## MEMORANDUM

TO: Lisa Biddle, EPA

FROM: Brent Ruminski, ERG

James K. O’Connell, ERG

DATE: March 3 0

, 2015

SUBJECT: Analysis of Pennsylvania Department of Environmental Protection’s Oil and

Gas Waste Reports ( DCN SGE0073 9 )

T his memorandum describes how ERG compile d and analyze d information from the Pennsylvania Department of Environmental Protection (PA DEP) fo r the Technical Development Document (TDD) for Proposed Effluent Limitations Guidelines and Standards for Oil and Gas Extraction ( DCN SGE00704 ). Specifically, this memorandum describes how ERG developed the TDD tables and figures listed in Table 1 all of which are specific to unconventional oil and gas (UOG) in Pennsylvania

. 1 

### It also discusses ERG’s analyses that support memoranda listed in Table 2 , some o f which include analysis of conventional oil and gas (COG) in Pennsylvania

. Tables and figures that are presented in the TDD not listed in Table 1 either did not require calculations and/or analyses by ERG or are described in separate, supporting memoranda. Appendix F of the TDD contains a crosswalk of all tables and figures in the TDD and the name of the relevant supporting memorandum, where applic able. This memorandum is organized into the following sections:

 

### Section 1.0 discusses background information about the PA DEP Waste Reports.

 

### Section 2.0 describes the methodology ERG used to analy ze the PA DEP W aste R eport data.

 

### Section 3.0 presents a data dictionary for the databases ERG developed.

 

### Section 4.0 describes ERG’s quality assurance procedures.

 

### Section 5.0 lists the references used for these analyses.

 

### Section 6.0 provides the three attachme nts to this memorandum.

The three attachments to this memorandum contain the underlying data and calculations used to create the figures and tables in the TDD as well as analyses of PA DEP waste report data that support other memoranda

. These attachments are:

 Attachment 1

– PA DEP Waste Reports Development Database ( DCN SGE 00 739 .A01 )

 Attachment 2

– PA DEP Waste Reports Analysis Database ( DCN SGE00 739 .A02 )

 Attachment 3

– PA DEP Data Calculations ( DCN SGE00 739 .A03 )

1 The primary UOG formations in Pennsylvania are the Marcellus and Utica shales.

### Memorandum

March 30, 2015 Page 2

Table 1 . List of TDD Tables and Figures Discussed in this Memorandum

TDD Table or Figure Number TDD Table or Figure Number Title Memo randum Section
Figure C

- 1 UOG Extraction Wastewater Volumes for Marcellus Shale Wells in

Pennsylvania (2004

– 2013) 2.2.1.1

Figure D

- 3 Management of UOG Drilling Wastewater Generated by UOG Wells

in Pennsylvania (2008

– 2013 ) 2.2.1.2

Table C

- 4 Average Drilling Wastewater Volumes for UOG Horizontal and

Vertical Wells in Pennsylvania a 2.2.1.3

a

– The data related to Table C

- 4 are also discussed in ERG’s Unconventional Oil and Gas (UOG) Drilling Wastewater Memorandum (DCN SGE00740)

.



### Table 2

. Data Supporting Other TDD Memoranda Discussed in this Memorandum

Data Description Supporting Memorandum Title and DCN Memo

. Section
UOG and COG extraction wastewater volumes accepted by POTWs Publicly Owned Tre atment Works Memorandum for the Technical Development Document

– DCN S GE00929 2.2.2.1
COG drilling wastewater management practices Conventional Oil and Ga s Memorandum for the Record

– DCN SGE01016 2.2.2.2

UOG long

- term produced water rates Unconventional Oil and Gas Produced Water Volumes and Characterization Data Compilation Memorandum

– DCN SGE00724 2.2.2.3



### This memorandum will refer to the following terms used throughout the TDD, the supporting memoranda, and memoranda attachments:

 

### Unconventional oil and gas (UOG) resources

- crude oil and natural gas 2 

### produced by wells drilled 3 

### into low porosity, low permeability formations. 4



###  

### UOG extraction wastewater

- sources of wastewater pollutants associated with production, field exploration, drilling, well completion, or well treatment for unconventional oil and gas extraction (e.g.

, drilling muds, drill cuttings, produced sand, produced water)

. 5 

### UOG extraction wastewater includes produced water, drilling wastewater, and produced sand 6



### .

 

### Drilling wastewater

– the liquid waste stream separated from recovered drilling fluid (mud) and drill cuttings during the drilling process

.

2 Natural gas can include “natural gas liquids,” components that are liquid at ambient temperature and pressure.
3 UOG wells may be drilled using horizontal, vertical, or directional well trajectories. Literature sometimes refers to well trajectory as “drill type”. PA DEP refers to this as “well configuration”.
4 This definition of UOG is similar to how PA DEP defin es it (see Table 13 ).
5 Stormwater is not considered a source of UOG extraction wastewater. In general, no NPDES permit is required for discharges of stormwater from a ny field activities or operations associated with oil and gas production, except as specified in 40 C.F.R. 122.26(c)(1)(iii) for discharges of a reportable quantity or that contribute to a violation of a water quality standard . States may impose additional requirements for management of drilling site stormwater.
6 Produced sand is not discussed in this memorandum.

### Memorandum

March 30, 2015 Page 3

 P roduced water

– the water (brine) brought up from the hydrocarbon

- bearing

strata during the extraction of oil and g as. This can include formation water, injection water, and any chemicals added downhole or during the oil/water separation process . Based on the stage of completion and production the well is in, produced water can be further broken down into the following components:

 Flowback

– the produced water generated in the initial period after hydraulic fracturing (i.e., fracturing fluid, injection water, any chemicals added downhole, and varying amounts of formation water)

.

 Long

- term produced water (LTPW)

– the produced water generated during the production phase of the well after the initial flowback process (includes increasing amounts of formation water)

.

