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0 Shell Exploration & Production <br />Ms. Wendy Cheung <br />U.S. EPA Region 8 <br />Mail Code 8P-W-GW <br />Denver, CO 80202-1129 <br />May 11, 2011 <br />Shell Exploration & Production Company <br />3737 Bellaire Boulevard <br />Houston, Texas 77025, U.S.A. <br />P.O. Box 481 <br />Houston, Texas 77001-048 1, U.S.A. <br />Internet http://www.shell.com/ep <br />Response to Comments: UIC Permit Application for Oil Shale RDD Lease COC 69166 <br />Dear Ms. Cheung; <br />Attached are Shell's responses to your initial comments on the Application for a Class III Underground <br />Injection Control Permit for activities on Oil Shale Research, Development and Demonstration (RDD) Lease <br />COC 69166 and Nahcolite Preference Right Sodium Lease C-0120057. <br />Shell has decided to permit two back-up leach wells that are identical in design to the original. <br />Application materials for these wells are included. <br />Reclamation cost estimate for the UIC injection wells are included. A separate UIC application for <br />reclamation of these wells will be submitted at a later date. A copy of the SPCC Plan is included. <br />We understand that you are the EPA-UIC contact. We also understand that the draft UIC permit will be <br />subject to public comment prior to finalization. <br />We look forward to working through these applications with you. Please contact me if you have any <br />questions or if you need further information. <br />Sincerely, r-, <br />Harry H. Posey <br />Senior Production Geologist <br />713-245-7385 Office <br />832-603-7814 Mobile <br />Cc: Dan Whitney, with attachments <br />Jon Sellars, with attachments <br />Paul Daggett, BLM Meeker (w/o attachment) <br />Travis Marshall, DRMS (w/o attachment)