Microsoft Word - Plan of Operations2.8.06.doc

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Table of Contents

1.0

INTRODUCTION AND BACKGROUND...................................................................... 1-1

2.0

PROJECT DESCRIPTION .............................................................................................. 2-1

2.1

General Technology Description ................................................................................. 2-2

3.0

GEOLOGY AND RESOURCE ........................................................................................ 3-1

3.1 Introduction.................................................................................................................. 3-1
3.2

Topography and Surface Drainage .............................................................................. 3-1

3.3 Structure....................................................................................................................... 3-1
3.4 Stratigraphy.................................................................................................................. 3-2
3.5

Oil Shale Resource....................................................................................................... 3-4

3.6 Hydrologic

Setting....................................................................................................... 3-4

4.0

OPERATING PLAN ......................................................................................................... 4-1

4.1

General Project Overview and Summary .................................................................... 4-1

4.2

General Site Development and Preparation................................................................. 4-3

4.3

In-situ Conversion Process .......................................................................................... 4-8

4.4

Recovery Efficiency and Energy Balance ................................................................. 4-21

4.5 Water

Management.................................................................................................... 4-25

4.6 By-products

and

Wastes ............................................................................................ 4-28

4.7 Monitoring

and

Response .......................................................................................... 4-29

5.0

RECLAMATION PLAN................................................................................................... 5-1

5.1

Reclamation of the ICP............................................................................................ 5-1

6.0

ENVIRONMENTAL SETTING AND BASELINE STUDIES ..................................... 6-1

6.1 Vegetation.................................................................................................................... 6-1
6.2 Soils.............................................................................................................................. 6-1
6.3 Wildlife ........................................................................................................................ 6-2
6.4

Cultural and Paleontology Resources .......................................................................... 6-3

6.5 Climate......................................................................................................................... 6-4
6.6 Visual ........................................................................................................................... 6-5
6.7 Hydrology .................................................................................................................... 6-5

7.0

ENVIRONMENTAL PROTECTION PLAN ................................................................. 7-1

7.1

Surface Water Management Plan................................................................................. 7-1

7.2 Ground

Water

Protection ............................................................................................. 7-1

7.3 Air

Quality ................................................................................................................... 7-1

7.4

Fish and Wildlife.......................................................................................................... 7-1

7.5

Soil and Vegetation...................................................................................................... 7-2

7.6 Health

and

Safety......................................................................................................... 7-2

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8.0

EXHIBITS .......................................................................................................................... 8-1

A – Regional Location Map
B – General Location Plan
C – Surface Ownership and Existing Facilities
D – Regional Geology Map
E – R&D Tract Base Map
F – Stratigraphic Column
G – Geology Map
H – Type Log
I – Structural Cross Section A-A’
J – Plot Plan
K – Cross Section of Facility
L – Drill Hole Schematic
M – Drainage Control Plan
N – Typical Hole Completion
O – Surface Water Hydrology Map
P – Ground Water Hydrology Map
Q - Reclamation Plan
R - Environmental Study Area

List of Figures

Figure 2.1 ICP Process................................................................................................................. 2-3
Figure 3.1 Potentiometric Surface for the “Upper Aquifer”........................................................ 3-7
Figure 3.2 Potentiometric Surface for the “Lower Aquifer” ....................................................... 3-8
Figure 3.3 OST Pad- Stratigraphic and Hydrostratigraphic Relationship ................................. 3-10
Figure 4.1 Diagram of OST ICP .................................................................................................. 4-2
Figure 4.2 Typical Access Road Design...................................................................................... 4-4
Figure 4.3 Schematic of Refrigerant Flow................................................................................. 4-10
Figure 4.4 Freeze Well............................................................................................................... 4-11
Figure 4.5 Photograph of Field Piping Network........................................................................ 4-16
Figure 4.6 Processing Block Flow Diagram .............................................................................. 4-17
Figure 4.7 Processing Water Management ................................................................................ 4-26
Figure 4.8 Reclamation Water ................................................................................................... 4-27
Figure 4.9 Dewatering and Injection Water Management......................................................... 4-28
Figure 5.1 OST Project Schedule................................................................................................. 5-2

List of Tables

Table 4.1 Equipment List............................................................................................................. 4-6
Table 4.2 Inventory of Drilling Fluid Additives for use by Shell and its Contractors ................ 4-9
Table 4.3 OST Surface Water Monitoring Locations................................................................ 4-29
Table 4.4 Surface Water Sampling Parameters ......................................................................... 4-30

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1.0

INTRODUCTION AND BACKGROUND

This Plan of Operations (Plan) has been developed by Shell Frontier Oil and Gas Inc. (Shell) in
order to develop a 160-acre parcel for the purpose of oil shale research and development (R&D).
Shell Frontier Oil and Gas Inc. is located at 4582 South Ulster Parkway, Suite 1340, Denver,
Colorado 80237, (303) 305-4016. The Plan provides substantial background information
generated by Shell over the past several years, and outlines how the R&D project will be
organized and implemented. The Bureau of Land Management (BLM) owns both the mineral
and surface land of the 160-acre R&D site. The operating company that would operate and
manage on behalf of Shell would be Shell Exploration and Production Company (Shell). Shell
Exploration and Production Company is located at 777 Walker St., Houston, Texas 77002.
Through diligent development of the R&D technology, Shell anticipates acquiring a commercial
scale lease from the BLM based on the success of its R&D project.

This project, called Shell Oil Shale Test (OST) Project, is located on 160-acres located in Section
1, Township 2 South, Range 99 West, Rio Blanco County, Colorado. The general location of the
R&D site is within the northern part of the Piceance Basin in Rio Blanco County (Exhibit A).
The general area surrounding the R&D site is bounded on the north by the White River, on the
east by the Grand Hogback, on the south by the headwaters of the Roan and Parachute Creeks in
the Roan Plateau, and on the west by the Cathedral Bluffs.

The northern part of the structural basin has been eroded into a topographic basin by the drainage
networks of the Piceance and Yellow Creeks that are tributary to the White River. Land surface
altitudes range from about 5,500 feet in the White River valley to more than 8,000 feet on the
Cathedral Bluffs west of the R&D site. The topography consists of ridges and valleys with local
relief of 200 to 600 feet.

Since 1980 Shell has worked on developing and refining the In-situ Conversion Process (ICP)
technique for oil shale development. The proprietary ICP uses subsurface heating to convert
kerogen contained in oil shale into light hydrocarbons which can be readily processed into ultra-
clean transportation fuels and gas. The ICP is more efficient and environmentally sensitive than
conventional oil shale development.

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2.0 PROJECT

DESCRIPTION

The purpose of the R&D project is to demonstrate the feasibility of a commercial oil shale
development to earn a 5,760-acre lease from the U.S. Government. The project site was selected
based upon the following criteria:

•

The oil shale resource should approximate what is currently considered to be a viable
commercial oil shale resource target. Some of the key parameters include resource
stratigraphic and structural continuity, resource grade, resource thickness, overburden and
nahcolite content.

•

The property is fully owned (minerals and surface) by the U. S. Government and managed by
the BLM, White River Field Office in Meeker, Colorado.

•

The surface water and associated tributary ground water are fully contained in the Yellow
Creek drainage sub-basin of the Piceance Creek Basin.

The proposed project site is a 160-acre federal tract of land in Section 1, Township 2 South,
Range 99 West in Rio Blanco County, Colorado and is shown in Exhibit B. The site is located in
the northern part of the Piceance Basin, approximately 18 aerial miles southeast of Rangely and
32 aerial miles west-southwest of Meeker. The majority of the surrounding area is owned by the
BLM and the Colorado Department of Wildlife. Additionally several large parcels are owned and
controlled by private entities. Land ownership and existing facilities adjacent to the R&D site are
provided on Exhibit C. Existing facilities such as oil and gas wells, mines, and utilities are also
depicted on Exhibit C.

The project will be comprised of 4 major phases:

•

Design and permitting

•

Equipment fabrication and field construction

•

On site heating, producing and operational testing

•

Site reclamation.

Project development will follow after the issuance of all required permits and lease. These
activities will include site preparation including topsoil salvaging and grading, construction of
primary and backup ICP containment systems, construction of heating and producing holes, and
product processing equipment. These will require up to three years to construct. It is expected

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that the project will continue for approximately fifteen years from initiation of operational testing
through final reclamation of the site. Full-scale production of up to 1,000 BOPD is expected
within 18-24 months after initiation of the heating phase. At the completion of this project, the
reclaimed site will either be surrendered and re-conveyed to BLM or incorporated into a
commercial scale oil shale development.

Prior to initiation of any site disturbance Shell will execute an acceptable financial assurance
mechanism with the BLM. Financial assurances include, but are not limited to self bonding,
third-party bonding, letter of credit, or cash escrow.

2.1

General Technology Description

Oil shale deposits are one of the largest unconventional hydrocarbon resources in the world.
Although oil has been produced from oil shale for a long time, earlier technologies to develop oil
from shale were expensive and had significant environmental impacts. Shell has been working
since 1980 on an in-situ technique for developing such deposits that could significantly improve
the product quality, recovery efficiency, energy balance and environmental impact of oil shale
development.

Shell’s proprietary ICP uses subsurface heating to convert kerogen contained in oil shale into
ultra-clean transportation fuels and gas. Shell’s process is more environmentally friendly and
more efficient than previous oil shale efforts.  It recovers the resource without conventional
mining, uses less water, and does not generate large tailing piles. ICP has the potential to make
much deeper, thicker, and richer resources available for development, without the complications
of surface or subsurface mining.

Extensive laboratory and field experiments by Shell has determined the optimum time,
temperature, and pressure for improved product quality. The kerogen is thermally cracked into
smaller hydrocarbon molecules that are slowly upgraded by in situ hydrogenation. Since the
average temperature is limited to the boiling point of diesel, the product is a light condensate
with little bottoms.

The product quality of ICP shale oil is that it flows more readily than from surface early
retorting. ICP petroleum products are lighter and cleaner, requiring less processing to become
finished transportation fuels like gasoline, jet and diesel. ICP’s suitability to a particular
resource is dependent on natural geologic conditions such as depth, thickness, and the presence
of ground water. Figure 2.1 shows a highly simplified diagram describing what ICP is, how it
works, possible hydrocarbon resource targets, and principle products.

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Confidential

In-Situ Conversion Process (ICP)

rsp

tiv

e V

iew

Producer

Heater

High Temperature Causes Long, Horizontal Fractures

Overburden

•

Naphtha

•

Jet

•

Diesel

•

Nat. Gas

•

Hydrogen

•

Chem. Feed

High Value Products

Surface Processing

What is it?

•

Enhancement of natural maturation

of kerogen by

slow

heating

•

Results in:

•

thermal cracking

•

in-situ hydrogenation

•

high sweep vapor phase production

•

high API oil

•

N,S,O content vary with resource

•

Average temperature limited to boiling

point of diesel, i.e. essentially no bottoms

How is it done?

•

Electric resistance heaters

•

Underground conductive

heat transport

To
Market

Figure 2.1 ICP Process

To prevent ground water from flowing into the heated pattern and to contain the ICP products, a
freeze wall is installed first. A series of holes are drilled outside the intended resource target and
a chilled fluid (-45

F) is circulated inside a closed loop piping system. The cold fluid freezes the

nearby rock and ground water and in 6-12 months creates a wall of ice. The freeze wall is
maintained during both the production and reclamation phases of the project.

After the freeze wall is established, producer holes are drilled and used to remove the ground
water trapped inside the wall. Heater holes are drilled and electric heaters are installed to
uniformly heat an otherwise undisturbed hydrocarbon-bearing target to between 550 and 750

for a period of several years. Additional holes are used to monitor hydrology, geomechanics,

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temperatures, pressures, and water levels. These holes are placed in the heated pattern, inside the
freeze wall, and outside the freeze wall.

Oil and gas comes to the surface via the previously installed producer holes and is collected for
further processing using traditional processing techniques.

The process has been granted over 70 US patents covering many aspects of its proprietary ICP
process. An additional 150 US patent applications have been filed. Internationally, patent
applications have been filed in over 30 countries.

Over the past 60 years, a variety of technologies for recovering shale oil from oil shale have been
tested, including mining with surface processing and in-situ technologies.

Conventional surface processing mines the oil shale by surface mining or underground mining
methods, transports the shale to the retort, collects the oil, cools down and finally disposes of the
“spent” shale. The heating phase in a retort is very short and results in a quality of oil that needs
significant processing.

In-situ retorting applies sustained heat to the kerogen while it is still embedded in its natural
geological formation, and then recovers the hydrocarbon fluids using oil field production holes.
Some in-situ processes rely on air or oxygen injection and require that relatively high permeability
exist or be created through fracturing. The target deposit is fractured, air is injected, the deposit is
ignited to heat the formation, and resulting shale oil is moved through natural or man-made
fractures to production holes that transport it to the surface. This type of in situ process suffers
from difficulties in controlling the pyrolysis temperature and the flow of produced oil, resulting in
poor oil and gas quality combined with low oil recovery efficiency because portions of the deposit
are left unheated.

In contrast to previous technologies, ICP has the potential to significantly reduce environmental
impact. ICP involves no surface or underground mining, creates no leftover piles of mine tailings,
generates fewer other unwanted byproducts, and potentially requires less water usage.

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3.0

GEOLOGY AND RESOURCE

3.1 Introduction

The proposed 160-acre R&D tract is located in the northern part of the Piceance Basin in
northwestern Colorado (Exhibit A). This rugged and remote area of Colorado contains the
world’s richest deposits of oil shale. An estimated one trillion barrels of oil shale resource occurs
within the Green River Formation in Colorado. The resource area covers 1,600 square-miles and
is bounded by the Colorado River on the south, the White River on the north, the Douglas Creek
Arch on the west, and the White River Uplift on the east (Exhibit D). The in-place oil shale
resource lying beneath the 160-acre proposed R&D tract is estimated to be 300 million barrels, a
small fraction of the total basin resource.

3.2

Topography and Surface Drainage

The proposed 160-acre R&D tract is located within the Yellow Creek drainage subbasin of the
Piceance Basin (Exhibits A and D). The tract lies along the northeast-trending Wolf Ridge at an
elevation of 6,840 ft in Section 1, Township 2 South, Range 99 West, Rio Blanco County,
Colorado (Exhibit E). The topographic relief surrounding the tract is as much as 200 feet. On
tract the terrain is mild, sloping eight percent northward.

3.3 Structure

The Piceance Basin is a structurally downwarped region of the Colorado Plateau Province. The
basin is surrounded by several uplifts that emerged during the growth of the Rocky Mountains
during the early Tertiary Period (Exhibit D). The Eocene Wasatch, Green River and Uinta
Formations were deposited in a river-lake depositional system during basin development, coeval
with this episode of mountain building. In the northern Piceance Basin, lying between the
Colorado River and White River, the basin is asymmetric to the east and forms a plateau that is
dissected by numerous ridges and valleys. The primary basin axis parallels the Grand Hogback-
Axial Basin Arch structural front. This structural front is defined by large basement thrust faults
and reverse faults that formed during basin development. Additionally, the basin contains several
secondary northwesterly-oriented folds and faults that formed during post-Uinta Formation (late
Eocene or later) time.