1.0 W ASTE 

### R EPORT 

### B ACKGROUND


### PA DEP requires all oil and gas operators t o report oil, gas, and waste generation for conventional and unconventional oil and gas wells 7 

### . For waste generation, operators must report waste quantity, waste type, and wa ste management information for each well they operate in Pennsylvania

. PA DEP peri odically publishes aggregated reports containing this waste data henceforth referred to as PA DEP Waste Reports 8



### . The PA DEP Waste Reports only include information about wells located within Pennsylvania, but may include information about waste generated a t a well in PA that is transferred to an other state

.
The PA DEP W aste R eports capture all waste generated per well during a specific reporting period specified by PA DEP

. Separate waste reports are published for COG wells and for UOG wells with the following reporting periods: COG waste reports are published annually and UOG waste reports are published semi

- annually. Because the information is collected directly from operators, the data contains a variety of naming conventions, spelling err ors, and missing information. See Section 2.1.2 for examples of ERG’s consolidations for the parameters listed in the waste reports. In general, e ach record in a w aste report is unique to the list of parameters below :

 

### Well Permit (i.e., well API number )

 

### Reporting period

 

### Waste Type (e.g., long

- term produced water 9 

### , flowback )

 

### Waste Management Practice (e.g., POTW 10 

### , CWT 11 

### facility )

 

### Waste Facility Name (e.g., Eureka Resources )

For example, if a well generated drilling wastewater and flowback during the given reporting period , and both waste streams were managed using underground injection, the corresponding waste report for that well would include two records for the given reporting

7 An indicator for the resource type (i.e., shale , tight) of the well that generated the waste is included in every PA DEP Waste Report entry.
8 ERG downloaded these reports (DCN SGE00188 and its attachments, DCN SGE00188.A01

- A23) as .CSV Microsoft Excel files.
9 The PA DEP waste reports include entries for “brine” and “produced fluid” that ERG standardized and called “long

- term produced water” ( see Table 4 ).
10 Publicly Owned Treatment Works
11 Centralized Waste Treatment

### Memorandum

March 30, 2015 Page 4

period. If a well only generated long

- term produced water during the reporting period and the operator managed it all using the same management practice and waste facility, the well would have only one record for the reporting period. Alte rnatively , if a well generated only long

- term produced water during the reporting period and the operator managed it all using the same management practice, but used different waste facilities, the well would have multiple waste records for the reporting p eriod (one for each waste facility)

.
2.0 M ETHODOLOGY


### ERG used the following three files to compile and analyze PA DEP W aste R eports.

 

### Attachment 1 (DCN SGE00739 .A01 )

– PA DEP Waste Reports Development Database (

Development Database ) : This database compiles individual waste reports from PA DEP into one master table called “PA DEP Waste Data.” This database also standardizes data entries for several fields to correct spelling errors and inconsistent naming conventions by operators

.

 

### Attachment 2 (DCN SGE00739 .A02 )

– PA DEP Waste Reports Analysis Datab a se (

Analysis Database ) : This database contains queries that summarize the resulting master table (“ PA DEP Waste Data ”) from the Development Database

. ERG further analyzed t he se results using the Analysis Spreadsheet below.

 

### Attachment 3 (DCN SGE00739 .A03 )

– PA DEP Data Calculations ( Analysis Spreadsheet

) : This spreadsheet contains the resulting data tables from the Analysis Database and figures and tables that ERG created for the TDD and for other supporting memoranda.

The following subsections describe the methodology in more detail. Section 2.1 discuses Attachment 1 (DCN SGE00739 .A01 )

. Section 2.2 discusses Attachments 2 (DCN SGE00739 .A02 ) and 3 (DCN SGE00739 .A03 ) because the queries in the Analysis Database are directly related to the tabs in the Analysis Spreadsheet

, which are best explained together.

2.1 P A DEP Waste Report s Development Database

ERG created the Development Database in Attachment 1 (DCN SGE 00739 .A01 ) as described in Sections 2.1.1 and 2.1.2

. ERG imported t he PA DEP Waste Reports data into the database from Microsoft Excel files using the import feature of Microsoft Access.

2.1.1 Development Database Queries

Table 3 s hows each of the relevant query names in the Development Database along with a description of each. The queries perform two primar y functions that ultimately create the final “PA DEP W aste” table:

1. Combine all waste reports from PA DEP’s website (2004 through 2013) (DCN SGE00188) into a single table titled “PA DEP Waste Data” and format t he data by removing dashes from the reported years (queries 000 through 110 in Table 3 )

.

### Memorandum

March 30, 2015 Page 5

2. Standardize data reported by operators in select fields using the crosswalks described in Section 2.1.2 (queries 200 and 201 in Table 3 ).

Table 3

. PA DEP Waste Report s Development Database Queries

Query Name Description 000

– Create PA DEP Waste Table (with 2012 Conventional) Creates the shell of the final PA DEP Waste Data table using the 2012 conventional waste report 12

001

- Append Waste 2004_All Appends the 2004 waste report for all oil and gas to the final PA DEP Waste Data table

002

- Append Waste 2005_All Appends the 2005 waste report for all oil and gas to the final PA DEP Waste Data table

003

- Append Waste 2006_All Appends the 2006 waste report for all oil and gas to the final PA DEP Waste Data table

004

- Append Waste 2007_All Appends the 2007 waste report for all oil and gas to the final PA DEP Waste Data table

005

- Append Waste 2008_All Appends the 2008 waste report for all oil and gas to the final PA DEP Waste Data table

006

- Append Waste 2009_All Appends the 2009 waste report for all oil and gas to the final PA DEP Waste Data table

007

- Append Waste 2010

- 0_ COG Appends the 2010 COG waste report to the final PA DEP Waste Data table

008

- Append Waste 2010

- 1_ UOG Appends the 1 st half of 2010 UOG waste report to the final PA DEP Waste Data table

