From: Lockhart, John V [ mailto:John.V.Lockhart@wv.gov ]

Sent: Tuesday, June 03, 2014 9:34 AM

To: Biddle, Lisa Subject: FW: West Virginia Oil and Gas Wastewater Management

Lisa,

The triangle on the figure is most likely the City of W eston WV0028088

– they accept CBM wastewater from Schlumberger Oil Field Services.

John

From: Lockhart, John V

Sent: Tuesday, June 03, 2014 9:22 AM

To: 'Biddle.Lisa@epa.gov' Subject: RE: West Virginia Oil and Gas Wastewater Management

Lisa,

Matt told me to follow up with you...

There is no prohibition on accepting Shale wastewater in WV. The POTWs have chosen not to accept Shale wastewater due to the many requirements that will be imposed in the accepting facilities permit if they do start accepting (see attachment). Currently I know of no POTW in WV accepting Shale water.

We do have 2 CWTs (WV0116408

– Fairmont Brine; WV0116441

– Reserve Environmental) that have at one time and will soon be accepting Sha le wastewater and I think there are a few mobile treatment units floating around the State but they do not require a permit (i.e. recycle only). My guess is that neither of these are operating at the moment. Fairmont Brine is close for I was up there a cou ple weeks ago and they are almost finished retrofitting. Reserve was not constructed a few months ago when I last

checked their status.

Wheeling experienced ammonia violations which was attributable to the high chlorides levels accepted

from the Shale was tewater. They chose to discontinue acceptance of the wastewater from Liquid Assets. Liquid Assets has since proposed to build a recycle system (now Reserve Environmental) and hold their own individual storm water only permit. Unclear if they have started a ccepting wastewater yet.

Clarksburg at one time was accepting Shale wastewater but if I recall had chlorides issues and decided it was not worth continued acceptance.

I learned a couple weeks ago that the City of Fairmont may be considering acceptance of treated wastewater from Fairmont Brine in the near future. The agency’s pretreatment coordinator is currently going over what the requirements would be for that activity.

The general problem with the wastewater is if untreated (straight from the site) it is high strength for many parameters that are generally not treatable (or treatability is limited) by conventional POTW treatment processes. Also there is a question of whether radiation would be present (alpha, beta, radium) in harmful amounts at the hea dworks which would cause concern for worker exposure orsludge contamination. WV has never been able to get a good answer on the TENORM question. Basically we have defaulted to “cannot accept” TENORM containing materials without prior approval from DHHR

or NRC. The most recent permits also have IH scans for radiologicals based on EPA’s water treatment plant guidance. If a POTW would start accepting this would probably be a requirement until the agency can confirm the presence/absence of radiologicals in har mful amounts.

The 3 cities you list have their own Pretreatment Programs so I can’t say for 100% sure they are not accepting; however, the agency notified the delegated cities that if they were to start accepting they would have to notify us (see attachme nt).

As for the triangle on Figure 9 I don’t think is Clarksburg

– it looks in the area of City of Buckhannon and may be CBM wastewater not Shale for they received the letter indicating the requirements the agency would impose too (I have attached a draft copy/example of the letter sent). Hard to tell from that figure though.

Note acceptance of Shale wastewater was circa 2009 timeframe. The issue has been pretty dead for a few years know I think most generators are shipping the wastewater out of WV for tr eatment due to the agency’s conservative stance.

Call me with questions,

John V Lockhart, P.E. West Virginia Department of Environmental Protection Division of Water and Waste Management

601 57th Street SE Charleston, WV 25304 304.926.0499 x1028 phone

30 4.926.0496 fax john.v.lockhart@wv.gov www.dep.wv.gov

From: Biddle, Lisa [ mailto:Biddle.Lisa@epa.gov ]

Sent: Wednesday, May 28, 2014 5:21 PM

To: Sweeney, Matthew L

Cc: McFadden, Angela; Sarah Yates ( sarah.yates@erg.com ) Subject: RE: West Virginia Oil and Gas Wastewater Management

Hi Matt, I am following up to the voice message I just left you. I wanted to circle back with you on this and see if you’ve had a chance to check into whether or not you have POTWs accepting shale gas/oil wastewater from well operators. In particular, if you have any specific information on the Wheeling POTW and/or the Clarksburg POTW, which may have taken these wastewaters in the past, that would be helpful (especially verifying whether or not they are currently accepting shale gas or oil wastewaters). My email

below asks about some other facili ties that are also of interest too. But if your time is limited, if you could at least provide the info on Wheeling and Clarksburg POTWs that would be a good start.

Thanks for your time,Lisa

_____________________ Lisa A. Biddle U.S. EPA, Office of Wate r ph: (202) 566 0350 Biddle.Lisa@epa.gov

From: Biddle, Lisa

Sent: Wednesday, April 09, 2014 8:45 AM

To: Sweeney, Matthew L

Cc: Sarah Hays; McFadden, Angela Subject: RE: West Virginia Oil and Gas Wastewater Manag ement

Thank you for the message Matt. We are not focused on CBM wastewater, so you do not need to go to lengths to summarize information about facilities that do not take shale gas/oil wastewater and only

take CBM. Is that documented somewhere in a rule o r agreement (that they will only take CBM wastewater out of the oil and gas wastewaters that could be generated and accepted at a POTW)?

