MEMORANDUM

TO: Brian D’Amico, EPA/EAD

Lisa Biddle, EPA/EAD

FROM: Meghan Camp , ERG

Besty Bicknell, ERG Brent Ruminski, ERG

DATE: 0 9 January 201 2

SUBJECT: Notes on Conference Call with 212 Resources on 4 January 2012

On 4 January 201 2 , EPA held a conference call with 212 Resources to discuss evaporation and distillation technology

. Discussion topics included:

 Introductions ;

 Origin of Technology;

 Installation Locations; and

 Technology Description

. Attachment 1 lists the meeting participant s

. Attachment 2 is the power point presentation provided by 212 Resources.

Background on 212 Resources and the Origin Evaporation Technology
Three representatives from 212 Resources participated on the call :

 Michael Zumwalt (vice president)
,
 Les Merrill ( VP of project development ) , and

 Da n Owen ( VP of operations ).

Prior to the call
, 212 Resources sent EPA a power point presentation (see attachment 2) describing their evaporation distillation treatment technology

.
Mr. Zumwalt described the origin of the evaporation technology

. Five years ago, h e learned that a Toyota manufacturing plant was treat ing and reusing waste water from painting operations

. The wastewater from painting operations consisted of an oil/water emulsion and high dissolved metals concentrations. To treat water for reuse, the Toyota plant separate d the oil and water phases and then remove d the dissolved and particulate metals from th e water phase using an evaporation /distillation technology. Mr. Zumwalt thought that a similar treatment process could be applied to oil and gas wastewater, which he expected would have similar characteristics to the Toyota painting wastewater: high oil , s and, and dissolved solids content.Installation Locations

212 Resources currently operates a treatment plant in Wyoming. They have two units that have been operating about four years. At this site, they treat brine wastewater and produce treated wastewater that is used for initial drilling through drinking water aquifers . The water used for initial surface drilling must match the quality of water in the aquifer the company is drilling through. In effect, the treated water produced by 212 Resources must meet drinking water standards. Although they did not mention the specific name of the operator in Wyoming, 212 Resource’s website states that Ultra Petroleum is an operator currently using their services in the Pinedale Field (near Boulder, WY). Mr. Zumwalt stated that it is not always clear whether the wastewater i s from hydraulic fracturing of shale or tight sands

. He said that shale and tight sands are often confused, especially in the Pinedale 1

.
Mr. Zumwalt also discussed a second treatment operation planned for a site in Colorado

. This operation was planned to treat flowback and produced water from the Piceance formation (shale gas). In the early stages of this p roject, 212 Resources conducted testing of the Colorado flowback and p roduced water to show that the effluent quality would meet trout stream discharge standards . In order to meet these standards, minerals would actually need to be added to the effluent stream. However, before the installations were made the client cancelled the project for economic reasons . Instead, the units are being installed in North Dakota to treat fracturing wastewater in the Bakken formation.

Slide s 20 to 24 in attachment 2 provide i nfluent and effluent performance data for three feed waters. Two h ave average TDS concentrations around 20,000 mg/L and the third has a concentration around 300,000 mg/L. TDS concentrations in treated water were less than 400 mg/L.

Industry Background

Mr. Zumwalt explained how water for is used in high volume hydraulic fracturing. During typical operation, operators will simply filter flowback water to remove suspended solids and reuse the water in subsequent fracturing events. Produced water from the fractured formation is higher in salt than the fracturing fluids. As the water flowing from the well is produced water, rather than fracturing fluid, it contains so much salt that chemical add itives cannot be used with the water . Once this occurs, the water must be treated to remove the salt

. Challenges with treating wast ewater: According to 212 Resource’s experience in the field, the wastewater characteristics associated with unconventional gas production are extremely variable. One example was given where , in a single well, TDS concentrations may be as low as 6,000 mg/L in the morning and as high as 78,000 mg/L later in the day. In addition, every company uses different drilling methods, fracturing methods, and chemicals. As a result the wastewater characteristics vary by well, by operator, and by time. Most wastewater treatment

