REVISION - 8/11/2009, 2:25:58 PM-MR1

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interval of the BH-1 exploration hole at a very low rate. The fluid consists of water, bitumen, and condensate in an unknown ratio. The fluid level in BH-1 has not yet reached a static condition. The transducer showed a fluid-level rise of approximately 23 feet over a 10-day period; currently, the fluid level is approximately 1,900 feet below ground surface. The origins of the fluids observed in BH-1 will be determined by monitoring inflows as the hole is sequentially cemented back to the bottom of the R1 zone. 2. In the Plan of Development Volume I of 3, also on Page 43, it is stated that "Monitor well sampling and evaluation will be performed quarterly during the operation, quarterly for a one year period following the operations, and annually thereafter for an additional two year period " Please provide justification and basis for the proposed sampling frequencies. AMSO Response: It is AMSO's understanding that it is the policy of the DRMS to require groundwater and surface water sampling at those sampling frequencies. If the DRMS does not agree, AMSO will modify its sampling frequency accordingly. 3. In the Plan of Development Volume I of 3, Page 48, it states "The heater producer well includes a multiple containment barrier system to protect the overhead groundwater from pollutant entry. The heater producer well also contains multiple thermal insulating barriers to prevent retorting the oil shale surrounding the well bore. " Please provide greater detail of the composition of both the thermal and contamination containment barriers that will be used for the pilot test heater producer well. AMSO Response: Please refer to page 49 for a description of the heater-produce well completion and Figure A4-3a for a schematic of the tubing string and heater. The heater-producer well design includes an 113/4-inch steel casing centered and cemented inside an18-inch well bore throughout the total measured depth including the overhead groundwater bearing zones. Four-inch, double walled, vacuum-insulated- tubing (VIT) will be placed, and centered, inside the 113/4-inch steel casing. Gases and liquids will be transported through concentric tubing annuli inside the VIT. From page 48 of the POD: "The hottest planned operating temperature inside the heater- producer well is below the 200°C minimum retorting temperature." Heat transfer calculations using vendor-supplied insulation values indicate that the shale surrounding the well is heated only to about 60°C after a full year of conducting 200°C fluids. From page 48 of the POD: "If it becomes advantageous to produce or reflux fluids in the heater-producer well at a temperature greater than 200°C, temperature monitoring will confirm that the heater-producer well is not capable of retorting the well bore oil shale." Heat transfer calculations using vendor-supplied insulation values indicate that the shale surrounding the well is heated only to about 110°C after a full year of conducting 350°C fluids. 110 East 3rd Street. Suite 201 P.O. Box 1470, Rifle CO 81650/nhone•970-62511324 facsimile:970 625 4318 2