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Sanitized Site Visit Report

Southwestern Energy

Fayetteville Shale Operations

March 30, 2015
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TABLE OF CONTENTS

Page

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

2.0 BACKGROUND AND OBJECTIVES .............................................................................. 1

3.0 COMPANY BACKGROUND......................................................................................... 2

4.0 OVERVIEW OF SWN FAYETTEVILLE OPERATIONS ................................................... 3

4.1 Well Development ...................................................................................... 4

4.1.1 Permitting........................................................................................ 5

4.1.2 Water Sources................................................................................. 5

4.1.3 Drilling ............................................................................................ 6

4.1.4 Hydraulic Fracturing ....................................................................... 6

4.1.5 Flowback ......................................................................................... 7

4.1.6 Production ....................................................................................... 7

4.2 Waste Management and Disposal Practices................................................ 8

4.2.1 Transportation ................................................................................. 8

4.2.2 Direct Reuse .................................................................................... 9

4.2.3 Wastewater Treatment for Discharge ............................................. 9

4.2.4 Underground Injection .................................................................. 11

4.2.5 Other Potential Management Options........................................... 11

5.0 SOUTHWESTERN SITES VISITED ............................................................................. 12

5.1 SWN Training Facility – Damascus SOTC.............................................. 13

5.2 Fracturing Site - Green Bay Well pad....................................................... 15

5.3 Flowback Site - Charles Hall Well Pad .................................................... 18

5.4 Judsonia Centralized Wastewater Treatment Facility............................... 22

APPENDIX A LIST OF PARTICIPANTS ON THE CITRUS SITE VISIT.............................................. 27

APPENDIX B POWER POINT PRES ENTATION OF ALL SITE VISIT PICTURES .............................. 29

APPENDIX C DOCUMENTS RECEIVED FROM SWN ..................................................................... 30
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LIST OF FIGURES

Page

Figure 4-1. Map of SWN’s Fayetteville Producing Wells, Wastewater Treatment Facilities, and 

Disposal Wells .........................................................................................................4

Figure 5-1. Map of Sites Visited by EPA ......................................................................................13

Figure 5-2. Cross Section of a Typical SWN Fayetteville Well Casing........................................14

Figure 5-3. Horizontal Separator at Damascus Training Facility ..................................................14

Figure 5-4. Vertical Separator at Damascus Training Facility ......................................................15

Figure 5-5. Reuse Fracturing tanks (left) and Reserve Pit (right) at Green Bay Hydraulic 

Fracturing Site........................................................................................................16

Figure 5-6. Fracturing Base Fluid Holding Tanks (left), Ecosphere Ozone Treatment Unit (right)17

Figure 5-7. Pump Truck at Green Bay Hydraulic Fracturing Site .................................................17

Figure 5-8. Wellhead (left) and Sand Separator (right) at Charles Hall Well pad.........................18

Figure 5-9. Four Corrosion Inhibitor Tanks at Charles Hall Well pad ..........................................19

Figure 5-10. Water/gas Separators (right) and Gas Collection Lines (bottom left corner) ...........20

Figure 5-11. Fracturing Tanks at Charles Hall Well Pad...............................................................21

Figure 5-12. Produced Water Tanks at Charles Hall Well Pad .....................................................21

Figure 5-13. Lined Reserve Pit at Charles Hall Well pad..............................................................22

Figure 5-14. Unloading Bays at Judsonia Centralized Waste Treatment Facility .........................23

Figure 5-15. Sedimentation Ponds (front) and Impoundment (rear) at Judsonia Centralized Waste 

Treatment Facility ..................................................................................................24

Figure 5-16. Purestream’s IGF Treatment Unit at SWN’s Judsonia Treatment Facility...............24

Figure 5-17. Purestream’s AVARAs MVR Unit at SWN’s Judsonia Treatment Facility.............25
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LIST OF TABLES

Page

Table 3-1. SWN 2010 Active Well Counts by Basin and Formation..............................................3

Table 4-1. SWN Fayetteville Wells Drilled Overtime and Costs....................................................4

Table 4-2. Summary of Existing Purestream Installments ............................................................11

Table A-1. List of Attendees..........................................................................................................28
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1.0 INTRODUCTION

On September 12 and 13, 2013, the U.S. Environmental Protection Agency (EPA) met 

with Southwestern Energy (SWN) and visited sites in the Fayetteville Shale Play in Arkansas.

These sites included:

 Damascus Safety Operations & Training Center;

 Charles Hall Well Pad;

 Green Bay Hydraulic Fracturing Well Site; and

 Judsonia Centralized Waste Treatment Facility.

Meeting participants are listed below. Contact information is included in Appendix A.

Appendix B provides a photo log from the site visit and Appendix C provides documents 

received from SWN before and after the site visit.

U.S. EPA Office of Water, Office of Science and Technology, Engineering and Analysis 

Division

Lisa Biddle

Karen Milam

Jesse Pritts

U.S. EPA Region 6

Maria Okpala

Eastern Research Group, Inc. (ERG) (EPA Contractor)

Sarah Hays

Brent Ruminski

Southwestern Energy

Thomas Alexander, Vice President – Health, Safety & Environmental

Jim Bolander, Senior Vice President – Resource Development

Peter Fyfe, Senior Facilities Engineer

Roy Hartstein, Vice President – Strategic Solutions

Mark Mazock, Manger – Water Team

Sean McKaren – Health, Safety & Environmental

Doug Melton, Special Project Manager

2.0 BACKGROUND AND OBJECTIVES

The SWN site visit was the sixth in a series of site visits that the EPA plans for this 

industry. Prior to site visits, the EPA planned to view a range of unconventional oil and gas

extraction operations and wastewater treatment operations that demonstrate a variety of 

treatment options.

The purpose of the SWN site visit was to collect background information on the 

unconventional oil and gas extraction wastewater treatment industry and observe wastewater 

treatment operations. To initiate site visits, the EPA reviewed information about unconventional

oil and gas operators and their wastewater management practices. During this review, the EPA 
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identified SWN as a major operator of shale gas extraction wastewater for treatment, active in 

the Fayetteville Shale Play.