Less than two miles to the southwest of the proposed 160-acre R&D tract, the Black Sulfur
Creek Anticline, a secondary fold in the basin, and associated small normal faults are exposed at
the surface (Exhibit E). The anticline plunges gently to the southeast. The surface traces of the
normal faults occur mainly on the eastern side of the fold axis and are sub-parallel to the trace of

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the fold axis. To the northeast of this area the strata dips gently to the northeast and is not known
to be structurally disturbed (Exhibit G). Folds and faults are not evident within the proposed 160-
acre R&D tract.

3.4 Stratigraphy
Overburden

The Uinta Formation and the underlying interfingering tongues of the Uinta and Green River
formations are exposed over much of the northern Piceance Basin. These rocks overlie the
organic-rich oil shale rocks in the Parachute Creek Member of the Green River Formation
(Exhibit F). The Uinta Formation is composed predominantly of fluvial and lacustrine
sandstones and siltstones. The Uinta tongues are of similar lithology but generally are finer-
grained and more thinly bedded. The Green River tongues consist predominantly of interbedded
marlstone and silty marlstone.

The Uinta Formation is exposed at the surface at the proposed R&D tract (Exhibit G). The
projected thickness and depth of these units at the tract are illustrated on Exhibit H. The Uinta
Formation is not known to contain acid-bearing minerals that can be readily leached by surface
water. As a result, surface modification for facilities development should not result in acid-water
issues.

Oil Shale and Marlstone

The Eocene Green River Formation conformably overlies the Wasatch Formation and it
conformably underlies the Uinta Formation in the Piceance Basin (Exhibit F). The Parachute
Creek Member of the Green River Formation contains most of the oil shale resources in the
basin. The lithology of the Parachute Creek Member consists ubiquitously of interbedded oil
shale and marlstone with minor thin beds of siltstone, and volcanic tuff. The lithology of the oil
shale is distinguished from that of marlstone by its quantity of organic matter (kerogen). An oil
shale contains greater than 10 gallons/ton oil yield from Fischer Assay analysis whereas a
marlstone contains less than 10 gallons/ton. The two lithologies form an alternating stratigraphic
succession of stacked organic-rich zones (R zones) composed primarily oil shale, and organic-
lean zones (L zones) composed predominantly of marlstone (Exhibit F and H). The organic-rich
and organic-lean zones are laterally continuous and can be correlated across the Piceance Basin.
The Parachute Creek Member contains the interval ranging from the R-2 zone through the R-8
zone.

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Sodium-bearing Minerals

The Parachute Creek Member thickens toward the basin-center, ranging from 650 feet on the
basin margins to 1,750 feet in the north-central part of the basin. This thickening is largely
attributed to increased deposition and preservation of marlstone, oil shale, and sodium-bearing
minerals including nahcolite, dawsonite, and minor halite. The sodium-bearing minerals are
interbedded, nodular, or disseminated within the oil shale and marlstone. The concentration and
stratigraphic distribution of sodium-bearing minerals decreases rapidly toward the basin margins
as a result of depositional facies and/or dissolution by circulating ground water.

Nahcolite (naturally occurring sodium bicarbonate) was deposited in varying amounts across the
R-2 through R-8 interval during Eocene time. Nahcolite has undergone extensive ground water
leaching in the basin. Nahcolite occurs in the lower part of the Parachute Creek Member, ranging
from the R-2 through L-5 interval in the depositional center of the Piceance Basin (Exhibit F).
This interval is commonly referred to as the Saline Zone. Lying above the Saline Zone is the
Leached Zone where circulating ground water has leached away the nahcolite and halite.
Basinward of the Saline Zone limit the nahcolite-bearing rocks increase in thickness and
nahcolite concentration. The top of the Saline Zone, also known as the dissolution surface, rises
stratigraphically toward the depositional center of the basin. The dissolution surface ranges from
the R-2 zone on the west and climbs stratigraphically to the L-5 zone in the center of the basin. It
represents the lowest stratigraphic level where ground water has leached the nahcolite in the
Parachute Creek Member.

The proposed 160-acre R&D tract straddles the limit of the Saline Zone (Exhibit E, G and I).
Most of the originally deposited nahcolite is believed to have been leached away by circulating
ground water on the tract. The nahcolite-leached rocks above the dissolution surface form
stratified layers with varying degrees of vugular porosity and permeability. They can hold
substantial volumes of ground water, and can be strong potential flow intervals. Some thin
isolated nahcolite-bearing strata may occur within the R-2 through the R-5 zones in the Leached
Zone. These are intervals where ground water has not circulated.

Dawsonite, a mineral consisting of sodium-aluminum carbonate, occurs as small, disseminated
crystals within the marlstone and oil shale. It occurs primarily within the R-2 through R-5
interval of the Parachute Creek Member. Dawsonite is not a soluble mineral in ground water and
as a result it has not been leached. The x-ray diffraction data from the Stake Springs Draw #1
core hole, located one mile southeast of the proposed  160-acre  R&D  tract  indicate  dawsonite
concentrations up to 15 percent by weight in some samples. The average dawsonite
concentration is estimated to be 5 percent by weight across the R-2 through R-5 interval. These

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concentrations are not considered economic for recovery and extraction of alumina from the
dawsonite.

3.5

Oil Shale Resource

The R-7 through R-2 interval of the Parachute Creek Member of the Green River Formation is
the resource interval of interest for oil shale development at the proposed R&D tract. The total
oil-in-place resource is estimated to be 300 million barrels beneath this tract (Exhibit G and
Exhibit I). The following table summarizes some important parameters of the resource target
interval at the site.

Resource Interval

R-7 through R-2 interval, Parachute Creek Member

Surface Elevation

6,840 feet

Resource Elevation

6,040 feet to 5,860 feet above mean sea level

Area

160

acres

Est. OIP Resource

300 million barrels; undiscounted for porosity

Average Overburden Depth

870 feet (depth to top of R-7 Zone)

Average Thickness

1,020 feet

Average Oil Grade

26.5 gallons/ton, Fischer Assay Oil Yield

Nahcolite Content

~0.3 %, visual estimate from core in offset core holes

Dawsonite Content

~5.0 %, estimate from XRD data in offset core holes

Est. Vugular Porosity

4% to 5%, visual estimate from core in offset core holes

Est. Fracture Porosity

<1%, visual estimate from core in offset core holes

Basinward of the proposed 160-acre R&D tract the oil shale zones increase gradually in
thickness and oil grade, resulting in a corresponding increase in oil richness (Exhibit I).
Similarly, nahcolite concentration, dawsonite concentration, and the depth of cover (overburden)
increase basinward.

3.6 Hydrologic

Setting

Ground Water Setting

There have been several testing programs that have been implemented since 2001 that have
provided data on hydrogeologic parameters of the bedrock. Results are detailed in a report

that

have been summarized here. All the hydrologic testing programs were conducted to provide
baseline conditions and characterization of the bedrock ground water flow system for local and
regional assessment including:

Norwest Corporation, Ground Water Hydrology of the Oil Shale Test and Freezer Heater Test Projects and

Vicinity (January 2006), 3-4.

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•

Potentiometric distribution within and between hydrostratigraphic units (based on
equilibrium water level elevation measurements in individual clustered monitoring wells)

•

Transmissivity and average lateral hydraulic conductivity (permeability) of the open interval
in each well

•

Approximate vertical hydraulic conductivity (permeability) of zones between open intervals
of wells

•

Storage coefficient and average storativity of the straddle-packed open interval (at multiple
drillhole packer testing sites only)

•

Geochemical variability and baseline water quality characteristics based on chemical
analyses of water samples collected during testing.

Ground water in the Piceance Creek/Yellow Creek Basin occurs in both near-surface and deep
water-bearing and porous bedrock systems. Near-surface porous hydrogeologic units include the
alluvium along streams and shallow bedrock units that are characterized as relatively permeable.

The rate and quantity of ground water movement primarily depends on the transmissivity (the
product of average hydraulic conductivity and saturated thickness) of the hydrogeologic units
and the hydraulic gradient. Overall, the alluvium of the White River is reported to have the
highest average hydraulic conductivity of any hydrogeologic unit in the resource area

. Where

saturated, alluvium is able to serve either as a source of recharge to the bedrock or as a ground
water discharge point. This type of stream-ground water system is typical of drainages in the
Piceance Basin. The OST project area is located in the upper reaches of the Yellow Creek
drainage basin where alluvium is substantially limited to the major drainage channels and can be
up to 120 feet thick in places. The alluvium near the project area receives recharge from local
bedrock springs and ephemeral surface runoff. The ground water in the alluvium discharges back
to the surface drainage in some areas.

Regional bedrock ground water flows are generally from areas of recharge around the margins of the
Basin towards the major discharge areas in the Piceance Creek and, to a lesser extent, Yellow Creek
valleys. The principal source of ground water recharge in the Piceance Basin has been identified
snowpack meltwater at topographic elevations greater than 7,000 feet

in the Cathedral Bluffs area.

Recharge to bedrock occurs either as direct infiltration, or indirectly via alluvial deposits in the upper

Bureau of Land Management, Craig, Colorado District Office, White River Resource Area, Proposed Resource

Management Plan and Final Environmental Impact Statement (1996).

J.B. Weeks, et al., “Simulated Effects of Oil-Shale Development on the Hydrology of Piceance Basin Colordo”

(U.S. Geological Society Professional Paper), 1pl.

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reaches of the numerous creeks that are tributary to Piceance and Yellow Creeks.

Discharge of ground water is primarily in the form of springs, baseflow to streams, alluvial
underflow, and evapotranspiration. There has been only some ground water pumping in the northern
Piceance Basin that was conducted for nahcolite extraction activities. The lower reaches of Piceance
Creek, and to a much lesser extent the lower reaches of Yellow Creek, are the major ground water
discharge areas

. Spring discharge areas in the lower reaches of both Piceance and Yellow Creeks

appear to be controlled by major fracture systems that allow hydraulic communication with deeper,
more saline ground water

Discharge in the upper reaches of the Piceance Creek and Yellow Creek watersheds is generally in
the form of a limited number of discrete springs. Discharge from springs in the creek channels of
upper tributaries is observed to reinfiltrate into the alluvium and may provide some of the recharge
for other springs further downstream. A large proportion of these tributary spring flows is consumed
by stream channel vegetation before reaching the lower reaches of Piceance and Yellow Creeks.
Ground water has been observed to discharge from the uppermost intervals of the Parachute Creek
Member of the Green River Formation in the lower-elevation drainages some distance up-drainage
of the OST site. Springs that discharge directly from the lower Parachute Creek or underlying
unnamed members of the Green River Formation have not been reported or identified in the vicinity
of the OST site.

Historically, two hydrologic bedrock units (“Upper” and “Lower”) aquifers have been described
as comprising the ground water flow system in the Parachute Creek Member. The original
hydrogeologic system nomenclature was proposed by Coffin and others6 and defined the “Upper
Aquifer” as the more permeable rocks above the Mahogany Zone (primarily L-7 or A-Groove)
and the “Lower Aquifer” as the more permeable rocks below the Mahogany Zone. It should be
noted that the terms “Upper” and “Lower” aquifers come from original U.S. Geological Survey
(USGS) terminology and are not used to describe local conditions associated with the OST
project except for direct reference to historic USGS reports. Regional potentiometric surface
maps for “Upper” and “Lower” bedrock aquifer systems, as conventionally designated by the
USGS, were developed by Robson and Saulnier

and are reproduced in Figures 3.1 and 3.2.

J.B. Weeks, et al,.

S.G. Robson and G.J Saulnier Jr., “Hydrochemistry and Simulated Solute Transport, Piceance Basin, Northwestern

Colorado” (U.S. Geological society Professional Paper1196),.

D.L. Coffin, et al., “Geohydrology of the Piceance Creek Structural Basin between the White and Colorado Rivers,

Northwestern Colorado” (U.S. Geological Survey Hydrologic Investigations Atlas HA-370, 1971).

S.G. Robson and G.J Saulnier Jr.,.

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Figure 3.1 Potentiometric Surface for the “Upper Aquifer”

Dots indicate locations of wells providing information. Project area is located between Stakes Spring Draw and Box
Elder Gulch, the tributary leading into Corral Gulch from the southwest, about on the 6,600 foot elevation

More site specific data have been obtained to generate the potentiometric contours for
intermediate hydrostratigraphic intervals that are located within these two very generalized
groups. These figures detail the local gradients and show minor deviations, but retain the strong
east-northeast gradient that is shown on the regional potentiometric surface maps.

Within and west of the OST project area, available potentiometric head and available water
quality information suggests that the conventional definition of Upper and Lower aquifer does
not apply. The A-Groove, B-Groove, and L-5 water-bearing zones tend to have similar
potentiometric heads. The largest vertical potentiometric head difference actually tends to occur

S.G. Robson and G.J Saulnier Jr.,.

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between the L-5 and L-4 water-bearing zones to the west of the OST area and between the L-4
and the L-3 water-bearing zones at the OST project site. This is consistent with findings at the
nearby C-a tract located to the west of the project site. At the C-a Tract the “Upper Aquifer”
generally includes both the A-Groove and B-Groove with a lower limit as deep as the top of the
L-5 zone. The “Lower Aquifer” lies between the top of the L-4 and the top of the Garden Gulch
Member (L1)

Figure 3.2 Potentiometric Surface for the “Lower Aquifer”

S.G. Robson and G.J Saulnier Jr.,.

S.G. Robson and G.J Saulnier Jr., 65.

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The Garden Gulch and Douglas Creek members of the Green River Formation are characterized
as an impermeable base to the Parachute Creek Member ground water system

. Thus there is

little suspected interaction between the Parachute Creek Formation and possible aquifers in the
Wasatch Formation or deeper geologic units.

Ground water flow in the Parachute Creek Member occurs through natural fractures, solution
cavities and “vugs.” Lean zones within the member tend to fracture more readily than do rich
zones, and are generally more permeable and typically coincide with zones of relatively high
water-production from boreholes. However, this is a very general relationship and does not hold
everywhere because some of the layers of richer oil shale also are fractured and permeable.
Several permeable zones have been identified within stratigraphically defined “rich” zones, and
low permeability zones can exist within stratigraphic “lean” zones. In most cases where
hydraulic testing has been conducted, it indicates that the rocks above and below the Parachute
Creek Member have lower permeability.

The geologic stratigraphic section determined from a drill hole logged within the OST project
area is provided in Exhibit F. As noted earlier, the hydrostratigraphic intervals of the section
differ in vertical location from the stratigraphic unit intervals (Figure 3.3). Part of the early OST
project delineation was directed toward site-specific determination of the hydrostratigraphic
units. The A-Groove and B-Groove are permeable lean zones lying above and below the
Mahogany Zone (R-7) respectively. The A-Groove and overlying R-8 zone are the most
transmissive zones upgradient of OST. In the vicinity of OST, the A-Groove and B-Groove
zones have high transmissivity; the L-5 and L-4 zones moderate to low transmissivity; and the L-
3, R-3, and L-2 zones have the highest transmissivity. The R-6, R-5, and R-4 zones exhibit low
transmissivity and act as seals between the more permeable zones.

S.G. Robson and G.J Saulnier Jr.,.

