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•, attached 14_iterials <br />Attached to this application are data and information prescribed in <br />Rule 7.'L.<1 of the Rules for Subsurface Disposal Systems promulgated by the <br />' Colorado 4later Quality Control Commission. i•iuch of this data has been previously <br /> submitted to the Colorado t4ined Land Reclamation hoard, in connection with its <br />' issuance of a permit for operation of the Logan 4Jash (D.A. Shale) facilities, <br /> and to th e Department of Energy (DOE) in connection with a 519.5 million <br /> <br /> contract bet~•reen DOE and Occidental for an engineering design and demonstration <br />1 project pertaining to operations at Logan 4Jash toward verifying commercial <br />production, as part of a 560 million cooperative program to develop alternate <br />energy sources to minimize reliance on imported petroleum. This latter contract, <br />we submit, o-rould support the issuance of a subsurface dispoal permit under <br />Section 505 even if some limited pollution of State waters were to occur from <br />' the retort operations, since it clearly evidences a strong public interest in <br /> and need for the development of Occide+ital's modified in situ process. <br /> Paragraph (7) of Rule 7.2.4 requests a description of "the chemical, <br /> physical, radiological, and biological properties and characteristics of the <br /> ~•:astes to b <br />o <br />f th <br />di <br />d <br />h th <br />" R <br />t <br />l <br />h <br /> se <br />roug <br />e <br />sp <br />o <br />em. <br />e sys <br />etorted s <br />a <br />e is a complex <br /> material, the character and properties of which vary as a function of the rare shale <br /> composition and as a function of retorting conditions, especially thermal <br />' history (Smith 1972). Qecause of the variation in retorting condixions that <br /> exists with respect to each Logan 41ash retort, we are unable to predict v;ith <br />' exactn <br />s th <br />i <br />f <br />h <br />t <br />l <br />l <br /> es <br />e propert <br />es o <br />e re <br />orted sha <br />t <br />e that wil <br />be generated. The <br /> point is moot, However, since this application is based on our proposed separ- <br /> ation of spent shale from State waters rather than on the characteristics of <br />' Lhe substances generated in the retort. <br /> On the basis set forth in this application, Occidental respectfully <br /> re <br />uest <br />th <br />t <br />h <br />4l <br />l <br />l <br /> q <br />s <br />a <br />t <br />e <br />ater Qua <br />ity Contro <br />Commission issue a permit to Occidental <br /> permitting ignition and operation of the Logan Wash retorts in the manner <br />-6- <br />