009

- Append Waste 2010

- 2_ UOG App ends the 2 nd half of 2010 UOG waste report to the final PA DEP Waste Data table

010

- Append Waste 2011

- 0_ COG Appends the 2011 COG waste report to the final PA DEP Waste Data table

011

- Append Waste2011

- 1_ UOG Appends the 1 st half of 2011 UOG waste report to the final PA DEP Waste Data table

012

- Append Waste 2011

- 2_ UOG Appends the 2 nd half of 2011 UOG waste report to the final PA DEP Waste Data table

013

- Append Waste 2012

- 1_ UOG 13 Appends the 1 st half of 2012 UOG waste report to the final PA DEP Waste Data table

014

- Append Waste 2012

- 2_ UOG Appends the 2 nd half of 2012 UOG waste report to the final PA DEP Waste Data table

015

- Append Waste 2013

- 0_ COG Appends the 2013 COG waste report to the final PA DEP Waste Data table

016

- Append Waste 2013

- 1_ UOG Appends the 1 st half of 2013 UOG waste report to the final PA DEP Waste Data table

017

- Append Waste 2013

- 2_ UOG Appends the 2 nd half of 2013 UOG waste report to the final PA DEP Waste Data tabl e

100

- Fix 2010 Waste Period ID Fixes the error associated with the Period ID for 2010 reports. The query changes values where the period was reported as “#NUM!” to 2010. 101

- Remove Waste dashes

- 2004 Changes “2004

- 0” to “2004” in the Period ID field 102

- Remove Waste dashes

- 2005 Changes “2005

- 0” to “2005” in the Period ID field 103

- Remove Waste dashes

- 2006 Changes “2006

- 0” to “2006” in the Period ID field 104

- Remove Waste dashes

- 2007 Changes “2007

- 0” to “2007” in the Period ID field 105

- Remove Waste dashes

- 2008 Changes “2008

- 0” to “2008” in the Period ID field 106

- Remove Waste dashes

- 2009 Changes “2009

- 0” to “2009” in the Period ID field

12 ERG created the PA DEP Waste Reports Development Database in 2013. ERG began with the 2012 conventional waste reports because ERG wanted to use the most recent data as a starting point.
13 The 2012 COG waste report does not have a separate query; rather it is contained in query 000.

### Memorandum

March 30, 2015 Page 6

Table 3

. PA DEP Waste Report s Development Database Queries

Query Name Description

107

- Remove Waste dashes

- 2010 Changes “2010

- 0”, “2010

- 1”, and “2010

- 2” to “2010” in the Period ID field

108

- Remove Waste dashes

- 2011 Changes “2011

- 0”, “2011

- 1”, and “2011

- 2” to “2011” in the Period ID field

109

- Remove Waste dashes

- 2012 Changes “2012

- 0”, “2012

- 1”, and “2012

- 2” to “2012” in the Period ID field

110

- Remove Waste dashes

- 2013 Chang es “2013

- 0”, “2013

- 1”, and “2013

- 2” to “2013” in the Period ID field

200

– Update Consolidated Waste Type Updates the waste type based on the waste type and units reported in the PA DEP Waste Reports data and using the “Waste Type Consolidation” crosswalk that ERG developed.

201

– Update Consolidated Disposal Method and Facility Updates the disposal method and waste facility name based on the waste facility permit number, waste facility address, consolidated disposal method, consolidated waste facility na me, and consolidated waste facility permit number reported in the PA DEP Waste Reports data and using the “Waste Disposal Method Consolidation” crosswalk that ERG developed

.



### 2.1.2 Data Entry Consolidations

ERG c reated two consolidation crosswalk tables to standardize reported data so the data could be more easily summarized

. As previously described, the PA DEP W aste R eports include a variety of naming conventions, spelling errors, and missing information. ERG first consolidated the reported waste types (e.g., flowback, drilling wastewater) and then standardized the facility records (i.e., waste disposal method, facility name, and permit number).

Table 4 shows the c omplete crosswalk ERG used for waste type consolidation

, which is also contained in the table titled “Waste Type Consolidation” in Attachment 1 (DCN SGE00739 .A01 ).

Table 4 . Waste Type Consolidation Crosswalk

Reported Waste Type Units Consolidated Waste Type Basic Sediment Bbl Basic Sediment Drill Cuttings Tons Drill Cuttings Drilling Bbl Drilling Wastewater Drilling Fluid Bbl Drilling Fluid Waste Bbl Flow

- Back Fluid Bbl Flowback Frac k ing Fluid Waste Bbl Fracking Fluid Bbl Flowback Fracturing Sand Tons Flowback Fracturing Sand Flow

- Back Fracturing Sand Tons Brine Bbl Long

- term Produced Water Produced Fluid Bbl Servicing Fluid Bbl Servicing Fluid Spent Lubricant Bbl Spent Lubricant Bbl

– Barrels.

### Memorandum

March 30, 2015 Page 7

Table 5 shows the complete crosswalk ERG used for waste disposal method consolidation. This table is included with in the “Facility Type Consolidation” crosswalk in Att achment 1 (DCN SGE00739 .A01 )

.

