### MEMORANDUM

TO: Lisa Biddle, U.S. EPA

Karen Milam, U.S. EPA

FROM: Sarah Yates, ERG

James K. O’Connell, ERG

DATE: June 7 , 2016

SUBJECT: Publicly Owned Treatment Works ( POTW) Memorandum for the Technical

Development Document (TDD) (DCN SGE0 1183 )

This memorandum describes data and methods that ERG used to compile information on publicly owned treatment works (POTWs) for the Technical Development Document for Effluent Limitations Guidelines and Standards for Oil and Gas Extraction (TDD) (DCN SGE0 1188 )

. Specifically, t his memorandum focuses on the tables and figures included in Chapter D.5 of the TDD

, as listed in Table 1

. TDD Tables and figures that are not listed in Table 1 either did not require calculations and/or analyses by ERG or are described in separate, supporting memoranda. The Crosswalk Memorandum between Proposed and Final Technical Development Document for Effluent Limitations Guidelines and Standards for Oil and Gas Extraction: Tables and Figures (DCN SGE01334) contains a crosswalk of all ta bles and figures in the TDD. Appendix F of the TDD contains the name of the relevant supporting memorandum for each TDD table and figure , where applicable. This memoran dum is organized into the following sections:

 Section 1.0 History of POTW Acceptance of UOG Extraction Wastewater (TDD Section D.5.2)

 Section 2.0 UOG Extraction Wastewater Constituents Discharged Untreated from POTWs (TDD Section D.5.3.1 ) and UOG Extractio n Wastewater Constituents and POTW Inhibition and Disruption (TDD Section D.5.3.2)

 Section 3.0 describes ERG’s quality assurance procedures.

 Section 4.0 lists the references used for these analyses

For those figures/tables ERG generated specifically for t his memorandum, the underlying data and analysis are contained in:

 Attachment 1

– POTW s D ata for TDD (DCN SGE01183.A01)

For the tables/figures explained in more detail in this memorandum

, Table 1 provides the TDD chapter , memorandum section, and attachment information.Memorandum

June 7 , 2016 Page 2

Table 1 . Overview of Information Covered in This Memorandum

TDD Figure/Table N umber TDD Figure/Table Name Relevant TDD Chapter Relevant

Memo Section Relevant Tab Name(s)

Within Attachment 1 (DCN SGE 01183 .A 0 1) Table D

- 10 POTWs That Accepted UOG Extraction

Wastewater from Onshore UOG Operators D.5.2 1.1 POTWs Accepting UOG WW

Table D

- 11 Percentage of Total POTW Influent

Wastewater Comp o sed of UOG Extraction Wastew ater at POTWs Accepting Wastewater from UOG Operators D.5.2 1.2 Percent of Influent; POTWs by Resource & Waste Type; DMR LT Data

Figure D

- 13 Clairton POTW : Tec hnical Evaluation

of Treatment Processes ’ Ability to Remove Chlorides and TDS D.5.3.1 2.1 Clairton Data; Clairton Figure

Figure D

- 14 McKeesport POTW : Technical

Evaluation of Treatment Processes ’ Ability to Remove Chlorides and TDS D.5.3.1 2.1 McKeesport Data; McKeesport Figure

Figure D

- 15 Ridgway POTW : Annual Average Daily

Effluent Concentrations and POTW Flows D.5.3. 1 2.2 Ridgway Summary of Data; Ridgway Figure

Figure D

- 16 Johnstown POTW : Annual Average

Daily Effluent Concentrations and POTW Flows D.5.3.2 2.2 Johnstown Summary of Data; Johnstown Figure

Figure D

- 17 California POTW : Annual Average

Daily Effluent Concentrations and POTW Flows D.5.3.2 2.2 California Summary of Data; California Figure

Figure D

- 18 Charleroi POTW : Annual Average Daily

Effluent Concentrations and POTW Flows D.5.3.2 2.2 Charleroi Summary of Data; Charleroi Figure

[No Figure or Table] Wheeling POTW Data Discussion a D.5.3.1; D.5.3.2 2.3 Wheeling Summary of

Data

a

– Wheeling POTW data are not presented in a figure or table, however t his discussion describes the data from Attachment 1 that are included in the text about the Wheeling POTW in S ection s D.5.3.1 and D.5.3.2 of the TDD

. For definitions of common terms used throughout the TDD, the supporting memoranda, and memoranda attachments, please refer to the Glossary in the introduction of the TDD.

