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T� T • • <br /> including BTEX and DOC. Results to date are not definitive because they were apparently run <br /> on whole water samples, so the Division awaits more definitive results. <br /> Thus, in responding to General Chemical's concern about Dawsonite and its relation to oil shale, <br /> the following is recommended. Because both DMG and BLM are charged with protecting the oil <br /> shale resource, and because test results to date do not definitively show whether the oil shale <br /> resource can be protected under the current thermo-solution mining proposal, the Division <br /> should not assume the oil shale resource can or cannot be protected until adequate baseline <br /> organic analyses of process solutions have been submitted by the company and reviewed and <br /> approved by DMG and BLM. <br /> SPECIFIC REVIEW COMMENTS <br /> Section I1, Distillation Process Concerns,11. Analyses of process solutions remain protected <br /> under C.R.S. 34-32-112(9). <br /> As above,12. Regarding time dependence of distillation, the times required are enormous <br /> relative to the potential utilization of the resource. Oxidation of the oil resource is of some <br /> concern, and has been addressed in previous adequacy comments. <br /> As above, ,13. The current monitoring will require analyses of numerous elements, including <br /> those present in dawsonite, including aluminum, sodium, and carbon. DMG would anticipate that <br /> those elements will appear in limited concentrations in the process solutions,but would not <br /> anticipate that their presence cannot be assigned definitively to dawsonite. Even if dawsonite did <br /> dissolve, albeit to some limited extent, that would not necessarily be taken to mean that the oil <br /> shale resource is being damaged. These elements present in dawsonite are present in clays, <br /> nahcolite, and probably other associated minerals which will dissolve more readily in the hot <br /> solution, so their presence in solution cannot be used to infer anything about oil shale retorting. <br /> The purpose for monitoring aluminum therefore is not to test for dawsonite solution but to test <br /> for potential exceedances of aluminum standards or numeric protection levels in groundwater. <br /> cc: Carl Mount <br /> Jim Pendleton <br />