MEMORANDUM

TO: Lisa Biddle, EPA

FROM: Brent Ruminski, ERG

James K. O’Connell, ERG

DATE: March 30, 2015

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

Gas Waste Reports (DCN SGE00739)

This memorandum describes how ERG compiled and analyzed information from the 

Pennsylvania Department of Environmental Protection (PA DEP) for 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 of 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 applicable. 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 analyze the PA DEP Waste 

Report 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 attachments 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 

SGE00739.A01)

 Attachment 2 – PA DEP Waste Reports Analysis Database (DCN SGE00739.A02)

 Attachment 3 – PA DEP Data Calculations (DCN SGE00739.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

Memorandum

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 Pennsylvaniaa 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 Treatment Works Memorandum for the Technical 

Development Document – DCN SGE00929 2.2.2.1

COG drilling wastewater 

management practices

Conventional Oil and Gas 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 gas2

produced by wells drilled3into 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 sand6.

 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 defines 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 any 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

 Produced water – the water (brine) brought up from the hydrocarbon-bearing 

strata during the extraction of oil and gas. This can include formation water, 

injection water, and any chemicals added downhole or during the oil/water 

separation process. Based on the stage of completion and production the well is 

in, produced water can be further broken down into the following components:

 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 WASTE REPORT BACKGROUND

PA DEP requires all oil and gas operators to report oil, gas, and waste generation for 

conventional and unconventional oil and gas wells7. For waste generation, operators must report 

waste quantity, waste type, and waste management information for each well they operate in 

Pennsylvania. PA DEP periodically publishes aggregated reports containing this waste data 

henceforth referred to as PA DEP Waste Reports8. The PA DEP Waste Reports only include 

information about wells located within Pennsylvania, but may include information about waste 

generated at a well in PA that is transferred to another state. 

The PA DEP Waste Reports 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 errors, and 

missing information. See Section 2.1.2 for examples of ERG’s consolidations for the parameters 

listed in the waste reports. In general, each record in a waste 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 water9, flowback)

 Waste Management Practice (e.g., POTW10, CWT11 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. Alternatively, 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 period (one for each waste facility).

2.0 METHODOLOGY

ERG used the following three files to compile and analyze PA DEP Waste Reports.

 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 

Database (Analysis Database): This database contains queries that summarize the 

resulting master table (“PA DEP Waste Data”) from the Development Database. 

ERG further analyzed these 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 PA DEP Waste Reports Development Database

ERG created the Development Database in Attachment 1 (DCN SGE00739.A01) as 

described in Sections 2.1.1 and 2.1.2. ERG imported the 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 shows each of the relevant query names in the Development Database along with 

a description of each. The queries perform two primary functions that ultimately create the final 

“PA DEP Waste” 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 the 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 Reports 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 report12

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 1st half of 2010 UOG waste report to the final PA DEP Waste 

Data table

009 - Append Waste 2010-2_UOG

Appends the 2nd 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 1st half of 2011 UOG waste report to the final PA DEP Waste 

Data table

012 - Append Waste 2011-2_UOG

Appends the 2nd half of 2011 UOG waste report to the final PA DEP 

Waste Data table

013- Append Waste 2012-1_UOG13

Appends the 1st half of 2012 UOG waste report to the final PA DEP Waste 

Data table

014 - Append Waste 2012-2_UOG

Appends the 2nd 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 1st half of 2013 UOG waste report to the final PA DEP Waste 

Data table

017 - Append Waste 2013-2_UOG

Appends the 2nd half of 2013 UOG waste report to the final PA DEP 

Waste Data table

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 Reports 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

Changes “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 name, 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 created two consolidation crosswalk tables to standardize reported data so the data 

could be more easily summarized. As previously described, the PA DEP Waste Reports 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 complete 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 Fluid Bbl Drilling Wastewater

Drilling Fluid Waste Bbl

Flow-Back Fluid Bbl

Fracking Fluid Waste Bbl Flowback

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 within the “Facility Type Consolidation” crosswalk in 

Attachment 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 Facility14

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 oil and gas operators in the PA DEP Waste Reports. The full crosswalk is contained 

in Attachment 1 (DCN SGE00739.A01) and is titled “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 Reports Analysis Database and Spreadsheet

The 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 the results 

from these queries into the PA DEP Data Calculations Microsoft Excel 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 

SGE00739.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 queries 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). The 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 the two pie charts that make up TDD Figure C1, which are in the “Breakdown of Marcellus Vert” and “Breakdown of Marcellus Horiz” tabs in 

Attachment 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 Reports 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). Well 

trajectory ais also included for each well permit number.

41 – UOG Extraction 

Wastewater Breakdown

This query summarizes the results from query 40 using the following calculations:

 Sum the volumes of each category of wastewater for each well trajectory

(i.e., horizontal, vertical)

 Count the number of well permit numbers (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 queries 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 into the “UOG Drill WW Mgmt Data” and “UOG PW Mgmt Data” tabs of 

Attachment 3 (DCN SGE00739.A03). In these tabs, 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” tabs of Attachment 3 (DCN SGE00739.A03). ERG excluded data for 2004

through 2007 in these graphs because there was minimal UOG extraction wastewater reported 

during these years. UOG produced water management data (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 Reports 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 to create TDD Table C-4, and the results are also presented 

in ERG’s Unconventional Oil and Gas Drilling Wastewater Memorandum (DCN SGE00740). 

ERG summed drilling fluid volumes for all wells in the PA DEP Waste Reports using query 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 10th

percentile, median, average, and 90th 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 10th percentile and 90th percentile as 

opposed to minimum and maximum to remove outlying data points. 

