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Mr. Travis Marshall <br />August 18, 2008 <br />Page 5 of 5 <br />AMSO Response: <br />Prior to implementing abandonment procedures, DRMS and BLM will be notified of AMSO's <br />intent to plug and abandon any drill holes constructed to support Phase I operations which are <br />no longer needed for monitoring or testing operations. Drill holes deemed valuable as <br />potential monitoring or water-supply wells by DRMS or BLM will not be abandoned. Drill <br />holes not deemed valuable as monitoring or water-supply wells will be plugged and <br />abandoned to prevent intermixing of aquifers and protect oil shale resources for potential <br />future development. Abandonment and plugging will be accomplished by first removing any <br />downhole equipment present within the hole and then filling the entire open interval and cased <br />portion of the hole with neat cement grout consisting of Portland cement with up to 5 percent <br />bentonite clay added to improve flow qualities of the slung and compensate for shrinkage. <br />The mixture will contain no chemicals or substances that have toxic properties or which may <br />decompose in the hole to produce toxic properties. The neat cement grout will be thoroughly <br />mixed using clean, non-saline water per manufacturer's specification to ensure uniform <br />consistency. Neat cement grout chemistry will be adjusted as necessary to be compatible with <br />formation water chemistry. The neat cement grout will be placed in the hole by pumping <br />through a tremmie pipe to totally displace any fluid in the hole. The mixture will be placed in <br />the hole from the bottom of the hole to a minimum depth below ground surface so as not to <br />interfere with other surface uses. All casing extending above the ground surface will be cut <br />below ground surface so as not to interfere with other surface uses. A Well Abandonment <br />Report (Form No. GWS-09) will be completed for each abandoned drill hole and submitted to <br />the Colorado Division of Water Resources (DWR). AMSO will provide DRMS and BLM <br />with a copy of each report filed with the DWR <br />Please do not hesitate to contact me if you have any questions regarding our responses to the <br />deficiencies noted by DRMS. I may be reached at (970) 625-4324 or rday@amso.net. <br />Sincerely, <br />American Shale Oil, L.L.C. <br />Roger L. Day <br />Vice President of Operations <br />Enclosures <br />110 East 3 Street, Suite 201 P.O. Box 1470; Rifle, CO 81650 Phone: 970-625-4324 Facsimile: 970-625-4318