# Unconventional Oil and Gas (UOG) Supplemental Quality Assurance Project Plan ( S QAPP)

Prepared for: 

## U.S. Environmental Protection Agency Engineering and Analysis Division Office of Water 1200 Pennsylvania Avenue, NW Washington, D.C. 20460

Prepared by: 

## Eastern Research Group, Inc. 14555 Avion Parkway Suite 200 Chantilly, VA 20151

August 1 5
, 201 4

EPA Contract No. EP

- C

- 12

- 021 Work Assignment 1

- 38Revision No. 0 Date : August 15 , 2014



### UOG S QAPP

Revision 0 Delivery Date June 26, 2014 Work Assignment 1

- 38 Scope Covers work performed for E PA under Contract EP

- C

- 12

- 021 regarding the development of the UOG T echnical D evelopment D ocument (TDD) in support of the proposed revisions to 40 CFR Part 435. Comments Received July 24, 2014 (written) July 30, 2014 (verbal) Comments Addressed August 15 , 2014 Approval August 27, 2014Revision No. 0 Date : August 15 , 2014



### TABLE OF CONTENTS Page

1.0 INTRODUCTION

................................ ................................ ................................ .............. 1

2.0 PROJECT MANAGEMENT E LEME NTS

................................ ................................ ........ 1 2.1 SQAPP Distribution

................................ ................................ ................................ 1 2.2 Project Description

................................ ................................ ................................ .. 2

3.0 COLLEC TION OF EXISTING DAT A FOR USE IN THE UOG PROPOSED RULEMAKING

................................ ................................ ................................ .................. 5 3.1 Source Flag Assignment and Data Quality Assessment

................................ ......... 6 3.2 Data Extraction from Literature Review

................................ ................................ . 7

4.0 ERG’S DELIVERABLE RE VIEW PROCESS

................................ ................................ .. 8Revision No. 0 Date : August 15 , 2014

LIST OF TABLES Page



### Table 2

- 1. SQAPP Distribution List

................................ ................................ ................................ 1

Table 2

- 2. Work Activities and Key Questions for the UOG Proposed Rulemaking

..................... 3

Table 2

- 3. WA 1

- 38 ERG Project Staff Responsibilities

................................ ................................ 5

Table 3

- 1. Source Flag Descriptions and Examples

................................ ................................ ........ 6

LIST OF FIGURES Page


### Figure 2

- 1. ERG Program Management Structure for WA 1

- 38

................................ ..................... 4Revision No. 0 Date : August 15 , 2014 Page 1 of 10



### 1.0 I NTRODUCTION
EPA requires Quality Assurance Project Plans (QAPPs) under the Agency’s Quality Assurance Policy CIO

- 2105 ( formerly EPA Order 5360.1A2 ) and implementing guidance CIO

- 2105

- P

- 01

- 0 (formerly EPA Order 5360A1 ) . Because the u nconvent ional o il and g as (UOG) proposed rulemaking requires the generation, collection, analysis, and use of environmental data, EPA’s policy specifies that it must have an approved QAPP to assure the quality, objectivity, integrity, and utility of the data and i nformation used in the project.

Eastern Research Group, Inc. ( ERG ) is providing support to EPA under the Environmental Engineering Support for Clean Water Regulations Contract (EP

- C

- 12

- 021), Work Assignment 1

- 38 (Unconventional Oil and Gas Engineering Supp ort). ERG will adhere to the approved Environmental Engineering Support for Clean Water Regulations Programmatic Quality Assurance Project Plan (PQAPP), Revision 1 (dated October 2013) for this contract when generating, collecting, and determining the use of data and information for any applicable task under W ork A ssignment 1

- 38

. ERG has prepared this Supplemental QAPP (SQAPP) for work required under this work assignment that is not already covered under the PQAPP. Th is SQAPP encompasses the specific activities conducted during the development of the UOG T echnical D evelopment D ocument (TDD) and other activities completed in support of the proposed rulemaking

. The SQAPP also documents the email review system that ERG implemented for WA 1

- 3 8 to track del iverable reviews.

This document is organized as follows:

**•** Section 2.0 presents Project Management E lements specific to WA 1

- 38

.

**•** Section 3.0 present s Existing Data Collection, Source Flag Assignment, and Data Quality Assessment specific to WA 1

- 38

.

