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(iii) A description of measures to be taken to prevent or control fire, soil erosion, <br />• subsidence, pollution of surface and ground water, pollution of air, damage to fish or <br />wildlife or other natural resources and hazards to public health and safety <br />AMSO's activities will comply with appropriate BLM fire management plans provided by the <br />BLM. In addition, AMSO will comply with fire prevention and reporting guidelines required by <br />the Colorado State Fire Marshall. All surface facilities will be inspected and approved by the <br />Fire Marshall. <br />For any emergency, including fire, AMSO will follow the guidelines in the AMSO Safety and <br />Health Plan included in this POD as Appendix 8-2. <br />AMSO has prepared a Storm Water Management Plan (SWMP), and has obtained a General <br />Permit for Stormwater Discharges Associated with Construction Activity from CDPHE-Water <br />Quality Control Division (See Appendix 4-7). Reduction or elimination of soil erosion is a <br />major component of the SW-MP. Erosion control devices including ditches, sumps, silt fences, <br />and other Best Management Practices will be employed where applicable to control soil erosion. <br />In addition, AMSO will also comply with all conditions of approval contained in our Notices of <br />Intent to Conduct Prospecting Operations issued by the Colorado Division of Reclamation, <br />Mining and Safety (DRMS) (See Appendix 4-6) which will also minimize erosion. <br />Because of the small scale of the Pilot Test, no subsidence will occur. <br />AMSO has prepared and submitted a Spill Prevention, Control, and Countermeasures (SPCC) <br />• Plan to the BLM for approval (See Appendix 8-1). By closely following the SWMP and the <br />SPCC Plan, AMSO will prevent any surface spills from entering any receiving waters and <br />prevent or control pollution of surface and ground water. <br />All waste materials generated during testing will be properly contained onsite. All liquid waste <br />materials will be contained onsite in lined pits or above-ground storage tanks. Liquid wastes <br />contained in lined pits will either be allowed to evaporate or transported offsite for disposal at a <br />facility licensed to receive such wastes. Liquid wastes contained within above-ground storage <br />tanks will be transported offsite for disposal at a facility licensed to receive such wastes. Solid <br />wastes (general trash and debris) will be contained onsite and transported offsite for disposal at a <br />licensed landfill facility. Pit sludges and sediment will be sampled and, based on results, <br />disposed of in accordance with BLM and other requirements. <br />AMSO's process facilities, including the retort and Test Well, are designed to contain fully all <br />process components, including any potential ground water pollutants. The preliminary design of <br />aboveground retort processing facilities has undergone a HAZID-PHA-Consequence Analysis, <br />and the detailed design will undergo a similar process. All gas, sour water, and excess oil will be <br />incinerated with specified 99.99% efficiency. In addition, the relatively low recovery <br />temperatures in, and the insulation surrounding, our Test Well will insure that the oil shale <br />formation adjacent to the Test Well within the protected aquifers will not reach retorting <br />temperatures. Thus, no pollutants or toxins will be liberated from our recovery facilities nor <br />produced in the surrounding oil shale formations. No pollution to surface or ground water is <br />• anticipated. <br />50