MEMORANDUM

TO: Lisa Biddle, Engineering and Analysis Division, U.S. EPA

FROM: Sarah Yates, ERG

James K. O’Connell, ERG

DATE: March 31, 2015

SUBJECT: Publicly Owned Treatment Works (POTW) Memorandum for the Technical 

Development Document (TDD) (DCN SGE00929)

This memorandum describes data and methods that ERG used to compile information on 

publicly owned treatment works (POTWs) for the Technical Development Document (TDD) for 

Proposed Effluent Limitations Guidelines and Standards for Oil and Gas Extraction (DCN 

SGE00704). This memorandum focuses on the tables and figures included in Chapter D.5 of the 

TDD, as listed in Table 1. Tables and figures in the TDD that are not listed below either did not 

require calculations and/or analyses by ERG or are described in separate, supporting memoranda. 

Appendix F of the TDD provides a crosswalk of all tables and figures in the TDD and the name 

of the relevant supporting memorandum.

For the tables/figures explained in more detail in this memorandum, Table 1 provides the 

TDD chapter, memorandum section, and attachment information. 

Table 1. Overview of Information Covered in This Memorandum

TDD 

Figure/Table 

Number TDD Figure/Table Name

Relevant 

TDD 

Chapter

Relevant 

Memo 

Section

Relevant Tab Name(s) 

Within Attachment 1 

(DCN SGE00929.A01)

Table D-10 POTWs That Accepted UOG Extraction 

Wastewater from Onshore UOG 

Operators

D.5.2 1.1 POTWs Accepting 

UOG WW

Table D-11 Percentage of Total POTW Influent 

Wastewater Composed of UOG 

Extraction Wastewater at POTWs 

Accepting Wastewater from UOG 

Operators

D.5.2 1.2 Percent of Influent; 

POTWs by Resource & 

Waste Type; DMR LT 

Data

Figure D-10 Clairton POTW: Technical Evaluation 

of Treatment Processes’ Ability to 

Remove Chlorides and TDS

D.5.3.1 2.1 Clairton Data; Clairton 

Figure

Figure D-11 McKeesport POTW: Technical 

Evaluation of Treatment Processes’ 

Ability to Remove Chlorides and TDS

D.5.3.1 2.1 McKeesport Data; 

McKeesport Figure

Figure D-12 Ridgway POTW: Annual Average Daily 

Effluent Concentrations and POTW 

Flows

D.5.3.1 2.2 Ridgway Summary of 

Data; Ridgway Figure

Figure D-13 Johnstown POTW: Annual Average 

Daily Effluent Concentrations and 

POTW Flows

D.5.3.2 2.2 Johnstown Summary of 

Data; Johnstown Figure
Memorandum

March 31, 2015

Page 2

Table 1. Overview of Information Covered in This Memorandum

TDD 

Figure/Table 

Number TDD Figure/Table Name

Relevant 

TDD 

Chapter

Relevant 

Memo 

Section

Relevant Tab Name(s) 

Within Attachment 1 

(DCN SGE00929.A01)

Figure D-14 California POTW: Annual Average 

Daily Effluent Concentrations and 

POTW Flows

D.5.3.2 2.2 California Summary of 

Data; California Figure

Figure D-15 Charleroi POTW: Annual Average Daily

Effluent Concentrations and POTW 

Flows

D.5.3.2 2.2 Charleroi Summary of 

Data; Charleroi Figure

[No Figure or 

Table]

Wheeling POTW Data Discussiona D.5.3.1; 

D.5.3.2

2.3 Wheeling Summary of 

Data

a

– Wheeling POTW data are not presented in a figure or table, however this discussion describes the data from 

Attachment 1 that are included in the text about the Wheeling POTW in Sections D.5.3.1 and D.5.3.2 of the 

TDD.

This memorandum will refer to the following terms used throughout the TDD, the 

supporting memoranda, and memoranda attachments: 

 Unconventional oil and gas (UOG) resources

1

- crude oil and natural gas2

produced by wells drilled3into low porosity, low permeability formations

(including, but not limited to shale gas, shale oil, tight gas, tight oil).

 UOG extraction wastewater - sources of wastewater pollutants associated with 

production, field exploration, drilling, well completion, or well treatment for 

unconventional oil and gas extraction.

4 UOG extraction wastewater includes 

produced water, drilling wastewater, and produced sand5.