1.0 TDD S ECTION D.5.2, H ISTORY OF POTW A CCEPTANCE OF UOG E XTRACTION

W ASTEWATER
ERG compiled data on POTWs in Pennsylvania

, New York , and West Virginia 1 that accepted UOG extraction wastewater , including the year that each POTW st opped accepting UOG extraction wastewater and the year that each POTW accepted its maximum amount of UOG extraction wastewater , where the data were available

.

1 ERG studied data from the PA DEP Waste Reports (DCN SGE0 1245 ) among other sources. These reports compile data from oil and gas operators in Pennsylvania. These operators discharge their extraction wastewater to v arious facilities in Pennsylvania, New York, and West Virginia. The other data sources that ERG analyzed and that are listed in Section 1.1 did not include informa tion about POTWs accepting UOG extraction wastewater in any other, additional states.Memorandum

June 7 , 2016 Page 3

1.1 POTWs That Accepted UOG Extraction Wastewater from Onshore UOG

Operators (Table D

- 10)

TDD Table D

- 10 lists POTWs in Pennsylvania

, New York , and West Virginia that, at one point in time, accepted UOG extraction wastewater

. All of the POTWs listed in Table D

- 10 accepted UOG extraction wastewater directly from operators. None of the POTWs listed in Table D

- 10 currently accept UOG extraction wastewater , and the year in which each POTW stopped accepting UOG extraction wastewater is shown in the table

.
ERG review ed and analyzed the following sources to determine which POTWs to include in Table D

- 10 :

 Notes from calls with Regional and State pretreatment program coordinators (DCN SGE00742, DCN SGE00743)

.

 Notes from EPA

- State implementation pilot project with the Environmental Council of the States (ECOS) in coordination with the Association of Clean Wat er Administrators (ACWA ) ( DCN S GE00762)

.

 EPA Region 3’s website ( DCN S GE 00368 )

.

 Site visits, conference calls, and meetings w ith industry representatives ( DCN S GE00613; DCN S GE00521), UOG operators ( DCN S GE00625; DCN S GE00635; DCN S GE00275; DCN S GE00280), centralized waste treatment ( CWT ) facilities ( DCN S GE00299; DCN S GE00300; DCN S GE00245; DCN S GE00244), and Native American tribal groups ( DCN S GE0 0785 ).

 Pennsylvania Department of Environmental Protection’s ( PA DEP ) statewide waste report data 2 ( DCN S GE0 12 45 ; DCN S GE0 1182 )

.

 U.S. Department of Energy’s ( DOE ) 2010 “Water Management Technologies Used by Marcellus Shale Gas Producers” repo rt ( DCN S G E00011 )

.

 Publicly available data sources identified through Internet searches

.
ERG compiled data related to POTWs accepting UOG extraction wastewater from all of these sources in the “POTWs Accepting UOG WW” tab in Attachment 1 (DCN SGE 01183 .A 0 1). ERG captured the following types of information about these POTWs:

 Location (e.g., city);

 NPDES permit number;

 Type of oil and gas wastewater accepted ( i.e

., UOG; conventional oil and gas, COG ) 3 ;

 Source of oil and gas wastewater (e.g., UOG operator

, CWT );

 Dates POTW began accepting and stopped accepting oil and gas wastewater; and

 Volumes of oil and gas wa stewater accepted.

2 PA DEP’s was te report data provides wastewater volumes by well over time and disposal information as it was reported by the oil and gas well operator to PA DEP. ERG’s m emorandum titled “Analysis of Pennsylvania Department of Environmental Protection’s (PA DEP) Oil and Gas Waste Reports” provides more detail (DCN SGE0 1182 ).

