MEMORANDUM

TO: Brian D’Amico, EPA/EAD

Lisa Biddle, EPA/EAD

FROM: Meghan Camp , ERG

Brent Ruminski, ERG

DATE: 07 March 201 2

SUBJECT: Notes on Meeting with Lamnipipe Inc. on 8 February 2012

On 8 February 201 2 , EPA met with Lamni pipe

, Inc. to discuss their technology for removing radionuclides from shale gas wastewater. ERG participated by phone. The topics

discussed included:

 Introductions ;

 Background;

 Patent o verview ; and

 Follow up

.

Attachment 1 lists the meeting participants

. Attachment 2 is a presentation provided by Lamnipipe prior to the meeting

.

Introductions

Don Nevin ( President

, CEO ) of Lamnipipe Inc.

, and inventor of the process, and Fred

Eames of Hunton and Williams LLP participated in the meeting. Lamnipipe Inc. owns two pending patent s for the technology discussed . On June 19, 2011, the U.S. Patent Office published the application for the patent s
, but they have not yet been issued

. Mr. Nevin noted that the patent

proce s s can take more than four years

.

Background

Mr. Nevin described how he created Lamnipipe

. A few years ago, he bought an

abandoned factory in a small town east of Bingham t on , New York and also became aware of hydraulic fracturing . He learned that his factory had two large industrial water wells, which because of their age

, were permitted for supplying water for oil and gas operations. Mr. Nevin

decided to sell his well water to local gas well operators who needed make up water for wel l testing and hydraulic fracturing. Mr. Nevin also started looking into problems related to hydraulic fracturing

, including radionuclides brought to the surface with shale gas extraction

wastewater

.

In oil and gas operations, companies are required to di spose of materials that reach the

surface , not materials that remain underground. Therefore, Mr. Nevin developed a concept forMemorandum

07 March 2012 Page 2 of 6 treating hydraulic fracturing flowback using DOWEX ion exchange resins within the well to

remove radionuclides before the wastewater reaches the surface

. 1 The novelty in the idea is that the process takes place below the earth’s surface and the radionuclides removed by the process remain underground

. To keep the removed radionuclides underground, the resin is applied to pipi ng and proppant, which will contact the wastewater before it flows the surface , but the proppant remains underground

. Mr. Nevin explained that removing the radionuclides below the surface eliminates the possibility of spills or accidents during disposal of treatment residues

downstream of the extraction process that could result in environmental releases of radioactivity ( e.g., truck

- hauling wastewater for disposal )

. Therefore, Lamnipipe claims that this technology has potential to decrease the threat to the environment and health human health by keeping the radioactive material in the ground.

According to Mr. Nevin , the underground treatment would also reduce potential for radioactivity

- contaminated metal to enter the stream of commerce. He explained th at above

ground piping and other equipment can be melted down and used to make other products, such as pipes or chains. As a result, above

- ground equipment used by the oil and gas industry can become a part of materials used by the general public (e.g., re creational equipment such as chains for swings) , resulting in potential exposures to radioactivity if this equipment is

contaminated with radionuclides.

Patent Overview

Lamnipipe owns two pending patents: Lamnipipe and Lamniproppants. Mr. Nevin

confirmed that neither Lamnipipe nor Lamniproppants have been used on any well to the best of his knowledge. He stated that the DOWEX resin has been used in conventional ion exchange treatment operations for other industries, but was not sure how the wast ewater matrix compares to oil and g as wastewater

.

For Lamnipipe, the resin is applied to the surface of the well casing already in the well. The application process requires the use of a “pig” that is sent down the hole to paint the pipe

with resin 2

. Mr. Nevin noted that the pig is an existing technology he believes can be easily retrofitted to apply the resin to the well casing

. 3 However, Mr. Nevin did not confirm or point to documentation that a pig has been used for this specific application. Using an estimate of

radionuclide loads in flowback, Mr. Nevin estimated that resin would need to be applied to approximately 500 to 600 feet of the pipe

. The removal process occurs as the wastewater flows up the well and contacts the treated piping.

For Lamni proppants, the resin is applied to the surface of the proppant used for the fracturing job

. 4 Mr. Nevin explained that the application of resin to the proppant would likely take place during proppant manufacture

. Compared to the Lamnipipe concept, Lamniproppants

1 Ion exchange is a wastewater treatment process that uses resins to remove pollutants from wastewater and replace them with particles that purify water.

2 Mr. Nevin noted the use of the DOWEX resin from Dow Chemical Company. He proposes using 100 mesh resin as opposed to the standard 16 mesh in order to increase exposed surface area 8 fold.