During the SWN Fayetteville Shale site visit, the EPA viewed a range of shale gas 

operations that demonstrate a variety of production and wastewater management options, 

including reuse, centralized waste treatment (CWT), hydraulic fracturing, and gas production at a 

well pad. 

Tom Alexander, Vice President – Health, Safety & Environmental, and Jim Bolander,

Senior Vice President – Resource Development, primarily led the discussion of the company’s 

Fayetteville operations and the site tour. Duke Sochalski of Purestream1, contractor to SWN, led 

the tour through the Judsonia treatment facility, one of three locations (active and pending) that 

SWN uses for wastewater treatment. Mr. Sochalski provided information specific to the 

treatment unit. The remainder of this report summarizes the site visit:

 Section 3.0 provides company background information on SWN;

 Section 4.0 provides an overview of SWN’s Fayetteville operations; and

 Section 5.0 provides site-specific information on the sites EPA visited.

3.0 COMPANY BACKGROUND

SWN, based in Houston, Texas, is the fifth largest oil and gas operator in the United 

States. The company includes approximately 1,200 employees, 360 of whom have offices in 

SWN’s Conway, Arkansas office building. SWN owns and operates unconventional oil and gas 

wells in the states below (shale formations/basins are noted parenthetically):

 Arkansas (Fayetteville Shale Formation);

 Pennsylvania (Marcellus Shale Formation);

 East Texas (Overton Field); and

 Oklahoma (Arkoma Basin).

SWN continues to explore unconventional formations in the following states (shale 

formations/basins are noted parenthetically where they are known):

 Utah (Paradox Basin);

 Colorado (Denver-Julesburg Basin2);

 Southern Arkansas and Louisiana (Brown Dense Formation3); and

 New Brunswick, Canada.

Table 3-1 provides additional information for each basin and formation in which SWN is

active as of 2013, including net acreage and active number of wells. SWN is most active in the 

Fayetteville Shale Play of Arkansas. 

 

1

Purestream is a wastewater treatment vendor that offers services to the unconventional oil and gas industry.

2

SWN owns less than 100,000 acres and is in the early exploration stages in the Denver-Julesburg (DJ) Basin.

3

The Brown Dense Formation is a liquids rich formation. SWN is drilling approximately 8 we lls per year that are 

producing oil at 150-200 bbl per day. SWN noted that to be economical, these wells need to produce approximately 

400 barrels of oil per day.
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Table 3-1. SWN 2010 Active Well Counts by Basin and Formation

States Basin Formation

Net Acreage 

(acres)

Number of 

Active Wells

AR Arkoma Fayetteville 913,500 3,500a

PA Appalachian Marcellus 337,300 129

OK, AR Arkoma White Oak 114,287 Unknown

CO Denver Julesburg Niobrara 302,000 1

TX, LA Unknown Lower Smakcover 

Brown Dense 507,000 0

New Brunswick 

(Canada) Unknown Unknown 2,500,000 0

TX East Texas Overton 49,300 Unknown

a—SWN noted that BHP and XTO are two other active shale play operators in the Fayetteville Shale formation and 

that BHP bought land from Chesapeake Energy.

4.0 OVERVIEW OF SWN FAYETTEVILLE OPERATIONS

The site visit focused on SWN’s operations in the Fayetteville Shale Play where SWN is 

furthest along in the formation development process. This level of development has allowed 

them to implement a proactive approach to wastewater management in this play. SWN noted that 

their wastewater management infrastructure in other plays, such as the Marcellus, is not as 

developed as their Fayetteville infrastructure. However, SWN plans to move Fayetteville

personnel to the Marcellus Shale to start evaluating wastewater management options in more 

detail.

Source: AOGC, 2013 (well locations); SWN (CWTs and disposal well); Map generated using ArcGIS

Figure 4-1 shows a map of SWN’s active producing wells, wastewater treatment 

facilities, and saltwater disposal facility in the Fayetteville Shale Play. SWN noted that they 

strategically located their three CWTs to minimize trucking for disposal. Assuming that gas 

prices stabilize at approximately $5 per MCF as anticipated by the United States Energy 

Information Administration (EIA), SWN projects that they will continue to drill in the 

Fayetteville for another 10 to 15 years at a rate of 400 to 500 wells per year until the formation is 

fully developed.
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Source: AOGC, 2013 (well locations); SWN (CWTs and disposal well); Map generated using ArcGIS

Figure 4-1. Map of SWN’s Fayetteville Producing Wells, Wastewater Treatment Facilities, 

and Disposal Wells

SWN’s Fayetteville operations are described in more detail in the following subsections:

 Well development (e.g., drilling, fracturing); and

 Wastewater management and disposal.

4.1 Well Development

Table 4-1 shows the number of Fayetteville wells that SWN drilled per year from 2007 to 

2012, including the well cost per year and operating costs in dollars per thousand cubic feet of 

natural gas. SWN noted that although the average well capital cost decreased over the years, the 

number of drilling days per well has increased dramatically and the average lateral length has 

increased. In general, SWN has a [REDACTED] percent hurdle rate (i.e., rate of return) on all 

investments.

Table 4-1. SWN Fayetteville Wells Drilled Overtime and Costs

Year

Wells DrilledPer 

Year

Well Capital Cost

(millions dollars)

Long Term Costs

(dollars per MCF)

2007 255 2.9 2.38

2008 329 3.0 1.44

2009 446 2.9 0.80

2010 553 2.8 1.04

2011 560 2.8 1.11

2012 493 2.5 2.53

MCF-Thousand cubic feet of natural gas.

The well development steps discussed include permitting, water acquisition, drilling, 

hydraulic fracturing, flowback, and production. These steps are described in the following 

subsections.
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4.1.1 Permitting

The Arkansas Oil and Gas Commission (AOGC) and Arkansas Department of 

Environmental Quality (ADEQ) are responsible for permitting and oversight of shale gas 

operations in Arkansas. Specifically, AOGC is responsible for permitting oil and gas wells in 

Arkansas while ADEQ is responsible for waste management.

SWN noted that land application of oil and gas wastewater has limited use in Arkansas 

and that it is difficult to get permitting from ADEQ. SWN stated that farmers have inquired 

about using water from SWN’s operations. SWN explained that the farmers haven’t required any 

specific water quality, but noted that shallow groundwater produced from well drilling is likely 

the most applicable water for land application in Arkansas. To-date, SWN has not land applied 

any of their oil and gas wastewater.

