# Site Visit Report Eureka Resources, LLC Marcellus Shale Gas Operations

February 25

, 2012i TABLE OF CONTENTS

Page

1.0 I NTRODUCTION

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2.0 B ACKGROUND AND O BJECTIVES

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3. 0 O VERVIEW OF S HALE G AS E XTRACTION W ASTEWATER T REATMENT

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- 1 3.1 Wastewater Services

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- 1 3.2 Plant Flow Description

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- 2 3.3 Treated Wastewater Streams

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- 8 3.4 Waste Streams

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- 9 3.5 Costs

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- 10

A PPENDIX A L IST O F P ARTICIPANTS ON THE E UREKA S ITE V ISIT

................................ .......... A

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A PPENDIX B P OWER P OINT P RESENTATION OF A LL S ITE V ISIT P ICTURES

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- E RROR ! B OOKMARK NOT DEFINED

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A PPENDIX C P LANT F LOW D IAGRAM

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- E RROR ! B OOKMARK NOT DEFINE D
.ii LIST OF FIGURES Page

Figure 3

- 1. Plant Flow Diagram

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- 3

Figure 3

- 2. Unloading and Screening Area

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- 5

Figure 3

- 3. Parallel Plate Clarifier

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- 5

Figure 3

- 4. Circular Clarifier

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- 5

Figur e 3

- 5. Eureka’s Nomad Evaporator Unit Flow Diagram

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- 7iii LIST OF TABLES

Page

Table 3

- 1. Eureka's Annual Wastewater Treatment Volume

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- 2

Table 3

- 2. Chemically Treated Wastewater Target Quality

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- 9

Table 3

- 3. Eureka’s Wastewater Treatment Costs

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- 10

Table 3

- 4. Eureka’s Operational Costs

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- 111

- 1

1.0 I NTRODUCTION
On June 14, 2012, the U.S. Environmental Protection Agency (EPA) held a conference call with Eureka Resources, LLC (Eureka) to discuss their plant operation in Williamsport, Pennsylvania. On September 18, 2012

, t he EPA met with Eureka in Willi amsport, Pennsylvania located in the northern tier of the Marcellus

. Discussion topics included:

 Wastewater S ervices

 Plant F low D escription

 Treated W astewater S treams

 Waste S treams

 Costs

Site visit participants are listed below. Contact inform ation is inc luded in Appendix A.

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

Lisa Biddle Tom Born Brian D’Amico Erik Helm Pooja Parikh

E astern R esearch G roup, Inc

. (ERG) (EPA Contractor)

Casey MacQueen Brent Ruminski

Eureka Resources

Jerel Bogden Dan Ertel John Saton2

- 1

2.0 B ACKGROUND AND O BJECTIVES

The Eureka site visit was the fourth in a series of site visits that the EPA plans for this industry. The purpose of the Eureka site visit was to collect background information on the shale gas extraction wastewater treatment industry and observe wastewater treatment operations. To initiate site visits, the EPA reviewed information about Marcellus shale gas producers and their wastewater management practices. During this review, the EPA identified Eureka as a recipient of shale gas extraction wastewater for treatment, active in the Marcellus Shale Play.

John Staton, Jerel Bogden, and Dan Ertel and of Eureka led the discussion of the company’s Marcellus operations and the site tour. The remainder of this report summarizes information discussed during the June 14, 2012 conference call

, September 17, 2012 site visit

, and a February 7, 2013 follow up telephone conversation . After the follow up tele phone conversation, Eureka provided the flow diagram presented in Appendix C.3

- 1

3.0 O VERVIEW OF S HALE G AS E XTRACTION W ASTEWATER T REATMENT
During the conference call and prior to a tour of Williamsport, Pennsylvania operations, the EPA and Eur eka discussed general shale gas extraction wastewater treatment. Eureka provided an overview of shale gas extraction wastewater treatment . Topics discussed include:

 Wastewater S ervices

 Plant F low D escription

 Treated W astewater S treams

 Waste S treams

 Costs

3.1 Wastewater Services

Eureka’s plant accepts shale gas wastewater from operators in northeastern Pennsylvania and is the only centralized waste treater (CWT) permitted by the PA DEP to discharge to a publically owned treatment works (POTW). Eureka either ret urns treated wastewater to operators for reuse in drilling or hydraulic fracturing or discharge it to the Williamsport POTW. Eureka holds a General Permit ( WMGR123NC005 ) 1 from PA DEP which allows them to accept all wastewaters from drilling, fracturing, an d production. It also allows them to accept any wastewaters from compressor stations prior to commerce. 2 Eureka plans to expand their business in the future by constructing three new plants throughout northern Pennsylvania.