**•** S ection 4.0 discusses ERG’s process for track ing deliverable reviews for WA 1

- 38.



### 2.0 P ROJECT 

### M ANAGEMENT 

### E LEMENTS



### 2.1

The S QAPP distribution list will include the staff identified in 

### S QAPP Distribution

Table 2

- 1

.

Table 2

- 1

. S QAPP Distribution List

Name / Title Contact Information Mailing Address
U.S. Environmental Protection Agency , Engineering and Analysis Division
Lisa Biddle E PA Work Assignment Manager (202) 566

- 0350 Biddle.Lisa@epa.gov U.S. Environmental Protection Agency Office of Science and Technology 1200 Pennsylvania Avenue, NW (4303T) Washington, DC 20460 (202) 566

- 1053 (fax) Ahmar Siddiqui EPA Alternate Work Assignment Manager (202) 566

- 1044 Siddiqui.Ahmar@epa.gov

Jesse Pritts EPA Alternate Work Assignment Manager (202) 566

- 1038 Pritts.Jesse@epa.govRevision No. 0 Date : August 15 , 2014 Page 2 of 10

Table 2

- 1

. S QAPP Distribution List

Name / Title Contact Information Mailing Address Eastern Research Group, Inc

. Sarah Yates ERG Work Assignment Manager (703) 633

- 1661 Sarah.Yates@erg.com

Eastern Research Group, Inc. 14555 Avion Parkway Suite 200 Chantilly, VA 20151

- 1102 (703) 263

- 7280 (fax) Betsy Bicknell ERG Work Assignment Senior Reviewer (703) 633

- 1612 Betsy.Bicknell@erg.com

Deborah Bartram ERG Program Manager (703) 633

- 1669 Deborah.Bartram@erg.com Mary Willett ERG Project QA Coordinator (703) 633

- 1615 Mary.Willett@erg.com Brent Ruminski ERG Work Assignment Project Team Member (703) 633

- 1701 Brent.Ruminski@erg.com
Patricia Engel ERG Work Assignment Project Team Member (703) 373

- 8105 Patricia.Engel@erg.com
Daisy Wang ERG Work Assignment Project Team Member (848) 209

- 9675 Daisy.Wang@erg.com

Carissa Erickson ERG Work Assignment Project Assistant (703) 633

- 1688 Carissa.Erickson@erg.com



### 2.2
For those industrial point source categories identified for effluent limitations guidelines ( ELG ) development, E PA conducts a series of data collection, evaluation, and analysis steps to identify technology

- based regulatory options and calculate associated regulatory limits and standards to control pollutant discharges from the point source. Figure 2

- 3 in the PQAPP pr esents the basic steps of the ELG
process. 

### Pro ject De scription

Discharge regulations for the oil and gas industry are codified in 40 CFR Part 435 . For Subpart C, Onshore S ubcategory, BPT guidelines are “ no discharge of waste water pollutants ” ; however, Subpart C does not incl ude pretreatment standards. Further, UOG extraction wastewaters have the potential to be discharged to publicly owned treatment works ( POTWs ) . For these reasons, EPA announced its plans to develop pretreatment standards for UOG extraction wastewater

. Becau se EPA plans to propose pretreatment standards that prohibit the discharge of UOG wastewater pollutants to POTWs, EPA does not plan to calculate numerical pretreatment standard s for existing sources (PSES) or new sources (PSNS)

. Further, because UOG extraction facilities are not currently discharging wastewater to POTWs, EPA does not plan to estimate costs or pollutant load reductions associated with the proposed regulations.

Under W ork A ssignment 1

- 38 , ERG will support EPA’s dev elopment of pretreatment standards and related support ing materials for the UOG proposed rulemaking . ERG’s support includes collecting existing data, evaluating and analyzing the data, and presenting the analyses in draft and final deliverablesRevision No. 0 Date : August 15 , 2014 Page 3 of 10

that docume nt the data and that document E PA ’s decision s for using the collected data

. Table 2

- 2 presents the specific work activities that ERG is support ing for the UOG proposed rulemaking

.

