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ÃÃTo:ÄÄÁØ	Ø	ÁDeborah Bartram <Deborah.Bartram@erg.com>
ÃÃDate: ÄÄÁØ	Ø	Á2/4/2004 11:34:27 AM
ÃÃSubject: ÄÄÁØ	Ø	ÁFw: Geo's TechBrief for US Energy Sector

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please post in 304(m) record....thanks!
----- Forwarded by Carey Johnston/DC/USEPA/US on 02/04/2004 11:15 AM
-----
                                                                                                               
                      Aro Arakel                                                                               
                      <a.arakel@geo-process        To:       Carey Johnston/DC/USEPA/US@EPA                    
                      ors.com.au>                  cc:       Js Wilson/R6/USEPA/US@EPA                         
                                                   Subject:  Geo's TechBrief for US Energy Sector              
                      01/20/2004 05:37 PM                                                                      
                                                                                                               




Dear Mr. Johnstone,

Thank you for your email of 16 January 2004 addressed to my colleague
Lance Stapleton. As requested I am forwarding a copy of our expanded
technology brief for U.S. energy sector, for your review.

I have also gone through the content of your Memorandum of 23 December
2003 and below are my comments/suggestions and enquiries:

Factor 1
In most of the Australian cases, the resource companies, utilities and
municipalities approach us after their exhaustive search for produced
water management methods that exclude part or complete treatment steps.
Whether corporate drive or other reasons, they ask us for help after the
stage of identifying the potential adverse impacts of their operations
and/or when they see the potential for implementing a technology that
achieves zero discharge and offsets the costs.

One issue that has generated considerable concern in Australia is the
method of measurement of water quality parameters for meaningful impact
assessment. For example, produced water from CBM sector may range in
salinity but usually has an inherited elevated dissolved HCO3 component
that can not be measured (and therefore can not be assessed) by direct
EC measurement. This is briefly/simply explained in Geo-Enviro
Newsletter No. 5 (please refer to "News" section of our web site).
There are many salinity survey maps and risk assessment reports prepared
in Australia which miss out this point. From our field trials part of
the dissolved HCO3 ion in the produced water brought to surface may be
released to atmosphere as CO2 gas emission. Changes in pCO2 and other
processes operating at air/water interface are the causes of such
release. The adverse impacts on the landscape (due to reaction of HCO3
with Na and Ca elements of clayey soils) is also equally important, and
there are many examples of this in Australia. In fact, we use this
phenomenon to our advantage by reacting the Bicarbonate rich produced
water with reagents to produce high-grade, valuable chemical products in
our treatment systems.

Based on the above single example I think that for the purpose of
establishing the extent of potential adverse impacts/risks (and whether
the development/revision of water quality limitations for oil/gas and
CBM industrial categories would be needed) the existing water quality
measurement guidelines and data presentation methods may need to be
reviewed and if necessary to be developed. From my experience this
should be done at federal level to avoid inconsistency and confusion,
particularly at industry level where our Australian experience clearly
indicates a lack of self discipline and self-regulatory approach. I can
help you with this as I have worked and researched this area for many
years.

Factors 2-4

I invite your review of the information in our TechBrief (attached) in
the first place and also happy to answer any question that you may have
on our technologies and their potential application to various
industry/community sectors' needs, etc. Whereas we are receiving
significant interest from US energy companies it is our desire to first
show case our technologies through a piloting project and public
demonstration process for its broader appreciation and application by US
energy sectors.  Our technologies address both the volume reduction (a
major concern of CBM industry) and pollution prevention aspects (US EPA
concern) of the produced water.

In view of our interest in application of our produced water treatment
technologies for the needs of the US energy sector I would appreciate
receiving your advice/suggestions on whether your organization as part
of its best available technology evaluation and implementation process
would be interested in a proposal from us. As a result of my recent
presentations in USA (Oct-Nov 2003) a very positive dialogue and some
interesting initiatives have been developed since then between our firm
and the US Bureau of Reclamation, a number of local government
authorities in the Southwest and some major engineering firms for
piloting our technologies for industry specific needs (water supply and
irrigation drainage management). I feel that the US oil/gas (and
particularly CBM) industries as well as the regulatory agencies have
already reached a stage requiring a serious look into  the viability of
treatment technologies as an alternative option for sustainable
management of produced water, particularly where the impacts are already
evident and the conventional approaches can no longer address the
sustainability requirements, as expected by the Community and the
Corporate. Most of our treatment systems offer ZLD solutions and I think
that these can be beneficially applied to US energy sectors' needs
through your proposed staged evaluation and implementation process
(Factors 2-4). There would be always cases where discharge to the
hypoxic zone would not be possible because of the potential adverse
impacts; also I strongly believe in market based instruments to promote
efficiency in industry. Therefore, new smart technologies and
technological approaches need to be systematically evaluated and
implemented to ensure the full growth potential of certain industry
sectors, in this case the oil/gas and CBM industries in USA.

To summarize, from our experience, and by considering the volumes
involved, apart from TDS and SAR issues I would suggest that your
organization to also consider the assessment of the fate of dissolved
HCO3 in the produced water cycle, in order to determine the CO2 gas
emission potential from the oil/gas and CBM industries.

I would also appreciate receiving your comments/suggestions on the
possibility of piloting/demonstration of our technologies through an EPA
initiative/program so to make possible the showcasing of our
technologies for the US energy sector.  If your response is positive, we
would then seek support and participation in the evaluation program from
the US companies who have expressed interest in our technologies.
Obviously, at this stage our preference is for systematic technology
evaluation and demonstration process through the EPA and/or DOE for the
benefit of both public and industry.

Best wishes,


Aro Arakel
Director


Date: Fri, 16 Jan 2004 09:02:41 -0500
From: Johnston.Carey@epamail.epa.gov
Subject: Re: Geo-Processors Tech Brief for US Energy Sector
To: Lance Stapleton <L.Stapleton@geo-processors.com.au>
Cc: a.arakel@geo-processors.com.au, Wilson.Js@epamail.epa.gov





Dear Mr. Stapleton:

I am very interested in learning more about your produced water
treatment technology. As you can see from the following document:

http://epa.gov/guide/304m/rationalememo_final.pdf

...we are interested in learning more about produced water treatment
technologies for both conventional O&G extraction as well as for coalbed
methane operations. Please send me your expanded technical brief and let
me know when (if) you are in Washington, DC. Thank you.

Sincerely,

Carey A. Johnston, P.E.
U.S. EPA, Office of Water
ph: (202) 566 1014
fx: (202) 566 1053
johnston.carey@epa.gov(See attached file: Geo_TechBrief-US_Energy.pdf)--



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PO Box 290, Pennant Hills NSW 2120
(Sydney) Australia
Phone: (+612) 96300804; Fax: (+612) 96300603
Web Site: <www.geo-processors.com.au>
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