JS Meyer Engineering PC, Inc. 

Lisa A. Biddle, P.E. 

U.S. EPA, Office of Water 

Office of Science and Technology 

Dear Lisa, 

1635 West I" Street, Suite 300 

Granite City, IL 62040 

Phone: 618-219-4748 

Fax: 618-451-5151 

Thank you for the opportunity to share our new technology with you . I have attached our 

presentation and removed the confidential labels from the slides. I am intending to write an 

article for one of the magazines. The JSM Technology offers a breakthrough with low cost for a 

high quality discharge. I have changed the presentation to answer some of the questions 

presented in our phone conversation on Monday, July 13, 2015. In addition I have added 

comments as to the use of JSM technology on off-shore produced water. 

We have reviewed the proposed "Effluent Guidelines and Standards for Oil and Gas Extraction." 

It is an impressive accumulation of facts and information with which we concur as to its 

compatibility with the knowledge base. We have condensed the information to those items we 

find relative to what we are doing. Rose Migliorini, one of our engineers, prepared a summary 

of key point, attached. Our conclusions are that 

1. The proposed standards do not prevent disposal of UOG produced water from being 

deep well injected. 

2. It places no limits on deep well injections as to volume or concentrations. 

3. It does not apply to privately owned waste water treatment plants to which other 

standards apply. (40 CFR part 437). 

4. It does not address the guidelines with off shore disposal of produced water. 

Deep well injection is not necessary, when JSM technology is used. There is a risk when the 

produced water is deep well injected. Injection of an incompressible fluid into an 

incompressible rock layer can produce an incompatible situation. Fractures into clean water 

aquifers are theoretically possible, either through fissure or pipe failure. Use of the JSM effluent 

for road salt or chlor-alkali feed eliminates this need. The collection of the metals in a fixed 

state would provide for safe disposal into one ofthe several secure landfills which can be 

monitored for adverse conditions. Accidental contamination of an aquifer with high salt 

produced water would compete with the LOVE Canal disaster. It could take centuries to clean 

up a spill at 6000 ft. in one of the clean water aquifers. 

One area the proposed standards do not address is the disposal of off-shore produced water. 

believe that the JSM technology can be used to produce an effluent stream compatible with the 

ocean environment. The greatest risk to the aquaculture is the heavy metals. The JSM 

technology can remove these to acceptable levels. 
JS Meyer Engineering PC, Inc. 

1635 West I st Street, Suite 300 

Granite City, IL 62040 

Phone: 618-219-4748 

Fax: 618-451-5151 

1 believe we should continue to improve our refuse disposal where practical. The proposed 

standards for disposal of produced water do not require any improvement ofthe liquor prior to 

deep well injection. It is not practical to attempt to convert everyone to the best achievable 

technology all at once. However, I believe that we can start on the long term produced water 

which is the nastiest. Regulations requiring some form of staged improvements are not only 

practical but needed. The addition of a government fee on deep well injection earmarked for 

long term improvements can be used to make the program income neutral. 

Sincerely, 

JS Meyer Engineering, PC 

1635 W l 5

t St Suite 300 

Granite City, 1162040 

618-219-4748 Direct 

618-444-3051 Cell 

~E ... .