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<br />714 1M,SS-S <br />American Shale Oil, LLC <br />110 East P Street, Suite 201 <br />P.O. Box 1470 <br />Rifle, CO 81650 <br />Phone: 970-625-4324 <br />Fax: 970-625-4318 <br />March 15, 2011 <br />REcEiaE? <br />Mr. Greg Johnson <br />Colorado Division of Oil and Public Safety MAR 18 2011 <br />633 17th Street, Suite 500 OFFICE JUNG, Denver, Colorado 80202-3610 - T plB?? ?Ay <br />RE: Opinion Concerning Aboveground Storage Tanks ? <br />Dear Mr. Johnson: <br />American Shale Oil, LLC (AMSO) is requesting your opinion whether storage tanks used to <br />store flammable and combustible liquids at its oil shale mining facility are considered <br />"aboveground storage tanks" per the definition specified at C.R.S. 8-20.5-101(2) and therefore, <br />subject to regulation under 7 C.C.R 1101-14. It is our interpretation of the regulations that our <br />operation is not subject to regulation under 7 C.C.R. 1101-14. As set forth at C.R.S. 8-20.5- <br />101(2): <br />(b) "Aboveground storage tank" does not include: <br />RECEIVED <br />(V 1) Aboveground storage tanks associated with crude oil production, storag?, f1AR Z I Z011 <br />ivisipn of Rsclsmauon <br />and gathering; <br />Mining a Safety , <br />(IQ Aboveground storage tanks used to store flammable and combustible liquids <br />at mining facilities and construction and earthmoving projects, including gravel <br />pits, quarries, and borrow pits where, in the opinion of the director of the division <br />of oil and public safety, tight control by the owner or contractor and isolation <br />from other structures make it unnecessary to meet the requirements of this article. <br />The tanks will be used in support of oil shale research and testing operations at AMSO's oil <br />shale research, development, and demonstration (RD&D) project site which are being <br />implemented under the jurisdiction of the Colorado Division of Reclamation, Mining, and Safety <br />(DRMS). The site is located on remote federal land in Rio Blanco County, Colorado (see <br />attached Exhibit A.1), and operations are being conducted under a lease agreement with the U.S. <br />Bureau of Land Management (BLM). The project is being conducted in accordance with a <br />DRMS-approved Notice of Intent to Conduct Prospecting Operations for Hard Rock/Metal <br />Mines, an approved Plan of Development following lease requirements specified by the BLM, <br />and the requirements specified in an Underground Injection Control Permit issued by the U.S.