . <*e «n 
use airborne S0 2 and sulfate concentrations to calc e t o.-l 
SiftTtne^e ^^irionfcal^ulatedty aLuming^ afJl aerosol 
and SO, which passes through an average rainstorm is deposited. 

Dry deposition may be estimated from the expression: 
F D = [N(S0 2 )V(S0 2 ) + N(S0 4 ) V (S0 4 )]T 

airborne SO and sulfate concentrations in terms of »eigh 
per unit volume), respectively and V(S0 2 ) and V (S0 4 ) are tn l 
Lion velocities of B0 2 and sulfate respectively Values of V^) 
and V(S0 4 ) for terrain in the west cental U.S have been P 

of average size. Thus, 

F w - (N(S0 2 ) + N(S0 4 ) ]x H x N 

where F is the total wet deposition of sulfur per unit area, H is the 
mean mixing height and N is the number of rainstorms per year with size 
qreater than some cutoff. Of course, since sulfur is fed into the 
local air parcel during extended rainstorms, this method may closely 
estimate wet deposition. 



Experience in the eastern U.S. and in Europe suggests that F w 
is about equal to F D . So as a crude approximation, in the absence 
of western U.S. data, F D may be doubled to get total sulfur deposition. 
In order to perform these calculations, background S0 2 and sulfate 
concentrations and incremental increases must be available. If only 
N(S0 2 ) is available, a lower limit on total sulfur deposition may be 
calculated from 

*Z N(SO 2 )V(S0 2 ) . 

This DEIS analysis of deposition rates is generally consistent 
with the approach outlined here. However, the draft fails to adequately 
evaluate the impact of the predicted deposition rates. 

Extensive studies nave been performed on sensitive aquatic 
ecosystems in order to determine a level of sulfur deposition which 
is "safe", that is, which is not accompanied by acidification of 
surface waters. Based on studies in Europe and eastern North taenca 
values greater than 0.5 gmS/m 2 -yr are accompanied by acidification 
of surface waters over a period of one to three decades while lower 
values may lead to acidification over a longer time scale or may 
not lead to any significant acidification. Thus, values above 0.5 
may be regarded as unsafe, whereas values below 0.5 may or may not be 
regarded as "safe"/ but are much less likely to cause significant 
adverse impacts in the near- term. 

Report of the 1982 Stockholm Conference on Acidification of the 
Environment, Stockholm, June 28-30, Swedish Ministry of Agriculture; 
U.S. Canada Memoranda of Intent on Trnnsboundnry Air Pollution, 
Report of the Working Group on Impact Assessment, February 198.1. 

In order to apply the current methodology for assessing impacts, 
one needs to determine the sensitivity of Colorado water resources to 
acidification compared to that of eastern and European aquatic systems. 
Such evaluations are generally based on the sensitivty to acidification 
of rock and soil types underlying the water resources. If the sensitiv- 
ities are comparable to those found in low buffered areas of the North- 
east such as the Adirondacks, then a value of 0.5 gm/m 2 -yr may be compared 
with the results of predictions above to determine if damaging levels 
of acid sulfur deposition are approached. 

The draft should indentify available geological surveys which 
would allow one to estimate the sensitivity to acidification of the 
underlying geology of western Colorado. If no such surveys are avail- 
able, the lack of such data should be identified as a research need. 

A second type of study which is more site-specific involves the 
direct measurement of the alkalinity of surface waters. Studies in 
the Adirondacks suggest that surface water with titratable alkalinity 
below 100 micro equivalents per liter are per liter are particularly 
sensitive to acidification. Waters with alkalinities in this range in 
western Colorado have been reported in the studies of Turk and Adams 
(Sensitivity to Acidification of Lakes in the Flat Tops Wilderness 








Area , Col 
tion and 
a I study 
have deer 
if ication 
Harte et 
those con 
provide a 
as propos 

orado, 1982), and Harte, Lockett and Schneider (Acid Precipita- 
Surface Water Vulnerability on the Western Slope of the High 
Rockies, 1982). The most significant aspects of the Harte et 
in the Galena Mtn/Mexican Cut preserve, is that alkalinities 
eased in the region over the last decade, suggesting that acid- 
is already occurring at current deposition levels." Both 
al and Turk et al report lakes with alkalinities at or below 
sidered marginal in the Adirondacks. These values should 

basis for estimating the effects of deposition rates calculated 
ed above. See Exhibit . 

Of course the calculated deposition rates should be added to those 
now being measured in the region. Measured data should be evaluated to 
determine background rates of deposition from existing sources. 

The calculation of "minimum lake pH values" AQTR 5-134, falls 
short of a "full and fair discussion of significant environmental impacts. 

40 CFR 1502.1. 

Under the assumption of identical distribution of wet and dry 
deposition, acid deposition is estimated to be "as high as 0.2 and 0.4 
g/m 2 /yr" in Flattops. AQTR 5-134. The actual rate of acid deposition 
may well exceed unsafe rates since 

a) The wet deposition rate will vary according to the distribution 
or precipitation; 

b) The location of sensitive receptors may be near or down wind 
from populated areas for which the dry only deposition rate 
is estimated to be "greater than 1 gram per square meter per 
year. " 

c) The„safe level in the Colorado Rockies may be less than 0.5 
g/m /yr, since some receptors have a low buffering capacity. 
Turk and Adams, 1982. 

5.4.3. Deposition rates fail to consider variation in precipitation 

The rough calculations which lead to the conclusion that the wet 
deposition rate "is about equal to that for dry deposition" , AQTR 5- 
131, fails to provide any information concerning the expected distri- 
bution of wet deposition. This fault is particularly significant in 
light cf the later statement that 

if wet deposition rates are comparable to dry rates... wet 
deposition values in the midst of the developed regions 
will be comparable to those measured currently in the eastern 
United States and in Europe, but deposition in wilder - 
nes s areas will be at background values. 

AQTR, p. 5-134 (emphasis added). Implicit in this statement seems to be 
an assumption that the spatial distribution of wet deposition will mimic 
that of dry deposition. Given the admission thaf'higher elevations re- 
ceive greater amounts of precipitation", AQTR 5-131, this assumption 
is particularly suspect. As noted above (4.13) the description of re- 
gional climatoloqy is too cursory to allow an evaluation of this assump- 
tion or understand what regional precipitation data are available 
for such an evaluation . 




5.5 Hydrocarbon Emissions are not Adequately Modeled. 

5.5.1 The PLUVUE model is inappropriate for this application, 
where hydrocarbon may be a significant emission. 

There is some question as to whether PLUVUE is an appropriate 
model for this application at all. The User's Guide states that the 
PLUVUE sulfur and N0 X conversion mechanisms are "not valid... for 
sources of significant quantities of reactive hydrocarbon" because 
PLUVUE does not contain the appropriate equations. The emission in 
ventories used for the oil shale industry report significant emissions 
of hydrocarbon both in plant operation and in storage and transport 
activities, related to the plant operation. 

In additi 
fugitive emiss 
Oil and Gas We 
emissions was 
ject-related f 
("tank farms") 
sources cf fug 
accounted for 

on, studies of oil and gas wells have shown significant 
ion of hydrocarbons, with concentrations of non-methane 
being on the order of 40 ppm. Emissions of Producing 
lis, EFA 908/4-77-006. Since the major cause of these 
found to be leaking valves, it can be expected that pro- 
acilities such as pipelines and oil storage facilities 

as well as the projects themselves will be significant 
itive hydrocarbons. These sources should be explicity 
in visibility modeling. 

Scientific integrity must be insured by 1) an evaluation of PLUVUE's 
ability to predict visibility impacts in a region with the type of hydro- 
carbon emissions that canbe expected and 2) a modification of PLUVUE to 
incorporate expected hydrocarbon reactions or use of a more appropriate 

5.5.2. The EKMA Model is not properly applied in the oil shale 
region . 

The prediction of 3 is strongly affected by the concentra- 
tion, rate of emission, and reactivity of hydrocarbons. Killus and 
Whitten, SAI publication It 81245. Despite the fact that large amounts 
of "fugitive" hydrocarbon can be expected from oil shale developments, 
the chemical mechanics used in this application of EKMA was for "rural 
area. . .involving methane, CO, and trace organics such as naturally 
emitted terpenes . " AQTR 4-74. After development, the region, at least 
with repect to ozone formation, cannot realistically be described as 
"rural" nor can re-active hydrocarbons emissior be handled by a chemical 
mechanism designed only for "trace organics." A full and fair discussion 
of significant impacts must include modeling which realistically pre- 
dicts the effects of the expected emission of hydrocarbons. 

5.6 The modeling used methods which are one-sided and tend to 
predict unrealistically small impacts. 

The EIS justifies setting confidence "bounds" by an assertion that GPM 
is "conservative," i.e. that it predicts unrealistically large concen- 
No studies external to this EIS are cited to support this 
There is some discussion of the theoretical reasons leading 
one to expect the model might over-predict. There is no balancing dis- 
cussion of factors which would lead to an opposite conclusion, such as: 

trations . 





nclude certain terrain-constraining 
valley trapping and channeling , 

cts of the interactions of plumes-; 

s application, where terrain may play 
na and where urban (notably. Grand 
cant contributions to emissions and 
h theoretical reason to expect GPM 
concentrations. The requirement that 
discussion" of impacts, 40 CFR 1501.1 
ion of both possibilities necessary. 

(1) failure of the GPM model to i 
or concentrating effects, such as 
effects-,— and 2) synergistic effe 
especially urban plumes. For thi 
a large role in transport phenome 
Junction) sources may add signifi 
conversion rates, there is as muc 
to under-predict as over-predict 
the EIS provide a "full and fair 

(emphasis added) , makes a discuss 

It is asserted that the GPM method of steering puffs at their cen- 
troid results in an over-prediction of concentrations because puffs are 
modeled as being unrealistically coherrent. AQTR 5-2. However, there 
are cases in which an explicit modeling of puff divergence could re- 
sult in higher concentrations of pollutants. The Gaussian assumption 
may be more diversive than a breakdown of cohesiveness . If in the atmosr 
phere, a splitting of plumes occured, while each sub-plume nevertheless 
retained its identity (with less than Gaussian dispersion,) local con- 
centrations could be higher than that predicted by GPM. If divergent 
sub-puffs from different sources mixed, optimal chemistry might result 
in larger concentration of reactive pollutants than concentrations 
predicted from Centroid-steered coherent puffs (which might never meet) . 
(see 5.2.1) . 

The requirement of a full and fair discussion means that the EIS 
must discuss circumstances in which GPM will result in under-pre- 
dicting circumstances of the models when drawing conclusions concerning 
liklihood of exceedences. 

6. Conclusion 

The Uintah DEIS fails to comply with statues and regulations gover- 
ning its prepartion and contents because; 

1) It does not "provide information that is useful in restoring, 
maintaining and enhancing the quality of the environment. 
42 USC 4332 (G; 

(2) It does not "provide full and fair discussion of siginificant 
environmental impacts." 40 CFR 8502.1. 


It does not Drovide information "necessary to understand the 
effects of the alternatives.' 40 CFR 1502.15 

It does not "insure the professional integrity .. .of the dis- 
cussion." 40 CFR 1502.24. 

It does not "identify... methodologies.. .[or] make explicit 
reference... [to] sources relied upon .. . 40 CFR 1502.24. 

Repectfully Submitted by: 


Richard Hughes 
Legal Intern 




Wall Stree t Journal . "Saudis to Hold Oil Price at $34 Despite Slump." 
15 September 1982. p. 35. Also; In the United States, 1980 oil 
consumption has dipped slightly below consumption levels of the 
preembargo period in 1973 (34.8 quad BTU in 1973 and 34.3 quad BTU 
in 1980) . (Source 1981 Statistical Abstract of the United States, 
1981 Abstracts, fig. 991). 

In the residential sector, demand for fuel oil and kerosene for home 

heating has dropped 22 percent between 1979 and 1980. (1981 Abstacts, 
fig. 997) . Additionally, oil used for electricity production has 
also decreased. The table below illustrates the trends. 


Percentage of Total 

Year Electric Energy Produced 

1970 11.9 

1975 15.1 

1976 15.7 

1977 16.8 

1978 16.5 

1979 13.5 

1980 10.7 

(Source: 1981 Abstracts, fig. 1011.) 

Net Generation by Oil 
(bil. kWh) 



In the transporation sector energy consumption is roughly the same 
as 19 75. Even though 26.1 million more vehicles were registered 
in 1980 than 1975. In 1975, energy consumption was approximately 
17.5 quads. While in 1980, 18.0 quads were consumed. (1981 Abstracts, 
figs. 1079 and 995.) In part, the trend towards reduced energy 
consumption can be attributed to technological improvements as well 
as price and income effects of the price increases for petroleum. 
(Between 1973 and 1980 oil prices have risen by a factor of 3.2 in 
constant 1972 dollars) Source: 1981 Abstracts, fig. 1001. 

The table below illustrates this trend: 

(Units: Average Million Barrels Per Day) 

Input to 

Domestic Demand 





Oil Products 





































♦Figures are based daily average for first half of 1981. 
Source : 1981 Statistical Abstract of the United States 
Department of Commerce. 

See WSJ . "Exxon Scuttles Oil Shale with Tosco Corp." 4 May 1982, p. 3. 
Also ; Western Colorado Report "Fortnightly Wrapup' 1 10 May 1982, p. 3. 

Office of Techonology Assessment, 
(Washington, D.C., 1980) p. 16. 

An Assessment of Oil Shale Technologies 

Charles Gray, jr. and Frnak VonHippel "The Fuel Economy of Light Vechicles 
Scientific American May 1981, Vol. 244, No. 5, pp. 48-59. 


Design Improvements includes reduction in vehicle weight, reduced aero- 
dynamic drag , and power train redesign. For more detailed description 
see Solar Energy Research Institute. A New Prosperity: Building A 
Sustainable Energy Future . (And over , Mass . * Brick House Publishing, 1981) 
p. 300. See Scientific American Vol. 244, No. 5, pp. 51-56. Also see 
Julius Marwood. MIT Technology Review. "Automakers Lighten the Load" . 
July 1981. pp. 60-67 . 

Demographic changes include matching future car design with anticipated 
family size, ages, and driving patterns . See Scientific Americ an 
Vol. 244, No. 5, p. 51. 

Scientific American, May 1981, p. 48. It should be noted that invest- 
ments in these measures are cost-effective. See p. 58. 

p. 49. 


According to Gray and VonHipple ( Scientif ic American, May 1981) 15 per- 
cent of U.S. oil production is from Alaska. In 1980, the roughly 
1.5mbbl/d from Alaska has a BTU content of 8 . 7 E12/day (Assumes 
5.8E6 BTU/bbl (Energy Data Card, Energy and Resources Group, Univ. 
of CA, Berkeley, 1981) and 42 gallons per barrel. Gasoline is 
assumed to have a BTU content of 125,000 BTU/gal. (Energy Data 
Card) or 5 . 3E6BTU/bbl . If energy savings are 2mbbl/d, then fuel 
savings are 1.83 greater than the energy content of TAPS.) 

SERI. 1981 p. 304. Congressional Budget Office. Fuel Economy Standards 
or New Passenger Cars After 1985. (CBA: DC Dec. 1980) . 


Scientific American May 1981 p. 59. 


Ibid., p. 57 

14 0TA. 1980 p. 218. 

15 A synthetic crude is produced by adding hydrogen to crude shale oil. 
(OTA 1980 p. 3) . 


National Energy Conservation Policy Act (NECPA) , Pub. L. No. 
95-619, 92 Stat. 3206 (1978); Federal Register Vol. 44 No. 
217,7 November 1975 

Tennessee Valley Authority. Program Summary. Division o f Energy Con- 
servatio n and Rates . (Knoxville, Tenn: April 1981); "Utility and^Power 
Picture: Northwestern States Develop Energy Conservation Programs , 
Building Energy Progress . Jan/Feb 1980. 

18 -,„■,,, 

"California Orders its utilities to 'Unsell' Energy, Business Week, 
26 May 1980; "Financing the Solar Transition, A Report to the Califor 
nia Legislature", (Sacramento, CA 2 January, 1980). 


General Public Utilities Corporation, 
ment Master PI in". 28 March 1980. 

"Conservation and Load Manage- 


;. Department of Energy (DOE). Energy Performance Standards for New 
Buildings. Notice of Proposed Rulemaking and Public Hearings . November 
1979. Section 2. 


Lawrence Berkeley Laboratory (LBL) , University of California Evalua- 
tion of Residential Building Energy Performance Standards . (LBL-9816) . 
December 1979. 


For an excellent summary see Solar Energy Research Institute, A New 
Prosper ity: Building A Sustainable Energy Future . (Andover, Mass.: 
Brick House Publishing, 1981) Introduction and Chapter 1. 

"council on Environmental Quality, Global Energy Futures and the Carbon 
Dioxide Problem (Washington, D.C., January, 1981). 


System Application, Inc. Final Report: Prevention of Significant Deter- 
ioration Policy implications for Projected Oil Shale Development. SAI 
it 8127 4, 6 November 1981. 

Start, G.E., L.R. Dickson and L.L. Wendell, 1975: Diffusion in a 
Canyon Within Rough Mountainous Terrain. J. Appl. Meteor. 14, pp. 333 34b. 

Lewis, Wm. M. 1982: Changes in pH and buffering capacity at lakes in 
the Colorado Rockies. Limnol . Oceanogr . 27, pp. 167-172. 

and M.C. Grant, 1980: Acid precipitation in the western U.S., Science 
207 , pp. 176-177. See Exhibits 1, 2 and 3. 

Radion Corp., 1977: Emissions of Producing Oil and Gas Wells. EPA 

Rio Blanco Oil Shale Co. Final Baseline Report; Cathedral Bluffs First 
Year Environmental Report; Union Oil PSD Application for Upgrading 
Plant — meteor logical report. 


Turner, Bruce D. , 1970: Workbook of Atmospheric Dispersion Estimates. 
U.S. Dept. Health and Human Services, Public Health Services Pub. 1999- 

Guidline on Air Quality Models, U.S.E.P.A. EPA-450/2-78-027 . 



Wilson, William E . , _e£ .a± . , 1977: Sulfates in the Atmosphere, Research, 
Traingle Park, North Caroling, U.S.E.P.A. Publications No. EPA-600/7- 

Zeedijk, H. and CA. Velds, 1973: The Transport of Sulphur Dioxide Over 
a Long Distance. Atmospheric Environment 7 , pp. 849-869. 


Goodin, William R. , Gregory J. McRae and John Seinfeld, 1979: A Com- 
parison of Metropolitan Methods for Sparce Data, J. Appl. Meteor 18 
pp. 761-771. 



A. Longhetto, ed. Atmospheric Boundary Layer Physics, "Gravity Haves 
and the Atmospheric Boundary Layer", F. Einaudi.' Elsevier Scientific 
Pub. Co., 1980. 

Environmental Defense Fund 









The Uintah Basin Synfuels Development EIS and supporting technical 
documents provide information that is useful in restoring, 
maintaining, and enhancing the quality of the environment. The BLM 
position is supported by responses to the more specific comments 
provided by the commenter. 

The EIS provides full and fair discussion of significant impacts. 
Regarding the alleged omissions, refer to the responses to Comments 
30.36 and 30.37 concerning the commenter 's item 1; response to 
Comment 30.44 for item 2; responses to Comments 30.52 through 30.54 
for item 3; and response to Comment 30.43 for item 4. 

As discussed in the responses to Comments 30.14 through 30.32, the 
EIS provides information necessary to understand the effects of the 

As discussed in the responses to Comments 30.33 through 30.58, the 
EIS provides accurate scientific analysis of impacts based on 
available high quality data and sound scientific methods. 

The EIS complies with federal statutory and regulatory requirements. 
As discussed in the responses to Comments 30.6 through 30.58, the 
allegations about deficiencies are invalid or the deficiencies have 
been remedied. 

Considering development of alternate fuel sources is beyond the scope 
of the EIS. The purpose of this EIS is to analyze the impacts of oil 
shale and tar sand development projects and alternatives that would 
achieve the same objectives of these projects. In all cases these 
objectives are to develop the oil shale/tar sand resources of the 
Uintah Basin for which the applicants are requesting federal 
rights-of-way. None of the leases are federal oil shale leases, but 
rather State of Utah leases that have already been issued. It is 
also beyond the scope of this EIS to consider alternative locations 
of C-ll and C-18 leases and other projects that are not permitted or 
under construction. The Supplemental Environmental Impact Statement 
for the Prototype Oil Shale teasing Program (BLM 1982d) analyzes the 
impacts of alternative federal Je«e locations. Environmental impact 
analyses prepared for other projects would analyze alternatives for 
these projects. 

The Uintah Basin Synfuels Development EIS Is not the proper forum to 
discuss national policy alternatives. Regional development 
alternatives are discussed In the Federal Oi l Shale Management 
Program EIS (BLM 1983). 

Evaluating the nation's need for liquid fuels and the effect of 
energy conservation on that need is beyond the scope of the EIS. 
EIS includes an analysis of the energy efficiency of each of the 
site-specific projects, a factor which the decision maker will 
consider when making decisions on the rights-of-way applications. 



i — ■ 

30.8 The purpose of this EIS is not to conduct a regional analysis. The 
use of the Draft EIS term "regional" in reference to the cumulative 
impact analysis for the nine proposed projects proved to be 
misleading to readers. The term has not been used in the Final EIS 
to avoid this confusion. 

It should be noted that this EIS is not a leasing or mine plan 
approval EIS; it was initiated as a result of requests for federal 
rights-of-way (refer to the EIS Preface). The Federal Oil Shale 
Management Program EIS (BLM 1983) analyzes the impacts of new 

The response to Comment 16.4 explains the purpose of the nine-project 
cumulative analysis and why a "regional" no-action alternative is not 

CEQ regulations do not require that alternative cumulative impact 
analysis scenarios be addressed. However, two levels of cumulative 
impact analysis are presented in this EIS, because there is concern 
whether all projects would be developed to the levels proposed within 
the given time frames (refer to Section R-l.C). The high-level 
scenario, based on the applicants' full production, represents a 
worst-case situation. The low-level scenario, which considers a 
cumulative production level about one-half the size of the high-level 
scenario, represents a potentially more probable regional production 
level and level of impact. Since a worst-case and potentially more 
probable case are presented, this is considered to be a reasonable 
review of the range of cumulative impacts. 

Alternative locations of some major project components were 
considered for each site-specific project. Alternative locations for 
project mines and processing plants are not considered, because each 
applicant has received approval from the State of Utah to mine these 
lands based on the fact that leases have been granted. 

Alternative production capacities, including the no-action 
alternative, are considered for all site-specific projects. Full 
production is analyzed as the proposed action and as part of the 
high-level scenario. A lower production level is analyzed as part of 
the low-level scenario. 

Alternative processes have been evaluated where they are considered 
to be viable options by the applicants. Alternative emission control 
strategies will be evaluated by the Environmental Protection Agency 
and/or by the respective state air quality agencies as part of the 
Prevention of Significant Deterioration permitting process. Approved 
projects will be required to use best available control 

30.9 BLM has no control over the lease tracts on which the applicants' 
mines would be located, because they are state lease tracts. The 
State of Utah has already granted each applicant the right to develop 
the land by issuing the mineral leases. 

BLM has no authority to impose siting restriction in order to control 
air emissions. However, EPA and/or the respective state air quality 
agencies can and will impose such restrictions as part of the 
Prevention of Significant Deterioration (PSD) permitting process if 
the restrictions are appropriate. No project will be able to proceed 
without a PSD permit. 

30.10 To the extent that it is possible and notwithstanding deficiencies in 
the meteorological data bases, BLM has attempted to achieve in the 
study the same things suggested in the comment. The regional 
modeling methodology employed focuses on transport to Class I areas 
and encompasses the full range of terrain variations within the 
region. However, it should be noted that this EIS does not address 
tract selections or lease conditions. The developments being 
evaluated are on state leased lands. The analysis is for 
developments or, already leased state lands which require BLM rights- 

30.11 The best available data have been used to estimate emission rates. 
Because there are currently no commercial size oil shale or tar sand 
facilities, there is considerable uncertainty as to the magnitude of 
actual emissions for each technology. Although it may be desirable 
to analyze a broad range of technologies, with the uncertainties in 
emission rates, such an analysis would introduce many additional and 
complex variables thereby confusing the issues directly associated 
with the projects as proposed by the applicants. Each applicant has 
a specified (and to some extent proprietary) interest in and 
rationale for the choice of technologies proposed; therefore, 
technology change alternatives are not considered viable at this time 
for the projects in question. 

30.12 The development of the emission inventories that were used in the EIS 
analysis is explained in the Air Quality Technical Report. The 
explanation has been expanded in the final technical report. The 
control systems proposed are explained in the applicants' technical 
reports and/or the PSD permit applications of those applicants that 
have begun or completed the PSD permitting process. However, it 
should be noted that there are no prototype tracts involved in this 
EIS except for the White River Shale project, which was included as 
an interrelated project for the purpose of assessing cumulative 

30.13 A discussion of measures that could be used at various synfuel 
facilities to mitigate the impact of emissions to the atmosphere has 
been added to EIS Appendix A-7 and the Air Quality Technical Report 
(Appendix E). The effect of a proposed mitigation measure can be 
determined if the specific design is known. Ground-level 
concentrations are roughly proportional to the mass emissions rate of 
the given pollutant if stack parameters, such as flow rate, 
temperature, and stack height, do not change. Except for such 
generalities, however, specific comments concerning the air quality 
impacts of alternative mitigation measures cannot be made at this 
time. Refer also to the response to Comment 30.11. 


30.14 As discussed in the responses to Comments 30.15 throjgh 30.17, the 
EIS provides sufficient description of the existing environment to 
understand and evaluate the impacts of the proposed projects. 

30.15 Tables R-3-6 and R-3-7 have been significantly revised. (The 
comparable tables in the technical report have also been revised.) 
The reliability of the data is evaluated in quality Assurance 
programs in which each monitoring organization participates. 

30.16 The Gaussian puff model was used to model the 1980 baseline annual 
average sulfur dioxide concentrations. Available measurements of 
baseline sulfur dioxide concentrations are also presented in the 
revised Table 2-3 of the Air Quality Technical Report and Table 
R-3-6 in the Final EIS. The text of the Final EIS (Appendix A-5) 
has been expanded to clarify the use of modeled and monitored 

30.17 Section R-3.A.2 has been expanded to more thoroughly consider 
precipitation patterns and other climatic factors. 

30.18 The process used in developing the emission estimates used in the EIS 
air quality analysis was explained in the Draft Air Quality Technical 
Report. An expanded discussion has been made in the Final Air 
Quality Technical Report. It should be recognized that uncertainty 
exists as to the emission source terms, because no commercial scale 
synfuel development is presently in operation. Actual emission 
measurements that presently exist have been made only for pilot- or 
bench-scale facilities. Thus, emissions from a full-scale operation 
have not been fully characterized and a number of uncertainties 
exist, particularly in the area of particulate and organic 
emissions. These emissions are strongly dependent on both the exact 
processing conditions and on the type of abatement equipment used. 
Therefore, a more rigorous evaluation of these types of emissions 
will have to wait for the operation of the first commercial scale 

Every effort was made in the air quality study by Systems 
Applications Inc. to obtain currently accurate emission inventories 
at the time the study was begun. These data can be expected to 
change by the time potential sources apply for a PSD permit in the 
regulatory permitting process. Applicants have changed emission data 
several time during the course of the PSD permit application review. 
As it turns out, emission values used in the EIS modeling study were 
generally higher; and, therefore, the analysis is expected to be 

30.19 The discussion of data sources and methodology has been expanded in 
the final technical report as discussed below and in the responses to 
Comments 30.20 through 30.25. 

The average operating conditions assumed for developing the 
inventories means that variations in normal operations from hour to 
hour, day to day, and month to month were averaged in arriving at 
emission rates for point and area sources. Equipment upsets were 
also not used to modify the emission rates. This is a typical 
procedure commonly employed in deriving emission inventories. 

Full production conditions--100 percent design capacity--were used to 
estimate all the components in the inventories. Unlike the variable 
effects of a malfunction, full capacity can be quantified and thus 
was used to derive the inventories. The effects of nonaverage 
conditions such as startups and malfunctions are covered during the 
permit review process by air pollution control agencies. The 
explanation has been added to the Final EIS (Appendix A-5). 

30.20 Mitigation proposed by applicants and mitigation committed to and 
enforceable by an authorizing agency are assumed. To assume that any 
unenforceable mitigation would be implemented would not present a 
true picture of potential impacts. Since mitigation lessens impacts 
to include uncommitted mitigation would present a "rosier" picture 
than might actually occur. This would be misleading to the public 
and the decision maker. 

30.21 Section 4.1.1 of the Air Quality Technical Report discusses the 
development of some of the final emission data; other sections 
(Sections 4.1.4 through 4.1.9 ) discuss area source-data 
development. For the projects, the major processes were reviewed, 
resulting in emissions, emission factors and control technologies, 
and other descriptions of each project. This information was then 
compared among the projects, to other oil shale/tar sand facilities, 
to reports on comparable sources, to data on control technologies, 
and to documentation on emission factors. As indicated, the final 
data set employed experience and judgment to derive the inventories. 
Refer to responses to Comments 30.23 and 30.25 for more information. 

30.22 An order of magnitude estimate of the uncertainty in the overall 
inventory might be approximately plus or minus 50 percent--a value 
comparable to the inventory uncertainty in any complete set of 
emission estimates covering a region of hundreds of kilometers. 
Specific components of the inventory, such as each project, would 
probably have a lower level of emission uncertainty. The reasons for 
inventory uncertainties are complex and not well understood; the 
above estimates are simply based on experience in developing and 
using emission inventories. 

Experience also indicates that true emission rates sometimes exceed 
inventory estimates. This is because sources are added to 
inventories over time, revisions to emission factors generally 
increase those factors with new information, and as more detailed 
data become available, they tend to result in increases to the older 
estimates. Refer to Section 4.1.10 of the Air quality Technical 
Report for more related information. 


30. 23 Engineering judgment is always employed in a study such as this 
throughout the entire project. This is because choices always exist 
in selecting emission factors, estimating the effects of controls, 
selecting operational conditions and levels, and similar parameters. 
These parameters are often available as ranges necessitating a 
selection process. Furthermore, should 92 percent control be 
selected when knowing the technology can meet that efficiency almost 
all the time; or should 97 percent control be selected when knowing 
the equipment can achieve that efficiency, the risk of equipment 
failure is higher at that level, but 97 percent may not be achieved 
on a long-term basis? One choice underestimates and the other 
overestimates emissions under certain conditions. This is the type 
of engineering judgment that is always needed and is based on 
professional and scientific experience. Refer to the discussion on 
fugitive dust emission factors (technical report Section for 
an example of the use of engineering judgment. 

