### MEMORANDUM

TO: Lisa Biddle, EPA

Karen Milam, EPA

FROM: James K. O’Connell, ERG

Brent Ruminski, ERG

DATE: June 6 , 2016

SUBJECT: Analysis of Centralized Waste Treatment (CWT) Facilities Accepting UOG

Extraction Wastewater ( DCN SGE01178 )

T his memorandum describes the data and methods used to compile information on
centralized waste treatment (CWT) facilities fo r the Tec hnical Development Document for Effluent Limitations Guidelines and Standards for Oil and Gas Extraction (TDD) ( DCN

SGE01188 ). Specifically, t his memorandum focuses on information included in Chapter D .4 of
the TDD and describes the sources and methodologies used to create Figure D

- 11 an d Table D

- 7
in the TDD. Tables and figures in Section D.4 in the TDD that are not described in this memorandum 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 memorandum is organiz ed into the following sections:

 Section 1.0 O verview of CWT facilities that accept UOG extraction wastewater

 Section 2.0 CWT facility data (TDD Section D.4)

 Section 3.0 discusses the data quality and limitations in these analyses

 Section 4.0 describes ERG’s quality control procedures.

 Section 5.0 lists the references used for th e s e analyses

.

The attachment to this memorandum contains the underlying data and analyses used to
create the TDD table s and figures discussed in this memorandum.

 Attachment 1

– CWT Facility List and Analysis (DCN SGE01178.A01)

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

1.0 O VERVIEW OF CWT F ACILIT IES T HAT A CCEPT UOG E XTRACTION W ASTEWATER

Information in the record indicates that s ome UOG well operators utilize centralized waste treatment (CWT) facilit ies to manage UOG extraction wastewater

. This may occur in areasMemorandum

June 6 , 2016 Page 2

where other wastewater disposal options (e.g., Class II disposal wells) are not available or are not
as cost effective ( DCN SGE00710; DCN S GE00139; DCN S GE00182 ). EPA defines a CWT
facilit y at 40 CFR 437.2(c) as “ any facility that t reats (for disposal, recycling or recovery of material) any hazardous or nonhazardous industrial wastes, hazardous or non

- hazardous industrial wastewater, and/or used material received from offsite ”

.

1.1 Types of Treatment

CWT facilities that accept UOG extr action wastewater use a variety of treatment

processes , depending on the fate of the treated wastewater and applicable regulatory requirements

. In general, for treatment prior to reuse/recycle of UOG wastewater for hydraulic fracturing of subsequent well(s )

, CWT facilities typically use tech nologies that are not designed

to reduce the level of the total dissolved solids (TDS) . F or treatment prior to discharge

, CWT
facilities may use TDS removal technologies , depending on regulatory requirements . For purposes of discussion in the TDD, EPA describes two levels of treatment at CWT facilitie s:

 Non

- TDS removal technologies

– Technologies that remove non

- dissolved 1 constituents from wastewater. Examples of non

- dissolved constituents in UOG
extraction waste water applications include suspended solids, oil and grease, metals, bacteria, and /or certain ions that potentially cause scale to form on equipment and interfere with fracturing chemical additives. These technologies do
not remove sodium and chloride ions , which make u p more than 50 percent o f the TDS in UOG extraction wastewater, as well as some other dissolved constituents
that contribute to TDS.

 TDS removal technologies

– T echnologies capable of removing dissolved
constituents that contribute to TDS (so dium, chloride, calcium, etc.), in addition
to the constituents removed by non

- TDS removal technologies.

1.2 Types of Discharge

The following list describes the types of CWT facilities that accept UOG extraction

wastewater

, classified according to the type of discharge used for treated wastewater. Section

D. 4.1 in the TDD provides a more detailed discussion about the se types of CWT facilities.

 Zero D ischarge

– CWT facilities that do not discharge wastewater to surface water s or to a POTW. These CWT facilities typically return the treated wastewater to the UOG operator for reuse/recycle in fracturing. 2

 Discharge

– CWT facilities that discharge treated wastewater to surface waters, either directly or indirectly via a POTW.

1 EPA has categorized treatment technologies into two categories in this memo: those that are designed to remove dissolved constituents and those that are not designed to remove dissolved constituents. However, it should be noted that some of the technologies in the non

- TDS removal category do in fact remove some dissolved constituents. For example, chemical precipitation will remove certain metals. However, these technologies typically will not remove salts and hardness, which are the primary components of TDS in UOG extraction wastewater.

