### MEMORANDUM

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

FROM: Sarah Yates, ERG

James K. O’Connell, ERG

DATE: March 3 1

, 201 5

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 Propose d Effluent Limitations Guidelines and Standards for Oil and Gas Extraction (DCN SGE00704)

. T his 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 e ither 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 N umber TDD Figure/Table Name Relevant TDD Chapter Relevant

Memo Section Relevant Tab Name(s)

Within Attachment 1 (DCN SGE00929.A 0 1) 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 Comp o sed of UOG Extraction Wastew ater 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 : Tec hnical 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 FigureMemorandum

M arch 31 , 2015 Page 2

Table 1 . Overview of Information Covered in This Memorandum

TDD Figure/Table N umber TDD Figure/Table Name Relevant TDD Chapter Relevant

Memo Section Relevant Tab Name(s)

Within Attachment 1 (DCN SGE00929.A 0 1) 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 Discussion a 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 t his discussion describes the data from Attachment 1 that are included in the text about the Wheeling POTW in S ection s 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 gas 2 produced by wells drilled 3 into 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 completi on, or well treatment for unconventional oil and gas extraction

. 4 UOG extraction wastewater includes produced water, drilling wastewater, and produced sand 5

.

 P roduced water

– the water (brine) brought up from the hydrocarbon

- bearing strata during the extra ction 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 Lon g

- 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 “dril l 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 oi l 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 stormw ater. 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

M arch 31 , 2015 Page 3

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

rates than flowback.

 Drilling wastewater

- t he 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 S ECTION D.5.2, H ISTORY OF POTW A CCEPTANCE OF UOG E XTRACTION

W ASTEWATER
ERG compiled data on POTWs in Pennsylvania

, New York , and West Virginia 6 that accepted UOG extraction wastewater , including the year that each POTW stopped accepting UOG e xtraction 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 review ed 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 Wat er Administrators (ACWA ) ( DCN S GE00762)

.

 EPA Region 3’s website ( DCN S GE 00368 )

.

 Site visits, conference calls, and meetings w ith industry representatives ( DCN S GE00613; DCN S GE00521), UOG operators ( DCN S GE00625; DCN S GE00635; DCN S GE00275; DCN S GE00280), centralized waste treatment ( CWT ) facilities ( DCN S GE00299; DCN S GE00300; DCN S GE00245; DCN S GE00244), and Native American tribal groups ( DCN S GE00785 ).

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 wa stewater in any other, additional states.Memorandum

M arch 31 , 2015 Page 4

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

report data 7 ( DCN S GE00188; DCN S GE00739)

.

 U.S. Department of Energy’s ( DOE ) 2010 “Water Management Technologies Used by Marcellus Shale Gas Producers” repo rt ( DCN S G E00011 )

.

 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.A 0 1). 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 wastewater 9

. The “POTWs Accepting UOG WW” tab in Attachment 1 (DCN SGE00929.A 0 1) shows all POTWs for which ERG collected data, including those not include d 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 ) extracti on wastewater 8 )

.

7 PA DEP’s was te 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 D epartment 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 wa stewater. 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 w as 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

M arch 31 , 2015 Page 5

1.2 Percentage of Total POTW Influent Wastewater Compo sed of UOG Extraction

Wastew ater 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 t he corresponding year when this maximum occurred

. The “Percent of Influent” tab in Attachment 1 (DCN SGE00929.A 0 1) shows the underlying data and analyses that ERG performed to create Table D

- 11.

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

“ POTWs by Resource & Waste Type ” tab in Attachment 1 (DCN SGE00929.A 0 1). ERG collected data from the PA DEP waste reports for years 2004 through 2013, with the except ion 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 SGE00 739).

ERG provides the discharge monitoring report ( DMR ) d ata 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.A 0 1)

. The DMR LT provides average total influent wastewater at each POTW and indicates exceedances experienced at each POTW.

ERG used the following data source s 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 W astewater Volume Accepted (gpd) 10
ERG total ed 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 Resou rce & 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 a s 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 flow 11 (“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 ga l/bbl and dividing by 365 days/year.Memorandum

M arch 31 , 2015 Page 6

Attachment 1)

, ERG averaged the re ported 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 Reynoldsvi lle) 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.A 0 1).

ERG calcu lated the percentage of the POTW ’s i nfluent 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 Tab le D

- 11.

Equation 1

2.0 TDD S ECTION D.5.3.1, UOG E XTRACTION W ASTEWATER C ONSTITUENTS

D ISCHARGED U NTREATED FROM POTW S AND TDD S ECTION D.5.3.2, UOG E XTRACTION W ASTEWATER C ONSTITUENTS AND POTW I NHIBITION AND D ISRUPTION
ERG analyzed effluent data from se veral 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 gene rated 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

- 1 1 )

Figures D

- 10 and D

- 1 1 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 stag es 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 InfluentMemorandum

M arch 31 , 2015 Page 7

information to support its evaluation of the ability of treatment processes to remove Cl and 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 t he Clairton POT W , it use d 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 slud ge, final settling tanks, and chlorine disinfection (DCN SGE00758 ). T he 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 ti me of the sampling at t he McKeesport POTW , it use d 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 P OTW 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 ta nk, 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.A 0 1) of this memorandum show th e raw data for Figure s D

- 10 and D

- 11 13 . Because sampling at each POTW was done at several points during the treatment process, th e data are organized by the location of the sample. ERG created a box plot for each stage of treatment to present the concentrat ion data for Cl and 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 Cl and TDS after each treatment step

.