3 The PA DEP Waste Reports (DCN SGE0 1245 ) consider wastewater from coal

- bed methane (CBM) productio n as a portion of COG wastewater, not UOG wastewater. Therefore, any wastewater produced from CBM operations is included in the COG wastewater data.Memorandum

June 7 , 2016 Page 4

During this data review, ERG did not identify any POTWs that were still accepting UOG extraction wastewater. ERG included a POTW in Table D

- 10 if the following criteria were met:

 POTW accepted UOG extraction wastewater directly from an onshore UOG operator (i.e., not exclusively from a CWT facility); and

 POTW is not currently accepting UOG extraction wastewater and existing literature provided a date when the POTW stopped accepting UOG extraction wastewater 4

. The “POTWs Accepting UOG WW” tab in Attachment 1 (DCN SGE 01183 .A 0 1) shows all POTWs for which ERG collected data, including those not include d in Table D

- 10 and those that were found to have never accepted UOG extraction wastewater (i.e., only accepted conventional oil and gas ( COG ) extraction wastewater 3 )

.
1.2 Percent age of Total POTW Influent Wastewater Compo sed of UOG Extraction

Wastew ater at POTWs Accepting Wastewater from UOG Operators (Table D

- 11)

TDD Table D

- 11 shows data related to the maximum amount of UOG extraction
wastewater that was accepted as influent at each POTW. For each POTW, Table D

- 11 shows the maximum annual average daily UOG extraction wastewater percent of POTW influent and the corresponding year when this maximum occurred

. The “Percent of Influent” tab in Attachment 1 (DCN SGE 01183 .A 0 1) shows the underlying data and analyses that ERG performed to create Table D

- 11.

ERG provides the data from PA DEP statewide waste reports (DCN SGE0 1182 ) in the

“ POTWs by Resource & Waste Type ” tab in Attachment 1 (DCN SGE 01183 .A 0 1). ERG collected data from the PA DEP waste reports for years 2004 through 201 4

, with the except ion of 2007 , when no data were available from the PA DEP. PA DEP’s waste report data provides UOG wastewater volumes by well over time and disposition information as it was reported by th e oil and gas operator of the well to PA DEP. ERG ’s Analysis of Pennsylvania Department of Environmental Protection’s (PA DEP) Oil and Gas Waste Reports memorandum provides more detail about the PA DEP waste report data ( DCN SGE0 1182 ).

ERG provides the discharge monitoring report ( DMR ) d ata from the DMR Pollutant Loading Tool (DMR LT)

, available online at http://cfpub.epa.gov/dmr (DCN SGE00608)

, in the

“ DMR LT Data ” tab in Attachment 1 (DCN SGE 01183 .A 0 1)

. The DMR LT provides average total influent wastew ater at each POTW and indicates exceedances experienced at each POTW.

ERG used the following data source s to obtain the data needed to complete this analysis:

4 ERG sometimes found documentation of the exact date or the month/year in which the POTW stopped accepting UOG extraction wastewater. Other times, the existing literature only reported the year in which the POTW stopped accepting UOG extraction wastewater. Occasionally, the date in which the POTW stopped accepting UOG extraction wastewater was not available at all in the existing literature; this data was excluded from Table D

- 10 because the analysis being performed required comparing data for periods before and after the POTW stopped accepting UOG extraction wastewater. Even though a date was not available for when some facilities stopped accepting UOG extraction wastewater, ERG was able to verify that those facilities were no longer accepting UOG extraction wastewater as of 2014.Memorandum

June 7 , 2016 Page 5

 PA DEP Waste Reports: Maximum Annual Average UOG Wastewater Volume

( barrels ( bbl) ) , presented in TDD Table D

- 11 as the Maximum Annual Average Daily UOG Extraction W astewater Volume Accepted (gpd) 5 ERG totaled the extraction wastewater volumes for conventional oil and gas ( COG ) and UOG reported in the PA DEP waste reports . For each individual POTW, ERG summed the drilling wastewater, flowback, and long

- term produced water volumes (shown in the “POTWs by Resource & Waste Type” tab in Attachment 1) and reported total COG and UOG extraction wastewater volumes (shown in the “ POTWs Accepting UOG WW ” tab in A ttachment 1)

. Though ERG reported total COG and UOG extraction wastewater volumes, for purposes of Table D

- 11 of the TDD

, ERG only presents the UOG extraction wastewater volumes. ERG presents the volume data for the year with the maximum total UOG extractio n wastewater volume in the “Maximum Annual Average UOG WW Volume (barrels)” column on the “ Percent of Influent ” tab in Attachment 1.