 Produced water – the water (brine) brought up from the hydrocarbon-bearing 

strata during the extraction of oil and gas. This can include formation water, 

injection water, and any chemicals added downhole or during the oil/water 

separation process. Based on the stage of completion and production the well is 

in, produced water can be further broken down into the following components:

o Flowback –the produced water generated in the initial period after hydraulic 

fracturing prior to production (i.e., fracturing fluid, injection water, any 

chemicals added downhole, and varying amounts of formation water). 

o Long-term produced water (LTPW) –the produced water generated during the 

production phase of the well after the initial flowback process. Long-term 

produced water consists primarily of formation water and continues to be 

 

1 UOG resource types are categorized into shale and tight formations.

2 Natural gas can include “natural gas liquids,” components that are liquid at ambient temperature and pressure.

3 UOG wells may be drilled using horizontal, vertical, or directional well trajectories. Literature sometimes refers to 

well trajectory as “drill type”.

4

Stormwater is not considered a source of UOG extraction wastewater. In general, no National Pollutant Discharge 

Elimination System (NPDES) permit is required for discharges of stormwater from any field activities or operations 

associated with oil and gas production, except as specified in 40 C.F.R. 122.26(c)(1)(iii) for discharges of a 

reportable quantity or that contribute to a violation of a water quality standard. States may impose additional 

requirements for management of drilling site stormwater. 

5 Drilling wastewater and produced sand are not discussed in this memorandum. Additional information about 

drilling wastewater can be found in ERG’s Unconventional Oil and Gas (UOG) Drilling Wastewater memorandum 

(DCN SGE00740).
Memorandum

March 31, 2015

Page 3

produced throughout the lifetime of the well, though typically at much lower 

rates than flowback.

 Drilling wastewater - the liquid waste stream separated from recovered drilling 

fluid (mud) and drill cuttings during the drilling process. Drilling fluid is the 

circulating fluid used in the rotary drilling of wells to clean and condition the hole 

and to counterbalance formation pressure.

 Drill cuttings—the particles generated by drilling into subsurface geologic 

formations and carried out from the wellbore with the drilling fluid (mud). 

1.0 TDD SECTION D.5.2, HISTORY OF POTW ACCEPTANCE OF UOG EXTRACTION 

WASTEWATER

ERG compiled data on POTWs in Pennsylvania, New York, and West Virginia6that

accepted UOG extraction wastewater, including the year that each POTW stopped accepting 

UOG extraction wastewater and the year that each POTW accepted its maximum amount of 

UOG extraction wastewater, where the data were available.

1.1 POTWs That Accepted UOG Extraction Wastewater from Onshore UOG 

Operators (Table D-10)

TDD Table D-10 lists POTWs in Pennsylvania, New York, and West Virginia that, at 

one point in time, accepted UOG extraction wastewater. All of the POTWs listed in Table D-10 

accepted UOG extraction wastewater directly from operators. None of the POTWs listed in 

Table D-10 currently accept UOG extraction wastewater, and the year in which each POTW 

stopped accepting UOG extraction wastewater is shown in Table D-10.

ERG reviewed and analyzed the following sources to determine which POTWs to include 

in Table D-10:

 Notes from calls with Regional and State pretreatment program coordinators (DCN 

SGE00742, DCN SGE00743).

 Notes from EPA-State implementation pilot project with the Environmental Council 

of the States (ECOS) in coordination with the Association of Clean Water 

Administrators (ACWA) (DCN SGE00762).

 EPA Region 3’s website (DCN SGE00368).

 Site visits, conference calls, and meetings with industry representatives (DCN 

SGE00613; DCN SGE00521), UOG operators (DCN SGE00625; DCN SGE00635; 

DCN SGE00275; DCN SGE00280), centralized waste treatment (CWT) facilities

(DCN SGE00299; DCN SGE00300; DCN SGE00245; DCN SGE00244), and Native 

American tribal groups (DCN SGE00785).

 

6 ERG studied data from the PA DEP Waste Reports (DCN SGE00188) among other sources. These reports compile 

data from oil and gas operators in Pennsylvania. These operators discharge their extraction wastewater to various 

facilities in Pennsylvania, New York, and West Virginia. The other data sources that ERG analyzed and that are 

listed in Section 1.1 did not include information about POTWs accepting UOG extraction wastewater in any other, 

additional states.
Memorandum

March 31, 2015

Page 4

 Pennsylvania Department of Environmental Protection’s (PA DEP) statewide waste 

report data7(DCN SGE00188; DCN SGE00739).

 U.S. Department of Energy’s (DOE) 2010 “Water Management Technologies Used 

by Marcellus Shale Gas Producers” report (DCN SGE00011).

 Publicly available data sources identified through Internet searches.

ERG compiled data related to POTWs accepting UOG extraction wastewater from all of 

these sources in the “POTWs Accepting UOG WW” tab in Attachment 1 (DCN 

SGE00929.A01). ERG captured the following types of information about these POTWs: 

 Location (e.g., city);

 NPDES permit number;

 Type of oil and gas wastewater accepted (i.e., UOG; conventional oil and gas, 

COG)

8

;

 Source of oil and gas wastewater (e.g., UOG operator, CWT);

 Dates POTW began accepting and stopped accepting oil and gas wastewater; and 

 Volumes of oil and gas wastewater accepted.