SWN builds storage reserve pits to store wastewater for reuse according to Arkansas Oil 

and Gas Commission (AOGC) Rule B17. 4

4.1.2 Water Sources

SWN has constructed its own freshwater ponds, in accordance with Army Corp of 

Engineers requirements, to provide collected surface water as freshwater for hydraulic fracturing

operations. The average size of SWN’s freshwater ponds ranges from 400,000 to 500,000 

barrels. In 2009, SWN added a pipeline transport to deliver freshwater to well pads for 

fracturing.

SWN also entered into an agreement with a local municipal water authority to obtain 

water during droughts. However, SWN has found this to be an uneconomical water source and 

does not plan to continue the agreement once the contract is up. SWN typically stores freshwater 

in unlined ponds. However, to store the treated municipal wastewater, SWN must adhere to 

additional ADEQ requirements, including obtaining a NPDES permit and treating the water (e.g., 

remove chlorine).

Another water source option that SWN has considered is to convert a producing well into 

a brackish water well. When a producing well is no longer economical and is located directly 

above or below a water bearing formation, SWN can recomplete the well into the water bearing 

formation to produce brackish water. SWN noted that this recompletion requires a permitting 

change.

SWN also commented on water source options in other shale formations. In northern 

Louisiana, operators are using pulp discharges as a water source. In the Marcellus Shale, SWN is 

researching using acid mine drainage (AMD) to recharge watersheds from which they are 

removing water for fracture jobs. For example, SWN proposed treating AMD at the source and 

discharging it into the local river and then withdrawing the same volume downstream from the 

 

4 Arkansas Oil and Gas Commission’s General Rules and Regulations, Rule B-17: Well Drilling Pits and 

Completion Pits Requirements (as of February 8, 2013). Available online at: 

http://www.aogc.state.ar.us/onlinedata/forms/rules%20and%20regulations.pdf
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same river at a location closer to where they are fracturing wells. This process would create a 

watershed balance and would reduce require transportation costs.

4.1.3 Drilling

SWN typically drills six to eight wells per pad. SWN owns and operates 14 drilling rigs

in the Fayetteville and 4 drilling rigs in the Marcellus. However, they also use third party drilling 

service providers. In addition, they always use third party service providers to cement their wells 

during drilling. SWN is currently monitoring 8 sputter rigs (6 in the Fayetteville Shale and 2 in 

the Marcellus Shale) and 10 re-entries (8 in the Fayetteville Shale and 2 in the Marcellus Shale).

Sputter rigs are smaller rigs that are used to air drill wells the first several hundred feet. Re-entry 

rigs are larger and are used to drill the remaining vertical section and eventually the horizontal 

leg of the well using water- or oil-based drilling fluid.

SWN has an Operation Support Center (OSC) located in their Conway, AR office that 

monitors all drilling operations for the company. The key responsibilities of the OSC are to 

optimize drilling and mitigate problems, monitor real-time collision avoidance data, manage gas 

lag, and populate and maintain SWN’s well trajectory database. The OSC has been monitoring 

Fayetteville Shale operations since March 2010, and the Marcellus Shale operations were 

brought online in 2012. SWN has seen improved drilling efficiency since implementing the 

OSC.

On the well drilling site, the well site supervisor also has access to similar data in the 

field office as what is housed at the OSC. The OSC provides continuous monitoring of the data 

during times when the supervisor needs to leave the field office to monitor on-site operations, 

which typically occurs at least twice a day.

4.1.4 Hydraulic Fracturing

SWN owns and operates two hydraulic fracturing “teams” to fracture wells. SWN also 

contracts out fracturing jobs to third party vendors such as Halliburton and Cal Frac. SWN 

indicated that they complete half of their fracture jobs themselves using these two teams and 

third-parties complete the other half of the jobs.

SWN described an efficient method of fracturing called a zipper-frac. This method allows 

SWN to fracturing two wells in the same length of time it would typically take to fracture a 

single well at a time. A zipper-frac is a method of subsequently hydraulically fracturing two 

wells using the following repeated process for each fracture stage: 

 Stage 1 of well 1 is perforated using the wire line.

 Stage 1 of well 1 is hydraulically fractured.

 While stage 1 well 1 is being fractured, stage 1 of well 2 is perforated using the 

wire line.

 After stage 1 well 1 fracture is complete it is plugged using the wire line to 

maintain pressure and fracturing of stage 1 well 2 commences.

 Process repeats until all stages are complete for both wells.
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The number of stages in a hydraulic fracture depends on the length of the horizontal leg. 

The average lateral drilled by SWN is 5,000 ft long (with a maximum of approximately 10,000 ft 

long) and SWN averages between 10 and 12 stages per well. The average length of time to 

complete one stage of a fracture is between 2 and 3 hours. Each stage requires up to 15,000 

barrels of fracturing fluid resulting in a total fracturing volume of approximately 120,000 to 

130,000 barrels per well. SWN currently uses 35 percent reuse wastewater and 65 percent 

freshwater on average for fracturing fluid makeup, which allows SWN to reuse nearly 100 

percent of the wastewater generated by previously fractured wells. 

A typical well requires 3 million pounds of sand to fracture. SWN owns a sand plant in 

Little Rock, AR that provides sand for all of its hydraulic fracturing operations. SWN typically 

only adds two chemicals to the hydraulic fracturing fluid in the Fayetteville Shale: biocides and 

friction reducers. On occasion, SWN also adds a corrosion reduction chemical. SWN noted that 

as the fraction of reuse wastewater in the fracturing fluid increases, they must use larger volumes 

of chemicals to account for the higher TDS concentrations. To eliminate the need for biocide, 

SWN uses Ecosphere, which is a company that offers chemical-free wastewater treatment using

ozone to eliminate bacteria and inhibit scaling. Ecosphere’s ozone treatment unit is run “on-thefly” with the fracturing process. The entire fracturing fluid volume is pumped through 

Ecosphere’s unit at 80 to 100 barrels per minute prior to the blending unit and pump trucks. 