 DMR Pollutant Loading Tool: Actual Average Annual POTW Inflow ( million gallons per day ( MGD) ) , presented in TDD Table D

- 11 as the Corresponding Total Annual Average Daily Influent Flow to POTW (MGD) Where the DMR LT data included multiple values for a POTW’s annual wastewater flow 6 (“Average Daily Flow (MGD)” column on the “DMR LT Data” tab in Attachment 1)

, ERG averaged the reported values for the corresponding year in which the maximum UOG extraction wastewater percent of POTW influent occurred to get an actual average annual POTW inflow value (MGD)

.

 Other: Average POTW Inflow (MGD)

, presented in TDD Table D

- 11 as the Corres ponding Total Annual Average Daily Influent Flow to POTW (MGD) The DMR LT did not have “ Average Daily Flow ” data for all POTWs of interest. Therefore, ERG found average POTW inflow values for three facilities (Belle Vernon, Waynesburg, and Reynoldsville) u sing documents and reports prepared by those individual POTWs. DCNs for these sources can be found in the “ Source_Actual Averages (MGD) ” column of the “Percent of Influent” tab in Attachment 1 (DCNSGE 01183 .A 0 1).

ERG calcu lated the percentage of the POTW ’s i nfluent that was made up of UOG extraction wastewater by dividing the maximum annual average UOG wastewater volume (bbl) into the actual average annual POTW inflow (MGD) , and converting units, as shown in Equation 1

. ERG reported the results in Table D

- 1 1.

Equation 1

5 ERG converted the data in Attachment 1 from barrels (bbl/year) to gallons per d ay (gpd) for the TDD by multiplying by 42 gal/bbl and dividing by 365 days/year.

6 The DMR LT data would include multiple values for a POTW’s annual wastewater flow if the POTW submitted sampling data for multiple parameters and/or multiple sampling locations. Max. Annual Average UOG Extraction WW % of POTW InfluentMemorandum

June 7 , 2016 Page 6

= [ Max Annual Avg UOG WW Vol ( bbl ) year ∗ 42 gal bbl ∗ 1 year 365 days

Actual Avg Annual POTW Inflow ( Mgal day )
∗ 1
, 000
, 000 gal

Mgal ]

∗ 100

2.0 TDD S ECTION D.5.3.1, UOG E XTRACTION W ASTEWATER C ONSTITUENTS

D ISCHARGED U NTREATED FROM POTW S AND TDD S ECTION D.5.3.2, UOG E XTRACTION W ASTEWATER C ONSTITUENTS AND POTW I NHIBITION AND D ISRUPTION
ERG analyzed effluent data from several POTWs in Pennsylvania , West Virginia, and Ohio to investigate possible effects of accepting UOG extraction wastewater pollutants on the POTWs’ treatment processes and discharges

. The following subsections describe the tables and figures that ERG ge nerated in TDD Section D.5.3.1 about constituents that may be discharged untreated from POTWs and in TDD Section D.5.3.2 about constituents that could cause inhibition and disruption at the POTW.

2.1 Technical Evaluation of Ability of Treatment Processes to Remove Chlorides and

TDS ( Figure D

- 13 , Figure D

- 14 )

Figures D

- 13 and D

- 14 of the TDD refer to the Clairton and McKeesport POTWs, respectively. These figures show the measured concentrations of chloride (Cl

- ) and total dissolved solids (TDS) at various stag es in the POTWs’ treatment processes. ERG used this information to support its evaluation of the ability of treatment processes to remove Cl

and TDS at these POTWs

. In 2008, PA DEP issued an Administrative Order (AO) to the Clairton and McKeesport POTWs that restricted their acceptance of oil and gas wastewater to amounts no greater than 1% of their average daily flow, among other requirements. These AOs also required each POTW to evaluate the potential effects of oil and gas production wastewater on its treatment processes (DCN SGE00758 ; DCN SGE00757)

. These evaluations included sampling during various stages of treatment at each POTW. The data from these evaluations are the basis for Figures D

- 1 3 and D

- 1 4

. At the time of the sampling at t he Clairton POT W

, the plant use d the following treatment processes: screening and grit removal, comminutor (i.e., grinder) 7

, aeration basins, clarifiers, activated sludge, aerobic digestion, and chlorine disinfection (DCN SGE00758 ). To evaluate the ability of the treatme nt processes to remove TDS and Cl

- , the POTW took samples at six points throughout the treatment facility after major treatment processes: grit removal and screening,
pre

- aeration tanks, settling tanks, activated sludge, final settling tanks, and chlorine disinfection (DCN SGE00758 ). T he data for the Clairton POTW are the average of five 24

- hour composite samples taken from December 8, 2008 through December 12, 2008 by the Clairton Municipal Authority (CMA).