30. 24 Many projects had 70 percent or more of their emissions (by 
pollutant) associated with one or two points; the remaining 30 
percent was associated with 10 to 50 individual points at each 
project. Many of the smaller emission points were co-located, 
ground-level emitters; other points were also co-located or placed 
within 0.2 km of each other with nearly identical stack data. In 
such cases, the smaller emission rates were consolidated into like 
emission points during the regional modeling efforts to reduce the 
complexity of the modeling activities. For example, a point located 
at UTH coordinates 663.3, 4432.4 km with a stack height, diameter, 
velocity, and exit temperature of 10 m, 0.5 m, 12 m/s, and 400 
degrees k, respectively, was consolidated with a point located at UTM 
coordinates 663.3, 4432.3 km with stack parameters of 10 m, 0.7 m, 15 
m/s, and 400 degrees k; average stack data were then specified for 
the point. Points were not moved more than about 0.3 km; 
ground-level and elevated points were never aggregated; and large 
sources were not consolidated. Considering the precision inherent in 
the locations and stack parameters of the projects at this 
preliminary stage, the consolidation process used for all the 
criteria pollutants had little or no effect on modeling results. 

30.25 Engineering judgment was used to derive emission estimates for the 
conceptual projects from the documentation provided by the 
applicants. However, judgment was also used throughout the entire 
inventory process for all projects and area source emission 

As indicated, overall inventory uncertainty may be plus or minus 50 
percent— typical for this type of inventory. More information would 
be necessary to estimate error bounds for specific components of the 
inventory. Refer to the response to Comment 30.24 for further 

30.26 During the study, Systems Applications Inc. carefully analyzed about 
25 existing sources in Uintah and Grand counties that had been 
reviewed by the State of Utah staff and documented in their files. 
Each source was reviewed by Systems Applications Inc. for its 
processes and likely emissions. Most of these sources had emissions 
ranging from approximately 0.5 to 5 kilograms per hour; the lypical 
emission rate was about 1 kilogram per hour. The types of point 
sources covered a broad spectrum, including quarries, pipelines, 
storage tanks, and associated fuel combustion activities. 

These sources were handled by the procedures used to establish the 
area source files. For example, Systems Applications Inc. obtained 
data on the amount of fuel used by stationary sources in Grand and 
Uintah counties. Emissions were calculated on the basis of this 
information and placed in the area source files. Thus, "point" 
sources documented in the State of Utah files were included in the 
area source files for this study (except the Plateau refinery). This 
is also consistent with the common definition of a point source — a 
facility with emissions greater than 100 tons per year. 

30.27 As a result of the evolving state of the synfuel industry's project 
plans, emission estimates are continually changing. Oue to the study 
schedule, emission estimates for the project applicants are current 
as of January 1982. However, we note that the differences in 
emissions for Magic Circle as discussed in the reviewer's comment are 
small and are well within the uncertainty of the emission estimates. 

Although the most recent THC emission estimates are a factor of 6 
higher than given in the Air Quality Technical Report, they are still 
quite low compared to other proposed synfuels projects and a very 
small fraction of regional THC emissions (see Tables 4-1 and 4-3 in 
the Final Air Quality Technical Report). Therefore, this increase in 
THC emissions is not significant. 

30.28 The concept of "normalizing" emission estimates for the same 
pollutant from similar sources is an overly simplistic and 
unscientific approach to assessing source emissions and controls. 
Simply stated, alternative process and control technologies are in 
fact the explanation for differences in emission rates. For example, 
even for a process type which is well known and well documented, 
uncontrolled emission factors for fluid catalytic cracking units 
(from the EPA report AP-42) vary substantially for N0 X (37 to 145), 
SO2 (100 to 525) and particulate (93 to 340) in units of pounds of 
pollutant per thousand barrels. Moreover, the range in emission 
factors becomes even greater when different types of catalytic 
crackers are considered (such as fluid versus moving-bed). 

Furthermore, emission controls introduce a multiplicative effect on 
the range in emission factors. Each project applicant proposes 
different types of control with varying levels of reduction. Such 
differences often result from the fact that some controls are not 
applicable to certain processes. These varying control levels are 
also acceptable to regulatory agencies as best available control 
technology (BACT), because regulators recognize that the definition 

of BACT inherently permits tailoring of control technology (and the 
conversion efficiencies resulting from such equipment) to an 
individual source. 

As explained in Section 4.1.1, fuel sulfur and nitrogen levels also 
vary in the fuel burned in heaters and boilers, which affects 
emissions even on a per unit of production basis. Thus, because 
processes and controls are unique, emission rates will differ for 
sources employing alternative equipment. 

30.29 Colorado and Utah baseline (and projected) emission totals for the 
study region differ, because sources in each region are completely 
different. For example, 1980 population in the Utah portion of the 
study region is 28,747, whereas in the Colorado portion 1980 
population is 123,432. Figure 1-1 also shows the different area of 
these two oortions of the study region. Thus, there is no 
inconsistency among the different emission totals. 

Regarding variations in project emissions and the concept of 
"normalization," refer to the response to Comment 30.28. 

30.30 Section 4.1 points out that average operating conditions were assumed 
in developing the emission data. The term average in this case 
refers to normal source operations rather than production capacity. 
The emission estimates were developed at full production capacity for 
each of the project applicants on the basis of average operations. 

^O For example, the effect of malfunctions in source operations was not 

factored into the emission rates. Normal daily changes in area 
source emissions, such as from day-to-day changes in motor vehicle 
use, were also not considered in the development of the emission 
data. Uncertainty in emissions was likewise not added to the 
emission inventory. However, use of the term average is not 
synonymous with the term full capacity, since emission estimates were 
developed for full production conditions as indicated in Table 4-1, 4- 
2, and 4-5. 

It is inappropriate to use emissions representative of "upset" 
conditions to analyze worst-case impacts, because the applicants' 
stated maximum emission rates (used in this analysis) will be those 
upon which each source is permitted to operate. PSD permits will 
require that sources curtail operations during periods when equipment 
is malfunctioning. The probability that an increased emission rate 
would coincide with a period of adverse meteorology is approximately 
the product of the probability of each event, a very unlikely 

30.31 The only new interrelated project listed in Table R-l-2 and Table 
R-l-3 which depends on the development of the proposed oil shale 
projects is the White River Dam. That dependency is described in the 
White River Dam EIS dated May 1982. Construction of the second unit 
of the Bonanza power plant may or may not depend on oil shale 
development as it may reflect aspects of broader marketing 
considerations. Potential expansion of the Plateau refinery probably 
depends on the development of Utah oil shale or tar sand projects. 
No other interrelated projects are dependent on construction and 

operation of the nine proposals which are the subject of this EIS. A 
discussion of the no-action alternative is included in the EIS in 
each of the site-specific project analyses. See also the response to 
Comment 30.8. 

30. 32 The Uintah Basin Synfuels Development EIS is based on a sequential 
concept, in that it treats impacts from known and eminent projects, 
a separate EIS will treat any additive impacts from potential 

new federal prototype oil shale leasing in Colorado, and another 
separate EIS will treat additive impacts from a potential permanent 
federal oil shale leasing program. These documents are interrelated 
by reference. For example, page 109 of the Draft EIS for the 
Prototype Oil Shale Leasing Program states "Scenarios and emission 
factors used the Uintah Basin Synfuels EIS and the Programmatic Oil 
Shale EIS have been incorporated into the prototype analysis." To 
repeat the prototype analysis in the Uintah Basin Synfuels EIS would 
be duplicative and counter to the intent of Council on Environmental 
Quality regulations, which encourage concise EIS documents, 
"tiering," and "referencing." A "full and fair discussion" is 
included in the Uintah Basin Synfuels Development EIS as related to 
the issuance of federal rights-of-way for the projects identified 
therein. Please see the separate EIS noted above for discussion of 
impacts from potential federal prototype leasing. Also see response 
to Comment 27.9. 

30.33 Our goal was to conduct realistic worst-case studies of air quality 
impacts on the basis of available emissions and meteorological data 
and advanced, state-of-the-art air quality models. In the air 
quality analysis work, realistic worst-case analyses were used to 
determine whether air quality standards or Prevention of Significant 
Deterioriation increments, many of which refer to worst-case, maximum 
concentrations (or concentrations that cannot be exceeded more than 
once per year), would be met or exceeded. Thus, by the very nature 
of the analysis, worst-case conditions had to be considered. Since 
information was indeed available regarding meteorological conditions 
in the region, an extreme worst-case analysis based on postulated 
wor&t-case meteorological data is neither warranted nor appropriate. 
Although state-of-the-art air quality models were utilized in the 
analysis, there still is considerable uncertainty in the results. 
This uncertainty was explicitly recognized in the study and was 
quantified with estimated ranges of concentrations, including 
conservative, upper-bound estimates and lower -bounds on worst-case 
concentrations. Although the EPA has approved a screening model 
(VALLEY) for complex terrain, there are no EPA-approved models for 
regional analysis in complex terrain. The modeling performed for 
this EIS was performed recognizing this and was based on advanced 
state-of-the-art models. 

30.34 The worst-case days are indeed pollutant specific. Different 
worst-case days are specified for TSP and SO2 for GPM. RTM was run 
on four worst-case days for SO;?. This information has been added 
to Section 5 of the Air Quality Technical Report and Appendix A-5 of 
the EIS. 



30.35 Certainly it would be advisable to investigate a large number of 
historical years in determining the worst case. Several years of 
meteorological data (wind and persistence roses) were examined to 
determine that 1978 was not an atypical year, and consequently would 
contain typical worst-case conditions. Regardless of the year 
selected, some chance that a more severe worst-case might occur will 
remain. Furthermore, it was considered important to use the most 
recent year for which sufficient data were available and that was not 
considered atypical. The EPA regional meteorologist concurred that 
1978 appeared to be a representative year and cautioned against the 
use of the 1976 and 1977 drought years. 

GPM was used in a fashion that permits the explicit treatment of 
limited mixing and impact on terrain. These two are probably the 
most likely critical plume behavior characteristics given the source 
types, terrain involved, and location of critical receptors. 

30.36 Visual effects were modeled assuming a line of sight perpendicular to 
the plumes from the proposed developments in the Uintah and Piceance 
basins. This is an EPA-recommended practice for evaluating worst- 
case visibility impairment (see Workbook for Estimating Visibility 
Impairment , pages 27 and 30). As noted in the EPA visibility 
workbook, visual impacts are greatest for perpendicular, rather than 
oblique, lines of sight because the distance between plume material 
and the observer is shortest for perpendicular lines of sight. 

The comment is made that the analysis is not a worst-case analysis 
because a mid-July day, not June 21, the day with maximum UV flux, 
was used. However, the difference in UV flux between mid-July and 
June 21 would have an insignificant effect on aerosol production and 
resultant visibility impairment. The analysis is a reasonable worst- 
case analysis because several inputs, such as mixing depth and wind 
speed, were specified in an extremely conservative manner (as 
discussed in Section 5.6.2 of the Air Quality Technical Report). 
Performance of sensitivity analyses to determine the date/time of 
maximum impact is judged to be not necessary, since an extremely 
adverse combination of mixing depth and wind speed was assumed, as 
discussed in the Air Quality Technical Report. 

A C-stability class was selected, because this stability class is_ 
representative of the dispersion on a summer day. Aerosol formation 
is at a maximum rate during summertime, well-mixed conditions; 
specification of D or E stability would have resulted in a smaller 
calculated impact, not a worst-case impact. For regional haze 
situations, visual range reduction is primarily a function of wind 
speed, mixing depth, and aerosol flux. The commenter is correct in 
stating that more stable conditions than C stability should be 
specified for the worst-case visual impact (plume height) of nitrogen 
oxides. This was in fact done in the Level-1 tests and in the 
frequency of occurrence analysis reported in the Air Quality 
Technical Report. E- and F-stability classes were selected for plume 
discoloration calculations. 

A relative humidity of 40 percent was used in the modeling analysis. 
The observer in Flat Tops Wilderness was assumed to be located on Big 
Marvine Peak. 

30.37 A discussion of existing ozone levels and measured O3 data has been 
added to Section 5 of the Air quality Technical Report. 

Although the photochemical model used is the basis of the EKMA 
procedure, the EKMA procedure was not applied in this study. The 
model was used as a means to quantitatively describe the impacts of 
future oil shale development, not requirements to reach NAAQS. 
Therefore, the EKMA guidelines need not be followed to perform 
simulations on the five worst-case days. Also, the straightline 
trajectories were chosen such that all oil shale emissions are 
accounted for. Thus, five different trajectories would not lead to 
significant differences in model predictions. 

The Killus reference has been changed. 

30.38 Refer to the response to Comment 30.24. 

30.39 The wind field randomization of wind direction is introduced to 
account for uncertainties in observed wind directions. The 
resolution of reported wind directions is typically at least as large 
as the plus or minus 12.5 degrees used in the GPM randomization. To 
use a single wind direction derived from upper-level soundings (which 
are representative of very short time periods) may lead to 

unreal istically low plume spread, expecially in complex terrain. For 
this reason, the concept of wind direction randomization or 22.5 
degrees sector plume spread have been used in this study as well as 
in several EPA guidelines models (e.g., VALLEY, CRSTER, COMPLEX I, 

30.40 The SO2 to SO4 conversion rates used in GPM were 1.5 percent for 
daytime and 0.1 percent for nighttime. Deposition velocities used in 
GPM were 0.5 cm/sec for TSP and 1.0 cm/sec for SO2. Mixing height 
was not used in GPM calculations. Rather, a conversion factor was 
used which was: 

deposition velocity 
plume thickness 

where plume thickness was calculated as the maximum of 4 sigma z or h 
+ 2 sigma z. The value of h was the effective plume height. 

30.41 Discussion of upper-level concentrations has been added to Section 5 
of the Air Quality Technical Report. 

The photochemical trajectory model can handle sophisticated chemical 
processes. Unfortunately, transport processes are treated in the 
model in a simplistic manner. Thus, transport processes associated 
with storm front or turbulent vertical mixing cannot be handled in a 
straightforward manner with a two-dimensional trajectory model. 




(20 km 

The comment is made that because plume chemistry is a nonlinear 
process, the linear combination of impacts from several emission 
source categories is inappropriate. It is true that atmospheric 
chemical mechanisms are nonlinear, but for this analysis it is 
conservative to assume a linear combination (addition) of individual 
plumes. This is true because in concentrated plumes, such as when 
several individual plumes overlap, the formation of sulfate aerosol, 
the principal light scatterer, is slowed because plume N0 X 
decreases the concentration of hydroxyl (OH) radicals responsible for 
the conversion of sulfur dioxide to sulfate. Thus, summing the 
contributions from individual dilute plumes will tend to overstate 
the total aerosol burden in the atmosphere. 

This conservatism can be confirmed by taking the EKMA model 
calculations of increased aerosol concentrations and computing the 
resulting visual range reduction. Using the increase in sulfate and 
organic nitrate aerosol concentrations from the 1980 baseline to the 
high oil-production scenario of 1.25 and 0.60 ug/m 3 , respectively, 
from Table 5-6{a) of the Air Quality Technical Report, the visual 
range reduction can be calculated using formulas from Latimer and 
Ireson (1980): 


T pi ume 

Using the width of the plume assumed in the EKMA model calculations 
(20 km) and a typical scattering-to-mass ratio for submicron aerosol 
nf fi x 10-6 m -l (un/rn3l up have 

(ug/m 3 


r vo 

(1000 m/km) (6 x 10-6 ra -l/( U g/m 3 )) (1.25 + 0.69 ug/m 3 ) (100%) 


» 5.95% 

This value is in basic agreement with, but smaller than, the value of 
visual range reduction calculated using PLUVUE by summing individual 
plume contributions. Thus, there is no reason to suspect that the 
approach used is inappropriate. 

30.43 The linear combination of impacts associated with industrial growth 
and associated population growth is justified since SO2 and TSP can 
be reasonably treated as conservative (nonreactive) species. To the 
extent that SOj converts to S04=, SO2 concentrations will be 
reduced and TSP concentrations increased. The S04= fraction of 
TSP is extremely small so this effect does not significantly affect 
the calculated TSP concentrations. 

Because of the high terrain between the Uintah Basin sources and 
Grand Junction, the interaction of these two source regions is not 
believed to be a reasonable scenario for analysis. It is reasonable, 
however, to expect an interaction between oil shale facilities in the 
Parachute-Roan Creek area of the Piceance Basin with the urban plume 
from Grand Junction. This interaction was not evaluated in this 
study, because the sources in the Uintah Basin, not the Piceance 
Basin, were the focus of the analysis. 

30.44 The modeling performed for this EIS utilized a regional modeling 
domain that extended far beyond the Uintah Basin where the sources 
being evaluated would be located. The study region was made 
sufficiently large to include the Flat Tops Wilderness Area, the 
mandatory Class I area identified in previous studies as receiving 
maximum air quality impacts from oil shale development. Latimer and 
Doyle (1981) showed that other Class I areas in Utah and Colorado 
would not be affected by synfuel development to the degree that Flat 
Tops would. Table C-3, which follows, is a condensation of Table 14 
from that study. Note that Flat Tops is the mandatory Class I area 
that was predicted to receive maximum SO2 concentrations from oil 
shale sources (7.1 ug/m 3 from the combination of Uintah and 
Piceance Creek basin sources). In this earlier study, Arches 
National Park was predicted to receive higher SO2 impacts than Flat 
Tops from the Uintah Basin sources, since the former is about 120 km 
distant while the latter is 140 km distant. The more recent study 
suggests that Arches National Park would receive incremental impacts 
similar to Flat Tops from Uintah Basin sources (see Air Quality 
Technical Report Figure 5-15). Arches National Park, located just 
south of the southwest corner of the modeling region, would receive 
maximum 24-hour average SO2 concentrations from Uintah Basin 
sources of about 0.4 ug/m 3 , approxmately equal to the maximum 
concentration predicted in the Flat Tops Wilderness Area. (The GPM 
calculations in the current study of concentrations in these two 
Class I areas are about a factor of 5 lower than the screening 
calculations performed by Latimer and Doyle (1981).) 

Exceedances of the Class I increment in Mount Zirkel Wilderness 
predicted by Latimer and Doyle (1981) and in the BLM Prototype Draft 
EIS are due primarily to the Craig Power Plant, not the Uintah Basin 
oil shale facilities. If detailed modeling required for PSD permits 
indicates that the Mount Zirkel increment is indeed consumed, it may 
be most appropriate to consider retrofit SO? emission controls on 
the Craig and Hayden power plants, 60 and 40 km from Mount Zirkel, 
respectively, than similar controls on the Uintah Basin sources which 
are about 240 km away from Mount Zirkel. 

The region selected for modeling air quality impacts for the Uintah 
Basin Synfuels Development EIS was a reasonable choice in that Class 
I areas with maximum impacts were evaluated, inferences could be made 
regarding impacts in other Class I areas from this and other studies, 
and the analysis considered realistically the cumulative effects of 
Uintah Basin and Piceance Basin sources. 


Maximum 24-hour Average SO2 Concentrations in Various Class I Areas 
due to Synfuel Development in the Uintah, Parachute Creek, 
and Piceance Creek Basins 

Maximum 24-hr SG7 Concentrations (ug/m 3 ) 

Class I Area 

Uintah Basin Parachute Creek Piceance Creek 
Sources Sources Sources 


Flat Tops Wilderness 
Maroon Bells-Snowmass Wilderness 
Rocky Mountain National Park 
Mount Zirkel Wilderness 
Rawah Wilderness 
Eagles Nest Wilderness 
Arches National Park 
West Elk Wilderness 
Black Canyon of the 
Gunnison Wilderness 
Colorado National Monument* 
Dinosaur National Monument* 


































♦Potential Class I area. 




Additional air quality analysis has been performed for the Prototype 
EIS since the draft air quality report was published. This 
additional analysis includes refined emission source terms 
meteorological input, and minor modification to the model to more 
realist ell" treat specific topographic and stagnation cases. BLM 
air qua ity specialists are in the process of preparing a comparison 
of the Ulntan Basin Synfuels Development EIS and Prototype EIS air 
quality analyses. 

There is no evidence that the tiered use of CTWM and GPM or CTWM and 
RTM is compromised by incompatibility. Indeed, every effort was made 
So "ensurfthelr compatibility based on modeling theory and know 
of regional transport characteristics. Selection of a GPM worst case 
episode for application of RTM does not guarantee that some o^er 
en ode might not yield higher RTM predictions However, appl cat on 
of RTM to an entire year or longer (as suggested by the commenter in 
other statements) would be very expensive and time-consuming and 
prohibited by practical EIS preparation constraints. Furthermore 
aenera lv speaking, for regional-scale 24-hour average impacts, both 
S^ and ^identify, as the worst-case those days «^h the greatest 
oersistence of trajectories from the emissions sources of concern to 
a aiven receptor Therefore, since both RTM and GPM derive wind 
direction input from the same data sources, it is likely that during 
a worst-case GPM episode, RTM would also predict relatively high 
concentrations In the vicinity. The statement by the commenter that 
"any Inaccurecy in the GPM prediction of the worst-case w,l result 
in a total failure of RTM to do a worst-case analysis" is incorrect 
and misleading. 

Verv little air quality monitoring data exists that would be useful 
for regional model verification in this or any other study area. 
Furthermore mos? of the emissions sources modeled in this study do 
not yet exist and, therefore, their impacts cannot be monitored In 
General there has not been sufficient data collected to verify the 

ormance of regional-scale models, and, therefore comparison 
models and their predictions rest on an assessment of theoretical 
aspects of model formulations and intercomparisons of model results 
(S?hock 1981- EPA 1978). A comparison could be made of RTM 
predictions using 1980 baseline emissions with air quality monitoring 
data bit it would not be a very meaningful comparison because of the 
sparse monitoring network and the very low concentration levels 

Lower and upper bounds were set, with GPM results as the upper bound, 
on the basis of considerable documentation presented in the Air 
Quality Technical Report (see Sections and b lj. since urn 
is expected to be conservative for the documented reasons and since 
Recalculations support this expectation it see* ; reaso n.ble to set 
the upper range of the estimates on the basis of GPM results ne 
lower P r1nge of the estimates for short-term averages was nominally 

and the quantitative comparison of GPM, RTM, and COMPLEX 1 
calculations. The specification of lower-range estimates s probably 
not as critical as the specification of upper range estimates, 


since few decisions in air quality management are made on the basis 
of lower-range estimates. The factor of 10 range of uncertainty was 
placed on the calculations to clearly communicate to the public that 
(1) there is uncertainty in regional air quality modeling, (2) GPH 
results are most likely on the conservative side of realistic 
expectations, and (3) actual impacts could be as much as a factor of 
10 lower than GPM results. 

30.48 Justification is provided in Section 5.1 of the Air Quality Technical 
Report for the smaller range of uncertainty for GPM annual average 
calculations: conservatism in the specification of the horizontal 
dispersion of individual puffs is cancelled out in the course of a 
year because of averaging over many puff trajectories. The factor of 
2 error range for the TSP empirical model is an estimate based on the 
observed scatter of data points around the best-fit line shown in 
Figure 2-11 of the Air Quality Technical Report. All of the observed 
TSP concentrations in the region shown in Figure 2-11 fall within a 
factor of 2 range of the best-fit line except for two outliers, where 
the best-fit equation predicted significantly higher concentrations 
than those observed. 

As noted in the response to Comment 30.46, there is considerable 
documentation and justification in the Air Quality Technical Report 
for the scientific judgment that GPM is conservative and for the use 
of a range of uncertainty for model calculations. Except for 
"turning-the-crank" exercises using the simplest of air quality 
models, scientific judgment is used in all air quality model 
simulations. BLM disagrees with the notion that the "scientific 
integrity" of the study approach may not have been "ensured." 

30.49 Refer to the responses to Comments 30.44 and 30.46. 

30.50 As stated in the Final Air Quality Technical Report, the "composite" 
mode of application of the CTWM is a carefully considered compromise 
between cost and accuracy. Certain problems may arise because of the 
simplifying assumptions attendant to the composite model and to its 
inadequacy of available data; the commenter correctly restates some 
of them. It is important, however, to recall that the use of a 
simpler approach has even more severe problems and that the preferred 
approach of running CTWM explicity for each hour of the year with 
fewer simplifying assumptions is prohibitively expensive. Since the 
latter was suggested by the commenter, it is estimated that the cost 
of 8,760 hourly (1 year) CTWM runs would be about $200,000 and would 
require several hundred magnetic tapes to store the results. 
Furthermore, the cost and complexity of annual GPM runs would be 
greatly increased because of the tremendous increase in report data 

It is also important to recall that the focus of CTWM, GPM, and RTM 
applications is the regional-scale transport of oil-shale-related 
emissions and impacts on distant, sensitive receptors. When 
considered in this context, many of the concerns raised by the 
commenter with regard to the characterization of regional wind fields 
are not of great significance. For example, comments were made about 
the spatial averaging and temporal interpretation of upper-level 

driving winds for CTWM; while it is true that the "composite" method 
employed may not be capable of accurately treating abrupt temporal or 
"chaotic" spatial variations in upper-level wind patterns, such 
conditions are not conducive to high 24-hour average regional-scale 
concentration impacts which generally are associated with 
well-organized and persistent flow patterns. Similar arguments can 
be made concerning the decoupling of upper- and lower-level winds. 

Concerns were raised about the upper-level wind observations being 
outside the study area and available only twice per day. It is 
agreed that better spatial and temporal resolution in the input data 
is desirable; however, all useful data that were available during the 
study were used. 

The comment was also made that division of wind directions into one 
of 16 classes may be too coarse because "there is no reason to 
believe that wind variations of less than 22.5 degrees are 
insignificant in a complex terrain region where sensitive receptor 
areas may occupy less than 22.5 degrees of the distances involved." 
BLM agrees with this comment and has attempted to account for 
variations of the wind in complex terrain using the CTWM and the 
randomization of wind directions in GPM. 

The reviewer's discussion of the treatment of slope winds raises some 
interesting questions and concerns. First, answers to the questions 
that were raised are: 

(a) surface winds data were hourly; 

(b) surface winds were collected at 10 m; 

(c) comparisons were made before assignment of the upper -air-wind 
direction category; 

Six slope wind categories were determined to be sufficient after 
sensitivity analyses were carried out (see Section, Step 3), 
as suggested by the reviewer. The hourly slope wind category was 
selected by examination of all available surface data for the hour, 
and the determination of the slope wind conditions that were observed 
at the majority of stations. It is known that slope winds may 
sometimes be highly variable in space and time, but the available 
meteorological data were too sparse to resolve these variations 
within the study region. Furthermore, it is not clear that the 
chaotic flow situation hypothesized by the commenter is conducive to 
elevated 24-hour concentration impacts at distant receptors. Given 
the current state-of-the-art 1n modeling, an attempt to focus on 
complex, hypothetical scenarios at the expense of more likely 
scenarios would lack the "scientific integrity" we all seek. 

Some criticism of the scaling and vector addition of wind fields used 
In the "composite" mode was expressed. The reviewer states that the 
procedure is mathematically unsound, but later admits that this 
procedure is mathematically correct for elliptical partial 
differential equations. Since CTWM is based on the numerical 
solution of an elliptical partial differential equation, it 1s 
mathematically correct, notwithstanding inaccuracies in the numerical 
solution technique. The question of whether CTWM elliptical 




equations can be expected to provide a fair representation of the 
motions in the real atmosphere is quite different from the issue of 
the mathematical soundness of the composite mode of CTWM application. 

The reviewer's statement, that only 96 possible synoptic/slope wind 
combinations and only 16 possible upper-level winds are possible 
using the composite mode, is false. An infinite number of 
combinations are actually possible, because the synoptic scaling 
factor is allowed to vary continuously. In addition, the reviewer is 
misleading when implying that because CTWM is based on an elliptical 
partial differential equation which is linear with respect to 
boundary condition and superpositioning, it is incapable of 
predicting nonlinear wind-field effects. Clearly, the examples of 
the wind fields predicted by the model given in the EIS reveal 
considerable "non-linearities." However, we would not claim to be 
able to accurately treat all atmospheric phenomena that exhibit very 
nonlinear behavior. 

It is readily admitted that the diagnostic wind model (CTWM) has 
imperfections and limitations as do all mathematical wind models. 
Indeed, CTWM has some theoretical limitations that more 
sophisticated, dynamic models do not, but it has many practical and 
computational advantages over them. On balance, a diagnostic model 
is much better suited to the needs of this study than a dynamic model 
because of the large modeling region and long time period modeled 
(1 e huge computational expense for a dynamic model) and the sparse 
input'data base available. Furthermore, CTWM has been shown to 
perform reasonably well in many complex-terrain settings similar to 
the present one (Yocke et al. 1977; Tesche et al. 1979; Yocke 1981; 
Yocke and Liu 1979) and under meteorological conditions of greatest 
importance to regional transport scenarios. This is not to claim 
that CTWM will perform well under all conditions that may exist. 

but the 

The upper-level driving winds are assumed to be uniform, bu 
predicted wind fields included considerable spatial variati 
reflecting the presence of terrain, frictional and temperature 

Stability was constant Pasquill-Gifford D stability only for the 
regional GPM runs. Pasquill-Gifford dispersion estimates are known 
to be very conservative for elevated plumes in complex terrain 
(Hovind et al . 1974; Stuart et al. 1974; Reid 1976). While there is 
some evidence that annual average stability is somewhere between 
class D and E, the effect of this on dispersion does not compensate 
for the high degree of conservatism embodied in the Pasquill-Gifford 
plume dispersion estimates used. 

RTM was not run with a uniform mixing depth but rather a uniform 
layer top. Mixing depth varied from grid cell to grid cell depending 
on the difference between the layer top and gridded terrain heights. 

Furthermore, limited mixing and the presence of ground-based stable 
layers in the late night and early morning hours were explicitly 
treated in the RTM runs, contrary to the reviewer's statements. 

30 52 The approach suggested for estimating wet and dry acid was, in fact, 
used in the analysis that was performed. A quantitative assessment 
of both wet and dry deposition was performed, taking into account 
trapping, drainage, and "other phenomena that can cause pollutant 
accumulation." The annual rate of deposition and its effect on the 
most sensitive (most poorly buffered) of the lakes in Flat Tops 
Wilderness was calculated. 

30.53 Surveys of the buffering capacity of lakes in Flat Tops Wilderness 
Area (Turk and Adams 1982) were used in the Air Quality Technical 
Report to estimate the effect of acid deposition on lake pH. The 
estimate of wet and dry sulfur deposition in Flat Tops which is 
believed to be conservative is 0.2 g/m z /yr, less than the criterion 
of 0.5 g/m 2 /yr mentioned by the commenter. 

A recently published document by the National Atmospheric Deposition 
Program (Norton et al. 1982) addresses the sensitivity to 
acidification of underlying geology in the United States on a 
state-by-state basis. This document and the accompanying paper by 
Norton et al . has been used to expand the acid deposition analysis 
and discussion in the Final EIS (Section R. 4. A. 2 and Appendix A-5). 
BLM concurs that much more work needs to be done in the West to 
relate deposition rates to effects, particularly in areas where high 
environmental quality is of national importance. 

30.54 Wet deposition rates are a function of the distribution of 
precipitation. Annual wet deposition rates were calculated on the 
basis of annual frequency distribution of significant rainfall 
events. For conservatism, it was assumed that all pollutants in the 
atmosphere, both sulfur and nitrogen oxides, would be completely 
deposited during precipitation events. In reality, the fraction of 
pollutants removed by precipitation will be a function of the 
precipitation intensity. It appears items b and c are the 
commenter's interpretation; BLM is unaware of sufficient data to 
substantiate either. 

