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<br /> <br />... ," .. <br /> <br />. <br /> <br />. <br />Occidental Oil Shale, Inc. <br />March 14, 1980 <br /> <br />In implementing the Colorado River salinity <br />standard, the Commission and the Water Quality <br />Control Division shall take into consideration <br />the respective contributions of different <br />categories of point and non-point sources to <br />TDS concentrations and loading, and shall <br />ensure that the water quality.benefits of the <br />control strategies utilized bear a r8asonable <br />relationship to the economic, energy, and <br />environmental impacts and other costs of such <br />strategies. The Commission and Divisio~ <br />shall not require unnecessarily wasteful <br />treatment measures. To the extent industrial <br />and municipal discharges of salt are regulated <br />through the NPDES program, in determining <br />what permit conditions shall be required the <br />Division shall continue to consider the prac- <br />ticability of eliminating or reducing the <br />discharge of salt, including the technical <br />and economic feasibility of achieving such <br />elimination or reduction on a case-by-case <br />basis. <br /> <br />(5) The Forum Proposed 1978 Revision appears to <br /> <br />assume that the oil shale industry in Colorado will achieve <br /> <br />no-salt discharge. This assumption is subject to question <br /> <br />for the following reasons. <br /> <br />(a) As noted above, the total elimination of <br /> <br />salt from discharges of water carries with it <br /> <br />severe economic penalty. <br /> <br />(b) The total elimination of discharges of water <br /> <br />may occur at full operating design, but may not <br /> <br />happen for some time or even be desirable. In <br /> <br />order to achieve zero discharge of water, larger <br /> <br />quantities of water may have to be evaporated <br /> <br />in the process, thereby making it unavailable <br /> <br />for other beneficial use. <br /> <br />1411 <br /> <br />-5~ <br /> <br />~---"'-=~~""-'f":""'":.-~!a'l"-:;::;'~.-:;--...:..-';:',:",,~;'':::--:--- ,', .~... <br /> <br />