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REVISION - 8/11/2009, 2:25:58 PM-MR1
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REVISION - 8/11/2009, 2:25:58 PM-MR1
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Last modified
6/15/2021 11:34:55 AM
Creation date
8/11/2009 2:27:37 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
P2008046
IBM Index Class Name
REVISION
Doc Date
8/7/2009
Doc Name
Notice of deficiency response
From
American Shale Oil, LLC
To
DRMS
Type & Sequence
MD2
Email Name
THM
Media Type
D
Archive
No
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retort interval. The partitioning between water and gas phases has not been calculated, <br />primarily because the retort will be isolated from the aquifers regardless. <br />IS. For the 93 % of the raw shale sulfur that is not converted to sulfur in the oil, is the <br />sulfur converted to a more soluble form that may be mobilized to the environment? <br />AMSO Response: <br />Part of the sulfur not converted to oil during pilot experiment will be produced as H2S <br />during the retorting and sent to the incinerator, where it will be oxidized to SO2 and <br />emitted into the atmosphere. This amounts to about a third of the raw shale sulfur, and <br />the amount of S02 emitted will conform to limits in the EA. In commercial operation, <br />this sulfur would be recovered as a product. The sulfur remaining at the end of the retort <br />will have been converted from pyrite to pyrhhotite, both of which are insoluble. The <br />pyrrhotite is stable unless exposed to oxygen, which is absent downhole. Even if the <br />pyrrhotite were converted to sulfate, the lack of mobile water would prevent it from being <br />mobilized. <br />We look forward to discussing our Pilot Retort Test plans with you and your staff at your <br />convenience. <br />Sincerely, <br />1 <br />Roger L. Day <br />Vice President of Operations <br />Copy: Paul Daggett <br />110 East 3`d Street Suite 201 P.O. Box 1470, Rifle, CO 81650/phone•970-6254324 facsimile 970-625-4318 10
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