At the time of the sampling at t he McKeesport POTW

, the plant use d the following treatment processes: screening and grit removal, aeration, clarification, activated sludge

, aerobic

7 A comminutor is a machine that reduces the particle size of wastewater solids using a cutting device.Memorandum

June 7 , 2016 Page 7

digestion, and chlorine disinfection ( DCN SGE00745 )

. The detention time at the McKeesport POTW was likely between 8 and 1 2 hours at the time of sampling ( DCN SGE01090 ). To evaluate the ability of the treatment processes to remove TDS and Cl

- , the POTW took samples at five points throughout the treatment facility: inflow, grit chamber, holding tank, primary clarifier effluent , and outflow. ERG did not include data from the holding tank samples in its analysis because McKeesport did not report results for every sampling date (DCN SGE00757)

. The data for the McKeesport POTW are the average of seven 24

- hour composite samples take n from November 1, 2008 through November 7, 2008 by the Municipal Authority of the City of McKeesport (MACM).

The “Clairton Data” and “McKeesport Data” tabs in Attachment 1 (DCN SGE 01183 .A 0 1) of this memorandum show the raw data for Figure s D

- 1 3 and D

- 1 4 8 . Because sampling at each POTW was done at several points during the treatment process, th e data are organized by the location of the sample. ERG created a box plot for each stage of treatment to present the concentration data for Cl

and TDS at each of t hese POTWs (shown in the “Clairton Figure” and “McKeesport Figure” tabs) . Figures D

- 1 3 and D

- 1 4 present the maximum, minimum, and average concentrations of Cl

and TDS after each treatment step

.
2.2 Annual Average Daily Effluent Concentrations and POTW Flows (Figure D

- 15 ,

Figure D

- 16 , Figure D

- 17 , Figure D

- 18 )

T he following four POTWs are discussed in this section :

 Ridgway POTW (Figure D

- 15 );

 Johnstown POTW (Fig ure D

- 16 );

 California POTW (Fig ure D

- 17 ) ; and

 Charleroi POTW (Fig ure D

- 18 ).

In each of the four figures presented in the TDD (i.e., Figure D

- 15 through Figure D

- 18 )

, ERG plots pollutant concentration and wastewater flow over the course of several years. The y

axis (left

- side ) shows effluent pollutant concentrations (mg/L)

. The val ues are plotted as points, connected by lines. Each POTW is required to monitor a suite of parameters as defined in their individual NPDES permits. This monitoring data is reported on the POTW’s discharge monitoring report ( DMR )

. ERG could only present pol lutant concentrations where data w ere available, so the parameters displayed in each figure were chosen based on availability and relevance to UOG wastewater (based on the UOG extraction wastewater characterization data in Section C.3 in the TDD )

. The y

- axis (right

- side) shows the annual average wastewater influent flow from oil and gas operators to each POTW. These values are represented as bars, and UOG and COG wastewater flows are presented separately as stacked bars

. ERG also labeled the figures with the number of permit limit exceedances and the years the POTWs accepted UOG extraction wastewater , where relevant

. Attachment 1 (DCN SGE 01183 .A 0 1) contains two worksheets for each of the four POTWs introduced at the beginning of Section 2.2 in this memorandum. The first worksheet is

8 Limited information was provided in the reports regarding analytical methods associated with the raw data. The Clairton POTW indicated “pollutants will be analyzed by test procedures under 40 CFR 136.” The McKeesport POTW noted that “testing was done using EPA approved methods.”Memorandum

June 7 , 2016 Page 8

the data summary for each POTW (e.g., “California Summary of Data”) and includes the PA DEP Waste Reports data, DMR LT data, and E RG’s calculations. The data summary worksheets each have information for 2008 through 201 4 9 and indicate which source ERG used to obtain each piece of data. The second worksheet is the relevant figure for the TDD (e.g., “California Figure”).