Table 2

- 2 . Work Activities and Key Questions for the UOG Proposed Rulemaking

Work Activities Key Questions to be Answered by the Project Work Statement ERG’s collection of existing data will support EPA’s technical understanding of UOG operations
, UOG pro cesses that generate wastewater subject to the Clean Water Act ( CWA ) , pollutant discharges and their impacts, and wastewater management and disposal prac tices

. ERG will develop a TDD to support the UOG proposed rulemaking. The TDD will describe the industry, UOG wastewater volumes and characteristics, and UOG wastewater management and disposal options.
In support of the rulemaking, ERG will provide techn ical support for the following activities:

**•** En gineering site visits

**•** Technical literature reviews

**•** Data extraction from existing databases (e.g., PA DEP Waste Reports, DIDesktop®)

**•** Industry profile development

**•** Preparation of technical documents

**•** Preparation of regulatory rulemaking records and public dockets

**•** Evaluation of public comments

**•** Rulemaking imple mentation support In collecting existing data as part of the UOG proposed rulemaking , E PA seeks to answer the following questions:

**•** What operators and wells are i ncluded in the onshore UOG extraction industry? Where are they located? What is their size?

**•** What are the primary sources of wastewater from UOG extraction?

**•** What are the characteristics of the UOG wastewater (i.e., produced water), which includes both flowb ack and long

- term produced water (i.e., pollutants, concentrations, flow rate/volume)?

**•** What are the pollutants of concern?

**•** How is UOG extraction wastewater currently managed?

**•** What are the potential concerns with managing UOG extraction wastewater at POTWs?

ERG’s pro gram management structure for Contract EP

- C

- 12

- 021 is shown in Figure 2

- 4 in the PQAPP

. ERG’s program management structure specific to WA 1

- 38 is shown in Figure 2

- 1 below

. In addition, the responsibilities of EPA and ERG project staff by project role are summarized in the PQAPP ( Table s 2

- 3 and 2

- 4) . The ERG WAM will have overall responsibility for ensur i ng that the project team adheres to the requirements of the PQAPP and the SQAPP and will work with the ERG Project QA Coordinator to assess compliance with the requirements of the PQAPP and SQAPP . The responsibilities of ERG ’s UOG project staff by project role are summarized below in 

### Table 2

- 3

.

.Revision No. 0 Date : August 15 , 2014 Page 4 of 10



### Figure 2

- 1 . ERG Program Management Structure for WA 1

- 38 EPA Project Officer Meghan Hessenauer EPA QA Coordinator Marion Kelly

EPA WAM Lisa Biddle Ahmar Siddiqui (Alternate WAM)

Jesse Pritts (Alternate WAM) ERG Program Manager Deb Bartram

ERG WAM Sarah Yates

ERG Project Team

Brent Ruminski

Daisy Wang Patricia Engel ERG Contract QA Manager ERG Project QA Coordinator Mary Willett

ERG Technical Reviewers Betsy Bicknell Deb Bartram

Reporting and authority

Lines of Communication

ERG Index Keeper and Project Assistant Carissa EricksonRevision No. 0 Date : August 15 , 2014 Page 5 of 10

Table 2

- 3 . WA 1

- 38 ERG Project Staff Responsibilities

Project Role Summar y of Responsibilities
ERG WAM C oordinates ERG activities conducted in support of the UOG proposed rulemaking. In executing these duties, the ERG WAM assumes the following responsibilities, in addition to those listed in Table 2

- 4 of the PQAPP:

**•** Prepare the SQAPP and coordinate the appro priate internal ERG deliverable reviews prior to delivery to EPA.

**•** Review select deliverables, as requ ired by the PQAPP (see Table 10

- 1 in the PQAPP ).

**•** During the monthly Technical Progress Report ( TPR ) review, confirm that the review process was completed a nd documented for all deliverables (see Section 4.0 ).

ERG Senior Technical Reviewer A ssumes the following responsibilities, in addition to those l isted in Table 2

- 4 of the PQAPP:

**•** Review select deliverables, as required by the PQAPP (see Table 10

- 1 in the PQAPP ).

**•** Provide advice on historical context relevant to the regulatory development process

. ERG Project Staff A ssume the following responsibilities, in addition to those listed in Table 2

- 4 of the PQAPP:

**•** Follow the deliverable review requirements in the PQAPP ( see Table 10

- 1 in the PQAPP ) and this SQAPP, and ensure that the Document Review Tracking Sheet is updated with the completion of each deliverable.