100

150

200

250

300

350

400

450

500

550

600

650

700

750

800

850

900

950

1000

1050

1100

1150

1200

1250

1300

1350

1400

1450

1500

1550

1600

1650

1700

1750

1800

1850

1900

6850

6800

6750

6700

6650

6600

6550

6500

6450

6400

6350

6300

6250

6200

6150

6100

6050

6000

5950

5900

5850

5800

5750

5700

5650

5600

5550

5500

5450

5400

5350

5300

5250

5200

5150

5100

5050

5000

Depth, ft.

Stratigraphy

Seals and Water Bearing Intervals

Elevation, ft.

depth, ft (elevation, ft)

400 (6458) estimated

753 (6105)

813 (6043)

901 (5957)

967 (5891)

1096 (5762)

1136 (5722)

1263 (5595)

1303 (5555)

1655 (5203)

1695 (5163)

1814 (5044)

1889 (4969)

Uinta

Uinta
Transition

R-8 Zone

A-Grv

R-7 Zone

B-Grv

R-6 Zone

L-5 Zone

R-5 Zone

L-4 Zone

R-4 Zone

L-3 Zone

R-3 Zone

L-2 Zone

R-2 Zone

400 (6458) estimated

753 (6105)

875 (5983)
891 (5967)

1036 (5822)
1053 (5805)

1213 (5645)

1293 (5565)

1476 (5382)

1519 (5339)

1678 (5180)

1714 (5144)

1799 (5059)

1827 (5031)

1889 (4969)

DS 1881 (4977)

Uinta Seal

UT Water Bearing Interval

R-8 Seal

A-Grv Water Bearing Interval

R-7 Seal

B-Grv Water Bearing Interval

R-6 Seal

L-5 Water Bearing Interval

R-5 Seal

L-4 Water Bearing Interval

R-4 Seal

L-3 Water Bearing Interval

L-2/R-2 Seal

Figure 1.3 OST Pad - Stratigraphic and Hydrostratigraphic Relationship

Figure 3.3 OST Pad- Stratigraphic and Hydrostratigraphic Relationship

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4.0 OPERATING

PLAN

4.1

General Project Overview and Summary

The Oil Shale Test Project (OST) is a research, development, and demonstration project
designed to demonstrate the In Situ Conversion Process (ICP), gather additional operating data
and information, and allow testing of components and systems to demonstrate the commercial
feasibility of recovering hydrocarbons from oil shale. This plan details the construction,
operation, and reclamation of the OST and the supporting facilities.

The ICP is an in situ process using electric heaters to heat the oil shale in place. The heating
process pyrolyzes the organic matter in the oil shale and converts this matter into oil and
hydrocarbon gas. The oil and gas are then removed from the ground using conventional oil field
pumping and extraction technology and processed using conventional oil and gas processing.
The recovery is conducted within a contained area to allow recovery of the hydrocarbons while
excluding ground water flow through the oil production area. Containment is provided in a
freeze wall containment area consisting of a freeze wall system and low permeability barrier
above and below the oil shale resource zone. These are described below.

Since the ICP for the OST is planned for use in areas below the ground water table, a freeze wall
containment area is created to isolate the ICP from the surrounding ground water. Freezing of the
in situ ground water and associated rock matrix creates a containment barrier that prevents
migration of fluids into or out of the ICP area. The freeze wall is constructed by drilling closely
spaced holes outside the intended oil shale resource target zone and circulating chilled refrigerant
through closed loop piping in each freeze wall hole. Through heat exchange with the surrounding
rock matrix, the refrigerant returns to the surface warmer than its inflow temperature and the
surrounding rock and associated pore and fracture water is cooled and frozen. This frozen barrier
is formed along the entire depth of the freeze hole and continues to grow and thicken until the
area between freeze holes is frozen, forming a continuous frozen wall-like barrier that extends
through the resource zone and into the impermeable layer at the bottom, thus forming a
containment area that confines the ICP. The freeze wall containment area is maintained through
heating and product recovery as well as during ground water reclamation.

Once the freeze wall is established, a series of dewatering holes are drilled in the interior of the
freeze wall containment area to allow recovery of the hydrocarbon products. Initially these ten
holes will be used to remove ground water inside the freeze wall containment area prior to
heating. The holes will later be converted to producer holes that will remove the hydrocarbon
products. Water from dewatering the freeze wall containment area will be re-injected outside the

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freeze wall into the appropriate water-bearing zones so that existing water quality is not
impacted. Dewatering and reinjection flow rates will be monitored to allow calculation of the
amount of water taken from the containment area. Removal of the ground water prior to heating
will prevent mixing of the hydrocarbons and ground water. Dewatering will not result in removal
of all of the ground water within the containment area as some pore water cannot be removed
through pumping during dewatering.

A series of heater holes are also drilled within the freeze wall containment area. Heaters are
installed in these holes to allow heating of the resource interval. The heater holes are placed such
that an unheated zone of approximately 125 feet is maintained between the freeze wall barrier
and the heated zone so that the freeze wall is not impacted by heating. The heaters raise the
temperature of the oil shale and initiate pyrolysis, releasing hydrocarbon products that are then
removed using the production holes.

Products from the pyrolyzed zone are piped to an on-site processing facility, where processing
separates the oil, gas, and water. Oil is processed to remove impurities, then shipped off site to
existing refineries for refining. Gas from the production holes is also treated and used to
supplement energy needs at the site or incinerated as quantities are not sufficient to justify
facilities necessary for commercial transportation and sale. Sulfur, produced as a product during
processing, is transported off-site as a marketable product. Figure 4.1 shows a simplified diagram
describing the steps included in the OST ICP.

After removal of the recoverable product from the oil shale
deposit, the area within the freeze wall containment area
contains residual pyrolysis products. These are removed
through rinsing prior to allowing the freeze wall barrier to
thaw. The water used for rinsing is treated in an on-site
ground water reclamation treatment plant, then recycled as
rinse water. Waste from the ground water reclamation
treatment plant is hauled off site. Reject brine solution from
the ground water reclamation treatment plant is disposed in
the evaporation pond. When the area is sufficiently rinsed
and the collected rinse water meets appropriate quality, the
freeze wall barrier is then allowed to thaw.

Figure 4.1 Diagram of OST ICP

Site Preparation And

Drilling

Freeze Wall

Establishment

Heating and

Production

Processing

Oil Shipped Offsite

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As a part of reclamation, the wells and holes not needed for monitoring are plugged and
abandoned in accordance with requirements of the Colorado Office of the State Engineer.
Facilities will be demolished and removed and the site will be regraded and revegetated. The
paved access road will also be reclaimed, leaving a dirt road access route. The reclamation plan
(Section 5) provides details on reclamation of the ICP and of the site disturbance.

Support facilities include a site access road; construction and drilling support consisting of lay
down yards, storage units and office trailers; portable pilot test plants, process control building,
change house, utilities, warehouse, shop/ maintenance facilities, laboratory, and other facilities
necessary to support the OST Project. Potable water will be trucked to the site and stored for use
in the on site potable water system. The following sections contain detailed information on the
various process components associated with the OST facility.

4.2

General Site Development and Preparation

Initial construction activities include development of the site access road and fencing of the
permit area. The present access to the OST site is from County Road (CR) 5 to CR 24 to CR 91
to an existing two-track road (see Exhibit C). This two-track road was originally constructed to
access several ground water hydrology monitoring well sites. The access road will be extended
to the OST site and expanded to a running width of approximately 24 feet to allow heavy
equipment travel in two directions. The access road will be paved with asphalt for the 24-foot
width and include appropriate ditches and culverts to maintain drainage control. Soils salvaged
during the road construction will be stored in berms located on either side of the road. Figure 4.2
provides additional information on the design of the access road. Access to the OST site from the
road will be restricted through an entry gate.

The OST project, excluding the access road, will be fenced with a combination barbed/smooth
wire fence with the top wire being smooth. A 12-foot wide fire lane will be constructed along the
permit boundary fence. Signs reading “Do Not Enter” will be posted at points of logical entrance
to the facility, such as roads or trails, to redirect unauthorized personnel. Eight-foot high chain
link fencing will be provided around lined ponds (storm water pond, process water pond, and
evaporation pond) when these ponds are constructed.

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Surface Drainage Controls

A surface water drainage collection and conveyance system will be established to manage
drainage throughout the site. The surface drainage control system along with the site grading will
route storm water flows from the disturbed areas into a storm water pond prior to discharge to
the existing surface drainage system. The surface drainage system consists of ditches, storm
sewers, culverts, curbs, and paving. Ditches will be lined with riprap or other material where
necessary to assure stability. The storm water pond has been designed with a retention capacity
of approximate 15.3 acre-feet and will be constructed near the northwest corner of the property.
The pond has been designed to retain the runoff and sediment from a 50-year, 24-hour storm
event (2.5 inches). A conservative runoff factor of 0.9 was used, assuming 90 percent of the
precipitation is directed into surface water control structures. The storm water pond will be lined
with a single synthetic liner. The liner is not needed for storm water control, hence the pond may
be constructed without the liner for use in collecting sediment during construction activities and
the liner would be installed at a later date. Although not anticipated to be needed, the pond will
be lined to provide the potential for additional lined containment should such containment be
needed in the future. Exhibit M shows the drainage control plan.

Construction storm water drainage will be managed through a construction Storm Water
Management Plan and the use of accepted Best Management Practices (BMP), in accordance
with a construction storm water permit. During construction and during operations areas of light
disturbance that do not report to the storm water pond will be managed using BMPs. Erosion
control measures will include stabilization of exposed soils and protection of steep slopes.
Exposed soils will be stabilized by mulching, seeding, soil roughening, or chemical stabilization.
Steep slopes will be protected by use of geotextiles, temporary slope drains, mulch, or seeding.
Sediment controls may include sediment basins rock dams, sediment filters such as filter cloth,
hay bales, erosion blankets, temporary seeding.

Site Preparation

The OST site will be terraced to provide five levels (support facilities, production, processing,
storage tanks, and shipping). Exhibit J is a plot plan that shows the locations for all facilities at
OST. Exhibit K contains several cross sections through the OST site showing the operating
levels and associated facilities.

The support facilities level will contain the warehouse, shop building, laboratory, potable water
tank and delivery system, and security. The production level will contain the freeze wall, heaters,
production gathering system, and water reclamation facility. The process level will contain the
process building, sulfur loading facility, refrigeration unit, refrigerant unloading facility, utility

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buildings, and electrical substations. The storage tank level contains tank storage and associated
containment for the Untreated Synthetic Condensate (USC) and storage for process
watertreatment feed and effluent. The shipping level contains the process water treatment plant,
product storage, truck loading and storm water pond. The process water pond and evaporation
pond will be located northeast of the terraced areas. A partial list of equipment needed for the
project is shown on Table 4.1.

Table 4.1 Equipment List

Air Blowers

Granular Activated Carbon
Beds

Scrapers

Ammonia Circulation Pumps

H2S Stripper

Separator

Ammonia Stripper
Accumulator

H2S Stripper Accumulator

Skimmings Concentrator

Ammonia Stripper Condensers H2S Stripper Condenser

Slop Oil Equalization Tank
and Pumps

Ammonia Strippers

H2S Stripper Inlet Preheat

Slops Pumps

Backhoes High

Pressure Nitrogen

Storage Package

Solids Separation Clarifier

Backwash water Pumps

Influent Transfer Pumps

Solvent Stripper

Bio-solids Blower

Instrument Air package

Sour Water Stripper Cooler

Bio-solids Pump

Lean Sulfinol Heaters Spent

Carbon Feed Tanks

Biotreater Feed Cooler

Lo-cat Absorber

SRC Pumps

Biotreater Pumps

Lo-cat Oxidizer Vessel

Stabilizer Reboilers

Boiler Packages

Lo-cat Slurry Centriguge Stand-by

Generator

Bulldozers Lo-cat

solution

Recirculation

Tank

Stripper Effluent Coolers

Carbon Regeneration Furnace

MDEA Carbon Beds

Stripper Feed Pumps

Clarifier Sludge Transfer
Pumps

MDEA Cooler

Sulfinol Pumps

Coalescing Filter

MDEA Exchanges

Sulfinol Reboilers

Combustion Products
Accumulator

MDEA Pumps

Sulfur Pit

Combustion Products
Condenser

Membrane Bio-reactor Unit Sulfur

Product

Tank

Concrete Trucks

Nitrogen Storage and
Vaporizer

Sulfur recovery unit Reaction
Furnace

Condensate Pots

NO2 Gas Absorber

Sulfur Seal Pots

Condensate Pumps

NO2 Gas Compressor Sulfur

Slurry

Pumps

Converter Heaters

NO2 Gas Condenser

Sump Pumps

Converters

NO2 Gas Recycle Pumps

Supply Trucks

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Deaerator Packages

Oil/Water Separators SWS

Overhead Accumulator

Deep bed Nutshell Filters

Product Pumps

SWS Pumps

Discharge Coolers

Product Tanks

SWS Reboilers

Dissolved Air Flotation Unit

Quench Tank

SWS Strainers

Drills

Quench Water System

Thickener and Pumps

Equalization Tanks and Pumps Recirculation Pumps

Utility Vehicles

Filter Press

Refrigeration Units

Vapor Catalytic Combustor

Flare Knock Out Pumps

Regeneration Carbon Storage
Tanks

Virgin Carbon Make-up Silo

Flare Packages

Reverse osmosis Unit

Water Heaters

Fuel Trucks

Sanitary Septic System

Water Pumps

Gas Burners

Scot Carbon Filters

Water Storage Tanks

Gas Compressors

Scot Pumps

Water Trucks

Gas Heaters

Scot Reflux Accumulator

Wet Well/Surge Tank

Glycol Chillers

Scot Regenerator

Prior to site preparation, the boundaries of the 160-acre site lease will be marked. The storm
water pond will be constructed, clean water diversion ditches installed, and BMPs will be
implemented. Larger trees will be cut and made available for firewood through a commercial
operator. Stumps will be disposed of by burning on site (with the appropriate burn permits) or by
hauling off site. Stumps may also be buried on site. Remaining vegetation will be cut and
chipped with chips left on the ground to be incorporated into the salvaged soil. Approximately 12
inches of soil will be segregated, removed and deposited in three designated soil storage areas
(Exhibit J). In areas where 12 inches of soil is not available for salvage, reasonable available soil
material will be removed, with a targeted minimum of six inches removed in any location, where
available. This material may not all be soil by strict definition, but will support vegetation and
hence be suitable for plant growth medium. The soil stockpiles, capable of storing approximately
200,000 cubic yards of material will disturb approximately 10 acres. The piles will be
approximately 12 to 15 feet in height. Soil stockpiles will be graded so that outslopes do not
exceed 2 Horizontal to 1 Vertical (2H:1V), unless the angle of repose is shallower. The soil
stockpiles will be seeded with the BLM approved grass seed mix to minimize erosion and
associated loss of soil. Soil stockpiles will also be covered with an erosion control netting to
further minimize erosion and promote growth.

