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AMSO Response: <br />As explained in Section 4a)a) of the POD, AMSO will drill one borehole for the Pilot <br />Test. The retort will be at the bottom of that borehole. Directional drilling of one hole to <br />intercept another is not proposed for the Pilot Test. <br />12. Has Applicant considered the possibility that retorting will induce decarbonation <br />and/or decalcification in the surrounding rock and subsequent release of C02? How <br />close is the proposed retort temperature to the temperature of decarbonation? Is there <br />a plan to capture or contain C02 and prevent release? <br />AMSO Response: <br />We understand and have considered the contribution of carbonate minerals to potential <br />C02 release. The illitic shale has less than one percent each of nahcolite and dawsonite, <br />which would likely decompose at the retort temperature of about 350 T. The shale also <br />contains dolomite and calcite at about one-half the level of typical Green River <br />marlstone, but these temperatures are too low to cause decomposition of those minerals. <br />Due to the low levels of nahcolite and dawsonite and the thermal stability of the major <br />carbonate minerals, the contribution of mineral C02 to the total C02 release is less than <br />that from the organic matter. <br />There is no plan to capture C02 in the pilot test, because only a very small amount will be <br />emitted from the small size and short duration of the test. We do intend to capture and <br />sequester C02 from commercial operations. The major C02 source for commercial <br />operations will be from heat generation, not from retorting the shale. <br />13. Given that sulfur and trace metals (e g., As, Ni, T) will be released along with oil <br />during retorting, and that recovery of retorted oil will likely be significantly less than <br />100%, have there been any studies to determine the extent to which mobilized trace <br />metals and unretorted oil will be released back to the aquifer after the operation is <br />complete? <br />AMSO Response: <br />The basic concept of retorting in the illite oil shale zone (i.e. the RI zone) is that that <br />zone is isolated from all groundwater by the overhead nahcolitic oil shale cap. In <br />addition, the RI zone contains no aquifers, as explained in AMSO Response number 6 <br />above to the June 17 DRMS letter. AMSO firmly believes that retorting in the illite oil <br />shale provides the best protection of ground water available and that no mobilized trace <br />metals or unretorted oil will be released to any aquifer. <br />14. What is the anticipated fate of H2S produced from sulfur after the retorting process <br />has run its course? Will it be driven off, retained in the aquifer as a dissolved gas, or <br />reduced/oxidized to a different form of sulfur? <br />AMSO Response: <br />After heat is shut off to the retort, the retort will gradually cool down, and product <br />formation rates will drop exponentially with temperature. When the gas generation rate <br />is sufficiently low, the incinerator will be stopped and the well shut in until it is <br />completely cool. In the absence of injected oxygen, the residual H2S will remain in the <br />110 East 3`d Street Suite 201 P.O. Box 1470, Rifle, CO 81650/phone:970 625-4324 facsimile:970 625-4318 9