30 55 For the purposes of conservatism, it was assumed that wet deposition 
rates would be equal to those for dry deposition. The conservatism 
derives from the fact that all sulfur and nitrogen oxides everywhere 
in the region are assumed to be washed out during precipitation 
events of 0.01 inch or more in Grand Junction. This is certainly 
conservative for light precipitation events. Precipitation 
intensities increase with elevation because of orographic effects. 
Thus, the degree of conservatism decreases with elevation in the 

30.56 Refer to the response to Comment 30.42 

30.57 The mechanism used is the Carbon-Bond Mechanism developed for urban 
areas. Sections 4 and 5 of the Air Quality Technical Report have 
been expanded to clarify this point. 

30.58 The discussion of the degree of conservatism does Include comments 
about the strengths and weaknesses of GPM. Where one might expect 
the likely possibility of underestimation to occur, other models or 
variations 1n mode of model application were applied. The specific 
examples cited as factors which may cause GPM to underestimate 
concentrations are Incorrect, GPM does explicitly account for the 
terrain effects given and the interaction of plumes. The logic of 
the discussion of "Gaussian plume coherency" is difficult to follow 
and, in parts, speculative. 

30.59 The Uintah Basin Synfuels Development EIS complies with statutes and 
regulations governing its preparation and contents. Refer to the 
responses to Comments 30.1 through 30.58 regarding BLH's responses to 
these allegations to the contrary. 









31.6 | 

United States Department of the Interior 

RESTON. VA- 22091 


MMS-Mail Stop 650 

oct i o m 

Lloyd Ferguson, District Manager 
Bureau of Land Management 
Vernal , Utah 

Acting Associate Director, Onshore Minerals Operations 


Review of Draft Environmental 
Development, Utah 

Impact Statement, Uintah Basin Synfuels 

The Minerals Management Service has reviewed the subject draft environmental 
impact statement (DEIS) both at headquarters and in the field. In general, we 
believe the document is comprehensive and addresses areas overlooked in previous 
synfuels EIS's, although certain significant oversights may be misleading. The 
following are our specific comments. 

Page v. R.3.A.13., Mineral and Energy Resources should be indexed to page R-3-57 
instead of page R-3-27. 

Page R-l-6, table R-l-2. A recently approved development plan modification for 
the White River Shale Project will result in peak construction and operating work 
force occurring 2 years later than shown. 

Page R-l-9, table R-l-3. The revised development plans for the Cathedral Bluffs 
Shale Oil Project to be prepared in 1983 will probably outlive a development 
scenario requiring a construction and operating workforce similar to the Union 
Oil Shale Project. 

Page R-l-12, table R-l-6. It should be appreciated that, since the specific and 
related projects acknowedged in the EIS will pass through these initial develop- 
ment phases during the late 1980's and early 1990's and since they are geographi- 
cally tied to Vernal as the principal residential community, there is a high 
probability that skilled workers will be able to move from one project to another 
as their particular trade is required. This will tend to lessen total regional 
population growth. The same considerations would apply to table R-l-13. 

Page R-l-15, 16, and 17, tables R-l-8, 9, and 10. Should not these tables be in 
section R-l.B, High Level Scenario? 








There are two characteristics of this EIS which are unusual. First, the reported 
results of the impact analysis include a range of possible values which reflect 
the uncertainty inherent in air quality modeling. The second is that results are 
reported, in the summary sections and the individual project analysis sections, 
in a form consistent with the objective of each particular section and appropriate 
to the technical understanding of most readers and reviewers. 

Uncertainty in computer modeling is absolutely unavoidable and ranges from a 
factor of 2 under ideal conditions and flat terrain to 10 or larger under complex 
terrain. Since most readers of EIS's will not have the experience to take this 
uncertainty into account, it is actually more accurate and realistic to report a 
range of potential values than the misleading single value usually reported. 

We want to point out the conservative nature of the entire analysis. While we 
may assume worst-case conditions of meteorology and plant emissions, we are 
assuming best-case economic and social conditions for development of the projects. 
Therefore, we expect actual regional impacts to be substantially below even the 
low end of the range predicted. 

Page xxx, paragraphs 3, 4, and 5. Will these impacts occur under the high level 
scenario, low level, or both? 

Page R-2-2, Air Quality. Although we believe this method of presenting air 
quality impact results (exceed, probably exceed, etc.) is more appropriate to 
a summary than most other EIS's we have seen, we believe it will put some readers 
off. This may be especially true for those predisposed to a negative viewpoint. 
We suggest a paragraph on page R-2-1 explaining the scheme of presentation of 

Insert "exceedances of the 

Page R-3-18, Existing Air Quality, paragraph 1. 
particulate standards." 

Page R-3-20, table R-3-6. We cannot stress enough the inadvisabil ity of compar- 
ing 3-year averages to annual (1 year) standards or, even worse, to 8-hour or 
1-hour standards, as in table R-3-6. Comparisons of this sort are misleading in 
the extreme. We recommend deleting table R-3-6 or using averaging times equal to 

Page R-4-25. Part R-4-A.2. of the air quality section addresses the general 
impacts of proposed synfuels projects on National Ambient Air Quality Standards 
(NAAQS) and Prevention of Significant Deterioration Increments (PSD). While the 
manner in which the various proposals might impact NAAQS and PSD is addressed 
sufficiently, the potential impacts of the proposals relative to the National 
Elimination Standards for Hazardous Air Pollutants (NESHAP) is not discussed. 
Hazardous aerosol compounds are produced in synfuels processing. Thus, the 
potential for NESHAP impacts should be discussed briefly at a minimum. In addi- 
tion, this part of the section on air quality does not seem to clearly address 
the combined cumulative impacts of all the synfuels proposals in the area^ We 










assume, based on information provided in the EIS, that the simultaneous operation 
of all facilities would completely consume and significantly exceed the available 
PSD increments. Such a potential impact, if valid, should be clearly stated in 
the EIS. 

Page R-4-26, paragraph 2, line 2. The term "GPM Model" is used without introduc- 

Jther Pol lutants 

Page R-4-37. It is appropriate that the potential aerial emissions of arsenic, 
cadmium, mercury, lead, ployaromatic hydrocarbons (PAH), etc., are mentioned. 
The potential emission of these compounds or their impacts has rarely, if ever, 
been addressed in previous synfuels EIS's. However, the section needs to be 
expanded and made more consistent with the safety and health discussion on 
pages R-4-1Q2 through R-4-104. Certainly, potential emission of such things as 
nitrous oxides, mercaptans, and benzene should be mentioned in both sections. 
Also, reference to the potential carcinogenicity of these compounds should be 
expanded to include a discussion of the potential impacts of these compounds on 
resident populations within close proximity of the installations. This could be 
accomplished by addressing potential impacts in several defined concentric circles 
ranging outward from the source. 

Acid Disposition 

Pages R-4-40 through R-4-4 
defined problem. It summa 
tions regarding acid dispo 
However, the discussion fa 
that they are unknown. Ba 
believe that sufficient in 
as to whether the impacts 
be included in the final E 
the acid deposition produc 
problem in the Western Uni 
is available. 

1. The discussion of acid depos 
rizes current knowledge of resea 
sition in the areas adjacent to 
ils to address potential impacts 
sed on the information provided 
formation should be available to 
are significant or minimal* Sue 
IS. Furthermore, some projectio 
ed by these projects on the over 
ted States would be helpful if s 


ition addresses an ill- 
rch and makes projec- 
tile proposed projects. 

other than to suggest 
in the document, we 

draw some conclusions 
h a discussion should 
n of the impacts of 
al 1 acid deposition 
uff icient i nformation 

Almost no detailed attention is given in the DEIS to the potential for degrada- 
tion or pollution of water resources at the various sites. Many of the engineer- 
ing procedures mentioned probably will not be effective in controlling water 
pollution over long periods of time. 

Little or no data are given on the composition of the resource to be processed. 
Thus, we have no way of evaluating the estimated enissions or other waste mate- 
rials insofar as their potential for pollution. For example, sulfur content in 
the oil shale and tar sands is not given, leading to great uncertainties in esti- 
mates of controls needed, to sulfur produced as by-product, and sulfur compounds 
-remaining waste materials. 









The EIS should clearly state the uncertain aspects of some operations (e.g., 
spent shale reclamation) and that the descriptions of proposed procedures have 
not yet proven to be satisfactory. 

Most abandonment procedures are oversimplified, perhaps out of necessity of the 
present state of knowledge. Shaft abandonment should, at minimum, recognize the 
potential effects on aquifers, and mine working abandonment should address effects 
of eventual subsidence on water resources. 

The discussions of "percent efficiency" should be supplemented with a discussion 
of resource recovery. Typical room-and-pi liar mines in the basin will recover 
only about half of the oil shale resource. 

Page R-3-25, paragraph 3. The "Birds Nest" aquifer occurs in the eastern part 
of the basin, where much of the ground water contains 2000-4000 mg/1 TDS (not the 
9,870 noted). Much of the water in the Douglas Creek aquifer contains less than 
2,000 mg/1 TJS. Near tracts U-a and U-b, limited data indicate the water con- 
tains less than 1,000 mg/1 TDS. 

Par\e R-4-7, paragraph 5. The discussion on mining ground water is neither com- 
plete nor as unequivocal as Implied. No mention is made of potential effects on 
water quality or on the potential for using ground water to supplement surface 
water supplies. 

Page R-4-45. This section sufficiently discusses impacts relative to water 
consumption. However, the more traditional water quality impacts relative to 
pH, total acidity, heavy metals, other toxics, total dissolved solids, etc., are 
not addressed either for surface or ground water. On page R-4-55, under "Other 
Water Quality Impacts," the possible mitigation measures for leachates of the 
projects are addressed in a cursory manner. A much more complete discussion of 
these measures, including a realistic evaluation of their long-term effectiveness 
and resultant impacts, would be appropriate. 

In addition, this section should fully address the potential impacts of leachates, 
particularly toxic leachates, on both the surface and ground water. Such a dis- 
cussion should Include the potential impacts for such things as acidity, salinity, 
total dissolved solids, heavy metals, PAH's, and other toxic leachates. It 
should be cross-referenced with the wildlife and endangered species discussion. 
Particular attention should be given to the potential impacts of these substances 
on aquatic habitat for endangered species and other aquatic life. 

Page R-4-54, paragraph 6. Where quantifiable, the estimated annual cost to down- 
stream users due to salinity should be stated, i.e., White River Dam $1,400,000 
to $1,900,000, and total costs from all sources $3,800,000. 

Page R-4-55, paragraph 1. The implication that spent shale can or will be 
reclaimed so as to produce "no leachate" is not supportable by data. A growing 
body of information indicates otherwise. The use of "average" precipitation and 
evaporation numbers in support of this is faulty reasoning. In summary, field 
and laboratory studies and the certainty of hydrogeologic processes in the area 
indicate that "no leachate" is a near-impossible achievement. 





Page M-4-8, paragraph 1. Experience to date in utilizing mine inflow water 

31.26 indicates that any large inflows during early mining stages will exceed the 
need for water, thus disposal methods will be needed. The E1S should address 

Page P-l-15, paragraph 16. No information is given on the slope of the spent 
shale surface, which is critical to its stability. The slope should be no 

31.27 greater than 4:1. The description of benches is not clear as to how many or 
what length of runoff from the slope feeds each bench. These descriptions, 
coupled with the lack of detail on the retention dams shown on the map on 
page P-l-3, make the proposed plan for spent shale disposal inadequate. 

Page T-l-10, paragraph 1. The recognition in the TOSCO plan that "soils or 
weathered bedrock" are suitable plant growth materials is a great step toward 
reality in the uncertain field of land reclamation in this and other soil- 
short areas. The alluvium in washes, which is also a suitable plant growth 
material, should be added to this list at all sites. 

I Page T-l-10, last paragraph. Mining under rivers should be approached with 
extreme caution. Long-term subsidence is a near certainty, with resulting, 
probably undesirable, effects on streamflow, ground water, and perhaps the 
mining process. 

Page T-l-13, last paragraph. There are sound reasons for the Bureau of Land 
31.30 I Management to encourage injection of excess mine water into the producing 

aquifer, as described here. Such injection has proven feasible and has been 
done successfully on lease tracts C-a and C-b. 

Page T-l-15, paragraph 6. The flood runoff precautions, as described, are 
conservatively realistic in view of the uncertainties in size of a rare storm. 

Page T-l-27, paragraph 3. Has the alluvial aquifer system along the White River 
been tested? There appears to be a 2-mile reach of alluvium that is a potential 
aquifer in the project area. A 9,000 AF/year demand could potentially be met, 
at least in part, by a well field along this reach. 

Page R-C-4, paragraph 5. No mention is made of the almost certain ground water 

31.33 degradation that will result from abandoned in-situ retorts where large volumes 
of soluble materials in the retort zone underlie a broken ground surface made 
more permeable by blasting and, thus, able to accept more recharge from precipi- 

Page R-3-9. The description of how spent shale would be converted to "... a 
stable, impervious, and erosion-resistant land mass" is oversimplified and mis- 

31.34 leading. Retorted shales generally require a great effort, perhaps prohibitively 
so, to compact them to very low permeabilities. The long-term stability of this 
low permeability, when subjected to fluid movement through it, has not been 

31.35 I 

31.36 | 

31.37 fi 

31.39 | 

31.40 | 


31.42 | 

31.43 | 



The time frames given for successful revegetation are not consistent between 
projects in similar vegetative and rainfall areas. One example is revegetation 
of timber species given as 75 to 300 years for different products in different 
parts of the report. 

The use of data carried to one decimal point, i.e., 57.1 percent, for an estimate 
based on little more than judgment is not justified. 

Use of the term "noxious weeds" in reclamation sections is incorrect. That term 
should designate only those weeds listed by the State as noxious. As used in the 
text, it should be simply "weeds." 

Page R-l-15, table R-l-8. Does the ground water column refer to construction or 

Page R- 1-22, table R-l-15. Does the ground water column refer to construction 
or operation? 

Page R-3-31, table R-3-10. This would be more useful if combined with acreage 

Page T-4-7, paragraph 4, line 5. 
is confusing. 

The sentence beginning "However, this impact" 

Page T-4-9, paragraph 1, line 1. Explain that the 2,000-acre disturbance takes 
place gradually and that reclamation on some parts can start while other parts 
are still being disturbed. 

Pages T-4-10 and T-4-11. What about impacts to mammalian predators, such as 
coyotes, which are common in the area? 

Page E-l-11, paragraph 1. The statement to return disturbed areas to "original 
contours" could be interpreted to be an unnecessary and expensive requirement. 


While the EIS does an adequate job on the regional description of the environment, 
when the discussion switches to individual sites, no specific site data is pre- 
sented on wildlife, habitat, or vegetation. It is assumed that the regional 
information presented for vegetation sites is sufficient for indivudal tracts 
without discussing any particular characteristics or dissimilarities of the 
natural resource on that specific tract. 

The discussion of impacts on individual wildlife species is very general. For 
instance, it is stated that removal of vegetation will impact birds and small 
mammals, but the major species which will be involved are not listed. Nor is it 
stated which part of their life cycle will be affected or how different species 
react to revegetation efforts. 





31.47 1 
31 .48 | 
31. 49 | 

31.50 | 

P?r ^Slt' rem0Ml ° f P^on/junlper will affect nesting areas of pinyon jays, 
etc., which are year-round residents. The reclaimed areas will be vegetated 

r^rnS r ? S \ and r n K 9 ShrUbS " Th,S ^ of hab1tat »"' ^vor specie suSh 
ttu 2 h I and other °Pen-habitat dwellers. Eventually, in 20 to 50 years 

H ? Ml fesl nd r hr eS 1 W , , ' f a9a i n Pr ° Vlde neStir,g habUat «W "»<"«nd specie of 
orov i I liS 9 k6 - the t 01 "^ '^ tailored to specific situations would 

provide a better description of impacts than that given. 

The wildlife-habitat-revegetation scenarios are misleading and incorrect. 

If a mine, which is on a 5,000-acre tract, will be developed over a 25-vear period 

3 OoS a a V rre, m nf 1mUm f.?'" '"" di5turbl *. "en the statement in the HS that 

The "line site or total tract will never have 3,000 acres out of production at 
any one time. The development schedule should be shown with acres disturbed 

ESlU f« tHirv reC ' a r d - i' firSt " dlst - b ance is rapid, as roads plant 
facilit es, utility corridor, and mine site areas are cleared and overburden 

Z S IV^l^t ™ S W0U ' d diStUrb " r0babl * ,e " "an 500 of m I 3,000 
lit LV\ I .k y !" r Per '° d - When actuaI rainin 9 storting and processing 

(if any) begin, then the spoil pile, raw rain material pile, and catchment pond 

production? t0 eXPdnd ' ""* °" ly " y ' fe " hU " dred aCreS per * ear "P ""tn full 

J''^ full Production is achieved and a portion of the spoil pile reaches final 
15 toTve^'wr 5" rec,aimed - After ™* PO«"t is reached (possibly \" 
ll f J, rl V' the " for every acre "^turbed there would be one being reveqe- 

tnrS; Jn r ° re K U ' 5 f ubtfu1 lf over one - half of the 3 .000 acres tota dis- 
turbed will ever be out of production at any one time. 

Even though livestock grazing may be prevented by fencing, it would be difficult 

rn pvhTT ° 'T "T a0d a " tel0pe out of these ^ a " d a "»<"t Impossible 
to exclude birds and small mammals. This probably would not be necessary anyway. 

»th^ here is . reaso " t0 ° el ' e "e "at proper reclamation using water harvesting 
methods, superior seed or stock mulch, fertilizer, herbicides, and insecticides 
cannot prov,de much greater livestock and wildlife carrying capacity than before. 

thf i?;?" 3 f'K tat ; le R " 3 " U - Use of the * cron * m " R0W ' S " 5 "° uld »>e defined. 
the list of birds is very short; what about season of use? 


nofRme! 8 ' tab ' e K " 3 " 15 ' Ve9d " ate Recre ation Area is in Collbran, Colorado, 
^chosen?" para9raph 6 ' The 10 ^ ear ff a ure appears arbitrary. Why and how was 

Page E-l-9 paragraph 3. This states that 100-ton trucks would be used but 
page E-l-11 states that 85-ton trucks would be used. Which is correct? 

31.51 I 

31.52 | 

31.53 | 




31.57 J 

31.58 | 
31. 59 1 

Page E-3-2, paragraphs 2, 5, and 6. The descriptions of vegetation and habitat 
type are too vague, what is the present carrying capacity of these areas for 
deer and elk? 

Page E-3-3, paragraph 1. 
tory routes? 

How do roads and utility corridors conflict with migra- 

Page S-5-6, paragraph 1. The estimate of a 61.2 percent increase in wildlife 
loss is highly speculative. 


The EIS addresses the subject of agriculture in several different sections under 
the various alternatives and/or proposals. This approach is highly desirable as 
it serves to clarify the impacts that the different alternatives and proposals 
may have on the aspect of agriculture. Several of our comments on agriculture 
are contained in our comments under "Vegetation, Soils, and Reclamation" and 

We believe the sections on agriculture are adequate. However, It would be bene- 
ficial if recommendations were made concerning possible mitigating measures 
and/or stipulations that may be necessary to alleviate the impacts to agricul- 
ture. While the EIS addresses the impacts, it does not clarify the effects that 
these impacts will have on the people in the area or on the field of agriculture 
as an important facet of the economy of the area. A more direct approach should 
be made concerning the actual impacts to agriculture that .nay result from the 
alternatives and proposals. It is also important to address mitigating measures 
and stipulations that may be necessary. This would help clarify a degree of 
vagueness that Is now present in the EIS. 


Page R-3-57, R-3.A.13. This is not comprehensive and provides little informa- 
tion for use. This is the basic section, and all other site specific comments 
are referred here. 

Page R-L-l, appendix 8-1. It seems illogical to include food and clothes, etc., 
for the workers, as all people need these energy itens, regardless of the loca- 
tion of their jobs. 

Page R-l-10, table R-l-4. Compare R-l-16 and R-l-23. The high and low scenarios 
do not make sense. Production from U-a/U-b is higher in low scenario, as is tar 

Page R-3-57, R-3.A.12. Paleo is not useful and is too general. 

Page R-4-10. The impact on paleontology is not significant. 





31.61 1 

31 .62 I 
31.63 1 
31. 64 1 





Page R-4-39 and R-4-91. Resources left in the ground, i.e., not recoverable as 
a result of present day mining technology, should not be considered in determin- 
ing project efficiency. Resources left in the ground make it possible to mine 
the recoverable resource. 

Page R-4-91, paragraph 6. These energies would be consumed anywhere, not just 
at the project. The additional "cost" in energy might be legitimate. 

How does "1-6" in the "Overall Energy Efficiency" differ from "1-4" in the "Final 
Project Efficiency"? 

Page R-4-102, paragraph 2, last line. MIS does not involve miners being directly 
exposed to fire. This may overstate the risk. 

Page SS-14, Pillar Design. The feasibility of pillar extraction is questionable 
with mining heights as indicated. 

Page E-3-5, E-3. This section on Minerals and Energy Resources references 
section R-3.A.13. Similar cross-references are in each site section. The 
information is inadequate. 

Pages E-4-12 and E-4-13. The efficiency analysis seems to consider the nonrecov- 
erable resource, which gives a distorted picture (see comments for pages R-4-89 
and R-4-91). 

Page M-4-17. See comments for pages R-4-89 and R-4-91 and E-4-12 and E-4-13. 

Page P-4-14. See comments for pages R-4-89 and R-4-91 and E-4-12 and E-4-13. 

Pages S-4-15 and 5-4-17. See comments for pages R-4-89 and R-4-91 and E-4-12 and 

Page T-l-25. There is no attempt in the discussion of the "Blocking-Up" alterna- 
tive to TOSCO's Sand Wash Projects to calculate the amount of oil shale resources 
that would be able to be mined on both the Federal and State lands as a result of 
this alternative or the amount of money saved by the company by not having to 
construct tunnels, more pipelines, conveyors, and powerline. No mention is made 
that this project would be able to operate for 9 more years at approximately 
66,000 tpsd. 

Page T-3-15, Geology. This has important conclusions on the seismic risk to the 
pipeline. This is not supported in the geology section in this EIS. 

Page T-4-15. See comments for pages R-4-89 and R-4-91 and E-4-12 and E-4-13. 

Page R-L-l. See comments for pages R-4-89 and R-4-91 and E-4-12 and E-4-13. 




The technical aspects of the mining and processing are covered adequately with 
the exception of quantification and discussion of impacts of polycyclic aromatic 

Thank you for the opportunity to review this document. 






U.S. Minerals Management Service 

31.1 BLM notes the comment on the comprehensiveness of the EIS. 

31. Z The Table of Contents has been revised. 






It is understood that perhaps the White River project may be delayed. 
Also, other projects have indicated changing work force plans. The 
synfuels industry is undergoing considerable change and is constantly 
faced with a great deal of uncertainty. The State of Utah, in 
preparing economic demographic projections of impact from synfuels 
development in the Socioeconomics Technical Report, has found it 
quite impossible to incorporate all changes in projects as they 
occur. Instead, the state was faced with using work force estimates 
as of January 1982. Changes in work force requirements after that 
date cannot be reflected in the EIS or the accompanying 
Socioeconomics Technical Report. White River Shale Project provided 
its best estimates of work force in January 1982, and these numbers 
are reflected in the EIS. 

Based on a new submission for funding to the Synthetic Fuels 
Corporation, the Cathedral Bluffs project would have a scaled-down 
peak construction work force of 2,200, and a peak operational work 
force of 1,500. These new work force projections could not be 
incorporated into the socioeconomic impact analysis, but are 
recognized in this response. Because the figures used for analysis 
purposes were greater than current estimates, the analysis can be 
considered a worst-case situation. 

Skilled workers would be 
their skills are required 
It should be recognized, 
Demographic (UPED) model 
labor at every point in t 
shifting of workers from 
before any new migration 
model has adequately proj 
development and that tota 
overstated because of shi 

able to move from one project to another as 

This is a very important consideration, 
however, that the Utah Process Economic and 
takes into account the supply and demand for 
ime and thus is able to simulate the 
one project to another within the region 
is induced. It is believed that the UPED 
ected the total impact of synfuels 
1 regional population growth has not been 
fting workers from one project to another. 

In keeping with usual editorial practices, the tables in question 
were placed immediately after the page on which they were referenced. 

BLM notes that the Minerals Management Service believes the air 
quality analysis was well presented. The air quality analysis was 
designed to be conservative; however, because of the nature of the 
available data, BLM believed it was better for the analysis to 
potentially overstate rather than understate the impacts. 

The impacts described in general terms in the Summary are appropriate 

for both the high- and low-level scenario. The actual magnitude of 

the impacts would be greater for the high-level scenario than for the 
low-level scenario. 

31.9 This is intended to be a summary table. It is unclear how the method 
of presentation (exceeded, probably exceeded, not exceeded) would 
adversely affect the reader's understanding of the information ("put 
them off"). The meaning of the key words used in the table 
(exceeded, probably exceeded, not exceeded) is explained in table 


The subject paragraph in Section R-3.A.2 has been expanded and the 
suggested insert has been incorporated. 

31.11 Table R-3-6 has been replaced. 

31.12 Additional information on hazardous air pollutants has been added to 
Section R-4.A.2 and Section 4. A. 2 of the site-specific analyses. PSD 
regulations require determination of Best Available Control 
Technology (8ACT) determination, and air quality analysis for all 
pollutants to which the National Emissions Standards for Hazardous 
Air Pollutants (NESHAPS) apply, unless emissions would be less than 
the "de minimis" emission rates set by EPA. 

It is true that analysis results indicate some PSD increments could 
be exceeded from the cumulative impacts of all proposed synfuels 
facilities. However, the exceedances are not predicted to be as 
widespread as the commenter suggests. The problem of which PSD 
increments would be exceeded and at what locations is complex and 
should not be oversimplified. 

31.13 The Section R-4.A.2 sentence in question has been corrected. 

31.14 Section R-4.A.16 is a general discussion of safety and health 
impacts. Section R-4.A.2 has been expanded to include additional 
information on potential trace elements and other emissions 
(including PAH impacts). 

31.15 Section R-4.A.2, Acid Deposition, has been expanded utilizing 
additional information and studies from the literature. 

31.16 The water quality analysis was based on determinations that the 
engineering procedures would be effective in controlling water 
pollution and producing stable slopes, and that the reclamation and 
revegetation plans would be complied with. Given these 
determinations and existing regulations and forced compliance by 
authorizing officers, there is not a case for water pollution over 
long periods of time. 

31.17 It is true that very few data on the raw shale are given; however, 
data on the composition of the products and by-products are included 
in the applicants' technical reports and PSD applications. 

The method of analysis for this EIS was to review the major processes 
resulting in emissions, emission factors and control technologies, 
and other descriptions for each project. This information was then 
compared among the projects, to other oil shale/tar sand facilities, 
to reports on comparable sources, to data on control technologies, 




and to documentation on emission factors for its reasonableness. 
Engineering judgment was used to derive estimates for the conceptual 

In the final analysis, permits would be issued based on the 
applicants' submitted data, and the applicants would be responsible 
for meeting the emissions standards. 

31.18 The EIS discussion of spent shale reclamation identifies major 
concerns, methods, and techniques with reference to reliable research 
and field trials conducted by leading researchers in the field of 
reclamation. The research on which the E1S conclusions are based is 
identified in the footnotes for Table A-8-2 and the associated 
reference list located in Appendix A-8. 

31.19 All shafts would be sealed from any infiltrating ground water during 
construction. It can be assumed they would be maintained during 
operation, and adequately sealed at the surface upon abandonment. 
The mines are designed to prevent subsidence based on strength and 
thickness of overburden. 

31. 20 Resource recovery is discussed in Section R-4.A.13. 

31.21 The ground water TDS values in Section R-3.A.3 have been corrected. 

31.22 Contamination of ground water has been added to the Chapter R-4 
Significance Criteria section. No applicant identifies ground water 
as its preferred water source. Magic Circle, the only applicant 
considering the use of ground water, proposes the Douglas Creek 
aquifer as an alternative water supply system (see Section M-1.E.2). 

31.23 The EIS considers water usage from several rivers in the Upper 
Colorado River System (White, Green, Colorado, and Duchesne). The 
water model that was used to determine impacts to the Colorado 
River System is capable of predicting changes in salinity and flow. 
The "more traditional water quality. . .that are not addressed" are not 
included for the following reasons: (1) there is no evidence that 
these parameters would change, because the applicants' project would 
be non-discharging; and (2) water quality data that would be needed 
to determine current site-specific baseline conditions do not exist. 

What the commenter referred to as mitigation measures for leachates 
are actually applicant disposal pile design parameters. More 
complete discussions of these parameters are contained in the 
referenced applicant technical reports. 

The Section R-4. A. 3 discussion on leachates has been expanded to 
include more data which support the conclusions in this section. 
(See also the response to Comment 32.11.) 

31.24 Section R-4.A.1 states that a 1 mg/1 increase would result in 
$472,000 of annual damages. The largest annual damage from all 
sources (baseline plus applicants' projects plus interrelated 
projects), measured at Imperial Dam, would be $46,633,600 in 1990. 









The largest annual increase in salinity damage from applicants' 
projects and interrelated projects as an increment above the baseline 
would be $3,776,000 in 1995. See also the response to Comment H-9- 

The reclamation of the spent shale is not the issue for leachate 
production, but rather the engineering of the spent shale pile. The 
engineering designs shown by the applicants have the potential of 
producing an inert plug of spent shale sealed from natural soil and 
rock by nearly impermeable liners. 

The use of average precipitation figures 
the best data that is available for the 
recharge to the water system is through 
principally in high altitudes, which are 
"certainty of hydrogeologic processes in 
believe. Because the applicants' spent 
highly permeable, would not occur in a z 
would have the runoff diverted plus use 
the chance of leachate production would 
response to Comment 32.11 for a more in- 

is not faulty, but rather 
area. It is well known that 
highly permeable zones, 
not as well known as the 
the area" would lead one to 
shale piles would not be 
one of high recharge, and 
a nearly impermeable liner, 
be remote. Refer to the 
depth discussion. 

Although existing data indicate little potential for a large inflow 
of water into the mine, any excess water would be stored in a holding 
pond and eventually used. (Refer to Sections 1.3 and 1.10.43 of the 
applicant's technical report.) 

Spent shale disposal and retention dams are discussed in detail in 
the applicant's PSD application, Section 2.2.4. The company has 
proposed 1.5:1 slopes on the spent shale pile, along with a cemented 
shale and rip-rap covering. Also see response to Comment 44.32. 

The statement as written includes "alluvium in washes." Weathered 
bedrock includes unconsolidated residues (regolith) which may consist 
of sedentary (in-situ) and/or materials transported by wind and 
water . 

Tosco is also concerned about mining under the river as reflected in 
the paragraph cited by the commenter. Tosco's planned approach is to 
prevent collapses. See pages 5.1-10 and 5.1-11 of the Tosco 
Technical Report for more information. 

