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IL <br />joints of special high collapse casing at the shoe to resist the anticipated forces. The <br />mitigation for internal corrosion is a packer and dual casing system creating an isolated <br />annulus between the 9 5/8" cemented casing and a 7° liner. The annulus will be monitored <br />for leaks. This will thus prevent any corrosive fluids from the retort being in contact with the 9 <br />5/8" casing. <br />For the integrity of the formation, two risks are identified, namely 1) that excess pressure <br />could fracture the formation and 2) the cemented well bore formation bond could be <br />compromised if heated above 450F during the pilot test. The mitigation for excess pressure <br />is to operate the retort at a maximum pressure of 1000 psi, much lower than the expected <br />fracture gradient of 1900 psi. As an additional mitigation, we also propose to cant' out a <br />formation integrity test when drilling out the 9 518" shoe to 1100 psi to ensure no fracturing <br />can occur during operations. The mitigation for excess wellbore formation temperature is to <br />reduce the heat getting to the formation by utilizing an insulating annulus between the 9 <br />5/8"casing and the 7° tubing and also, if necessary, injecting cooler reflux oil to cool the well <br />- --- ---during the operation - - - -- - --- - --- - - - - - <br />As far as monitoring is concerned, we have designed two main systems into our pilot, <br />namely, 1) active temperature and pressure measurements and, 2) imaging of the retort <br />using four tomography wells around the retorted area. We will measure and report retort, <br />production, and injection temperatures and pressures. The cemented wellbore will be <br />temperature monitored outside the 9 5/8° casing across the aquifers. The tomography wells <br />will be used to image the development of the retort, using techniques such as: cross well <br />seismic, electrical resistivity, micro-seismic, and sonic scanner. <br />Finally, in case of loss of retort or well integrity or well bore over heating that threatens the <br />aquifer water quality an emergency procedure will be activated to cool the retort and well <br />system by terminating the heat input and shutting in the well. <br />We trust that the above explanation of our methodology to protect the aquifers assists you in <br />reviewing our application and granting us the required permit <br />Sincerely, <br />American Shale Oil, LLC <br />Roger L. Day <br />VP of Operations <br />Copy: (Without Enclosure) <br />Paul Daggett - Bureau of Land Management <br />Travis Marshall - Colorado Division of Reclamation, Mining and Safety <br />110 East 3'd Sua:L Suite 201 P.O. Box 1470- Rifle CO 81650 970-62511324 phone 970-625-4318 facsimile