**•** Notify the ERG WAM if they determine that the appropriate review requirements were not met for a deliverable.

**•** Where needed, help the project assistant update the UOG r ecord database and answer questions about deliverables and/or docke t items.



### 3.0 C OLLECTION OF 

### E XISTING 

### D ATA FOR 

### U SE IN THE 

### UOG P ROPOSED 

### R ULEMAKING
The following subsections of this SQAPP discuss the types of existing data ERG collected and how ERG assessed the qu ality of existing data sources. Section 4.2 of the existing a pproved PQAPP discusses how ERG manages existing data sources and Section 2 of the Unconventional Oil and Gas Project File Management Plan discusses source management specific to the UOG proposed rulemaking.

E RG collected information under the existing approved PQAPP to support the UOG proposed rulemaking in several ways: through site visits and telephone contacts with UOG facility operators, facilities that treat and/or dispose of UOG wastewater, and wastewater management equipment ve ndors ; through outreach to stakeholders including industry groups, environmental groups, and state regulators ; by conduc t ing an extensive review of published information ; and by participat ing in ind ustry conferences and webinars.

ERG began collecting data through targeted searches for literature about the UOG industry. Through these targeted literature searches and general I nternet searches, ERG identified select publicly available data sets (e.g., P ennsylvania Department of Environmental Protection (P A DEP ) Waste Report data available on the PA DEP website). ERG continued to collect data by contacting UOG operators and operators of facilities that treat and/or dispose of UOG wastewater. ERG set up site visits and/or conference calls with these operators to gather additional information about the UOG industr y. ERG and EPA also worked together to obtain information from the EPA regional offices and states , where data were not available from other sources

.Revision No. 0 Date : August 15 , 2014 Page 6 of 10
All of the information that was collected or developed during the development of the UOG proposed rulemaking will be included in the UOG Extraction project file, as described in Section 1.2 of the Unconventional Oil and Gas Extraction Project File Management Plan

. The analyses and products generated by ERG wer e typically qualitative assessments that answered the key questions presented in Table 2

- 2 . The answers to these key questions provided input for the main
sect ions of the TDD, which include:

**•** Chapter A: Introduction

**•** Chapter B: Background on UOG Extraction

**•** Chapter C: UOG Process Wastewater Volumes and Characteristics

**•** Chapter D: UOG Process Wastewater Management and Disposal Practices

As part of the research, EPA determined that there are no existing discharges to POTWs associated with unconventional oil and gas extraction. EPA decided that data sources could be evaluated based primarily on the source of the data (i.e., author/organizat ion) and relevant citation information rather than evaluating data sources based on more specific acceptance criteria (e.g., Table 4

- 2 in the PQAPP).



### 3.1

As ERG collects sources ( references ) to support the UOG proposed rulemaking, t he UOG project team member who enters the document into the UOG Literature Review database also assigns a source flag to each reference. The source flag is used to assess the source for usability and categorize it according to the

au thor affiliation and document context (e.g., conference proceedings, peer

- reviewed publication). S ource flag s are only assigned to references that have been identified as containing information relevant to UOG
opera tions (as identified by the UOG project t eam member who reviews the source). 

### Source Flag Assignment and Data Quality Assessment

Table 3

- 1 presents a general description of each source flag and provides examples of the types of documents that fall into each source flag category.

Table 3

- 1

. Source Flag Descriptions and Examples

Source

Flag Description Examples

A Documents prepared for or by a government agency or p eer

reviewed journal articles

. **•** Documents published by or prepared for a state or federal government.

**•** Site visit reports and/or industry meeting notes.

**•** Peer reviewed journal articles.

B Documents prepared by a verified a source that include citation information

. **•** University publications (including theses and/or dissertations).

**•** Industry publications that include citations (e.g., operator reports, vendor publications).

**•** C onference presentations that include citations.Revision No. 0 Date : August 15 , 2014 Page 7 of 10

Table 3

- 1

. Source Flag Descriptions and Examples

Source

Flag Description Examples

C Documents prepared by a verified a source that do not include citation information

. **•** Industry or other publications relevant to the UOG industry that do not in clude citations.