1 According to the USGS report Gas, Oil, and Water Production from Jonah, Pinedale, Greater Wamsutter, and Stagecoach Draw Fields in the Greater Green River Basin, Wyoming the Pinedale field is mostly sandstones or tight sands.technologies, such as reverse osmosis, cannot handle this kind of variability in the feed stream. A

major feature of 212 Resources’ technology is that it is designed to handle the high variability of the unconventional g as production wastewater.
Water Quality Criteria for Fracturing Fluid Makeup: 212 Resources explained that different types of fracturing fluids require different levels of makeup water quality . Two specific types of fracturing fluids were mentioned:

 Cros s

- linked gels: Used primarily i n W yoming and North Dakota . Operators add the gel to makeup water to assist in uniform placement of the proppant. The makeup water must be cleaner than slick

- water makeup.

 Slick

- water fluids: Used primarily in Pennsylvania a nd Texas . Slick water fluids include “soapy” (surfactant) friction reducers which operators add to make up water. The makeup water for slick

- water fracturing jobs does not need to be as clean as makeup for cross

- linked gels.
EPA and 212 Resources did not d iscuss the details of the ch emical constituents in gel and slick

water fracturing fluids or what criteria an operator would use to select one type of fracturing fluid over another

.

Evaporation Technology

Influent TDS Concentrations and Treated Wastewater Volumes : Mr. Zumwalt explained the basic principle of the evaporation technology and the relationship between influent TDS concentrations and water recovery volumes

. I nfluent TDS concentration s directly limit the maximum volume of treated wastewater that can be recovered by evaporation

. This is because the evaporation unit produces a concentrated brine stream that cannot exceed a concentration of 300,000 mg/L, which is the concentration limit before solid crystals will begin to form (i.e., crystallize). Th erefore, high er influent TDS concentrations will result in low er treated waste water recovery volumes , and lower influent TDS concentrations will result in higher treated wastewater recovery volumes . For example , if you have 10 bbls of wastewater at 30,000 mg/L TDS, then 1 bbl of wastewater must remain in the brine solution to keep the brine concentration at 300,000 mg/L TDS (shown in Figure 1 ). Therefore , only 9 bbls of treated water can be recovered. Conversely
, if you have 10 bbls of wastewater at 3,000 mg/L TD S , then only 0.1 bbl of wastewater needs to remain in the brine solution and 9.9 bbls of clean water can be recovered.

Figure 1 . Example Calculation of Water RecoveryFlow Rate : 212 Resources discussed the differences in typical produced water flow rates

and TDS concentrations by geographic region. In Pennsylvania, TDS concentrations are typically around 150,000 ppm while TDS concentrations in North Dakota are typically around 190,000 to 210,000 ppm. A hypothetical plant treating shale wastewater from Pennsylvania , the 212 Resources treatment unit could treat around 4,000 bbl/day , but less in North Dakota

. Energ y: Although specific energy consumption was not discussed
, Mr. Zumwalt pointed out on the first slide in the presentation (slide 1 of attachment 2) that the unit runs on electricity generated from 4 generators that operate on wellhead natural gas. The plan t also includes a boiler but Mr. Zumwalt did not mention what type of fuel the boiler consumes

.
Materials : Mr. Zumwalt explained that during design of the treatment system, for material selection, each unit of the plant was analyzed separately because th e fluid flow through each unit is different. Some examples of material selection include: titanium substitutes for pumps and a combination of stainless steel, titanium, and alloys for the main heat exchange unit.

Detailed Description: Mr. Zumwalt explained the process flow diagram for the 212 Resource evaporation technology , shown in Error! Reference source not found.

. From the wellhead, t he wastewater enters closed holding tanks. Waste water previously accumulated in large, open pits but they have switched to using closed tanks

. The following is a description of the treatment steps a fter the water leaves the storage plant :

1. The feed wastewater enters the plant anywhere between 35 and 75 ° F and first flows through a sensible heat exchanger . E ffluent clean wastewater also enters the heat exchanger at 180 to 190 ° F. After the heat exchanger
, the feed wastewater is heated to 150 to 170 ° F and the effluent clean wastewater exits at 110 to 120 ° F. 2. T he preheated wastewater enters a coalescing oil/water separator where liquid hydrocarbons are removed and returned to the client. 3. After oil removal, the wastewater enters the recirculation loop where it is immediately mixed with wastewater that has alre ady been concentrated in downstream steps

