Unconventional Oil and Gas (UOG) 

Supplemental Quality Assurance Project 

Plan (SQAPP)

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 15, 2014

EPA Contract No. EP-C-12-021

Work Assignment 1-38

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Date: August 15, 2014

UOG SQAPP

Revision 0

Delivery Date June 26, 2014

Work Assignment 1-38

Scope Covers work performed for EPA under Contract EP-C-12-021regarding the 

development of the UOG Technical Development Document (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, 2014
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TABLE OF CONTENTS

Page

1.0 INTRODUCTION .............................................................................................................. 1

2.0 PROJECT MANAGEMENT ELEMENTS........................................................................ 1

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

2.2 Project Description.................................................................................................. 2

3.0 COLLECTION OF EXISTING DATA 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 REVIEW PROCESS.................................................................. 8
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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.....................................................4
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1.0 INTRODUCTION

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 unconventional oil and gas (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 information 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 Support). 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 Work Assignment 1-38. ERG has prepared this Supplemental 

QAPP (SQAPP) for work required under this work assignment that is not already covered under the 

PQAPP. This SQAPP encompasses the specific activities conducted during the development of the UOG 

Technical Development Document (TDD) and other activities completed in support of the proposed 

rulemaking. The SQAPP also documents the email review system that ERG implemented for WA 1-38 to 

track deliverable reviews.

This document is organized as follows:

• Section 2.0 presents Project Management Elements specific to WA 1-38.

• Section 3.0 presents Existing Data Collection, Source Flag Assignment, and Data Quality 

Assessment specific to WA 1-38.

• Section 4.0 discusses ERG’s process for tracking deliverable reviews for WA 1-38.

2.0 PROJECT MANAGEMENT ELEMENTS

2.1

The SQAPP distribution list will include the staff identified in 

SQAPP Distribution

Table 2-1.

Table 2-1. SQAPP Distribution List

Name/Title Contact Information Mailing Address

U.S. Environmental Protection Agency, Engineering and Analysis Division

Lisa Biddle

EPA 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.gov
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Table 2-1. SQAPP 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, EPA 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 presents the basic steps of the ELG 

process.

Project Description

Discharge regulations for the oil and gas industry are codified in 40 CFR Part 435. For Subpart C, 

Onshore Subcategory, BPT guidelines are “no discharge of waste water pollutants”; however, Subpart C 

does not include 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. Because EPA plans to propose 

pretreatment standards that prohibit the discharge of UOG wastewater pollutants to POTWs, EPA does 

not plan to calculate numerical pretreatment standards 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 Work Assignment 1-38, ERG will support EPA’s development of pretreatment standards and 

related supporting 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 deliverables 
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that document the data and that document EPA’s decisions for using the collected data. Table 2-2 presents 

the specific work activities that ERG is supporting 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 processes that generate 

wastewater subject to the Clean Water Act (CWA), pollutant 

discharges and their impacts, and wastewater management and 

disposal practices.

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 technical support 

for the following activities:

• Engineering 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 implementation support

In collecting existing data as part of the UOG 

proposed rulemaking, EPA seeks to answer the 

following questions:

• What operators and wells are included 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 flowback 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 program 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 (Tables 2-3 and 2-4). The ERG WAM will have overall responsibility for ensuring 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.

.
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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 Erickson
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Table 2-3. WA 1-38 ERG Project Staff Responsibilities

Project Role Summary of Responsibilities

ERG WAM Coordinates 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 appropriate internal ERG deliverable reviews prior to 

delivery to EPA.

• Review select deliverables, as required 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 and documented for all deliverables (see Section 4.0).

ERG Senior 

Technical 

Reviewer

Assumes the following responsibilities, in addition to those listed 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

Assume 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 record database and answer 

questions about deliverables and/or docket items.

3.0 COLLECTION OF EXISTING DATA FOR USE IN THE UOG PROPOSED RULEMAKING 

The following subsections of this SQAPP discuss the types of existing data ERG collected and how ERG 

assessed the quality of existing data sources. Section 4.2 of the existing approved 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.

ERG 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 vendors; through outreach to

stakeholders including industry groups, environmental groups, and state regulators; by conducting an 

extensive review of published information; and by participating in industry conferences and webinars.

ERG began collecting data through targeted searches for literature about the UOG industry. Through 

these targeted literature searches and general Internet searches, ERG identified select publicly available 

data sets (e.g., Pennsylvania Department of Environmental Protection (PA 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 industry. ERG and 

EPA also worked together to obtain information from the EPA regional offices and states, where data 

were not available from other sources.
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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 were typically qualitative assessments that answered the 

key questions presented in Table 2-2. The answers to these key questions provided input for the main 

sections 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/organization) 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, the 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 

author affiliation and document context (e.g., conference proceedings, peer-reviewed publication). Source 

flags are only assigned to references that have been identified as containing information relevant to UOG 

operations (as identified by the UOG project team 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 peerreviewed 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 

verifieda source that include 

citation information.

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

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

vendor publications).

• Conference presentations that include citations.
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Table 3-1. Source Flag Descriptions and Examples

Source 

Flag Description Examples

C Documents prepared by a 

verifieda source that do not 

include citation information.

• Industry or other publications relevant to the UOG industry that 

do not include citations.

• Conference presentations from a verified source in the UOG 

industry that do not include citations.

• Industry or treatment facility websites.

D Documents prepared by a 

source that could not be verified 

and that do 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 deliverables 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 the 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 

appropriate 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 

flag 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 WAM

will work together to determine the level of quality control (QC) necessary. Therefore, in 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 perform a 20 percent 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 for 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.”
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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 rulemaking. ERG developed the 

source flags1 shown in Table 3-1 to aid in determining suitable sources.

4.0 ERG’S DELIVERABLE REVIEW PROCESS

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. 

The document author must first determine the levels of review that are required for the specific document 

(see Table 10-1 in the PQAPP) and a schedule for the review. The document author works 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 may be required are listed below:

Step 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 Manager 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)

• DCN2

• 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 DCN 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).
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When the document is ready for review, the document author emails the reviewer(s) directly to request a 

review of the document, including the location of all relevant documents. The document author copies 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 following 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.

• File path and the due date for the reviewer’s comments to the email.

After emailing the reviewer(s), the document author enters the document’s Network Location

Step 4. Update the Document Review Tracking Sheet (Document Author)

3 into the 

Document Review Tracking spreadsheet. Additionally, the document author populates 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 tracking sheet and enters the Date 

Comments Provided upon receipt of comments from the reviewer. The document author incorporates the 

comments received into the next version of the file for review or delivery (e.g., for a deliverable going 

through technical and WAM 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 responds to the document author’s email request when the review is complete and copies

the UOG_QA email account. The reviewer sends the location of the files 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 delivers the document 

to the client and copies the UOG_QA email account. When comments are received from the client, the 

document author forwards the email from the client to the UOG_QA email account. After the client’s 

comments are incorporated, the document author copies the UOG_QA email account when delivering the 

revised document. The document author also populates 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 the end of the file name (e.g., UOG TDD_2014.03.20_SYRev) in the Network 

Location folder.
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extensive, the document author works with the ERG WAM or task lead to determine if the revised

document should be treated as a new deliverable. If so, the document author will restart the review 

tracking process for the new deliverable at Step 1.

Three days prior to the WAM’s TPR review, the index keeper reminds 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 the 

tracking sheet. The document author updates 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 

forwards the relevant emails to the account or reminds the responsible 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 confirms that the review process was completed for all 

deliverables listed 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, the 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 TPR.