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4.3

In-situ Conversion Process

Ground freezing as a means of containment was introduced in the 1800s to temporarily
strengthen soils and serve as a barrier to ground water flow. Ground freezing continues to be
applied in civil and geotechnical engineering to exclude water from areas being excavated; to
seal tunnels, mine shafts, or other subsurface structures against flooding from ground water; and
to enclose and/or consolidate hazardous or radioactive contaminants during remediation or
reclamation operations. The containment system for the OST will consist of a series of drill holes
in a close pattern (Exhibit L). Refrigerant will be circulated through the holes in a closed circuit
to create a barrier of frozen water in a rock matrix.

The construction of the freeze wall containment area for the OST will allow heating of oil shale
to recover products while preventing mixing of products with the ground water system. A freeze
wall will be established for the depth of the freeze holes and will encircle the resource target
zone creating an enclosed freeze wall containment area. The resource target zone is a carefully
selected portion of the oil shale resource. The top and bottom of the resource target zone are low
permeability layers that will prevent movement of converted hydrocarbons in a vertical direction.
The freeze wall containment area provides lateral containment. The freeze wall will act to
prevent liquid movement into or out of the containment area, separating the ground water system
from the ICP products. The freeze wall containment area will be maintained and monitored
throughout the heating, recovery, and the ground water reclamation phases of the operation.
Since the freeze wall will take an extended period of time to thaw, the freeze wall refrigerant
circulation may be stopped prior to final flushing if it can be demonstrated that the containment
area is sufficiently rinsed and collected rinse water meets appropriate quality.

Freeze Wall Construction

Upon completion of site preparation, approximately 157 drill holes will be drilled approximately
8 feet apart. The freeze holes will be drilled to a depth of approximately 1,650 feet or the depth
of the entire target interval. The configuration of a typical freeze hole is shown on Exhibit N.
Both air-mist fluid drilling and aerated fluid drilling methods are under consideration at this
time. The air-mist method produces greater volumes of water compared to the aerated fluid
method. Drilling methods will be selected based on field conditions and technology. Drilling
fluids and additives that may be used are shown in Table 4.2

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Table 4.2 Inventory of Drilling Fluid Additives for use by Shell and its Contractors

Coring and Drilling Projects
Foamers

Baroid Quik-Foam
Bachman 485
Weatherford WFT FM A-100

Gels and Polymers

Baroid EZ-Mud - polymer
Halliburton Quik-Gel – bentonite gel
Halliburton Mud-Gel – bentonite gel
Baroid Quik-Trol and Quik-Trol LV - polymer
Benseal– for plugging back holes and hole abandonment
Baroid Holeplug – for plugging back holes and hole abandonment

Thread Compounds

Jet Lube Well Guard
MacDermid – Vinoleo thread compound for fiberglass casing
Best-O-Life Silicone GGT
Best-O-Life 72733 high temperature high pressure thread compound – not used in water wells or monitor holes.
Lub-O-Seal NM-91 anti-seize

Corrosion Inhibitors

Weatherford Corrfoam

Others

Rock Drill Oil R.D.O. ES
Sodium bicarbonate –pH neutralizer
Mazola Corn Oil – to free stuck pipe
Ventura Ultra-Fry (Canola Oil) – to free stuck pipe
Huskey LVI-50 Rod Grease – lubricate drill rods in dry hole

To complete the freeze hole and provide refrigeration for the length of the hole, an interior steel
freeze tube will be installed to a depth of approximately 1,880 feet. The bottom of the steel tube
will be sealed with an end cap. A smaller diameter high-density polyethylene (HDPE) inner
freeze tube will be installed inside of the steel freeze tube. It is expected to take about six months
to complete the drilling for the freeze wall pattern.

Once the drilling is completed, a chilled aqua ammonia solution (refrigerant), at an approximate
temperature of -45º F is pumped through the holes. The interior HPDE tube will be used to
convey the chilled aqua ammonia to the bottom of the hole and the outer steel pipe allows the

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solution to return to the surface for recycling back to the refrigeration system (see Figure 4.3).
The aqua ammonia solution will be circulated at approximately 50 gallons per minute (gpm) per
hole.

The area immediately surrounding the holes is frozen first. The frozen area continues to expand
as refrigerant is re-circulated down each hole. Eventually the frozen “columns” expand to the
point where the approximately concentric frozen “columns” are joined and a freeze wall barrier
is created as shown in Figure 4.4.

It is anticipated to take approximately 18
months to establish a continuous freeze wall
barrier.

As the circulation of refrigerant continues, the
thickness of the freeze wall will continue to
grow, although the rate of growth will slow as
the wall thickens. Heating in the interior of the
containment zone will inhibit inward growth of
the freeze wall barrier.

Once the freeze wall is in place, there will be
little change in the temperature of the wall
throughout the thickness because of the
insulating capacity of the rock matrix. In
addition, the system can withstand power
outages without damaging the integrity of the
freeze wall due to the temperature and
thickness.

Figure 4.3 Schematic of Refrigerant Flow

Chilled Fluid

Water

Shale

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Freeze Well

Temp. Monitor Well

Frozen

Saturated Rock

Figure 4.4 Freeze Well

The freeze wall containment area will be maintained until it can be demonstrated that the
containment system is sufficiently rinsed and collected rinse water meets appropriate quality.
The period of time for operation of the freeze wall containment area is currently estimated to be
approximately ten to eleven years.

If piping in the freeze hole or above ground develops a leak, it would be detected by pressure and
temperature sensors in the closed loop system. Shutoff valves are available at each hole to stop
circulation of fluid in the hole. Shutoff valves are also available within the surface system to stop
surface flows should a leak be detected. Any aqua ammonia in the down hole piping can be
purged using high-pressure nitrogen. Leaks or spills would be piped back into the refrigeration
system or hauled off-site. A Process Safety Management Manual for ammonia handling will be
developed in accordance with Occupational Safety and Health Administration regulations prior
to operation.

Refrigeration System

As the freeze holes are being drilled and completed, the refrigeration system will be constructed.
The refrigeration system will be installed before other process equipment due to the length of
time required to establish the freeze wall containment barrier. The refrigeration system will be
located on the processing level along with the processing facilities as shown on Exhibit J. The
plant will contain three (3) refrigeration units, which can each be operated separately. Initial
charging of the refrigeration system with anhydrous ammonia and carbon dioxide will occur
using the truck loading area closest to the refrigeration system, also on the processing level
southwest of the refrigeration units.

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The refrigeration units will be constructed on a concrete foundation that is curbed and graded to
drain to a series of collection points that convey any spilled materials to a concrete sump. The
sump will collect spills which will then be pumped to a truck for transport and disposal off-site.
This containment includes operating areas and truck loading and unloading facilities. An
expansion tank, an approximately 25,000-gallon tank, will contain aqua ammonia solution during
initial cooling and in the event of an extended shutdown in the system. The expansion tank will
be located adjacent to the production area.

Appropriate procedures for storage, handling and emergency response for ammonia chemicals
used in the refrigeration system will be included in the Process Safety Management Manual to be
developed in accordance with Occupational Safety and Health Administration regulations prior
to operation. Emergency response procedures including procedures for clean-up of spills and
notification requirements will be included in the Emergency Response Plan (ERP) to be
developed prior to operations.

Because the refrigeration system is a closed loop system, the system will be designed with
temperature and pressure monitors throughout to identify changes that will indicate a potential
leak within the system as well as shutoff valves to stop the flow of refrigerant when a problem is
detected. The monitoring will include alarms to alert of potential problems. Provisions are made
to isolate portions of the system when a problem is detected. Because there are three separate
refrigeration units within the refrigeration system, individual units can be isolated and shut down
without impacting the entire system.

Dewatering Within the Freeze Wall Containment Area

Once the freeze wall has been established, drilling will occur inside the freeze wall containment
area for both producer wells and heater holes. The functions and operations of these are
discussed in later sections of this Project Description. Some of the producer holes will initially
serve as ground water dewatering holes and their function as dewatering holes is discussed in
this section.

There will be approximately ten dewatering holes drilled inside the freeze wall containment area.
The dewatering holes will be completed to the total depth of approximately 1,650 feet as shown
on Exhibit N. The upper portion of the hole will be cased with and cemented in place. Slotted
liner will be placed from just below the bottom of the casing to the bottom of the hole and
electrical submersible pumps will be installed.

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Ground water removed from inside the freeze wall containment area prior to heating will be
injected into wells located down gradient, and outside the freeze wall. This will be accomplished
through an above ground piping network that allows this water to be directed from dewatering
holes to injection wells.

Two to four injection wells will be installed outside of the freeze wall as shown on Exhibit J; one
upper strata and one lower strata. The dewatering phase is expected to last approximately 4
months, but actual time will be determined by dewatering efficiency. Dewatering pumping rates
will be adjusted to match with injection rates.

Once the ability to pump water slows to the point that dewatering is no longer economical or
feasible, dewatering operations will cease. During dewatering, the water being re-injected will be
monitored periodically for water quality prior to re-injection to ensure that the water is being re-
injected into the appropriate strata and that existing water quality is not impacted. Dewatering
and re-injection flow rates will also be monitored to allow calculation of the amount of water
taken from the containment zone and associated rate of re-injection.

Heater System

Approximately 30 heater holes will be drilled in the interior of the containment zone, spaced
approximately 25 feet apart, as shown on Exhibit L. A buffer zone of approximately 125 feet will
be established between the freeze holes and the heater holes to minimize the potential for heating
of the freeze wall. Electric heaters will be installed in each hole to uniformly heat the oil shale.
The approximate surface area of the heated pattern is 130 feet by 100 feet. The heaters are in
place and heat the resource target zone for approximately 2 years.

All the heaters will be installed and energized at about the same time. The heaters are operated to
achieve heating rates that bring the average reservoir temperature to between 550 and 750

F in

approximately two years. The requirements for high operating temperature and long heating
duration have resulted in the development of heaters specially designed for the project.

Each heater has a controller and temperature indicator. Some heater holes will be monitored for
changes in pressure. The temperature and pressure monitoring will provide operating information
and data from this research project that will help in the design of future operations. The heaters
are designed to operate for the entire period without requiring maintenance. If heaters fail in
service, they may be replaced.

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During heating, the heat is transferred in the rock formation by thermal conduction only – no
steam or heat transfer fluids are injected into the oil shale. The superposition or overlapping of
heat from the array of heaters causes the average resource target zone temperature to rise quite
uniformly, except within a few feet of the heater holes. The kerogen closest to the heaters will be
converted first with the conversion moving outward as the heating progresses.

Heating also results in expansion of the rock. The rocks have differing thermal conductivities,
with the leaner oil shale having greater conductivity than the kerogen-rich oil shale. The design
of the heated zone accounts for these conductivities to ensure a sufficient buffer distance to the
freeze wall to prevent unacceptable input of heat to the freeze wall. This is a function of the
amount of heat put into the system, the conductivity of the rock, the time that the heaters are
energized and the distance between the heaters and the freeze wall.

Due to the heating associated with production, heave and subsidence can occur at the surface and
compaction can occur within the reservoir. Based upon the small production footprint and the
depth of heating, little surface expression of changes within the pyrolyzed zone is anticipated.
The surface expressions of heave is expected to be approximately 1.0-1.5 inch and the surface
expression of subsidence is expected to be approximately 0.5 – 1.0 inch.

Product Recovery

As heating occurs, the lighter and higher quality vaporized ICP products, plus steam and non-
condensable gases, will flow to the producer holes. Because of the slow heating rate, and the
close spacing between holes, the initial reservoir permeability required for fluid transport can be
relatively low. There is no need to create permeability by hydraulic or explosive fracturing. The
producer wells will collect the converted kerogen products (oil and gas mixed with some water)
in the pyrolyzed zone and convey those products to the surface for transport to the processing
facilities. Both traditional and experimental lift systems will be used in the producer holes to
“lift” the product to the surface.

Ten producer wells will collect the gas and oil produced by the ICP. The locations of the
producer wells are shown on Exhibit L. Initially the producer wells will be used to dewater the
freeze wall containment area. Upon completion of dewatering, pumps are removed from the
dewatering holes and they are converted to producer wells.

The producer holes are drilled to a depth of approximately 1,675 feet. Pumps will be installed in
each hole to bring the product to the surface.

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Each producer hole will be equipped with instrumentation to monitor production and reservoir
condition, performance, temperature, rates, and pressure as part of the ongoing research efforts at
OST.

A pump with lift assist is used to bring the liquids to the surface. Such lift systems are used on
conventional oil and gas production. Standard oil and gas production lift systems, as well as
some experimental lift systems, will be used. This will enable operating personnel to determine
the best system for use in future operations.

At the start of the heating cycle, cutter stock (purchased diesel or jet fuel) is injected into the
inlet of the down-hole production pumps to prevent plugging from bitumen which is produced
when the pyrolyzed zone is relatively cool. The cutter stock may also be circulated in the above
ground field collection piping to prevent plugging. Both the cutter stock and the treated gas used
in the chamber lift system will be recovered and treated in the processing system.

In general, the down hole heating process will be sufficient for release of the hydrocarbons from
the kerogen, and movement toward the producer holes. At later stages of production, the
hydrocarbons released from the kerogen may be removed with the assistance of water injection
holes. These water injection holes will be located inside the freeze wall containment area, but
outside the heated pattern. These holes will be used to inject water into the pyrolyzed zone. The
intent is to assist in collecting and pumping fluid from the producer holes, while protecting the
freeze wall. The recovered fluid (a mixture of water and hydrocarbons) will be collected for
further processing.

The temperature of product from the producer holes will be approximately 400

F. The product

is quenched to cool the material for transport to the processing facility. Quench water brought to
the well head is mixed with the heated product coming from the producer hole. This results in a
mixture of water and hydrocarbon. The mixture is piped to the processing facility at about 250

Oil and gas production is approximately 600 barrels of oil or 1,000 barrels of oil equivalent (oil
and gas) per day at full production for the OST.

When production is completed, producer holes will revert back to water collection holes during
the cooling and water reclamation phase of the project. The collection system will be used to
capture and transport water to the water reclamation plant.

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Field Collection Network

The field collection network will consist of headers and piping to collect oil and gas from the
producer holes for transport to the processing facility. Figure 4.5 is a photograph of a typical
production field piping network. The piping network at the OST site is expected to look similar
to that shown in this photograph. Power is distributed throughout the surface of the production
zone.

Figure 4.5 Photograph of Field Piping Network

The above ground collection system will operate under a nominal pressure of 60 psi. Pressure is
monitored with instrumentation throughout the system, with readouts in the process control
room. Visual inspections of the above ground piping network will be made on a regular basis. If
there is a drop in pressure in the collection system indicative of a potential leak or break, that
portion of the system can be shutoff until repairs are made. Surges in pressure will be relieved by
a pressure release valve. Appropriate procedures for storage, handling and emergency response
for the product recovery system will be included in Materials Handling and Waste Management
Plan or the ERP to be developed for the site.

Processing System

The recovered product will include a mixture of liquid hydrocarbons, gas, and water that will be
processed further to remove impurities and ready the products for transport off site or reuse in
the recovery process. The recovery process is a typical process used in the oil and gas industry.
The processing system location is shown on Exhibit J with a more detailed, process block flow
diagram shown on Figure 4.6.