4.1.5 Flowback

After fracturing is complete the flowback process begins. The Fayetteville Shale is an 

under-pressure reservoir, meaning that gas will not flow on its own when the wellhead pressure 

is released to commence flowback. As a result, SWN must run small truck-mounted compressors 

at the beginning of the flowback process to initiate flow of natural gas and water using artificial 

lift.

Typically, 10 to 20 percent of the fracturing fluid volume returns to the surface during the 

flowback process. Most wells generate flowback at rates up to 1,000 to 1,100 barrels per day 

immediately after flowback commences. SWN stores flowback into lined reserve pits or 500 

barrel fracturing tanks. SWN noted the following fracturing tank prices:

 Fracturing tanks with secondary containment built-in (Bradley tank): $55 per day

 Fracturing tanks with separate secondary containment: $95 per day

These fracturing tanks are typically only used for the first two weeks until water is 

produced at a low enough rate that it can be handled in the above ground produced water tanks. 

4.1.6 Production

During the production phase, SWN’s Fayetteville wells generate on average anywhere 

between 3.6 and 54.8 barrels of produced water per day. However, the cumulative average 

produced water rate is 10.3 barrels per day. SWN approximated these volumes using water 

generation data for 2,305 wells that have been producing for 60 days or longer. SWN estimated 

that between 25 and 30 percent of the totaled fracturing fluid volume injected will flowback to 

the surface over the entire life of the well (includes flowback and produced water). SWN stores 
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produced water in above ground produced water tanks at all producing well sites. New sites have 

one or more 400 barrel tanks, while older sites have one or more 150 barrel tanks depending on 

how many wells are producing on the well pad. A typical SWN well pad includes six to eight 

wells.

SWN transports produced gas to the Tennessee Gas Pipeline, a set of natural gas 

pipelines running through Arkansas among other locations. Ideally, SWN wants to keep an 80 

psi line pressure at each producing well, which is monitored by SWN personnel in SWN’s 

Houston, Texas office. The Fayetteville Shale produces dry gas consisting of approximately 97

percent methane, with the remaining 3 percent composed of primarily of inert gases, CO2, and 

H2S. 

4.2 Waste Management and Disposal Practices

As explained in Section 4.1.4, SWN currently uses 35 percent reuse wastewater and 65 

percent freshwater on average for fracturing fluid, which allows SWN to reuse nearly 100 

percent of the wastewater generated by previously fractured wells. The following subsections 

provide more detailed information on SWN’s wastewater management practices in the 

Fayetteville Shale Play.

4.2.1 Transportation

SWN has a Logistics Operation Center (LOC) located in their Conway, AR office that 

monitors all transportation operations for the company. The LOC monitors the movement of 

sand, fracturing tanks, mud, casing/tubing, and water for all operations in the Fayetteville Shale 

and Marcellus Shale. The LOC database also houses information about available water sources 

and maximum roadway loads. In order to minimize transportation, SWN tries to only handle the 

water once before it arrives at its final destination. Last year, SWN was able to increase 

efficiency, which they measure using the following parameters:

 Fewer miles driven by trucks (SWN reduced the total amount of transportation by 

2,500 miles last year). 

 Trucks filled to maximum capacity.

 Fewer trucks on the road.

The key responsibilities of the LOC are to provide the following types of data for all 

SWN locations:

 Carrier Management – incident review, performance metrics

 Load Planning – sand sourcing, weekly fracturing planning

 Dispatch – production tanks, water transfers, field transfers

 Reporting – load volume, truck capacity, mileage

 24 Hour Hotline – staff 24 hour emergency hotline

The LOC tracks approximately 700 loads per day, with the following average quantities 

of loads based on 2012 data:
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 Average flowback or freshwater load: 111 barrels per load

 Average produced water load: 90 barrels per load

 Average sand load: 48,000 lbs/load 

SWN contracts all trucking to third-party entities and has seven dedicated carriers. Dedicated 

carriers go through a bid process where they negotiate a rate. Tier 1 carriers have a set rate and 

they are guaranteed a set number of loads. Tier 2 carriers have a (higher) set rate and are not 

guaranteed as many loads. This allows for flexibility in the quantity of trucks needed at a given 

time. The water haulers that SWN uses have contract rates at approximately $80 to $90 per hour. 

A third-party entity, IS NetWorld, gathers health and safety information about each carrier for 

use in the bid process. Each third-party truck has a QualCom satellite communication system 

installed that the LOC uses to locate each truck at any given moment.

SWN also uses pipelines to transport freshwater water only. Typically, they use high 

pressure flex-lines to move water above-ground. SWN does a portion of the pipeline work inhouse, but also contracts to third-party entities. Depending on the particular need on-site, 

pipelines may move freshwater or reuse water.

4.2.2 Direct Reuse

SWN’s currently development rate in the Fayetteville Shale Play is 400 to 500 new wells 

per year, which provides enough demand for fracturing water to enable SWN to reuse nearly 100 

percent of their wastewater. Reuse involves transporting wastewater from the generating well to

another location for temporary storage and then transporting it a second time to the next well that 

is to be fractured. Where possible, SWN tries to truck wastewater directly to the next hydraulic 

fracturing site for use in the fracture job, rather than transporting it to a treatment facility or other 

storage area. 

SWN reported that they typically pay between [REDACTED] per barrel to reuse 

wastewater directly without any treatment. SWN provided a breakdown of this cost:

 Transportation: [REDACTED] per bbl (first move)

 Reserve pits, fracturing tanks, and auxiliaries: [REDACTED] per bbl

 Transportation [REDACTED] per bbl (second move)

 Freshwater cost offset: [REDACTED] per bbl

4.2.3 Wastewater Treatment for Discharge

Although SWN currently reuses all of their wastewater, they indicated that eventually 

wastewater volumes will exceed the water demand for new fracturing jobs. As a result, SWN 

proactively obtained permits to treat and discharge wastewater to prepare for a future need for 

wastewater disposal. SWN has three permitted centralized waste treatment facilities described in 

more detail below. SWN is permitted to accept wastewater from other oil and gas operators at all 

three of these facilities. However, at the time of the site visit, SWN was not accepting

wastewater from other operators. SWN continues to construct their facilities, refine their 

treatment systems, research additional treatment options and negotiate contracts with other 

operators.
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 Judsonia treatment facility: This facility is currently operating a wastewater 

treatment system consisting of induced gas flotation (IGF) followed by 

mechanical vapor recompression (MVR). The distilled wastewater is currently 

permitted for discharge under NPDES permit AR052051 but SWN is still making 

adjustments to the treatment system to meet their discharged limits. As a result, 

all distilled wastewater is currently being reused for fracturing. The EPA visited 

the Judsonia treatment facility during their site visit on September 12, 2013. The 

Judsonia treatment facility is discussed in more detail in Section 5.4 of this report.