This method of disposal of excess water also may be used in other 
places, where appropriate, reducing potential for significant 

Tosco's design is purposely conservative to ensure maximum 

Whether or not the aquifer has been tested is a moot point. The 
hydrologic connection is so direct to the flowing river that it would 
respond as a surface water source. 









The only data BL.M has that is related to recharge over in-situ 
retorts is that after blasting and burning, a significant increase in 
soil bulk density occurs (ERO Associates, undated). This suggests a 
decrease in permeability and a corresponding decrease in 
infiltration/ recharge. This point has been added to Section R-4. A. 3 
(note the purpose of the appendix is to describe the applicant's 
proposed project rather than discuss impacts). 

A more detailed description of the disposal pile design is not 
available for the Agency Draw Project. The project is conceptual and 
has not proceeded into a detailed design phase. It is assumed that 
the disposal design would be similar to those submitted by the other 
applicants (see applicants' technical reports) and that the 
reclamation procedures would be similar to those outlined in Appendix 

Given these considerations and existing regulations enforced by the 
State of Utah, the disposal pile would be erosion resistant and 
stable. It may, however, be somewhat permeable. For the issue of 
permeability and fluid movement, see responses to Comments 31.25 and 

It also should be noted that no authorizing decisions will be made at 
this time for the conceptual projects. When project designs are 
sufficiently developed that action on the rights-of-way decisions is 
requested, BLM will request detailed project description data and, 
based on this, determine whether additional environmental analyses 
are necessary. Refer to the EIS Preface for additional explanation 
of this point. 

31.35 Vegetation sections have been reviewed and revised to be consistent. 

31.36 Generally numbers have been rounded to the nearest whole number. 
However, there are situations where detail to the nearest tenth is 
needed in resource display tables (for example, when a comparison of 
one component is made to another to ensure a 100 percent total). 

31.37 Vegetation sections have been reviewed and the term "noxious weeds" 
has been eliminated. 

31.38 Tables R-l-8 and R-l-15 have been revised so that the construction 
and operation ground water requirements are clear. 

31.39 Table R-3-10 recognizes vegetation types affected by applicants' 
project components, which is the purpose of Chapter R-3, Affected 
Environment. The amounts of acreage disturbed are considered to be 
impacts and, therefore, are included in Chapter R-4, Environmental 
Consequences (Section R-4. A. 4). 

31.40 The sentence in Section T-1.A.4 has been clarified. 

31.41 The next two sentences of the paragraph in Section T-4.A.4 explain 
that disturbance and reclamation would occur in stages. 

31.42 Since mammalian predators (such as coyotes and bobcats) are highly 
mobile and opportunistic species, no impacts are anticipated. 

31.43 Enercor informed BLM that this was the company's intent. The 
statement pertains to abandonment procedures and should be complied 
with as nearly as possible. 

31.44 Most site-specific areas have no inventories as to numbers, 
densities, and similar parameters for wildlife populations. Species 
occurrence is noted and estimates made as to general impacts to 
resident or transient populations. 

Site-specific analyses, in most cases, do not present data on 
wildlife numbers present, as no data exist on these parameters on 
such small areas. Occurrence is noted on each site, but differences 
or similarities between tracts are not stated, as this document is 
not comparing one site against another for decision purposes. 

31.45 Where appropriate, this type of impact is discussed in the EIS. 
Refer to Section T-4.A.5 for a discussion of numbers of small birds 
lost and speculation on different species returning to a revegetated 
area because of a new habitat type. 

31.46 The reclamation and revegetation scenario identified in the comment 
is different from the operations proposed for the Uintah Basin 
synfuels projects. Reclamation of the spent shale disposal areas 

and surface mining disturbance is discussed in Section R-4. A. 4. Even 
though the total area would not be disturbed or covered by spent 
shale in the early stages of the project and portions would be 
reclaimed during the later stages of the project, the entire area was 
considered to be removed from vegetation production due to the 
following: (1) stripping and storage of topsoil and suitable plant 
growth materials would require space; (2) procedures for placing 
spent shale in the disposal area would require parts of the area to 
remain disturbed for long periods of time; (3) reclamation would be 
accomplished in stages concurrently with project operations; and (4) 
the associated traffic would necessitate exclusion of other uses for 
most of the area for the life of the project. (Spent shale disposal 
areas would not be disturbed and reclaimed on an acre-by-acre basis.) 

Through the intensive use of applicable and effective reclamation 
measures, there is a strong possibility that grazing carrying 
capacities would be increased. However, it is the primary objective 
to reach at least near preconstruction conditions. 

31.47 The list of birds is not intended to be a complete species occurrence 
listing, only selected species. A complete listing of bird species 
occurring in the regional area can be obtained from the Utah Division 
of Wildlife Resources. 

The definition of ROW has been added to Table R-3-11. 











Table R-3-15 has been changed to indicate Vega State Recreation Area 
is in Collbran, which is near Rifle. 

The 10-year figure was used, because it is based on experience and 
research results (Sims 1974) in areas with similar vegetation types, 
and climatic and soil conditions. 

One-hundred-ton trucks would be used, 

Section E-1.D.2 has been 

There is no data available on big game species carrying capacities on 
these areas. 

As referenced in Section E-3.A.5, detailed descriptions of vegetative 
(habitat) types are included in Section R-3.A.4. 

Because the applicant does not propose to fence roads or utility 
corridors, these facilities would not interfere with big game 

The 61 
human pop... 
exists to projec 

The major impact to agriculture is the effect population increases 
would have on land use conversion of cropland to other uses (mainly 
urban uses) at the regional level. 

2 percent increase is based upon a straight line projection of 

lopulation increase in the area. No better way presently 

to project effects of human population increases on wildlife 

Refer to discussion in Section R-4. A. 6, Section R-4.B.6, 
R-4.A.1 (Other Socioeconomic Impacts, Agriculture). 

and Section 

The purpose of the EIS is to identify impacts associated with the 
proposed action. The only impact to mineral resources that is 
expected to result from an oil shale/tar sand industry is consumption 
of the resource. This is discussed in Section R-3.A.13 and Section R- 
4. A. 13. Also Table R-l-9 shows how much resource would be mined by 
each project. 

These items are part of the standard inclusions called for in the 
Energy Analysis Handbook for Preparation of Oil Shale Deve lopment 
Environmental Impact Statements (BLM 1982a) adopted by BLM as the 
method to determine energy effic i ency . 

The commenter is not comparing similar tables. Table R-l-4 
identifies high-level scenario oil production in barrels per stream 
day; Table R-l-16 identifies low-level scenario oil shale mined in 
tons per stream day. Table R-l-4 should be compared to Table R-l- 

31.58 In such a depositional environment as that which took place in the 
Green River Formation, such generalities are necessary. Mitigation 
for unquantifiable losses recommends contacting a qualified 
paleontologist if necessary. 

31.59 Under the conditions set forth in the Chapter R-4 Significance 
Criteria section, it appears that impacts may be significant. The 
comnenter did not provide evidence to support the contention that 
impacts would be insignificant. 

31.60 Resources left in the ground do indeed make it possible to mine the 
recoverable resource and therefore are an energy cost. Table R-4-27 
does consider oil shale and other resources left in the ground. 
Table R-4-28 does not consider oil shale left in the ground, only 
that which is removed. This is also true for the energy efficency 
data provided in the Chapter 4 Minerals and Energy section included 
for each site-specific project. 

31.61 Inclusion of infrastructure energy is part of the standard method 
used in the analysis (refer to Appendix A-10 for more information on 
methodology). This allows one to compare a project in Utah with one 
in Kentucky, for example, on somewhat equal terms. 

31.62 Final project efficiency was not intended to refer to something 
different from overall energy efficiency. The intent of the 
paragraph in which the term "final project efficiency" was used was 
to point out what items included in the energy efficiency calculation 
have the greatest effect on the energy efficiency of a project. 
Items 1 and 2 in this paragraph would fall under item 1 in the 
previous paragraph, item 3 would fall under item 2 in the previous 
paragraph, and item 4 would fall under item 4 in the previous 
paragraph. Section R-4. A. 13 has been revised to clarify the intended 

31.63 It is conceivable gases or fire could exit the retort through an 
undiscovered opening, but standard safety requirements would include 
detection and warning devices, and provisions for escape and rescue. 

31.64 This is intended to be a general statement. For a particular 
site-specific project, the final mine design would determine whether 
it would be possible to remove pillars. 

31.65 Refer to the response to Comment 31.55. 

31.66 Refer to the response to Comment 31.60. 

31.67 Approximately 954 million tons would be mined under this alternative. 
This has been clarified in Section T-1.E.9. 

As a result of the land exchange, no federal leases would be 
involved; only state land would be mined. 

It is beyond the scope of the EIS to address such economic factors as 
money that could be saved by an applicant because of differences in 
project design. 

Although the text does not state the project would operate for 9 
more years, it does state that project operations would continue 
"about 44 years rather than 35," which implies the same meaning. 

31.68 The documents cited in Section T-3.H.11 support this statement. 

31.69 Refer to the response to Comment 31.60. 

31.70 The potential risks of air emissions from a one-million barrel per 
day industry were examined in a public health and environmental 
effects risks analysis study (IWG 1982), The scenario analyzed was 
similar to the scenario in this EIS. Information from this study has 
been added to EIS Section R-4.A.2. 


i— ' 





1988 California Street, Berkeley, CA 94703 
(415) 845-0983 

Lloyd Ferguson 
District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 84078 

Dear Mr. Ferguson: 

I have reviewed the draft environmental impact statement for the 
Uintah Basin Synfuels Development. E-iy comments, which are attached, 
focus on air quality and water resources aspects of the oil shale 
projects. I did not review other portions of the EIS . The full bib- 
liographic citation for the references used in my comments are given 
in the BLH report, "Literature and Data Search of Water Resources 
Information of the Colorado, Utah, and Wyoming Oil Shale Basins." 

If you have any questions on these comments, please do not hesitate 
to call me on 415-845-0983. 

His Fox 



Co mm en t s on Uintah Basin Synfuels Development EIS 
J. P. Fox 






1. The pagination and figure, table, and section numbering system 
employed in this EIS are difficult to use. The accessibility of 
information, overall organization, and ease of use would be 
greatly improved if a numerical-sequential numbering system were 
employed, i.e., pages should be numbered from 1 to n, chapters 
from 1 to n , e t c . 

2. Adequate information is not presented on Bite hydrogeology in 
sections on affected environment to evaluate impacts on 
groundwater resources. As a minimum, a hyd ro geo log ic cross 
section of each project site and the location of alluvial 
aquifers and flood plains should be provided. 

3. The site specific and regional impact analyses do not 
adequately address groundwater and alluvial aquifer impacts. 
These sections should evaluate im pacts due to percolation from 
raw and spent shale disposal piles, from seepage through process 
water containment ponds, from oil and process water spills, from 
reduction in local recharge due to location of facilities and 
disposal piles, and from modifications in local hydrogeology 
caused by blasting-induced fractures, "mining, and overburden 
comp ression by disposal piles. Some of these issues are 
discussed further in subsequent comments. 

4. The air quality analyses do not address volatilization of 
toxic and malodorous gases during construction of spent shale 
piles and from open-air process water containments. These 
emission sources are more significant than many of the fugitive 
sources considered in the air quality analyses. Process waters 
containing high concentrations of organic and inorganic 
contaminants will be used to moisturize spent shale for dust 
control, for cooling, and to facilitate compaction. ContaminantB 
in these waters will be volatilized during spent shale spreading 
through mechanisms such as evaporation, photodecomposition, and 
microbial conversions. A less important, though related source 
of fugitive gaseous emissions is process waters stored in open- 
air equilization basins. 

These sources/mechanisms will release large quantities of 
gases including H 113, H2S, hydrocarbons, methylated metals, 
pyridine, etc. Approximately 50 X of the organics and inorganics 
in process waters may be released from disposal piles and pondB. 
This will result in a substantial local odor problem and may Lead 
to worker health problems. These emissions can be controlled by 
proper pretreatment of process waters prior to spent shale 
wetting or containment in open-air basins. Most of the oil shale 
developments described in this EIS do not include sufficient 
pretreatment to adequately control such air emi ssions. This 
emission source should be quantitated. 

qo cl 5 . Water units, i.e., ac-ft/yr, 
I some parts of the report. 


etc. are inconsistent in 








6 . Th 




p ro j ec 


irif or' 




e first sentence on p. xxxi states that 32,000 ac-ft/yr of 
will be required for the nine projects under the high-level 
tion scenario from the Green River and that a total 
ion of 132, 000 ac-ft/yr would be required for proposed 
ts , associated interrelated projects, and their associated 
tion increases. This seems to disagree with the 
ation presented in Table R-l-8. That table indicates that 
5,000 ac-ft/yr will be consumed from the Green River and 
196,700 ac-ft/yr will be used for the projects and related 

7. There is an arithemetic error in the last column of Table R-l- 

8, p. R-l-15. The sum of the values in this column is 5,510 

rather than 
"gr oundwa t er " 

4,970. Also, it is not clear whether the 
is under construction or operation. 

8. On p. SS-3, in the second complete paragraph, it is stated 
that 180,500 bpsd of oil would be produced by the five projects 
in this EIS by 1991. Table R-l-4 is referenced. This table 
indicates that 319,053 bpsd of oil will be produced, presumably 
during full operation of all projects, and this table does not 
present production information by year. 

9. The water resources significance criteria discussed on p. R-4- 
7 are inadequate to assess impacts that ma y result from oil Bhale 
development. These criteria should be expanded. The proposed 
spent shale disposal piles are located in and adjacent to 
alluvial valleys where significant recharge occurs. Thus , the 
recharge criterion should be expanded to consider reduction in 
recharge due to location of disposal piles, processing 
facilities, etc. 

The oil shale projects al6o may be expected to result in 
ficant groundwater degradation, and alterations in 
dwater quality should be addressed in this EIS. Groundwater 
ty will be impaired by percolation from raw and spent shale 
sal piles, by seepage from leachate catc hmen t d am s 
iated with the piles, and by seepage from evaporation basins 
other structures containing process waters. Spills of oil 
process waters also may affect groundwaters. There is an 
ance of literature on these topics, and this should be 
lted to quantify these impacts (see J. P. Fox, The Leaching 
1 Shale Solid Wastes: A Critical Review, 1982; Leenheer et 
1981; Leenheer and Stuber, 1981). 

10. The discussion of air quality significance criteria on p. R- 
4-4 indicates that state and federal air quality requirements, 
including prevention of significant deterioration standards, are 
used to assess air quality impacts. However, the EPA de minimis 
criteria, presented in Table R-4-3 , apparently were not 


gr oun 

qua li 

d i spo 

as soc 



a bund 

con bu 

of Oi 

al . , 




considered. These values provide criteria for determining 
whether specific pollutants are significant. Some of these 
constituents, particularly Hg, reduced S, and H 2 S may exceed 
these criteria for several of the proposed facilities. Adequate 
data are available to calculate emission of these de minimis 
constituents, and this EIS, as a minimum , should identify those 
constituents which exceed de minimis levels for each facility, or 
explicitly state that none are exceeded. 

11 . On 
sent enc 
s tr earn 
its us 
di sagre 
comb ine 
d i scu s s 
s imi lar 
has 1 e 
of impa 
piles a 


: are 

e wit 



t ure 
wa t 


s . 

r y s 

wa t 



1 sy s 

C t 8 O 

nd ot 


is ind i 
vium is 
h this 
uvia 1 a 
with gr 
of all 
n this E 
Se lf-pur 
low pro 
c t s to e 
o the ab 
m ( p . 
her f aci 

f ir Bt 
cat ed t 
ed in t 
ategor i 
qu if er 
oundwa t 
uvia 1 
c t s and 
IS is 
if ic a t i 
ce b Be s 

a 1 te 
a ch s y s 
sence o 

aqu if er 
lit ies 

hat for 

as sue 
he su rf 
zat ion , 
impac ts 
er impa 
aqu if er 

becau b 
o t hydr 
ring t 
t em . I 
f c r ite 

and to 

ph u 


c ts 




d t 
he s 
n th 



in spit 
are located 

nder Gro 
poses of 

water an 
d I encou 
a separ a t 
This is 
acts d if 
e a lluviu 
cally con 
harge of 
o ana lag 
ever it y 
is EIS, 
for j udg i 

e of the 


und W 
d tha 


f er s 
m a 
nee t e 
a 1 luv 




of an 

a ter 

c t io 
rt an 
d wi 
at eg 
pac t 
y d 

" , second 
water in 

pacts on 

to either 


to or ov 

t because 
tly from 
me 8 i t es 
th stream 

aqu if er s 
esses in 
i tud e of 
s to the 
iscuBS ion 

di spo Ba 1 
er them. 

12. The 
incoraple t 
" imp e rmea 
the s pen t 
" imp e rmea 
order of 
etc . Th 
prec ipita 
that fal 
pene tr at e 
pile con 
content , 
the pile, 
from wet 
pile . T 
Labora tor 
Disposal ; 
Mov emen t 
This stu 
and reac 
Similar ly 
packed wi 

e product 
ty Impac 
e vi se d . 
d throug 
c lima tic 

have low 
c ompa c t i o 
f 1 eacha t 
ce is not 

be large 
, pr e c ip 
nes of hi 
m mo i st ur 
ces in dr 
ng in wat 
ied by Ba 

1982 , 
nkment Ph 

for a hy 

would be 
about 10 
een obser 
ly et a 1 . 

i on on 
ts , " i 

It is 

h the 

cond i t 

by the 


, sha 


egard i 


ly eva 

ita t i o 

gher t 

e d ist 

ier zo 

er mi 



y s ica 1 

po the t 

cont i 

cm/ y r 

ved in 


d ev 


le c 

men t 


c t . 

por a 

n th 


r ibu 



S ta 


f i 


ina c 

e lop 
i t ie 
har a 
; i 
eva p 
at f 
d es i 
on t 
d is 
s ly 

na t i 
a » 

c ter 

t do 

ora t 

e c ip 



n m 







po s a 
d i s 

in the 

te and 
ly that 
on of 

Fir Bt , 
are not 
on the 
i st i ce , 
es no t 
ion of 
it at ion 
wou 1 d 

oi s tu re 
oughou t 
e water 
gh the 
r thw est 
nd t he 
1 pile, 

years . 

me t er s 

Percolation also will originate from raw shale stockpiles. 









b ioa b 






po t en 

do ex 



gh them 
ate to 
in envir 
Bays u 

shown t 
major io 

impor tan 
not care 
t ial for 
ist . T 
t ion . 



p rev 


hor t e 

ng IK 


db a 1 





his E 

p i 1 in 

v ery pe 
leers p 
ent perc 
tally g i 
r, 1980; 


ome raw 
so are e 

raw sha 
n spent 

en gi ne e 
if icant 
IS shoul 

ia a 
sha 1 
le 1 
s ha 1 
en v i 

se d 
i cant 
LI enw 
nd fa 
ted i 
ea cha 
e lea 
to co 


chat e 
n raw 
tes m 
c ha t e 
ntro 1 

water w 
ome de 
cha tes 
entr a t i 
1980; S 


sha 1 e 

y be a 

1 ea cha 
deve lop 
potent i 

ill mo- 
ve loper 

OQ6 O f 

s (Berg 
oxic . 
1 eac hat 
ce raw 
te migr 

from t 
er ' s pi 

1 for 

read i ly 

are no t 

w Bhales 

Li, Mo, 

980), and 

n, 1982) 

rganic C 


n t a s or 

ale piles 

ion , the 

s source 

b for raw 

leac ha te 


13. The discussion of irreversible and irretrievable commitment 
of water resources on p. R-5-2 should be expanded to include 
degraded groundwater resources resulting from leachate 
production. Disposal piles will be pe rmanent additions to the 
landscape and will continuously discharge leachates, long after 
the sites are abandoned. Since groundwaters are not readily 
decontaminated, this represents an irretrievable loss, 


Magic Circle 

14. The first complete paragraph on p. 
requirements for the Magic Circle project 
ac-ft/yr would be obtained from well6 for 
constructin) and that 1,000 ac-ft/yr woul 
Green River for later construction activ 
appear to disagree with those presented 
table indicates that no groundwater is use 
is used for construction. 






states tha 

t 120 





be c 

btained fro 

m the 


t ie 8 . 

These f 

igu res 

in Table R-l-8. 




that 700 ac 




5. On p. H-l-13 , the source of the 2,842 ac-ft/yr of water for 
he Paraho alternative is not specified. 

16. The note to Table M-l-2 on p. M-l-17 states that "All 
facilities required for the Paraho Process Alternative and On- 
site wells alternative would be located .within the plant site." 
Since all of these alternatives have off-site facilities, a more 
Ot.lo accurate statement would be: "All additional facilities required 
for the Paraho Process Alternative and On-site wells alternative 
that are not in the Proposed Action would be located within the 
plant site." 

117. The list of resources consumed in Table M-l-4 is very 
incomplete . A project such as this would also consume fuel oil, 
diesel, gasoline, etc. 


18. Table M-2-2 indicates that there is no difference in water 
consumption for the Paraho alternative and proposed alternative 

32.20 Iwh i 1 e p. M-l-15, section M-l.E.l indicates that the Paraho 
(gQUf\|al ternat ive requires 2,842 ac-ft/yr, which is considerably higher 
■than that required for the proposed alternative. 

32 2ll 19 * The controll 
|from those Bummari 

ed air emissions reported in Table M- 1-5 differ 
zed in Table M-2-1 . 


20. Tables M-2-1 and H-2-2 indicate that the 540 ac-ft/yr of 
water required by the proposed alternative represents 0.001% of 
the flow in the Green River. Page H-4-7 , first paragraph under 
"Surface Water," indicates that this same 540 ac-ft/yr represents 
0.01% of the flow of the Green River. Finally, the Technical 
Report for Magic Circle states that water requirement for the 
project amount to about 0.013% of the combined flow of the White 
and Green Rivers at their confluence. This should be resolved, 
and the discussion on p. M-4-7 amended to state at what point 
along the Green River the 0.01% (or 0.001%) refers to, i.e., 
specify the gaging station. 


21 . Pa 
ind ic a t 
bound ar 
This d 
of the 
unab le 
Tec hnic 
made o f 
p robab 1 
for gr 
as not 
whic h 








ed in 

nd er ly 


at t 
a d e 
t ion 
nd a 
ha Le 


, thir 

he d isp 

f roi 1 



with c 

ny di bc 



be " 


1 ft 


This li 

c ont ami 


g roundw 

d p 


us s 








ar agr 
1 pil 
nch 1 
conf 1 


ion o 
ou 1 d 
e rmea 
i ne r 

pe rue 

ion f 

r s ar 

aph und 
e s are 
ay er b o 
ic t wit 

re por t 
compac t 
f an ov 
be poin 

than s 

wou Id h 
u t 
able sh 

wou Id 
r om per 
r wou Id 
e deg ra 

er "Spent 
under lain 
f o ven-d r 
h a s imil 

ind icate 
ed to 80 
en drying 
ted out t 
pent aha 1 

ave a 1 

c e r t ain 1 
ou Id be r 
not "remo 

only red 
ded . 



3 ha le 
Due o 


e fi 

y w 
e p la 

ces i 



ou 1 d 





D ispo 
pe rme 
n p 
1 i ner 
ea b il 
pot en 
the p 


ha le 




ch a 

"1 ow 
t ial 


22. The discussion of surface water impacts on p. M-4-7 should be 
expanded to include im pacts on water quality due to consumpt ive 
use of water and on water quantity due to changes in overland 
runoff. TheBe are at least as significant sb the subsequently 
discussed groundwater im pacts. The consumptive use of 540 ac- 
ft/yr of water will increase the TDS at the diversion point and 
all points downstream. The plant facilities, disposal pile, etc. 
will reduce the quantity of overland flow that reaches stream 
channels and alter its t empo ral and spatial distribution. This 
will affect local streamflows, particularly in the washes. 

23. The discussion of the environmental consequences of 


proposed action on groundwater resources is inadequate. 


hydraulic properties and chemical quality of alluvial and 



aquifers will be altered by the proposed project by: 


percolation through raw and spent shale disposal piles; 


modification of hydraulic properties from weight of pile; 


changes in permeability due to blasting and mining; and 





(COnt)j reduction of natural recharge. 


a ceo 
1 ea c 

1 .10 
& i 1 i 
ha s 
c ond 
sp en 
sa li 

The 1 

adat ion 
.4.2 s 
er t 8 id 
c a t e s 
era t ure 

been su 


i t i OD8 


t shal 
ni t y . 

eacha t e 

to Mag 

, cont 


as s t a 

tates t 

ost of 


s are 

t emp era 

b 6 t ant i 

pent Eh 

s im i 1 a 

(Hall , 

a hav 

ic ( 
r ar y 
s hi 
ted c 
hat i 
the t 
ot hi 
a ted 
ale 1 



ii the 

to im 

a p. 
e t or t i 
nist in 
^h eno 


com t h 
I ) dem 

11 no 
103 th 
ng tern 
g calc 
ant to 
ugh to 
tes ( 
ecen t 
e prop 
on s t r a 
nc en t r 

T3 spen 
may r 
ions in 
t be 
e Techni 
ium and 
c hemic 
ee Park 
study wh 
10- ton 
se d for 
ted that 
at ion of 

t eh 
e eu 1 t 
the T 
es i st 

G Of 

mag ne 

1 1 


et al 

ich r 

re tor 




e d i 
in g 
t to 
port . 
300 t 
ua ox 
aC03 , 
or t e d 
or gan 

spo se 
1 Re 
c he 
o 16 


9) . 


ic C 

d of 
po r t . 
mica 1 
c t ion 
00 F 


etc . 


sue h 

re ce iv e 
this pr 
and t h 
po lluta 
av a i lab 
ant icip 
mo i s t u r 
sp re a d i 
f rom 
g roundw 


econd i 

of NTU 

d by the 

ed p roc e b 


oc ess wa t 

s will b 

that or 
nt s will 
1 e re sea 
ganics wi 
02, H2S) 
at e d em 
i zed wit 
ng to coo 

plus t ho 
he spent 

ter s . 




11 n 
i ss i 
h ad 
1 it 
se a 

ant f 
1 eac ha 

er wil 
ream w 
i lab le 
r emo ve 
ugg est 
t be b 

ns . ) 
i t iona 
and t o 
ded du 
1 e an 

c t or 

1 be 

s t ea 
ill b 

u tant 
d by 
b t ha 
u rne d 


d wi 


s wi 

t it 

s t e a 

va lu 





ana f 


11 b 






d w 





wa t 

m ge 



s t-re 

ith h 
f the 
ed to 

bur ne 
any i 
he ga 
dur in 

a t ion 

rt i 

O t 8 



d a 

e ly 


s ph 

i s 

g co 

am in 

s id er i 
ing h 
nd ica t 
p en t s 
L am ina 

hni cal 
nd in 
). H 
tha t m 
a se , 

sub se 

nvey an 

ants i 

11 be 

h und 

ng the 

and ling 
es that 
ha 1 e in 
nt s in 
sha le 

owever , 
any of 

1 ter ing 
quen t ly 
le ac he d 
er ly ing 

24. On p. M-4-18, second paragraph under section M-4.B, second 
sentence, it is stated that emissions for both processes are 
identified on Table M- 1 - 5 . Table M-l-5 shows emissions only for 
the proposed alternative. 

125. The titles of Tablea M-4-5 and M-4-6 are confusing. The 
phrase "Magic Circle Retort Alternative" should be changed to 
"Small-scale Paraho Process Alternative." 


26. The on-site well alternative discussed on p. M-4-18 would 
increase flow in the Colorado River System and decrease the TDS, 
relative to the proposed alternative. This should be stated on 
p. M-4-18. 

27. The project components section on p. M-l-11 does not discuss 

32.30] product gas recovery and cleanup. The discussion of the 

wastewater treatment system appears to address only mine drainage 





and runoff (from processing plant). Many other wastestreams will 
be produced at this facility (i.e., retort water, gas condensate, 
gas cleanup effluents, oily waters, etc.) The treatment, if any, 
proposed for these other effluents should be discussed. 

28. This project does not include on-site upgrading. The crude 
shale oil will be transported to any combination of three 
refineries (p. M- 1 - 1 ) . This upgrading will produce hazardous 
wastes such as As-laden catalysts, air emissions, and water 
effluents. These should be considered in the present EIS. In 
particular, one possible final destination for the crude shale 
oil is the Roosevelt refinery, which is within the study area. 

Paraho-Ute Proiect 

29. On p. P-l-10, fifth and sixth paragraphs, it is not clear to 
the reader why 39,500 bpsd of dry oil go into the upgrading 
facility and 42,000 bpsd of hydrotreated oil are produced. 


1 1 on on 
n ly re so 
proc es 
u Id be ai 
wou Id not 
t d i f f e re 
mpt ion an 
s more wa 
cess doe s 
ics of 
y . And 

among th 
em i ss ions 
p. P-l-19 


Al ter nat 

ive " on p . 

P-l-19 states 

urce tha 

t would b 

e affected 

by us ing an 


combina t 

ion direct- 

indirect mode 

r quality 

and that 

air emissions from these 

be s ign i 

ficant ly 

diferent from those of the 

d mod e . 

This is 

inaccurate . 

First , the re 

nces between these 

alternatives in t erms of 

d water quality im 
ter (125 gal/bbl) 
(McKee and Kuncha 

pacts. The indirect mode 
than the direct mode (89 
1, 1976) . The leaching 

the two 

types of 

spent shale 

also differ 

there are 

s ignif i c 

ant differences in offgas 

ese two processes, 

and it is 

not c 1 ear why 

wou Id be 


as suggest 

ed in the last 


32.35 1 


30. The sec 
that the 
ind irec t-mod 
sc enar i o 
Proposed dir 
are import an 
water cons 
process use 
gal/bbl) pro 
charac ter i st 
s ignif icant 1 
composi t ion 
contro lied 
sent enc e on 

31. A sufficient number of alter natives to the proposed project 
were not considered. A single water supply alternative, from the 
Bonanza Power Plant, was considered (p. P-l-19) while for other 
projects, multiple water supply alternatives were considered. 
Similarly, alternates to the power transmission line and access 
roads were not considered. 

32. The total controlled emissions in Table P-l-6 differ from 
those presented in the Air Quality Technical Report in Table 4-1. 

33. The discussion of impacts on water resources on p. P-4-7 is 
inadequate and should be expanded to include the surface water 
impacts noted under comment 22 and the groundwater impacts noted 
in comment 3 . 


34. On p. T-l-12, third paragraph and in Table T-l-6, total 
suspended particulates are reported as 120 kg/hr while in table 
p. 4-9 of the Air Quality Technical Report, it is reported 

4-1 , 





(conl)l 08 127 k s/or. 

.35. The list of resources consumed in Table T-l-5, p. T-l-32, ie 
9jC.wS I i ncompl e te and should be expanded to include diesel, fuel oil, 
et c . 


36. In Tables 
boc ioeconomics 
summar i zed in 

T-2-1 and T-2-2, the employment figures under 
seem to conflict with personnel requirements 
Table T-l-k and with those reported in the 

Technical Report in Table 3.2.1. The relationship between these 
three seta of figures la not clear. 