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The initial processing will separate the recovered product into three streams: liquid
hydrocarbons, sour gas, and sour water. The term sour refers to the presence of sulfur
compounds and carbon dioxide. Once the three streams have been separated, each stream is
further processed to remove impurities. Except as noted in the following discussions, the waste
streams generated during much of the processing are recycled back into the processing for
further treating.

Liquid Hydrocarbons
The liquid hydrocarbons go through a two-step process to remove additional water and gas and
create the liquid hydrocarbon product. The first step in the process involves removal of salt in the
hydrocarbons through a desalting process. The hydrocarbon product is mixed with water and the
salt is dissolved. The oil and water mixture is then separated using large electro-charged plates.
The salty water is pulled to the bottom and the cleaned oil floats on top. The salty water is then
sent for water treatment along with the sour water and the oil moves on to the next step.

The second step involves stabilizing the hydrocarbon product for transport through a distillation
process. The distillation process separates the lighter gaseous and water fractions from the
heavier liquid fractions and lowers the vapor pressure in the heavier fractions to that allowed for
storage and transport. The liquid and gaseous streams are returned to the processing system for
further processing.

The liquid hydrocarbon product is then sent to storage tanks. The product, known as Untreated
Synthetic Condensate (USC) will be stored in two tanks located as shown on Exhibit J prior to
transport off site. The facility is expected to produce approximately 600 barrels of oil per day at
full production. The two USC tanks will each have a capacity of 139,000 gallons and will be
designed with floating roofs. The tanks will be located within a containment area with curbing to
contain any spills. Any spills will be collected and sent back to the processing system.

One or both USC tanks will initially be used to store cutter stock prior to product recovery and
processing. Once the cutter stock has been introduced into the system, the tanks will be used for
product storage. No clean-out will be required prior to the change in use.

Approximately five truckloads of USC will be shipped per day at full production. The tank
loading area is a concrete area with curbed containment. Any spills will be collected and sent
back to the processing system. The truck loading area will be equipped with heat sensors that
control a foam system for fire suppression, if needed.

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Gas Stream
The gas stream separated from the hydrocarbon product is treated through a multi-step process to
remove sulfur and any remaining hydrocarbons and water. Hydrocarbons and water removed
during the gas stream processing are returned to the hydrocarbon or sour water processing
streams.

The gas is first compressed and cooled. Any condensed sour water and hydrocarbons are
collected and sent back for further processing. The gas is then passed through columns and
contacted with an amine-based solution that will absorb organic sulfur compounds, carbon
dioxide, and acids. The treated gas collected after passing through the columns is then sent to the
chamber lift system for use in product recovery, or used to supplement site fuel needs, or is
incinerated. The solution is further processed to remove the high sulfur content gas and carbon
dioxide and is then recycled back for reuse. The acid gas from the solution is sent to a
conventional Claus sulfur recovery unit where it is converted to liquid sulfur. Gas which does not
get converted to liquid sulfur in the sulfur recovery unit undergoes further treatment in a
conventional SCOT (Shell Claus Offgas Treating) unit to remove the bulk of the remaining
sulfur compounds. Methyl diethanolamine (MDEA) is used to strip the organic sulfur in this
processing segment and then the MDEA is regenerated for reuse.

The sour gas processing employs the use of Sulfinol M, a proprietary solution containing
MDEA, Sulfolane, and water. The MDEA and Sulfolane will be stored in tanks located within
the processing system area (see Exhibit J for the processing area location). The Sulfolane and
MDEA will be trucked to the site and unloaded into the tanks. Both the Sulfolane and MDEA are
recycled for reuse in the process so large quantities are not required to be shipped to the site on a
regular basis.

The gas processing results in products that include treated gas and liquid sulfur. The liquid sulfur
will be stored in an enclosed concrete vault. The concrete vault will include steam coils in the
bottom to maintain the sulfur as a liquid until shipped offsite. An estimated maximum of eight
truckloads of liquid sulfur are shipped per month during the full production period. The tanker
will be loaded in a curbed, concrete loadout area adjacent to the processing facility and concrete
vault. Any spills will be collected and returned to the processing facility.

The treated gas will be incinerated on site, or used to supplement natural gas requirements used
in processing. An incinerator was chosen to control the burn temperature to reduce the carbon
monoxide and NO

emissions. The incinerator operates at a temperature of approximately 1500

F. The exhaust gas from the incinerator is composed mainly of nitrogen, carbon dioxide, and

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water vapor. It also contains smaller amounts of nitrogen oxides, sulfur oxides, and carbon
monoxide. A permit will be obtained from the Colorado Air Pollution Control Division for the
incinerator exhaust gas.

As in other conventional treatment facilities for oil and gas, over pressure protection systems are
provided as a safety feature. These safety systems provide pressure relief through a piping
system that terminates at a lighted flare. The flare combusts any hydrocarbon in the relief stream
to prevent the undesirable accumulation of combustible vapor. The flare location is shown on
Exhibit J. The flare will not be routinely used, but is for emergency pressure release.

Water Stream
The sour water stream is run through a multi-step process to improve the water quality for reuse
or discharge. The first step is a distillation process that removes ammonia, hydrogen sulfide gas,
and light hydrocarbons. The vapor is sent for further treating in the gas stream segment of the
processing system. The water is sent to a flotation cell and compressed air is used to generate gas
bubbles that carry hydrocarbons and solids to the surface of the water in a froth layer that is then
skimmed off. The froth layer is stored in a tank for eventual shipment from the site. The water
continues to the next step of processing which is the membrane bio-reactor. The membrane bio-
reactor uses bacteria, protozoa, and rotifers to remove organic material and convert this matter to
biomass and other byproducts such as carbon dioxide, nitrogen gas and sulfates. Excess biosolids
are collected and stored in a 214,000 gallon tank for shipment offsite. The water then goes
through a reverse osmosis process to remove dissolved salts and other ions. Reject water from
the reverse osmosis is directed into an 189,000 gallon tank for storage and transport offsite.
Clean water is recycled back for use in the as quench water or in the processing facility.

The only additions for the water processing are compressed air and the bacteria, protozoa and
rotifers. Tanks for storage of waste streams from the water treatment (air flotation solids, excess
biosolids, and reject water from the reverse osmosis) will be located within concrete lined and
curbed containment. The loadout area will be located north of the storm water pond as shown on
Exhibit J and will also be a concrete lined and contained area. Any spilled materials will be sent
back to one of these storage tanks.

The purified water stream is recycled for use as boiler feed water, washes for condenser units
and as temperature regulating quench water. Any water not needed for the project will be
discharged to the Yellow Creek drainage following treatment to the applicable standards. A
Colorado Discharge Permit System permit will be obtained from the Colorado Water Quality
Control Division for this discharge.

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Processing System Pilot Scale Test Skids

Small “slipstream” volumes of gas, oil, and sour water will be processed in pilot scale test
facilities located on skids to provide easy movement. These small plants will be used to conduct
testing and collect data on USC processing methods. The pilot scale tests will be conducted
within the process facilities area. Pilot scale testing will be used to evaluate the potential for
additional processes to assist in further refining the products from the ICP process. Wastes from
the pilot scale facilities will be handled in the process water treatment plant or the gas cleaning
systems. Spills will be captured and treated in the process water treatment plant.

Process Water Pond

The Process Water Pond is a lined pond that is used as storage capacity for the stripped sour
water from the Sour Water Stripper. This pond will be used to provide extra storage and in the
event that the Dissolved Air Floatation, Membrane Bio-Reactor, or the Reverse Osmosis Units
are off line for maintenance or repair or during periods when additional storage is needed. The
stripped sour water can be diverted and stored in the Process Water Pond until the water
treatment units are functional again. It is expected that the pond will be used for storage on a
routine basis and will not remain empty for long periods of time.

The process water treatment pond has a capacity of approximately 10 acre-feet. Because the
pond will hold process water that has not been fully treated to meet discharge standards, it is
designed with a triple liner system composed of a soil liner overlain by two synthetic liners with
a leak detection layer between. The soil liner is a geosynthetic clay liner (GCL) mat overlain on a
six inch prepared subgrade. A 60-mil smooth HDPE liner will placed over the GCL. The primary
liner is an 80-mil HDPE liner, textured on the side slopes and smooth on the bottom. Geo-net
with a leachate collection and recovery system will be placed between the two liners. The pond
does not have an outfall structure as it is a total containment pond.

The process water pond will be fenced with an eight-foot high chain link fence to prevent
wildlife from entering the pond and causing liner damage.

4.4

Recovery Efficiency and Energy Balance

Although Shell’s economic model contains many inputs, ICP economics depends heavily on the
following three subsurface process performance metrics:

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•

Recovery Efficiency – the ratio of produced ICP oil to Fischer-assay oil in place

•

Energy Balance – the ratio BTU’s out as oil and gas to the BTU’s input via electrical power

•

Product Quality – the composition and properties of produced ICP fluids (e.g. API gravity)
Product quality is addressed further in Section 4.7 below.

The high recovery efficiency of ICP (~100% of Fischer assay BOE, Barrel of Oil Equivalent)
results from the slow, uniform heating process and also from the in situ vaporization of the
hydrocarbons.

ICP makes more complete use of the oil shale resource. The entire oil shale column is pyrolized,
including lower grade zones that could not be mined economically for surface retorting. ICP also
can access deeper oil shale resources than are uneconomical to mine. Overall, much more oil and
gas may be recovered from a given area utilizing the ICP process.

There are locations of thick resources in the Piceance Basin that could yield in excess of one
million barrels of shale oil per acre.

ICP requires energy input for heating, freeze wall construction, processing, and maintenance but
still generates three to four times as much net energy as it consumes. This energy ratio is very
comparable to steam injection in heavy oil projects.

Support Facilities

Support facilities associated with the ICP and processing facilities include the building complex
near the project entrance, the utility building and substations, a process control and
locker/change house building, loading / unloading facilities, construction support, and driller
support. Sanitary wastes from these facilities will be piped to the process water treatment
building and treated in the Bio-Reactor. Solid waste (trash) will be disposed off site at an
approved facility.

Security will be provided at the site. Trucks, visitors and employees will be required to enter
through the security gate to access the work site. The maximum number of people employed at
the site will occur during construction and drilling. An estimated maximum of approximately
720 individuals will be employed at the site during the construction and drilling period. Once
construction is completed, the maximum expected employment at the site will be approximately
155. Shifts will typically be nine-hours per day, with some operators working twelve hour shifts.

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Parking will be available in a parking lot just inside the main gate. An automated exit gate will
be installed. Traffic will range from 300 to 650 vehicles per day, including personal automobiles
and supply and product trucks.

Emergency Response personnel will be on site or on call. Written emergency procedures will be
kept in manuals developed in accordance with Occupational Safety and Health Administration
regulations prior to operation and in the Spill Prevention Control and Countermeasures (SPCC)
and ERP. Copies of these manuals will be located in the control room and guard shack.
Employee training will include safety, chemical handling, spill control and cleanup, and other
emergency procedures.

Building Complex

The building complex includes a guard shack and gate, warehouse, shop building, laboratory
building, and potable water tank and delivery system (see Exhibit J). The warehousing and
maintenance shop will provide routine services for the operation.

Spill containment and cleanup procedures developed as part of the SPCC and the ERP will be
implemented for any regulated chemicals used or stored in these facilities.

The laboratory will be used for process quality control testing, research testing and
environmental monitoring. The building will be on a concrete foundation with a sump for spill
containment. Chemicals will be stored in cabinets, appropriately segregated. Liquid waste from
the laboratory will be treated at the process treatment plant or collected for off-site disposal in
accordance with applicable regulations.

Potable water will be stored in a 12,500 gal tank at the building complex. Potable water will be
brought from off site. The potable water system will service the lab, warehouse, shop, control
room, and change house.

Utilities

Power is brought into the site from an electrical substation constructed, owned, and operated by
White River Electric Association (WREA), just outside the permit boundary. Two substations on
the project site will be maintained on site for power distribution to the project. It is anticipated
that WREA will obtain the permits necessary for the substation and distribution line, an
approximate location is shown on Exhibit C.

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An electrical sub yard for heaters is located adjacent to the freeze wall containment area to
support the heating process. An additional electrical sub yard is located just east of the WREA
substation and services the rest of the facilities. Natural gas is brought on site via a pipeline from
a commercial supplier located in proximity to the site and distributed to the processing facility. A
stand-by diesel generator is located in the utility building. A small diesel storage tank will be
located inside the curbed building to provide fuel for the stand-by generator.

The utility building area is also the location for the compressed air and nitrogen storage and
distribution. Liquid nitrogen will be brought to the utility building in tank trucks. A paved
unloading facility will be used. The liquid nitrogen is pumped into a 1,500-gallon nitrogen
storage tank with a pressure release valve to atmosphere. The liquid nitrogen is vaporized for use
in the process, including uses as blanket gas in process storage tanks and in the aqua ammonia
expansion tanks. High pressure nitrogen is also brought to the site. The nitrogen will be brought
to the site via a tube trailer and will be used to supply the refrigeration system with utility
nitrogen, in the producer holes and gathering area as purge gas, and for instrument air.

Chemicals used in the processes are stored and handled within secondary containment and are
subject to the ERP to be developed prior to initiation of refrigeration.

Process Control and Change House

The process control building and a change house are located near the utility building. The
process control building will include data loggers from the many process sensors located
throughout the project. The change house will be supplied with potable water. Sanitary waste
from both buildings will be treated at the bioreactor at the process water treatment plant.

Drillers Support

Drilling of holes within the freeze wall containment area will last approximately one year.
During that time, there will be a designated area for location of drilling support. Drilling support
will include separate office, warehousing and operating equipment. Trailers for use as office and
changing rooms will be located at the southwest end of the disturbed area as shown on Exhibit J.
A material storage yard will be adjacent to the trailers. Diesel fuel, piping, and supplies will be
located in the material storage yard.

Air compressors, mud traps and mud pumps will be located adjacent to the active drilling during
the drilling program. Drill cuttings removed from the drilled holes will be dewatered so the water
can be recycled back to the drill rigs. The dewatered cuttings will be placed into a cutting pit as
shown on Exhibit J. This pit will be approximately 100 feet by 300 feet. The drill cuttings are not

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toxic or acid forming as shown by results of Meteoric Water Mobility Testing performed on
cutting samples.

4.5 Water

Management

Water requirements vary throughout the project life. Water uses include construction, potable
water, dust control, drilling, processing, filling and cooling of the heated interval for reclamation,
and rinsing of the zone inside the freeze wall.

Water Supply and Water Requirements

Water will be trucked to the site for construction and drilling activities. Potable water will be
trucked to the site throughout the life of the facilities.

Onsite water will be used for most operational uses and will be supplied from water wells drilled
for that purpose. A primary and a backup water supply well are planned. The well will supply
water needed for processing and reclamation. Peak pumping demand from the well is estimated
to be approximately 300 gpm and will occur during the fill and cool phase of the reclamation
cycle (see Section 5.0). If the water well is available during construction and drilling, then this
water will supplement or replace construction and drilling water trucked to the site.

Water needs for each phase of the operation are outlined below. The projected water needs are
estimates and are subject to change as additional information becomes available and facility
designs are finalized. Water rights required for the project will be acquired prior to startup of the
operation.

