2011-05-12_PERMIT FILE - P2010026 (3)

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3.0 ENVIRONMENTAL MONITORING COMPONENTS The environmental monitoring program is designed to characterize flow and water quality of ground water in an area of interest of the Pilot. The two components of the environmental monitoring are to establish ground water baseline chemistry prior to Pilot activities and to monitor water quality in the WBIs during and after the project activities. Ground water quality baseline is established with at least 5 quarters of water quality measurements, per Colorado Mined Land Reclamation Board (MLRB) Regulations. The up and down gradient water quality of each WBI above the Pilot has been established utilizing a number of wells regionally, and will be established locally prior to leaching and pyrolysis activities. There are currently four quarters of monitoring data for the Uinta, L7, L6, and L5 WBIs at the 138-4-298 hydrology pad, and 2 quarters of baseline for the L4 well. As established with Shell's previous pyrolysis prospecting projects, only a few inorganic parameters have the potential to be affected by pyrolysis, and several organic compounds are generated by pyrolysis. For monitoring purposes after establishing baseline for the several inorganic compound, it is proposed that the inorganic parameter TDS be measured directly; whereas the organics are best represented (after establishing baseline for the full EPA SW846 8260 and 8270 target list of volatiles and semi volatiles) from the indicator organic compounds benzene, toluene, ethylbenzene, and xylene (BTEX). 3.1 Ground Water Monitoring and Response The 135-4-298-L4 well is being installed to establish baseline water quality close to the proposed leach/pyrolysis pattern, and to serve as an "early warning" well to gauge potential impacts from the project prior to their reaching the 138-4-298 well pad that is located farther down gradient. The 135-4-298-L4 monitoring well is to be drilled approximately 60 ft downgradient (northeast) of the Pilot in April 2011, and at least 5 quarters of baseline data will be gathered prior to any activities that might affect ground water quality. Table 1 presents a list of baseline water quality parameters. Additionally, continuous temperature and water level measurements will be taken using transducer monitoring at the 135-4-298-L4 well during leaching and pyrolysis activities (V-monitor or Pi tie in - 1 min. data logging). Monthly water quality samples for TDS and BTEX (BETX only during and after heating) will be collected during the active phase of project leaching/pyrolysis, and cooling. Quarterly samples will be collected for 2 years after project completion for TDS and BTEX and the results will be reported annually unless anomalous condition occurs. Shell has implemented quarterly ground water quality baseline monitoring at the down-gradient 138-4-298 Pad wells. This includes well completions in the Uinta, L7, L6, L5 and L4 water bearing intervals. The L3 water bearing interval is not present near the East RDD project as it is precluded by the presence of nahcolite of the Saline Zone, which has not been leached away to form an L3 hydrologic unit. These compliance wells will be sampled during Pilot activities, quarterly for one year after Pilot activities, and annually for two additional years to assure no ground water impacts. Water levels from scope and transducer data will be recorded at a frequency 1/minute and downloaded at least monthly to conduct a visual analysis for anomalies. Data will be reported yearly, unless upset conditions are encountered, in which case a reporting schedule will be worked out with EPA and other involved agencies. Anomalous analytical results are defined as follows: • 1.25 times above the 85th percentile established background TDS value, • Any value above the regulated value for benzene (5 ug/L). EAST RDD ENVIRONMENTAL MONITORING, SAMPLING AND ANALYSIS PLAN 6