ERG developed these figures using data obtained from the DMR Pollutant Loading Tool

, available online at http://cfpub.epa.gov/dmr (DCN SGE00 608 )

, and data from the PA DEP statewide waste reports (DCN SGE0 1182 ; DCN SGE0 1245 ). ERG presents the relevant pollutant concentration a nd exceedance counts from the DMR Pollutant Loading Tool in the “DMR LT Data” and “Exceedances” tab s , respectively, in Attachment 1 (DCN SGE 01183 .A 0 1 ) as well as data for individual facilities in the facilities summary tabs (e.g., “Californi a Summary of Data”). ERG presents the relevant PA DEP waste report data in the “ POTWs by Resource & Waste Type ” tab in Attachment 1 (DCN SGE 01183 .A 0 1 ). ERG used the following data from these sources to complete this analysis:

 DMR Pollutant Loading Tool: Ac tual average annual POTW inflow (1,000 gpd), pollutant concentrations, and e xceedance counts ERG averaged the reported values for each POTW’s wastewater flow (“ Average Daily Flow (MGD) ” column on the “DMR LT Data” tab in Attachment 1) and multiplied the value by 1,000 to convert the units from MGD to “1,000 gpd”.

ERG pulled the average concentrations for a given pollutant in a given year from the DMR LT data (“Average Concentration (mg/L)” column on the “DMR LT Data” tab in Attachment 1).

ERG found e xceedance data using the “Everyday Searches

– Facility Exceedance Counts” search function in the DMR LT and searched for each facility permit. E xceedance data are shown in the “Exceedances” tab in Attachment 1. ERG presents exceedances by f

acility, year, and parameter

.

 PA DEP Waste Reports : Annual total COG and UOG extraction wastewater volumes for each POTW (MG) For each individual POTW, ERG summed the drilling wastewater, flowback, and long

- term produced water volumes and reported total C OG and UOG extraction wastewater volumes. The total waste volumes by resource type are presented on the “POTWs Accepting UOG WW” tab in Attachment 1. ERG presents the un

aggregated values for each year (200 4

- 2006, 2008

- 201 4 ) and for each waste type on the “POTWs by Resource & Waste Type” tab in Attachment 1

.

2.3 Wheeling POTW Data
Data for the Wheeling POTW is included on the “ Wheeling Summary of Data” tab in Attachment 1 (DCN SGE 01183 .A 0 1). ERG did not present these data as a figure for the TDD because PA DEP data for transfers of UOG wastewater to this POTW were only available for
one year. It is u nknown if UOG extraction wastewater from other states ( e.g., W est V irginia ) was

9 ERG was unable to find 2012 and 2013 DMR data for the Charleroi POTW.Memorandum

June 7 , 2016 Page 9

treated at the Wheeling POTW. Also, the reported UOG extraction wastewater vol ume makes up a small percent of the total flow to the Wheeling POTW

. Concentration and wastewater flow data are used anecdotally in Sections D.5.3.1.2 and D.5.3.2.2 and are presented in the “ Wheeling Summary of Data” tab in Attachment 1 along with an indic ation of which source ERG used to obtain each piece of data

.
3.0 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 existing data and information about POTWs

. Specifically, ERG used the p rocedures described in Section 4 of the PQAPP to gather and manage existing data in support of the UOG rulemaking. ERG staff entered reference information for relevant sources into the UOG Literature Review database. The ERG index keeper reviewed all refer ence information, assigned each reference a Document Control Number (DCN ), imported the reference information into the UOG Project File Index database, and saved referenced files in the Electronic Project File folder.

ERG also used the procedures described in Section 3 of the SQAPP when collecting existing data for use in the UOG rulemaking. ERG used a combination of sources, including reports, papers, and online databases from state regulatory agencies such as departments of environmental protection and oi l and gas commissions. As shown in Table 2 in this memorandum, ERG assigned a source flag (A, B, C or D) to all references used in these analyses which are defined below.

 Source Flag A

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

 Source Flag B

- Documents prepared by a verified 10 source that include citation information (e.g., operator reports, vendor documents, university publications);

 Source Flag C

- Doc uments 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 citat ion information.

EPA and ERG followed the procedures described in Section 7.0 of the PQAPP to generate, evaluate, and analyze data using a spreadsheet. ERG conducted the following QA checks during the analyses:

 ERG created the POTWs Data for TDD spreadsh eet provided in Attachment 1 (DCN SGE 01183 .A 0 1) to track useful data and to document analyses.

10 ERG considered sources as “verified” if we were able to find infor mation 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

June 7 , 2016 Page 10

 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 in internal ve rsion s of the spreadsheet.