3 The term pig stands for pipeline interventio n gadget. It is typically used to remove undesired materials from pipelines.

4 A fracturing job typically requires 200,000 pounds of proppant but can vary well to well.Memorandum

07 March 2012 Page 3 of 6 provide greater surface area and contact time with the contaminated wastewater , which should

increase removal efficiency.

Included in attachment 2 is Mr. Nevin ’s computation of rad ioactivity removal efficiency using Lamnipipe in a natural gas well. Mr. Nevin noted that his calculations were “back of the hand” estimates for the purpose of creating some ballpark figures. His calculation claims that Lamnipipe is capable of reducing radi oactivity from 1,000 picocuries per liter ( pCi/L ) to 5 pCi /L

, using the f

ollowing assumptions:

 Well uses 5 million gallons of water for fracturing job;

 Entire volume of wastewater returns to the surface with 1,000 pCi/L of radioactivity ;

 Well total radioactivity is therefore approximately 2 x 10 10 pCi;

 Ion exch ange resin loading rate of 100 nanocuries per gram ( nCi/gm ) of resin;

 1,000 pounds ( lbs ) of resin required (220 lbs actually required x 4.5 for a conservative estimate); and

 Final average concentration of radioactivity of wastewater over the lifetime of the well would be 5 pCi/L assuming the resin’s capacity is used entirely.

Mr. Nevin acknowledged that this computation is only a ball park and many different scenarios are possible. He stated that the typical proppant weight for a we ll is 200,000 pounds. Therefore, only a small portion of the proppant would require coating. He also estimate d that the

above scenario would cost the operator about $10,000 dollars including the cost for application

.

Mr. Nevin and EPA discussed some of t he practical considerations for implementing this technology:

 Surface Area Contact: Mr. Nevin stated that surface are a contact will have a large impact on the effectiveness of this treatment process. Therefore, he recommends installing disruptors in the p iping. EPA noted that Lamnipipe would need to demonstrate that the disruptors do not hinder the flow of gas to the well surface and decrease production. Wastewater contact times required to achieve removals

were not discussed.

 Regeneration: Mr. Nevin state d that the DOWEX resin is “one shot” and cannot be regenerated. According to Mr. Nevin , this makes it a good match for hydraulic fracturing since flowback is a one

- time occurrence . Resin capacity was calculated to be greater than the amount of radi o nuclide s in flowback.

 Produced Water: EPA noted that Mr. Nevin ’s calculations were based on the

amount of radio nuclides in flowback. However, it did not account for produced water, which according to data that EPA has reviewed, contains higher

concentrations of radio nuclides

. Mr. Nevin stated that, depending on the amount of produced water expected for the formation, operators can use excess resin to

account for the radio nuclides in the produced water.

 Coating: EPA also noted that Lamnipipe would need to look into whether the pipe coating could result in increased scaling. Mr. Nevin also stated that operatorsMemorandum

07 March 2012 Page 4 of 6 would likely need to find a way to protect the pipe coating when the hydraulic fracturing fluid (containing proppant) is injected under high pressure.

Follow Up

Mr. Nevin asked if EPA has any suggestions for reaching out to industry or having this technology considered for the rulemaking. EPA made the following suggestions :

 Ask Dow Chemical Compan y for performance data on the DOWEX or other relevant resins. EPA clarified if provided to EPA, this information can be

maintained as Confidential Business Information. Any specifications of the DOWEX or relevant resins would also be helpful.

 C onduct bench scale testing on shale gas wastewater using the technology to

demonstrate its applicability

.

 Determine how the chemical matrix of shale gas wastewater may affect resin performance.

 Communicate with industry to answer some of the following questions:

 If used as pipe coating, how susceptible is it to scaling?

 If used as pipe coating, how susceptible is it to erosion from proppant during fracturing?

 If used as pipe coating, how would it affect the flow of gas and

wastewater ?

 If used as proppant coating, ho w would change in size a ffect the fracturing job?Attachment 1

Table A

- 1. List of Meeting Participants

Name Affiliation Phone Email

Don Nevin Lamnipipe 800

- 656

- 8075 don@mailbdm.com

Fred Eames Hunton & Williams 202

- 778

- 2245 feames@hunton.com

Brian D’Amico US EPA 202

- 566

- 1069 Damico.Brian @epamail.epa.gov

Lisa Biddle US EPA 202

- 566

- 0350 Biddle.Lisa@epamail.epa.gov Meghan Camp ERG 703

- 633

- 1684 meghan.camp@erg.com

Brent Ruminski ERG 703

- 633

- 1701 brent.ruminski@erg.comAttachment 2 Lamnipipe Presentation