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MEMORANDUM

TO: Public Record for the 2010 Effluent Guidelines Program Plan EPA Docket Number EPA-HQ-OW-2008-0517 (www.regula tions.gov)

FROM: Carey A. Johnston, P.E.

USEPA/OW/OST ph: (202) 566 1014 johnston.carey@epa.gov

DATE: 27 July 2010

SUBJECT: Summary of EMIT Water Discharge Technolog y (an Exterran Company) held on

18 February 2010

The U.S. Environmental Protection Agency (EPA) is c ollecting a variety of technical, financial, and environmental data as part of EPA’s detailed st udy of the coalbed methane (CBM) extraction sector ( http://www.epa.gov/guide/cbm/ ). EPA is collecting information on available techn ologies used for CBM produced water. This memorandum summar izes an 18 February 2010 teleconference with EMIT Water Discharge Technology (EMIT).

EMIT staff briefly described the history of the com pany. Founded in 2002, EMIT licenses Higgins Loop Continuous Countercurrent Ion Exchange (CCIX) Technology from Severn Trent Services, and applies the CCIX technology to CBM pr oduced water.

EMIT staff described a system designed for treatmen t of sodium bicarbonate water that produces less than 1 percent brine volume, is efficient and robust, and performs with runtimes greater than 99 percent. EMIT staff described the system as tur nkey, automated, and modular in nature (i.e.,
units are identical in size and additional units ar e added to meet flow requirements (EMIT staff described set up within 90 days)).

EMIT staff reported that they have deployed 25 unit s, primarily in the Powder River Basin (PRB) (Wyoming and MT). Emit has also deployed unit s in the Atlantic Rim area of the Greater Green River Basin (Southwest WY) and one unit in Co lorado. EMIT staff stated that they have treated close to 360 million barrels of water, and that they are largest treatment company in the
PRB in both the volume of water treated and the num ber of units deployed. EMIT staff reported units treating as little as 6,000 bbls/day, and tha t they recently completed a 125,000 bbl/day
treatment system.

EMIT staff confirmed that there are three primary i nputs needed for system design:

1) Flow rate and duration of water treatment; 2) Water quality; and, 3) The discharge standard.Page 2

EMIT requires a complete water characterization (ca tions, anions, metals, hydrocarbons) in order to determine the treatment and pretreatment necessa ry (e.g., pretreatment is necessary if oil & grease if present).

EMIT staff stated that for the PRB standards that t hey have been requested to evaluate, they have
been able to treat water to those standards. EMIT s taff noted that they may need to add gypsum to meet sodium adsorption ratio (SAR) requirements. EMIT staff also described that they have enough experience and data to accurately model how their treatment systems will perform for given water characteristics. EMIT has a wealth of performance data to use in predictive modeling because they regularly sample incoming and outgoing water from their systems (as well as some intermediate water sampling).

EMIT noted the sensitive nature of their cost data but shared that they contract to treat a range of water quality and that the contract is also based o n the quantity of cations removed. EMIT does require a minimum fee or water quantity requirement s under their contract requirements. EMIT also noted that they consider monitoring data as se nsitive customer data.

Participant Information

Carey A. Johnston, P.E. Paul Hanson U.S. EPA, Office of Water PG Environmental LLC (U S EPA Contractor) ph: (202) 566 1014 607 10th St, Suite 307 fx: (202) 566 1053 Golden, CO 80401 johnston.carey@epa.gov Phone: 303 279-1778

Douglas Beagle Brian Barrett Manager, Business Development Manager, Operations EMIT Water Discharge Technology EMIT Water Dischar ge Technology
2665 Aviation Drive
P.O. Box 6795 Sheridan, Wyoming 82801
+1.307.675.5135 - direct
+1.307.673.0807 - fax
+1.307.752.4196 - mobile Doug.Beagle@Exterran.com