Table 5 . Waste Disposal Method Consolidation Crosswalk

Reported Disposal Method Consolidated Disposal Method Reuse Other Than Road Spreading Reuse/Recycle Brine Or Industrial Waste Treatment Plt

CWT Facility 14 Centralized Treatment Plant For Recycle Residual Waste Transfer Facility Cent Waste Trt Fac NPDES Discharge Centralized Treatment/Discharge(>500Mg/L) Residual Waste Proc Fac (General Permit) Injection Disposal Well Underground Injection Public Sewage Treatment Plant POTW Municipal Sewage Treatment Plant Surface Impoundment Storage Pending Disposal or Reuse Storage Pending Disposal Or Reuse On Site Pit Treated On

- Site, NPDES Discharge Treated On

- site, NPDES Discharge Road Spreading Road Spreading Landfill Landfill Other Other Identify Method In Comments Land Application Land Application Encapsulation Encapsulation On Site Encapsulation



### Table 6 shows examples from the crosswalk ERG used to correct inconsistent reporting, spelling errors, and missing information related to the waste facility (e.g., name, permit number) reported by oi l and gas operators in the PA DEP Waste Reports. The full crosswalk is contained in Attachment 1 (DCN SGE00739 .A01 ) and is titl ed “Facility Type Consolidation

. ” To better demonstrate the standardization of the data fields, records in Table 6 are grouped together by facility (groups are highlighted). As shown in Table 6
, ERG performed these standardizations simultaneously, often using information from one data field to assist in the standardization of another. For this reason, the standardizations shown in Table 6 supersede the consolidations shown in Table 5

. In some cases, engineering judgment was required to properly standardize all of the data fields.

14 For more information on how ERG identified CWT facilities, see ERG’s Analysis of Centralized Waste Treatment (CWT) Facilities Accepting UOG Extraction Wastewater Memorandum (DCN SGE00596)

.

### Memorandum March 30, 2015 Page 8

Table 6

. Subset of Crosswalk of Waste Facility Record Standardization

Reported Waste Type Reported Disposal Method Reported Waste

Facility Name Reported

Waste Facility Permit # Consolidated

Waste Type Consolidated

Disposal Method Consolidated Waste

Facility Name Consolidated

Waste Facility Permit #
Drilling Fluid Centralized Treatment

Plant For Recycle Mccutcheon Enterprise PAD01382684

7 Drilling

wastewater CWT Facility Mccutcheon Enterprise PAD013826847

Drilling Centralized Treatment

Plant For Recycle Mccutcheon Enterprises Inc PAD01382684

7 Drilling

wastewater CWT Facility Mccutcheon Enterprise PAD013826847

Frac Flowback Residual Waste Transfer

Facility Mccutcheon Enterprises Inc PAD01382684

7 Flowback CWT Facility Mccutcheon Enterprise PAD013826847
Fracking Fluid Municipal Sewage

Treatment Plant Mccutcheon Enterprises, Inc. -- a Flowback CWT Facility Mccutcheon Enterprise PAD013826847

Drilling Fluid Public Sewage Treatment

Plant Dornick Point Wwtp PA0026034 Drilling
wastewater POTW Johnstown STP PA0026034

Drilling Fluid Public Sewage Treatment

Plant Johnstown Sewage Treatment Plant PA0026034 Drilling
wastewater POTW Johnstown STP PA0026034

Drilling Brine Or Industrial Waste

Treatment Plt Johnstown Stp

-- a Drilling
wastewater POTW Johnstown STP PA0026034

Brine Municipal Sewage

Treatment Plant Johnstown Stp

-- a Long

- term produced water POTW Johnstown STP PA0026034

Produced Fluid Reuse Other Than Road

Spreading Johnstown Stp

-- a Long

- term produced water POTW Johnstown STP PA0026034

Drilling Fluid Brine Or Industrial Waste

Treatment Plt Ridgeway Borough -- a Drilling
wastewater POTW Ridgeway Borough STP PA0023213

Drilling Fluid Centralized Treatment

Plant For Recycle Ridgway Borough Sewage Plant PA0023213 Drilling
wastewater POTW Ridgeway Borough STP PA0023213

Drilling Fluid Public Sewage Treatment

Plant Ridgway Borough Sewage Treatment Plant PA0023213 Drilling
wastewater POTW Ridgeway Borough STP PA0023213

Brine Injection Disposal Well Carper Well Svc Bryane Smith 1 34

- 121

- 23390 Long

- term produced water Underground

Injection N/A N/A

Produced Fluid Centralized Treatment

Plant For Recycle Carper Well Svc Bryane Smith 1 34

- 121

- 23390 Long

- term produced water Underground

Injection N/A N/A

a

– No permit number was reported for these records. ERG assigned the correct permit number during the consolidation process.

### Memorandum

March 30, 2015 Page 9

2.2 PA DEP Waste Report s Analysis Database and Spreadsheet

T he PA DEP Waste Reports Analysis Database in Attachment 2 (DCN SGE00739 .A02 ) contains queries that organize and sort data in the table titled “ PA DEP Waste Data ” (the table developed in the PA DEP Waste Reports Development Database )

. ERG exported t he results from the se queries into the PA DEP Data Calculations Microsoft E xcel file in Attachment 3 (DCN SGE00739 .A03 ) to create TDD Figure C

- 1, Figure D

- 3, Table C

- 4 , and various data tables used in supporting memoranda

. The following subsections describe the individual methodologies used to generate these figures and table.

2.2.1 TDD Figures and Table

The following describes how ERG created Figure C

- 1, Figure D

- 3, and Table C

- 4 in the TDD . Each subsection describes the associated queries and tabs in Attachments 2 (DCN SGE0073 9 .A02 ) and 3 (DCN SGE00739 .A03 ), respectively, that ERG used to create these figures and table.

2.2.1.1 Figure C

- 1. UOG Extraction Wastewater Volumes for Marcellus Shale

Wells in Pennsylvania (2004

– 2013)

To create TDD Figure C

- 1, ERG used quer ies 40 and 41 ( see Table 7 ) in Attachment 2 (DCN SGE00739 .A02 ) to sum UOG extraction wastewater volumes for all wells in the database by the type of wastewater (i.e., drilling wastewater, flowback, long

- term produced water) and by well trajectory (i.e., horizontal

, vertical). T he results from query 41 are presented in the “WW Volume Breakdown” tab of Attachment 3 (DCN SGE00739 .A03 )

. In this tab, ERG converted the volumes into percentages of the total extraction wastewater volume for each well trajectory

. Subsequently, ERG plotted these percentages in t he two pie charts that make up TDD Figure C

1 , which are i n the “Breakdown of Marcellus Vert” and “Breakdown of Marcellus Horiz” tabs in Attach ment 3 (DCN SGE00739 .A03 )

. The numbers of horizontal and vertical wells are noted at the top of each pie chart.

