MEMORANDUM

TO: Brian D’Amico, EPA/EAD

Lisa Biddle, EPA/EAD

FROM: Meghan Camp, ERG

Besty Bicknell, ERG

Brent Ruminski, ERG

DATE: 09 January 2012

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

On 4 January 2012, 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 participants.

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 

 Dan 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, he 

learned that a Toyota manufacturing plant was treating and reusing wastewater 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 separated the oil and 

water phases and then removed the dissolved and particulate metals from the 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, sand, 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 is from hydraulic fracturing of shale or tight sands. He said that shale and tight sands 

are often confused, especially in the Pinedale1.

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 project, 212 Resources conducted testing of the Colorado 

flowback and produced 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. 

Slides 20 to 24 in attachment 2 provide influent and effluent performance data for three 

feed waters. Two have 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 additives cannot be used with 

the water. Once this occurs, the water must be treated to remove the salt. 

Challenges with treating wastewater: 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 gas 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:

 Cross-linked gels: Used primarily in Wyoming 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 and 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 discuss the details of the chemical constituents in gel and slickwater 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. Influent TDS concentrations 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). Therefore, higher influent TDS concentrations will result in lower treated 

wastewater 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 TDS, 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 Recovery

Influent wastewater:

10 bbls

TDS—30,000 mg/L

Effluent treated wastewater:

9 bbls

Concentrated brine:

1 bbl 

TDS—300,000 mg/L

Evaporation 

Unit
Flow 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.

Energy: 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 plant 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 the 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, the wastewater enters closed holding tanks. Wastewater previously accumulated in

large, open pits but they have switched to using closed tanks. The following is a description of 

the treatment steps after 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. Effluent 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. The 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 already been concentrated in 

downstream steps. Once inside the circulation loop, the 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 

passes through the main heat exchange unit. Compressed wastewater 

vapor (from downstream) also enters the heat exchange unit. Heat is 

transferred from the compressed wastewater vapor to the liquid 

wastewater. 

d. The heated wastewater enters the main vessel. A portion of the heated 

wastewater will flash into vapor leaving a more concentrated stream at the 
bottom of the tank where it enters the circulation loop. This concentrated 

stream is approximately 300,000 mg/L TDS.

4. The vapor in main vessel exits at the top and enters a mechanical compressor 

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 heat 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 wastewater (now at 180 to 190°F) exits the plant through the 

initial 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. Zumwalt explained that currently operators do one of two things 

with the brine. The first option is to send it to deep well injection. However, 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. 

4. Mechanical 

Compression

3a. Pump

2. Oil-Water separator

5. Recovered light 

hydrocarbons 

(alcohols)

Recovered

oi l

Treated wastewater

1. Feed wastewater

The Core Technology

3. Circulation 

Loop

3b. Brine 

separator

concentrate

3d. Main 

vessel

3c. Heat 

exchanger

5. Distillation

1. Sensible 

heat 

exchanger
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.com
Attachment 2
1

Technologies That Deliver

Economics That Work
2

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 Agenda
3

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 Pad
4

Plant Objective

Objective: Recycle 

flowback waters into 

fresh water for re-use.

Type of Frac Fluid: 

Cross-Linked Gel with 

Methanol.
5
6

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-Out
9

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

12
13

Two Plant Set-Up for 

Treating Produced Water
14

Operations Near 

Grand Junction, CO

Two Plant Facility to 

Treat Produced Water
15

The Core Technology
16
17

Deployment

Colorado Data 
PARAMETER

ACTUAL EFFLUENT RESULTS

30 Day 

Average

7 Day 

Average

Daily 

Maximum

2- Year 

Average PQL Pass/Fail

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

Results 
PARAMETER

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