During this data review, ERG did not identify any POTWs that were still accepting UOG 

extraction wastewater. ERG included a POTW in Table D-10 if the following criteria were met:

 POTW accepted UOG extraction wastewater directly from an onshore UOG operator 

(i.e., not exclusively from a CWT facility); and

 POTW is not currently accepting UOG extraction wastewater and existing literature 

provided a date when the POTW stopped accepting UOG extraction wastewater9.

The “POTWs Accepting UOG WW” tab in Attachment 1 (DCN SGE00929.A01) shows 

all POTWs for which ERG collected data, including those not included in Table D-10 and those 

that were found to have never accepted UOG extraction wastewater (i.e., only accepted 

conventional oil and gas (COG) extraction wastewater8).

 

7

PA DEP’s waste report data provides wastewater volumes by well over time and disposal information as it was 

reported by the oil and gas well operator to PA DEP. ERG’s memorandum titled “Analysis of Pennsylvania 

Department of Environmental Protection’s (PA DEP) Oil and Gas Waste Reports” provides more detail (DCN 

SGE00739).

8 The PA DEP Waste Reports (DCN SGE00188) consider wastewater from coal-bed methane (CBM) production as 

a portion of COG wastewater, not UOG wastewater. Therefore, any wastewater produced from CBM operations is 

included in the COG wastewater data.

9 ERG sometimes found documentation of the exact date or the month/year in which the POTW stopped accepting 

UOG extraction wastewater. Other times, the existing literature only reported the year in which the POTW stopped 

accepting UOG extraction wastewater. Occasionally, the date in which the POTW stopped accepting UOG 

extraction wastewater was not available at all in the existing literature; this data was excluded from Table D-10 

because the analysis being performed required comparing data for periods before and after the POTW stopped 

accepting UOG extraction wastewater. Even though a date was not available for when some facilities stopped 

accepting UOG extraction wastewater, ERG was able to verify that those facilities were no longer accepting UOG 

extraction wastewater as of 2014.
Memorandum

March 31, 2015

Page 5

1.2 Percentage of Total POTW Influent Wastewater Composed of UOG Extraction 

Wastewater at POTWs Accepting Wastewater from UOG Operators (Table 

D-11)

TDD Table D-11 shows data related to the maximum amount of UOG extraction 

wastewater that was accepted as influent at each POTW. For each POTW, Table D-11 shows the 

maximum annual average daily UOG extraction wastewater percent of POTW influent and the 

corresponding year when this maximum occurred. The “Percent of Influent” tab in Attachment 1 

(DCN SGE00929.A01) shows the underlying data and analyses that ERG performed to create 

Table D-11. 

ERG provides the data from PA DEP statewide waste reports (DCN SGE00739) in the 

“POTWs by Resource & Waste Type” tab in Attachment 1 (DCN SGE00929.A01). ERG 

collected data from the PA DEP waste reports for years 2004 through 2013, with the exception 

of 2007, when no data were available from the PA DEP data. PA DEP’s waste report data 

provides UOG wastewater volumes by well over time and disposition information as it was 

reported by the oil and gas operator of the well to PA DEP. ERG’s Analysis of Pennsylvania 

Department of Environmental Protection’s (PA DEP) Oil and Gas Waste Reports memorandum

provides more detail about the PA DEP waste report data (DCN SGE00739).

ERG provides the discharge monitoring report (DMR) data from the DMR Pollutant 

Loading Tool (DMR LT), available online at http://cfpub.epa.gov/dmr (DCN SGE00608), in the 

“DMR LT Data” tab in Attachment 1 (DCN SGE00929.A01). The DMR LT provides average 

total influent wastewater at each POTW and indicates exceedances experienced at each POTW.

ERG used the following data sources to obtain the data needed to complete this analysis:

 PA DEP Waste Reports: Maximum Annual Average UOG Wastewater Volume 

(barrels (bbl)), presented in TDD Table D-11 as the Maximum Annual Average Daily

UOG Extraction Wastewater Volume Accepted (gpd)10

ERG totaled the extraction wastewater volumes for conventional oil and gas (COG)

and UOG reported in the PA DEP waste reports. For each individual POTW, ERG 

summed the drilling wastewater, flowback, and long-term produced water volumes 

(shown in the “POTWs by Resource & Waste Type” tab in Attachment 1) and 

reported total COG and UOG extraction wastewater volumes (shown in the “POTWs 

Accepting UOG WW” tab in Attachment 1). ERG presents the volume data for the

year with the maximum total UOG extraction wastewater volume in the “Maximum 

Annual Average UOG WW Volume (barrels)” column on the “Percent of Influent” 

tab in Attachment 1.