Table 7 . PA DEP Waste Report s Analysis Database Query Descriptions Related to Figure C

- 1 Query Name Description 40

– UOG Extraction Wastewater Breakdown Sums the total drilling wastewater , flowback, and long

- term produced water volumes separately for each UOG well permit number (i.e., API number ) . W ell trajectory a is also included for each well permit number. 41

– UOG Extraction Wastewater Breakdown This query summarizes the results from query 40 using the following c alculations:

 Sum the volumes of each category of wastewater for each well trajectory ( i.e., horizontal

, vertical)

 Count the number of well permit numb ers (i.e., API number) for each well trajectory category

a

– Well trajectory is referred to as well configuration in the PA DEP data (see Table 13 ).



### 2.2.1.2 Figure D

- 3. Management of UOG Drilling Wastewater Generated by

UOG Wells in Pennsylvania (2008

– 2013)

Using q ueries 30 and 31 ( see Table 8 ) in Attachment 2 (DCN SGE00739 .A02 ), ERG summarized UOG extraction wastewater management practices, by year . ERG copied the results

### Memorandum

March 30, 2015 Page 10

of these queries in to the “ UOG D rill WW Mgmt Data ” and “UOG PW Mgmt Data” tab s of Attachment 3 (DCN SGE00739 .A03 )

. In these tab s , ERG converted annual volumes into percentages of the total extraction wastewater volume each year. Subsequently, ERG plotted these percentages in the “UOG Drill WW Mgmt Graph” (i.e., TDD Figure D

- 3) and “UOG PW Mgmt Graph” tab s of Attachment 3 (DCN SGE00739 .A03 )

. ERG excluded d ata for 2004 through 2007 in th e s e graph s because there was minimal UOG extraction wastewater reported during these years

. UOG produced water management d ata (query 32 and “UOG PW Mgmt Graph” tab) are not explicitly presented in the TDD
, but are discussed in Chapter D of the TDD

.

Table 8 . PA DEP Waste Report s Analysis Database Query Descriptions Related to Figure D

- 3 Query Name Description 30

– UOG Drilling Fluid WW Management Sums total UOG drilling wastewater volume by consolidated disposal method for 2004

- 2013 31

– UOG Flowback and Long

- term PW Management Sums total UOG flowback and long

- term produced water volumes by consolidated disposal method for 2004

- 2013



### 2.2.1.3 Table C

- 4

. Average Drilling Wastewater Volumes for UOG Horizontal

and Vertical Wells in Pennsylvania

This next analysis was used t o create TDD Table C

- 4, and the resu lts are also presented in ERG’s Unconventional O il and Gas Drilling Wastewater Memorandum (DCN SGE00740). ERG summed drilling fluid volume s for all wells in the PA DEP W aste R eports using quer y 10 ( see Table 9 ) in Attachment 2 (DCN SGE00739 .A02 )

. ERG copied the results of query 10 in the

“ Drill WW Vol by Well” tab of Attachment 3 (DCN SGE00739 .A03 )

. ERG calculated the 10 th 

### percentile, median, average, and 90 th 

### percentile volumes on a well basis for each well trajectory type for unconventional wells which are shown in the “Drill WW Vol Summary” tab of Attachment 3 (DCN SGE00739 .A03 )

. ERG calculated the 10 th 

### percentile and 90 th 

### percentile as
oppos ed to minimum and maximum to remove outlying data points.

Table 9 . PA DEP Waste Report s Analysis Database Query Descriptions Related to Table C

- 4 Query Name Description 10

– Drilling Wastewater Volume by Well Calculates total drilling wastewater volume by well API number and includes indicator for well trajectory a and resource type (conventional, unconventional)

a

– Well trajectory is referred to as well configuration in the PA DEP data (see Table 13 ).



### 2.2.2 Analys e s Supporting Additional Memoranda

The following describes how ERG created various data tables used to create figures and tables in oth er supporting memoranda. Each subsection describes the a ssociated queries and tabs in Attachments 2 (DCN SGE00739 .A02 ) and 3 (DCN SGE00739 .A03 )

, respectively

, that ERG used to create these figures and tables

.
2.2.2.1 POTW Analysis

ERG’s Publicly Owned Treatment Wo rks (POTW) Memorandum for the Technical Development Document (DCN SGE00929) references data from queries 20

, 21

, and 22 in

### Memorandum

March 30, 2015 Page 11

Attachment 2 (DCN SGE00739 .A02 ). Table 10 describes these queries that sum UOG extraction wastewater discharged to POTWs by resource type, waste type, and /or year. ERG create d several figures in Chapter D of the TDD using these data, including Figures D

- 10 through D

- 15

.

Table 10 . PA DEP Waste Report s Analysis Databas e Query Descriptions Related to ERG’s Analysis of POTWs Accepting Oil and Gas Extraction Wastewater Query Name Description 20

– Total WW Volume by POTW and Resource Type Using the PA DEP Waste Data table , sums the total wastewater volume by resource type (COG or UO G ) for POTWs in Pennsylvania 21

– Total WW Volume by POTW and Waste Type Using the results from Query 20 , sums the total wastewater volume by waste type for POTWs in Pennsylvania 22

– Total WW Volume by POTW Over Time Using the results from Queries 2 0 and 2 1 , sums the total wastewater volume by waste type and resource type for POTWs in Pennsylvania



### 2.2.2.2 Management of COG Drilling Wastewater in Pennsylvania (200 4

– 2013)
ERG analyzed PA DEP’s Waste Reports to support ERG’s Conventional Oil and Gas M emorandum for the Record (DCN SGE01016) and Unconventional O il and Gas Drilling Wastewater Memorandum (DCN SGE00740)

. U sing q uer ies 50 and 51 ( see Table 11 ) in Attachment 2 (DCN SGE00739 .A02 ) , ERG summarized statewide management practices of COG extraction wastewater generated each yea r. ERG copied the results of these queries into the “COG Drill WW Mgmt Data ” and “COG PW Mgmt Data” tab s of Attachment 3 (DCN SGE00739 .A03 )

. In th ese tab s , ERG converted annual volumes into percentages of the total extraction wastewater volume for each year

. Subsequently, ERG plotted these percentages in the “COG D rill WW Mgmt Graph” and “COG PW Mgmt Graph” tabs.