12 A comminutor is a machine that reduce s 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 usin g EPA approved methods.”Memorandum

M arch 31 , 2015 Page 8

2.2 Annual Average Daily Ef fluent Concentrations and POTW Flows (Figure D

- 12 , Figure D

- 13, Figure D

- 14, Figure D

- 15)

T he following four POTWs are discussed in this section :

 Ridgway POTW (Figure D

- 12);

 Johnstown POTW (Fig ure D

- 13 );

 California POTW (Fig ure D

- 14) ; and

 Charleroi POTW (Fig ure 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 y

axis (left

- side ) shows effluent pollutant concentr ations (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 w ere 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 separ ately 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.A 0 1) contains two worksheets for each of the four POTWs i ntroduced 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 includ es the PA DEP Waste Reports data, DMR LT data, and ERG’s calculations. The data summary worksheets each have information for 2008 through 2013 14 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 SGE00 608 )

, and data from the PA DEP statewide waste reports (DCN SGE00739; DCN SGE00 188 ). ERG presents the relevant pollutant concentration a nd exceedance counts from the DMR Pollutant Loading Tool in the “DMR LT Data” and “Exceedances” tab s , respectively, in Attachment 1 (DCN SGE00929.A 0 1 ) as well as data for individual facilities i n 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.A 0 1 ). ERG used the following data from these sources to complet e this analysis:

 DMR Pollutant Loading Tool: Actual average annual POTW inflow (1,000 gpd), pollutant concentrations, and e xceedance counts

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

M arch 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 L T Data” tab in Attachment 1).

ERG found e xceedance data using the “Everyday Searches

– Facility Exceedance Counts” search function in the DMR LT and searched for the each facility permit. E xceedance 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 wate r 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 un

aggregated values for each year (200 4

- 2006, 2008

- 2013) a nd 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.A 0 1). ERG did not present these data as a fig ure for the TDD because PA DEP data for transfers of UOG wastewater to this POTW were only available for
one year. It is u nknown if UOG extraction wastewater from other states ( e.g., W est V irginia ) 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 Attachm ent 1 along with an indication of which source ERG used to obtain each piece of data

.
3.0 Q UALITY C ONTROL P ROCEDURES
All of the analyses presented in this memorandum adhered to the Environmental Engineering Support for Clean Water Regulations Programmatic Qua lity Assurance Project Plan (PQAPP) (DCN SGE00957) and the Unconventional Oil and Gas (UOG) Supplemental Quality Assurance Project Plan (SQAPP) (DCN SGE00 958 ), including collecting, evaluating, and analyzing existing data and information about POTWs

. Speci fically, 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

M arch 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 f or a government agency (e.g., site visit reports, industry meeting notes);

 Source Flag B

- Documents prepared by a verified 15 source that include citation information (e.g., operator reports, vendor documents, university publications);

 Source Flag C

- Doc uments 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 citat ion 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 spreadsh eet provided in Attachment 1 (DCN SGE00929.A 0 1) 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 ve rsion s of the spreadsheet.

 An ERG senior staff member familiar with ELGs and the UOG proposed rulemaking review ed the results from each analysis in the two spreadsheets.

4.0 R EFERENCES

Table 2 provides all of the references that ERG used for the analys e s 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 Flag a
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 informati on by looking for company/organization websites that confirmed the author’s affiliation with the UOG industry.Memorandum

M arch 31 , 2015 Page 11

Table 2

. References Used for This Memorandum

DCN Source Citation Source Flag a
SGE00188 O'Connell, James, ERG.2014. Pennsylvania Department of Environmental

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

S GE00244 ERG. 2012. Camp, Meghan; Bicknell, Betsy; Ruminski, Brent. Notes on

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

S GE00245 ERG. 2012. Camp, Meghan et. al. Notes on Conference Call with Reserved

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

S GE00275 U.S. EPA. 2012. Site Visit Report: Citrus Energy Corporation Marcellus

Shale Gas Operations. (January 22). A

S GE00280 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

S GE00299 U.S. EPA. 2012. Site Visit Report: US Gas Field Fluids Management

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

S GE00300 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.A 0 1 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). AMemorandum

M arch 31 , 2015 Page 12

Table 2

. References Used for This Memorandum

DCN Source Citation Source Flag a
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). C ourthouse 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

S GE00625 U.S. EPA. 201 5 . Site Visit Report: Southwestern Energy (SWN) Fayetteville

Shale Gas Operations Sanitized A

S GE00635 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. 201 5 . 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: Author ity 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

S GE00785 U.S. E PA . 201 5

. Summary of Discussions with Native American Tribes

Regarding Unconventional Oil and Gas

. AMemorandum

M arch 31 , 2015 Page 13

Table 2

. References Used for This Memorandum

DCN Source Citation Source Flag a
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 Qualit y

Assurance Project Plan (SQAPP)

. A

SGE00997.A 0 4 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 document s, 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 co uld not be verified and that do not include citation information.A TTACHMENT 1 : POTW S D ATA FOR TDD ( DCN SGE00929 .A 0 1 )