 DMR Pollutant Loading Tool: Actual Average Annual POTW Inflow (million gallons 

per day (MGD)), presented in TDD Table D-11 as the Corresponding Total Annual 

Average Daily Influent Flow to POTW (MGD)

Where the DMR LT data included multiple values for a POTW’s annual wastewater 

flow11 (“Average Daily Flow (MGD)” column on the “DMR LT Data” tab in 

 

10 ERG converted the data in Attachment 1 from barrels (bbl/year) to gallons per day (gpd) for the TDD by 

multiplying by 42 gal/bbl and dividing by 365 days/year.
Memorandum

March 31, 2015

Page 6

Attachment 1), ERG averaged the reported values for the corresponding year in 

which the maximum UOG extraction wastewater percent of POTW influent occurred 

to get an actual average annual POTW inflow value (MGD).

 Other: Average POTW Inflow (MGD), presented in TDD Table D-11 as the 

Corresponding Total Annual Average Daily Influent Flow to POTW (MGD)

The DMR LT did not have “Average Daily Flow” data for all POTWs of interest. 

Therefore, ERG found average POTW inflow values for three facilities (Belle 

Vernon, Waynesburg, and Reynoldsville) using documents and reports prepared by 

those individual POTWs. DCNs for these sources can be found in the “Source_Actual 

Averages (MGD)” column of the “Percent of Influent” tab in Attachment 1 

(DCNSGE00929.A01).

ERG calculated the percentage of the POTW’s influent that was made up of UOG 

extraction wastewater by dividing the maximum annual average UOG wastewater volume (bbl) 

into the actual average annual POTW inflow (MGD), and converting units, as shown in Equation 

1. ERG reported the results in Table D-11.

Equation 1

 

 

 

 

 

 

 

 

 

 

 

 

 

2.0 TDD SECTION D.5.3.1, UOG EXTRACTION WASTEWATER CONSTITUENTS 

DISCHARGED UNTREATED FROM POTWS AND TDD SECTION D.5.3.2, UOG

EXTRACTION WASTEWATER CONSTITUENTS AND POTW INHIBITION AND 

DISRUPTION

ERG analyzed effluent data from several POTWs in Pennsylvania, West Virginia, and 

Ohio to investigate possible effects of accepting UOG extraction wastewater pollutants on the 

POTWs’ treatment processes and discharges. The following subsections describe the tables and 

figures that ERG generated in TDD Section D.5.3.1 about constituents that may be discharged 

untreated from POTWs and in TDD Section D.5.3.2 about constituents that could cause 

inhibition and disruption at the POTW.

2.1 Technical Evaluation of Ability of Treatment Processes to Remove Chlorides and 

TDS (Figure D-10, Figure D-11)

Figures D-10 and D-11 of the TDD refer to the Clairton and McKeesport POTWs, 

respectively. These figures show the measured concentrations of chloride (Cl-) and total 

dissolved solids (TDS) at various stages in the POTWs’ treatment processes. ERG used this 

 

11 The DMR LT data would include multiple values for a POTW’s annual wastewater flow if the POTW submitted 

sampling data for multiple parameters and/or multiple sampling locations.

Max. Annual Average 

UOG Extraction WW 

% of POTW Influent
Memorandum

March 31, 2015

Page 7

information to support its evaluation of the ability of treatment processes to remove Cland TDS

at these POTWs. 

In 2008, PA DEP issued an Administrative Order (AO) to the Clairton and McKeesport 

POTWs that restricted their acceptance of oil and gas wastewater to amounts no greater than 1% 

of their average daily flow, among other requirements. These AOs also required each POTW to 

evaluate the potential effects of oil and gas production wastewater on its treatment processes

(DCN SGE00758; DCN SGE00757). These evaluations included sampling during various stages 

of treatment at each POTW. The data from these evaluations are the basis for Figures D-10 and 

D-11. 

At the time of the sampling at the Clairton POTW, it used the following treatment 

processes: screening and grit removal, comminutor (i.e., grinder)12, aeration basins, clarifiers, 

activated sludge, aerobic digestion, and chlorine disinfection (DCN SGE00758). To evaluate the 

ability of the treatment processes to remove TDS and Cl-, the POTW took samples at six points 

throughout the treatment facility after major treatment processes: grit removal and screening, 

pre-aeration tanks, settling tanks, activated sludge, final settling tanks, and chlorine disinfection 

(DCN SGE00758). The data for the Clairton POTW are the average of five 24-hour composite 

samples taken from December 8, 2008 through December 12, 2008 by the Clairton Municipal 

Authority (CMA). 