2 Zero discharge does not always mean reuse in fracturing. Zero discharge CWT facilities may also evaporate the
wastewater or send it to underground injection wells ( DCN SGE00 374).Memorandum

June 6 , 2016 Page 3

 Multiple Discharge Options (i.e., D ischa rge, Zero Discharge)

– CWT facilities that

have the option of d ischarging treated wastewater, but may also use a zero discharge option (e.g., recycle/reuse in a subsequent fracturing operation when that is the most

cost

- effective option, then discharging a t times when the demand for reuse/recycle wastewater is low)

.

2.0 C OMPILATION OF CWT F ACILITY D ATA

Th e following sub section s describe the primary references and methodology that ERG
used to create Figure D

- 11 and Table D

- 7 in the TDD:

 Section 2.1 discusses the primary references

.

 Section 2.2 discusses the compiled list of CWT facilities

.

 Section 2.3 describes how ERG created Figure D

- 11 and Table D

- 7 in the TDD

.

The “O&G C WT List” tab in Attachment 1 to this memorandum (DCN SGE01178 .A 0 1) contains the full list of CWT facilities that accept or plan to accept UOG extraction wastewater
of which ERG is aware . This tab includes all of the relevant information associated with the se CWT facilities that ERG found in the available data source s described in Section 2.1 in this
memorandum

.

2.1 Primary References Used to Identify CWT Facilities Accepting UOG Extraction

Wastewater

ERG searched for CWT facilities in all states with known UOG operations. ERG focuse d on searching for comprehensive lists of CWT facilities published by state agenc ies to compile CWT facility information

. The four states described in Sections 2.1.1 and 2.1.2 are the only ones identified with comprehensive lists of CWT facilities. CWT facilities in other states were identified using miscellaneous sources (e. g., CWT facility websites) as described in Section

2.1.3

. ERG listed a ll of the sources used to de velop the “O&G CWT List ” tab in A ttachment 1 to this memorandum (D CN SGE01178 .A 0 1 ) in Section 5.0 of this memorandum

. ERG specifically
searched for CWT facilities that accept UOG extraction waste water

.

2.1.1 Pennsylvania Department of Environmental Protection (PA DEP)

ERG compiled information from the Pennsylvania Department of Environmental Protection (PA DEP) statewide data downloads (i.e., waste reports data) (DCN SGE01245 )

, which are published in six month reporting periods (i.e., January to June, July to December ). For each rep orting period, t he data downloads include the following types of information : API
number of the well that generated waste, waste quantity and type , and waste management
information

. T he data downloads also provide information about the facility where the w aste was disposed

, including the facility name, permit number, and location

. ERG used the statewide data
downloads from 2004 through 2014 to compile a list of CWT f acilities that have accepted UOG extraction wastewater generated by UOG wells in Pennsylvania

. In some instances, t h e PA DEP
statewide data downloads also capture d waste facilities located in states other than Pennsylvania

. This occurred when the operator hauled th eir waste out of the state for disposal (i.e., wastewater generated by UOG wells in PA was disposed of in a state other than PA)

. ERG’s Analysis of Pennsylvania Department of Environmental Protection’s (PA DEP) Oil and Gas Waste ReportsMemorandum

June 6 , 2016 Page 4

memorandum (DCN SGE 01182 ) includes additional information about the PA DEP statewide
data downloads

.

2.1.2 Other State Websites

ERG searched for lists of CWT f acilities published by other state agencies to identify

CWT f acilities that accept or plan to accept UOG extraction was tewater

. ERG identified the following s tate agency sources :

 Wyoming Department of Environmental Quality (WY DEQ) permits all commercial oilfield wastewater disposal facilities 3 in Wyoming and publishes a
list of these facilities that includes the facility name, operator, and address (DCN

SGE01 26 4)

.

 Railroad Commission of Texas (TX RRC) lists permitted commercial recycling
and surface waste facilities 4 with permit number and expiration date information. Commercial recycling and surface waste f a cilities are organized in to the following groups: Recycling 5 , Pits 6 , Stationary Treatment Facilities 7

, Landfarm/Landtrea t ment Facilities 8 , and Reclamation Plants 9 (DCN SGE01 26 5)

.