 An ERG senior staff member familiar with ELGs and the UOG rulemaking review ed the results from each analysis in the one spreadsheet.

4.0 R EFERENCES

Table 2 provides all of the references that ERG used for the analys e s discussed in this memorandum and their assigned source flags (see Section 3.0 for a discussion of source flags)

.

Table 2

. References Used for This Memorandum

DCN Source Citation Source Flag a
SGE00011 Veil, John A. 2010. Water Mgmt Technologies Used by Marcellus Shale Gas

Producers. Prepared by Argonne National Lab. Prepared for U.S. DOE NETL. A

SGE00244 ERG. 2012. Camp, Meghan; Bicknell, Betsy; Ruminski, Brent. Notes on

Conference Call with 212 Resources on 4 January 2012. (January 9) A

SGE00245 ERG. 2012. Camp, Meghan et. al. Notes on Conference Call with Reserved

Environmental Services, LLC on 5 Januar y 2012. (February 1) A

SGE00275 U.S. EPA. 2012. Site Visit Report: Citrus Energy Corporation Marcellus

Shale Gas Operations. (January 22). A

SGE00280 U.S. EPA. 2013. Site Visit Report: Anadarko Petroleum Corporation

Marcellus Shale Gas Operations. (January 9). A

SGE00286 Hammer, R. et. al. 2012. In Fracking’s Wake: New Rules Are Needed to

Protect Our Health and Environment from Contaminated Wastewater. NRDC D:12

- 05

- A A

SGE00299 U.S. EPA. 2012. Site Visit Report: US Gas Field Fluids Management

(for merly Clean Streams) Marcellus Shale Gas Operations. (October 9). A

SGE00300 U.S. EPA. 2012. Site Visit Report: Eureka Resources, LLC Marcellus Shale

Gas Operations. (February 25). A

SGE00368 U.S. EPA. 2012. (Region 3). Key Documents About Mid

- Atlantic Oil and

Gas Extraction. (November 26). A

SGE00368.A01 U.S. EPA. 2013. Key Documents About Mid

- Atlantic Oil and Gas Extraction.

(January 9) A

SGE00493 Allegheny Valley Joint Sewage Authority. 2011. Letter to PA DEP (Permit

ID: PA0026255). (March 29). A

SGE00494 Allegheny Valley Joint Sewage Authority. 2011. Letter to U.S. EPA Region

3. (October 3). A

SGE00495 Altoona Water Authority. 2011. Letter to PA DEP (Permit ID: PA0027014).

(April 6). A

SGE00506 Bissell, Alex. Unknown. Wastewater Wasteland: An Investigation of

Flowback Fluid Disposal in NY. Neighbors of the Onondaga Nation. B

SGE00514 Clairton Municipal Authority. 2011. Letter to U.S. EPA Region 3. (September

30). AMemorandum

June 7 , 2016 Page 11

Table 2

. References Used for This Memorandum

DCN Source Citation Source Flag a
SGE00515 Clean Water Action (CWA). 2012. Groups Reach Settlement with

McKeesport in Gas Drilling Wastewater Dumping Case. (May 1). C

SGE00521 ERG. 2012. Camp, Meghan; Ruminski, Brent. Notes for Shale Gas Industry

Meeting Held on 29 February 2012. (April 20). A

SGE00522 Env Review Appeals Comm, State of OH. 2012. Patriot Water Treatment and

City of Warren v Chris Korleski and Scott Nally: 2012 Decision. A

SGE00538 Johnstown Redevelopment Authority. 2011. Letter to U.S. EPA Region 3.

(September 30). A

SGE00539 Johnstown Redevelopment Authority. 2012. Letter to U.S. EPA Region 3.

(December 19). A

SGE00540 Kiski Valley Water Pollution Control Authority. 2011. Letter to McCutcheon

Enterprises, Inc. (April 21). A

SGE00543 Macormac, Zach. 2011. Wheeling Fined for Taking Fra ck Water. The

Intelligencer/Wheeling News

- Register. (October 15). D

SGE00548 McCauley, Erin. 2011. Environmentalists Say Oil

- Drilling Sewage is

Polluting Pittsburgh's Drinking Water. (July 21). Courthouse News Service. D

SGE00568 PA DEP. 2010. Oil & Gas Facility Summary. (August 26). A
SGE00572 PA DEP. 2012. Return of NPDES Application No. PA0026310 A

- 2

(Clearfield Municipal Authority WWTP). (March 30). A

SGE00576 Pittsburgh Business Times. 2008. Oil, Gas Wells Face Waste Hurdle: Sewage

Plants Ordered by DEP to Curb Processing Wastewater from Drilling. D

SGE00582 Reuther, Mike. 2013. Gas wastewater treatment facility to begin operations.