. Once inside the circulation loop, t he wastewater travels through the following components in order

. a. Pump

— Pumps the wastewater around the loop at 7,000 gpm. The high flow rate creates a turbulent flow to maximize heat transfer in the main heat exchanger. b. Brine Separator

— After being pumped, the wastewater passes by a brine separator that removes any brine heavier than 10 lb /gallon . This is where the brine exits the plant.

c. Heat exchange unit

— The wastewater that still needs to be concentrated passe s through the main heat exchange unit. Compressed was tewater vapor (from downstream) also enters the heat exchange unit. Heat is transferred from the compressed wastewater vapor to the liquid wastewater. d. The heated wastewate r enters the main vessel. A portion of the heated wastewater will flash into vapor leaving a more concentrated stream at thebottom of the tank where it enters the circulation loop. This concentrated stream is approximately 300,000 mg/L TDS. 4. The vapor in m ain vessel exits at the top and enters a mechanical compresso r where it is compressed (pressure increase). The compressed water vapor flows through main heat exchange unit (step 3c) where it gives heat back to liquid wastewater. 5. After exiting the main hea t exchange unit, the wastewater condenses back to a saturated liquid and is routed to the final distillation column. The final distillation column is designed to capture any remaining light hydrocarbons

. 2 6. The final distilled waste water (now at 180 to 190 ° F ) exits the plant through the initia l heat exchanger where it gives heat back to cool influent wastewater (step 1).

Figure 2 . Process Flow Diagram

Costs: Mr. Zumwalt provided general costs for the technology. He first stated that they charge around $4 per barrel of treated wastewater. This cost does not include disposal of concentrated brine but does include amortization of capital costs. He estimated capital costs at about $5 million for the plant installed in Wyoming (2,000 to 4,000 bbl per day of operation).

Brine Management: Mr. Zumwal t explained that currently operators do one of two things with the brine. The first option is to send it to deep well injection. H owever, in cases where the operator drills through a salt zone, they may use the dense brine for drilling

.

2 The light hydrocarbons recovered are those that boil at a temperature lower than water. Because of this, hydrocarbons pass through the initial evaporation step but are separated from the water in this distillation column.Follow Up

Following the discussion, EPA asked 212 Resources for additional information on analytical methods used to generate the performance data in Attachment 2. 212 Resources followed up with the analytical methods by re

- sending the power point presentation with an addition slide (slide 26). EPA also asked if 212 Resources could supply a list of customer names. 212 said they will need to look into permission and that some customer names may be available on their website.Attachment 1

Table A

- 1. List of Meeting Participants Name Affiliation Phone Email Michael Zumwalt 212 Resources 801

- 550

- 5102 mzumwalt@212resources.com Dan Owen 212 Resources Unknown DOwen@212resources.com Leslie Merrill 212 Resources Unknown lmerrill@212resources.com Brian D’Amico US EPA 202

- 566

- 1069 Biddle.Lisa@epamail.epa.gov Lisa Biddle US EPA 202

- 566

- 0350 Biddle.Lisa@epamail.epa.gov Meghan Camp ERG 703

- 633

- 1684 meghan.camp@erg.com Betsy Bicknell ERG 703

- 633

- 1119 betsy.bicknell@erg.com Brent Ruminski ERG 703

- 633

- 1701 brent.ruminski@erg.comAttachment 21 

# Technologies That Deliver Economics That Work2 

# Technologies That Deliver Economics That Work 1. Objective of Call. 2. Introduction of Parties. 3. Origin of Technology. Brief. 4. Technology Introduction into E&P Industry. Brief 

# a) Conceptual Presentation to E&P Company. Economics. b) Means to Finance Capital Expenditures for Technology. 5. Technology Description. a) Mechanical Vapor Recompression. b) Steam Stripping. 

# 6. Wyoming Operation. a) End Objective for Water after Treatment. b) Description of the Water before Treatment. c) Efficacy of Treatment. 7. Colorado Discharge Tests. a) End Objective for Water after Treatment. b) Description of the Water before Treatment

. c) Efficacy of Treatment

. 8. Work with high TDS Waters.