 Colorado Oil and Gas Conservation Commission (COGCC) maintains the

“ Colorado Oil and Gas Information System

. ” This system allows a user to
conduct facility searches and provides facility ID, operator name , and location
information for CWT facilities (DCN SGE00518)

.

The lists of CWT facilities provided by the agencies listed abov e include facilities outside the scope of this analysis (e.g., underground injection well facilities, CWT facilities that only accept waste from sources other than oil and gas extraction operators)

. ERG used the information provided by the agency to identi fy each CWT facility website. Using the CWT facility websites, ERG determined if the facility accepts UOG extraction wastewater for treatment. 10

3 “Disposal facility” is a term used directly by WY DEQ. Based on the facilities listed by WY DEQ, this term includes types of facilities outside the scope of this analysis such as evaporation pond facilities in addition to
wastewater treatment facilities.

4 “Surface waste facility” is a term used directly on the TX RRC website. The TX RRC notes on their website: “commercial surface waste disposal and treatment facilities typically receive a variety of oil and gas wastes from a wide spectrum of sources”. Bas ed on the facilities listed by TX RRC, this term includes types of facilities outside the scope of this analysis such as evaporation pond facilities in addition to wastewater treatment facilities.

5 Recycling is defined as storing , handl ing , treat ing, and reus ing fresh water , water

- based drilling fluids, and oil

base d drilling fluids, and cuttings for reuse for the following load bearing structures: lease roads, drilling pads, tank batteries, compressor station pads, and county roads

. 6 Pits are used to d ispose of water base drilling fluid and associated cuttings (maximum chloride concentration of 3,000 mg/l).

7 Stationary Treatment Facilities t reat non

- hazardous oil and gas wastes

. 8 Landfarm/Landtreatment Facilities d ispose of non

- hazardous oil and gas w aste, including water base d drilling fluid and associated solids, oil base d drilling mud and associated cuttings, tank bottoms, material from produced water collecting pits, produced formation sand, and soil impacted by crude oil or condensate spills.

9 Re clamation Plants receive, store, handle, treat and dispose of certain non

- hazardous oil and gas wastes.

10 ERG did not include CWT facilities that only accept Conventional Oil and Gas (COG) extraction wastewater in this analysis.Memorandum

June 6 , 2016 Page 5

2.1.3 Miscellaneous

For states without comprehensive lists of CWT facilities, ERG conducted internet
searches and r eviewed information from technical presentations related to UOG to identify CWT
facilities. For CWT facilities identified through technical presentations, ERG used the information to identify the CWT facility website to determine if the facility accepts UO G
extraction wastewater for treatment. 11 These sources are noted in Attachment 1 to this memorandum (DCN SGE01178 .A 0 1), and a complete list of sources can be found in Section 5.0
in this memorandum

.

2.2 Generation of the List of CWT Facilities

The “O&G CWT List” tab in Attachment 1 to this memorandum ( DCN SGE01178 .A 0 1) contains a list of unique CWT facilities that ERG c ompiled from the sources previously
described in Section 2.1 in this memorandum

. ERG investigated CWT facilities that were
identified using the previously mentioned data sources by searching for the CWT facility
website . In most cases, the CWT facility website provided additional information that ERG used to populate the “O&G CWT List” tab.

A full list of the data fields contained in the “O&G CWT List” and description of each
field is shown in Table 1

.

Table 1

. Data Dictionary for “O&G CWT List” Tab in Attachment 1 to this

Memorandum (DCN SGE01178 .A 0 1)

Field Name Description Waste Facility Name or Operator Name of the facility that accepted and treated the waste products from the well, or t he

o rganizational n ame of the CWT facility o perator
Formation The name of the formation served by the CWT facility Facility City The municipality in which the CWT f acility is located Facility State The s tate in which the CWT f acility is located

Latitude The latitude value, in decimal degrees, for the CWT facility location Longitude The longitude value, in decimal degrees, for the CWT facility location

Lat Long Comment ERG’s notes on the source or specific address of the latitude and longitude coordinates

Permit Number The NPDES permit number of the CWT facility. If no NPDES permit number applies or no permit was available, other types of permit numbers may be used in this field.

