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)

This memorandum describes the data and methods used to compile information on 

centralized waste treatment (CWT) facilities for the Technical Development Document for 

Effluent Limitations Guidelines and Standards for Oil and Gas Extraction (TDD) (DCN 

SGE01188). Specifically, this memorandum focuses on information included in Chapter D.4 of

the TDD and describes the sources and methodologies used to create Figure D-11 and 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 tables 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 organized into the 

following sections:

 Section 1.0 Overview 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 these analyses.

The attachment to this memorandum contains the underlying data and analyses used to 

create the TDD tables 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 introduction of the TDD.

1.0 OVERVIEW OF CWT FACILITIES THAT ACCEPT UOG EXTRACTION WASTEWATER

Information in the record indicates that some UOG well operators utilize centralized 

waste treatment (CWT) facilities to manage UOG extraction wastewater. This may occur in areas 
Memorandum

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 SGE00139; DCN SGE00182). EPA defines a CWT

facility at 40 CFR 437.2(c) as “any facility that treats (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 extraction 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 technologies that are not designed 

to reduce the level of the total dissolved solids (TDS). For 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 facilities:

 Non-TDS removal technologies – Technologies that remove non-dissolved1

constituents from wastewater. Examples of non-dissolved constituents in UOG 

extraction wastewater 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 up more than 50 percent of the 

TDS in UOG extraction wastewater, as well as some other dissolved constituents 

that contribute to TDS.

 TDS removal technologies – Technologies capable of removing dissolved 

constituents that contribute to TDS (sodium, 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 these types of CWT facilities.

 Zero Discharge – CWT facilities that do not discharge wastewater to surface waters

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 SGE00374).
Memorandum

June 6, 2016

Page 3

 Multiple Discharge Options (i.e., Discharge, Zero Discharge) – CWT facilities that 

have the option of discharging 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 at times when the demand for reuse/recycle 

wastewater is low).

2.0 COMPILATION OF CWT FACILITY DATA

The following subsections 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 CWT List” tab in Attachment 1 to this memorandum (DCN SGE01178.A01) 

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 these 

CWT facilities that ERG found in the available data sources 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 focused 

on searching for comprehensive lists of CWT facilities published by state agencies 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 all of the sources used to develop the “O&G CWT List” tab in Attachment 1 to 

this memorandum (DCN SGE01178.A01) in Section 5.0 of this memorandum. ERG specifically 

searched for CWT facilities that accept UOG extraction wastewater.

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 reporting period, the data downloads include the following types of information: API 

number of the well that generated waste, waste quantity and type, and waste management

information. The data downloads also provide information about the facility where the waste 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 facilities that have accepted UOG 

extraction wastewater generated by UOG wells in Pennsylvania. In some instances, the PA DEP 

statewide data downloads also captured waste facilities located in states other than Pennsylvania. 

This occurred when the operator hauled their 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 Reports
Memorandum

June 6, 2016

Page 4

memorandum (DCN SGE01182) includes additional information about the PA DEP statewide 

data downloads. 

2.1.2 Other State Websites

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

CWT facilities that accept or plan to accept UOG extraction wastewater. ERG identified the 

following state agency sources: 

 Wyoming Department of Environmental Quality (WY DEQ) permits all 

commercial oilfield wastewater disposal facilities3in Wyoming and publishes a 

list of these facilities that includes the facility name, operator, and address (DCN 

SGE01264).

 Railroad Commission of Texas (TX RRC) lists permitted commercial recycling 

and surface waste facilities4 with permit number and expiration date information.

Commercial recycling and surface waste facilities are organized into the 

following groups: Recycling5, Pits6, Stationary Treatment Facilities7, 

Landfarm/Landtreatment Facilities8, and Reclamation Plants9(DCN SGE01265).

 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 above 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 identify 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”. Based 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, handling, treating, and reusing fresh water, water-based drilling fluids, and oilbased 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 dispose of water base drilling fluid and associated cuttings (maximum chloride concentration of 

3,000 mg/l).

7 Stationary Treatment Facilities treat non-hazardous oil and gas wastes.

8 Landfarm/Landtreatment Facilities dispose of non-hazardous oil and gas waste, including water based drilling fluid 

and associated solids, oil based 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 Reclamation 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 reviewed 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 UOG 

extraction wastewater for treatment.11 These sources are noted in Attachment 1 to this 

memorandum (DCN SGE01178.A01), 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.A01) 

contains a list of unique CWT facilities that ERG compiled 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.A01)

Field Name Description

Waste Facility Name 

or Operator

Name of the facility that accepted and treated the waste products from the well, or the 

organizational name of the CWT facility operator

Formation The name of the formation served by the CWT facility

Facility City The municipality in which the CWT facility is located

Facility State The state in which the CWT facility 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 these 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 operated by an oil and gas company. 