**•** Conference presentations from a verified source in the UOG industry that do not include citations.

**•** Industry or treatment facility websites.

D Docum ents prepared by a source that could not be verified and that d o not include citation information

. **•** Conference presentations from a source that could not be verified in the UOG industry that do not include citations.

**•** Newspaper articles.

a ERG considered authors “verified” sources if we were able to find information about the author outside of the reference document. ERG primarily verified information by looking for company/organization websites that confirmed the author’s affiliation with the UOG industry.

EPA and ERG discussed the requirements for including or excluding data from delivera bles developed in support of the UOG proposed rulemaking and concluded that it was appropriate to assign source flags to the reference (source), rather than to the individual data points. ERG and EPA ultimately came to this decision because ERG is using th e collected data to describe the industry and to characterize the wastewater generated by the industry, but not to develop numeric limits. Therefore, the ERG WAM and the EPA WAM agreed that assigning a source flag to categorize a source, rather than a data point, was
approp riate for this work assignment.

ERG and EPA decided that data originating from sources assigned a source flag of A, B, or C were suitable for inclusion in project deliverables and that data originating from references assigned a source fl ag of D would be included only where the data were otherwise unavailable from a source with a flag of A, B, or C. ERG will identify these instances within the deliverable (e.g., in a footnote), noting that the data originate from a reference with a source flag of D and describing the meaning of that specific source flag. ERG will document these data quality assignments in underlying data files that will be included in the docket and will support the TDD and other deliverables prepared in support of the UOG proposed rulemaking.



### 3.2

When ERG identified specific data that helped provide an answer to a question in 

### Data Extraction from Literature Review

Table 2

- 2 , ERG captured the data from the source in the appropriate format (e.g., Microsoft Excel ® spreadsheet, Microsoft Word ® document). Section 7.2 in the PQAPP notes that the ERG WAM and the EPA WA M will work together to determine the level of quality control ( QC ) necessary. Therefore, i n the event that existing data from the new source required data entry into a spreadsheet or database, the ERG and EPA WAMs decided that ERG will pe rform a 20 percen t check of all data entered to ensure it had been accurately transcribed from the hard copy. In addition, the ERG and EPA WAMs decided that f or any calculations or data manipulation, ERG will perform a 100 percent check of the data. All of these checks

are documented in the associated spreadsheet or database in a tab or table named “QC.”Revision No. 0 Date : August 15 , 2014 Page 8 of 10
ERG and EPA worked together to identify suitable sources from which to pull data points that could be summarized and included in a deliverable supporting the UOG proposed r ulemaking. ERG developed the source flags 1 Table 3

- 1 shown in to aid i n determining suitable sources.



### 4.0 ERG’ S 

### D ELIVERABLE 

### R EVIEW 

### P ROCESS
ERG adopted the following process for performing and documenting deliverable reviews under this project . Each subsection below represents a step in the deliverable review process and the person(s) responsible for completing each step is noted in parentheses in the step heading

.

When ERG is tasked with a deliverable , the ERG WAM assigns a document author from the project team. T he document author must first determine the levels of review that are required for th e specific document (see Table 10

- 1 in the PQAPP ) and a schedule for the review

. The document author w ork s with the ERG WAM or task lead to determine an appropriate level of review and schedule for the document. The different levels of review that ma y be r equired are listed below: Ste p 1. Determine Levels of Review and Review Schedule (Document Author)

**•** Technical Review

**•** Senior Technical Review

**•** Project QA Coordinator Review

**•** WAM or Task Lead Review

**•** Technical Editor (if editing staff is used)

**•** Program Ma nager Review

After the levels of review have been determined and an appropriate schedule developed, the document author must go to the Document Review Tracking Sheet , located on ERG’s UOG project network area, and enter the following information: Step 2. Enter Document into the Document Review Tracking Sheet (Document Author)

**•** DCN 2

**•** ERG project number (Column B) (Column A)

**•** Title of document (Column C)

**•** Original author (Column D)

**•** Client due date (Column E)

**•** Levels of review required (Columns F

- L)

1 As described in Section 3.1 , source flags were assigned at the reference level because the data are being used only to describe the industry and are not being used to develop numeric limits.