Table 11 . PA DEP Waste Report s Analysis Database Query Descriptions Related to COG Extraction Wastewater Management Query Name Description 50

– COG Drilling Wastewater Management Calculates total COG drilling wastewater volume by consolidated disposal method for 2004

- 2013 51

– COG Flowback and Long

- term PW Management Calculates total COG flowback and long

- term produced water volumes by consolidated disposal method for 2004

- 2013



### 2.2.2.3 U O G Long

- term Produced Water Rates in Pennsylvania

ERG estimate d long

- term produced water rates using PA DEP’s Waste Reports to support ERG’s Unconventional Oil and Gas (UOG) Produced Water Volumes and Characterization Data Compilation Memorandum (DCN SGE00724)

. ERG supplemented this particular analysis with the “Spud Data” (DCN SGE00712) also published by PA DEP

. Using
q uer ies 60 and 61 ( see Table 12 ) in Attachment 2 (DCN SGE00739 .A02 )

, ERG summed all produced water volumes over time by well trajectory 15



### , production year

, and spud year. Although all produced water (i.e., flowback and long

- t erm produced water) is included in quer ies 60 and 61 , ERG removed flowback volumes in Attachment 3 (DCN SGE00739 .A03 ) prior to the final calculation of average long

- term produced water rates (as explained further below)

.

15 Well trajectory is referred to as w ell configuration in the PA DEP data.

### Memorandum

March 30, 2015 Page 12

ERG copied the results of query 61 i nto the “ UOG LTPW Rates” tab of Attachment 3 (DCN SGE00739 .A03 )

. In this tab, ERG calculated the average annual long

- term produced
water rate by dividing the total produced water volumes from 2004 through 2013 by the number of wells for each spud year. 16 

### ERG did not include the volumes of produced water generated during the spud year in order to remove flowback from the calculation of average long

- term produced water rates. ERG used the results of this analysis as inputs to their analysis of UOG produced w ater volumes in the aforementioned supporting memorandum (DCN SGE00724)

.
Table 12 . PA DEP Waste Report s Analysis Database Query Descriptions Related to UOG Long

- term Produced Water Rates Query Name Description 60

– UOG LTPW Calcs This crosstab query calculates total produced water volume over time by production
year and spud year for each UOG well permit number (i.e., well API number )

. 61

– UOG LTPW Calcs This query summarizes the results from query 60 using the following calculations:

 Sum the p roduced water volume over time by production year

, well trajectory a

, and spud year combination

 Count the number of UOG wells for each spud year and well trajectory a

a

– Well trajectory is referred to as well configuration in the PA DEP data (see Table 13 ).



### 3.0 D ATA BASE 

### D ICTIONARY



### Table 13 provides descriptions of the data fields in the “PA DEP Waste Report” table included in both of the databases E RG created for this analysis (i.e., Development Database

, DCN SGE00739 .A01 ; Analy sis Database , DCN SGE00739 .A02 ) . Most of the descriptions come directly from PA DEP’s website (DCN SGE00763 )

, indicated by “PA DEP” in the “Origin of Field” column in Table 13

. T he consolidated field names that E RG added for the purpose of this analysis ( listed at the end of Table 13 ) are indicated by “ERG” in the “Origin of Field” column and begin with “ Consolidated ” in the “Field Name” column

.

Table 13

. “PA DEP Waste Report” Table Field Descriptions

Field Name Origin of Field Description

Well Permit # PA DEP The number of the Permit that was issued to the Oil and Gas Operator for this well by the PA DEP

. This is equivalent to well API number.

Period Id PA DEP A code value indicating the 4

- digit reporting year and a number indicating the report period , where: 0=Annual ; 1=Marcellus 6

- month from Jan

- June ; 2=Marcellus 6

- month from July

- December ; and 3=Initial Marcellus 12

- month reporting period from 7/1/2009 through 6/30/2010

.

Well Status PA DEP An indicator of the well’s current status , where: Inactive= not dril led yet and Active= producing

. Other acceptable values for this field are “ Plugged ” and “ Abandoned

. ”

Farm Name PA DEP The name given to a well by the w ell o perator. Name u sually corresponds with the landowner at the time of permitting, which does not change. The Farm Name and Well # normally produce a unique ide ntifier for the well.

Well # PA DEP The number of the well being reported that was assigned by the w ell

o perator. Usually follows the Far m Name (above)

. Waste Type PA DEP The type of waste product that was generated at the well

. Waste Quantity PA DEP The amount of the waste product that was generated at the well

. Units PA DEP The unit of measure that was used for the generated waste

.

16 ERG also divided by 365 days per year to convert the annual volumes into rates.

### Memorandum

March 30, 2015 Page 13

Table 13

. “PA DEP Waste Report” Table Field Descriptions

Field Name Origin of Field Description Disposal Method PA DEP The method used to dispose of the waste generated at the well

.

Averaged PA DEP This Y/N field indicate s whether the production and wa ste amounts were averaged (Y) or not (N). If Y, they were averaged based on the well being
repo rted as part of a group of wells.