At the time of the sampling at the McKeesport POTW, it used the following treatment 

processes: screening and grit removal, aeration, clarification, activated sludge, aerobic digestion, 

and chlorine disinfection (DCN SGE00745). The detention time at the McKeesport POTW was 

likely between 8 and 12 hours at the time of sampling (DCN SGE01090). To evaluate the ability 

of the treatment processes to remove TDS and Cl-, the POTW took samples at five points 

throughout the treatment facility: inflow, grit chamber, holding tank, primary effluent, and 

outflow. ERG did not include data from the holding tank samples in its analysis because 

McKeesport did not report results for every sampling date (DCN SGE00757). The data for the 

McKeesport POTW are the average of seven 24-hour composite samples taken from November 

1, 2008 through November 7, 2008 by the Municipal Authority of the City of McKeesport 

(MACM).

The “Clairton Data” and “McKeesport Data” tabs in Attachment 1 (DCN 

SGE00929.A01) of this memorandum show the raw data for Figures D-10 and D-1113. Because 

sampling at each POTW was done at several points during the treatment process, the data are

organized by the location of the sample. ERG created a box plot for each stage of treatment to 

present the concentration data for Cland TDS at each of these POTWs (shown in the “Clairton 

Figure” and “McKeesport Figure” tabs). Figures D-10 and D-11 present the maximum, 

minimum, and average concentrations of Cland TDS after each treatment step. 

 

12 A comminutor is a machine that reduces the particle size of wastewater solids using a cutting device.

13 Limited information was provided in the reports regarding analytical methods associated with the raw data. The 

Clairton POTW indicated “pollutants will be analyzed by test procedures under 40 CFR 136.” The McKeesport 

POTW noted that “testing was done using EPA approved methods.”
Memorandum

March 31, 2015

Page 8

2.2 Annual Average Daily Effluent Concentrations and POTW Flows (Figure D-12, 

Figure D-13, Figure D-14, Figure D-15)

The following four POTWs are discussed in this section:

 Ridgway POTW (Figure D-12); 

 Johnstown POTW (Figure D-13);

 California POTW (Figure D-14); and 

 Charleroi POTW (Figure D-15). 

In each of the four figures presented in the TDD (i.e., Figure D-12 through Figure D-15), 

ERG plots pollutant concentration and wastewater flow over the course of several years. The yaxis (left-side) shows effluent pollutant concentrations (mg/L). The values are plotted as points, 

connected by lines. Each POTW is required to monitor a suite of parameters as defined in their 

individual NPDES permits. This monitoring data is reported on the POTW’s discharge 

monitoring report (DMR). ERG could only present pollutant concentrations where data were

available, so the parameters displayed in each figure were chosen based on availability and 

relevance to UOG wastewater (based on the UOG extraction wastewater characterization data in 

Section C.3 in the TDD). The y-axis (right-side) shows the annual average wastewater influent 

flow from oil and gas operators to each POTW. These values are represented as bars, and UOG 

and COG wastewater flows are presented separately as stacked bars. ERG also labeled the 

figures with the number of permit limit exceedances and the years the POTWs accepted UOG 

extraction wastewater, where relevant.

Attachment 1 (DCN SGE00929.A01) contains two worksheets for each of the four 

POTWs introduced at the beginning of Section 2.2 in this memorandum. The first worksheet is 

the data summary for each POTW (e.g., “California Summary of Data”) and includes the PA 

DEP Waste Reports data, DMR LT data, and ERG’s calculations. The data summary worksheets 

each have information for 2008 through 201314 and indicate which source ERG used to obtain 

each piece of data. The second worksheet is the relevant figure for the TDD (e.g., “California 

Figure”).

ERG developed these figures using data obtained from the DMR Pollutant Loading Tool,

available online at http://cfpub.epa.gov/dmr (DCN SGE00608), and data from the PA DEP

statewide waste reports (DCN SGE00739; DCN SGE00188). ERG presents the relevant 

pollutant concentration and exceedance counts from the DMR Pollutant Loading Tool in the 

“DMR LT Data” and “Exceedances” tabs, respectively, in Attachment 1 (DCN SGE00929.A01)

as well as data for individual facilities in the facilities summary tabs (e.g., “California Summary 

of Data”). ERG presents the relevant PA DEP waste report data in the “POTWs by Resource & 

Waste Type” tab in Attachment 1 (DCN SGE00929.A01). ERG used the following data from 

these sources to complete this analysis:

 DMR Pollutant Loading Tool: Actual average annual POTW inflow (1,000 gpd), 

pollutant concentrations, and exceedance counts

 

14 ERG was unable to find 2012 and 2013 DMR data for the Charleroi POTW.
Memorandum

March 31, 2015

Page 9

ERG averaged the reported values for each POTW’s wastewater flow (“Average 

Daily Flow (MGD)” column on the “DMR LT Data” tab in Attachment 1) and 

multiplied the value by 1,000 to convert the units from MGD to “1,000 gpd”.

