2011-02-16_REVISION - P2008046

• Permit No: P2008046
• IBM Index Class Name: REVISION
• Doc Date: 2/16/2011
• Doc Name: NOI- notice of deficiency ‎(MD-05)‎
• From: DRMS
• To: American Shale Oil, LLC
• Type & Sequence: MD5
• Email Name: THM
• Media Type: D
• Archive: No

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STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
February 16, 2011 J
RECOV"
FEB 18 2011
Division of Reclamation,
M-.rt.ng
COLORADO
D I V I S ION OF
RECLAMATION
MINING
SAFETY
John W. Hickenlooper
Governor
Mike King
Executive Director
Mr. Roger Day Loretta E. Pineda
American Shale Oil, LLC Director
P.O. Box 1470
Rifle, CO 81650
Re: American Shale il, LLC. RD &D Project, Notice of Intent (NOI) P-2008-046, Notice of
Deficiency, MD-0.
Dear Mr. Day,
The Division of Reclamation, Mining and Safety (DRMS) has reviewed the request for a modification to
the Notice of Intent to Conduct Prospecting Operations (NOI), No. P-2008-046, submitted by American
Shale Oil, LLC on January 31, 2011. The modification cannot be approved until the following issues
are adequately addressed.
Please review the enclosed final reclamation cost estimate carefully and notify staff immediately
if any errors are observed. The reclamation estimate is significantly higher than previously
accepted values due to the increase of surface disturbance and the addition of five (5) years of
post operational groundwater monitoring. The increased post operational monitoring is based off
the previously accepted cost for one (1) year of post operational monitoring. The basis for the
monitoring increase is based on Rule 3.1.3(2) which states that all reclamation shall be carried
to completion by the operator with all reasonable diligence, and each phase of reclamation shall
be completed within five (5) years from the date the operator informs the board or office that
such phase has commenced... and Rule 3.1.7(8) which states Release of Reclamation Liability:
An operator shall demonstrate, to the satisfaction of the office, that reclamation has been
achieved so that existing and reasonably potential future uses of groundwater are protected.
2. Per Rule 5.3.3, upon filing the NOI the prospector shall provide financial warranty in order for
the NOI to be considered filed. In this case the financial warranty amount determined by the
office based on the projected costs of reclamation is $699.361.00.
3. An error of the disturbed area was discovered in Section III Project Description on Page 5. The
disturbance is stated to be 12.4 acres. The actual disturbance related to the project is actually
13.6 acres. The disturbance calculation error is caused by the omission of the MWP1 Pad which
accounts for 1.2 acres of disturbance. Please submit a corrected acreage breakdown.
Office of Office of
Mined Land Reclamation Denver Grand Junction • Durango Active and Inactive Mines