- 25 - Ham suggests that there were probable reserves on the Utah tar sands properties, but Ham provides no reliable data or support for this assertion. At trial, Ham testified that the Utah tar sands properties had possible reserves. Regarding Burnt Hollow, he speaks vaguely in terms of “secondary reserves” and “a lot of reserves” without any greater precision. Even petitioners' other experts would not agree with Ham on this matter. Neither Austin, Bursell, nor Cayias makes similar assertions or speaks in terms of reserves. In fact, Cayias characterizes Burnt Hollow as “an exploration type risk”. (9) Relying primarily on Bursell's estimates of a 50- percent recovery rate, petitioners dispute our finding that Cromwell's 20- to 70-percent oil recovery estimates were unreasonable. Bursell's 50-percent recovery estimate, however, itself is flawed. Bursell uses a hypothetical viscosity for Burnt Hollow oil of 10,000 cp at 90 degrees Fahrenheit. He then plots this hypothetical viscosity on a laboratory-derived curve correlating viscosity and recovery. Bursell's theoretical viscosity, however, for Burnt Hollow is incorrect. Even at 102 degrees Fahrenheit, the viscosity of the tar at Burnt Hollow was indicated at over 1,000,000 cp. At 90 degrees Fahrenheit, the tar would be even thicker, and the viscosity higher, nowhere near the 10,000 cp that Bursell uses. In making his calculations, Bursell evidently did not have and did not consider the actual data from Burnt Hollow. Factoring in this data on Bursell'sPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011