ERG pulled the average concentrations for a given pollutant in a given year from the 

DMR LT data (“Average Concentration (mg/L)” column on the “DMR LT Data” tab 

in Attachment 1).

ERG found exceedance data using the “Everyday Searches – Facility Exceedance 

Counts” search function in the DMR LT and searched for the each facility permit. 

Exceedance data are shown in the “Exceedances” tab in Attachment 1. ERG presents 

exceedances by facility, year, and parameter.

 PA DEP Waste Reports: Annual total COG and UOG extraction wastewater volumes 

for each POTW (MG)

For each individual POTW, ERG summed the drilling wastewater, flowback, and 

long-term produced water volumes and reported total COG and UOG extraction 

wastewater volumes. The total waste volumes by resource type are presented on the 

“POTWs Accepting UOG WW” tab in Attachment 1. ERG presents the unaggregated values for each year (2004-2006, 2008-2013) and for each waste type on 

the “POTWs by Resource & Waste Type” tab in Attachment 1.

2.3 Wheeling POTW Data

Data for the Wheeling POTW is included on the “Wheeling Summary of Data” tab in

Attachment 1 (DCN SGE00929.A01). ERG did not present these data as a figure for the TDD

because PA DEP data for transfers of UOG wastewater to this POTW were only available for 

one year. It is unknown if UOG extraction wastewater from other states (e.g., West Virginia) was 

treated at the Wheeling POTW. Also, the reported UOG extraction wastewater volume makes up 

a small percent of the total flow to the Wheeling POTW. Concentration and wastewater flow 

data are used anecdotally in Sections D.5.3.1.2 and D.5.3.2.2 and are presented in the “Wheeling 

Summary of Data” tab in Attachment 1 along with an indication of which source ERG used to 

obtain each piece of data.

3.0 QUALITY CONTROL PROCEDURES 

All of the analyses presented in this memorandum adhered to the Environmental 

Engineering Support for Clean Water Regulations Programmatic Quality Assurance Project 

Plan (PQAPP) (DCN SGE00957) and the Unconventional Oil and Gas (UOG) Supplemental 

Quality Assurance Project Plan (SQAPP) (DCN SGE00958), including collecting, evaluating, 

and analyzing existing data and information about POTWs.

Specifically, ERG used the procedures described in Section 4 of the PQAPP to gather and 

manage existing data in support of the UOG proposed rulemaking. ERG staff entered reference 

information for relevant sources into the UOG Literature Review database. The ERG index 

keeper reviewed all reference information, assigned each reference a Document Control Number 

(DCN), imported the reference information into the UOG Project File Index database, and saved 

referenced files in the Electronic Project File folder.
Memorandum

March 31, 2015

Page 10

ERG also used the procedures described in Section 3 of the SQAPP when collecting 

existing data for use in the UOG proposed rulemaking. ERG used a combination of sources, 

including reports, papers, and online databases from state regulatory agencies such as

departments of environmental protection and oil and gas commissions. As shown in Table 2 in 

this memorandum, ERG assigned a source flag (A, B, C or D) to all references used in these 

analyses which are defined below.

 Source Flag A - Journal articles and documents prepared by or for a government 

agency (e.g., site visit reports, industry meeting notes); 

 Source Flag B - Documents prepared by a verified15 source that include citation 

information (e.g., operator reports, vendor documents, university publications); 

 Source Flag C - Documents prepared by a verified source that do not include citation 

information (e.g., operator reports, vendor documents, conference presentations); and 

 Source Flag D - Documents prepared by a source that could not be verified and that 

do not include citation information.

EPA and ERG followed the procedures described in Section 7.0 of the PQAPP to 

generate, evaluate, and analyze data using a spreadsheet. ERG conducted the following QA 

checks during the analyses:

 ERG created the POTWs Data for TDD spreadsheet provided in Attachment 1 

(DCN SGE00929.A01) to track useful data and to document analyses.

 ERG performed a 20 percent check of all data entry.

 ERG performed a 100 percent check of all data analyses and calculations, and 

documented these in internal versions of the spreadsheet.

 An ERG senior staff member familiar with ELGs and the UOG proposed 

rulemaking reviewed the results from each analysis in the two spreadsheets.

4.0 REFERENCES

Table 2 provides all of the references that ERG used for the analyses discussed in this 

memorandum. ERG assigned source flags to each of the sources referenced in this memorandum

(see Section 3.0 for a discussion of source flags).