37. In Table T-2-2, the air emissions for the Proposed Action 
vere omitted and should be added. 

38. The air quality section on p. T-3-1 does not address the 
volatilization of malodorous and toxic gases from process 
waters used for spent shale moi6turization. Haste treatment 
proposed in the Technical Report (sour water stripping) will 
remove MH3 and H2S but will not affect any substantial reduction 
in organoni trogen and other organic compounds, many of which are 
volatile, ma lodorous, and toxic. Additional treatment, which 
must include substantial reduction of or gan ica, would be required 
to eliminate volatilization of these compound s from spent shale 
diopooal piles. 

39. The discussion of impacts on water resources on p. T-4-3 is 
32.42 (inadequate and should be expanded to include those in pacts noted 

c o mm ents 3 and 22. 



J. Phyllis Fox Consulting Services 

32.1 BLM has reviewed the comments provided. Responses to each follow. 

32.2 The alpha -numeric system used to number chapters was adopted to 
accommodate potential changes in the scope of the EIS. The 
alpha-numeric pagination system is a logical extension of the chapter 
numbering system. It is often used in BLM EISs. 

32.3 In view of the insignificant impacts on ground water, it was 
determined that detailed hydrologic illustrations were unnecessary. 

32.4 Percolation from raw and spent shale piles would not be expected to 
take place (refer to the response to Comment 32.11). However, if it 
should, the applicants' plans to collect, treat, and use any water 
that should move through, or run off of the piles would prevent 
significant impacts. Also see response to Comment 32.14. 

Water containment ponds are designed so they would not have seepage. 
They would be lined to prevent seepage, and the water in them would 
be in a continual state of treatment, reuse, and refilling by water 
from the applicable source (Green River or White River). 

Oil and process water spills could occur on site (within the 
plant/process area boundaries). As identified in Section l.D.l for 
each site-specific project, the plant sites would be diked to contain 
run-off (which would contain any spill) and the wash down water would 
be reprocessed through the oil-water separators. All plants would be 
required to develop detailed oil spill contingency plans. 

Reduction in local recharge is not an issue. At most, 20 square 
miles (for roads, buildings, spent shale piles, and similar 
structures) would be "sealed" from percolation and potential 
recharge. This is so small a portion of the project area that it 
would have no noticeable effect. A similar situation exists for 
modifications in local hydrology. 

32.5 BLM is unaware of an adequate data base that might be available for 
quantifying noncriteria emissions during the construction of spent 
shale piles and the operation of process water containments. A data 
base is being developed by the Department of Energy, Fossil Energy, 
with studies which were begun in 1982 to address both of these 
potential issues. 

Emission controls such as surface covers would generally be employed 
at each project to reduce the evaporation of organic compounds from 
equipment like oil/water separators. Treatment of certain process 
water also would be a part of most of the projects. However, the 
rate of uncontrolled pollutant emissions from ammonia and methylated 
metals, for instance, is unknown. Section R-4.A.2 has been expanded 
to recognize these areas as possible concern. 

32.6 The report has been checked for consistency. The units used are 
appropriate for the various sections. 



32. 7 The figures in Table R-l-8 represent the most likely maximum amounts 
of water that would be withdrawn from the individual rivers. Note 
that footnotes b and c indicate use figures for the White River Shale 
Project and for municipal and agricultural uses are included in the 
totals for both the Green and White rivers. Therefore, it is 
inaccurate to combine the totals of the various columns of the 
table. A footnote has been added to Tables R-l-8 and R-l-15 to 
clarify this point. 

3Z.8 The error in Table R-l-8 has been corrected. The ground water 

column represents operation consumption. This has been clarified on 
the table. 

32.9 As stated in the sentence in question, 180,500 bpsd is the full 
production figure for the five site-specific projects and is the 
rounded total of the production figures presented in Table R-l-4. 

The 319,053 bpsd figure is the total production for the site-specific 
and conceptual projects. 

The year when all the site-specific projects first would reach full 
production is 1994 rather than 1991 as stated in the Draft E1S. This 
date is based on information presented in Table R-l-1. A reference 
to Table R-l-1 and the correct full production year has been 
included in the Final EIS Site-Specific Analyses Introduction. 

32.10 Contamination of ground water has been added to the significance 

Spent shale will be placed on rolling uplands and, in one operation, 
in a steep ravine tributary to the White River. Little or no 
alluvium occurs in the ravine. Spent shale on the uplands would 
cover only the uppermost heads of drainage which contain little or no 
alluvium. Significant recharge occurs in the lower reaches of these 
drainages where thicker alluvial deposits may be present. The total 
area of spent shale would be less than 12 square miles (0.0024 
percent) of the nearly 5,000 square miles of the part of the Uintah 
8asin addressed in this statement. 

32.11 Development of sufficient leachate in spent shale deposal piles to 
endanger either surface or ground water requires a quantity of water 
several magnitudes greater than available in this arid to semi-arid 
climate. It is well known that recharge in these climates occurs 
only in depressions or below stream or drainage courses. Studies 
(Freeze and Cherry 1979) acknowledge that effective recharge may not 
take place above a deep water table below a sand or gravel plain even 
in a humid climate. 

Unfortunately, the bulk of investigation on the potential of water 
contamination by spent shale has dwelled on leachate, the production 
of which requires saturation. The few investigations addressing the 
potential for leachate production are adequate to show that any 
leachate produced would be limited to the upper few feet, or at 
maximum, few tens of feet, where 40 inches of water might be used 

initially to leach the root zone. Subsequent evapotranspiration 
would remove this moisture and leave any potential contaminants 
attached to the spent shale. 

The hydrologic regime expected in the spent shale deposited on land 
surface in the southeastern Uintah Basin is similar to that described 
by Winograd (1981). He shows that ambient flow of moisture through 
thick, unsaturated zones in arid and semi-arid climates is extremely 
small; it may not be readily measurable with present instrumentation. 
He also indicates that ionic transport may be retarded by several 
orders of magnitude in comparison to moisture movement. The work is 
well-noted and contains a wealth of significant, worthwhile 
references. Section R-4.A.3 has been expanded to clarify these 

32.12 Very little data are available to assess the magnitude of noncriteria 
pollutant emissions from oil shale and tar sand facilities. As a 
part of the PS0 permit submittals, four project applicants supplied 
information and their best estimates of certain noncriteria 
pollutants. These values are given in Table C-4. Of the numbers 
reported, beryllium and sulfuric acid mist emissions exceed the EPA 
"de minimus" emission rates; several other values are close to the 
"de minimus" rates 

The Chapter R-4 Significance Criteria section has been expanded to 
include discussion of EPA "de minimis" emission rates. Section 4. A. 2 
of each site-specific analysis has been expanded to include the 
projected emission rates of pollutants covered by the de minimis 

32.13 Where an applicant considered using alluvial aquifers, there would be 
direct and intimate contact with the surface water. This type of 
contact would be required to ensure an adequate water source. The 
term alluvial aquifer may be somewhat misleading due to the 
applicants' designs. The proposed designs consist of a large 
diameter shaft sunk into the streamside alluvium with small diameter 
horizontal shafts radiating from it, thus the intimate hydraulic 

32.14 Because the applicants have stated they would contain and treat or 
use any runoff water from the spent shale disposal piles and raw 
shale stockpiles, the potential for leachate reaching a water source 
would be remote. (See also the response to Comment 32.11 regarding 
leaching potential.) Furthermore, these piles would accommodate much 
more water than would be available, and any moisture succeeding to 
infiltrate deeper than the root zone would return to the surface to 
be evaporated and transpired. In addition, the processing area would 
be compacted due to truck traffic, construction work, and by design. 
This would significantly reduce or eliminate infiltration. 

32.15 Refer to the response to Comment 32.11. 

32.16 Table R-l-8 has been revised to include Magic Circle's use of ground 
water during construction. 



Emission Estimates for Selected Noncriteria Pollutants 
(tons per year) 

Magic Circle 









Total Reduced 

Reduced Sulfur nil 
Sulfuric Acid 

Mist 16.1 































*Final expansion. 


































The Small-Scale Paraho Process Alternative is an alternative to the 
proposed retort process and would not affect the water supply source. 
It could be used in conjunction with the proposed water supply system 
or any alternative w.ater supply system. 

The statement is correct as written. Neither the On-Site Wells 
Alternative nor the Paraho Process Alternative would have off-site 

The list of resources consumed is not intended to be all-inclusive 
but rather gives major known uses. Engineering details are not 
sufficiently developed to generate an all-inclusive list. 

Section M-l-E.l was in error and has been revised. There would be no 
difference in water consumption for the Paraho process alternative 
and the proposed action. 

The values in Table M-2-1 and M-2-2 have been changed to correspond 
to Table M-l-5. See also the response to Comment 30.21. 

The 0.01 percent figure is correct. Tables M-2-1 and M-2-2 have been 
revised. The gauging station for the Green River data has been 

The EIS discussion refers to the use of "shale fines;" spent or raw 
is not specified. The fact that they would be oven-dry raw shale 
fines has been clarified. However, it is the grain size (fines) that 
is important, not what stage of the processing they have come from. 

The fact that the boundaries of the spent shale pile would be 
slightly permeable has been clarified in Section M-1.D.2. 

The water quality parameter that was considered critical to this 
study was salinity. Withdrawal of these amounts of water are so 
small compared to the average annual flows (400,000 cfs), that 
salinity changes are beyond the detection limit of the CRSS model. 

Overland runoff in this area, if decreased, could only improve water 
quality. The availability of sediment for transport is so high in 
these areas that it far outweighs the ability of streams and washes 
to transport sediment. Due to this, surface evaporative salts would 
not dissolve and move with run off, and less sediment would be 

Refer to the response to Comment 32.11. 

Refer to the response to Comment 32.11. 

Emission rates for the alternative have been added to Table M-l-5. 

Tables M-4-5 and M-4-6 have been deleted based on updated 
information. Refer to the response to Comment 13.4. 

The comment is true to the extent the aquifer is not a tributary to 
the Colorado River system. 


32.30 Product gas recovery and cleanup is part of the Internal shale 
processing process, and as such, its details were not included in 
the EIS. Refer to Section 1.10.2 of the applicant's technical report 
for the available details. Any wastewater contaminated with oil 
would be sent to the slop oil tank and reprocessed. Retort water, 
gas condensate, gas cleanup effluents, and similar substances were 
included in the terra "wastewater from the processing plant," which 
would be treated by a conventional treatment plant and used on the 
spent shale pile. 

32.31 Upgrading shale oil at existing refineries is not part of the actions 
proposed by the applicants and, therefore, is not covered by this 
EIS. The impacts due to upgrading shale oil may be covered by a 
refinery's existing PSD permit. If not, impacts would be analyzed as 
part of the process to amend the existing permit. 

32.32 By adding hydrogen, the 39,500 bpsd of crude will swell to 42,000 

32.33 The retorting alternative section was in error and has been deleted 
from the EIS. Paraho has developed two other modes of processing. 
However, the company has not proposed their use on this project, 
since the direct heated mode has been demonstrated over a longer 
period of time and a wider range of operation conditions. Paraho 
plans to continue its research in retorting technologies and at some 
future date, second generation retorts may be proposed as an improved 

32.34 Additional alternatives for the Paraho project have been analyzed in 
the Final EIS. Refer to the discussions of the White River 
Alternative Water Supply System, Additional Lands Alternative, and 
Phased Approach Alternative. No alternative access roads or power 
transmission line was added, because no alternatives that would 
significantly reduce the proposed action impacts (which were 
generally insignificant) are evident. 

32.35 The Air Quality Technical Report was only able to consider emission 
rate changes through January 1982 in order to complete the modeling 
analysis. The values appearing in Table P-l-6 were submitted to BLM 
by the applicant after this time, and it was too late to incorporate 
these new values into the Air Quality Technical Report. The more 
recent values are lower than the values used in the analysis; 
therefore, the analysis used conservatively high emission rates. 

32.36 The level of detail of this discussion is in keeping with the 
available data and the regional impact analysis. Refer to the 
responses to Comments 32.4 and 32.24. 

32.37 The number on page T-l-12 should also be 127 kg/hr. This has been 
corrected in Section T-l.D.l of Final EIS. 

32.38 The list of resources consumed is not intended to be all-inclusive, 
but rather lists major known uses. Engineering details are not 
sufficiently developed to generate an all-inclusive list. 

32.39 There were some discrepancies in the Tosco employment figures shown 
in the Draft EIS and the Socioeconomics Technical Report. Tables 
T-2-1, T-2-2, and T-l-4 have been corrected to ensure consistency 
between the EIS and the supporting technical report. 

32.40 The emission rates have been added to Table T-2-2. 

32.41 Refer to the response to Comment 32.5. 

32.42 Refer to the response to Comment 32.36. 











19 October 1982 

Lloyd Ferguson, District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, UT 84078 

Re: Uintah Basin Synfuels Development 

Dear Mr. Ferguson: 

The National Wildlife Federation has reviewed the "Uintah 
Basin Synfuels Development" Draft Environmental Impact Statement 
(DEIS) . The Federation is submitting these general comments for 
your consideration. In addition to these comments, we also adopt 
and incorporate by reference the comments on the DEIS filed by 
the Environmental Defense Fund. 

The National Wildlife Federation (NWF) has over 4.6 million 
members and supporters, 22,000 of whom live in Colorado and Utah. 
Environmental impacts resulting from resource developments are a 
principal concern of NWF. We believe that the protection of the 
environment is best achieved through reasoned and judicious 
resource development decisions and that certain areas, due to 
their environmental quality and natural beauty, are best protected 
by excluding all development. The potential impacts associated 
with the proposed Uintah Basin Synfuels Development' Project rep- 
resent a central issue for our national membership, including our 
Colorado and Utah members, many of whom view the Green, White, and 
Yampa Rivers and surrounding areas as key links in maintaining the 
environmental integrity of northeast Utah and northwest Colorado. 

NWF is principally concerned about two issues raised in the 
DEIS: (1) analysis of the alternatives and the selection of a 
preferred alternative, and (2) environmental impacts resulting 
from the development of the proposed projects. 

Selection of Preferred Alternative 

NWF takes issue with the fundamental premise of the DEIS: 
all proposed synfuels projects will proceed at their estimated 
levels. We assume that the granting of monies for the development 

Lloyd Ferguson, 

Page 2 

19 October 1982 

District Manager 





of tracts Ua and Ub from the Synfuels Corporation is driving the 
issuance of the DEIS. However, restricting the regional cumula- 
tive analysis to a discussion of a "high level scenario" and a 
"low level scenario" hardly constitutes a reasonable review of 
viable alternatives to the proposed project. In fact, given the 
present synfuels economy , we fail to understand the need for 
this synfuels development at this time. The DEIS should be with- 
drawn for that reason alone (i.e., no demonstration of need) or 
should be written to analyze the Ua and Ub projects only. Several 
of the projects analyzed in this DEIS are no longer being actively 
considered. The rush to permit these projects is premature. 
Other uses of the land are foreclosed by the uncertainty of the 
status of the projects; if and when the projects proceed, the land 
use situation may have changed and may require additional analysis. 

The DEIS fails to evaluate other reasonable alternatives to 
the identified preferred alternative {full scale production levels 
for all projects) . This deficiency in analysis violates NEPA 
requirements. For example, analysis of a no-action alternative 
does not occur in the regional cumulative analysis. Burying the 
no-action alternative analysis in the project specific analysis 
dilutes the thrust of the no-action alternative and fails to supply 
reviewers with sufficient data to assess the cumulative impacts 
of the proposal. Concomitantly, the baseline analysis summarized 
in Tables R-l-2 to R-l-17 contains requirements for projects in 
Utah and Colorado, but most of the Colorado project requirements 
are listed as unknown. NWF is very concerned that a rigorous and 
definitive cumulative analysis be performed in Colorado and Utah. 
The jurisdictional mismatch issue means that Colorado will receive 
many of the impacts from synfuels development in Utah, without the 
means to mitigate them. It is the NWF's position that regional 
cumulative analysis presented in the DEIS is insufficient for making 
regional resource management and project impact mitigation decisions. 

We can discover no rationale underlying the selection of a 
preferred alternative (i.e., the high level scenario) other than 
that the high level alternative would not exceed so-called resource 
"threshold levels," assuming "that mitigating measures would be 
incorporated to avoid 'worst-case 1 conditions" (xxix) . Manage- 
ability of impacts from the proposed developments should not be 
the sole criterion for determining a preferred alternative. NWF's 
position is that a preferred alternative should specify committed 
mitigation measures. Existing regulations may be inadequate to 
deal with the projected environmental impacts from synfuels devel- 
opment. BLM has not traditionally leveraged socioeconomic impact 
mitigation agreements between projects and local or state govern- 
ments. Identification of a preferred alternative based on the 






Lloyd Ferguson , 

Page 3 

19 October 1982 

District Manager 

assumptions that mitigation of impacts will occur, that existing 
environmental regulations are sufficient to ensure environmental 
integrity, and that socioeconomic impact mitigation agreements 
can be worked out on the "front end" of the project, belies the 
traditional role of BLM in implementing environmental and socio- 
economic impact mitigation. We have to look no further than the 
recently closed Colony Project in Colorado to see that the boom/ 
bust cycle still exacts its economic, social, and environmental 
tolls despite the implementation of some committed mitigation 
measures. We need not repeat this scenario elsewhere in the West. 

Environmental Impa ct s an d Mi tigation 

The magnitude of the surface disturbance of the proposed 
action (36,911 acres) is downplayed in the DEIS analysis by the 
assertion that nearly 80% of the disturbed land can be reclaimed 
to grass (cover vegetation) in 3-10 years. The assumption of 
reclamation success in a region characterized by a semi-arid 
climate and unfavorable soils is tempered by the recognition that 
"revegetation is difficult on most of the soils in the region. 
. . . Unfavorable soil properties, such as rock- fragments on the 
surface, thin surface layers , moderate to strong alkalinity, and 
shallow depths, are very common in the region and would present 
problems for erosion control and revegetation." (R-3-34) . NWF 
submits that reclaiming the disturbed lands to pre-project vege- 
tation would take between 75 and 300 years. (R-4-59) . No success- 
ful reclamation efforts have been demonstrated in this environment 
without intensive management or for that time period. Responsibility 
for reclamation management after completion of the project is not 
discussed . In all likelihood the federal government will have to 
assume the responsibility and costs of the reclamation effort 
after cessation of the project. The DEIS points out "that climatic 
conditions in the area of influence make establishment of vegeta- 
tive cover difficult . . . [and that] favorable years for seedling 
establishment can be as variable as once every 20 years," (R-4-56) . 

Spent shale disposal reclamation research has not demonstrated 
a long term success rate and does not support the claim in the 
DEIS that "spent shale disposal areas would be reclaimed in stages 
. . . the surface of these areas would be stabilized and made 
suitable for plant growth through various reclamation measures and 
procedures." (R-4-60) . In fact, no one knows if spent shale dis- 
posal sites can ever be reclaimed. Certainly , application of a 
12 to 24 inch mantle to the spent shale will encourage vegetative 
cover in the short term. However, in an area of minimal topsoil 
depth (less than 6 inches) , volumes of topsoil required to cover 
spent shale piles are not available. 



Lloyd Ferguson, 

Page 4 

19 October 1982 

District Manager 

NWF does not agree with the assertion in the DEIS that the 
loss of 52,631 acres" of small non-game mammal habitat is not a 
significant adverse impact. Removal of that amount of habitat 
may have significant impacts on small mammal populations in the 
area. These potential impacts need to be defined and not sum- 
marily dismissed because of the total acreage of "available" 
habitat. (R-4-67) . Similarly, potentially adverse impacts to bird 
habitat cannot be ignored due to the "total amount of habitat 
available to bird species." (R-4-67) . Impacts on big game populations 
are analyzed in a similar vein. Impacts are dismissed "since big 
game animals can easily move into adjacent habitat . . . [and] 
would not cause significant problems if the adjacent habitat were 
below carrying capacity." (R-4-67) . Definitive carrying capacity 
data should be presented in the DEIS. If carrying capacity data 
do not exist, they need to be gathered prior to any definitive 
analysis of project impacts on wildlife populations. 

The magnitude of the proposed project requires a detailed 
presentation of reasonable alternatives and a thorough discussion 
of environmental impacts and impact mitigation measures. The DEIS 
should be revised sufficiently to correct these deficiencies. 

Thank you for the opportunity to comment. 




/%. \4k^ 

Prances M. Green 





National Wildlife Federation 

33.1 The comments filed by the Environmental Defense Fund are included as 
Letter 30. 

33.2 The views expressed will be considered in the decision-making 

33.3 It is incorrect to assume that the granting of money from the 
Synfuels Corporation is driving the issuance of this EIS. As stated 
in the EIS Preface, the driving force for this EIS is the request for 
rights-of-way across public land to allow private development. This 
EIS does not address the development of federal oil shale leasing. 
The impacts of federal least tracts U-a and U-b were covered in the 
Final Environmental Statement for the Prototype Oil Shale Leasing 
Program (BLH 1973f). Development of these tracts is included in 
this tlS only as an interrelated project in order to assess 
cumulative impacts. 

All the appplicants' proposed projects (the projects for which this 
EIS will be used in making a decision) would be developed on State of 
Utah leases or on private land. (No federal oil shale leases are 
involved.) The market place will actually determine whether these 
projects proceed at the indicated levels and timeframes. It is not 
the responsibility of BLH to make this determination for privately 
developed projects. 

BLM is unaware of any other uses proposed for the land that would be 
affected by the projects that are being or would be foreclosed. All 
applicants currently have valid leases to develop the state land 
where the mine and processing facilities would be located. In 
general, the project facilities located off the state lease tracts 
(roads, power transmission lines and buried pipelines) would not 
limit public use of the affected land. 

33.4 Refer to the responses to Comments 16.4 and 30.8. 

33.5 Even though specific resource requirements are not included for all 
Colorado projects, this does not mean that these project were 
omitted from the cumulative analysis. Development in western 
Colorado would interact cumulatively with synfuels development in the 
Uintah Basin in three main areas— socioeconomics (population increase 
and associated pressures on community infrastructure and natural 
resources), air quality, and water quality and flow in the Colorado 
River system. The modeling efforts 1n each of these areas included 
assumptions about the cumulative effects of projects where no data 
were available (refer to the methodology sections of the air quality 
(Systems Applications Inc. 1983) and socioeconomics (State of Utah 
1983) technical reports and the Colorado River Simulation System 
Executive Summary (Bureau of Reclamation 1981). 

In addition, this EIS does not address a true regional plan of 
development. The "regional" part of the EIS was misnamed in the 
Draft EIS. It has been changed to Nine-Project Cumulative Analysis 
to better reflect its intended purpose. 

33.6 It is BLM's contention that sufficient regulations exist to assure 
that adequate safeguards are taken when developing a project of this 
magnitude. It is the intent of this EIS to identify impacts and 
suggested mitigation that would reduce or eliminate those impacts. 
Determining the acceptability of an impact is not the purpose of an 
EIS, rather it is to analyze and discuss impacts. It will be the 
decision-maker's responsibility to consider these impacts and decide 
on mitigating measures that would be included as stipulations in any 
permits or grants issued. 

The State of Utah has recently passed a law (S.B. 170) that requires 
companies to develop impact mitigation plans that cover socioeconomic 
changes associated with their activities. These plans are completed 
in advance of any on-the-ground activities. 

33.7 Discussions throughout the EIS acknowledge that achieving successful 
reclamation and erosion control on lands disturbed in the Uintah 
Basin would require an intensive reclamation program due to the 
unfavorable climatic and soil conditions. The response to Comment 
22.5 addresses the basis for determining that reclamation and erosion 
control would be successful. As stated by Sedgley (1974), "the 
successful revegetation of oil shale sites will not be easy, but 
obviously it can be done if present technology is fully utilized and 
research is planned to require necessary additional knowledge." The 
applicants are responsible for reclamation efforts throughout the 
project life and after abandonment, with inspection and certification 
determined by the landowner or authorizing agency (Appendix A-8). 

33.8 Specific measures associated with surface mining and spent shale 
disposal area reclamation are based on recent research and field 
trials identified in a footnote to Table A-8-2. All practices and 
procedures identified are well, documented and have been demonstrated 
to be reliable in making assumptions regarding effectiveness where 
properly implemented. 

As discussed in Section R-4.A.4, volumes of topsoil and suitable 
plant growth materials (soil parent material - alluvial, aeolian, and 
sedentary) are available, but will require intensive stockpiling and 
use procedures. 

33.9 No carrying capacity data exist for any wildlife species and areas in 
the Uintah Basin. The impact of the loss of 52,631 acres of small 
nongame mammal habitat would be the loss of most of the animals on 
the disturbed area; repopulation would be rapid once reclamation is 
completed. There are estimates of breeding bird losses in each 
site-specific analysis. Section R-4.A.4 is merely an overview of the 
whole area; specific details related to individual projects are noted 
in site-specific Wildlife sections. 

33.10 Refer to the responses to Comments 16.4 and 30.8. 







October 20, 1982 

Mr. David Moore 
Vernal District Office 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 84078 

Steven B. Golnar 
Town of Dinosaur 
P.O. Box 
Dinosaur, Co 81648 

Dear Mr. Moore: 

Thank you for allowing the Town of Dinosaur to comment on the Uintah Basin 
Synfuels Development Draft Technical Report , August 1982. 

It is evident in reviewing the Synfuels report that the base information used 
in generating projected impacts for Dinosaur is out dated and inappropriate. 
We appreciate the acknowledgement appearing in the report that Dinosaur 
will experience "significant" cummulative impacts from the five Synfuels projects 
discussed. The extend of this "significance" is where our figures differ. 

A major factor which was not addressed in the Synfuels report is that the Town 
of Dinosaur is currently experiencing massive impacts from 3 projects: 

1. The Western Fuels Deserado Coal Mine; 

2. Deseret G & T's Unit 1 of the Moon Lake Power Plant Project; and 

3. The railroad being constructed between these two sites to transport 
coal to the power plant. 

Because a sizeable portion of the electricity generated by the Moon Lake 
Power Plant will be used by the Synfuels projects discussed in your report, 
don't these projects qualify as support industries for the Uintah Basin 
Synfuels effort? If these projects do, then isn't Dinosaur already experiencing 
population impacts associated with Uintah Basin Synfuels Development? If 
this is the case, then why aren't these impacts considered in the Synfuels report? 


A. Problem 

The root of the problem that socioeconomic researchers encounter when dealing 
with Dinosaur is that there is little documentation on the Town. It is difficult 
to determine impacts when few numbers are available. The population of the Town 
according to the 1980 census was 312. This figure, for that time, was fairly 
accurate. As base information for the projections appearing in the Synfuels 
report 1980 Census data was used. 

Mr. David Moore 

Uintah Basin Synfuels Comment 

October 20, 1982 

Page 2 





B. Current Town Population/Housing 

Our information shows that Dinosaur's population has tripled since the 
beginning of 1982. This population change over a ten month period works out 
to a 240% increase. This growth rate contrasts sharply with the historic 
growth rate of 1.7 percent (pI-22) used to predict "a population of just 
over 400 by the year 2000." The Synfuels report (pI-26) estimates 1982 
baseline population to be 451 with 158 households. Conservative estimates 
of the Town's October 11, 1982 population, based on a housing inventory 
performed on this date, range from 966 to 1053 (Exhibit A). During this 
inventory, a housing stock of 411 dwelling units was identified. In addition 
30 motel units were counted. 

While it is true that a significant portion of dwelling units in Town are 
recreational vehicles, one must keep in mind that even R.V.s are serviced 
with permanent water and sewer taps. The R.V.'s are thus provided with the 
essential services to sustain long-term habitation, and in the event that one 
should vacate its lot, another can and probably will replace it. Currently, 
the RV park established by Western Fuels is being fully utilized. In fact, 
it is difficult, if not impossible at present, for the R.V. owner to find 
a space in either Dinosaur or Rangely. 


A. Existing Dwelling Unit Mix by Community (PI-38) does not identify the 
Town of Dinosaur as a separate entity. We &re not aware of the Town being 
contacted for such information either. 

The Dinosaur Housing inventory conducted on October 9, 1982 (Exhibit A) 










Total Units 


B. Existing Housing Conditions by Community (PI-39) - Dinosaur is not 
included in this table. 

Building Inspector, Darrell Williams estimates the following conditions: 







Mobile 'Home 





Multi -Family 












Mr. David Moore 

Jintah Basin Synfuels Comment 

October 20, 1982 Page 3 


A. Increased Population 

As one of the primary variables considered in the Spatial Allocation Model, 
or in any gravity model, the current population of approximately 1000 (verses 
that projected 451, pI-26) will have substantial impact on the relative 
attractiveness of Dinosaur. 

B. Town Expansion and Improvements 

The Town has annexed approximately the same amount of property as that 
which constituted the old Town area in March of 1982 (Exhibit B). Sewer and 
water systems are being upgraded to handle a capacity of 2000 people. According 
to pl-142, Community Level Impacts: 

"Allocations to the community level were based on both existing 
boundaries and planned additions to the cities where such plans 
existed. " 

The recent annexations, coupled with infrastructure improvements would seem 
to increase the relative attractiveness of Dinosaur greater still. 



A. "The majority of the traffic increases will occur along U.S. 40 and on 1-70." 

B. Due to the condition of the Bonanza Road, "...the true impedance from Rangely 
to Bonanza should be measured via state route 45 and U.S. route 40." (pl-141). 

C. The Rangely Airport is making progress toward achieving expansion. 

D. For rail service from Craig, U.S. 40 would be the most direct route to the 
Synfuels project sites (pI-88). 

Dinosaur is in the middle of all of a great deal of transportation activity. It 
seems that the Town would experience a considerable increase in highway traffic. 
This should in turn, affect highway impacts and the attractiveness of the community 
as an intermediate location along a transportation route. 


A. The Town of Dinosaur is separate and distinct from the Town of Rangely and 
should be identified as such. The two communities are located eighteen miles away 
from each other, in different counties - Moffat and Rio Blanco County. 

The magnitude of impacts experienced by them should also be identified and 
disaggregated from the "Colorado Communities" heading. 

B. For purposes of project related allocation, the Dinosaur CCD area definition 
was changed from the official census area. 

1. How will this affect the comparability of figures? 

2. Why was the definition of this area changed from the official 
census designation? 



Mr. David Moore 

Uintah Basin Synfuels Comment 

October 20, 1982 


Page 4 

A. Enrollment 

The figure indicated in pl-41 stating that 86 students enrolled in Dinosaur 
Elementary (1-6) in 1981 is incorrect. Darrell Williams, Head Teacher - Dinosaur 
Elementary School commented that 65 students constituted peak enrollment for 1981. 
For the 1982 school year the break-down of Dinosaur students is as follows: 

September 1982 
As of October 1982 

As of October 1982 

HIGH SCHOOL* (9-12) 
As of October 1982 

91 students 
108 students 

40 students 

45 students 

B. Capacity 

The Head Teacher of Dinosaur Elementary School, Darrell Williams, says that 
because the dining room and library, currently present in the school , were not 
included in the original school plans, this cuts down on school capacity. 
Williams states capacity is 175 students. 