First Operational Year The first year each CWT facility accepted UOG wastewater. If the CWT had not begun accepting UOG wastewater by the end of 2014 , but had plans to, ERG noted th ese as “pending ”

Not Yet Constructed

Indicator An “x” indicates that the CWT facility had not yet been constructed

Commercial or Operator Indicates whether the CWT facility is owned and operate d by an oil and gas compan y

. “C ommercial” is shorthand used to indicate that the facilit y is not owned and operated by an oil a nd gas compan y and “ operator ” is used to describe a facilit y that is owned and operated by an oil and gas compan y

.

CWT Fac ility Type The type of CWT facility, classified according to the type of discharge used for treated

wastewater (i.e., zero discharge, discharge, multiple discharge options )

11 ERG did not include CWT f acilities that only accept COG extraction wastewater in this analysis.Memorandum

June 6 , 2016 Page 6

Table 1

. Data Dictionary for “O&G CWT List” Tab in Attachment 1 to this

Memorandum (DCN SGE01178 .A 0 1)

Field Name Description

Discharge Type If the CWT facility discharges, this field indicates whether it discharges indirectly (i.e., through a POTW) or directly (i.e., to surface waters ). Discharge type is listed as “N/A”

for zero discharge CWT facilities

Treatment Level Indicates the type of treatment technology the CWT facility operates: “ TDS removal ” or

“ Non

- TDS removal ” . If a facility had both types but does not always use the TDS removal, ERG still assigned it as “TDS removal”.

Evaporation Pond An “x” indicates a CWT facility that use s evaporation ponds . ERG categorized this as

non

- TDS removal.

Filtration or Chemical Precipitation An “x” indicates a CWT facility that use s filtration and/or chemical precipitation . ERG categorized this as non

- TDS removal.

Electrocoagulation An “x” indicates a CWT facility that uses electrocoagulation . ERG categorized this as

non

- TDS removal. Evaporation and
Condensation An “x” indicates a CWT facility that use s evaporation/condensation . ERG categorized
this as TDS removal.

Crystallization A n “x” indicates a CWT facility that use s crystallization . ERG categorized this as TDS
removal.

RO An “x” indicates a CWT facility that use s reverse osmosis (RO) . ERG categorized this
as TDS removal.

Other Indicates the type of “other” treatment that is used at the given CWT facility Accepts WW From
Other Industries Yes/No indicator about w hether or not the CWT facility accepts wastewater from

in dustries other than oil and gas extraction Design/ Permitted Capacity (gpd) Indicates the CWT facility’s design or permitted capacity in gallons per day.

References All of the sources (listed by DCN number) that ERG use d to popu late data for each CWT facility

CWT Facility Website CWT facility website (if any)

Notes ERG’s notes on the treatment technologies employed by the CWT facilit y

2.3 Generation of TDD Figure D

- 11 and Table D

- 7

This section explains how ERG create d Table D

- 7 and Figure D

- 11 in the TDD using
data from the “O&G CWT L ist ” tab in Attachment 1 to this memorandum (DCN

SGE01178 .A 0 1)

.

2.3.1 Table D

- 7 in the TDD. Number, by State, of CWT Facilities That Have Accepted or

Plan to Accept UOG Extraction Wastewater

To create Table D

- 7 in the TDD, ERG counted the number of CWT fac ilities in each

state using the data in the “O&G CWT List” tab in Attachment 1 to this memorandum (DCN

SGE01178 .A01 ). ERG separated t he total number of CWT fac ilities in each state into three categories related to the type of CWT facility : zero discharge

, discharg e , or multiple discharge options

. Within those categories, ERG further separated the CWT fac ilities by their treatment
level: TDS remov al or non

- TDS removal

. 12 The “ Summary by State ” tab in Attachment 1 to this memorandum (DCN SGE01178 .A01 ) shows the total number of CWT fac ilities by state

, CWT facility type

, and t reatment level

. ERG searched for more states than what are shown in TDD

12 If a facility had TDS removal technologies, even if it did not always use the TDS removal, ERG still assigned it as
“TDS removal”.Memorandum

June 6 , 2016 Page 7

Table D

- 7 and only presented data for the states in which ERG identified CWT facilities accepting UOG extraction wastewater

. Additionally, to be consistent with the well data collected from states (see Section 2.3.2 ), ERG did not include CWT information after 2014.