 Cleveland treatment facility: This facility is currently operating as a zero 

discharge facility. The facility does not currently have any treatment on-site; it 

only has lined impoundments for storage of flowback and produced water from 

SWN wells. SWN is waiting to complete the Judsonia treatment facility to 

determine what type of treatment train to install at the Cleveland facility. The 

Cleveland treatment facility is currently permitted to discharge 4,000 barrels per 

day to surface water under NPDES permit AR0052175.

 Bee Branch (also referred to as Hartwick) treatment facility: This facility is not 

yet constructed, but is also permitted to discharge to surface water under NPDES 

permit AR0052086. The facility’s current purpose is to facilitate reuse similar to 

the Cleveland treatment facility.

SWN reported that they expect treatment costs to be between [REDACTED] per barrel. 

SWN provided a breakdown of this cost:

 Transportation: [REDACTED] per bbl

 Treatment via evaporation/condensation: [REDACTED]

 Brine disposal: [REDACTED]

5

For the two facilities that do not yet have treatment systems installed, SWN continues to 

research additional treatment technologies including: reverse osmosis, capacitative deionization, 

crystallization, biological treatment, and other treatment technologies. SWN is also considering 

small scale treatment options that would allow operations to scale up or down according to 

variations in wastewater volumes. 

SWN contracted with Purestream, a wastewater treatment vendor that offers services to 

the oil and gas industry and has already installed a treatment system, to construct the Judsonia 

site.

6

Purestream offers a mechanical vapor recompression (MVR) treatment system called the 

AVRA. Table 4-2 shows all of Purestream’s current unconventional oil and gas deployment 

locations with the AVRA units including formation, state, operator name, and influent TDS 

according to Purestream’s website.

 

5

[REDACTED]

6 More information on Purestream is available online at: http://purestreamtechnology.com/. 
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Table 4-2. Summary of Existing Purestream Installments

Formation/Basin State OperatoraInfluent TDS (mg/L)

Marcellus PA, W V PDC Mountaineer, SM Energy Unknown

Colorado River Basin (CBM) UT Unknown 17,700 

Bakken ND Whiting Oil and Gas 198,000

Eagle Ford TX Unknown 15,000 - 40,000

Permian Basin TX Unknown 40,000 - 120,000

Woodford Shale OK Unknown 15,000 - 40,000

Granite Wash OK Unknown 15,000 - 40,000

Fayetteville AR SWN 20,000 - 35,000

a—Purestream may have commercial operations in some formations/basins.

Mg/L—Milligrams per liter.

Source: PurestreamWebsite7

4.2.4 Underground Injection

SWN owns several Class II underground injection for disposal wells in the Fayetteville 

Shale Play. At the time of the site visit, SWN was only actively operating two of these wells at 

their Griffin Disposal Facility, which were formerly used for hydrocarbon disposal. SWN’s 

remaining underground injection for disposal wells are shut in or abandoned. 

Source: AOGC, 2013 (well locations); SWN (CWTs and disposal well); Map generated using 

ArcGIS

Figure 4-1 shows the location of the Griffin Disposal Facility. Griffin Mountain #1 is permitted 

by AOGC for 20,000 barrels per day at 975 psig and Griffin Mountain #2 is permitted by AOGC 

for 20,000 barrels per day at 1,041 psig. However, on a daily basis, SWN noted that they only 

inject a very limited volume of wastewater due to their 100 percent reuse operation.

SWN reported that they spend approximately [REDACTED] per barrel to reuse 

wastewater directly without any treatment. SWN also provided a breakdown of this cost:

 Transportation: [REDACTED] per bbl

 Injection for disposal market rate: [REDACTED]

SWN noted that they had previously hauled Fayetteville wastewater to Oklahoma for 

underground injection disposal. However, for the last few years, SWN has managed all of its 

flowback and produced water in Arkansas. SWN stated that the cost of disposing of wastewater 

at Oklahoma Class II underground injection wells was between $5 per barrel and $6 per barrel. 

4.2.5 Other Potential Management Options

SWN discussed with EPA several other wastewater management options that they are 

considering, including decentralized treatment at the well pad level and discharging to POTWs. 

 Decentralized Treatment: SWN stated that centralized waste treatment (CWT) is 

currently the best treatment option for their oil and gas wastewater. However, in 

 

7 Available online at: http://Purestreamtechnology.com/. 
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the future they would like to implement treatment at the well pad with flexibility

to increase/decrease capacity based on wastewater volumes. For example new 

wells will need higher treatment capacity than older wells. Well pad treatment 

would reduce trucking, and in turn increase SWN’s water management efficiency. 

SWN is considering a treatment system offered by Epiphany Solar Water 

Systems, located in Pittsburgh, PA. Epiphany’s technology consists of a solar 

concentrator that heats a working fluid, which is then used in a thin film 

evaporator to crystallize the influent wastewater. The wastewater is converted to a 

distilled water stream and a solid waste stream. The treatment system is relatively 

small and would only be designed to treat sufficient number of barrels per day to 

treat produced water generated by a single well pad.8SWN plans to conduct a 

pilot scale test of a solar concentrator at a Fayetteville well pad sometime by the

end of 2013. Potential issues that may arise with the well pad treatment option 

include permitting for the treatment units and compliance with the effluent 

limitations guidelines and standards (ELGs) for the onshore subcategory of the oil 

and gas extraction point source category. 

 Discharge to POTWs: SWN stated that they are not sending untreated wastewater 

to POTWs. They assumed that Region 6 would not approve POTW discharges

due to the historic problems with POTWs accepting shale gas wastewater in the 

Marcellus Shale. However, SWN also noted that if permissible under current or 

future regulations, SWN would consider transporting the evaporated water at the 

Judsonia treatment facility to a POTW. This would eliminate the need for SWN to 

refine their treatment system to meet direct discharge standards, which includes 

reducing ammonia and increasing mineral content. SWN suggested that a POTW 

would be able to handle both of these issues.

