## JS MeyerEngineeringPC, Inc.

Lisa A. Biddle, P.E . U.S. EPA, Office ofWater 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 opportunityto share our newtechnology with you . I have attached our presentation and removed the confidential labels from the slides. I am intendingto write an article for one ofthe magazines. The JSM Technology offers a breakthrough with low cost for a high quality discharge. I have changed the presentation to answer some ofthe questions presented in our phone conversation on Monday, July 13, 2015. In addition I have added comments as to the use ofJSM 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 offacts 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 ofour 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 applyto privately owned waste watertreatment plants to which other standards apply. (40 CFR part 437). 4. It does not address the guidelines with offshore 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, eitherthrough fissure or pipe failure. Use ofthe JSM effluent for road salt or chlor-alkali feed eliminates this need. The collection ofthe 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 ofan 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 ofthe clean water aquifers. One area the proposed standards do not address is the disposal ofoff-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.

## JSMeyer EngineeringPC, Inc. 1635 West Ist Street, Suit e 300 Granite City, I L 62040 Phone: 618-219-4748

Fax: 618-451-5151 1believe 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. Since rely,

JS Meyer Engineering, PC 

### 1635 W 

### l 5t St Suite 

### 300 Granite City, 

### 1162040 618-219-4748 Direct 

### 618-444-3051 Cell 

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