Table D

- 7 also presents the UOG formation served by the CWT facility . ERG populated this column based on information provided by the underlying references used to create the list of
CWT facilities.

2.3.2 Figure D

- 11 in the TDD. Number of Known Active CWT Facilities over Time in the

Marcellus and Utica Shale Formation s

ERG created Fig ure D

- 11 in the TDD using some of the CWT fac ilities in the “O&G
CWT List” tab in Attachment 1 to this memorandum (DCN SGE01178 .A01 ) along with Ohio spud 13 data (DCN SGE01172 ) , W est Virginia spud data (DCN SGE01258 ) , and Pennsylvania spud data (DCN SGE01246 )

. ERG used the following steps:

Step 1

– Count the Facilities

Using the list of CWT facilities discussed in Section 2.2 in this memorandum

, ERG

c ounted the number of active CWT fac ilities accepting UOG extraction wastewater
between 2004 and 201 4 in Pennsylvania, Ohio, and West Virginia

. 14 ERG grouped the data by “first operational year” and included the summarized data in the “Marc. CWTs

over Time Data” tab in Attach ment 1 to this memorandum (DCN SGE01178 .A 0 1) 15

. ERG also included facilities that were planning to accept but had not yet accept ed UOG

wastewater as of 2014 . These facilities are included under “ pending ” in the first operational year field

.

Step 2

– Count the Wells

ERG obtained UOG well data from Pennsylvania, Ohio, and West Virginia 16 ; the source
of each state dataset is described below . Each dataset includes a unique list of wells and their spud, completion, or status date. ERG counted the number of UOG we lls that were drilled in Pennsylvania, Ohio, and West Virginia between 2004 and 201 4 (primarily in the Marcellus and Utica shale plays). ERG reports the results on the “Marc. Drilled Wells Data” tab of Attachment 1 to this memorandum (DCN SGE01178 .A 0 1).

 P ennsylvania

– The PA DEP provides an online searchable database called “ Spud Data Report ” (DCN SGE01246 ). R esults from this database can be exported to

Microsoft Excel and are included in the “PA Wells” tab in Attachment 1 to this memorandum (DCN SGE01178

. A01 ) . ERG accessed this database and downloaded

13 “Spud” is an industry term for the commencement of drilling (DCN SGE00763).

14 These states contain the majority of the Marcellus/Utica shale resources. Other states (e.g., Kentucky) may also
contain limited Marcellus/Utica shale resources.

15 The “first operational year” is the first year each CWT facility accepted UOG wastewater. If the CWT had not begun accepting UOG wastewater, but had plans to, ERG noted these as “pending.”

16 ERG obtained UOG well data from spud databases. “Spud” is an industry term for the commencement of drilling

a new well (DCN SGE00 763).Memorandum

June 6 , 2016 Page 8

records for wells where the “Unconventional only” field was “yes. ” 17 Because the PA

DEP Spud Data Report only includes wells that were actually spudded, ERG did not apply additional filters to this database. E RG used the spud date field to group new well counts by year.

 West Virginia

– The West Virginia Department of Environmental Protection (WVDEP) provides an online searchable database called “ Oil and Gas Well Search ” ( DCN SGE01258 )

. R esults from this database can be exported to Microsoft Excel and are included in the “WV Wells” tab in Attachment 1 to this memorandum (DCN

SGE01178 .A 0 1)

. ERG searched the database and downloaded well records that were
associated with the “Marcellus shale” forma tion. 18 ERG selected wells flagged in the “status field” as active well, drilling, shut in, plugged, or under construction (listed as drilling)

. 19 ERG also only included wells flagged as gas well or oil well. ERG used the completion date field to group new w ell counts by year.

 Ohio

– The Ohio Department of Natural Resources (OH DNR) periodically publishes

a M icrosoft Excel spreadsheet containing a unique list of wells that have been permitted to be drilled into th e Utica shale formation in Ohio ( DCN SGE01172 )

. ERG downloaded this spreadsheet and included the results in the “ OH Wells” tab in Attachment 1 to this memorandum (DCN SGE01178 .A 0 1)

. ERG applied filters to
obtain the relevant well list. OH DNR’s well list includes a status indicator field populated wit h : drilled, drilling, producing, or permitted. To capture the number of wells drilled over time, ERG only counted those wells that were drilled, drilling, or producing in the status field and did not include those wells that were only permitted

. ERG used t he permit issue date field to group new well counts by year.