Construction Water

Construction water will be trucked to the site as necessary for use in compaction, dust control
and miscellaneous construction water needs. Construction water needs are estimated at
approximately six gpm. Potable water needs during construction will be through provision of
bottled water brought to the site.

Drilling Water

Water required for drilling will be trucked to the site until water from the on site water supply
well is available to supplement or replace trucked water. Water needed for drilling operations is
estimated at approximately five gpm.

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Potable Water

Potable water will be delivered to the site by truck for use in the potable water system. The
system will consist of a potable water tank and distribution lines to points of use. Potable water
needs are estimated to be less than one gpm.

Operations and Reclamation Water

Water will be needed for various processing and operating needs. Water removed with the
hydrocarbon products will be treated in the processing facilities and recycled or discharged.
Figure 4.7 provides a general schematic of the process water management. It is currently
anticipated that there will be excess water available during the initial processing period as a
result of water within in the freeze wall containment area and that there will be no need for the
water supply well to provide water for processing during this initial period. As processing
progresses, there will be a need for up to approximately 11 gpm for water in processing.

Water is also needed to conduct reclamation filling and cooling of the heated interval within the
freeze wall containment barrier as well as rinsing of the heated interval. This water will be a
combination of recycle water and make up water from the water supply well as needed. During
reclamation up to an approximately 300 gpm will be needed for initial stages of flushing and
cooling. Figure 4.8 provides a general schematic of the reclamation water management.

Figure 4.7 Processing Water Management

CDPS Discharge

Pyrolosis

Zone

Treated Water

Quenching

Processing

Facility

Process Water

Treatment

Plant

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Figure 4.8 Reclamation Water

Water Discharge

Water that cannot be recycled or otherwise used will be treated to appropriate discharge
standards in the process water treatment plant and released to a surface drainage under a
Colorado Department of Public Health and Environment Colorado Discharge Permit.

Water Injection

Once the freeze wall is formed the containment area interior to the freeze wall will be dewatered
by pumping. This intercepted natural ground water will be pumped from the freeze wall
containment area and injected down gradient of the freeze wall through injection wells. The
injection wells will be permitted with the EPA Underground Injection Control program for Class
V injection wells authorized by rule. Water of appropriate quality will be injected into
appropriate zones so that beneficial use classifications are maintained. Figure 4.9 shows a typical
schematic for water management during dewatering and injection.

Evaporation Pond

Water

Treatment

Plant

Recycle

Pyrolosis Zone

Supplemental

Water

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Figure 4.9 Dewatering and Injection Water Management

4.6

By-products and Wastes

During the course of the R&D project, construction and operation, a variety of by-products and
waste materials will be generated. They include construction waste, drill hole cuttings, garbage
and miscellaneous solid wastes and sanitary waste.

Surface construction operations will result in a variety of small waste products that could include
paper, wood, scrap metal, refuse, garbage, etc. These materials will be collected in appropriate
containers and recycled or disposed off site in accordance with applicable regulations

Approximately 200,000 cubic feet of earth and rock materials will be generated during drilling
operations for the project. These non-toxic, non-acid forming drill cuttings will be separated
from free water and will be buried below grade. Burial depth and soil coverage will be sufficient
such that the materials will not impede revegetation.

During operation, garbage from the site will be collected in appropriate containers and disposed
off site. Waste oils, reagents, lab chemicals that are not collected sumps and treated at the water
treatment plants will be recycled or disposed off site in accordance with applicable regulations.

Upper water

Bearing

Zones

Lower

Water

Bearing

Zone

Inject to

Appropriate

Water Bearing

Zone

Freeze Wall

(Containment

Area)

dewatering

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Sanitary Waste

A combination of sanitary waste handling methods will be employed. Some sanitary waste, such
as that collected in temporary toilet facilities may be shipped to an approved facility for offsite
treating and disposal. Any gray water or black water disposed onsite will be treated in an
appropriate sewage processing unit or disposed according to standards via an approved septic
system with clarifier and drain field.

4.7

Monitoring and Response

The OST project is a research, development, and demonstration program designed to
demonstrate the ICP, gather additional operating data and information, and allow testing of
components and systems. As a result, monitoring is inherent in the design of the project. ICP
process monitoring will be designed to gather data on the functioning of the various system
components. Shell will conduct extensive compliance monitoring as part of permit requirements
e.g. air, water and mining permits. These will be defined as part of the permitting process.

Environmental monitoring that will be done to demonstrate other environmental protection
measures for the site are described in this section.

Surface Water Monitoring

A proposed quarterly surface water sampling program will be performed on sampling sites
identified in Table 4.3. The locations for these sites are shown in Exhibit O. The sampling
parameters are detailed in Table 4.4. All monitoring records will be maintained at the project
site.

Table 4.3 OST Surface Water Monitoring Locations

Stream
Sites

Upstream Corral

Gulch

CR242

Downstream Corral

Gulch

CR408

Upstream

Stake Springs Draw

CR407

Downstream

Stake Springs Draw

CR411

Downstream Yellow

Creek

CR255

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Table 4.4 Surface Water Sampling Parameters

Parameter Unit

Parameter

Unit

Discharge gpm

Boron,

dissolved

mg/L

Field pH

Cadmium, dissolved

mg/L

Field Conductivity

umhos/cm Chromium dissolved

mg/L

Field Temperature

°C

Chromium, Trivalent
Dissolved

mg/L

Field Dissolved Oxygen

mg/L

Chromium, Total

mg/L

Field Turbulence

ntu

Copper, dissolved

mg/L

Residue, Filterable (TDS)

mg/L Iron,

total

recoverable

mg/L

Calcium, dissolved

mg/L

Lead, dissolved

mg/L

Magnesium, dissolved

mg/L

Manganese, dissolved

mg/L

Sodium, dissolved

mg/L

Mercury, total

mg/L

Hardness as CaCO

mg/L
CaCO

Nickel, dissolved

mg/L

Bicarbonate as CaCO

mg/L

Selenium,

dissolved

mg/L

Chloride mg/L

Silver,

dissolved

mg/L

Sulfate mg/L

Zinc,

dissolved

mg/L

Sulfide as S

mg/L

Benzene

ug/L

Nitrogen, Ammonia

mg/L

Toluene

ug/L

Nitrate/Nitrite as N

mg/L

Ethylbenzene

ug/L

Arsenic, dissolved

mg/L

Xylene

ug/L

Ground Water Monitoring

Ground water monitoring will be conducted outside of the freeze wall barrier to monitor ground
water quality during operation and after reclamation.

Ground water monitoring will consist of monitoring of the water bearing units including the
Uinta, A and B Groove, L5, L4 and L3. Compliance monitoring of these zones will occur using
dedicated single completions in each zone.

Multiple zone completions are being tested for some wells interior to the freeze wall containment
at FWT. Multiple completion wells are equipped with isolation packers to prevent crossflow
between zones. Sample ports in the tubing string will allow for collection of pressure data and

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water samples. Should the information gained from the multiple zone completion wells
demonstrate this type of completion is appropriate for ground water quality monitoring, then
multiple zone completions could be proposed for ground water monitoring at a later date, subject
to approval.

Planned ground water monitoring for the OST will include one upgradient completion in each
unit and downgradient completions in each unit. Additional wells may be installed within the
project area for early detection of potential problems.

Facilities Monitoring

Routine visual inspections and operational warning systems will facilitate monitoring of
containment systems and features at the OST site. These will include the following:

•

Piping systems will be pressured tested prior to use. The pipe systems will have pressure
monitors to alert operators when a loss of pressure occurs that could be indicative of a
potential problem.

•

Sumps within concrete containment areas will be visually monitored on a daily basis and any
liquids present in these sumps would be pumped to the process water treatment plant or sent
off site for disposal at an appropriate facility.

•

Storm water management systems would be inspected on a periodic basis as prescribed in the
Storm Water Management Plan.

•

A SPCC will be developed to address spill prevention and response for petroleum products at
the site. The SPCC plan will prescribe inspection types and frequencies for petroleum related
vessels and containments.

In addition, an ERP will be developed for responding to emergencies at the site while ensuring
worker safety. The Plan will include designation of responsible personnel, an outline of
procedures to be followed, a list of chemicals to be used or stored on site, a list of materials
available to control spills or leaks, and notification requirements.

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5.0

RECLAMATION

PLAN

Reclamation for the OST Project will occur as operations at various project components are
completed. The first step in reclamation of the OST will be reclamation of the pyrolyzed zone
inside the freeze wall containment area. Reclamation of the freeze wall containment area will
involve flushing of the pyrolyzed zone with water to provide cooling after the heating phase and
to flush potentially toxic-forming constituents from this zone. After flushing the freeze wall will
be allowed to thaw. As such, the refrigeration plant will need to continue operation and the
freeze wall will need to remain in place until the acceptable ground water quality is reached.
Most of the on-site facilities would need to remain to support the flushing operations.

Once facilities are no longer needed, the equipment will be removed and the facilities
demolished. Concrete foundations will be broken and buried at the site with a minimum of four
feet of cover. The site will be regraded, soil will be replaced and the site will be revegetated.

The following section provides information on the reclamation of the OST project. Figure 5.1
shows the anticipated schedule for operation and reclamation of site facilities. Exhibit Q shows
the expected final topography and revegetation for the disturbed areas.

5.1

Reclamation of the ICP

Once pyrolysis and production are completed, the pyrolyzed oil shale within the freeze wall will
be flushed with water for cooling and reclamation. After production has been completed, water
will be injected into each water-bearing strata and allowed to remain in the pyrolyzed zone for a
sufficient period of time to promote cooling. Temperatures in the pyrolyzed zone will be
monitored during the period to evaluate the cooling process. The initial injected water is
converted to steam, and some remaining volatile hydrocarbons are removed by steam distillation.
The steam generated by the initial cooling is collected in the gathering system and routed to the
ground water reclamation treatment plant.

After the cooling period, reclamation of the pyrolyzed zone will be performed by injecting
ambient ground water into each water-bearing strata to mobilize (“flush”) residual hydrocarbons,
while the freeze wall containment barrier remains in place. Injected water will be passed through
the pore spaces, pumped to the surface, treated in the ground water reclamation treatment plant
to remove potential ground water contaminants, and then recirculated to repeat the flushing
process. The injection, flushing, pumping, treatment, and reinjection procedure will be continued
until concentrations are sufficiently low so as to meet applicable water quality targets.

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The ground water reclamation treatment plant is designed to remove hydrocarbons and some
other trace elements and compounds. The treatment plant will be comprised of a number of unit
processes that separate the residual oil, water, and gas phases; capture, convert, and treat gases;
and provide additional treatment of the water with refined separation, selective sorption, and
filtration as necessary.

Flushing will be accomplished through the use of the ground water monitoring wells completed
interior to the freeze wall containment. Monitoring wells for all zones are completed as multi-
zone completions with each zone isolated through the use of packers. Water will be circulated
from the ground water reclamation treatment plant down the hole to the water-bearing zone
being flushed. Flushed water is recovered through the producer holes and circulated back to the
treatment plant for treatment. If needed, up to an additional five holes will be drilled within the
freeze wall containment area for the purpose of dewatering during reclamation. This cycle
continues until approximately 20 pore volumes have been flushed through each zone or until the
water quality meets acceptable standards.

Prior to the completion of recovery operations, the ground water reclamation treatment plant and
associated evaporation pond will be constructed in the locations shown on Exhibit J. The primary
purpose of the treatment plant is to provide water treatment for the water used and recovered
during flushing of the pyrolyzed zone. The treatment plant has been designed to treat
approximately 2,100 gallons per minute, however the current anticipated rate for flushing is
estimated to be approximately 1,050 gallons per minute. In order to allow 20 pore volumes to
circulate at the rate of 1,050 gallons per minute, the plant will operate for approximately 5-years.

The producer holes will be used for circulation of the flush water along with the existing piping
system. The treatment plant will provide treatment for removal of hydrogen sulfide, ammonia,
volatile and semi-volatile organic compounds as well as removal of metals and selenium.

The treatment system will include pretreatment and polishing steps to optimize the water
treatment. The first step is to remove remaining hydrocarbons through an oil / water separation
stage. This stage uses flotation methodology to capture the oil in air bubbles, which float to the
top of the water and can be skimmed off the surface. Depending on the concentration of
hydrocarbons in the skimmed portion removed, the removed hydrocarbons will either be
processed through the processing facility or hauled from the site for appropriate disposal.

The water then moves to a filtration unit to remove remaining solids and hydrocarbons prior to
the steam stripper. The filtration unit will be periodically backwashed to clean out filtered

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substances and allow for continued optimal treatment. This backwash will be sent to an
equalization tank for further processing to recover oil and collect waste sludge that will be
ultimately hauled off site for proper disposal.

The removal of solids and hydrocarbons is important prior to the next stage to prevent short
circulating of the steam stripping process. The purpose of the steam strippers is to concentrate
contaminants into a vapor stream and recover the water portion of the steam separately from the
other vapor products produced. The steam stripper operates in two stages; the first stage focuses
on removal of hydrogen sulfide, while the second stage focuses on removal of ammonia and
volatile and semi-volatile organic compounds. In the first stage, hydrogen sulfide would be
converted to elemental sulfur which will be collected and hauled off site. Volatile and semi-
volatile organic compounds are sent on to the second stage stripper. In the second stage stripper,
these gases are collected and sent to a catalytic oxidizer along with ammonia. The ammonia in
the off gas is combusted to nitrogen oxide and water. The nitrogen oxide is then converted,
through compression and diffusion in a NO

absorber to nitric acid. Nitric acid and water used to

clean out the absorber is sent to the evaporation pond along with any residual solids. Sodium
hydroxide is used to neutralize the nitric acid prior to discharge to the evaporation pond. Volatile
and semi-volatile organic compounds are combusted.

Following steam stripping, the water is sent to an equalization tank. The equalization tank also
collects supernatant from the sludge thickener and filtrate from sludge filter press. Suspended
solids would be deposited as sludge in the bottom of the equalization tank. The waste sludge
would be contract hauled at least once per year. The solids are primarily of an inert chemical
nature and the sludge should not be biologically or chemically active.

The effluent is then sent to coolers to decrease the temperature prior to being passed through
granular activated carbon for removal of any remaining volatile and semi-volatile organic
compounds. Two carbon trains will be used and each carbon train will have two beds operating
in series. Each bed in the train can operate independently and during maximum loading in the
early stages of treatment, one bed will be regenerated while the other is being used. The carbon
will be regenerated on site. Water released during regeneration goes to equalization tank. Off
gases, which will be mainly carbon dioxide and water vapor with some metal oxides and
oxidized sulfur compounds, will be sent to the NO

absorber.

Following the carbon filtration, selenium, mercury, molybdenum, and vanadium will be removed
by the selenium and metals removal treatment. Metals treatment includes hydrogen peroxide
addition and ferric iron co-precipitation. Sludge produced during the metals treatment will go
through a thickener before being hauled off-site for proper disposal. The sludge is expected to

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test as non-hazardous under Toxicity Characteristics Leaching Procedure standards.

Treated effluent goes to the final effluent sump for re-injection to the pyrolyzed zone or for use
as fresh water in the ground water reclamation treatment plant.