Over the past several years, nor thern Pennsylvania operators have increasingly managed shale gas wastewater through reuse in fracturing or drilling activities. If the wastewater requires treatment prior to reuse, operators may treat it onsite or at available CWTs. At the time of the site visit, Eureka estimated that 50 percent of operators that reuse wastewater send their wastewater offsite to CWTs for treatment in the Marcellus

. Table 3

- 1 provides wastewater volume, number of operators, and number of wells served by Eureka between 2009 and June 2012 according to Pennsylvania Department of Environmental Protection’s (PA DEP) oil and gas database. Eureka has a customer base of 20 different sh ale gas operators from 18 counties . According to PA DEP data, only seven different customers have delivered wastewater to the plant in 2012 through June

. Eureka estimated that most of their customers haul wastewater from wells within 120 miles of the Willi amsport plant.

1 More information available online at: http://fi les.dep.state.pa.us/Waste/Bureau%20of%20Waste%20Management/WasteMgtPortalFiles/SolidWaste/Resid ual_Waste/GP/WMGR123.pdf

. 2 Commerce is the point at which the gas is sold by the operator.3

- 2 Table 3

- 1 . Eureka's Annual Wastewater Treatment Volume

Year Volume of Wastewater (bbls) a Number of Operators Number of Wells Served
2009 292,964 2 48
2010 490,446 6 198
2011 747,770 14 286
2012 b 248,450 7 325 Source: PA DEP’s Oil and Gas Reporting Database.

a

— Includes flowback, produced water, and drilling fluid. 42 gallons equals 1 barrel. b

— 2012 data is through June 30, 2012.

The company offers two main services :

 Disposal

— Operators pay to drop off a load of wastewater for treatment and leave. Eureka either finds another operator to take the treated wastewater or discharges it to the Williamsport POTW

.

 Recycling

— Operators pay to drop off a load of wastewater and pick up a load of treated wastewat er

. They can choose from the following treatment levels:

 Chemical treatment

— Wastewater goes through clarification and chemical precipitation to remove total suspended solids (TSS) and some metals. Operators commonly reuse this wastewater for hydra ulic fracturing and drilling.

 Chemical treatment and evaporation/condensation

— Wastewater goes through clarification, chemical precipitation, and evaporation/condensation to remove TSS, metals, and total dissolved solids (TDS) resulting in a distilled water product. Operators do not typically use distilled water for hydraulic fracturing, but may take this water if freshwater is in demand.

3.2 Plant Flow Description

The plant is permitted to treat 337,500 gallons per day (8,036 barrels per day) on a monthly aver age and has no daily maximum limit but has treatment capacity of 420,000 gallons per day ( 10,000 barrels per day )

. A typical throughput for the plant is 168,000 gallons per day (4,000 barrels per day) . Eureka’s discharge permit allows them to discharge a m aximum 325,000 gallons per day (7,738 barrels per day) to the POTW. However, the monthly average discharge to the POTW must be less than 225,000 gallons per day (5,357 barrels per day)

. Figure 3

- 1 presents a flow diagram of the overall treatment system. Figure 3

- 2 through Figure 3

- 4 provide photos of individual units from the site visit. N o photos of the filter press or evaporator wer e taken due to confidentiality. Appendix C includes a detailed plant flow diagram Eureka provided after the February 2013 follow u p call.3

- 3 Figure 3

- 1 . Plant Flow Diagram Treatment steps include:

 Screening

— All f

luids are unloaded into receiving tanks through basket strainers

, sampled and graded based on pH, TDS, and TSS

. Influent loads are categorized into two groups: l ow TSS (i.e., flowback and produced water ) and high TSS (i.e., top hole 3 and drilling fluids )

. Eureka also monitors all incoming wastewater for radioactivity and rejects any wastewater load with radioactivit y more than 10 microrems per hour above background levels. Figure 3

- 2 show s the unloading

area.

