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point of collapse, a subsurface void of finite size could develop. The void is limited to <br />the net space after rubblization of the collapsed oil shale matrix. Reasonable potential <br />exists that the void will remain stable. In the event that collapse does occur, caving could <br />propagate upward through a limited amount of strata. The height of caving will be <br />constrained by the bulking of collapsed strata to the point the bulked strata support the <br />roof or the formation of a self-supporting arch. The planned retort volume will limit <br />subsurface strata movement, if any, to a short distance above the retort horizon <br />anticipated not exceeding tens of feet. No significant risk of surface subsidence is <br />identified. <br />8. The applicant has not submitted any information related to clean up measures to be <br />taken after the desired product is removed from the hole <br />• a) Is there a plan for removing by products from the hole? <br />• b) How will this be accomplished without impacting groundwater if the rind <br />cracks during cooling? <br />AMSO Response: <br />a) Essentially all fluid products are recovered during the Retort Test. <br />b) The rind is not considered to be a groundwater protective feature. That isolation is <br />performed by the low permeability of the illite shale itself and the overlying saline <br />mineral formation layer. <br />9. No groundwater monitoring plans, trigger points, or mitigation plans were submitted <br />with this information. Is HMSO relying on the existing surface water monitoring plan <br />submitted in their original application? <br />AMSO Response: <br />AMSO submitted its "Ground and Surface Water Monitoring and Response Plan" to the <br />DRMS and to the BLM in 2008, and that plan is also included in the POD as Appendix 4- <br />10. It is AMSO's intent to follow that plan for all water monitoring and reporting. <br />10. How will the intermingling of aquifers be minimized or prevented throughout this <br />process, including during drilling? <br />AMSO Response: <br />Intermingling of aquifers will be minimized by completing each well promptly after <br />drilling. Casing and cementing will be used to prevent long-term intermingling of <br />aquifers. <br />11. How will the heater wells, through which multiple products and byproducts will be <br />circulated and re-circulated, be monitored for leaks? <br />AMSO Response: <br />Mechanical integrity of the heater-producer well will be confirmed prior to conducting <br />retort operations in accordance with EPA requirements. The product streams within the <br />VIT have redundant containment as explained in the answer to deficiency question 3. <br />Due to the short duration of the Pilot Test, no monitoring for leaks is planned. <br />110 East 3`' Street. Suite 201 P.O. Box 1470, Rifle, CO 81650/nhone:970-6254324 facsimile•970-625-4318