Operator Name PA DEP The o rganizational n ame of the w ell o perator reporting well production during all or a portion of the reporting period. Several operators may report during the reporting period based on their period of co ntrol

.

OGO # PA DEP The Oil and Gas Operator (OGO) Id of the operator of the well during the report period. Well County PA DEP The County in which the well is located

. Well Municipality PA DEP The Municipality in which the well is located

. Well Latitude PA DEP The latitude value, in decimal degrees, for the permitted well location

. Well Longitude PA DEP The longitude value, in decimal degrees, for the permitted well location

.

Unconventional PA DEP A yes or no indicator that identifies a bore hole drilled or being drilled for the purpose of or to be used for the production of natural gas from an unconventional formation 17

.

Well Configuration 18 Code PA DEP An indicator code that describes whether a well is horizontal, vertical, or intentionally deviated. A value of “HORIZ” indicates that the well is a horizontal well, meaning a well is initially drilled vertically then curved to become horizontal (or near horizontal) in order to parallel a particular geologic formation. Intentionally deviated wel ls are indicated by a value of “DEVIA”, whereas vertical wells are indicated by a value of “VERTI”

.

Home Use PA DEP A yes or no indicator that will represent whether the well has been identified as a Home Use Well or not. Home use wells have no commercial production and the product is used entirely on the property

. Waste Facility Permit # PA DEP The permit number of the Waste Facility that the waste product was taken to if the facility was permitted by DEP

. Waste Facility Name PA DEP Name of the facility that accepted and treated the waste products from the well. Facility Address 1 PA DEP The primary address of the Waste Facility

.
Facility Address 2 PA DEP The optional second line of the address of the Waste Facility

.
Facility City PA DEP The municipality in which the Waste Facility is located

. Facility State PA DEP The s tate in which the Waste Facility is located

. Facility Zip Code PA DEP The z ip c ode of the Waste Facility

. Facility Phone PA DEP The p hone n umber of the Waste Facility

. Facility Latitude PA DEP The latitude value, in decimal degrees, for the waste facility location

.
Facility Longitude PA DEP The longitude value, in decimal degrees, for the waste facility location

.

17 PA DEP’s definition of unconventional formations is as follows: A geological shale formation existing below the base of the Elk Sandst one or its geologic equivalent stratigraphic interval where natural gas generally cannot be produced at economic flow rates or in economic volumes except by vertical or horizontal well bores stimulated by hydraulic fracture treatments or by using multilate ral well bores or other techniques to expose more of the formation to the well bore.
18 ERG refers to this field as “well trajectory.”

### Memorandum

March 30, 2015 Page 14

Table 13

. “PA DEP Waste Report” Table Field Descriptions

Field Name Origin of Field Description Reporting Period PA DEP The date range of the Production or Waste Report that is being reviewed

. Comment Reason PA DEP Well Operator comment on the well or group of wells, typically indicating why no production data was reported

.

Comment Text PA DEP Well Operator comment on a well or group of wells, typically indicating why no production data was reported. Consolidated Disposal Method ERG The consolidated Disposal Method assigned by ERG in this analysis (see Section 2.1.1 ). Consolidated Waste Facility Name ERG The consolidated Waste Facility Name assigned by ERG in this analysis (see Section 2.1.1 ).

Consolidated Waste Facility Permit # ERG The consolidated Waste Facility Permit # assigned by ERG in this analysis (see Section 2.1.1 ).

Consolidated Waste Type ERG The consolidated Waste Type assigned by ERG in this analysis (see Section 2.1.1 ).



### 4.0 Q UALITY 

### C ONTROL 

### P ROCEDURES


### All of the analyses presented in this memorandum adhered to the Environmental Engineering Support for Clean Water Regulations Programmatic Quality Assurance Project Plan (PQAPP) (DCN SGE00957) and the Unconventional Oil and Gas (UOG) Supplemental Quality Assurance Project Plan (SQAPP) (DCN SGE00 958 ), including collecting, evaluating, and analyzing data and information from the PA DEP Waste Reports

. ERG also used the procedures described in Section 3 of the SQAPP when collecting existing data for use in the UOG proposed rulemaking. ERG used a combination of sources, including reports, papers, and online databases from state regulatory agencies such as departments of environmental protection and oil and ga s commissions. As shown in Table 14 in this memorandum, ERG assigned a source flag (A, B, C or D) to all references used in these analyses

, which are defined below. On ly documents prepared by a government agency or for a government agency were used in this analysis.

 Source Flag A

- Journal articles and documents prepared by or for a government agency (e.g., site visit reports, industry meeting notes);

 Source Flag B

- D ocuments prepared by a verified 19 

### source that include citation information (e.g., operator reports, vendor documents, university publications);

 Source Flag C

- Documents prepared by a verified source that do not include citation information (e.g., operator reports, vendor documents, conference presentations); and

 Source Flag D

- Documents prepared by a source that could not be verified and that do not include citation information.

19 ERG considered sources as “verified” if we were able to find information about the author outside of the reference docum ent. ERG primarily verified information by looking for company/organization websites that confirmed the author’s affiliation with the UOG industry.

### Memorandum

March 30, 2015 Page 15

EPA and ERG followed PQAPP procedures for spreadsheets (Section 7.0) and databases (Section 8.0) to generate, evaluate, and analyze data using a spreadsheet and databases . ERG conducted the following QA checks during the analyses:

 

### ERG created the databases and spreadsheet provided in Attachment s 1 , 2, and 3 (DCN SGE00 739 .A01

- 0 3 ) to track useful data and to document analyses.

 

### ERG performed a 100 percent check of data imported into the Development Database and the Analysis Database

.

 

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

 

### E RG performed a 100 percent check of all data analyses and calculations, and documented these checks in internal version s of the spreadsheet and databases

.

