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1 1 <br /> > 1 <br /> j 1 <br /> AOUATECH <br /> seawces. <br /> INCORPORATED ROBERT F LOWES, President <br /> January 12, 1987 <br /> Environmental Protection Agency <br /> Office of Solid Waste <br /> Special Waste Branch <br /> 401 M Street S.W. <br /> Washington, D.C. 20460 <br /> Attention: Mr. Robert Hall <br /> Room 2627, Mail Stop 565 A <br /> Subject: Alternative Technology <br /> Disposal of Brines Generated with Oil & Natural Gas Production <br /> Gentlemen: <br /> Section 8002 (M) of the Resource Conservation and Recovery Act (RCRA), 42 <br /> U.S.C. 8982 (M), requires EPA to study the adverse affects of produced <br /> waters associated with the production of oil and natural gas on human health <br /> and the environment. Additionally, EPA is required under a consent decree <br /> (Alaska Center for the Environment vs. Lee Thomas) to submit a final report <br /> to Congress by August 31, 1987. Part of this report is to include a <br /> technical section in which EPA is to address a number of subjects, to <br /> include the following: <br /> A. Alternatives to current disposal methods. <br /> B. Costs of such alternatives. <br /> C. Impacts of these alternatives on the exploration and production of <br /> oil and natural gas. <br /> In October, 1986 a draft report entitled, "Pechnical 'Report Wastes from the <br /> Exploration, Development and Production of Crude Oil, Natural Gas, and <br /> Geothermal Energy" was published. Part 1, Chapter 3 of this report deals <br /> with the procedures and costs of alternative disposal techniques. <br /> Aquatech Services, Inc. (ASI) has developed proprietary evaporation tech- <br /> nology which offers a cost effective means of disposing of brine production <br /> from oil and gas wells in California. This technology has been successfully <br /> demonstrated at two sites in northern California. One site handles 400 <br /> barrels/day, the other 250 barrels/day. ASI is offering this technology to <br /> the marketplace under terms which, in many cases, meet or beat competitive <br /> costs of disposal through commercial injection wells. Assuming costs of <br /> producer owned injection wells are commensurate with costs of commercial <br /> injection wells, this technology offers a viable economic and technical <br /> r alternative to oil and gas operators for a significant percentage of the <br /> AOUATECH SERVICES, INCORPORATED P.O. Box C ;x257 EI Toro, California 92630 (714) 859-1194 <br />