May 1, 2014

Heckman Water Resources, Inc.

300 Cherrington Parkway, Suite 200

Coraopolis, PA 15108

To Whom It May Concern:

RE: Stabilization of brines and other waste substances

Heckman Water Resources, Inc. is receiving this letter because Heckman Water Resources, Inc. has been issued Chief’s Order 2014-13 to store, recycle, treat, or process brine or other waste substances pursuant to R.C. 1509.22. Division (C)(1) of R.C. 1509.22 states that brine from a horizontal well can only be disposed of by injection into a Class II injection well, in association with a method of enhanced recovery, or in a manner approved by a permit or an order issued by the Chief that authorizes an alternative method of brine disposal. If wastes containing amounts of brine are being solidified with compressible bulking agents, such as sawdust or auto-fluff, the use of such bulking agents may release brine when the waste is transported and/or placed in a landfill. In order to eliminate the release of brine during transportation or placement in a landfill, liquid and semi-solid oil and gas wastes that contain free liquids must be stabilized with Portland cement, quick-lime (CaO), and other materials that may be approved by the Chief. Stabilization with these agents binds the liquid waste component to the stabilizing agent resulting in a stable solid that passes the paint filter test.

All facilities that are operating under a Chief’s order authorized under R.C. 1509.22 must ensure that all oil and gas wastes are stabilized with agents as referenced above.

Please note that the above process does not eliminate the responsibility to test for levels of radium 226 and radium 228 in all technologically enhanced naturally occurring radioactive material (TENORM), pursuant to R.C. 1509.074.

Sincerely,

Richard Simmers

Chief, Division of Oil and Gas Resources Management