 

### An ERG senior staff member familiar with ELGs and the UOG proposed rulemaking reviewed the results fr om each analysis in the spreadsheet and database s.

5.0 R EFERENCES



### Table 14 lists the references that ERG used for the analyses discussed in this memorandum. ERG assigned source flags to each of the sources referenced in this memorandum (see Section 4.0 for definitions of source flags).

Table 14

. References Used for This Memorandum

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

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

. A

SGE00188.A01 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 1: Jan

- Jun 2014 Waste (Unconventional wells)

. A

SGE00188.A02 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 2: Jan

- Dec 2013 Waste (Conventional wells)

. A

SGE00188.A03 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 3: Jan

- Jun 2 013 Waste (Unconventional wells)

. A

SGE00188.A04 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 4: Jul

- Dec 2013 Waste (Unconventional wells)

. A

SGE00188.A05 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 5: Jan

- Dec 2012 Waste (Conventional wells)

. A

SGE00188.A06 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 6: Jan

- Jun 2012 Waste (Unconventional wells)

. A

### Memorandum

March 30, 2015 Page 16

Table 14

. References Used for This Memorandum

DCN Source Citation Source Flag a
SGE00188.A07 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 7: Jul

- Dec 2012 Waste (Un conventional wells)

. A

SGE00188.A08 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 8: Jan

- Dec 2011 Waste (Annual O&G, without Marcellus)

. A

SGE00188.A09 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 9: Jan

- Jun 2011 Waste (Marcellus Only, 6 months)

. A

SGE00188 .A 1 0 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 10: Jul

- Dec 2011 Waste (Marcellus Only, 6 months)

. A

SGE00188 .A 1 1 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 11: Jan

- Dec 20 10 Waste (Annual O&G, without Marcellus)

. A

SGE00188 .A 1 2 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 12: Jul

- Dec 2010 Waste (Marcellus Only, 6 months)

. A

SGE00188 .A 1 3 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 13: Jul 2009

- Jun 2010 Waste (Marcellus Only, 12 months)

. A

SGE00188 .A 1 4 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 14: Jan

- Dec 2009 Waste (Annual O&G, with Marcellus)

. A

SGE00188 .A 1 5 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- At tachment 15: Jan

- Dec 2008 Waste (Annual O&G, with Marcellus)

. A

SGE00188 .A 1 6 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 16: Jan

- Dec 2007 Waste (Annual O&G, with Marcellus)

. A

SGE00188 .A 1 7 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 17: Jan

- Dec 2006 Waste (Annual O&G, with Marcellus)

. A

SGE00188 .A 1 8 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 18: Jan

- Dec 2005 Waste (Annual O&G, with Marcellus)

. A

SGE00188 .A 1 9 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Report ing Period

- Attachment 19: Jan

- Dec 2004 Waste (Annual O&G, with Marcellus)

. A

SGE00188 .A 2 0 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 20: Jan

- Dec 2003 Waste (Annual O&G, with Marcellus)

. A

SGE00188 .A 2 1 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 21: Jan

- Dec 2002 Waste (Annual O&G, with Marcellus)

. A

### Memorandum

March 30, 2015 Page 17

Table 14

. References Used for This Memorandum

DCN Source Citation Source Flag a
SGE00188 .A 2 2 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downloads by Reporting Period

- Attachment 22: Jan

- Dec 2001 Waste (Annual O&G, with Marcellus)

. A

SGE00188 .A 2 3 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide

Data Downl oads by Reporting Period

- Attachment 23: Jan

- Dec 2000 Waste (Annual O&G, with Marcellus)

. A

SGE00596 ERG. 201 5 . Analysis of Centralized Waste Treatment Facilities (CWTs) Accepting

UOG Extraction Wastewater. A

SGE00704 U.S. Environmental Protection Agency (U.S. EPA). 201 5

. Technical Development

Document for Proposed Effluent Limitations Guidelines and Standards for Oil and Gas Extraction . Office of Water Engineering and Analysis Division. A

SGE00724 ERG. 2015. Unconventional Oil and Gas (UOG) Produc ed Water Volumes and

Characterization Data Compilation

. A

SGE00740 ERG. 2015. Unconventional Oil and Gas Drilling Wastewater Memorandum. A
SGE00763 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Oil and

Gas Reporting

– Electronic (OGRE) Public Reporting Data Dictionary, v1.0. (January 15). A

SGE00929 ERG. 2015. Publicly Owned Treatment Works (POTW) Memorandum for the

Technical Development Document

. A

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

Programmatic Quality Assurance Project Plan (PQAPP)

. A

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

Project Plan (SQAPP)

. A

SGE01016 ERG. 2015. Conventional Oil and Gas Memorandum for the Record. A

a

— Source Flag A

- Journal articles and documents prepared by or for a government agency (e.g., site visit reports, industry meeting notes) Source Flag B

- Documents prepared by a verified 20 source that include citation information (e.g., operator reports, ve ndor documents, university publications); Source Flag C

- Documents prepared by a verified source that do not include citation information (e.g., operator reports, vendor documents, conference presentations); and Source Flag D

- Documents prepared by a s ource that could not be verified and that do not include citation information.



### 6.0 A TTACHMENTS

20 ERG considered sources as “verified” if we were able to find information about the author outside of the r eference document. ERG primarily verified information by looking for company/organization websites that confirmed the author’s affiliation with the UOG industry.

### A TTACHMENT 

### 1 : PA DEP W ASTE 

### R EPORTS 

### D EVELOPMENT 

### D ATABASE 

### (DCN SGE00739 .A01 )

### A TTACHMENT 

### 2 : PA DEP W ASTE 

### R EPORT S 

### A NALYSIS 

### D ATABASE 

### (DCN SGE00739 .A02 )

### A TTACHMENT 

### 3 : PA DEP D ATA 

### C ALCULATIONS 

### (DCN SGE00739 .A03 )