Step 3

– Plot the Results

ERG plotted the results of Step 1 and Step 2 above in the “Marc. CWT s over T ime Figure ” tab of Attachment 1 to this memorandum (DCN SGE01178 .A01 ), which is also Figure D

- 11 in the TDD. For both datasets, ERG plotted the cumulative number of CWT
facilities and cumulative number of UOG wells over time. ERG indicated the number of pending CWT facilities with a dashed line in the figure.

3.0 D ATA Q UALITY AND L IMITATIONS

As discu ssed in Section 2.0 , ERG focused on identifying comprehensive list s of CWT facilities published by state agencies. However, ERG on ly identified four such states . F or all
other UOG

- producing states, ERG relied on miscellaneous sources (e.g., CWT facility websites

, technical presentations ) to identify CWT facilities that accept UOG extraction wastewater

. Although ERG searched for CWT facilities by a number of differen t methods, the information presented may not be exhaustive. Because there is no national inventory of CWT facilities and

17 The “unconventional only” field in PA DEP’s dataset is 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.
Most of the UOG w ells flagged by PA DEP are Marcellus shale wells but may also include Utica shale wells.

18 ERG also searched for Utica wells drilled in West Virginia but there were zero results.

19 Blank status fields were also included but only if there was a valid comple tion date provided.Memorandum

June 6 , 2016 Page 9

few states maintain comprehensive lists of CWT facilities

, Table D

- 7 in the TDD likely
underestimate s the number of CWT facilities acce pting UOG extraction wastewater

. 20

All CWT data is based on publicly available information

, and therefore not all of the
metadata is filled in on the “O&G CWT List” tab in Attachment 1 (DCN SGE01178.A01) . ERG only included facilities if, at minimum, the following information could be identified: Waste Facility Name or Operator, Facility State, CWT Facility Type, and Treatment Level. While for the most part, the lists from Pennsylvania, Wyoming, Texas, and Colorado contained this information, many other data gaps remained. Information identified from CWT facility websites primarily included facility location , type of wastewater accepted

, and treatment technology

.

4.0 Q UALITY C ONTROL P ROCEDURES

All of the analys es 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 CWT facilities

.

Specifically, ERG used the procedures 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 reference information, assigned each reference a Document Control Number (DCN ), imported the reference i nformation 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 to evaluate the quality of data sources collected for use in the UOG r ulemaking. 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 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 for a government agency (e.g., site visit reports, industry meeting notes);

 Source Flag B

– Documents prepared by a verified 21 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 cou ld not be verified and that
do not include citation information.

20 It is also possible that some CWT facilities in Table D

- 7 have closed since ERG identified them.

21 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 U OG industry.Memorandum

June 6 , 2016 Page 10

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 performed a 20 percent check of all data entry ;

 ERG performed a 100 percent check of all analyse s and calculations, and
documented these in the internal version of the spreadsheet ; and

 An ERG senior staff member familiar with Effluent Limitation Guidelines ( ELGs )
and the UOG rulemaking review ed the results from the CWT Facility List and Analysi s spreadsheet provided in Attachment 1 to this memorandum (DCN

SGE01178 .A 0 1 ).

5.0 R EFERENCES

Table 2 provides DCNs, citations , and source flags for references used in the s e analyses

. The references in Table 2 are sorted by DCN.

Table 2

. References

DCN Full 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

SGE00139 Puder, M.G.; Veil, J.A. 2006. Offsite Comm. Disposal of Oil and Gas Exploration and

Prod. Waste: Availability, Options, and Costs. 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 Servic es, LLC on 5 January 2012. (February 1) A

SGE00273.A21 Jim Kline. 2012. Examining The Regulations and Restrictions Set by the DEP to

Determine the Operational Feasibility of Disposal. PA DEP. A

SGE00284 Hayes, Thomas et al. 2012. Barnett and Appalachian Shale Water Management and

Reuse Technologies. RPSEA A

SGE00298.A24 Johan Themaat. 2012. Water Infrastructure Versus Mobile Options for Treating and

Disposing Fracking and Produced Water. High Sierra Water Services. C

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

SGE00363 2012. New Subsidiary Alanco Energy Services, Inc. To Provide Produced Water