3 Water that flows to the surface during the initial drilling proce ss.3

- 4

 Primary Clarification

— The primary clarifier separates oils and solids from the wastewater. Oil is recovered and recycled. Each graded load flows to one of two sets of chemical treatment trains

. Treatment train A has a 110 gallon per minute throughput equipped with a parallel plate clarifier while t reatment train B has a 240 gallon per minute throughput equipped with a large circular clarifier

. Although treatment train B is capable of treating higher TSS wastewater, Eureka often switches high and low TSS loads between the two treatment trains depending on the influent volumes of each load type per day.

 Clarification

— Each clarification treatment train contains pH adjustment tanks, flash mixer, clarifier, and equalization tank. If the treated wastewater does not meet the quality targets after equalization it is routed back to the storage tank. Figure 3

- 3 a nd 3

- 4 show the parallel plate and large circular clarifiers

, respectively.

 Evaporation/Condensation

— Chemically treated wastewater flows from t he clarifiers to either the chemically treated wastewater storage tanks for reuse or the Nomad evaporato r unit. The evaporator unit generates concentrated brine and distilled water. The concentrated brine is hauled to Ohio underground injection wells or returned to the operator for reuse. The distillate is stor ed until an operator picks it up for reuse or di scharged to a sewer line that runs to the Williamsport POTW

.

 Treated Wastewater and Distillate Storage

— Chemically t reated wastewater and distillate are stored in separate tanks until an operator picks it up for reuse. Alternatively, distillate may be rout ed directly to the POTW via sewer line.

 Solids Handling

— Tank bottoms from the clarifiers flow to a rotary filter press which generates solid waste and water. The solid waste is hauled to a landfill. Water is routed back to the headworks.3

- 5 Figure 3

- 2 . Unloading and Screening Area

Figure 3

- 3 . Parallel Plate Clarifier

Figure 3

- 4 . Circular Clarifier3

- 6

Eureka ’s plant is equipped with a Fountain Quail evaporation/condensation unit called the Nomad. This unit uses mechanical vapor recompression (MVR) technology to convert high TDS wastewater into concentrated brine and treated wastewater called distillate. The p ercentage of distillate recovered is inversely proportional to the influent TDS concentration , as illustrated through Equation 1

. 4

For example, the typical shale gas wastewater delivered to Eureka has a TDS concentration of 100,000 . Using the above equation, this results in a 60 percent distillate
recovery. The 2012 cumulative average recovery was 62 percent. TDS concentrations higher than approximately 125,000 will result in lower than 50 percent recovery. At TDS concentrations of 250,000 mg/L, recovery is approximately zero. Eureka explained it is not practical to evaporate wastewater with such high TDS

. Figure 3

- 5 shows a flow diagram of the Nomad unit. The steps include:

1. Influent wastewater is preheated through a series of cross

- flow heat exchangers. E nergy is transferred from the downstream concentrated brine, distillate, and compressed water vapor to the influent wastewater.

2. The wastewater enters the main vessel. During startup and before there is flow through the downstream heat exchangers , the wastewater is not preheated ; it is heated in the main vessel by steam from a 35 horsepower natural gas boiler. The boiler only runs approximately two percent of the total operational time. During startup and steady state operation

, the surface of the wastewater reaches approximately 212 degrees Fahre nheit at atmospheric pressure and evaporates. P ollutants remain in the wastewater
, resulting in concentrated brine.

3. The water vapor in the boiler is vented to a mechanical compressor. The compressor increases temperature and pressure of the vapor to 235 degrees Fahrenheit and 22 to 24 pounds per square inch (psia).

4. The compressed water v apor expands across the main heat exchanger where its latent heat of condensation 5 is transferred to influent wastewater. At this point, the wastewater becomes condensed wastewater (i.e.

, distillate) at 212 degrees Fahrenheit.

5. The distillate flows through a series of additional heat exchangers where it provides sensible heat 6 to preheat influent wastewater.

