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With a $3.5 billion investment riding on the temperament of a nervous nation, Shell Oil is going to great lengths to convince the Obama administration it can safely drill in the Arctic Ocean. \

Asked to more fully explain its intended programs and safety measures, late Monday the company released its five-page response (PDF) to the U.S. Department of the Interior and the Minerals Management Service, the federal agency with the power to approve or deny new offshore drilling permits. In the wake of the ongoing oil spill in the Gulf of Mexico, which began with the sinking of the Deepwater Horizon on April 20, President Obama ordered a moratorium on any new drilling pending a 30-day review. With plans to explore underwater prospects in the Beaufort and Chukchi seas this summer, Shell is pressing on in hopes the drilling fleet it's mobilizing won't become idle, hit, potentially, with a more permanent "no new drilling" mandate by federal regulators too leery from the Gulf of Mexico spill to risk another disaster.

For now, Shell is moving forward as though the answer will be "yes" and its drilling permit authorized, and is making the case to the Interior Department that while it's incorporating lessons learned from the Gulf spill into its plans, drilling in Alaska is not the same as drilling down south.

Under greater depths of water and drilling to deeper petroleum fields, operations in the Gulf are "technically more complex" and subject to two to three times more pressure, wrote Shell President Marvin Odum. Alaska's shallower depths will allow Shell to more quickly detect and respond to spills, and its arctic conditions can actually "aid oil spill response," as "differences in evaporation rates, viscosity and weathering provide greater opportunities to recover oil."

MMS inspectors will be on board the drill ship 24/7, and, in the event of an incident, Shell will be fully accountable, Odum wrote.

Odum also described how Shell thoroughly tests its blowout preventers, and noted that the one for use this summer will undergo a final test in Dutch Harbor before installation. The letter goes on to discuss a wide range of safety considerations and strategies for preventing spills and responding to them should they occur.

Shell has also added new safety measures to its drill plan as a result of the spill in the Gulf. It's taking steps to reduce "kicks" -- an unexpected high pressure surge to the surface. It will test its blowout preventers weekly instead of every other week and ensure that they can be activated from two locations by remote underwater vehicles, and the company is considering adding a second set of "shear rams." It will also have on hand a prefabricated containment dome for use in the event of a spill, as well as be prepared to apply underwater dispersants.

Odum closed by saying he has "complete confidence in (Shell's) ability to execute the 2010 Chukchi Sea and Beaufort Sea exploration plans in a safe and environmentally responsible manner."

And he ends on a note of optimism:

"We look forward to receiving your final authorizations to proceed with our 2010 exploration plans."