Table 2. References Used for This Memorandum

DCN Source Citation 

Source 

Flaga

SGE00011 Veil, John A. 2010. Water Mgmt Technologies Used by Marcellus Shale Gas 

Producers. Prepared by Argonne National Lab. Prepared for U.S. DOE 

NETL.

A

 

15 ERG considered sources as “verified” 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. 
Memorandum

March 31, 2015

Page 11

Table 2. References Used for This Memorandum

DCN Source Citation 

Source 

Flaga

SGE00188 O'Connell, James, ERG.2014. Pennsylvania Department of Environmental 

Protection’s (PA DEP) Statewide Oil and Gas Waste Reports. (December)

A

SGE00244 ERG. 2012. Camp, Meghan; Bicknell, Betsy; Ruminski, Brent. Notes on 

Conference Call with 212 Resources on 4 January 2012. (January 9)

A

SGE00245 ERG. 2012. Camp, Meghan et. al. Notes on Conference Call with Reserved 

Environmental Services, LLC on 5 January 2012. (February 1)

A

SGE00275 U.S. EPA. 2012. Site Visit Report: Citrus Energy Corporation Marcellus 

Shale Gas Operations. (January 22).

A

SGE00280 U.S. EPA. 2013. Site Visit Report: Anadarko Petroleum Corporation 

Marcellus Shale Gas Operations. (January 9).

A

SGE00286 Hammer, R. et. al. 2012. In Fracking’s Wake: New Rules Are Needed to 

Protect Our Health and Environment from Contaminated Wastewater. NRDC 

D:12-05-A

A

SGE00299 U.S. EPA. 2012. Site Visit Report: US Gas Field Fluids Management 

(formerly Clean Streams) Marcellus Shale Gas Operations. (October 9).

A

SGE00300 U.S. EPA. 2012. Site Visit Report: Eureka Resources, LLC Marcellus Shale 

Gas Operations. (February 25).

A

SGE00368 U.S. EPA. 2012. (Region 3). Key Documents About Mid-Atlantic Oil and 

Gas Extraction. (November 26). http://www.epa.gov/region3/marcellus_shale/

A

SGE00368.A01 U.S. EPA. 2013. Key Documents About Mid-Atlantic Oil and Gas Extraction. 

(January 9). Available online at: 

http://www.epa.gov/region3/marcellus_shale/pdf/responses2info-req5-12-

11/swepi255-508.pdf

A

SGE00493 Allegheny Valley Joint Sewage Authority. 2011. Letter to PA DEP (Permit 

ID: PA0026255). (March 29).

A

SGE00494 Allegheny Valley Joint Sewage Authority. 2011. Letter to U.S. EPA Region 

3. (October 3).

A

SGE00495 Altoona Water Authority. 2011. Letter to PA DEP (Permit ID: PA0027014). 

(April 6).

A

SGE00506 Bissell, Alex. Unknown. Wastewater Wasteland: An Investigation of 

Flowback Fluid Disposal in NY. Neighbors of the Onondaga Nation.

B

SGE00514 Clairton Municipal Authority. 2011. Letter to U.S. EPA Region 3. (September 

30).

A

SGE00515 Clean Water Action (CWA). 2012. Groups Reach Settlement with 

McKeesport in Gas Drilling Wastewater Dumping Case. (May 1).

C

SGE00521 ERG. 2012. Camp, Meghan; Ruminski, Brent. Notes for Shale Gas Industry 

Meeting Held on 29 February 2012. (April 20).

A

SGE00522 Env Review Appeals Comm, State of OH. 2012. Patriot Water Treatment and 

City of Warren v Chris Korleski and Scott Nally: 2012 Decision.

A

SGE00538 Johnstown Redevelopment Authority. 2011. Letter to U.S. EPA Region 3. 

(September 30).

A

SGE00539 Johnstown Redevelopment Authority. 2012. Letter to U.S. EPA Region 3. 

(December 19).

A

SGE00540 Kiski Valley Water Pollution Control Authority. 2011. Letter to McCutcheon 

Enterprises, Inc. (April 21).

A
Memorandum

March 31, 2015

Page 12

Table 2. References Used for This Memorandum

DCN Source Citation 

Source 

Flaga

SGE00543 Macormac, Zach. 2011. Wheeling Fined for Taking Frack Water. The 

Intelligencer/Wheeling News-Register. (October 15).

D

SGE00548 McCauley, Erin. 2011. Environmentalists Say Oil-Drilling Sewage is 

Polluting Pittsburgh's Drinking Water. (July 21). Courthouse News Service.

D

SGE00568 Pennsylvania Department of Environmental Protection (PA DEP). 2010. Oil 

& Gas Facility Summary. (August 26).

A

SGE00572 PA DEP. 2012. Return of NPDES Application No. PA0026310 A-2 

(Clearfield Municipal Authority WWTP). (March 30).