4 Equation derived from EPA’ s Proceedings of the Technical Workshops for the Hydraulic Fracturing Study: Water Resources Management. 600/R

- 11/048. May 2011 Available online at: http://www.epa.gov/hfstudy/HF_Workshop_4_Proceedings_FINAL_508.pdf

. 5 Latent heat of condensation is the heat release by water vapor when it condenses from a gas to a liquid.
6 Sensible heat is the heat released or obtained by water during a change in temperature.3

- 7 Figure 3

- 5 . Eu reka’s Nomad Evaporator Unit Flow Diagram During a February 2013 telephone conversation, Mr. Staton reported that Eureka was in the process of permitting and constructing a crystallization 7 unit as an add

- on treatmen t option to their Williamsport plant

. 8 When installed, the crystallizer will treat the concentrated brine from the evaporator and convert approximately 80 to 85 percent of it concentrated to distillate

. . The sodium chloride crystals will be 98 to 99 percent pure. Eureka explained that they hav e not yet determined how salt crystals will be disposed of or sold for reuse, but options include :

 Ha uled to l andfill 9 ;

 R eturned to o perators to u se as an a dditive in d rilling f luid 10 ;

 Sold as d eicing r oad s alt ; and

7 Crystallization is a treatment process that converts water containing high TDS concentrations into solid crystals and distillate.
8 Eureka recently shipped a sample of Pennsylvania shale gas wastewater to Switzerland to test on an existing crystallizer.
9 Because the water has been removed, transport and disposal of salt crystals is less expensive than transport and disposal of brine.
10 Salt may be used as an additive in drilling fluid to increase density and/or increase a fluids electrical conductivity.3

- 8

 Sold as an ingredient to an industrial pr ocess.

Eureka explained that the liquid purge stream contains calcium chloride at concentrations less than 35 percent

. If the calcium chloride concentration is at least 35 percent

, the purge stream would have high value for other industrial applications. As a result, Eureka is considering future upgrades to the crystallization unit that would further concentrate the purge stream to increase the calcium chloride concentration

. In the mean time, Eureka explained that they their purge stream disposal and reuse options include:

 Ha uled to underground injection well ;

 Returned to o perators to u se as a d rilling f luid additive 11 ; and

Eureka conducted preliminary research for using the salt crystals as road salt. PA DEP ’s General Permit WMGR 128 provides stand ards for salts generated at oil and gas waste facilities with a General Permit WMGR123 (Eureka’s current permit type) that are to be use d for deicer or as an ingredient to other industria l processes

. 12 This permit provides 21 specific quali ty standards for salt crystals including two radioactive constituents: Thorium 232 (2 p Ci/kg) and Uranium 238 (2 pCi/g). Eureka expects the salt crystals generated by their crystallizer to meet all of the standards of the PA DEP WMGR128 permit.

Eureka estimated the crystallizer unit will cost approximately $7 million and will be capable of crystallizing 5,000 barrels per day

. Eureka had the option between a 5,000 and 10,000 barrel per day design but chose the smaller unit because it is capable of being moved to new locations. Expected cost to operato rs for this treatment will be $10.75 to $11.00 per barrel assuming the s alts must be hauled to a landfill. In the event that the salt can be beneficially used b y operators or as road salt, total cost may be as low as $7 per barrel to operators.

3.3 Treated Wastewater Streams

Two streams of treated wastewater leave the plant:

 Chemically T reated W astewater

— Picked up by operator for reuse in fracturing or drilling ; an d

 Distillate

— Piped to Williamsport POTW or picked up by operator for reuse in shale gas activities.

Most commonly, operators tend to reuse chemically treated wastewater for hydraulic fracturing. Chemically treated wastewater contains approximately 100,0 00 mg/L TDS when it leaves the plant. Most operators mix this treated wastewater with freshwater prior to fracturing for a final TDS concentration of approximately 50,000 mg/L. Eureka monitors the chemically treated water to ensure the water quality meets the operator’s specifications. Specifications vary from operator to operator, but Table 3

- 2 lists some general target levels.

11 Salt may be used as an additive in drilling fluid to increase density and/or increase a fluids electrical conductivity.
12 PA DEP Perm it 128 guidance is available online at: http://files.dep.state.pa.us/Waste/Bureau%20of%20Waste%20Management/Waste MgtPortalFiles/SolidWaste/Resid ual_Waste/GP/WMGR128.pdf

.3

- 9 Table 3

- 2

. Chemically Treated Wastewater Target Quality

Constituent Approximate Concentration or Range (mg/L)
TDS 100,000
TSS < 50
Sulfate Non Detect pH 5 to 8 S.U.