Disposal Services to Nat'l Gas Ind. C

SGE00364 Alanco Energy Svs., Inc. 2012. Alanco Energy Svs., Inc. Commences Commercial

Operation of New Colorado Oil & Gas Produced Water Trea tment Facility C

SGE00365 Fountain Quail Water Management, LLC. Unknown. Eagle Ford Shale (South Texas). C

SGE00366 Clarion Altela Environmental Services (CAES). n.d. CAES Overview. Downloaded on

1/28/2013. C

SGE00367 CARES. n.d. CARES McKean. Downloaded on 1/28/2013. CMemorandum

June 6 , 2016 Page 11

Table 2

. References

DCN Full Citation Source Flag a

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

- Atlantic Oil and Gas

Extraction. (November 26). A

SGE00369 Anticline Disposal, LLC. Unknown. Anticline Disposal, LLC. C

SGE00374 Red Desert. n.d. What Makes Our Water Treatment & Reclamation Facility So

Advanced? Downloaded on 1/28/2013. C

SGE00375 Rigzone. 2011. Sionix to Buil d Bakken Water Treatment Plant. Last accessed on June 5,

2016. http://www.rigzone.com/news/oil_gas/a/110613/Sionix_to_Buil d_Bakken_Water_Treat ment_Plant C

SGE00376 Somerset Regional Water Resources (SRWR). 2012. Unknown. SRWR: Our Services. C

SGE00378 Waste Management. 2011. DRBC Proposed Natural Gas Development Regulations

Comments of Waste Management. C

SGE00379 Hill, David A. 2012. The Future Is NOW for Water Recycling in the Niobrara.

Wyoming Energy News. C

SGE00414 Hayes, Thomas, et.al. 2012. Characterization of Flowback Waters from the Marcellus

and the Barnett Shale Regions Report No. 08122

- 05.09. RPSEA A

SGE00469 Barger, Brian. Unknown. Testimony of Brian P Barger RE: HB 59 on Behalf of Patriot

Water Treatment, LLC. A

SGE00474 GreenHunter Water, LLC. 2013. GreenHunter Water Acquires Barging Terminal in

Wheeling, Ohio County, West Virginia. GreenHunter Wat er, LLC. C

SGE00476 Hydro Recovery, LP. 2013. Company Info. Downloaded on 5/20/2013. C

SGE00478 Kasey, P. 2009. Gas Well Drilling Brine Treatment Facility Opens in Fairmont. The

State Journal. D

SGE00479 Kadramas, Lee & Jackson, Inc. 2012. Power Forecast 2012: Williston Basin Oil and

Gas Related Electrical Load Growth Forecast. B

SGE00481 McCutcheon Enterprises. 2013. Waste Reduction: A Greener Alternative for Treating

Drilling Muds. (April). C

SGE00484 Jim Davis. 2012. WM Environmental Services : Oilfield Solutions in the Marcellus

Shale. Waste Management Eastern Group. C

SGE00488 West Virginia Dept. of Environmental Protection. 2012. NPDES Water Pollution

Control Permit WV0116441. Reserved Environmental Services CWT Permit. A

SGE00490 Advanced Waste Services. 2013. Marcellus & Utica Shale Services. Company website. C

SGE00507 Boschee, Pam. 2012. Handling Produced Water from Hydraulic Fracturing. Oil & Gas

Facilities. B

SGE00512 Casper Star

- Tribune (Trib). 2010. Red Desert Water Plant Opens To day. C

SGE00518 Colorado Oil and Gas Conservation Commission (COGCC). COGIS

- Production Data

Inquiry. A

SGE00524 Eureka Resources. 2013. Eureka Resources Announces Plans for New Wastewater

Treatment Plant. January 7. C

SGE00534 High Sierra Energy, LP. 2012. Denver Julesberg Basin. C

SGE00568 PA DEP. 2010. Oil & Gas Facility Summary. (August 26). A

SGE00577 Polar Bear Water Treatment. 2013. Polar Bear Water Treatment Company Website. C

SGE00578 Purestream. 2013. Purestream Services Will Begin Commercial Operations to Treat

Eagle Ford Shale Prod and Frac Flowback Water in Gonzalez County, TX. CMemorandum