Dr. Groves, Superintendant Moffat County Schools, estimates that student 
capacity is around 240 students if they are really packed in. The elementary 
school is a 14,500 square foot building. 

C. Contacts 

1. Darrell Williams, Head Teacher, Dinosaur Elementary School, (303) 374-2265. 

2. D. Groves, Moffat County Schools, (303) 824-3268. 

3. Gail Palmer, Secretary Rangely High School, (303) 675-2253. 


Again, there was nothing recorded for the Town of Dinosaur. The following 
information reflects the Law Enforcement Status as of October 20, 1982: 

Number of City Police Stations = 1 

Staff = l a 

Support Staff = 

Patrol Cars = 1 

*Dinosaur transports its Middle School and High School students to Rangely 
Schools (Note: If Dinosaur continues to grow, there will be a point when 
Secondary School facilities are merited in Town). Currently two buses run from 
Dinosaur to Rangely daily. 

The information for Middle and High School attendance was obtained from 
Gail Palmer, Secretary Rangely High School. 





Mr. David Moore 

Uintah Basin Synfuels Comment 

October 20, 1982 

(Law Enforcement Status, Cont.) 

Number of Highway Patrol Officers = 

" " " " Staff = 

Number of Highway Support Staff = 
Number of Highway Patrol Cars 

Number of City Jails c = 
Capacity City Holding Tank 

Staff City Jail » 

Page 5 

a Police Staff and Jail Staff is the same person. 
D NA = Information not available. 
c Jail = Two 24 hours holding tanks. 

SEWER (pI-49) 

Dinosaur is currently serviced by a new seweage system just recently 
completed by Uintah Engineering. My understanding is that the system is designed to 
serve a capacity of 2000 persons. 

Contact Mr. Lawrence Kay with Uintah Engineering for details. 


The Town of Dinosaur owns and maintains a Solid Waste Disposal site. 
The site covers 13.22 acres. Garbage collection is available and a solid 
waste disposal ordinance is in effect. 


Source: Wells 
Supply Amount: N/A 
Storage Capacity: 400,000 gallons. 

The Town recently received funds to proceed with a water system study. 
Contact: Bob Demos, Armstrong and Associates Engineers (303) 245-3861, 


A. Town of Dinosaur (Exhibit 'C ) 

B. Artesia Sanitation District (Exhibit C) 

C. Artesia Fire Protection District 

(Contact: Wilma Sims, Town Clerk, 374-2335.) 

Mr. David Moore 

Uintah Basin Synfuels Comment 

October 20, 1982 Page 6 


A. Artesia Fire Protection District: 

1982 1981 

Assesed Valuation $ 1,156,320 $ 760,490 

Taxes Collected $ 2,416 $ 1,836 

Mill Levy 2.1089 2.089 

Percent Increase 31.6 N/A 

B. Artesia Sanitation District: 


1982 1981 
Assesed Valuation $ 583,410 $ 408,370 
Taxes Collected $ 7,111 $ 5,158 

Hill Levy 12.189 12.63 

Percent Increase 34.2 N/A 

C. Town of Dinosaur 

1982 1981 
Assesed Valuation $ 671,900 $ 427,840 

Property Taxes $ 8,248 $ 5,783 

Mill Levy 12.276 13.52 

Percent Increase 45.8 N/A 


For Town, Fire District and Sanitation District: None. 


We realize that this comment does not comprehensively address all of the issues 
discussed in the Synfuels report. The BLM is encouraged to contact Dinosaur Town 
Planner, Steve Golnar, for additional assistance in developing an accurate 
portrait of the Town of Dinosaur, Colorado. It is our hope that BLM's analysis can 
begin with a current assessment of the Town's situation, and additional impacts 
can be identified and included with those that we are already experiencing. 

Yours^Truly, /l. 

TDennis E. Sims 


Mr. David Moore 

October 1982 


A. Town of Dinosaur Housing Inventory 
(October 11, 1982) 

Map showing estimate of Town Boundaries, Identifying 
new annexations. 

Annual Budget 1982, Town of Dinosaur 



igSJJUJ* P, O, BOX 108 - CHNOSAUR, COIQ3ADO 81610 

Exhibit A 
11 October 1982 

I. Town of Dinosaur Housing Inventory (October 9. 1982 ) 

Housing Type 

Single Family, wood frame 

, stucco or masonary 
, abandoned/vacant 

Mobile Home, single wide 
, double wide 
, vacant/stored 

Recreational Vehicles 

Comrr.erci al/Hesidential 

Motel Units 

Total Permanent Housing 267 

Total Housing Units 297 


r of. Units 
Blue Mtn. 


















? 267 







^Quantities in this category reflect how many housing units 
are in Town excluding Western Fuels' Blue Mountain Village Mobile 
Home and H.V. Pp.rks. 

^'Abandoned, vacant or stored housing units were nob 
included in Total Housing Stock. 

II. Housing Mix 

Housing Ty pe 

All Recreational Vehicle 
All Mobile Homes 
All Single Family 

Absolute % of Permanent Housi 





Totals 411 









Dinosaur Housing Inventory 
October- 11, 1982 
Pape two 



High, medium and low population scenarios for the 
Town of Dinosaur, as of October 9, 1982, based on the housing 
inventory of October 9 are developed below. In these 
scenarios the average houshold size of 2.9 8 persons as reported 
in the 1980 Census of Fopulatior. and Housing has been applied 
to mobile homes, single family units and commercial/residential 
units. The factor which is varied to develop these scenarios in 
the averare number of persons residing in recreational vehicles. 
The hi^h scenario assumes the average to be 2.0 persons, the 
medium 1.75 persons; and the low 1,5 persons. 

Town of Dinosaur 
Population Scenarios as of October 9, 1982 

High Scenario 
hou sing "'yp e . 

i\o. of Units person/unit Total 

All Recreational Vehicles 
All Mobile Homes 
All Single family 
Commerc i al/He j iden t ial 

fiedium Scenario 

Housing n 'yu" 

All Recreational Vehicles 
All mobile Homes 
All Single Family 
Oo;Tir:" ; erciaI/nesiderit if:l 

Low Scenario 

Housing T'yp. - 

All Hecreational Vehicles 
All r.obile Homes 
All Sin;-'le Feini y 
Cornniei-c ial/ii'::;? i'? ent ial 





















Total Population 


of Units n erscn/unit Total 























Total Population 



Total Population 
















° . » 


" J »g 







5 t ° S 3 j 



^« u ; 



3 »SB5: 



U < s 
* > 1 

annual budget 1984 

tow; of dinosaur 

statekext of estimated revenues 

general fund 

•Exhibit C 




3x1 &a*V£fll ;>.neri'l ?r..;»r.-;'! ; 

$ 4,804 



$ 5,783 

~>\2 Z,,.':<tU: . ,i::-iSl? --. .: 




313 General <5 a les £ Use Tax 




314 Tobacco Tax 




317 Road 4 Bridge Tax 




318 Franchise Tax 




319 Penalties & Interest on Delinquent Taxes 
Total Taxes 





Licenses & permits 

321 Business Licenses 

$ 376 



$ 600 

322 Building Permits 




323 Dog Licenses 

Total Licenses & Permits 

-•;; 703 




Intergovernmental Revenues 

331 Hoffat County Commissioners 

$ 6,136 



:'; 8,U0C 

335 Highway Users Tax 




336 Additional Motor Vehicle Registration Fen 




337 Federal Revenue Sharing 



- ; JW! 

333 Oil Shale Grants 

Total Intergovermental Revenues 





8 14.102 



Fines ar.d Forfeits 

341 Fines 

t 3:335 



$ 5,000, 

Charges for Services 

351 Equipment Rental 

$ 328 



v' 600 

352 Miscellaneous 




353 Gravel 

Total Charges for Services 

* -0- 
$ 52E 



, m 

T 1.100 

Total Revenues 

1 35.801 


37 -210 


ANNUAL BU£.;ET 1982 





311 Water Sales $ 13,393 

$ 16,675 

i) Jo, 201 

312 Water Tap Fees qqO 


- } MX ■ 

313 Interest Income 1.103 



314 Oil Stale Grants 91.692 
Total Revenues $107,003 











1- 'J2 


411 Salaries $ c oj;o 

v <=,932 

i 15 e-,0 

412 Supplies i (f g 59 


.;■. u 

413 Power 3,024 


. :oo 

421 Capital Outlay - J Cost of Vehicle 


422 Capital Outlay - Water Line Project 

.■-£:■ COO 

V>>: : .,'ooo 

Total Expenditures S"r3~623" 

V 12,719 






ceiierai ran 

General Government 
411 Dog Licenses 

Court Salaries 

Legal & Accounting 

Administration Supplies 


416 Clerk & Treasurers Salaries 

417 County Treasurers Fees 
Publishing 4 Printing 
Dues & Membership 
Sanitation Pill 




421 Board Member Salaries 

422 Building Inspector Salary 

Total General Government 

Public Safety 

431 Police Salary 

432 Police Car Expenses 
433' Fire Department 

434 Telephone £ Postage 

435 Insurance & Bonis 

436 Street lighting 


Police Benefits 

Total Public Safety 

Public 'forks 

441 Street Equipment Expenses 

442 Gravel 

443 Heed Control 





.$. -0- 

$ -n- 
















10 cvo 
















S 4,913 

y 8,010 

$ 9,779 

s 12,900 

















§ 26.377 

S 27. $22- 

, .?■ '800 

1,072 $ 1,972 $ 5,000 

-0- 300 300 

-0- 100 5OG 
(Contlnv <<0 





Public Storks (Continued) 

444 Toun Hall Phone & Utilities 

445 Maintenance Salary 

Total Public Works 

Health A Sanitation 

*rjl Cemetery 

452 Senior Citizen Support 

Total Health & Sanitation 

Parks k Recreation 

461 City Park 

Other - Capital Outlay 

471 Capital Outlay - Town Fark 

472 Capital Outlay - Comprehensive Kan 

473 Capital Outlay - Streets 

Total Other - Capital Outlay 

Total Expenditures 




'i 1.750 ■' 1,600 .;., ; 

4.0 07 S ^292" :j_ ii'S-S 

250 ? 250 

2 TO 

500 1 S00 



I36,5ig J 42.124 §g&M. 







Licenses & Permits 

Intergovernmental Revenues 

Fi.nos and Forfeits 

Charges for Services 
Total Revenues 

Estimated Carryover of Unappropriated- Surplus 
Due from Other Funds 

Total Estimated Revenues 

General Government 
Public Safety 
Public Horfc 
Health 4 Sanitation 
F?xks £ Recreation 

Other - Capital Outlay 
Total Expenditures 




* 17,132 $ 15.935 $ 20,258 

708 550 3.00C 

14,102 16,115 217,500 

3.335 3.800 5.000 

524 890 1.100 

$ 35,801 $ 37.290 §243,858 

a '.^,913 





5 292 







S 42,12.4 . :i 



311 Oil Shale Grants 





J.990 .1931. 1982L 

Actual Budget y. £j*ISgai 





1980 1981 

Actual Budget 


411 Canital Outlay - City Hall Building 




Town of Dinosaur 









Data for Dinosaur was developed by the State of Colorado through the 
Cumulative Impact Task Force process. Refer to the responses to 
Comments 34.3 and 34.6 for additional details. 

It is recognized that Dinosaur is and will continue to be heavily 
affected by the Deserado Coal Mine and Bonanza Power Plant. It is 
also recognized that these projects may be very closely related to 
the synfuels industry and the second unit of the Bonanza Power 
Plant. The related coal mining and associated impacts have been 
analyzed in the EIS as "interrelated projects." Refer to Section R- 
l.A and Section R-4.A.1 for clarification and information. The 
impacts of interrelated projects also can be found on pages 1-258 
through 1-280 of the Socioeconomics Technical Report. This section 
states that Dinosaur 1s likely to receive an impact of over 1,000 
people from the Deserado Mine and second unit of the power plant 
above baseline projections. This would make the population of 
Dinosaur over four times its 1980 census populations without any 
impacts from the applicants' proposed synfuel projects. 

In relation to baseline projections and the 1.7 percent growth rate 
found in Table R2A-7 of the Socioeconomics Technical Report, 1t 
should be noted that these projections were not developed by the 
State of Utah, but rather by the State of Colorado as part of their 
Cumulative Impact Task Force process. These baseline projects should 
have included impacts from the first unit of the Bonanza Plant and 
Deserado Mine. These Cumulative Impact Task Force baseline 
projections were used as provided by the State of Colorado even 
though there are apparent differences between actual levels and 
projected levels. 

Dinosaur has been identified as a separate entity in Table R2B-1 1n 
the Socioeconomics Technical Report, and data from the Dinosaur 
housing inventory has been incorporated. 

Existing conventional housing condition data furnished by the Town of 
Dinosaur has been incorporated in Table R2B-2 in the Socioeconomics 
Technical Report. 

The current and baseline projected population of Dinosaur will make a 
difference in the attractiveness of the community when using a 
gravity model. If a current population of 1,000 had been used, then 
the gravity model would have attributed a higher population impact 
from synfuels development to Dinosaur. However, the State of Utah 
relied on census data and baseline projections provided by the 
Colorado Cumulative Task Force Process in their gravity model, since 
this is the data base recommended by State of Colorado for impact 
analysis. No other official data sources were available at the time 
the analysis was performed to substantiate the large increase in 
population in Dinosaur. State of Colorado has been informed of this 
discrepancy, but revised runs of the gravity model were not made. 

34.7 When community allocations of synfuels impacts were accomplished for 
Dinosaur, it was assumed that all of the impact would be 1n the 
incorporated limits and none in the unincorporated area. (This was 
not assumed 1n the Utah areas.) Therefore, recent annexations 1n 
Dinosaur would not affect the impact projections for Dinosaur. 

34.8 The EIS analysis (Section R-4.A.7) supports the statements that the 
proposed synfuels development would result 1n increased highway 
traffic and create highway impacts 1n the vicinity of Dinosaur. 

34.9 Dinosaur and Rangely were treated as separate communities, and 
projections by community can be found 1n Tables R2A-7, R3A-13, R3A- 
27, R3A-42, R3A-45, SSA-2, and SSA-4 of the Socioeconomics Technical 
Report. The Colorado area was an area derived for modeling purposes 
similar to the CCDs in Utah. (The Utah CCDs also contained several 
communities). The "Colorado Area" was used, because it was believed 
that the impact would be centered in this area which consisted of the 
Rangely CCD plus the town of Dinosaur. The 1980 census was used to 
establish the calibration data for this area; no incomparability 
should be created by using such a designation, because allocations 
between counties and communities were accomplished and can be found 
1n the tables listed above. 

34.10 Using the 65-student peak enrollment and 175-student capacity figure 
for 1981 furnished by Darrell Williams results in a 1981 percent of 
capacity of 37.1. Using the same 65-student enrollment with Dr. 
Grover's estimated 240-student capacity results in a 1981 percent of 
capacity of 27.1. Since the capacity estimate of 31.3 calculated 
from data obtained from school district officials early in 1982 is 
bounded by the more recent estimates, Table R2B-3 has not been 
changed with respect to Dinosaur Elementary. 

34.11 The additional information on public safety, sewer, solid waste 
disposal, water system, and fiscal data for the Town of Dinosaur has 
been incorporated into appropriate tables in the Socioeconomics 
Technical Report. 

34.12 Selected data furnished by the commenter (October 20, 1982) have been 
utilized in revising sections pertaining to Dinosaur in the 
Socioeconomics Technical Report and the EIS. BLM appreciates the 
submittal of these additional data. 







20 October 1982 

Mr. Lloyd Ferguson, District Manager 
Bureau ot" Land Management 
170 South 500 East 
Vernal, UT 84078 

Dear Mr. Ferguson: 

Tne Draft Environmental Impact Statement for Uintah Basin Synfuels Development 
dated August 1982, was referred by the Office of Chief of Engineers, 
Washington, D.C., to Sacramento District Corps of Engineers for appropriate 
re spons e . 

We have reviewed the Draft Environmental Statement and have concluded that the 
developments, as proposed, will not conflict with flood control projects or 
flood control programs witnin our jurisdiction. Further, it appears that 
adequate consideration has been given to constructing flood plain facilities, 
diversion dams, roads, bridges, and pipeline crossings of streams, in a manner 
that should not adversely affect the passage of floodflows or significantly 
change hydrologic conditions as they relate to urban areas. 

The proposed facilities would not cross navigable waterways of the United 
States or have any significant effects on navigability. The placement of 
dredged or till material into waterways of the United States or adjacent 
wetlands will require a Department of the Army permit under Section 404 of the 
Clean Water Act (33 USC 1344). A final determination as to whether the 
activities are covered under a nationwide permit or whether individual permits 
may be required for the construction activities will be made by our office 
when detailed plans are provided to us. 

It would be helpful to us and potential future applicants if the Final EIS 
discussed impacts on wetlands, if any. Tnis section should be separate from 
the discussion of riparian impacts. It should focus on freshwater marshes. 
Thank you for the opportunity to review the EIS. 

Copy furnished: 

Commander, South Pacific Division 


Washiigton, D.C. 20314 


U.S. Army Corps of Engineers, Sacramento District 

35.1 The Corps of Engineers' determinations that none of the proposed 
projects would conflict with flood control projects or programs 
within their jurisdiction will be considered in the decision-making 

BLH appreciates the observation that areas of concern to the Corps 
have been adequately assessed. 

The requirement for a Section 404 permit is noted in the Authorizing 
Actions section (Table SS-3). 

35.2 No wetlands (as defined) would be affected by project construction or 
operation. The somewhat poorly drained to poorly drained areas along 
the Duchesne, Uintah, and Green rivers and areas bordering irrigated 
cropland are used mainly for pasture and hay production and are 
considered as cropland. Refer to Sections R-4.A.6 and M-4.A.6 for 
discussion of impacts. 










Public Health Service 

Centers for Disease Control 
Atlanta, Georgia 30333 
(404) 452-4126 
October 20, 1982 

Lloyd Ferguson, District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 84078 

Dear Mr. Ferguson: 

We have reviewed the Draft Environmental Impact Statement (EIS) for the Uintah 
Basin Synfuels Development, northeastern Utah. We are responding on behalf of 
the U.S. Public Health Service and are offering the following comments for 
your consideration in preparing the final document. 

R egional ^ C umulat ive Analysis 

Several unresolved environmental issues are identified in the EIS (p. xxxil). 
These Include: (1) air quality concerns involving possible violation of the 
Colorado Category PSD Class 1 increment and possible limitation of future 
development on the Ute Indian Tribe Reservation, and (2) the availability and 
use of a satisfactory water supply without Interfering with the prior 
commitment of water rights. We expect that these issues will be resolved and 
addressed in the final document. 

According to the EIS, a number of hazardous compounds can be produced during 
the processing of oil shale and its conversion to shale oil. While an 
overview discussion is presented on the hazardous materials produced during 
this process, the efforts that will be taken to safely dispose of these 
hazardous materials and prevent the release of hazardous materials via 
environmental pathways should be addressed . Where potential releases of 
hazardous materials cannot be adequately controlled or prevented because of 
environmental or technological constraints, the significant risks to public 
health should be disclosed. 

With all nine of the applicant's proposed projects and the interrelated 
projects, the EIS indicates that the Uintah Basin population is projected to 
Increase about 2.2 times its present population or to as many as 151,739 
people by 1995 This increase could create problems of " . . . substantial 
magnitude for local city and county governments as well as for the Ute Indian 
Tribal Council" (p. xxix). 

Because of the housing demand to be created by the projects, efforts need to 
be taken by local governments to assure that existing planning, zoning, and 
building regulations are sufficient to prevent incompatible and haphazard 
development in the county. Are the existing local building and Banitary codes 
sufficient to Insure the placement and/or construction of State housing, water 
supplies, and sanitary systems? What local regulations exist to control 
development in flood hazard areas, geologically unstable areas, in soil areas 
unsuitable for septic tank systems, and unacceptable noise Impact zones? 



Page 2 - Lloyd Ferguson, District Manager 

%U5i Sh ff" addreSS t he S " tU8 and <=«««"■**» »f State and local 
lltTcZLrZ IS° f." 1Mt ™™°"P**Me development of reclaimed lands 
producing radiation (i.e., radon and radon progeny concentrations) in excess 

, f 2 \f": Md FEderal 8"«*"°*s- " radon emissions are a 
T °2T , T c ln the "" dy """' the Potential Indoor health effect, of 
radon emissions from land to be reclaimed and used for development in the 

pr geVl'e've 1 VJSSZL ^ "S 8h ° Uld ^^ " f-SSTlS^V*. 

progeny levels for slab-on-grade structures on reclaimed lands will exceed the 
U.S. Environmental Protection Agency's recommended levels. 

tne'n^L'T.T UreS " m be fomented into the design and management of 
SZnZT t d r iDage SYBtem ' holdln 8 P " 08 - disposal basins, and ofher 
facilities having vector breeding potential to prevent the Increase of vector 
populations that could cause future vector-borne disease or nuisance problems 
nrevent r ^ ca P ablllt >' ° f l °«l health authorities to detect a" 
prevent excessive on.ite breeding of problem vectors should be discussed? 

We appreciate the opportunity to review the Draft EIS. We are sendine our 
compy of the Draft EIS to the Indian Health Service for their infor^Uon? 

Please send one copy of the final document when it becomes available. Should 
you have any questions about the comments above, please call Mr Robert ill of 
my staff at PTS 236-6649. Robert Kay of 

Sincerely yours, 

Prank S. Lisella, Ph.D. 
Chief, Environmental Affairs Group 
Environmental Health Services Division 
Center for Environmental Health 




Center for Disease Control 

36 1 Because insufficient additional data were available, these issues 

remain unresolved in the Final EIS. As stated in the Summary, for 

the most part, these issues would need to be pursued outside of and 

independent from the EIS process in order to be resolved. 

36.2 A small amount of hazardous waste would be produced by some of the 
projects (Paraho, Syntana-Utah, and Tosco), a result of upgrading 
operations. This waste would mainly consist of spent catalysts. The 
transportation, use and disposal, or recycling, of these products is 
regulated by both the EPA and the state under the Solid Waste 
Disposal Act as amended by the Resource Conservation and Recovery 
Act. For more detail, see Sections l.D.l and 1.D.2 of the Paraho, 
Syntana-Utah, and Tosco discussions and Section R-4.A.16. 

36 3 The communities within the study area have either recently completed 
or are undertaking a review and update of their planning and zoning 
ordinances to ensure their adequacy and compatibility with the 
proposed synfuel projects. 

36.4 Radon emissions have not been found to be a problem in the study 

36.5 Drainage systems, basins, and holding ponds would be small in these 
projects and would be designed with steep banks so that water depths 
would not be conducive to vector reproduction. Constant recycling of 
water would also discourage vector production. Therefore, problems 
with vector populations are not anticipated. 





Friends of The Earth 

Colorado Office 

22^9 East Colfax Avenue Room 209 

Denver, Colorado 80206 

■'S°5) J22-279I 

18 October 1982 



These comments are necessarily brief because of the press of other 
business. However, we did not wish the opportunity to pass without 
expressing our concern about the single most serious (and we believe 
fatal) flaw in the environmental statement: The statement either 
hides behind so-called "unresolved issues" or does not evaluate the 
effectiveness of proposed mitigating measures which are claimed to 
allow development to occur without significant impact. 

"Unresolved Issues" 

The Uintah Basin statement states that issues still unresolved are- 

(1) the extent to which impacts may be offset as a result of Utah's 
Senate Bill 170, 

(2) issues raised and yet to be evaluated in response to concerns bv 
the Ute Nation, and 

(3) measures which will overcome revenue/cost imbalances. 

Let's be honest with the public, BLM. The statement, except for its 
vague, general references to Senate Bill 170, does not contain any 
proposed, substantive socioeconomic mitigation measures. Such mea- 
sures must be developed on a site-specific basis for each project 
We have searched in vain for any project-specific social mitigation 
plans. Without such plans there is no hope for adequately avoiding 
serious community development problems. 

The statement relies almost exclusively on Senate Bill 170 's protec- 
tions. However, these protections only address local government fis- 
cal imbalances. They do not address housing, human service needs 
phasing of construction, private sector service deficiencies or the 
rate of growth. None of these problems have solutions within the 
non-mitigation of the proposed actions. Indeed, each of the conuni- 
ties in the area will experience greater than 10% annual conpound 
growth through 1985. Simple fiscal assistance will not relieve the 
boom this entails. Without specific plans, how will the communities 
deal with runaway crime, runaway local inflation, seniors and other 
fixed income residents no longer able to afford housing secondary 
service workers unable to afford housing, delinquency disorderly 
conduct, strained roads and transportation networks, no sources for 
capital needed for new housing or new businesses? 

With regard to these questions, BLM is silent. Worse, BLM only calls 
them "unresolved." With the information presented in the EIS we 
would make the following conclusions and take the following actions: 

Committed to the preservation, restoration, and rational use of the Earth. 






2 - Uintah Basin Synfuels Development EIS 

1 - The rate of growth expected in the Basin, greater than 12% annual 

compound growth with 18* in the two largest communities through 
1985, will make impacts unmanageable for the high scenario. 

2 - The applicants have not submitted adequate project-specific 

socio-economic mitigation plans. They and the communities are 
not adequately prepared for the magnitude of the proposed under- 

3 - We will withhold approval of proposed permits until adequate 

mitigation plans are submitted and applicants commit to perform 
the proposed mitigation. 

4 - We will not approve all actions simultaneously, but will, based 

on the readiness of each project, issue permits in a phased, 
orderly manner to spread the impacts. 

Other Mitigation 

BLM also plays tricks with mitigation proposed 
mental impacts. It concludes that: 

(1) Loss of vegetation and habitat due to const 
disposal will be temporary because of succe 

(2) "It is assumed effective erosion control an 
tices would be implemented ... " 

Yet, for the most part there is no assessment o 
of proposed reclamation. There are slight hint 
tiveness will be less than desired. The EIS ac 
climatic conditions and that the application o 
dures would be at the discretion of authorizing 
BLM's analysis assumes success in these efforts 

for physical environ- 

ruction and shale 
ssful reclamation, 
d reclamation prac- 

f the effectiveness 

that their effec- 

knowl edges difficult 

f mitigation proce- 

agencies. Still, 

An analysis of the situation should yield more sobbering results. 
In particular, Utah's reclamation laws is one of the least strict 
in the nation. It provides little substantive in the way of reclam- 
ation standards but miles of flexibility for the Oil and Gas Commi- 
sion. This is particularly disturbing because the Uintah Basin will 
be very difficult to reclaim. Topsoil is almost non-existence. 
Spent shale reclamation is still experimental. Precipitation is 
sparse . 

Similarly, the statement does not evaluate the effectiveness of such 
mitigating measures as: 

o Stretford equipment for H ? S removal 

o Compacted spent shale as an "impervious liner" for shale piles 

o "Construction practices ... designed to minimize surface dis- 
turbance" (what are they? how well will they perform?) 

o Fugitive dust ... supressed as necessary to "comply with air 
quality regulations" (if it is as effective as Colony's dust 
supression, the EIS had better calculate the cost of respirators.} 

o "Paraho is coordinating with all regional, county, and local 

officials ...." (It can coordinate without taking mitigating action.) 

o No process wastewater would be discharged. (What about accidents? 
What is the effectiveness of retort water cleanup?) 

o Raw shale fines would be stockpiled .... (What about fires? ) 

EA's in the future 

Given the little we know about the "conceptual " projects , there is 
no way BLM should condone an "environmental analysis" for final 
approval of proposed "conceptual" projects . 




Friends of the Earth 

37.1 Appendix A-7 presents 11 uncommitted mitigation measures that could 
be used to alleviate or minimize potential socioeconomic effects from 
the proposed developments. These measures are not committed to by 
the federal agencies or the applicants. They could be used by the 
applicants for voluntary implementation or by the authorizing 
officials in eventual permit stipulations. These and other more site- 
specific measures would be developed by the applicants and affected 
communities under the requirements of S.B. 170 and by the applicants 
in conjunction with the lite Indian Tribe. BLM does not have the 
authority to require applicant committment to socioeconomic 
mitigation measures. 

37.2 In Appendix A-8, footnote 2 of Table A-8-2 identifies the reliability 
and effectiveness of the measures and procedures outlined in the 
Erosion Control and Reclamation Program. 

Table A-8-3 presents analysis identifying the effectiveness of 
several erosion control measures and combinations that would be 
implemented to control soil loss and promote revegetation. 

It should also be noted the measures and procedures outlined in the 
erosion control and reclamation program are (1) based on years of 
experience, field trials, and research conducted by leading 
researchers in the field of reclamation; and (2) have been 
demonstrated to be reliable in making assumptions regarding 
effectiveness when properly implemented. 

37.3 Because oil shale is still developmental, specific industry data on 
the effectiveness of Stretford equipment cannot be cited. Stretford 
equipment is an acceptable system and standardly used in the 
petroleum industry. Based on this use and research, 97 percent 
sulfur removal is expected. 

Tests indicate compacted shale is a relatively impervious layer with 
0.1 to 1.0 feet per year permeability. However, more importantly, 
under the conditions present in the area, moisture will move to the 
surface of shale piles and evaporate rather than penetrate the pile 
as leachate. This has been clarified in Section R-4.A.3, Ground 
Water. See also the response to Comment 32.11. 

Construction practices that the applicant would use which would 
mitigate impacts are detailed in the individual project technical 
reports and Appendix A-8. Measures that would be required by 
permitting agencies are identified in Appendix A-ll. Also, under 
Section 504 of the Federal Land Policy and Management Act, the 
applicant would be required to provide funding to the appropriate 
federal agencies for the purpose of financing one or more specialists 
for administration of construction activities (Appendix A-ll). 

Fugitive dust suppression is required to comply with state and 
federal air quality regulations, including the Clean Air Act, as 
amended (42 USC 7401). 


Mitigation which is not committed to has not been used in analysis or 
determination of impacts. The impact analysis is, therefore, a worst- 
case analysis. Any mitigation measures which are later adopted, 
including those resulting from ongoing coordination between the 
applicants and federal, state, and local agencies, would result in 
impacts less severe than those presented in the EIS. 

The applicants must comply with state and federal wastewater 
regulations, including the Clean Water Act (33 USC 1251). The 
likelihood of impacts due to accidental discharge is remote because 
of the safeguards of construction standards, automatic monitoring, 
area dikes, and other protective devices. 

Recommendations by the Environmental Protection Agency concerning raw 
shale fines are included in Appendix A-ll. 

The level of detail required and the need for subsequent impact 
assessment for a conceptual project will be determined by BLM when a 
detail project description is submitted and action on a right-of-way 
application is requested (EIS Preface). 








Mono Power Company 


October 18, 1982 

Mr. Roland G. Robison 

State Director 

Bureau of Land Management 

136 E South Temple 

Salt Lake City, Utah 84111 

Dear Mr. Robison: 

Mono Power Company has completed the review of the 
Draft Environmental Impact Statement for the proposed Uintah 
Basin Synfuels Projects. As a conceptual project, it is 
important to recognize the tentative nature of the proposed 
P.R. Spring Tar Sand Project and that the viability of the 
project greatly depends upon the outcome of our resource 

At the onset and during preparation of the Draft EIS, 
Mono Power had a joint participation agreement with Enercor for 
the P.R. Spring Project. However, during the past month that 
arrangement has been dissolved. Each of the two companies may 
develop their leases as separate or possibly, in the future, 
joint projects. There should not be any significant changes to 
the text of the EIS. In other words the combined impacts of the 
projects under the various scenarios should remain much the same. 