Eureka explained that operators do not typically specify quality criteria for barium and strontium, especially if they are reusing the water for drilling fluid. This is because barium is a component of barite, which is a common additive for drilling fluid that increases density. If treated drilling fluid has hig her barium concentration , then the operator can reduce costs by purchasing less barite additive.

Distillate from the evaporation/condensation unit contains less than 10 mg/L TDS as well as trace amounts of ammonia and light organics (e.g., ethanol). 13 Disti llate is not typically used for hydraulic fracturing operations; however, operators will use distillate as a freshwater source if weather has been dry and freshwater is in demand. Operators can also use distillate for miscellaneous shale gas activities, su ch as rig cleaning and cementing. If operators do not have a need for distilled water, Eureka indirectly discharges the water through the Williamsport POTW. Eureka conducts the following monitoring on the discharge to the POTW:

 D aily monitoring for TDS and pH

.

 Monthly monitoring for biochemical oxygen demand (BOD), chemical oxygen demand (COD), and organic parameters regulated under 40 CFR 437 Organics Subcategory C

. 14

 Annual mo nitoring for priority polluta nts

.

3.4 Waste Streams

Two waste streams leave the plant:

 Concentrated brine

— Trucked to Ohio for underground injection or picked up by operator for reuse; and

 Solid waste

— Trucked to landfill. Eureka estimated that when the plant is running at typical capacity (4,000 barrels per day), it generates 10 to 30 tons per day of solid waste.

Concentrated brine is either trucked to Ohio for underground injection or given back to the operators. The bri ne has a TDS concentration around 250,000 mg/L. Eureka explained that there are a few injection wells in Pennsylvania but they are owned by operators and have relatively low capacities. In Ohio , there are almost 200 injection wells. Ohio i njection well
ope rators charge approximately $2.5 to $4.5 per barrel for disposal for heavier brine (i.e., concentrated brine from evaporator)

. F or less dense fluid (i.e., flowback ), this cost may be as

13 Pollutants that have a lower boiling temperature than water will likely be present in the distillate at trace levels.
14 Available online at: http://ecfr.gpoaccess.gov/cgi/t/text/text

idx?c=ecfr&rgn=div5&view=text&node=40:30.0.1.1.13&idno=40#40:30.0.1.1.13.3.4.1

.3

- 10

high as $3.8 to $6.75 per barrel. Injection operators may surcharge fo r excessive TSS concentrations. These disposal fees are in addition to trucking

, which costs Eureka $9 to $13 per barrel. Eureka pays fo r trucking on a contract basis.

Because trucking this waste stream to Ohio is expensive, Eureka offers it to operators f or a credit on their account. Operators may have use for concentrated brine during the drilling process when high density fluids are desired or in cold weather as an anti

- freezing agent. D uring winter months

, Eureka does not haul any brine to Ohio because the operators reuse it all. Eureka is not required to monitor the brine for any constituents

, but voluntarily monitor s the brine to evaluate the evaporator’s performance and to study the potential performance of a crystallizer unit.

Solid waste is hauled to a landfill that is PA DEP

- approved for handling non

- hazardous oil and gas solid waste. Eureka screens each load for radioactivity using a Geiger counter before it leaves their site . If they detect radioactivity levels more than 10 micorems per hour above background level, they immediately quarantine the load and notif y PA DEP. Eureka stated that the y eventually would ship the quarantined solid waste to the landfill where it would be retested to verify the radioactivity level. If the landfill operator confirms that the radioactivity level exceeds the threshold , Eureka pays a surcharge in addition to the disposal cost in Table 3

- 4

. Eureka indicated that of the types of solid waste they generate , waste from high TSS influent
wastewate rs is most likely to exceed the 10 micorems per hour threshold, but the frequency is extremely low (i.e., less than 5 times over several years)