June 6 , 2016 Page 12

Table 2

. References

DCN Full Citation Source Flag a

SGE00580 Randy Wells. 2012. CORRALLING WASTEWATER: Treatment company sets up

shop in Kay Arena. Indiana Gazette. (January 2012). C

SGE00584 Shallenberger Construction. 2012. Marcellus Water Treatment. Company website

accessed on 10/28/2013. C

SGE00616 U.S. EPA. 2013. Summary of the Technical Workshop on Wastewater Treatment and

Related Modeling. (April 18) 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

SGE00638.A12 Wilkerson, Tommy. 2013. Strategies for Sustainable Water Transport Lessons Learned

in the Marcellus Applied to the Niobrara. B

SGE00691 U.S. EPA. 2013. Summary of the Technical Workshop on Water Acquisition Modeling:

Assessing Impacts Through Modeling and Other Means. (September ). A

SGE00710 Slutz, J; Anderson, J; Broderick, R; Horner, P. 2012. Key Shale Gas Water

Management Strategies: An Economic Assessment Tool. (September 11). B

SGE00711 Devon Energy Corporation (DVN). 2014. Cana Water Reuse Project Helps Devon

Overcome Dro ught. C

SGE00713 McIntire, Carrol. 2014. Chesapeake Officials Show Off Their New Water Recycling

Facility. Free Press Standard. (February 14). C

SGE00729 Iron Eagle. 2014. Iron Eagle Opens Water Recycling Facility to Serve Oil and Gas

Industry. C

SGE00763 PA DEP. 2014. Oil and Gas Reporting

– Electronic (OGRE) Public Reporting Data

Dictionary, v1.0. A

SGE00772 Lodge, Terry. 2014. Demand for revocation of Chief’s Orders for drilling waste

disposal facilities. Terry Jonathan Lodge Law Office. (June 3). 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

SG E01092 Fairmont Brine Processing. 2012. Company Website. Last accessed on June 5, 2016.

Retrieved from: http://fairmontbrine.com/ C

SGE01172 OH DNR. 2015. Utica/Point Pleasant Shale Cumulative Permitting Activity through

12/07/2013. Downloaded on 9/6/2015. Last updated on 8/29/2015. A

SGE01181 ERG. 2016. Unconventional Oil and Gas (UOG) Drilling Wastewater Memorandum A

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

SGE01246 PA DEP. 2015. Spud Data Report. Accessed on 11/19/2015. A

SGE01256 Southwestern Energy, Inc. 2011. Waste Management Plan. ADEQ. A

SGE01257 Fairmont Brine Processing. 2012. Fairmont Brine Processing Home Page. Last accessed

on June 5, 2016. http://www.fairmontbrine.com/. CMemorandum

June 6 , 2016 Page 13

Table 2

. References

DCN Full Citation Source Flag a

SGE01258 WVDEP. 2015. Oil and Gas Well Search. Accessed on 12/17/2015. Available online at:

https://apps.dep.wv.gov/oog/wellsearch_new.cfm A

SGE01264 WY DEQ. 2015. Permitted Commercial Oil Disposal Facilities. (September 1). A

SGE01 265 TX RRC. 2015. Commercial Recycling & Surface Disposal Facilities. A

SGE01266 TX RRC. Unknown. Authorization to Treat by Produced and Frac Flow

- back Water for

Re

- use. A

SGE01267 HydroRecovery. 2010. About Us

- HydroRecovery. Accessed on 12/29/2015.

http://www.hydrorecoverylp.com/?section=about&id=locations. C

SGE01268 Bulger Facility. MAX Environmental. 2015. Accessed on 12/29/2015.

http://www.maxenvironmental.com/our

- facilities/bulger

- site/ C

SGE01269 Yukon Facility. MAX Environmental. 2015. Accessed on 12/29/2015.

http://www.maxenvironmental.com/our

- facilities/yukon

- site/ C

SGE01270 Aspen Integrated Systems. 2015. Aspen Integrated Systems Website. Accessed on

12/29/2015. http://www.aspenintegratedsystems.com/index.html. C

SGE01272 Marks, J.F. 2012. Oklahoma City

- based Devon Energy Corp. is saving water with its

reservoir project. NewsOK. D

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 : CWT F ACILITY L IST AND A NALYSIS ( DCN SGE01178 .A01 )