2 If the DC N is not yet assigned, the document author can leave this field blank and populate it later, once the index keeper assigns the DCN (see Unconventional Oil and Gas Extraction Project File Management Plan in Attachment B for more details).Revision No. 0 Date : August 15 , 2014 Page 9 of 10

When the document is ready for review, the document author email s the reviewer (s) directly to request a review of the document, including the location of all relevant documents. The document author cop ies the UOG

- QA email account ( Step 3. Notify Reviewers that Document is Ready for Review (Document Author)

UOG

- QA@erg.com ) as documentation of the review process

. The document author includes the f ollow ing information in the review request :

**•** ERG project number, type of review, and document title in the subject line EXAMPLE: 0317.01.038.050

– WAM Review

– TDD Part D

.

**•** F ile path and the due date for the reviewer’s comments to the email.

After emailing the reviewer ( s ) , the document author enter s the document’s Network Location Step 4. Update the Document Review Tracking Sheet (Document Author)

3 in to the Document Review Tracking spreads heet . Additionally, the document author populate s the Reviewer Name, Date Document Given to Reviewer, and Date Comments Due columns under the relevant type of review. The document author is always responsible for updating the trackin g sheet and enter s the Date Comments Provided upon receipt of comments from the reviewer. The document author incorporate s the comments received into the next version of the file for review or delivery (e.g., for a deliverable going through technical and W AM reviews, the comments from the technical review are incorporated into the version of the document that is passed to the WAM for review). Any deviations from the standard review and documentation process are described in the “Notes” column of the Document Review Tracking Sheet.

The reviewer respond s to the document author’s email request when the review is complete and cop ies the UOG_QA email account. The reviewer send s the location of the fi les in the email ( not the actual files to minimize the need to archive emails in the UOG_QA email account ) . The reviewer can also send any comments directly in the email. The reviewer adds “Completed” to the subject heading in the response email (e.g., Re: 0317.01.038.050

– WAM Review

– TDD Part D

– COMPLETED )

. Step 5. Notify Author that Review is Complete (Reviewer)

Once all levels of internal review and revision are completed, the document author deliver s the document to the client and cop ies the UOG_ QA email account . When comments are received from the client, the document author forward s the email from the client to the UOG_QA email account. After the client’s comments are incorporated, the document author cop ies the UOG_QA email account when deliver ing the revised document. The document author also populate s the Client Review columns in the Document Review Tracking Sheet with the appropriate date when the document is delivered to the client, comments are expected from the client, comments are received from the client, and the revised document incorporating the client comments is delivered to the client

. If comments received from the client are Step 6

. Deliver the Document to the Client (Document Author)

3 The Network Location should point to the folder containing all of the review drafts of the deliverable. The Network Location should not list each individual file name. Each reviewer should save a copy of the deliverable with their initials and “Rev” at th e end of the file name (e.g., UOG TDD_2014.03.20_SYRev) in the Network Location folder.Revision No. 0 Date : August 15 , 2014 Page 10 of 10

extensive, the document author work s with the ERG WAM or task lead to determine if the re vised document should be treated as a new deliverable. If so, the document author will restart the review tracking process for the new deliverable at S tep 1.

Three days prior to the W AM’s TPR review, the index keeper remind s the team/document authors to ensure the Document Review Tracking Sheet is up to date. The document authors proxy into the UOG_QA email account and confirm all the reviews are documented in the UOG_QA email and in t he tracking sheet. The document author update s the tracking sheet if any review emails were not documented. If any review emails are missing from the UOG_QA email account, the document author forward s the relevant emails to the account or remind s the respo nsible party to email the UOG_QA email account documenting when the review was completed. Step 7

. Review the UOG_QA Email Account ( Index Keeper & Document Author )

During the WAM’s TPR review, the WAM confirm s that the review process was completed for all deliverables l isted in the TPR by reviewing the Document Review Tracking Sheet. Step 8

. Review the Document Review Tracking Sheet (ERG WAM)

Should the ERG WAM find a deliverable that did not receive the appropriate reviews before being delivered to EPA, the ERG WAM will discuss this with the EPA WAM. If the review deviation was not pre

- approved by the EPA WAM, t he ERG WAM will ensure that the deliverable goes through the appropriate reviews and is redelivered to EPA after the appropriate reviews have been completed. These instances will be identified in the “Identification of Deviations from the QAPP” portion of the TP R.