# Proposed Agenda3



## Since March 2008, 212 has been recycling waters generated during drilling, completion, and production activities. 212 has now recycled more than 110 million gallons for reuse. 212’s treated waters must meet a standard equivalent 

## to the area’s fresh water wells. 

# Single Plant Facility on Drilling Pad4 

# Plant Objective

Objective: Recycle 

# flowback waters into fresh water for re

- use.
Type of Frac Fluid: Cross

- Linked Gel with Methanol.56 

# Clean Dirty

Recovered Methanol ~0

- 2% Concentrate ~5%



# Working To Reduce Water Costs 212’s technology creates significantly more clean water than its competitors. And, 212 is able to meet far more rigorous water 

# quality standards.

# Flexible Site Configurations

7

## Generators



# Pod

Reserve (Source) Pond

Boiler Cleaned Water

Condensate or Methanol Chiller
s

Controls E

- House

Actual Site Layout Depends on Local Needs 

# Site Lay

- Out9 Mechanical Compression

Brine Separator Concentrate or Recovered Oil Oil

- Water Separator Recovered Alcohol

Recovered Oil 40 - Effect Distillation

Clean Water Feed 

## Simple Schematic of Technology 

# The Core Technology

# MVR Evaporator

10

# Evaporator and Distillation Column

11

# Effluent Polishing System

1213



# Two Plant Set

- Up for Treating Produced Water14 

# Operations Near Grand Junction, CO Two Plant Facility to Treat Produced Water15 

# The Core Technology1617 

# Deployment

# Colorado DataPARAMETER ACTUAL EFFLUENT RESULTS
30 Day Average 7 Day

Average Daily

Maximum 2

- Year

Average PQL Pass/Fa il
Effluent Flow (MGD) 0.194 Pass Temp ( ° C) June

- Sept 14.8 Pass Temp ( ° C) Oct

– May 3.7 10.8 4.1 Pass pH (su) 8 8.3 Pass TSS, effluent (mg/L) <4.0 <4.0 10 Pass Oil and Grease (mg/L) 1.7 1.7 Pass TDS (mg/L) 322.5 384 10 Pass As, Tot (μg/L) <1 <1 1.0 Pass Ba, TR (μg/L) 15.4 5.0 Pass Be, TR (μg/L) <0.5 <0.5 1.0 Pass Cd, PO (μg/L) <0.5 1.0 Pass Cr +3, TR (μg/L) (Cr Tot (μg/L)) 2.2 3 2.2 20 Pass Cu, PO (μg/L) 2.2 3 1.3 5.0 Pass CN, WAD (μg/L) <2.0 <2.0 <2.0 5.0 Pass Fe, TR (μg/L) 9 9 10 Pass Pb, TR (μg/L) 0.1 0.1 0.1 1.0 Pass Mn, PD (μg/L) <0.5 <0.5 <0.5 2.0 Pass Hg, Tot (μg/L) <0.1 <0.1 0.1 Pass Ni, PO (μg/L) <5.0 <5.0 <5.0 50 Pass Se, PD (μg/L) 1.8 4.9 1.8 1.0 Pass Ag, PD (μg/L) <0.5 <0.5 <0.5 0.5 Pass U, PD (μg/L) 1.9 5.7 1.9 1.0 Pass Zn, PO (μg/L) 4.9 20 4.9 10 Pass B, Tot (mg/L) 0.39 0.39 .05 Pass Chloride (mg/L) 121.7 126 2.0 Pass Sulfide (mg/L) <0.2 <0.2 0.2 Pass Calcium (mg/L) 25.1 0.02 Pass Magnesium (mg/L) 3.3 0.02 Pass Sodium (mg/L) 37.7 0.2 Pass Bicarbonate as HC03 (mg/L) 93.8 Pass SAR calc limit (capped at 6.7) 1.95 Pass SAR, adjusted SAR, effluent 1.62 Pass SAR, Pass/Fail Pass Pass EC maximum (dS/m) 0.788 Pass Radium 226 +228 (pCi/L) 0.44 0.67 0.44 Pass
WET Test Pass Pass PARAMETER FEED CHARACTERISTICS

