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~ OCC{DENTAL OIL SNALE, ! NC. -,;;-. '~ P. D. BDX 2G87 2372 G ROAD GRAND JUfJCTION, COLOIlADO 81501 (303) 242-84fi3 ' hlarch 29, 1978 4Jater Quality Control Division Colorado Department of Health 4210 East Eleventh Avenue Denver, Colorado 80220 Attention: I.1r. Kenneth 4Jebb rip Re: In Situ Retort Permit, D. A. Shale Site Gentlemen: Pursuant to C.R.S. 1973 § 25-3-505, Occidental Oil Shale, Inc. ' ("Occidental") hereby applies for a permit to ignite and operate a modified in situ oil shale re :ort co..^encing in June of 1978^, and additional retorts ' thereafter, at its D. A. Shale property in Garfield County. This property is at the head of Logan 1•lash, nine miles northeast of DeBeque, Colorado. (See Figure 1 attached hereto.) This application is made on the ground, as more ' fully described belovr and in the attached materials, that no waters of the State of Colorado trill be polluted by the ignition, operation and continued ' existence of the retorts because (i) the retorts will not intersect any sat- , urated zone, (ii) water prcduced in the retorts during operation will be captured and reused in the process, and (iii) the small amount of crater that ' will infiltrate through the ground above the retorts twill be collected .and diverted so that it does not contact the retorted shale after a retort is ' abandoned. ' We recognize that tre would not be required to obtain a permit under Section 505 for the proposed retorts if the products of the retorting process are not radioactive, toxic or otherwise ha __>ardo w. Hotrever, without conceding that the nature of these products brings them within Section 505, in the in- ' terest of expediting your consideration and resolution of this matter, rre are choosing to assert here only that the facts dictate a finding by the 4later Quality Control Conuni`ssion that there will he no pollution and therefore that ' a permit should issue.