“Commercial” is shorthand used to indicate that the facility is not owned and operated 

by an oil and gas company and “operator” is used to describe a facility that is owned 

and operated by an oil and gas company.

CWT Facility 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 facilities 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.A01)

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 uses evaporation ponds. ERG categorized this as 

non-TDS removal.

Filtration or Chemical 

Precipitation

An “x” indicates a CWT facility that uses 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 uses evaporation/condensation. ERG categorized 

this as TDS removal.

Crystallization An “x” indicates a CWT facility that uses crystallization. ERG categorized this as TDS 

removal.

RO An “x” indicates a CWT facility that uses 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 whether or not the CWT facility accepts wastewater from 

industries 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 used to populate 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 facility

2.3 Generation of TDD Figure D-11 and Table D-7

This section explains how ERG created Table D-7 and Figure D-11 in the TDD using 

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

SGE01178.A01). 

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 facilities in each

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

SGE01178.A01). ERG separated the total number of CWT facilities in each state into three 

categories related to the type of CWT facility: zero discharge, discharge, or multiple discharge 

options. Within those categories, ERG further separated the CWT facilities by their treatment 

level: TDS removal 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 facilities by state, CWT 

facility type, and treatment 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 Formations

ERG created Figure D-11 in the TDD using some of the CWT facilities in the “O&G 

CWT List” tab in Attachment 1 to this memorandum (DCN SGE01178.A01) along with Ohio

spud13 data (DCN SGE01172), West 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 

counted the number of active CWT facilities accepting UOG extraction wastewater

between 2004 and 2014 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 Attachment 1 to this memorandum (DCN SGE01178.A01)15.

ERG also included facilities that were planning to accept but had not yet accepted 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 Virginia16; 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 wells that were 

drilled in Pennsylvania, Ohio, and West Virginia between 2004 and 2014 (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.A01). 

 Pennsylvania – The PA DEP provides an online searchable database called “Spud 

Data Report” (DCN SGE01246). Results 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 SGE00763).
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. ERG 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). Results 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.A01). ERG searched the database and downloaded well records that were 

associated with the “Marcellus shale” formation.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 well counts by year.

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

a Microsoft Excel spreadsheet containing a unique list of wells that have been 

permitted to be drilled into the 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.A01). ERG applied filters to 

obtain the relevant well list. OH DNR’s well list includes a status indicator field 

populated with: 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 the 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. CWTs over Time 

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 DATA QUALITY AND LIMITATIONS

As discussed in Section 2.0, ERG focused on identifying comprehensive lists of CWT 

facilities published by state agencies. However, ERG only identified four such states. For 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 different 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 wells 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 completion date provided.
Memorandum

June 6, 2016

Page 9

few states maintain comprehensive lists of CWT facilities, Table D-7 in the TDD likely 

underestimates the number of CWT facilities accepting 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 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 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 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 to evaluate the 

quality of data sources collected 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 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 verified21 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.

 

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 UOG 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 analyses 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 reviewed the results from the CWT Facility List and 

Analysis spreadsheet provided in Attachment 1 to this memorandum (DCN 

SGE01178.A01).

5.0 REFERENCES

Table 2 provides DCNs, citations, and source flags for references used in these analyses. 

The references in Table 2 are sorted by DCN. 

Table 2. References

DCN Full Citation

Source 

Flaga

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 Services, 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 Treatment 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. C
Memorandum

June 6, 2016

Page 11

Table 2. References

DCN Full Citation

Source 

Flaga

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 Build Bakken Water Treatment Plant. Last accessed on June 5, 

2016. 

http://www.rigzone.com/news/oil_gas/a/110613/Sionix_to_Build_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 Water, 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 Today. 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.

C
Memorandum

June 6, 2016

Page 12

Table 2. References

DCN Full Citation

Source 

Flaga

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 Drought.

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

SGE01092 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/.

C
Memorandum

June 6, 2016

Page 13

Table 2. References

DCN Full Citation

Source 

Flaga

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

SGE01265 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., 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.
ATTACHMENT 1:

CWT FACILITY LIST AND ANALYSIS (DCN SGE01178.A01)