SWN indicated that setting a pre-treatment standard would help to determine what 

treatment technologies they should be pursuing. SWN suggested that EPA should 

consider setting POTW capacity thresholds (e.g., majors/minors, minimum 

capacity) for POTWs accepting SGE wastewater to ensure that they are large 

enough to effectively treat the unconventional oil and gas wastewater. In 

additional, SWN noted that because water quality changes significantly in 

different geographic areas, using surrogate test parameters such as WETT could 

provide nationally comparable data without requiring testing of specific pollutants 

of concern, which would vary with location. SWN also suggested requiring 

recurring water quality test results at certain stages during permitting (e.g., PA 

DEP’s 26R form).

5.0 SOUTHWESTERN SITES VISITED

This section describes the four sites that the EPA visited during the September 12 tour, which 

include:

 

8 More information on Epiphany’s wastewater treatment system for unconventional wastewater is available online 

at: http://transtechenergy.org/wp-content/uploads/2012/11/Ron_Pettengill_TransTech-Epiphany-SWS-8-minutepresentation-for-publish.pdf. 
DCN: SGE00625 13

 SWN Training Facility – Damascus Safety Operations & Training Center

 Fracturing Site – Green Bay Well pad

 Production Site – Charles Hall Well pad

 Judsonia Centralized Waste Treatment Facility

Figure 5-1 shows these sites along with the SWN’s regional office in Conway, Arkansas and 

producing wells.

Source: AOGC, 2013 (well locations); SWN (sites visited); Map generated using ArcGIS

Figure 5-1. Map of Sites Visited by EPA

5.1 SWN Training Facility – Damascus SOTC

SWN’s Damascus Safety Operations and Training Center (SOTC) includes the following 

facilities: 

 Training facility;

 Laboratory; and

 Equipment storage.

SWN’s training facility houses an “off-line” full scale setup of an active producing well 

site. The setup includes both old equipment (used prior to 2010) and new equipment to allow 

new personnel to be up-to-speed on old producing well sites as well as recently drilled wells.

Figure 5-2 shows a cross section of a typical SWN well casing for their Fayetteville 

Wells. It consists of an outer diameter casing which would be filled with cement up to the inner 

diameter. The inner diameter casing would be filled with cement up to the well casing. The 

perforated tubing is housed inside the well casing and is not cemented to allow water and gas to 

flow between the perforated tubing and the well casing.
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Figure 5-2. Cross Section of a Typical SWN Fayetteville Well Casing

The training facility also included a cross section view of the different types of gas/water 

separators. Figure 5-3 shows a photo of the old, horizontal gas/water separator, which involved 

gas venting and was not as reliable for high flow rates during flowback. The average cost of the 

old, horizontal separator was approximately $10,000 per unit. The new method, also called a 

“green completion”, uses a vertical separator. Figure 5-4 shows a cross section of a vertical 

gas/water separator which does not vent gas and is more reliable for high flow rates in the early 

part of flowback. The average cost of the new, vertical separator is approximately $37,000 per 

unit.

Figure 5-3. Horizontal Separator at Damascus Training Facility
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Figure 5-4. Vertical Separator at Damascus Training Facility

The water that collects in the bottom of the separator is not released from the unit in a 

continuous flow. Instead it is collected in the bottom of the tank allowing the water level to rise. 

Once the water level reaches a certain level in the tank it is released from the tank in batches. 

There are three methods for measuring the water level and releasing it out of the separator and 

into a nearby fracturing tank:

1. Guided wave – measures water height and dumps water once it reaches a certain 

height.

2. Float – measures water level and dumps water once it reaches a certain level.

3. Vibrating fork – vibrations of forks mounted at different heights on the tank 

indicate when to dump water. The vibrating fork is used on all new vertical 

separator installations.

5.2 Fracturing Site - Green Bay Well pad

The Green Bay wellhead contained three wells that were already fractured and two wells 

that were being completed at the time of the visit. The wells that were previously fractured are 

covered with orange metal housing to protect them during the hydraulic fracturing of the other 

wells. EPA observed the service provider performing hydraulic fracturing, plugging, and 
DCN: SGE00625 16

perforating. Third-party entity, CalFrac, was conducting the fracture. Once completed, this well 

will have a total of 16 stages.

The fracturing job on the day of the site visit was using 65% freshwater and 35% reuse 

water for fracture fluid. The reuse water was transported overland from the fracturing tanks (i.e., 

8 – 500 bbl fracturing tanks) via black poly-pipelines to the mixing tank. Shallow groundwater 

produced during the well drilling was contained in a single-lined reserve pit on-site and was also 

reused as a portion of the fracture fluid. Freshwater was transported overland from one of SWN’s 

freshwater ponds located approximately two miles away via black poly-pipelines to the mixing 

tank. Figure 5-5 shows the fracturing tanks, reserve pit, and overland black poly-pipelines 

transporting reuse fluid to the well pad. 

Figure 5-5. Reuse Fracturing tanks (left) and Reserve Pit (right) at Green Bay Hydraulic 

Fracturing Site

From the pumps shown in Figure 5-5, the mixture of reuse and freshwater is pumped to 

the Ecosphere ozone treatment unit. The Ecosphere ozone treatment unit destroys all bacteria in 

the fracturing base fluid to eliminate the need for biocide use in fracturing. From here, the 

fracturing base fluid is pumped to the blue fracturing base fluid holding tanks. 
DCN: SGE00625 17

Figure 5-6. Fracturing Base Fluid Holding Tanks (left), Ecosphere Ozone Treatment Unit 

(right)

From the blue fracturing base fluid holding tanks, the fluid is pumped to a blender where 

sand and chemicals are added to create the final fracture fluid. The fracturing fluid is pumped out 

of the blender through pump trucks that pressurize the fluid prior to being pumped downhole. 

Figure 5-7 shows one of the large pump trucks onsite. SWN noted that an average fracture 

requires 15 (2,000 to 2,500 horsepower each) pumps pumping 8 to 10 barrels per minute. The 

ideal fracture rate is 100 barrels per minute.