Generally speaking, we have found the EIS to be well 
done and adequately addressing Mono's concerns. However, we 
have identified a few items in the draft which need to be clari- 
fied. There are several references, particularly on Pg . R-4-85 
and R-5-3 to the Winter Ridge area which is currently under con- 
sideration for wilderness designation. Some discussion about 
the potential impact to our leases or development of the Tar 
Sand resource in the event the wilderness status is granted 
should be addressed in the EIS. That is, do we lose the option 
to convert our P.R. Spring leases to combined hydrocarbon holdings. 

There are several references throughout the text about 
the "new townsite" at Westwater. It should be clarified that 
Westwater is but one of many sites being considered for a new 
town. The EIS now reads as though this is the only site being 
considered (Para. 2, Pg. R-4-81) . 


It is not clear after reading the Air Quality sections 
of the report that the State of Utah will be issuing P.S.D. 
permits for the projects. Even though it is generally known 
that Utah has adopted EPA standards, reference to the Air 
Quality Tecnical Report or mention of Utah's permitting authority 
would be helpful. 

We wish to thank BLM for allowing us to participate in 
this worthwhile project and look forward to seeing the final 
version of the EIS. Should you have any questions about or 
wish to discuss our comments, please call me at (213) 572-2149. 





Hono Power Company 

38 1 BLH recognizes the conceptual nature of the P.R. Springs project. 
Appendix A-l has been revised to up-date the current status of the 

38.2 Should the Winter Ridge Wilderness Inventory Unit receive 
Congressional designation as a Wilderness Area in its present 
configuration, the Mono Power leases that would be affected could be 
converted to combined hydrocarbon holdings. Nonetheless, the 
development of combined hydrocarbon holdings (i.e., strip mining) 
within a Wilderness Area would be considered incompatible with the 
purpose and intent of the Wilderness Act of 1964 and with the 
protection of wilderness-related values in the Winter Ridge area. 
Since the Interior Board of Land Appeals is reviewing the status of 
the Winter Ridge unit (whether the unit be returned to multiple use 
management or be designated as a Wilderness Study Area), it would be 
presumptuous at this time to assume the unit will become a Wilderness 

38.3 Appendix A-l clarifies this point. Alternative townsites considered 
by Enercor-Mono Power (Webster 1981) were not assessed in the EIS due 
to the conceptual nature of this project. The Westwater townsite was 
selected for consideration in this EIS, because based on the rating 
of a study conducted for Enercor-Mono Power (Webster 1981), it was 
the applicant's preferred town site. 

38.4 Reference to the fact that Utah is the PSD permitting authority has 
been added to the Air Quality Technical Report and Section R-4.A.2 of 
the Final EIS. 









United States Department of the Interior 



I'.O. I10\ I138K 

-SALT I.AkK(lT\. ITAH Slltf 

October 28, 1982 




District Manager, Bureau of Land Management, 
Vernal, Utah 84078 

Regional Director 
Bureau of Reclamation 

170 South 500 East, 

Subject: Review of Draft Environmental Statement - Uintah Basin Synfuels 
Development (ER 82/46) 

We have reviewed the above draft environmental statement for the Bureau of 
Reclamation and have the following comments to offer: 


1. The route of the Salt Lake City Alternative Product Pipeline could 
cross rights-of-way under jurisdiction of the Bureau of Reclamation. 
Appropriate coordination would be required. 

2. It is not clear whether or not the applicants would provide any fish 
and wildlife mitigation to compensate for habitat and population losses 
resulting from project development. 

3. Development of the proposed projects would increaae the demand for 
Central Utah Project water. 

4. The social information and statistics are consistent with those being 
used by the Bureau of Reclamation. Because of its location, one project, 
the Sohio Project, could cumulatively interact with Bureau of Reclamation 
projects and create a housing shortage in Roosevelt, Utah, around the year 
1988. During this peak construction year, given the high level development 
scenario, a labor force of about 475 would seek housing in Roosevelt. This 
demand could be added to that associated with the Upalco Unit, Duchesne River 
Area Canal Rehabilitation, Uinta Basin Water Systems Improvement, and con- 
struction of the Upper Stillwater Dam. 


Page xxxii. Paragrap h 2 under "Water Supply " - We believe this paragraph 
should be revised to read as follows: "Green River water could be used 
through execution of an interim water service contract from Flaming Gorge 




39.8 | 

39.9 | 


Reservoir. According to the Bureau of Reclamation, water Is available from 
the Flaming Gorge Reservoir for beneficial consumptive uses; however, interim 
contracts for the use of this water would first require the approval of the 
Utah Division of Water Rights (State Engineer) for use and place of diversion. 
Other institutional requirements would also have to be met. It is the opinion 
of the Utah Division of Water Rights (State Engineer) that water in perpetuity 
may not be available from Flaming Gorge Reservoir. This is due to commitments 
of water for the Central Utah Project, and water that would be withdrawn from 
the Green River to supply the Indian lands on the Leland Bench Project (Utah 
Division of Water Rights 1981)." This revision better explains contract policy 
and procedures for water supplies from Flaming Gorge Reservoir. 

Page R-3-1 - It is not clear to us whether the baseline conditions described 
are existing conditions, or constitute future conditions without the proposed 

Page R-3-16. Quality of Life - We suggest mentioning the potential for cultural 
problems involving religious differences. 

Page R-3-23, Surface Water - The Duchesne River Is also being developed for 
in-basin use under the Central Utah Project. 

Page R-4-15, Paragraph 4 - Would there be an active program of minority 

Page R-4-20, Water - Vernal City and adjacent communities will get municipal 
water from the Jensen Unit of the Central Utah Project. Roosevelt, Myton, 
and other communities are also scheduled to get water from the Central Utah 




39.15 | 

Page R-4-45, Surface Water - In-basin development of the Duchesne River drain- 
age under the Central Utah Project should be mentioned. This development 
would provide some municipal water for impacted communities. 

Page R-4-58, Soils and Reclamation - The credibility of commitments made 
would be significantly enhanced if applicants would provide up-front funding 
to ensure that adequate financial resources would be available. 

Page R-4-62, Wildlife, Last Paragraph - The statement that disturbance of 
nearly 37,000 acres of mule deer habitat would not be significant does not 
seem supportable from a biological point of view. Severity of impact is 
not necessarily directly related to percentage of total available habitat. 
A more meaningful comparison would involve the most critical habitat type. 

Page R-4- 65, Paragraph 5 - Central Utah irrigation projects should be changed 
to Central Utah Project features. 

Page R- 4-69, Fisheries - A discussion of how water diversion structures would 
be designed to prevent entrapment of fish would be meaningful. 

Page R-4 -70, Threatened or Endangered Species - This discussion appears to be 
inconsistent with page R-K-4 of the memorandum from the Fish and Wildlife 





39.18 I 

39.19 j 

39.20 I 












39.32 I 

Pages R-4-81 and R-4-82 - There would also be a resultant increase in the 
cost of providing adequate law enforcement for management agencies and 

the Ute Tribe. 

Pa ge R-4-93, Ruptures and Spills - Should expand discussion to specify who 
would pay the costs of cleaning up spills. 

Page R-4-110, Last Paragraph - Would there be an active hiring program for 

Page R-4-114, Last Paragraph - A significant part of the needed water supply 

would come from the Central Utah Project. 

Page R-4-115 - Under discussion of hunting and fishing expenditures, benefits 
would be offset somewhat by increased administrative costs. 

Page R-4-124, Paragraph 3 - As with the discussion of wildlife impacts, the 
assumption that loss of 6,542 acres of vegetative habitat would be insignificant 
needs support. 

Page R-5-1. Section R-5.A. - It would seem like the trend toward reduction of 
wildlife habitat and populations would be a significant concern, particularly 
at the cumulative level . 

Page R-5-1, Section R-5.B. - It would appear that loss of wildlife habitat 
and populations would be an irreversible and irretrievable commitment of 
resources . 

Page SS-9, Table SS-4 - It seems like the Ute Tribe should be included. 

Page E-l-8, General - We suggest mentioning the provision of vegetative buffer 
strips along water courses. 

Page E-l-8) Plant Site - We suggest including a requirement for development of 
plans for cleanup of product spills. 

Pa ge M-l-14, Paragraph 2 - Would the applicant be responsible for paying cleanup 

Page P-l-9 - We suggest the inclusion of a requirement to provide buffer strips 
along water courses as a construction measure. 

Page S-l-13, Paragraph 3 - Who would be responsible to pay the cleanup costs? 

Page T-l-10 - We suggest adding the requirement or provide protective buffer 
s trips along water courses to the list of environmental safeguards . Also , who 
will monitor and enforce commitments made by the various applicants? 

Page T-3-16, Table T-3-1 - Little Dell is a project being planned by the Corps 
of Engineers , not the Bureau of Reclamation. 

39.33 | 

39.34 | 



39.37 | 


39.44 | 

Page T-4-11, Paragraph 5 - Harassment of golden eagles is prohibited by law. 

Page T-4-11, Paragraph 7 - Instream diversion structures can be designed to 
prevent damage to fish. 

Page R-E-3 - We suggest including Uintah Basin Association of Governments in the 
list of local government entities to receive a copy of the draft environmental 
impact statement. 

Page R-I-l - In order to give this section some real value, it appears necessary 
for the decisionmakers to determine which, if any, of the uncommitted mitigation 
measures would be implemented. Without this knowledge, the true net impacts 
cannot be identified. 

Page R-I-2. Wildlife - Another potential mitigation measure would be to provide 
replacement habitat by increasing the productive capacity of adjacent lands. 

Page R-I-2. Paragraph 4 - Landscape mitigation would be better insured if appli- 
cants were required to provide up-front funding and sign agreements to follow 
through on stated commitments. 

Page R-I-9, No. 3 under River Crossings - If steep slopes are involved, right- 
angle crossings of streams should be avoided to reduce the potential for 
erosion of soil into the stream. 

Page R-J-5 - We suggest adding a stipulation precluding right-angle stream 
crossings where steep slopes are involved. This measure would reduce soil 
erosion into water courses. 

Page R-J-4 - We suggest including the objective of enhancing wildlife values in 
the revegetation guidelines. Such a commitment could function as a wildlife 
mitigation measure. 

Page R-J-4 - Would temporary irrigation of reclaimed lands or retreatment of 
difficult areas be included in revegetation plans? 

Page R-K-l - It would be informative to explain why biological assessments have 
not been prepared to provide the impact data for this draft environmental impact 

Page SS-A-4, Vegetation - Mention of the Executive Orders covering floodplains 
and wetlands would be meaningful. 

We appreciate the opportunity to review this draft environmental impact 
statement . 

cc : Commissioner , Attention: 150 




U.S. Bureau of Reclamation, Upper Colorado Regional Office 

39.1 Should Tosco's Salt Lake City Alternative Product Pipeline be 
approved, Tosco would need to coordinate with all affected 
governmental and private entities, including the Bureau of 
Reclamation, in order to acquire the necessary permits. 

39. 2 The applicants' revegetation plans (Appendix A-8) provide for 
revegetation with plant species that could be used by wildlife. 

39.3 While the comment is correct that oil shale development would 
increase the use of Central Utah Project (CUP) water, it should be 
noted that all CUP water is not now being used. However, for 
analysis purposes the model considers the water as used. Water 
needed to support municipal and industrial concerns which are above 
the CUP's ability to supply were analyzed as coming from existing 
surface waters (the Green or White rivers). 

39.4 The elements of the" CUP were included in the Utah Interrelated 
Projects (Table R-l-2) and were considered in the nine-project 
cumulative analysis. Housing demand, high-level scenario (Table R-4- 
6) shows a cumulative increase in households in Roosevelt of 72.8 
percent in 1985 and 148.3 percent in 1995. Given the light housing 
situation in Roosevelt presently (Section R-3.A.6), this could lead 
to a housing shortage in the late 1980s, depending upon the response 
of the housing industry to the need. Housing within the Roosevelt 
area would need to be carefully monitored to assure an adequate 
supply. Since Sohio is a conceptual rather than a site-specific 
project, no site-specific analysis was made of its impacts in 1988 
considering other related projects, such as elements of CUP. 

39.5 The EIS Preface has been revised. 

39.6 The introduction to Chapter R-3 has been supplemented to clarify the 
parameters of the baseline conditions. (Also see Section R-l.A, 
paragraphs 1 and 2, Table R-l-2, Table R-l-3, and Section R-3.A.1, 
paragraph 2.) 

39.7 The referenced discussion of Quality of Life focuses on existing 
conditions in the environment that would be affected by the nine 
proposed project. The Quality of Life discussion in Section R-4.A.1 
discusses potential conflicts between persons of different 
backgrounds, including religious preference. 

39.8 Section R-3. A. 3 has been revised to reflect this point. 

39.9 Hiring policies of the proposed synfuels projects are considered a 
mitigation measure that the BLM perceives is the purview of the 
applicants in consultation with state and local governments. In the 
EIS, this type of mitigation is identified in Appendix A-7, because 
neither the applicants nor an authorizing agency is presently 
committed to an active minority training/hiring program. 

39.10 While it is true Vernal City and adjacent communities will get 
municipal water from the Central Utah Project, distribution and 
treatment facilities would have to be expanded to serve the increased 
population that would result from synfuels development. 

39.11 This point has been clarified in Section R-3. A. 3, which describes the 
environment that would be affected by synfuels development. 

39.12 This is true; however, it is not within the scope of the EIS to 
obligate the applicants to up-front funding for mitigation measures. 

39.13 Section R-4.A.5 gives a general overview of the impacts to the area 
to be affected by the nine proposed projects. Crucial habitats are 
identified and discussed if the analysis of site-specific projects 
shows they would be affected. 

On a regional scale, the areas of identified critical habitats amount 
to about 777,614 acres for deer and 269,568 acres for elk (Table R-3- 
12). The total amounts of these habitats that are estimated to be 
disturbed are about 1.3 and 1.6 percent of the classified critical 
habitats available for deer and elk, respectively (Table R-4-20). It 
is not felt that this small amount of disturbance would adversely 
affect these species. 

39.14 Section R-4.A.5 has been revised. 

39.15 Refer to Appendix A-ll for a requirement for a mitigation plan to 
eliminate impacts to threatened and endangered fish species. 

39.16 It 1s not known at the present time whether the black-footed ferret 
occurs in the area. Should a project be approved, surveys will be 
undertaken as directed by the U.S. Fish and Wildlife Service to 
determine the presence or absence of the- ferret in the area. The 
U.S. Fish and Wildlife Service memorandum (Appendix A-9) indicates 
that the ferret may be present, because the area is in historical 
ferret range. Therefore, site-specific surveys will be required to 
clear the area prior to any construction. 

39.17 This impact is noted in Section R-4.A.1 under the Government Services 
and Facilities section. 

39.18 As discussed in 'the various site-specific Sections 1.0.1, the 
applicants would assume responsibility for cleaning up any spills. 
Under Section 311 of the Clean Water Act (USCA 1251), each company is 
responsible for the cost of cleaning up spills. 

39.19 Refer to the response to Comment 39.9. 

39.20 While it is true the Central Utah Project will add to the water 
supply, distribution and treatment facilities would have to be 
expanded to serve the increased population. 



39.21 Benefits from increased hunting and fishing expenditures would be 
offset somewhat by increased administrative costs, although no 
attempt was made to estimate the magnitude of the increased 
administrative costs. Section R-4.B.1 has been amended accordingly. 

39.22 Refer to the response to Comment 39.13. 

39.23 The concern about the cumulative loss of wildlife habitat due to the 
combined effects of the applicants' projects is discussed in terms of 
an irretrievable loss of resources in Section R-5.B. In the Final 
EIS, this discussion has been expanded to include wildlife 
populations. In addition, the cumulative effects of individual site- 
specific projects and interrelated projects are discussed in the 
appropriate site-specific Chapter 5. 

39.24 This point is made in the Lost Production discussion of Section R- 

39.25 The actual permitting body for granting a right-of-way across Ute 
Indian lands would be the Bureau of Indian Affairs (BIA), not the Ute 
Tribe (see Table SS-2). Of course, BIA's issuance of any right-of- 
way grant across Indian lands would have to have the concurrence of 
the Ute Indian Tribal Council. Refer to Appendix A-ll for the Uintah 
and Ouray Tribal requirements. 

39.26 The section referenced in the comment includes only project design 
features proposed by the applicant. Since the applicant has not 
committed to this type of mitigation, it would be inappropriate to 
add i t . 

39.27 The requirement for a Comprehensive Spill Prevention, Control, and 
Countermeasure Plan (SPCC) has been added to Section R-4.A.15. It 
would apply to all applicants' projects, including the Enercor 
Rainbow project. 

39.28 Refer to the response to Comment 39.18. 

39.29 Refer to the response to Comment 39.26. 

39.30 Refer to the response to Comment 39.18. 

39.31 Refer to the response to Comment 39.26. The land manager (such as 
BLM or State of Utah) or landowner would be responsible for 
monitoring and enforcing (on lands under their jurisdiction) the 
commitments made by the various applicants. 

39.32 Table T-3-1 has been revised. 

39.33 The comment is correct. No construction activities can be undertaken 
during the identified critical period because of the law, unless a 
special permit is obtained from the U.S. Fish and Wildlife Service. 

39.34 The comment is correct. This type of mitigation would be required, 
as explained in Appendix A-ll. 

39.35 A copy of the Draft EIS was sent to the Uintah Basin Association of 
Governments. The list of groups identified in the Consultation and 
Coordination Appendix of the Draft EIS was not intended to be all- 
inclusive. The Final EIS has been sent to everyone who received a 
copy of the Draft. 

39.36 The impact analysis did not assume any of the uncommitted mitigation 
measures would be implemented, because neither the applicants nor any 
authorizing agency are committed to the mitigation listed in this 
section. These uncommitted measures were identified during the 
impact identification process so that the applicants could 
voluntarily incorporate them into their projects or the authorizing 
officials could require them in eventual permit stipulations. Should 
any of these measures eventually be stipulated by an authorizing 
agency or committed to by an applicant, the severity of the impacts 
discussed in the EIS would be lessened. Assuming in the impact 
analysis that these measures would be implemented would result in a 
false picture of potential impact. 

39.37 Refer to the response to Comment 21.53, 

39.38 The concern of most people is that the proposed projects be completed 
in the most environmentally responsive manner. It is both the land 
manager's and the applicant's responsibility to require the best 
possible design and workmanship should the project be eventually 
permitted and implemented. The manager does have the prerogative of 
selecting the mitigative measures for inclusion in the permit 
requirements which will, in his or her judgment, assure the best job 
possible without overstepping the rights of the applicant. In most 
cases, up-front agreements are made, and by acts of accepting the 
terms and conditions of the rights-of-way agreements, the applicant 
agrees to follow through on stated commitments. 

39.39 The concept behind these measures is that they should be used where 
appropriate and applicable, inferred by the "where possible" phrase 
in the measure. When applying the mitigating measures, the 
consequences of the measures themselves should be understood to 
assess the net value before being implemented. 

39.40 Refer to Appendix A-8, Backfilling and Grading section, for 
discussion concerning restoration and erosion control associated with 
stream crossings. 

Right-angle stream crossings are not precluded to allow for 
flexibility in construction techniques to site-specific conditions. 

39.41 The intent and purpose of the Erosion Control, Revegetation, and 
Restoration Guidelines for use on federal lands is to assure that 
lands disturbed by construction and operation activities would be 
restored to a stable, productive, and aesthetically acceptable 
condition. Refer to the Reseeding and Planting section of the 
guidelines for discussion concerning revegetation. 

39.42 Supplemental water would be used mainly in the leaching process 
associated with preparing a suitable plant growth condition in the 
upper layer of the spent shale piles. Supplemental irrigation would 
be very limited, since revegetation is based on use of adapted native 
species and applicable measures to provide a vegetative cover that 
would withstand the climate and soil conditions typical of the area. 

Refer to Appendix A-8, Maintenance and Monitoring section, for the 
guidelines. The monitoring program would identify problem areas and 
corrective measures to ensure vegetation cover and erosion control. 

39.43 The assessment and the U.S. Fish and Wildlife Service biological 
opinion have been incorporated in this Final EIS (Appendix A-9). 



This point has been added to the Bureau of Land Management section of 
Appendix A-ll. 





United States Department of Agriculture 

forest service 

324 25th Street 

Ogden, UT 84401 


OCT 271982 

Mr. Lloyd Ferguson, District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, UT 84078 

Dear Mr. Ferguson: 

The review of the Uintah Basin Synfuels Development-Draft Environ- 
mental Impact Statement by personnel from this office and the con- 
cerned National Forests prompted no comments for text changes. 
General satisfaction with the DEIS was expressed. 

We attribute our satisfaction with the DEIS to the following: 

1) Active participation in the writing of the UBS - Tosco 
Alternative Product Pipeline Technical Report; 

2) Sufficient time (2 full weeks) to review and comment on 
the Preliminary DEIS; 

3) Participation in the "permission to print review" held in 
Denver, Colorado, with full cooperation by the EIS team 
leader in making appropriate changes as per that review 
and comments from the PDEIS review. 

We appreciate the involvement, good coordination, and acceptance of 
applicable field data for the project by Thorn Slater of the Utah 
State BLM Office. Thorn provided full support for Forest Service 
concerns and, through his position, emphasized and secured cooper- 
ation from the Denver EIS team. 



Deputy Regional Forester 
State and Private Forestry 

U.S. Forest Service 


BLM appreciates the cooperation and many hours of work contributed to 
the EIS effort by Forest Service personnel. 









Table R - t - 11 on Page R - **- ^5 of the Uintah Basin Synfuels Develop- 
ment Draft Environmental Statement indicates that the Uinta Ground Souirrel 
whose scientific name is Soermoohilus armatus and the Least Chipmunk whose 
scientific name is Eutamias minimus were observed by all synthetic fuels 
companies that have leased land in the Uinta Basin. In Utah, the Uinta 
Ground Squirrel has been seen no further east than Fruitland, Duchesne County. 
It certainly does not occur east of the Green River. The Least ChiDmunk has 
not been seen by all synthetic fuels companies that contributed data to the 
present EIS. It exists on synthetic fuels tracts in the Uinta Basin only in 
montane habitat. The Colorado Chipmunk ( Eutamias ouadrivittatus ) is the 
commonly observed chipmunk occurring on the rock outcroppings of synthetic 
fuels leases. 

Only 13 mammal, 1? avian t and four fish species were listed in Table R - "\ 
- 11. The Blue Grouse, one of those listed, has not been seen on any 
synthetic fuels tract because it occurs almost exclusively in montane 
forests which exist on a relatively small portion of those tracts. 

I believe that all vertebrate species observed on synthetic fuels tracts 
in the Uinta Basin ought to be listed. 

A. Gay Ion Cook, Ph.D. 

Gay Ion Cook 

41.1 A F ield Guide to M ammals (Burt and Grossenheider 1976) and 
Vertebra te Wi Id 1 ife~~S"pecies of Utah (Utah Division of Wildlife 
Resources 1981)" show the Uinta ground squirrel as occurring in the 
oil shale area. The scientific name of the Uinta ground squirrel is 
Citellus armatus . 

41.2 Blue grouse are found on the Enercor-Mono Power P.R. Springs proposed 
strip mine site (Utah Division of Wildlife Resources 1981). 

41.3 Long lists of animals or plant species are not needed to understand 
the overall impact analysis. Complete listings of animal species 
found in the area can be obtained from the Utah Division of Wildlife 




Department of Energy 
Washington, D.C. 20585 

ocT n ,aa 

Lloyd H . Ferguson 
District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 84078 

Dear Mr. Ferguson: 

We have reviewed the draft environmental impact statement on 
Uintah Basin Synfuels Development, released by the Bureau of Land 
Management in August 1982 . It provides an extensive discussion 
of the expected impacts of a number of proposed projects in the 
area, consistent with their varied levels of development. 

The Department of Energy's comments are provided in the 
attachments for your consideration. If you have any questions 
concerning the technical aspects of these comments , you may 
contact Mr. Tom Owen ( FTS 328-4204) at the Department's Laramie 
Energy Technology Center. 

We appreciate the opportunity to review and comment on this draft 
EIS, and look forward to receiving the final document. 


'.'./ - ' , 

Robert W. Davies 
Deputy Assistant Secretary for 
Environment, Safety, and Health 

Attachments! 2) 





Air Quality 

The discussion of air quality impacts in the supporting 
technical document provides a thorough examination of this 
issue. However, the results arrived at through this 
modeling effort differ significantly from the results 
presented in the Supplemental EIS for the Prototype Oil 
Shale Leasing Program, also prepared by BLM. Because both 
BLM offices used the same air quality model this discrepancy 
in results is especially confusing. BLM should explain its 
use of different stability class assumptions and dimensions 
for the Uintah Basin Synfuels DEIS. We suggest that BLM 
select a model with uniform assumptions, dimensions, etc., 
in these NEPA documents and in the upcoming Oil Shale 
Programmatic EIS. 

Tar Sand Impacts 

The impacts discussed in detail in the DEIS are mainly 
associated with the development of oil shale. Impacts 
associated with tar sand are discussed under specific 
project sections. For example, impacts associated with 
spent sand disposal piles and the backfill of spent sand 
into surface mines should be discussed. In this regard, 
research conducted by the Department of Energy's Laramie 
Energy Technology Center has indicated the potential for 
acid leachates from spent sand piles. These acids would 
likely be light carboxylic acids, principally acetic acid. 
Such acids are excellent chelating agents for heavy metals 
which may be present in the tar sand formations. 
Additionally, some leaching of solvent from spent sand piles 
would occur if a solvent is used in the process, such as the 
Sohio extraction process. 

Hydroloqic Impacts 

Backfilling of sand into a strip mine would mitigate terrain 
impacts associated with reclamation. However, the backfill 
of permeable sand where a previously impermeable tar sand 
formation has been mined may pose problems. In addition to 
the leaching problems of spent sand piles, this permeable 
backfill changes the hydrologic characteristics of the local 
area surrounding the mine and, in some instances, the 
regional hydrology. 

Locally, the potential for a new aquifer is created. 
Although this aquifer may not exist for years after the mine 
has been abandoned, the potential for the aquifer exists. 
This aquifer would leach any process solvents, oil, etc., 
left as a residual on the sand and contaminate the water. 




The regional impacts of the new permeable formation would be 
dependent on the site specific geology. Depending on 
the other geologic formations such a backfill formation 
contacted, the area could act as a recharge area or a 
discharge area for existing aquifers. In either case, the 
potential for contaminant transport would be magnified. 


The resources associated with the various projects are not 
presented in sufficient detail to allow examination of 
projected project lives. The tar sand information is 
especially lacking in estimates of tons of ore required to 
produce a barrel of bitumen. It should also be noted that 
20-25% of the bitumen is lost during refining and 
upgrading. This affects production numbers presented in the 

Water requirements for tar sand processing should also be 
presented in a uniform manner. The amount of water 
necessary to produce a barrel of crude bitumen or a barrel 
of upgraded bitumen is not the same. 





The effect of the White River Dam and the proposed dam 
near Rangely, Colorado, on the levels of dissolved and 
suspended solids 1n Upper Colorado River System should be 
presented to supplement the discussion presented here. 



The discussion of floodplains should be limited to areas 
affected by the projects. The width of the floodplaln 
Immediately below Dinosaur National Monument is irrele- 
vant unless 1t extends to the Sohio Asphalt Ridge Project. 
The effects of the Flaming Gorge Dam, the White River 
0am, and proposed dams in Colorado on these historical 
floodplains should be presented. 



The existence of prairie dog colonies as habitat for 
black- footed ferrets does not guarantee the presence of 
ferrets 1n and of Itself. Remote areas 1n the Uintah Basin 
should be searched, but 1n a uniform manner prescribed by 
the U.S. or Utah Fish and Midlife Service. The Intensity 
or these searches should be consistent with the reported 
occurence of the species. 



The Impact of these projects on the Colorado River from 
Its confluence with the Dolores River, Utah, upstream to 
a point 19.5 miles in Colorado from the Colorado-Utah 
border and the Green River 1n Colorado as wild and 
scenic rivers 1s not presented. This Impact should be 
discussed or these references eliminated. 


| K-3-57 

Paragraph R-3.A.13 omits discussion nf the gllsonlte 
hydrocarbon resource. 



The reduction of autonomy of the Uintah Indian tribe 
suggested here should be explained In greater detail. No 
Supporting evidence is presented. 



No discussion 1$ presented for spent sand disposal, a 
problem which will exist with any surface tar sand pro- 
cessing plant. Depending on the process, the potential 
for add runoff from spent sand piles, solvent leaching, 
and/or erosion exists. 


R-4-61 Strip mining of tar sand and backfill of processed sand 

will drastically alter local and possibly regional aquifer 
characteristics. The backfill sand will replace a highly 
Imperwabile formation of tar sand with a formation that 
1s highly permeable. Over a period of time, the permeable 
formation could develop into a local aquifer. The water 
quality of this aquifer would be dependent upon the 
degree of contamination of the backfill sand. 








The escape of gases from highly fractured 1n situ retorts 
should be monitored despite the anticipation of no adverse 
effects. Several small mammals are believed to have died 
from retort gas leakaqe 1n the past. 



Paragraph E-l .A Is Incomplete. 


Information on the Enercor Rainbow project should be 5000 
bpsd of bitumen and 4000 bpsd of upgraded crude. 



> tar sand project will have spent sand tn dispose of, not 
spent shale. 



Table E-l-1 has misspellings within 1t. 



The enercor module has a capacity to recovery 1250 bpsd 
of bitumen or 100O bpsd of upgraded bitumen. 



Plant operation at the 5000 bpsd level would require a 
maximum 6250 acre-ft/yr. of water based on D0E/LETC 
research which funded the University of Utah study that 
developed the hot water extraction process used by Enercor. 



Calculations using the data In Table E-l-3 indicate a 
bitumen production rate of 6235 bpsd. This should be 
reconciled with the rest of the discussion on Enercor. 



The mineral and energy resources alluded to 1n paragraph 
E-3-A.11 are not identified In Section R-3.A.13. 



Impacts to aquifer should be discussed 1n light of the 
general conment presented. 



Site specific Impacts to floodplains should be presented 



, E-4-14 

There Is no discussion of spent sand disposal and its 
associated impacts. 


tto methodology is presented for the energy efficiency 


1 E-5-1 


A judgment cannot be made on the cumulative Impacts of 
the project without realistic resource data and subsequent 
determination of life of the project. 


1 M-l-7 

Hap M-l-1 does not show all site roads. 


The mining discussion does not address the effect of the 
White River Dam and Reservoir on water 1n the mine. The 
ore body at the Paraho site is likely to be affected by 
the Increased water level which will also affect other 
hydrologlc properties of the area. 

