- 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's
Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: May 25, 2011