An evaporation pond is designed as a triple-lined containment area to hold certain wastes streams
from the ground water reclamation treatment plant and allow water to evaporate. The
evaporation pond will receive solids from boiler water treatment reverse osmosis, and blow
downs from the boilers, and the NO

absorber.

The pond is designed to an inside height of 10 feet, with a surface area of approximately 11
acres, and an estimated capacity of approximately 119 acre-feet. Maximum required storage for
the life of the evaporation pond is approximately 70.6 acre-feet at a depth of approximately six to
seven feet. The pond is capable of containing a 100-year 24-hour storm in addition to the effluent
stream from the treatment plant. The evaporation pond is anticipated to remain in place for
approximately three years after completion of flushing and treatment to allow additional
evaporation to occur. Concentrated brine, remaining after this period, will be excavated and
hauled to an appropriate off-site disposal facility.

The evaporation pond will be fenced with an eight-foot chain link fence to prevent wildlife
ingress to the lined pond area.

Thawing of the Freeze Wall

When the flush water meets acceptable water quality targets, the refrigerant will cease to be
circulated in the freeze holes and the freeze wall containment barrier will be allowed to thaw.
High-pressure nitrogen will be used to flush refrigerant from the holes. Down-hole refrigerant
flushed from the holes will be loaded directly into appropriately equipped tanker trucks for
shipping offsite due to the limited capacity for storage of the down hole portion of aqua
ammonia. The aqua ammonia is used in many agricultural applications and would be either sold
or donated to an entity in the agricultural community for use in accordance with applicable
regulations. The freeze wall is expected to take some time to completely thaw. Previous testing
as well as modeling indicates that the freeze wall containment will thaw slowly and the barrier
will continue to be in place for some period of time following the cessation of refrigerant flow
into the freeze holes. Monitoring of down hole freeze hole temperatures will continue through
thawing. Monitoring in temperature monitoring holes will also continue to provide information
on the length of thawing.

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Plugging and Abandonment of Drill Holes

Once the flushing is completed and the freeze wall is allowed to thaw, drill holes associated with
the OST can be plugged and abandoned. Plugging and abandonment will occur over a period of
time, as certain holes will continue to be used for monitoring of the freeze hole thawing and
related water quality monitoring internal to the freeze wall containment area. It is currently
anticipated that the heater and producer holes will be the first holes to be reclaimed internal to
the containment area along with injection holes being reclaimed external to the containment area.
Some freeze holes and monitoring holes will remain open to allow monitoring of the thawing of
the freeze wall. The following discussion contains general information on drill hole plugging and
abandonment as well as specific plugging and abandonment procedures for each type of hole.

All borings will be plugged and abandoned consistent with applicable state rules and regulations.
Sealing is important to prevent mixing of different quality ground water. Most of the holes will
have surface casing cemented through alluvium. This casing will be left in place, but will be cut-
off five feet below final grade. The uppermost five feet of the hole will be filled with a material
less permeable than the surrounding soils and will be adequately compacted to prevent settling
and a cap will be welded at the top of the hole with proper identification information. Cement
plugs will also be placed where the surface casing is cut off, five feet below the surface and
where required to isolate water-bearing zones. Coated bentonite pellets, cement grout,
abandonment fluid or comparable alternative will be used as fill between required cement plugs.
There may be variations from this protocol in some types of holes, as identified below.

Decommissioning of Facilities

When it has been determined that the flushing is completed and the freeze wall is allowed to
thaw, the refrigeration system and processing facilities can be decommissioned. All chemicals
will be removed from the site and properly disposed. Any remaining product and wastes will be
removed as well; wastes will be disposed off-site and product will be shipped for additional
treatment. Storage tanks for waste and product will be triple rinsed prior to removal with the
rinse water directed to the ground water reclamation treatment plant. Plant equipment will be
removed for disposal or reuse.

If there is any sludge in the bottom of the process water treatment pond, such sludge will be
tested to determine appropriate disposal. Results of the testing will determine if the sludge can be
buried in place or must be removed from the pond prior to pond reclamation. If test results
indicate that the pond sludge meets applicable leaching standards, the sludge will be left in place,
otherwise the sludge will be removed for appropriate disposal off-site. The pond liners will then
be punctured and folded inward. The pond will be backfilled and graded in preparation for soil
placement and revegetation.

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Upon completion of the ground water flushing and associated water treatment, the ground water
reclamation treatment plant will be reclaimed. Any remaining unused chemicals or wastes will
be removed from the site for off-site disposal. Storage tanks for waste and product will be triple
rinsed prior to removal with the rinse water directed to the evaporation pond. Plant equipment
will be removed for disposal or re-use. The plant building will be demolished and the site
regraded in preparation for soil placement and revegetation.

The evaporation pond would not be reclaimed for approximately 3 years following completion of
ground water treatment and flushing. During that period of time, the brine in the pond will be
allowed to concentrate. The concentrated brine that remains in the bottom of the pond at the end
of the three-year period will require removal and appropriate disposal off-site. Once the brine
solution has been removed from the pond, piping and pumping would be removed and the pond
liners will be punctured and folded inward. The pond area will be backfilled and the surface area
regraded prior to soil replacement and revegetation.

Other facilities associated with the OST operations will be removed when no longer needed to
support the reclamation efforts. Small quantities of chemicals and waste stored in the laboratory
and at other locations will be collected and shipped off site for re-use or disposal. The buildings
will be demolished and foundations broken and buried on site. The building locations will be
graded in anticipation of soil replacement and revegetation.

When no longer needed to collect storm water runoff from the site, the storm water pond will be
reclaimed. It is currently anticipated that this pond will be reclaimed along with removal of the
storm sewer drainage system and grading of disturbed areas. Any sediment in the bottom of the
storm water pond will be tested to determine appropriate disposal. If test results indicate that the
sediment is not acid- or toxic-forming, the sediment will be left in place, otherwise the sediment
will be removed for appropriate disposal off-site. The piping and pump systems will be removed
and the pond liners will then be punctured and folded inward. The pond will be backfilled and
graded in preparation for soil placement and revegetation.

Final Site Regrading and Revegetation

The site access road will be reclaimed to a dirt road at the completion of project activities.
Asphalt paving will be removed and the road will be regraded to an approximate 12- foot wide
compacted dirt travel surface. Soil stockpiled on either side of the road will be replaced on the
regraded areas and the areas will be revegetated as shown in Exhibit Q.

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Following completion of demolition of the facilities, land reclamation will begin. Soils in the
vicinity of aboveground petroleum product storage tanks will be tested for petroleum
contamination prior to recontouring the area. Existing sediment control structures will control
erosion and contain runoff and sediment within the project area during reclamation. Using
typical earth moving equipment, the disturbed area will be recontoured to a final topography that
blends with existing undisturbed growth. Maximum slope gradients will occur in the eastern
portion of the disturbed area. Slope grades in other portions of the project area will be less than
ten percent. Earthmoving should be limited based upon the cut/fill work used to establish the
benched layout of the facilities to centralize drainage control. The regraded material will be
scarified prior to planting to prepare a seed bed.

Salvaged and stockpiled soils will be redistributed over the recontoured area. Topsoil will be
redistributed to a minimum depth of six inches over disturbed areas. Redistributed soil will then
be tested to determine if amendments are necessary to promote plant establishment. Fertilizer
and other appropriate amendments, if needed, will be applied after soil placement. The area will
then be seeded with seed mixes recommended in the BLM Resource Management Plan modified
based upon site specific data obtained during the baseline vegetation survey. Seed will be drilled
or broadcasted. Straw will be crimped over the seed or mulch will be added using a
hydromulcher. Seeding will occur in the fall with the early spring serving as an alternative
should fall seeding not be completed.

Three types of vegetative habitats are planned for reclamation of the OST to allow final land uses
of rangeland and wildlife habitat. The three vegetative habitat types consist of a pinyon pine/
Utah juniper mixture located on the ridgelines, a more mesic mix for the mid-slope position of
the regraded topography and a third mix for reclaiming upland drainages.

The main species in each of the mixes will not vary significantly as the two dominant plant
communities in the area are sagebrush grassland and pinyon/juniper. However, the percentages
by species will be adjusted slightly for the various topographic positions. The pinyon/juniper
type will be augmented with seedling plantings in the area. Additionally, smaller “islands” of the
pinyon pine/Utah juniper seedlings will be interspersed within the mid-slope areas to serve as a
seed source and cover areas for wildlife species. Pinyon/juniper at the edge of disturbance will
also provide a natural source of seed for the revegetated area. Exhibit Q provides mapping of the
expected areas for seeding by each type and the estimated acreage for each type.

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Pinyon/Juniper Ridge Top Community Seed Mix

Species of plant

Variety

Pure Live Seed (lbs/acre)

Western wheatgrass*

Rosanna

Bluebunch wheatgrass*

Secar

Thickspike wheatgrass*

Critana

Indian ricegrass*

Nezpar

Fourwing saltbush*

Wytana

Utah sweetvetch*

Junegrass

Hood’s Phlox

Antelope Bitterbrush

Broom Snakeweed

Wyoming Big Sagebrush

Alternates: Needle and thread, globemallow

Based on the average number of 241 trees per acre in the pinyon/juniper ridge top communities
surveyed at the site, of which 123 are pinyon and 118 are juniper, approximately 160 pinyon
Pine and 150 Utah juniper seedlings will be planted per acre, with an assumed mortality rate of
30 percent, in order to achieve pre disturbance tree and shrub counts.

Mid slope Community Seed Mix

Species of plant

Variety

Pure Live Seed (lbs/acre)

Western wheatgrass*

Rosanna

Indian ricegrass*

Nezpar

Bluebunch wheatgrass*

Whitmar

Thickspike wheatgrass*

Critana

Green needlegrass*

Lodorm

Globemallow*

0.5

Junegrass

Hood’s Phlox

Fremont’s Penstemon

Wyoming Big Sagebrush

Broom Snakeweed

Rubber Rabbitbrush

Alternates: Fourwing saltbush, Utah sweetvetch, balsamroot

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Upland Drainage community Seed Mix

Species of plant

Variety

Pure Live Seed (lbs/acre)

Western wheatgrass*

Rosanna

Needle and thread*

Thickspike wheatgrass*

Critana

Indian ricegrass*

Nezpar

Sand dropseed*

Slender Wheatgrass

Basin Wildrye

Basin Big Sagebrush

Rubber Rabbitbrush

Greasewood

Following reclamation, vehicle traffic will be restricted over the area. Some limited travel will be
required to conduct post reclamation monitoring of vegetation, potential subsidence and water
monitoring holes. The revegetated areas will be monitored for the first two years to evaluate the
need for supplemental seeding and noxious weed control. Recontouring, reseeding, or other
appropriate measures will address areas of erosion in the revegetated areas. Noxious weed
control will occur through the use of BLM recommended procedures based on the amount and
type of noxious weed present. Erosion control measures will not be removed until vegetation is
established.

Although subsidence of the disturbed area is not anticipated, periodic monitoring will be
conducted in order to detect any significant deformation in the area.

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6.0 ENVIRONMENTAL

SETTING

AND BASELINE STUDIES

The project site is located on federal lands managed by the BLM. The land is not wilderness,
wilderness study areas or adjacent to a wild and scenic river. Shell has completed preliminary
baseline surveys on several large parcels which include the 160-acre R&D site (Exhibit R).
Baseline information has been forwarded to the BLM field office; it is summarized here.

6.1 Vegetation

Vegetation varies from sagebrush grassland desert-shrub community at drier lower elevations to
a forest pinyon/juniper community at higher moister elevations. In addition to the natural
vegetation, several large parcels of irrigated pasture and hay meadows are located within the
Piceance Creek drainage. Irrigated pasture and hay meadows are limited in the Yellow Creek
drainage. Water requirements for upland vegetation communities are supplied by natural
precipitation, while bottomland communities have water sources that supplement precipitation,
such as runoff from adjacent slopes, ground water discharge, and streamflow diversions for
irrigation. Based on studies completed to date no federally threatened and endangered (T&E)
species or BLM sensitive species were located. A wetland delineation was conducted in October
2005 that found no wetlands present within the OST site boundary or within the proposed access
route into the site.

6.2 Soils

Predominant soils types in the project area are the Redcreek-Rentsac complex, the Rentsac
channery loam, and the Rentsac-Piceance complex. These soil types support livestock grazing,
wildlife habitat, and woodlands. Primarily they are well drained and the permeability is
moderately rapid with a very low available water capacity.

Surface layers (soils and soil parent materials) in the study area are derived primarily from the
Uinta Formation, with exposures of the Green River Formation along valley slopes. The
relatively barren exposures of the Green River Formation are of considerable interest, as the rare
plants known to occur within the Piceance Basin all occur on Green River shale barrens.

The baseline survey area associated with the R&D site has an elevation range between 6,460 to
7,100 feet. In the Piceance Basin, these elevations are dominated by the pinyon-juniper
woodlands along the ridge tops with a few intermingled Wyoming sagebrush/grass parks. The
bottoms of larger upland drainages generally have shallower soils supporting pinyon and juniper.
Lower slopes of these upland drainages usually have deeper soils which generally support a
Wyoming sagebrush/grass plant community.

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6.3 Wildlife

Between 2004 and 2005, SWCA Environmental Consultant biologists conducted wildlife
surveys within a 2,225-acre study area. The OST area was included within that larger study area.
Between the two years of wildlife investigations, a total of 36 species of birds were observed
within the area. Of the 36 species, twelve are nesting species obligately associated with pinyon-
juniper/sagebrush shrubland communities within this area including black-chinned hummingbird
(

Archilochus alexandri

), ash-throated flycatcher (

Myiarchus cinerascens

), gray flycatcher

(

Empidonax wrightii

), western scrub-jay (

Aphelocoma california

), pinyon jay (

Gymnorhinus

cyanocephalus)

, juniper titmouse (

Baeolophus ridgwayi

), bushtit (

Psaltiparus

minimus)

Bewick’s wren (

Thryomanes bewickii

), blue-gray gnatcatcher (

Polioptila melanura

), black-

throated gray warbler (

Dendroica nigrescens

), green-tailed towhee (

Pipilo chlorurus

), and

Brewer’s sparrow (

Spizella breweri

Other nesting species noted (20) are more universal in habitat requirements, though still nest
within the general study area, including Cooper’s hawk (

Accipiter cooperii

), red-tailed hawk

(

Buteo jamaicensis

), long-eared owl (

Asio otus

), mourning dove (

Zenaida macroura

), broad-

tailed hummingbird (

Selasphorus platycercus

), common nighthawk (

Chordeiles minor

), northern

flicker (

Colaptes aura

), plumbeous vireo (

Vireo plumbeous

), black-billed magpie (

Pica

hudsonia

), violet-green swallow (

Tachycineta thalassina

), mountain chickadee (

Parus gambeli

white-breasted nuthatch (

Sitta carolinensis

), rock wren (

Salpinctes obsoletus

), mountain bluebird

(

Sialia currucoides

), hermit thrush (

Catharus guttatus

), Virginia’s warbler (

Vermivora

virginiae

), chipping sparrow (

Spizella passerina

), vesper sparrow (

Pooecetes gramineus

), house

finch (

Carpodacus mexicanus

), American goldfinch (

Cardueli tristis

). An additional four species

were observed as fly-overs, and may or may not nest within the immediate project area,
including turkey vulture (

Cathartes aura

), cliff swallow (

Hirundo pyrrhonota

), red crossbill

(

Loxia curvirostra

), and pine siskin (

Carduelis pinus

A total of nine species of mammals or signs of occurrence were observed within the general
study area during SWCA surveys. These included an unidentified bat, cottontail (either

Sylvilagus nuttallii

S. audubonii

), least chipmunk (

Eutamias minimus

), Colorado chipmunk

(

Tamias quadrivittatus

), Wyoming ground-squirrel (

Spermophilus elegans

), bushy-tailed

woodrat (

Neotoma cinerea

), coyote (

Canis latrans

), black bear (

Ursus americana

), elk (

Cervus

canadensis

), and mule deer (

Odocoileus hemionus

). The Colorado Division of Wildlife (DOW),

which maps significant big-game habitats, has mapped the project area as mule deer winter
range, though does not map the areas as significant to the elk population. Two species of reptile,
sagebrush lizard (

Sceloporus

graciosus

) and short-horned lizard (

Phrynosoma hernandesi

) were

also observed during surveys.