Figure 5-7. Pump Truck at Green Bay Hydraulic Fracturing Site
DCN: SGE00625 18

After one stage is fractured it is plugged using a wire line. Next, the service provider

perforates the next stage using explosives. The perforations protrude through the casing and into 

the formation about one foot in order to guide the fractures outward when the fracturing fluid is 

injected during fracturing. The plugging and perforation takes approximately 2 hours to 

complete. During the perforations, SWN operates under radio silence (i.e., no cell phones or 

other signals) due to the potential for radio waves to interfere with the perforations.

A fuel truck is located on-site at all times during the fracturing job. The truck has 

secondary containment around it to catch potential leaks and spills. A tractor trailer is brought 

into the site to refill the fuel truck daily.

In 2011, SWN began installing dust control units. All SWN personnel working on or 

around the sand tanks are required to wear respirators. SWN also noted that they are participating 

in a study with NIOSH regarding sand tank dust and safety procedures.

5.3 Flowback Site - Charles Hall Well Pad

The EPA visited the Charles Hall well pad on September 12, 2013 and observed six 

producing wells that had been fractured approximately 2 months prior to our visit and have been 

flowing for approximately one and a half months (see Figure 5-8). SWN noted that these wells 

should produce gas for the next 30 to 40 years.

Flowback water and gas travel to the well head and first into a sand separator shown on 

the right side of Figure 5-8. The separated sand is collected in a rectangular waste bin on the well 

pad and periodically emptied via truck. The remaining water/gas is piped to the water/gas 

separators on the other side of the well pad.

Figure 5-8. Wellhead (left) and Sand Separator (right) at Charles Hall Well pad

Figure 5-9 shows the white, plastic tanks containing corrosion inhibitor chemicals were 

located next to each of the six wellheads on-site. Corrosion inhibitor chemicals were being fed 
DCN: SGE00625 19

down each well bore to minimize corrosion. The pipes at the bottom of Figure 5-9 are carrying 

the flowback water and natural gas mixture from the sand separators to the water/gas separators 

on the other side of the well pad.

Figure 5-9. Four Corrosion Inhibitor Tanks at Charles Hall Well pad

From the sand separators, the water/gas mixture flows to the water/gas separators shown 

in Figure 5-10. After the water/gas mixture enters each separator, the gas flows to the top, into 

the collection pipeline shown in the bottom left corner of Figure 5-10. Using these closed 

separators total eliminates the need to flare gases generated by the wells during the completion 

and flowback phases. Separated flowback water exits near the bottom of the separator. 
DCN: SGE00625 20

Figure 5-10. Water/gas Separators (right) and Gas Collection Lines (bottom left corner)

At the time of the site visit, the flowback was being routed to the blue fracturing tanks 

shown in the background of Figure 5-10. Figure 5-11 provides a close up of the fracturing tanks. 

The average wastewater flow rate at the time of the site visit was 250 barrels per day (10 barrels 

per hour). SWN noted that eventually as the well enters the production phase and the wastewater 

flow rates decrease and level out, they will remove the blue fracturing tanks from the well pad 

and route the produced water to the three permanent produced water tanks shown in Figure 5-12. 

Each produced water tank has a capacity of 400 barrels.
DCN: SGE00625 21

Figure 5-11. Fracturing Tanks at Charles Hall Well Pad

Figure 5-12. Produced Water Tanks at Charles Hall Well Pad

SWB takes chlorides and pH samples from the flowback and produced water. SWN 

indicated that the chloride and TDS content was fairly constant in the produced water over time. 

SWN checked the most recent pH and TDS measurements of the produced water while EPA was 

on site and reported the following:

 pH: 7.0 SU

 TDS: 35,000 mg/L

SWN noted that the TDS reading during EPA’s visit erred on the high side and that the average 

TDS values for Fayetteville Shale produced water are between 20,000 mg/L and 25,000 mg/L.

The Charles Hall well pad also contained a double-lined reserve pit that received fluids 

during the drilling process. Figure 5-13 shows this reserve pit. The fluid stored in this pit 

included drill cuttings, shallow groundwater produced during well drilling, and stormwater. 

SWN produces approximately 2,000 bbl of groundwater per well drilled. SWN also noted that 

the reserve pit has a leak detection system installed. These reserve pits are temporary and are 

typically removed within one year of fracturing. When the reserve pit is no longer in use, SWN 

will pump it dry, stabilize the solids with fly ash and dispose of them in a landfill, fill in the pit, 

and re-grade the entire site.

A compressor was also located on site, but was not operating. The compressor had 

previously been used to artificially lift the well to initiate flowback water and natural gas flow; 

however, the formation was now capable of flowing gas freely so the compressor was no longer 

needed. 
DCN: SGE00625 22

Figure 5-13. Lined Reserve Pit at Charles Hall Well pad

5.4 Judsonia Centralized Wastewater Treatment Facility

SWN’s Judsonia treatment facility is located at 4301 Highway 157N in Judsonia, 

Arkansas and has been operating since February 2013. The facility uses Purestream’s induced 

gas flotation (IGF) and mechanical vapor recompression (MVR) treatment technologies to treat 

oil and gas wastewater from nearby SWN wells. 9 The Judsonia treatment facility is permitted to 

discharge up to 4,000 barrels per day (0.168 MGD) under NPDES permit AR0052051. However, 

at the time of the site visit, the facility had not yet discharged. The facility’s influent capacity is 

2,500 bbl per day with an average influent TDS of 20,000 mg/L. With the relatively low TDS 

compared to other shale formations, the evaporator is able to recover approximately 80 percent 

of the influent wastewater as distilled wastewater. Typical brine production is between 400 

barrels per day and 600 barrels per day.

SWN’s contract with Purestream requires SWN to provide Purestream with a certain 

quantity (barrels per day) of wastewater as long as Purestream continues to meet SWN’s 

discharge permit limits. Wastewater from the impoundment is treated through the following stepwise processes:

1. Wastewater is hauled to the facility in trucks and delivered using six unloading 

bays constructed with inlets that drain to treatment unit (see Figure 5-14).

