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As indicated in our letter of ilarch 2, 1973, from Daniel R. hale <br /> to the Office of the Attorney General, in submitting this application Occidertal <br /> does not concede the validity of said statute or the regulations proinulyated <br /> thereunder by th e Colorado hater Quality Control Commission or the applicability <br /> of said statute and regulations to our operation of the proposed retorts. It <br /> should be noted that Occidental presently has i1PD ES Permit No. CO-99299h7 <br />' issued February 22, 1977 which covers discharges for the Logan IJash operation. <br /> Refere nces in this letter to Exhibits, Fiyures and Tables are to those <br /> included in the supporting materials accompanying this letter. <br />' The Occidental Process <br /> The Occidental shale oil process produces oi l by mining approxir.iately <br /> 20`,0 of the material within the retort, rub blizing the balance of the shale <br /> within the retort and retorting the rubble in place. At the Logan Nash site, <br /> <br /> several hundred feet of overburden remain beb;ieen the ground surface and the <br />' top of the mire workings. <br />Petorting is begun by introducing a fuel and air to burn at the top <br />' of the rubble pile until the shale is heated sufficiently to produce oil and <br />gas and a carbonaceous residue. The oil and water from the retort flow to an <br />impermeable sump at the bottom of the retort where they are collected and <br />pumped to storage. The gas is also piped off at the bottom of the retort. <br />The carbonaceous residue burns as air is continued and the outside fuel storage <br />is discontinued. As the carbonaceous residue burns, the rock below tfre corn- <br />, bustion front is heated and continues to produce oil, gas, and more carbonaceous <br />residue. The latter then burns, continuing the process until the retorting <br />front reaches tfre bottom of the retort. Steam is introduced along with air in <br />order t.o control the oxygen content of the feed gas. <br />' Occidental's mining and retorting operations involve two kinds of <br />' water. "Retort water" is water within a retort, including water produced by <br />-2- <br />1 <br />