MIN MAX AVERAGE

Effluent Flow (MGD) 0.21 Temp ( ° C) June

- Sept Temp ( ° C) Oct

– May pH (su) 5.3 7.4 6.82 TSS, effluent (mg/L) 24 157 75.29 Oil and Grease (mg/L) 15 79 36.91 TDS (mg/L) 6160 76700 19930 As, Tot (μg/L) 30 110 43 Ba, TR (μg/L) 3190 60000 31680 Be, TR (μg/L) ND ND ND Cd, PO (μg/L) 0 0.1 0 Cr +3, TR (μg/L) (Cr Tot (μg/L)) 4.2 8.3 6.8 Cu, PO (μg/L) 2.0 16 6.9 CN, WAD (μg/L) 4 12 7.5 Fe, TR (μg/L) 8200 80200 30093 Pb, TR (μg/L) 1 40 23 Mn, PD (μg/L) 2 47 11.5 Hg, Tot (μg/L) 0.0 0.7 0.2 Ni, PO (μg/L) 3 9 6.3 Se, PD (μg/L) 60 300 160 Ag, PD (μg/L) 17.1 282 149.6 U, PD (μg/L) 0 1.5 0.1 Zn, PO (μg/L) 10 120 54.2 B, Tot (mg/L) 3.9 8.4 6 Chloride (mg/L) 3800 11900 8586.25 Sulfide (mg/L) 0.6 1.1 0.7 Calcium (mg/L) 70.7 343 231.99 Magnesium (mg/L) 8.1 26.7 20.84 Sodium (mg/L) 2570 8230 5509.36 Bicarbonate as HC03 (mg/L) 400 944 692.25 SAR calc limit (capped at 6.7) n/a n/a n/a SAR, adjusted SAR, effluent n/a n/a n/a SAR, Pass/Fail n/a n/a n/a EC maximum (dS/m) 1430 2630 2300 Radium 226 +228 (pCi/L) 3.5 10.8 7.3
WET Test n/a n/a n/a

# Wyoming Data

### PARAMETER PERFORMANCE

FEED 

## (Typical) EFFLUENT



## (Typical)

TDS (mg/L) 20100 29.32
TPH (mg/L) 186 ND Ba, TR (mg/L ) 31 0.02 Benzene (mg/L ) 1.10 ND Toluene (mg/L ) 5.24 ND 

## Ethylbenzene (mg/L )) 4.2 ND Xylene (mg/L ) 9.56 ND Methanol (mg/L ) 1950 <5

# High TDS

ResultsPARAMETER High TDS Produced Water
Feed Treated % Removal Physical Properties pH 5.7 10.0 Specific Gravity 1.21 0.99 TDS (ppm) 306000 20 99.99% Inorganics Chloride (ppm) 188000 < 1 > 99.999% Sulfide (ppm) < 0.6 < 0.6 Boron (ppm) 496 0.68 99.86% Barium (ppm) 38 < 0.005 > 99.99% Calcium (ppm) 23400 0.5 99.998% Iron (ppm) 351 < 0.02 > 99.99% Sodium (ppm) 87000 1.0 99.999% Organics Oil & Grease (ppm) 173 5 97.11% Methanol (ppm) 31 15 51.61% TPH

- GRO (ppm) 14.2 0.5 96.48% TPH

- DRO (ppm) 58.6 22.6 Benzene (ppb) 169 40 76.33% Ethylbenzene (ppb) < 25 < 5 MTBE (ppb) < 25 < 5 Naphthalene (ppb) < 50 < 5 Toluene (ppb) 81 41 49.38% Xylenes (ppb) 142 83 41.55% 

## Note: Organic Results shown are for re

- use in fracing operations and do not represent discharge performance.25 

# Michael Zumwalt Executive Vice President

• Works in developing 212’s service offerings

Mr. Zumwalt also has an extensive background as a CEO & VP

- Ops in the environmental industry. He 

### operated a hazardous waste TSD facility that went 6 years without an compliance violation, earning EI Digest’s Top Compliance Award. Early in his career, he served as CFO of a drilling company.26