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

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From the July 7, 2009, DRMS letter 1. The surface water monitoring sites constitute Points of Compliance, which are very important in the Environmental Protection Plan, so the locations of those sites should be submitted and approved prior to approval of the Modification. AMSO Response: The AMSO RD&D site lies between Ryan Gulch to the north and Black Sulfur Creek to the south. Please see attached Figure 1 depicting the surface water monitoring site on Black Sulfur Creek. No surface water has been found in Ryan Gulch; therefore, no surface water monitoring can be conducted in Ryan Gulch. 2. Page 27 of the Plan of Development states that the environmental assessments began in 2006, but the Sept 22, 2009 SAP states that subsurface exploration has not yet been conducted Please describe the nature of the environmental assessments conducted to date If they have been previously provided in other documents, please indicate such. AMSO Response: The Bureau of Land Management analyzed the potential impacts of RD&D activities on the Tract in 2006. The Environmental Assessment and associated documents are available on the White River Field Office web site. Other then collecting baseline data, no site activities were started before the EA was completed. 3. DRMS is concerned about pyrolysis products that could form in the heated zone and whether the monitoring of potential pyrolysis products will be adequately monitored Has AMSO conducted any bench scale studies to determine the comprehensive effects of pyrolysis on the surrounding rock and the extent to which pyrolysis will enhance mobilization of inherent rock constituents and mobilization of pyrolysis products? What is the anticipated fate of pyrolysis products, i. e-, will organic products be short- lived due to bio- or thermal degradation, or will they persist with the potential to be mobilized off-site by natural ground water transport? AMSO Response: AMSO has conducted pyrolysis tests on illitic shale and characterized the products. We know from micro-scale sealed vessel tests, for example, that shale oil from the illitic zone is more paraffinic and contains less BTEX than conventional shale oil. However, the basic concept of retorting in the illite oil shale zone (i.e. the RI zone) is that that zone is isolated from all groundwater by the overhead nahcolitic oil shale cap. In addition, the RI zone contains no aquifers, as explained above. The tightness of this seal is demonstrated by the fact that we found naturally occurring oil and gas in the illite shale retorting interval. AMSO firmly believes that retorting in the illite oil shale, which is naturally isolated from protected aquifers, provides the best protection of ground water available. 110 East 3rd Street. Suite 201 P.O. Box 1470: Rifle. CO 81650/phone:970-62514324 facsimile:970-625-4318 6