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be subjected to slight heating from the leach /heater zone. The modeling results indicate that under these circumstances, the potential overstressed zone In the overburden rock does not extend more than 10 feet into the crown, leaving more than 100 feet of stable rock above. Shell considers both assumptions to be conservative during the leaching phase. During this phase the oil shale and nahcolite structure that remains in place will provide formational support, reducing the risk of subsidence. Also, during the leaching phase, the pyrolysis heaters will not be used. During pyrolysis, the amount of residual structural strength that will exist in the rock will depend on the original composition and fabric of the strata. Dense maristone that contains no nahcolite or oil shale will be unaffected by teaching and heating, and so will remain competent for load bearing. Groundwater Monitoring Program The Sampling and Analysis Plan For: Environmental Water Quality Monitoring East Research, Development, and Demonstration Lease dated May 2011 will be incorporated into the UIC area permit by reference. The document includes the sampling protocol and analytes to be tested. This document may be revised and updated in the future. Shell has a established a network of monitoring wells in the 138 -4 -298 well pad,•to monitor groundwater quality and piezometric pressures down - gradient of the RDD Project Site. These groundwater quality monitoring wells collect samples from the Uinta, L7, L6, L5, and L4 hydrostratigraphic WBi units. Shell has collected 4 -5 quarters of monitoring data from these wells, and will have collected 5 quarters of monitoring data prior to any injection activities. Shell has also Installed an additional monitoring well, 135 -4- 298 -L4, that is considered a near -field monitoring well to gauge potential impacts from the project prior to their reaching the 138 -4 -298 well pad that is located further downgradient. The 135 -4- 298 -L4 monitoring well is approximately 60 feet downgradient (northeast) from the RDD Project Site and at least 5 quarters of baseline data will be obtained prior to any injection activities. PART VII. Additional Wells to Area Permit Additional new injection wells may be added to the area permit as 'necessary pursuant to 40 CFR §144.33, provided the Permittee provides notice to the Director. The Director periodically will review the cumulative effects pursuant to 40 CFR §144.33 and advise the Permittee .oLany.. required changes - to or mine operations. All sections of the area permit apply to additional well(s) approved for injection. Additional requirements beyond those described in this permit may be required for additional wells that will be included in this area permit. Shell has submitted a conversion plan for the 01301 and OB03 wells in the event that these wells need to be converted to injections wells to achieve the desired uniform radial dissolution pattern. Any changes to the construction or plugging and abandonment plans must first be approved by the Director and the Permittee shall not begin construction or conversion of the well(s) of the plan until after receiving written authorization from the Director. PART VIII: Plugging and Abandonment Requirements (40 CFR §146.10) Plugging and Abandonment Plan Prior to abandonment, the inert gas used to create the gas cap will be collected at the surface and properly disposed. Additional logs and tests provided in Appendix B will be required. The Injection and production tubings will be pulled from the welibore and a Cement Bond Log or Cement Permit CO3221(1-00000 17 Statement of Basis