2. Wastewater is gravity fed through an overland pipe from the unloading bays into 

two sedimentation basins prior to going into the impoundment. The sedimentation 

ponds remove solids from the water as well as skimming oil and grease off the 

surface of the water. The impoundment’s maximum capacity is 250,000 bbl and it 

is aerated for odor control (see Figure 5-15).

 

9 More information on Purestream is available online at: http://purestreamtechnology.com/. 
DCN: SGE00625 23

3. The wastewater is treated using induced gas flotation (IGF) to remove suspended 

solids (SS) and oils, which are collected and pumped to the brine tank. Figure 

5-16 shows one of the IGF treatment units.

4. The wastewater is filtered through a 50 micron bag filter to remove any remaining 

SS.

5. The pretreated wastewater is evaporated and then condensed using MVR to create

a distillate and concentrated brine. Figure 5-17 shows one of the MVR units.

6. The distillate stream is stored in the verification tanks (holding tanks) and a 

concentrated brine stream that goes to the brine tank prior to disposal.

7. Treated effluent from the facility is similarly hauled away from the facility using 

three loading bays with identical drain systems that recycle effluent water to the 

treatment unit.

Figure 5-14. Unloading Bays at Judsonia Centralized Waste Treatment Facility
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Figure 5-15. Sedimentation Ponds (front) and Impoundment (rear) at Judsonia Centralized 

Waste Treatment Facility

Figure 5-16. Purestream’s IGF Treatment Unit at SWN’s Judsonia Treatment Facility
DCN: SGE00625 25

Figure 5-17. Purestream’s AVARAs MVR Unit at SWN’s Judsonia Treatment Facility

The two MVR treatment units are powered by electricity that is available for purchase for 

between $0.06 per kilowatt hour (kWh) and $0.08 per kWh. The MVR treatment units are 

capable of running off of natural gas, but SWN chooses to use electricity because it is available 

to them at a low cost. SWN reported that in July 2013, the Judsonia treatment facility used 8.3 

kWh per barrel of influent wastewater treated. The current wastewater treatment cost at the 

Judsonia facility is $5.50 per barrel and the capital costs to build the facility were approximately 

$1.5M.

While the EPA was visiting the Judsonia facility, the effluent TDS concentration in the 

distillate stream was 34.81 mg/L and the pH was 8.34 SU. The average TDS concentration in the 

brine stream is 200,000 mg/L. SWN currently disposes of brine by using it as kill fluid, using it 

as an additive for drilling fluid, or hauling it to a landfill. SWN is looking into other options for 

disposing of brine (e.g., blending into fracturing fluids for reuse; substituting for potassium 

chloride (KCl), agricultural uses).

SWN is capable of sampling from each of the verification tanks that contain the treated 

distillate stream. The Judsonia NPDES permit sets limits for the following parameters:

 Carbonaceous Biochemical Oxygen Demand (CBOD5)

 Total Suspended Solids (TSS)

 Ammonia Nitrogen (NH3-N)

 Dissolved Oxygen (DO)
DCN: SGE00625 26

 Chlorides

 Sulfates

 Total Dissolved Solids (TDS)

 Oil & Grease (O&G)

 Arsenic, Total Recoverable (Ar)

 Cadmium, Total Recoverable (Cd)

 Chromium III, Total Recoverable (Cr3)

 Chromium (VI) (Cr6)

 Chromium, Total Recoverable (Cr)

 Cobalt, Total Recoverable (Co)

 Copper, Total Recoverable (Cu)

 Lead, Total Recoverable (Pb) 

 Mercury, Total Recoverable (Hg)

 Nickel, Total Recoverable (Ni)

 Silver, Total Recoverable (Ag)

 Tin, Total Recoverable (Sn)

 Zinc, Total Recoverable (Zn) 

 Cyanide, Total Recoverable (CN) 

 Bis (2-ethylhexyl) phthalate

 Butylbenzyl phthalate

 Carbazole

 n-Decane

 Fluoranthene

 n-Octadecane

 Radium-226 (dissolved) 

 Strontium-90 (dissolved)

 Beta radiation (gross)

 pH

 Chronic WET Testing

The facility is having difficulties complying with the NPDES permit limits for ammonia 

and methanol. SWN suggested the following potential options to try to obtain compliance with 

these permit limits:

 Run the distillate stream through crushed limestone prior to discharge to lower the 

pH and slightly raise the TDS concentrations.

 Send treated water to POTW to treat ammonia and methanol before discharge.
DCN: SGE00625 27

APPENDIX A

LIST OF PARTICIPANTS ON THE SWN SITE VISIT
DCN: SGE00625 28

Table A-1. List of Attendees

First Name Organization Phone Number Email

Lisa Biddle U.S. EPA, Engineer (202) 566-0350 Biddle.Lisa@epa.gov

Karen Milam U.S. EPA, Economist (202) 564-9752 Milam.Karen@epa.gov

Jesse Pritts U.S. EPA, Engineer (202) 566-1038 Pritts.Jesse@epa.gov

Maria Okpala U.S. EPA, Region 6 (214) 665-3152 Okpala.Maria@epa.gov

Thomas Alexander SWN, Vice President –

Health, Safety & 

Environmental (HS&E)

(281) 618-7366

Cell: (497) 409-6495

Tom_Alexander@swn.com

James Bolander Senior Vice President –

Resource Development

(281) 618-4789 Jim_Bolander@swn.com

Peter Fyfe Senior Facilities Engineer (281) 618-6147

Cell: (281) 382-1082

Peter_Fyfe@swn.com

Roy Hartstein Vice President – Strategic 

Solutions

(281) 618-4875

Cell: (281) 433-3252

Roy_Hartstein@swn.com

Mark Mazock Manger – Water Team NA NA

Sean McKaren Team Member, HS&E NA NA

Doug Melton Special Project Manager

(Geologist)

(501) 548-6620 Doug_Melton@swn.com

Sarah Hays ERG, Environmental 

Engineer

(703) 633-1661 Sarah.Hays@erg.com

Brent Ruminski ERG, Energy Engineer (703) 633-1701 Brent.Ruminski@erg.com 
DCN: SGE00625 29

APPENDIX B

POWER POINT PRES ENTATION OF ALL SITE VISIT PICTURES

[REDACTED]
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APPENDIX C

DOCUMENTS RECEIVED FROM SWN

[REDACTED]