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Agency

• Bureau of Reclamation
• Note: Reclamation believes an environmental assessement for a federal water contract is required.

Subcontractors

• Mike Swenson - attorney from Emery County in Orangeville, Utah.

Narrative about the Paradox Basin

Sub-surface brines in the Paradox Formation of eastern Utah can carry trace amounts of lithium carbonate (an inorganic compound of lithium, carbon and oxygen) at depths about 9,000 feet. Another desireable trace mineral includes bromine. Deposits here are below sea level, under extreme pressures, and at temperatures higher than a hot tub.

The Paradox Basin region includes the counties of the "four corner states:" Arizona, New Mexico, Colorado and Utah. Grand County, Utah has the most crustal deformation, which is caused by the dissolution of the underlying salt formations, due to hosting the incised canyons of the Colorado River and its close proximity to the La Sal Mountains, which condenses a significant amount of precipitation from the atmosphere (meteoric water) and dispersed as groundwater and as spring fed surface water.

The Paradox Formation consists of diverse layers of gypsum, anhydrite, and salt, interbedded with shale, sandstone, and limestone. There are geologic traps that contain reserves of petroleum, natural gas, carbon dioxide, and helium.

The Paradox Formation was formed in the Pennsylvania Period near stuctural depressions along the coast of the ancestral Rocky Mountains and the ancestral Pacific Ocean. Very similar to structural depressions such as the Salton Through and Death Valley in California (Basin and Range Province).

Sea level fluctuations were wildly aggressive during that time period. The basins filled with seawater and then evaporated away in at least 33 individual cycles, or until these basins were completely filled with deposits of sea water evaporates.

And then they were buried at depth by subsequent formations (overburden) during the Mesozoic and Cenozoic Eras, which are now being incised and dessicated by the aggressive erosive power of the Colorado River, which is even piercing through the Paradox Formation in Moab-Spanish Valley, Utah, and Cataract Canyon in Canyonlands National Park. This includes a tributary, the Dolores River, adjacent to the eastern slopes of the La Sal Mountains at Paradox Valley, Colorado.

Drilling pads are required to mechanically install steel well casings into a targeted layer of brine, so that fresh water can be injected into the layer to dissolve the brine and bring it to the surface for processing. Anson consultants says that the brine layers they are targeting are already saturated and that injection is not required. We understand this statement to be an untested hypothesis. Additionally, Anson uses the word "replenishment" when discussing the resource zones to be targeted.

Solution mining and solar evaporation ponds to crystallize the desired mineral, is not a new technology. For decades the Intrepid Potash mining company near Moab, Utah has perfected solution mining techniques to extract potash (potassium chloride) from the Paradox Formation and for industrial uses, especially for food production.

What is different about Anson Resource's proposed and untested technology for mineral extraction in the Paradox Basin, is that evaporation ponds are not necessary to remove the processing liquids. They intend to use beads of resin that attract the lithium ions that this process crystalizes. This technology was developed in China and requires a licensing agreement for users such as Anson Resources.

The processing water is then returned to the subsurface with injection wells, which requires the drilling of more well cases and utilizing high pressure pumps, which also is not a new technology, but requires a 10-year operating permit from the Environmental Protection Agency (EPA).

For instance, the Bureau of Reclamation's operating permit in the western Colorado intercepts brine water that seeps into the Dolores River. Reclamation then injects the captured brine at depths of 16,000 feet (the deepest well casings in the world). This facility is located at Paradox Valley, Colorado, which is the name sake (type locality) for the Paradox Formation.

This practice by Reclamation has been recently modified to smaller injection volumes to avoid the hazards of earthquakes. Another public concern is pressurized brine can cause fractures in crustal rocks (hydro-fracking) and this leakage under pressure could contaminate nearby layers of fresh groundwater.

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The serious issues about drilling for rare metals in the Paradox Basin to make car batteries include installing well casings that wobble, warp, buckle and break in geologic formations that resemble toothpaste, rather than durable bedrock.

Also how to avoid accidentally venting hydrogen sulfide gas, natural gas, nitrogen gas, and helium gas into the atmosphere, at the work place, or into the neighborhood.

Not to forget how to avoid mobilizing formation water at depths between 8 and 10 thousand feet that is very stinky and toxic (hydrogen sulfide).

We also think it is important to mention that lithium batteries will not power these operations. What will power and construct the intense extractive operations of Anson Resources is fossil fuels.

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Drilling issues near the Green River in Grand County, Utah.

• Abstract: Office of Scientific and Technical Information. DOE.
• Abstract: Four Corners Geological Society

"The Salt Wash field is located 15 miles southeast of Green River, Utah, in the Paradox fold and fault belt. The field was discovered in 1961 and has produced over 1.3 million bbl of oil and 11.6 billion ft of gas from the Mississippian Leadville LImestone. The average surface elevation is 4,389 ft above sea level, and the depth to the top of the oil production is form 8,500 to 8,914 ft. Salt Wash field is an anticline with over 200 ft of closure on top of the Leadville. The producing zone is in the lower Leadville with intercrystalline and vuggy porosity developed in limestone and crystalline dolomitic limestone. The produced oil is a 50 to 53 API gravity crude with a 40 degrees F pour point. The gas, a mixture of two sources, is predominately nitrogen with some hydrocarbons (>10%) and smaller amounts of carbon dioxide and helium. All of the original wells suffered casing collapse in the overlying Paradox section resulting in their premature abandonment.

Additional undeveloped Leadville reserves may still be present. There may also be undiscovered reserves in the stratigraphically higher Cane Creek shale of the Pennsylvanian Paradox Formation in the Salt Wash field. The field is roughly 12 mi northwest of the Kane Springs unit where Columbia Gas has been completing horizontally drilled wells in the Cane Creek. The State 1-16A in Salt Wash field recovered 600 ft of 52 API gravity crude and no water from a drill-stem test of the Cane Creek. The State 1-16A well in Salt Wash field recovered 600 ft of 52 API gravity crude and no water from a drill-stem test of the Cane Creek. Reverse faulting and recumbent folding combined with structural closure increases the potential for fracture development in the Cane Creek at Salt Wash field."

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