2011-09-08_GENERAL DOCUMENTS - P2008046

• Permit No: P2008046
• IBM Index Class Name: GENERAL DOCUMENTS
• Doc Date: 9/8/2011
• Doc Name: Request for Modification
• From: DRMS
• To: American Shale Oil, LLC
• Permit Index Doc Type: General Correspondence
• Email Name: THM
• Email Name: SSS
• Media Type: D
• Archive: No

DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
September 8, 2011 V
Mr. Roger Day
American Shale Oil, LLC
P.O. Box 1470
Rifle, CO 81650
Dear Mr. Day,
Sincerely,
Travis Marshall
Environmental Protection Specialist
Mined Land Reclamation
STATE OF COLORADO
RECE ED
SEP 12 2011
vivisiGA0i Redd rt Sian,
Re: American Shale Oil, LLC, Notice of Intent (NOI) File No. P- 2008 -046, Request for
Modification.
COLORADO
D I V I S I O N O F
RECLAMATION
MINING
SAFETY
John W. Hickenlooper
Governor
Mike King
Executive Director
Loretta E. Pineda
Director
On August 4th, 2011 the Division of Reclamation, Mining and Safety (Division) received the
American Shale Oil, LLC — Casing Cement Operations & Evaluations report. Based on the
results of the report, wells TM -1, TM -2, TM -3, TM -4, TM -5 and TM -6 were not completed per
the requirements approved in the NOI. The tests conducted and indications stated in the report
revealed that the cement ratings for the tomography wells have a poor rating from the top of the
scanned column to depths varying between 258' below ground surface (bgs) to 696' bgs. Due to
the non - compliance in the completion of the tomography wells American Shale Oil, LLC
(AMSO) must submit a modification to the NOI that specifies how AMSO intends to address the
non - compliance of these wells and ensure that the Uinta, A- Groove, and other aquifers are
adequately isolated to prevent comingling and that adequate aquifer protection has been
established. It is the Division's understanding that AMSO will direct a secondary contractor to
perform additional cement logging in the tomography wells that have not had equipment installed,
to acquire more information about the quality of the cement job. Furthermore, as an added
measure of assurance, AMSO will contract to have all of the test results evaluated by a third party
expert in the field.
AMSO must submit the above required NOI modification within 60 days of the date of this letter.
Additionally, AMSO must secure Division approval of the modification and the Division's
written concurrence that any additional measures taken to isolate and protect the groundwater
aquifers is adequate, prior to initiating the heating phase of the NOI operation.
If you need additional information, please contact me at the Division of Reclamation, Mining and
Safety, Grand Junction Field Office, 101 S. 3rd St., Suite 301, Grand Junction, Colorado 81501,
telephone no. 970.241.2042.
Office of Office of
Denver • Grand Junction • Durango Active and Inactive Mines