Again, thanks for your help on this!

- Lisa

_____________________ Lisa A. Biddle U.S. EPA, Office of Water ph: (202) 566 0350 Biddle.Lisa@epa.gov

From: Sweeney, Matthew L [ mailto:Matthew.L.Sweeney@wv.gov ]

Sent: Tuesday, April 08, 2014 7:24 PM

To: Biddle, Lisa

Cc: Sarah Hays; McFadden, Angela Subject: RE: West Virginia Oil and Gas Wastewater Management

Lisa,

Sorry for the delayed response. This will take some time for me to compile updated information. I am currently swamped with some permits and appeals. I wil l try to get back to you this month with some updated info. If I am recalling from memory correctly, I do not believe we have any POTWs taking any shale wastewater, but there may be a couple taking CBM wastewater. I will need to compile some info

to veri fy in order to provide accurate answers to your questions. If you are not interested in POTWs taking CBM wastewater, let me know and I will not compile that information in my research.

Thanks, Matt Sweeney, P.E. NPDES Individual Permitting Supervisor WV Department of Environmental Protection Division of Water and Waste Management

601 57 th Street, SECharleston, WV 25304 (304) 926

- 0495

From: Biddle, Lisa [ mailto:Biddle.Lisa@epa.gov ]

Sent: Tuesday, March 25, 2014 3:25 PM

To: Sweeney, Matthew L

Cc: Sarah Hays; McFadden, Angela Subject: West Virginia Oil and Gas Wastewater Management

Hello, Dana Walker and Angela McFadden in EPA’s Region 3 Office suggested I contact you for some help with

information we are looking for about oil and gas wastewater management in the state of West Virginia. I work in EPA’s Office of Water in a group that writes Effluent Limitations Guidelines and Standards. We are working on a pretreatment standard for wastewater that is gener ated from the unconventional oil and gas industry. As part of the regulatory development process we write a Technical Development Document which provides background on the industry and details about what we’ve learned pertaining

to industrial wastewater ma nagement, characteristics, and general industry practices. We have been compiling data from existing literature, States, research/presentations, site visits, operators, etc., pertaining to unconventional oil and gas wastewater characterization and managem ent practices. A summary of the rulemaking effort can be found here: http://water.epa.gov/scitech/wastetech/guide/oilandgas/unconv.cfm

.

It is my impression that, in light of the recent state requirements, shale gas wastewater is no longer being disposed of at POTWs in WV. But I wanted to check in with you to make sure my understanding is correct. Also, there are some more detailed questions below which I think you may be able to help us tie up to tell the background on oil and gas wastewater management in WV accurately.

I have attached a document titled, “Water Resource Reporting and Water Footprint from Marcellus Shale Development in West Virginia and Pennsylvania”. This doc ument notes that, between 2010 and 2012 in WV, about 22% of flowback was disposed of via underground injection and about 1% was disposed of via POTWs. Although there is only a small volume of O&G wastewater being disposed of at POTWs, we’re still interest ed in identifying those POTWs. We have the following questions about

POTWs in WV:

1. In addition to the names of any POTWs that have accepted (or currently are accepting) O&G wastewater, we’d like to know the following information:

- Is the POTW currently permitted to accept O&G wastewater? Are there any limitations to the type of water the POTW can accept (e.g., not allowed to accept shale gas wastewater)?

- Is the POTW currently accepting O&G wastewater? If so, what is the source of the wastewater (e.g., conventional O&G, unconventional (shale gas) O&G, CWT facility)?

- What quantity of O&G wastewater was/is accepted by the POTW? What volume of wastewater was/is from conventional O&G wells and what volume was/is from

uncon ventional O&G wells?2. Are you aware of any problems experienced by the POTWs that have accepted O&G wastewater as a result of accepting the O&G wastewater? We’ve heard that the Wheeling POTW experienced some issues while accepting O&G wastewater f rom LAD CWT. If there is additional information on that which you could provide (e.g., a report about the problems experienced by Wheeling), that would be very helpful.

3. To

- date, we have identified the following POTWs as having accepted O& G wastewater. Can you verify that the information below is correct and can you provide any additional information and/or updates, where available?

a. Clarksburg POTW (WV0023302)

– Unclear whether or not they are accepting any O&G

wastewater. Please i nform about the status of this POTW, where data are available.

b. Morgantown POTW (unknown permit number)

– Accepted conventional oil and gas (COG) wastewater directly from a COG operator in 2006. Not currently accepting any

O&G wastewater.

c. W heeling POTW (WV0023230)

– Accepted unconventional oil and gas (UOG) wastewater directly from a UOG operator in 2008 as well as from the “Liquid Assets Disposal” CWT. Unclear whether or not they are currently accepting any O&G

wastewater.

Figure 9 (on pag e 34 of the pdf) identifies a POTW in the central part of WV. It doesn’t appear that this POTW is the Wheeling POTW or Morgantown POTW that we’ve identified, but it could possibly be the Clarksburg POTW. Can you verify that it is the Clarksburg POTW,

or, i f not, can you otherwise identify it?

Thanks for any information you can provide. If I can help clarify anything, please let me know and we can set up a time to talk.

- Lisa

_____________________ Lisa A. Biddle U.S. EPA, Office of Water ph: (202) 566 0350 Biddle.Lisa@epa.gov