Paqe Conments 

P-4-3 Data submitted by Paraho for the Jlntah Basin Synfuels 
EIS showed i high Incidence of wind blowing from the 
south and southeast. These particular wind directions 
would cause process pollutants released Into the air to 
travel toward Dinosaur National Monument. Paraho should 
consider air quality monitoring 1n or near Dinosaur H. M. 
to determine the effects of the project on air quality. 


Ambient monitoring should commence prior to the start of 
operation due to a high release of particulate matter 
into the air from fugitive dust associated with construc- 
tion activities. 

Ambient monitoring should also monitor visibility. 
Although no standards for visibility yet exist 1n regu- 
lations, degradation of visibility has been a primary 
concern in eastern Utah and western Colorado. 


P-4-7 The; data presented by Paraho on water resources 1n the 
Uintah Basin Synfuels. EIS and the Surface Oil Shale 
Demonstration. (SOSD) reports- have emphasized non-site 
specific data. It would be desirable to monitor the water 
quality of the various wet zones- quarterly to establish a 
fulT year of baseline data. 

The proposed parameters to be monitored should Include 
alkyi pyridines since these compounds have been previously 
associated with spent shale leachates. 


P-4-7 Soils analyses presented in the Uintah Basin EIS and SOSD 
reports indicate high transmissivity in shallow soil 
horizons. Although the site is considered to be semi- 
arid to arid, flash flooding caused by heavy localized 
thunderstorms does occur. These shallow horizons could 
transport oils and other pollutants over time from the 
Plant area and disposal piles. Paraho should consider a 
program of monitoring soil quality in susceptible areas. 

R-3-17 The applicability of low level wind measurements taken 

outside tho Uintah Basin 1s questionable. Prior discussion 
1n the text has focused on the complex terrain of the 
region. Correlation of the ground stations in Colorado 
to the Uintah Basin should be presented to validate the 
use of this data. 


Although general wind patterns are from the west and 
west-southwest, data collected on the White River 011 
Shale Project showed a tendency for winds originating 
from the southeast. These winds would transport pol- 
lutants from the Paraho-Ute, Syntana-Utah, and Bonanza 
Power Plant Projects toward Dinosaur National Monument. 
This data and specific wind roses should be included in 
the body of the NEPA document. 



U.S. Department of Energy 

42.1 BLM notes the Department of Energy's assessment that the EIS provides 
extensive discussion of the expected impacts of the proposed synfuels 

42.2 It is not true that the Uintah Basin Synfuels Development EIS and 
Prototype EIS air quality analyses used the same model. Because of 
conflicting schedules, it was necessary that different contractors do 
the air quality analyses for the two EISs. Because each contractor 
used its own model, this resulted in different modeling approaches. 
With different approaches, one could not expect identical • results. 
BLM air quality specialists are in the process of comparing the two 
analyses. Also see the response to Comment 27.9. 

42.3 The type of material disposed (oil shale or tar sand) is less 
important than the probability of producing leachate. Given the 
results of the studies cited in the response to Comment 32.11, this 
probability would be very low or nil. 

42.4 The major part of recharge in the southern Uintah Basin derives from 
runoff to alluviated valleys. The tar sand proposed to be mined 
underlies narrow ridges between incised drainage and does not extend 
to the depth of the valleys. Restoration will reproduce original 
slopes promoting runoff, and revegetation will enhance transpiration, 
both factors limiting or eliminating deep infiltration. Although 
highly improbable, any excess moisture succeeding to infiltrate to 
the bottom of the spent sand would be impeded downward by underlying 
less permeable layers, and, if sufficient, could appear as seeps on 
the valley sides, which would likely evaporate. The quantity of 
water available for deep infiltration is very small after runoff and 
evapotranspiration demands are satisfied and would be highly diluted 
when added to the bulk of recharge that occurs in the valleys. 

42.5 Additional information about the resources associated with the site- 
specific projects are included in the applicants' technical reports. 

For the Rainbow project, the tons of ore required to produce a barrel 
of oil can be determined from the tons of tar sand mined per day as 
identified on Table R-l-9. The average is 2.73 tons per barrel, with 
a process efficiency of about 80 percent. This figure has been added 
to Section E-l.D.l. 

Water requirements shown are total use by project. If the analysis 
used only water required for processing, a true water use impact 
would not be presented. Total water use is the figure that must be 
considered in determining environmental impacts. While processing 
water requirements are useful in comparing different processes, the 
purpose of this EIS is not to evaluate the attributes of different 
processes, but rather to assess impacts of individual projects. 








Impacts of the White River Dam are discussed in detail in the White 
River Dam Project Final EIS (BLM 1982b). However, determination of 
accurate sedimentation rates was cited as an unresolved issue. In 
the Uintah Basin Synfuels Development EIS, the effect of the White 
River Dan on total dissolved solids (salinity) is discussed in 
Section R-4.A.3. Salinity at Imperial Dam would increase from 3 to 4 
mg/1. The increases in salinity are not discussed for the Upper 
Colorado River System, because the water model is not as reliable in 
these reaches. 

The Taylor Draw Reservoir (referred to in the comment), which is 
under construction near Rangely, was considered to be an interrelated 
project (Table R-l-3). This project's effects on total dissolved 
solids (salinity) are considered in the cumulative impact analysis 
(Section R-4.A.3). However, as is the case for White River Dam, 
sedimentation or suspended solids in the Upper Colorado River system 
is an area that, at present, cannot be quantitatively determined. 
Nonetheless, there will be a net sediment decrease due to the 
trapping effect of the reservoir. 

The description of floodplains referred to in the comment is a 
picture of the existing landform that was formed due to flooding. It 
is true that the chances of it flooding are more remote on the Green 
River due to the construction of Flaming Gorge Dam. (The Taylor Draw 
Reservoir, which is under construction in Colorado, will have very 
limited effects on flood control due to its small capacity.) The 
discussion as presented is still accurate in that there would be no 
impacts on flood stage. The effects of Flaming Gorge Dam, White 
River Dam, and Taylor Draw Reservoir are addressed in the EISs 
written about these projects. 

The U.S. Fish and Wildlife Service has an approved black-footed 
ferret search technique to be used on any prairie dog colony that 
would be affected by project construction. 

This impact is discussed in Section R-4.A.8 under the Water-Oriented 
Activities section. 

.. resource on 
on the other 

Gilsonite was not discussed, because it is a mined-out 
some of the applicants' leases and is not found on the 
applicants' leases. 

The word "antonomy" was not the correct word to use. The intended 
meaning was that a lessening of some definition of reservation 
services and facilities would occur because of the need to share them 
with other regional communities for adequate regional coverage. 
Section R-4.A.1 has been changed to reflect this intended meaning. 

Section R-4.A.4 has been revised. 

42.13 Refer to the response to Comment 42.4. 


42.14 The oil shale and sedimentary rock layers above the shale would not 
be highly fractured. The possibility of small mammals dying from 
escaping gases is considered to be remote because of the lack of 
fracturing and the type of gas recovery system that would be used. 

42.15 The 5,000 bpsd figure refers to the amount of upgraded crude oil 
rather than bitumen that would be produced. This has been clarified 
in Section E-l.A. 

42.16 Section E-l.C.l and Table E-l-1 have been revised. 

42.17 This point has been clarified in Section 0-1. D. 2. 

42.18 The 5,000 acre-ft/year is an average water use figure furnished by 
the company. It is not the total water required to produce 5,000 
bpsd, since the majority of the water would be recycled. 

42.19 On the average, 6,000 bpsd of crude bitumen would be produced, which 
would be, on the average, 5,000 bpsd of upgraded bitumen. The words 
crude and upgraded have been added to the text. 

42.20 The only mineral resources that would be significantly affected by 
the proposed project would be the hydrocarbons identified in Section 
R-3.A.13. See also the responses to Comments 31.55 and 42.10. 

42.21 Refer to the response to Comment 42.4. 

42.22 In order to reduce the volume of the EIS and avoid repeating similar 
information, the reader is referred to the Floodplains subsection of 
Section R-4.A.3. 

42.23 The discussion of spent sand disposal in Section E-4.A.4 has been 

42.24 As stated in Section E-4.A.11, methodology is discussed in Section R- 
4. A. 13 and Appendix A-10. 

42.25 More detailed resource data is included in the applicants' technical 
reports. Please refer to these reports. 

42.26 The map shows the main access road. In order to emphasize major 
project components, no minor on-site roads have been included in any 
of the lease area maps. 

42.27 The proposed upper limit (high water line) of the White River Dam 
Reservoir is just south of the Paraho site. Due to this, surface 
water levels in this area would not be very different than they are 
now, so the reservoir would not greatly increase the potential for 
ground water intrusion into the mine. 

42.28 Pilot balloon data collected for EPA near Bonanza, Utah, indicates 
frequent wind directions at plume height that would transport 
pollutants toward Dinosaur National Monument from each of the 
applicant's proposed project. The visibility analysis (Systems 





Applications Inc. 1983) indicates that yellow discoloration is 
predicted to be visible at Dinosaur National Monument from one or 
more of the synfuel facilities from 5 to 50 mornings per year, 
depending upon the perceptibility threshold assumed. Because 
Dinosaur National Monument is not presently a Class I area, it is not 
afforded visibility protection by law under the Clean Air Act. The 
National Park Service Organic Act of 1960 states that it is the 
responsibility of the National Park Service "to conserve. . .the 
natural... objects and the wildlife therein, and to provide for the 
enjoyment of the same in such a manner. will leave them 
unimpaired for the enjoyment of future generations." The National 
Park Service interprets this as a mandate to protect the natural 
resources under its jurisdiction from the effects of air pollutants. 
The National Park Service is currently monitoring visibility at 
Dinosaur National Monument. Because air quality could be affected to 
varying degrees by one or more of the projects, BLM concurs that the 
applicants should consider monitoring programs in or near the 
monument. The State of Utah has a requirement in their PSD 
permitting process for pre- and post-operation monitoring of major 
emissions from a permitted facility. Monitoring requirements are 
determined on a case-by-case basis by the executive secretary of the 
Air Conservation Committee. 

Regarding fugitive dust emissions, due to the large size of most of 
the particles, it is unlikely a significant amount would reach 
Dinosaur before settling out and being deposited on the ground. 

The BLM cannot require monitoring. The lands in question are state 
lands and monitoring is, therefore, a state issue. 

Soils in the area are mainly moderately permeable to moderately 
slowly permeable, with the shallow and moderately deep soils 
underlain by interbedded, fine-grained sandstone and shale. 

The transport of oils and similar pollutants through these soils 
would be very minimal to nonexistent. Runoff, due to thunder storms, 
could move sediments containing pollutants. However, the retention 
dams would control runoff and sediment. 

Low-level winds measured outside the Uintah Basin were not used in 
the regional modeling exercise. These winds would not be 
applicable. Upper-level winds from four National Weather Service 
measurement sites, and lower-level winds from the site of the White 
River Oil Shale Project were used. The southeast winds measured at 
White River are likely to be nighttime and morning drainage winds. 

Wind roses were not included in the EIS, because they would not 
contribute significantly to the layperson's understanding of the 
impacts. However, wind roses are included in Section 2.2 of the Air 
Quality Technical Report. 








P.O. BOX 580 


Phone 303/675-8476 

October 26, 1982 

Mr. David Moore 

Vernal Di strict 

Bureau of Land Management 

17Q South 500 East 

Vernal, UT 84078 

Re: Uintah Basin Synfuels Development Draft Technical Report, 
August 1982 {Socioeconomics): Comments of Town of Rangely, 
Rio Blanco County, and Districts of Western Rio Blanco 
County, Colorado. 

Dear Mr. Moore: 

I have reviewed the letter of 10-19-82 from Rangely Mayor 
Peggy Rector on the above. The analysis is thorough and accurate. 
No doubt errors and misconceptions in the Draft Technical Report 
can be readily addressed. 

However, a far more critical issue is inability of the 
Towns, Counties, and Districts on this side of the border in 
Colorado to negotiate any kind of serious, realistic impact 
mitigation efforts. 

None of us issue permits, licenses, or have any kind of 
clout in our dealings with companies the other side of the 
border in Utah. Only the United States Government Agencies 
have clout that could be used in our behalf. 

I would request that as a condition of issuance of any 
permit or license from a federal agency, such as the Bureau 
of Land Management, any company seeking or receiving such 
license or permit would be required to negotiate a suitable 
impact mitigation agreement with any impacted jurisdiction, 
regardless of location. 

Very truly yours , 

Don C. Peach 
Town Manager 


cc: Hayor and Council 

Corrmunity Devel . Director 
County Devel. Director 

Te»m of Rangely, Colorado 


BLM has no authority to require an applicant to negotiate mitigation 
of Impacts with any town or county, regardless of whether it is 
located In Utah or Colorado. 







OCT 2 I99t DENVER COLORADO 80295-0699 

Ref: 8PH-EA 

Mr. Lloyd Ferguson, District Manager 
Bureau of Land Management 
170 South 500 East 
Vernal, Utah 84078 


Draft Environmental Impact Statement for the Uintah Basin Synfuels 

Dear Mr. Ferguson: 

The Region VIII Office of the Environmental Protection Agency has 
reviewed the above-referenced document and would like to offer the attached 
detailed comments for your consideration in preparing the final environmental 
impact statement. We understand that the preparation of this document within 
the strict time constraints was a difficult and demanding task. We feel that 
your staff has produced a document which identifies most significant 
environmental impacts and which is forthright in presenting the fact that 
there is a great deal yet to be learned about this emerging industry. EPA has 
three major areas of concern with respect to oil shale development in the 
Uintah Basin; Air quality, Water Quality and Solid Waste Disposal (including 
spent shale and hazardous wastes as regulated under RCRA). 

The potential National Ambient Air Quality Standard and PSD increment 
violations predicted in this and other documents can be a constraining factor 
on oil shale development in this region. There are alternative methods for 
approaching PSD increment consumption which the companies involved may want to 
consider. These options may be found in a recent EPA report; "Preliminary 
Evaluation of Alternative Prevention of Significant Deterioration Policies: A 
Case Study of Oil Shale Development 1n Colorado and Utah", May 1982 (copy 
enclosed). The air quality modeling discrepancies noted between this document 
and the Prototype 01 1 Shale Leasing Supplemental DEIS should be resolved if 
possible as they present a confused picture of future air quality in the 
region. As a result of the substantial uncertainties surrounding the 
potential air quality impacts associated with this industry, a comprehensive 
monitoring program (Including worker health monitoring) would be a necessity 
in order to detect and eliminate adverse impacts to workers and the 
surrounding population. 

The potential water quality problems of this Industry have been 
identified but the extent of impacts are still unknown. The primary water 
quality concerns 1n the Uintah Basin are ground and surface water 
contamination from spent shale leachate, product spills, salinity increases 
and the reservoir contamination problems (previously identified) associated 
with the White River Dam project. EPA recommends that a monitoring program be 
established for the spent shale piles (see EPA's Draft Source and Ambient 
Monitoring Reference Manuals and the monitoring program established for the 
White River 011 Shale Project) so that potential problems can be detected 
early. It should be noted that each of the developers has identified a 



reasonable and feasible method of water supply which does not depend on the 
development of the White River Reservoir. Upon further investigation, the use 
of suitable groundwater resources may also prove to be economically feasible 
and environmentally preferable. 

The methods for handling spent shale and hazardous solid wastes need some 
refinement (see detailed comments). In general, there is not enough 
information on hazardous waste handling to assess potential environmental 
impacts. In instances where there are well-documented reclamation studies and 
a good monitoring program we feel the chances of successful spent shale 
disposal are enhanced. We are especially supportive of the suggestion that a 
reclamation specialist be charged with overseeing the program for each 

In sumnary, we feel that the potential environmental impacts from the 
industry and the lack of Information on some aspects of the operations require 
us to rate this EIS as ER-2. (This means that EPA has environmental 
reservations about the Impacts of the proposed projects and that the EIS 
should contain additional information, as outlined in our detailed comments, 
to assist in determining the extent of environmental impact.) We appreciate 
the opportunity to review this document. If you have questions, please 
contact Mr. Gary Voerman (FTS 327-4831) of my staff. 

Sincerely yours 

Steven 0. Durham s~~ 
Regional Administrator 





EPA's Detailed Comments on the 

Draft Environmental Impact Statement for the 

Uintah Basin Synfuels Development 


EPA has provided technical review of the air quality modeling techniques 
and results through participation on the technical advisory committee. There 
are some issues which should be clarified for the benefit of the public and 
the companies involved. The predicted National Ambient Air Quality Standards 
(NAAQS) and Prevention of Significant Deterioration (PSD) Class II increment 
violations for Total Suspended Particulates (TSP) would not be allowed to 
occur. However, the primary cause of the high TSP values appears to be 
windblown dust and this fact may allow for the use of a lower background TSP 
value when calculating air quality impacts from the proposed projects. 
44 5 Approval for the use of lower TSP background values would be given on a 

case-by-case basis when companies are applying for PSD permits. (All 
applicants siting in Utah would apply to the State for their PSD permits.) 
This approach is consistent with EPA's fugitive dust policy. A prediction of 
a NAAQS violation after discounting for rural fugitive dust would likely lead 
to a permit denial unless the company could find additional ways of reducing 
TSP emissions to bring ambient values down below the NAAQS. Other options 
exist for ameliorating PSD Class II violations including redesignation of the 
areas as CI ass III. 

The projected PSD Class I violations at Flat Tops from the cumulative 
development in the Uintah and Piceance Basins could be offset in a variety of 
ways including the granting of a variance pursuant to section 165(d) of the 
Clean Air Act. It should be noted that EPA does not recognize the Colorado 
Category I Standards for the Dinosaur and Colorado National Monuments. These 
44 6 are f ederal Class II areas and will be so treated by EPA for PSD purposes 

(i.e. for facilities proposed for Colorado) until formally redesignated. 
Since the State of Utah now has the PSD program any "violations" of Colorado 
Category I Standards at Dinosaur and Colorado National Monuments caused by 
facilities siting in Utah would probably be resolved by an agreement between 
the two States . 

The Draft Technical Report to the Air Quality portion of the Uintah Basin 
Draft. EIS contains modeling performed by SAI, which does not show appreciable 
SC<2 increment violations at .any of several Class I areas in Colorado and 
Utah. The Prototype Oil Shale EIS, on the other hand, contains modeling 
performed by Dietrich, Fox, Wood and Marlatt, which predicts higher 
concentrations of SO2 (as much as double the Class I increment) at the Flat 
44 7 Tops wilderness Area. The discrepancy by almost a factor of two between these 

respective modeling approaches is not to be unexpected. SAI's modeling was 
largely with Gaussian steady state models, while Dietrich, Fox, Wood and 
Marlatt, et. al. performed most evaluations using a varying flow field model. 
If adequate and appropriate meteorological data were available over the area 
of interest, a variable flow field modeling approach, which is capable of 







simultaneously using data from more than one point, would therefore certainly 
be expected to better describe plume paths. Yet without these meteorological 
data, it is not clear that results from one model are superior to the other. 

Further, differences in results in the two technical studies can be 
expected because the assumed meteorology in the models differed. SAI assumed 
"D" stability, while Dietrich, Fox, Wood and Marlatt, et. al . assumed "E" 
stability for 24-hour averaging periods. In our opinion, neither can be 
realistically expected to persist for 24 hours over the entire Region. 
However, one might intuitively expect persistent "D" stability to be more 
likely than persistent "E" stability. Thus, for realistic model estimates a 
neutral atmosphere should be assumed while use of a stable atmosphere leads to 
higher estimates and therefore likely errs on the side of protecting the 

The two studies also differ in their use of potential air emissions 
sources. The prototype EIS does not include any of the Uintah Basin Synfuels 
facilities and the Uintah Basin EIS includes only the multimineral development 
(only one of the two prototype lease tracts). This discrepancy should be 
rectified or its impacts on model predictions explained. 

Although we recognize that every effort was made in both studies to 
obtain currently accurate emission inventories, these data can be expected to 
change by the time the potential sources apply for a PSD permit. In fact, 
applicants have changed emissions data several times during the course of the 
PSD permit application review. 

In view of these meteorological and emission data uncertainties and with 
little or no idea as to the accuracy of the model itself, it is our opinion 
that further attempts to define a best modeling approach among several already 
adequate approaches may be futile. However, model discrepancies make it 
rather difficult to predict and understand the real tradeoffs involved in the 
many leasing and right-of-way decisions which must be made in the near 
future. It would be useful for all decisionmakers if a more accurate 
predicton of impacts could be made. One small step in this direction could be 
provided by making at least one more run of the RTM model to confirm the 
conclusions reached in the Air Quality Technical Report concerning GPM 

On page R-4-33 reference is made to consideration or secondary emissions 
during the PSD permitting process. The current PSD regulating requirements 
are that secondary emissions from these facilities are to be considered when 
calculating emissions impacts from the source. EPA assumes that the State of 
Utah will consider these emissions during the PSD permitting process. 

EPA agrees with the statement that wet deposition rates deserve more 
detailed study. The EIS admits that the increased acidity of high mountain 
lakes in the Flat Tops will have unknown impacts. Given the limited buffering 
capacity of these lakes the potential exists for significant adverse impacts 
to biota. Again, it would be useful for the decision-maker to know what the 
potential environmental impacts of this leasing decision could be, expecially 
in areas where high environmental quality is of national importance. 









The EIS correctly identifies the potential worker and societal hazards 
from an oil shale industry. EPA encourages each applicant to develop an 
extensive monitoring program covering those elements known to be toxic and 
carcinogenic in this industry, including unregulated pollutants. Applicants 
for Synfuels Corporation funding are required to develop a comprehensive 
monitoring program in consultation with EPA (Section 131(e), Energy Security 
Act). In addition, more detailed emission data will be required as part of 
the PSD permitting process. EPA supports the statement in the EIS that 
workers health would need to be carefully monitored if health damage is to be 
avoided and prevention techniques improved. The development of a mechanism 
for sharing health data (e.g- a cancer registry) should be an integral part of 
this health monitoring program. 

On page R-4-37 the statement is made that, "No health effect potential 
was found for exposure to fluoride, mercury, lead, selenium or vanadium". 
Does this mean "no effect" or "estimatable risk factor" was found for the 
levels of these metals estimated to occur in ambient air and originating from 
the oil shale activities? 

On page R-4-61 the statement is made that there will be no adverse 
effects due to gas escape from the Lofreco project because of the kind of gas 
recovery system to be used. A discussion of this system and how it will 
prevent this problem should be included in the final EIS or in the 
environmental assessment to be written for the Geokinetics projects. 


Monitori nq 

The potential exists for severe water quality impacts due to spent shale 
leachate, retention dam failure, product or by-product spills or shale pile 
reclamation failure. The EIS currently recognizes the necessity of having an 
effective monitoring program in place in order to detect any problems before 
they become unmanageable. Unfortunately, there are no monitoring details 
presented in the EIS. EPA recommends that the companies consult the 
monitoring program document produced for the White River Shale Project and 
EPA's draft versions of the Source and Amount Monitoring Reference Manuals for 
the Synthetic Fuels Industry. EPA would be glad to meet with any of the 
participating companies to review their air and water quality monitoring 
programs to help insure completeness. 


The analyses of salinity impacts is seriously deficient from three 
perspecti ves: 

(1) The DEIS does not adequately acknowledge yiat salinity is the major, 
basinwide water quality problem in the Colorado River Basin causing an 
estimated $100,000,000 in annual damages. The Department of the Interior 






estimates that annual damages will reach $237,000,000 by the year 2000 if 
adequate salinity control is not implemented. Opportunities to mitigate 
adverse salinity impacts should be discussed. 

(2) The DEIS does not evaluate salinity impacts from salt loading, only 
salinity impacts from consumptive water use are discussed. Salt loading 
could be very significant and could include, but not be limited, to the 

(a) discharge of intercepted groundwater, 

(b) leachate from raw shale and/or spent shale piles, 

(c) runoff from disturbed areas, 

(d) process water. 

The salt loading impacts must be analyzed to fully assess the salinity 
impacts of synfuels scenarios. 

(3) The DEIS assumes that water for the synfuels activities will come only 
from the Green River and/or the White River. The assumption ignores the 
policies of the seven-state Colorado River Basin Salinity Control Forum 
and the State of Utah which are to encourage the use of brackish and/or 
saline waters for industrial purposes (copies of these policies are 
attached). To be consistent with these policies, the EIS should examine 
alternative sources of water including "brackish and/or saline waters". 
This could include saline springs and seeps and groundwater sources 
(e.g., Birds Nest and Douglas Creek Aquifers). 

Additional Comments 

The relationship between 132,000 acre-feet depletion and a 5 mg/1 
increase in salinity is not clear and should be explained. A depletion of 
132,000 acre-feet of good quality water would normally cause a salinity 
increase of approximtely 13 mg/1 at Imperial. In any case, the salinity 
damages in dollars should be acknowledged (i.e., 5 mg/1 increase at Imperial 
causes approximately $2,500,000 in annual damages). 

Table R-4-18 (pg. R-4-52) should note that the water quality 
standard/numeric criteria for salinity at Imperial Dam is 879 mg/1. This 
standard has been adopted by all seven basin states and has been approved by 
EPA. Section 313 of the Clean Water Act requires that Federal agencies comply 
with all water pollution control requirements in the same manner as any 
non-governmental entity. This requirement applies to water quality standards. 

The discussion on page R-4-54 of salinity increase is confusing with 
numerous different figures (19 mg/1, 4 mg/1, 10 mg/1 , 5 mg/1, etc.) presented 
yet no explanation of how these figures were derived, or what they actually 
represent. Given the critical importance of salinity increases, the 
derivation of the mg/1 increases must be explained. 










The discussion of "Other Water quality Impacts" (pg. R-4-55) is totally 
inadequate and ignores research on the subject. (For example, Lysimeter Study 
on the Disposal of Paraho Restored Oil Shale , EPA-600/7-79-188; and 
Environmental Perspective on the Emerging Oil Shale Industry , 

Wastewater Treatment 

The EIS should be more specific regarding the status of the enlargement 
and upgrading of Vernal's wastewater treatment facilities. Specifically, it 
is important to cl ari fy whether the construction timetable coresponds to 
projected growth needs. 

There is insufficient information provided on wastewater treatment for 
oil shale process water (e.g. see pages E-l-13, M-l-13 and S-l-12) that will 
be used for spent shale or spent sand disposal. Some minimum wastewater 
quality criteria should be established for water to be used for spent 
shale/ sand compaction. 

It is not clear (pg. E-l-13) how the "impervious bottom" in the 
backfilled mine will prevent seepage of process water mixed with the sand. 
How impervious is this bottom (e-g. in cm. of liquid movement allowed per 
day)? What is the ultimate fate of leachate that seeps through the impervious 
layer? The EIS does not provide adequate information regarding disposal of 
spent sands, nature of leachates produced and site specific information to 
evaluate potential environmental impacts. 


Potential impacts upon groundwater should be stated to be a significant 
criteria (pg. R-4-7). While there is not a great deal of information 
available on the groundwater hydrology of the Uinta basin, hydrologic test 
information has shown that groundwater can be found in the sandstone and 
siltstone beds above and below the oil shale and within fractions in the oil 
shale. The groundwater data presented in Section R-3.a.3 (pg. R-3-25) 
provides a little regional information on the groundwater hydrologic system. 
However, the limited discussion presented does not provide enough detail for a 
site-specific assessment. 

As was pointed out in our comments on the Preliminary Draft EIS, the 
statement on page E-4-6 is misleading. Groundwater aquifers below the 
overburden can logically be impacted by mining leachate. 

The EIS talks (pg. R-4-55) about "Temporarily disrupt normal groundwater 
flow until reinjection can begin". Rejection is talked about as a given. 
However, quality issues have not been defined enough to pass judgement on 
reinjection . It should be noted that any well reinjection would require an 
underground injection permit and would be covered by regulations found at 40 
CFR 146. 







Groundwater is eliminated as a water supply alternative on page E-l-18 
and yet vital information for judging the basis for that decision is not 
provided. The aquifers are not characterized, the quantities of water 
expected are not noted and the costs for upgrading poorer quality water are 
not compared to pipeline and property costs. It is not possible for the 
reviewer to determine the basis for eliminating this alternative from 

Other Water Quality Impacts 

The EIS correctly states (pg. R-4-55) that sufficient data is not 
available to determinethe potential for leachate production from spent shale 
disposal piles. However, the EIS then proceeds to dismiss the importance of 
leachate formation by saying it can be prevented by using impermeable linings, 
runoff diversion and sealing of the surface of the disposal piles. These two 
statements are in conflict. Further, not all the applicants are proposing the 
use of impermeable linings, surface seals and runoff diversion from the 
piles. (See specific comments on applicants technical reports). In addition, 
a definition of impermeable is not provided. Applicants also constantly 
ignore the installation of drains above and below the impermeable lining. 
Without drains the bottom of a pile may liquify causing failure with resultant 
heavy silt and salt loading into streams. The EIS also says that infiltration 
into the piles will occur only from high intensity thunderstorms. Host 
infiltration will likely occur from snow melt not thunderstorms. The EIS has 
ignored numerous EPA, DOE, and industry studies that bear upon this important 
question. Other water quality impacts of concern include volatile organic 
carbon contamination and spent shale pile bio-leaching. 

Flow numbers 
preliminary draft. 

[pg. R-3-23, paragraph 4, 
Are these correct? 

line 12) are different than in the 

The section on Ruptures and Spills (R-4.A.15) should recognize that the 
oil from the Magic Circle facility is a nontreated hydro oil and that its 
potential environmental impacts may be different than the product from the 
other facilities. Unhydrotreated crude shale oils contain more carcinogens 
and other elements that could cause more significant environmental impacts 
than hydrotreated oil . 

Nonpoint Source Water Quality Impacts 

Uintah Basin Association of Governments (UBAG) has identified and 
suggested solutions to nonpoint pollution sources in at least three 208 

Uintah Basin Areawide Water Quality Management Plan, October, 1977, 
Energy Resource Development Within the Uintah Basin (Interim Output 
Report No. 11), November, 1976, 

Technical and Institutional Alternative Management Practices for the 
Reduction of Point and Nonpoint Pollution Within the Uintah Basin 
208 Planning Area (Interim Output Report No. 12), November, 1976. 









The EIS could be clearer in relating management of the synfuels projects 
to these Uintah Basin Association of Governments (UBAG) planning efforts. 
Adequate implementation, monitoring, and follow-through for the conditions of 
BLM and the other applicable agencies will be needed. 

Both the WQM Plan and Interim Report No. 12 cover urban nonpoi nt 
pollution sources. Sources such as septic systems, and urban runoffs and 
erosion, among others, are addressed. These publications are important tools 
for use in formulating the necessary public programs to prevent and control 
these growth-induced sources. The EIS could provide much stronger guidance to 
local officials in addressing this issue. 


In general, the EIS covers on-site solid waste (especially spent shale) 
handling in an adequate manner, although more details will be needed on the 
monitoring programs. EPA supports those companies who have stated that they 
will dispose of construction and operation related solid wastes in a state 
approved on-site sanitary landfill. The E.IS does not address solid waste 
impacts caused by off-site disposal of direct or induced (secondary