A

SGE00576 Pittsburgh Business Times. 2008. Oil, Gas Wells Face Waste Hurdle: Sewage 

Plants Ordered by DEP to Curb Processing Wastewater from Drilling. 

(October 31).

D

SGE00582 Reuther, Mike. 2013. Gas wastewater treatment facility to begin operations. 

(August 21).

D

SGE00608 U.S. EPA. 2012. Discharge Monitoring Report (DMR) Pollutant Loading 

Tool. Downloaded on 1/28/2013. Available online at: 

http://cfpub.epa.gov/dmr/

A

SGE00613 U.S. EPA. 2013. Meeting Summary: Meeting with Industry Representatives 

About the Unconventional Oil and Gas Effluent Guideline Rulemaking. 

(February 28).

A

SGE00625 U.S. EPA. 2015. Site Visit Report: Southwestern Energy (SWN) Fayetteville 

Shale Gas Operations Sanitized

A

SGE00635 US EPA. 2012. Site Visit Report Chesapeake Energy Corporation Marcellus 

Shale Gas Operations Sanitized.

A

SGE00704 U.S. EPA. 2015. Technical Development Document for Proposed Effluent 

Limitations Guidelines and Standards for Oil and Gas Extraction.

A

SGE00739 ERG. 2015. Analysis of Pennsylvania Department of Environmental 

Protection’s Oil and Gas Waste Reports.

A

SGE00742 U.S. EPA. 2012. States Pretreatment Coordinators' Quarterly Conference 

Call: Summary. (August 8).

A

SGE00743 U.S. EPA. 2013. States Pretreatment Coordinators’ Bi-monthly Conference 

Call. (August 14).

A

SGE00745 KLH Engineers. 2011. Municipal Authority of the City of McKeesport: 

Headworks Loading Analysis for Natural Gas Drilling Wastewater Pollutants. 

(March).

B

SGE00751 Borough of Charleroi. 2008. Re: Authority of the Borough of Charleroi 

Administrative Order. (November 21).

A

SGE00757 KLH Engineers. 2008. Technical Evaluation of the Impact of Oil and Gas 

Well Wastewaters on the Municipal Authority of the City of McKeesport. 

(November).

A

SGE00758 KLH Engineers. 2009. Technical Evaluation of the Impact of Oil and Gas 

Well Wastewaters on the Clairton Municipal Authority Wastewater Treatment 

Facility. (February).

A

SGE00762 Biddle, Lisa. 2015. Summary of EPA-State Pilot on Improving Regulatory 

Implementation.

A

SGE00785 U.S. EPA. 2015. Summary of Discussions with Native American Tribes 

Regarding Unconventional Oil and Gas.

A
Memorandum

March 31, 2015

Page 13

Table 2. References Used for This Memorandum

DCN Source Citation 

Source 

Flaga

SGE00788 NYSDEC. 2009. Supplemental Generic Environmental Impact Statement 

(SGEIS) on the Oil, Gas, and Solution Mining Regulatory Program.

C

SGE00957 ERG. 2013. Environmental Engineering Support for Clean Water Regulations 

Programmatic Quality Assurance Project Plan (PQAPP).

A

SGE00958 ERG. 2014. Unconventional Oil and Gas (UOG) Supplemental Quality 

Assurance Project Plan (SQAPP).

A

SGE00997.A04 Borough of Waynesburg. 2009. Clean Water Act Section 308 Request for 

Information - Attachment 4: Sampling Summary.

A

SGE01001 Fayette Engineering Co., Inc. 2009. Clean Water Act Section 308 Request for 

Information - Attachment 5: DMR Records. (March 13).

A

SGE01002 Reynoldsville Sewage Authority. 2012. Authorization to Discharge under the 

National Pollutant Discharge Elimination System Discharge Requirements for 

Publicly Owned Treatment Works (POTWs). (July 17).

A

SGE01003 McFadden, Angela; Lovell, John; Biddle, Lisa. 2014. E-mail – POTWs with

IUs that discharge O&G waste, and local limits evaluations. (March 18)

A

SGE01090 ERG. 2015. McKeesport POTW. (March) A

a–Source Flag A - Journal articles and documents prepared by or for a government agency (e.g., site visit 

reports, industry meeting notes); 

Source Flag B - Documents prepared by a verified source that include citation information (e.g., operator 

reports, vendor documents, university publications); 

Source Flag C - Documents prepared by a verified source that do not include citation information (e.g., 

operator reports, vendor documents, conference presentations); and 

Source Flag D - Documents prepared by a source that could not be verified and that do not include 

citation information.
ATTACHMENT 1: POTWS DATA FOR TDD (DCN SGE00929.A01)