.
3.5 Costs

Eureka reported ge neral prices that they charge to customers based on level of treatment, type of service, and incoming wastewater quality. The base price for chemical treatment to operators that are able to take a load of treated wastewater is approximately $3 .25 per barrel . If an operator is dropping a load off for disposal, Eureka charges the operator for the full treatment process (approximately $10 per barrel). In general, Eureka surcharges operators for wastewater with high concentrations of TSS, TDS, iron, stron tium, barium , and gels, and polymers

. Occasionally, operators who unsuccessfully treated flowback in the field will bring wastewater containing polymers , which then requires significantly more chemical to treat. Eureka has also received wastewater from gel fracturing during early Marcellus development, which requires more chemical to treat and causes operational problems. Eureka explained that they are able to treat this type of wastewater but at a higher cost to the operator. However, operators have predom inantly used slickwater fracturing in the Marcellus

. Table 3

- 3 and Table 3

- 4 p rovide an overview of Eureka’s t reatment and operational costs.

Table 3

- 3

. Eureka’s Wastewater Treatment Costs

Wastewater Type Service Type of Treatment Approximate Cost (Dollars per bbl)

Low TSS (Flowback and Produced Water) Disposal Chemical treatment, filtration, evaporation/condensation a 10

Reuse Chemical treatment 3.25 b

Reuse Chemical treatment and

evaporation/condensation 6.5

— 10 b3

- 11 Table 3

- 3

. Eureka’s Wastewater Treatment Costs

Wastewater Type Service Type of Treatment Approximate Cost (Dollars per bbl)
High TSS (Top hold, drilling fluid) Reuse Chemical treatment 7

— 16

Disposal Chemical treatment,

evaporation/condensation a 16

a

— Distillate from evaporation/condensation is discharged to POTW and concentrated brine hauled to Ohio. b

— Eureka charges a surcharge for any wastewater over 150,000 mg/L TDS due to an increase in chemical required. Surcharges may increase the per barrel cost up to $15.50 per barrel.

Table 3

- 4

. Eureka’s Operational Costs

Waste Type Destination Transportation Cost Disposal Fee Total Cost

Solid waste Landfill 16

— 20 a (dollars per ton) 50 (dollars per ton) 66

— 70 (dollars per ton)

Concentrated brine Ohio

underground injection 9

— 13

(dollars per barrel) 2.5

— 4.5 b (dollars per barrel) 12.5

— 15 (dollars per barrel)

Distillate Williamsport

POTW N/A $ 0.378 (dollars per barrel) $0. 378 c (dollars per barrel)

a

— Each truck hauls approximately 15 tons. b

— Injection of concentrated brine costs $2.5 to $4.5 per barrel. Injection of flowback wastewater, which is less dense and requires more energy i nput to inject, costs $4.5 to $6.75 per barrel.

c

— The Williamsport POTW may surcharge Eureka if BOD concentrations are too high. This price was reported as approximately $ 9 per 1,000 gallons

. N/A

— Not Applicable. NR

— Not Reported.A PPENDIX A L IST O F P ARTICIPANTS ON THE E UREKA S ITE V ISITTable A

- 1. List of Attendees

First Name Organization Phone Number Email
Lisa Biddle U.S. EPA, SGE Engineer (202) 566

- 0350 Biddle.Lisa@epa.gov

Tom Born U.S. EPA, SGE Environmental

Scientist (202) 566

- 1001 Born.Tom@epa.gov

Brian D’Amico U.S. EPA, SGE Engineer (202) 566

- 1069 Damico.Brian@epa.gov
Erik Helm U.S. EPA, SGE Economist (202) 566

- 1049 Helm.Erik@epa.gov Pooja Parikh U.S. EPA, SGE Attorney (202) 564

- 0839 Parikh.Pooja@epa.gov Jerel Bogden Eureka (716) 560

- 5413 j.bogden@erueka

- resources.com Dan Ertel Eureka (570) 971

- 9978 d.ertel@erueka

- resources.com John Staton Eureka, Vice President of

Operations ( 570 ) 295

- 1438 j.staton@erueka

- resources.com
Casey MacQueen ERG , Chemical Engineer (703) 633

- 1686 Casey.Macqueen@erg.com
Brent Ruminski ERG , Energy Engineer (703) 633

- 1701 Brent.Ruminski @erg.com