Table 9. PA DEP Waste Reports 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 trajectoryaand resource type (conventional, 

unconventional)

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

2.2.2 Analyses Supporting Additional Memoranda

The following describes how ERG created various data tables used to create figures and 

tables in other supporting memoranda. Each subsection describes the associated 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 Works (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 created several 

figures in Chapter D of the TDD using these data, including Figures D-10 through D-15.

Table 10. PA DEP Waste Reports Analysis Database 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 UOG) 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 20 and 21, 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 (2004 – 2013)

ERG analyzed PA DEP’s Waste Reports to support ERG’s Conventional Oil and Gas 

Memorandum for the Record (DCN SGE01016) and Unconventional Oil and Gas Drilling 

Wastewater Memorandum (DCN SGE00740). Using queries 50 and 51 (see Table 11) in 

Attachment 2 (DCN SGE00739.A02), ERG summarized statewide management practices of 

COG extraction wastewater generated each year. ERG copied the results of these queries into the 

“COG Drill WW Mgmt Data” and “COG PW Mgmt Data” tabs of Attachment 3 (DCN 

SGE00739.A03). In these tabs, ERG converted annual volumes into percentages of the total 

extraction wastewater volume for each year. Subsequently, ERG plotted these percentages in the 

“COG Drill WW Mgmt Graph” and “COG PW Mgmt Graph” tabs.

Table 11. PA DEP Waste Reports 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 UOG Long-term Produced Water Rates in Pennsylvania

ERG estimated 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 

queries 60 and 61 (see Table 12) in Attachment 2 (DCN SGE00739.A02), ERG summed all 

produced water volumes over time by well trajectory15, production year, and spud year. Although 

all produced water (i.e., flowback and long-term produced water) is included in queries 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 well configuration in the PA DEP data.
Memorandum

March 30, 2015

Page 12

ERG copied the results of query 61 into 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 water volumes in the aforementioned supporting memorandum (DCN SGE00724).

Table 12. PA DEP Waste Reports 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 produced water volume over time by production year, well 

trajectorya, and spud year combination

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

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

3.0 DATABASE DICTIONARY

Table 13 provides descriptions of the data fields in the “PA DEP Waste Report” table 

included in both of the databases ERG created for this analysis (i.e., Development Database, 

DCN SGE00739.A01; Analysis 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.The consolidated field names that ERG 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 drilled 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 well operator. Name usually corresponds 

with the landowner at the time of permitting, which does not change. The 

Farm Name and Well # normally produce a unique identifier for the well.

Well # PA DEP

The number of the well being reported that was assigned by the well 

operator. Usually follows the Farm 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 indicates whether the production and waste amounts were 

averaged (Y) or not (N). If Y, they were averaged based on the well being 

reported as part of a group of wells.

Operator Name PA DEP

The organizational name of the well operator 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 control.

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 formation17.

Well 

Configuration18

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 wells 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 state in which the Waste Facility is located.

Facility Zip 

Code PA DEP The zip code of the Waste Facility.

Facility Phone PA DEP The phone number 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 Sandstone 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 multilateral 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 QUALITY CONTROL PROCEDURES

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 SGE00958), 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 gas 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. Only 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 - Documents prepared by a verified19 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 

document. 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 Attachments 1, 2, and 3

(DCN SGE00739.A01-03) 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.

 ERG performed a 100 percent check of all data analyses and calculations, and 

documented these checks in internal versions of the spreadsheet and databases.

 An ERG senior staff member familiar with ELGs and the UOG proposed 

rulemaking reviewed the results from each analysis in the spreadsheet and 

databases.

5.0 REFERENCES

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 

Flaga

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 2013 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 

Flaga

SGE00188.A07 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide 

Data Downloads by Reporting Period - Attachment 7: Jul-Dec 2012 Waste 

(Unconventional 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.A10 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.A11 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide 

Data Downloads by Reporting Period - Attachment 11: Jan-Dec 2010 Waste 

(Annual O&G, without Marcellus).

A

SGE00188.A12 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.A13 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.A14 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.A15 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide 

Data Downloads by Reporting Period - Attachment 15: Jan-Dec 2008 Waste 

(Annual O&G, with Marcellus).

A

SGE00188.A16 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.A17 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.A18 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.A19 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide 

Data Downloads by Reporting Period - Attachment 19: Jan-Dec 2004 Waste 

(Annual O&G, with Marcellus).

A

SGE00188.A20 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.A21 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 

Flaga

SGE00188.A22 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.A23 Pennsylvania Department of Environmental Protection (PA DEP). 2014. Statewide 

Data Downloads by Reporting Period - Attachment 23: Jan-Dec 2000 Waste 

(Annual O&G, with Marcellus).

A

SGE00596 ERG. 2015. Analysis of Centralized Waste Treatment Facilities (CWTs) Accepting 

UOG Extraction Wastewater.

A

SGE00704 U.S. Environmental Protection Agency (U.S. EPA). 2015. 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) Produced 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 verified20 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.

6.0 ATTACHMENTS

 

20 ERG considered sources as “verified” if we were able to find information about the author outside of the reference 

document. ERG primarily verified information by looking for company/organization websites that confirmed the 

author’s affiliation with the UOG industry.
ATTACHMENT 1: PA DEP WASTE REPORTS DEVELOPMENT DATABASE (DCN SGE00739.A01)
ATTACHMENT 2: PA DEP WASTE REPORTS ANALYSIS DATABASE (DCN SGE00739.A02)
ATTACHMENT 3: PA DEP DATA CALCULATIONS (DCN SGE00739.A03)