(August 21). D

SGE00608 U.S. EPA. 2012. Discharge Monitoring Report (DMR) Pollutant Loading

Tool. Downloaded on 1/2 8/2013. Available online at: http://cfpub.epa.gov/dmr/ A

SGE00613 U.S. EPA. 2013. Meeting Summary: Meeting with Industry Representatives

About the Unconventional Oil and Gas Effluent Guideline Rulemaking. A

SGE00625 U.S. EPA. 2015. Site Visit Report: Southwestern Energy Fayetteville Shale

Gas Operations. Sanitized. A

SGE00635 U.S. EPA. 2012. Site Visit Report Chesapeake Energy Corporation Marcellus

Shale Gas Operations Sanitized. A

SGE00742 U.S. EPA. 2012. States Pretreatment Coordinators' Quarterly Conference

Call: Summary. (August 8). A

SGE00743 U.S. EPA. 2013. States Pretreatment Coordinators’ Bi

- monthly Conference

Call. (August 14). A

SGE00745 KLH Engineers. 2011. Municipal Authority of the City of McKeesport:

Headworks Loading Analysis for Natural Gas Drilling Wastewater Pollutants. (Mar). B

SGE00751 Borough of Charleroi. 2008. Re: Authority of the Borough of Charleroi

Administrative Order. (November 21). A

SGE00757 KLH Engineers. 2008. Tech Evaluation of the Impact of O& G Well

Wastewaters on the Municipal Authority of the City of McKeesport WW Trmt Facility. AMemorandum

June 7 , 2016 Page 12

Table 2

. References Used for This Memorandum

DCN Source Citation Source Flag a
SGE00758 KLH Engineers. 2009. Technical Evaluation of the Impact of O&G Well WW

on the Clairton Municipal Authority Wastewater Treatment Facility. (February) A

S GE00762 Biddle, Lisa. 2015. Summary of EPA

- State Pilot on Improving Regulatory

Implementation A

SGE0 0785 USEPA. 2015. Summary of EPA Outreach and Coordination with Indian

Tribes for the Proposed Pretreatment Standards for UOG Extraction Wastewater A

SGE00788 NYSDEC. 2009. Supplemental Generic Environmental Impact Statement

(SGEIS) on the Oil, Gas, and Solution Mining Regulatory Program. C

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

SGE00997.A04 Borough of Waynesburg. 2009. Clean Water Act Section 308 Request for

Information

- Attachment 4: Sampling Summary. A

SGE01001 Fayette Engineering Co., Inc. 2009. Clean Water Act Section 308 Request for

Information

- Attachment 5: DMR Records. (March 13). A

SGE01002 Reynoldsville Sewage Authority. 2012. Authorization to Discharge under the

NPDES Requirements for Publicly Owned Treatment Works (POTWs). (July 17). A

SGE01003 Biddle, Lisa. 2015. Information from EPA Region 3 about Treatment

Facilities in Pennsylvania A

SGE01090 ERG. 2015. McKeesport POTW
SGE01182 ERG. 2016. Analysis of Pennsylvania Department of Environmental

Protection’s Oil and Gas Waste Reports. A

SGE01188 U.S. EPA. 2016. Technical Development Document for Effluent Limitations

Guidelines and Standards for Oil and Gas Extraction. A

SGE01245 ERG. 2015. Pennsylvania Department of Environmental Protection’s (PA

DEP) Statewide Oil and Gas Waste Reports. (November) A

SGE01334 ERG. 2016. Memorandum Providing a Crosswalk between Tables and

Figures in the Proposed and Final Technical Development Document for Effluent Limitations Guidelines and Standards for Oil and Gas Extraction

. 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 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.,
opera tor 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.A TTACHMENT 1 : POTW S D ATA FOR TDD ( DCN SGE 01183 .A 0 1 )