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u?o?rur+a M M? <br />United States Department of the Interior <br />BUREAU OF LAND MANAGEMENT <br />White River Resource Area <br />220 East Market Street <br />Meeker, Colorado 81641 <br />CO-110 <br />3557 <br />Oil Shale RD&D <br />CC?C 69169 <br />RECEIVED ? <br />October 17, 2008 <br />Roger Day / <br />American Shale Oil, LLC <br />P. O. Box 1470 <br />110 E. 3`d Street, suite 210 <br />Rifle, CO 81650 <br />Dear Mr. Day: <br />OCT 2 0 2008 <br />GRAND JUNQ'K ;? ?.u OFFICE <br />DIVISION OF <br />RECLAMATION MINING & SAFETY <br />P - 200, Ala <br />OCT 2 1 2008 <br />Division ui "eclamation, <br />Mining and Safety <br />On August 5, 2008 the White River Field Office (WRFO) received your "Addendum to the Plan of <br />Operations for Oil Shale Research, Development and Demonstration (RD&D) Tract COC-69169". This <br />document contains variations from the original Plan of Operations (POO) in the nomination that was <br />submitted to the WRFO on September 14,-2005. The POO was evaluated during the approval process <br />for E. G. L.'s RD&D lease tract application. The WRFO reviewed the addendum to determine its <br />compliance with the lease terms. Importantly, a compliance determination with Section 2 of the lease <br />and with the Environmental Assessment for the lease tract also was performed. Section 2 states, <br />"...process and disposal of the oil shale and the products of oil shale contained within the Leased Lands <br />as proposed in the nomination submitted in response to the Federal Register notice of June 9, 2005." <br />Site specific research and development work has led to the submission of the addendum to the original <br />POO. The following summarizes the submission: <br />The addendum identifies a lower oil shale zone, R-1 and R-2 for shale oil recovery, <br />instead of the R-6 and R-7 that is identified in the original POO.. A barrier cap of <br />nahcolitic oil shale will remain in place between the retorted zone and the overlying <br />aquifer system to isolate the overlying aquifer zones from the shale oil recovery zone. <br />This lower zone is below the water bearing portion of the Green River Formation and <br />therefore does not necessitate the dewatering of water bearing zones prior to the initiation <br />of heating the oil shale resource <br />The in-situ methodology of conduction convection and reflux in the addendum remains <br />consistent with in-situ methodology submitted in the original POO. <br />Implementation of L or U shaped confined heater wells instead of only U shaped <br />confined heater wells remains consistent with in-situ methodology submitted in the <br />original POO.