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No threatened or endangered species were found at the sites. A Cooper’s hawk nest (BLM
sensitive species) was found in 2003 and another in 2005 inside of the OST site. The nest located
in 2003 was about 20 feet up in a pinyon snag within a moderately open stand that contained
many large, mature trees. Although there were a few streaks of whitewash on the ground under
the nest, the nest was in disrepair and there were no feathers, egg shell fragments, prey remains,
or casting that would indicate the nest was used in 2003. The nest found in 2005 was located
north of the nest found in 2003. It was an active nest with one chick present. The nest was
located in a pinyon pine tree approximately 12 feet above ground. The nest previously located in
2003 was not seen during the 2005 survey. No raptor nests were located within the north access
corridor to the OST site.

Seven raptor nests were found outside the project areas during surveys from 2003 to 2005. Three
of the nests were actively being used by Cooper’s hawks during the years they were recorded,
with another nest having failed in 2005. An inactive Copper’s hawk nest was found near an
inactive red-tailed hawk nest in 2005. Another inactive red-tailed hawk nest (BLM species of
concern) was mapped in 2003 within the project area. Red-tailed hawks were observed but no
active nests were found near the project area. A day-roost used by long-eared owls (BLM species
of concern) was observed and mapped in 2005.

Five primary habitat types were identified and mapped. Based on habitat composition within the
project area, known habitat affinities, and records of species occurrences, one federally listed
threatened species, the bald eagle (

Haliaeetus leucocephalus

), and three BLM sensitive species,

the Great Basin spadefoot (

Spea intermontana

), midget faded rattlesnake (

Crotalus oreganos

concolor

), and milk snake (

Lampropeltis triangulum

) may occur within or near the project area.

Although suitable habitat is present, no T&E species were located during the survey. One BLM
listed sensitive species was spotted during the survey.

6.4

Cultural and Paleontology Resources

The cultural resource survey investigated prehistoric occupation and use of the drainage-
bottom/ridge-top, pinyon-juniper habitat of the Piceance Basin region. During the inventories,
the newly and previously recorded resources indicate that this area was intensively occupied
during the Protohistoric Era. Additional inventories in the immediate vicinity support this
conclusion.

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Several of the recorded historic sites located in and near the project area are brush or drift fences.
Unrecorded are the numerous evidences of juniper post-cutting activities that were present
throughout the area.

A relatively low count of prehistoric artifacts were found during the survey, compared to many
other regions of western Colorado. This is consistent with the University of Denver inventory
and an inventory of an adjacent federal sodium lease area. The prehistoric sites revisited during
surveys have been previously classified as open lithic scatters based upon the low artifact/feature
counts. Inferred activities at the sites are generally tool manufacture and/or maintenance. All of
the prehistoric sites and isolates are within the pinyon-juniper forest.

In the southwest corner of Section 36 T1S, R99W (on the west side of the unnamed tributary to
Corral Gulch), and facing the OST site, is a 250-foot high cliff of massive fluvial sandstone of
the Eocene Uinta Formation. It is probable that this unit covered the entire project area prior to
the erosional cycle that shaped the present landscape. Because of the lack of exposures of
bedrock, only a limited paleonotolgical survey of the OST site was conducted. No fossils were
found.

6.5 Climate

Climate of the R&D site is similar to a semi-arid steppe region. High mountains surrounding the
northwest Colorado region deflect many migratory low-pressure systems around the region.
Stationary high-pressure cells often persist for days, their passage blocked by the Continental
Divide to the east. As a result there is a high frequency of clear sunny days with light winds and
large diurnal temperature changes. Gradient winds are generally westerly, existing throughout
the year, except when interrupted by the passage of frontal systems. Surface winds tend to be
from the southwest, following the axis of the ridges and gulches.

Precipitation is about 12 inches annually, occurring throughout the year in winter snow showers
and summer thunderstorms. Wettest months are March through May with September through
October being fairly dry. The dry air and lack of activity in the area provide excellent visibility in
general.

Lightning during summer thunderstorms is a significant problem due to the high elevation and
exposure on the mountain ridges. Wildfires (grass fires) do occur during the dry season.

Ambient temperatures have been recorded as low as –20ºF in winter. Summer temperatures
rarely exceed 85ºF. A diurnal change of 30 – 40ºF is common.

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6.6 Visual

The project area includes areas that viewers may travel through or recreate in. The project area
is, according to the White River Resource Management Plan, within a Class III Visual Resource
Management (VRM) area. These areas are intended to partially retain the existing character of
the landscape. The temporary level of change to the characteristic landscape should be moderate.
Management activities may attract attention, but should not dominate the view of the casual
observer. Changes should repeat the basic elements found in the predominant natural features of
the characteristic landscape (BLM 1986)

. Prior to project start-up Shell will consult with the

responsible Land Manager regarding additional work on visual assessment.

6.7 Hydrology

Surface Water

The OST site is located in the headwaters of the White River watershed, a tributary of the Lower
Colorado River. The OST facilities are located on a ridge between Stake Springs Draw to the
south, and Corral Gulch to the north, tributaries of Yellow Creek, an intermittent stream flowing
north to the White River. Stake Springs Draw and Corral Gulch are also intermittent, with short
reaches of perennial flow in association with springs and seeps.

Springs and seeps near the OST site (with the possible exceptions of two at Yellow Creek)
discharge from alluvial sediments near the floor of the stream channels in the major drainages.
The alluvial ground water systems that support streams and springs in the study area are likely
recharged from higher-elevation regions to the west along Cathedral Bluffs, where precipitation
and the potential for ground water recharge is greater. Alluvial ground water systems in the
major drainages, which are underlain by very low-permeability bedrock, likely act as conveyance
mechanisms for water from recharge areas to the west to discharge areas in lower-elevation
regions to the northeast. This is further substantiated by the fact that there are no springs or seeps
(bedrock or colluvial) that discharge from the hillsides along the margins of the drainages.
Similarly, there is no water in the ephemeral surface water drainages in the upland areas between
the major drainages. This suggests that discharges from springs in the channel bottoms in the
major drainages are likely from alluvial ground water systems. The alluvial ground water
systems in the major drainages do not appear to receive appreciable recharge from bedrock
ground water systems adjacent to the major drainages in the area.

The water quality of the surface waters is typically a magnesium sulfate, with moderate salinity
levels and high hardness. Periodically, elevated levels of iron, selenium, and sulfide are

Bureau of Land Management,

Visual Resource Inventory

(BLM Manual – Handbook 8410-1, 1986).

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observed. Sampling at springs identified reduced dissolved oxygen levels that would
compromise aquatic life. As water flowed downstream, however, normal oxygenation from
turbulence increased dissolved oxygen to acceptable concentrations. The mainstem of Yellow
Creek, including all tributaries, from the source to the confluence with the White River have
stream standards and are classified as usable for recreation (Class 2), agriculture, and Class 2
aquatic life warm. Representative standards for the reach are identified for pH, dissolved oxygen,
fecal coliform, as well as some anion inorganics and metals. Existing water quality is the
standard until the next triennial review (February 28, 2009). Surface water data has been
summarized in a report by Norwest Corporation

Ground Water Quality

Ground water quality has been monitored and evaluated in the vicinity of the project site. Ground
water monitoring well locations are shown on Exhibit P. A brief summary of the ground water
quality is included here.

Water is principally a sodium-rich bicarbonate type where increases in TDS are the result,
principally, of increases in sodium and bicarbonate. The principal variants are substitution of
calcium for sodium and substitution of chloride for bicarbonate. These substitutions occur within
zones and seemingly increase with increasingly deeper hydrostratigraphic zone.

In general, the regional ground water quality of the Uinta and Parachute Creek and Garden Gulch
Members of the Green River strata is of moderately poor quality, using “common” water quality
parameters such as TDS. The data show the presence of a number of “more common” water
quality parameters in concentrations that exceed numeric criteria used to assess the
appropriateness for use of the water. These parameters are TDS, arsenic, barium, boron,
cadmium, chloride, iron, fluoride, and sulfate. These parameters do not necessarily exceed
criteria in each and every stratum. (TDS does exceed the guideline value of 500 mg/L for
domestic water supplies in every case).

There is little use made of the ground water, except that associated with alluvial stream channels.
There is one, 450-foot deep Uinta well near the confluence of Corral Gulch and Yellow Creek
that has a classified use with the Colorado Office of the State Engineer as “Other” and is on Shell
owned land.

Norwest Corporation, Surface Water Resource Evaluation: Oil Shale Test (January 2006).

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The variability of the ground water quality is high. In other words, concentrations vary widely
from location to location, both horizontally (within a permeable stratum) and vertically (from
one more permeable stratum to another). Examination ground water data suggest no discernable
horizontal trends; rather a high degree of variation due to the heterogeneous mineral composition
of the Uinta and Parachute Creek and Garden Gulch Members of the Green River formations.
The data show that water entering the various more permeable strata in areas of recharge appears
to gain a “signature” chemical pattern that remains with that water as it flows from “west to
east,” unless the water encounters a variation in the mineralogy of the particular horizon. The
water quality assessment does confirm a vertical variation that is quasi-predictable; that of
increasing total dissolved solids with depth of the permeable strata. Certain other parameters
mimic this increase, while a few change with depth but decrease in concentration.

The high degree of variability in concentration with no horizontal trend allows combination of
data from various longitude-latitude locations by individual, more permeable stratum. This
heterogeneity facilitates grouping ground water quality parameters by zone. Then, the distinct
changes in water quality with depth as function of the hydrostratigraphy allow additional
grouping of strata into four water-quality-distinct groups, (1) UT, (2) L7-L5, (3) L5-L2, and (4)
L1

. This grouping is generally aligned with the prior characterization of the Parachute Creek

and Garden Gulch Members of the Green River formation ground water system into an “upper”
and a “lower” water bearing zones.

Aquatics

Analysis of data collected in 2001 and 2003 of the Yellow Creek drainage indicates that fish
populations are limited to reaches downstream from a waterfall located close to the confluence of
Yellow Creek to the White River. Macroinvertebrate communities do persist throughout the
Yellow Creek basin. The communities are consistently dominated by very tolerant taxa. Factors
such as sedimentation, unstable fine substrates, very low flows, and elevated TDS concentrations
create conditions that can only be tolerated by certain species. Zooplankton communities were
also dominated by groups that would be expected to be found in nearly any freshwater aquatic
environment.

Observations made in November 2005, indicated that flow and aquatic habitat conditions on
Corral Gulch and Yellow Creek have remained fairly stable over time (that the aquatic
community has not changed from that evaluated and discussed in the analysis of data that was
collected in 2001 and 2003).

Norwest Corporation, 3-4.

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7.0

ENVIRONMENTAL

PROTECTION

PLAN

7.1

Surface Water Management Plan

Surface water drainage has been described in Section 4.2. Waters discharged into surface waters
will be treated to meet specifications of permits. Surface water monitoring will verify
environmental protection measures.

7.2

Ground Water Protection

Extensive ground water protection measures are built into the ICP process. One of the primary
purposes of the freeze wall is to segregate the processing zone from ground water. Water
management and treatment is an integral part of the operation. Ground water monitoring will
verify environmental protection measures.

7.3

Air

Quality

Facilities Emission by Permit

The processing system will have emissions to the air. The process equipment is designed to
substantially control these emissions. The facility emissions will be evaluated to procure all
permits, with associated compliance demonstration requirements prior to construction of the
R&D project. The demonstration requirements may include assurance during the application
process through atmospheric dispersion modeling that ambient air impacts around the project
will meet National Ambient Air Quality Standards (NAAQS).

Fugitive Dust Control

A Fugitive Dust Control Plan will be created for the site in order to control fugitive dust. All
access roads will maintain a good drivable surface and speed will be controlled as necessary.
Where needed, water will be used to suppress dust on roads and disturbed areas.

Control of Wild Fires and Resource Fires

Consistent with BLM guidelines, a fire breach will be constructed abound the site. Should a wild
fire occur within or adjacent to the R&D site, Shell will notify the appropriate agencies and will
provide assistance where feasible for containing and extinguishing the fire.

7.4

Fish and Wildlife

There will be a temporary interruption to fish, wildlife, soils and vegetation within the R&D site.
Impacts to fish and wildlife will be protected by maintaining water quality with the use of
conveyance and containment structures to detain water until its acceptable for release. Wildlife

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habitat will be restored through the reclamation plan which includes planting grasses, forbs,
shrubs and trees. Planting patterns will utilize small clusters of trees and shrubs to serve as seed
sources for adjacent sagebrush/grass lands. These measures are more formerly described in the
reclamation plan.

7.5

Soil and Vegetation

Prior to salvaging soil, sediment control measures will be constructed and all suitable soil
materials salvaged and stockpiled to minimize erosion. Stockpiles will be seeded with fast
growing seeds to minimize disturbance. Following recontouring, salvaged soil will be
redistributed and seeded with BLM approved seed mixes as part of the reclamation plan.

7.6

Health and Safety

Shell will control access to the R&D site. Access points will have signs and markers to alert the
general public. In an emergency Shell will notify local emergency planning coordinators as
directed under SARA as well as any other applicable local agencies.

Shell will have a quality HSE Management System (HSEMS) to ensure this operation protects the
people and the environment. Some elements of that HSE will include a Spill Prevention Control &
Countermeasures (SPCC), Risk Management Planning (RMP), Process Safety Management
(PSM), and an Emergency Response Plan (ERP).

The ERP is designed to train employees and contractors to handle a potential emergency situation
effectively. Shell will maintain the ERP in several key locations as required by applicable
regulations. An “emergency” would be defined as a serious incident that is not part of the normal
operation of the project. The ERP provides an orderly and systematic approach to manage a crisis.

The ERP will include appropriate notification to all regulatory agencies. Any releases which
exceed the reportable quantity (RQ) of hazardous substances as defined by CERCLA will be
reported to the National Response Center and applicable state and local agencies within 24
hours. The facility will appoint an emergency response coordinator.

Any releases of extremely hazardous substances which exceed the reportable quantity, as defined
by SARA, and which leave the site boundary will be reported to state and local emergency
response coordinators. The site SPCC Plan will provide a list of these regulated substances and
appropriate contact information.