# Site Visit Report for

Reserve d Environmental Services

, LLC

Mt. Pleasant, PA Centralized Waste Treatment

February 10 , 2015i TABLE OF CONTENTS

Page

1.0 I NTRODUCTION

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2.0 B ACKGROUND AND O BJECTIVES

................................ ................................ ....................... 2

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3. 0 G ENERAL F ACILITY I NFORMATION

................................ ................................ ................... 3

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4.0 P LANT P ROCESS F LOW D ESCRIPTION

................................ ................................ ................ 4

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5.0 C OSTS

................................ ................................ ................................ ............................... 5

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6.0 A DDITIONAL I NFORMA TION

................................ ................................ .............................. 6

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7.0 A DDITIONAL I NFORMATION P ROVIDED DURING C ONFERENCE C ALLS

.............................. 7

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Appendix A: LIST OF PARTICIPANTS ON THE RES SITE VISIT

Appendix B: RES MANIFEST RECORDS (MOUNT PLEASANT FACILITY)

Appendix C: RES MOUNT PLEASANT, PA PLANT PROCESS FLOW DIAGRAMii LIST OF FIGURES Page

Figure 1. Mr. Kicinski Testing for Conductivity in the Receiving Area

................................ ..... 4

- 3

Figure 2. Green Piping Transports Wastewater to the Three Reaction Tanks

............................. 4

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Figure 3. View of the Three Reaction Tanks from Above

................................ .......................... 4

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Figure 4. Bench Setup in the Wet Chemistry Lab

................................ ................................ ....... 4

- 5

Figure 5. Parallel Clarifiers

................................ ................................ ................................ .......... 4

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Figure 6. Parallel Clarifiers

................................ ................................ ................................ .......... 4

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Figure 7. Filter Feed Tank with Some Crude Oil Floating at the Surface

................................ ... 4

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Figure 8. Two of the Three P arallel Coal Filters

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Figure 9. Mr. Kicinski Collecting a Wastewater Sample from the Reservoir Tank

.................... 4

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Figure 10. Close Up View of the Treated Wastewater from the Reservoir Tank in the

Foreground and Red Frac Tank in the Background

................................ ............. 4

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Figure 11. Sludge Thickening Tank

................................ ................................ ............................. 4

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Figure 12. Sludge Filter Press

................................ ................................ ................................ ...... 4

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Figure 13. Inside View of the Sludge Dewatering Tank

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Figure 14. Close

- Up View of Sludge Cake

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1.0 I NTRODUCTION

On July 28, 201 4

, t he U.S. Environmental Protection Agency (EPA) met with representatives of Reserved Environmental Services , LLC (RES ) at their centralized waste
treatment (CWT) facility located at 1119 Old State Route 119, Mt. Pleasant, PA 15666

. Discussion topics included:

 Ge neral Facility Information, and

 Pl ant F low D escription

.

Site visit participants are listed below. Contact inform ation is included in Appendix A.

U.S. EPA Office of Water, Office of Science and Technology Engineering and Analysis Division

Lisa Biddle Jan et Goodwin Adr i an Hanley Karen Milam Jesse Pritts

U.S. EPA Region 3

Joel Blanco

- Gonzalez

E astern R esearch G roup, Inc

. (ERG) (EPA Contractor)

Cortney Itle Kathleen Wu

RES

Nick Haden Andrew Kicinski

Pennsylvania Department of Environment al Protection

Katie Boone Michael Kaufman Pam McQuistian

Prior to this site visit, EPA held conference calls with RES on 5 January 2012 and on 12 June 2014. Topics discussed du ring these two calls included:

 Introductions ;

 Company Background;

 Mount Pleasant Facility Information; and

 Drilling Fluid Wastewater Characteristics.1

- 2

Information obtained during these conference calls has been used to supplement this site visit report. Appendix B is a database of manifest records provided by RES after the January 2012 call.2

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2.0 B ACKGROUND AND O BJECTIVES

The recent increase in unconventional oil and gas (UOG) extraction activities through practices such as hydraulic fracturing has increased the need for management and disposal options for flowback , long

- term produced water

, and other wastewater that is generat ed

. EPA is evaluating oil and gas extraction wastewater management practices, including CWT facilities accepting oil and gas extraction wastewaters. As part of this evaluation, EPA is collecting data from a variety of sources, including site visits at CWT facilities and other facilities that man a ge oil and gas extraction wastewater. The goals of these site visits are to evaluat e treatment technologies (including factors such as their cost and performance), evaluat e types and volumes of wastewater managed and the characteristics of these wastewaters, evaluat e residuals management practices, and understand the economic and financial factors affecting the industry.

EPA conducted a site visit at RES’s Mt. Pleasant facil ity to collect background information on the oil and gas extraction wastewater treatment industry and observe wastewater treatment operations. Before the visit , the EPA reviewed information about CWT facilities in Pennsylvania that accept oil and gas extra ction wastewater. During this review, the EPA identified RES as receiving oil and gas extra ction wastewater for treatment.

Andrew Kicinski of RES led the wastewater treatment operations discussion and tour of the facility. The remainder of this report summ arizes information discussed during the July 28

, 2014

, site visit and previous phone calls with EPA

.3

- 1

3.0 G ENERAL F ACILITY I NFORMATION

Andrew J. Kicinski, President of RES started CWT operations in 1997 in his Wheeling, WV facility, about 20 miles from the first Marcellus shale gas well . Currently

, Mr. Kicinski operates RES has three CWT facilities that primarily service the Marcellus shale industry :

 Mount Pleasant Facility (Mount Pleasant, PA)

— This plant has a 30,000 barrel per day capacity and accepts flowback, long

- term produced water, and drilling fluid wastewater. Contaminated stormwater from secondary containments within the facility is also collected and treated

.

 Butler Facility ( Renfrew, But ler County, PA)

— This plant has an 8 ,000 barrel per day capacity and accepts flowbac k and long

- term produced water.

 Liquid Assets Disposal (LAD) Facility (Wheeling, WV)

— Currently, this plant accepts only “low chloride” wastewater from oil and gas extra ction activities such as compressor station wastewater. Mr. Kicinski noted that the Wheeling facility has about a 10% hurdle rate.

RES has about 45 total employees with about 2 2 at the Mt. Pleasant facility, 1 5 of which are truck drivers. The Butler facility, a smaller operation, has about 8 employees, and the Wheeling facility has only 4 employees, because it does not operate 24 hours per day.

During EPA’s 12 June 2014 call, RES also noted that they intend to o pen one new facility in Pennsylvania and one new facility in Ohio, but did not provide exact dates for when either facility was expected to open. During the July 2014 site visit, RES reported that they have a permit for a facility near State College, PA , b ut it is not yet operating

. RES reported that their Mount Pleasant and Butler CWT facilities operate similarly such that all treated wastewater is returned to operators for reuse in hydraulic fracturing. The Mount Pleasant facility accepts conventional and unconventional oil and gas . The Butler facility accepts only unconventional oil and gas. LAD is a CWT facility that did accept waste from multiple industries including UOG operators and discharges treated wastewater to the Wheeling, WV publically owned treatment works (POTW). However, during the June 2014 call, RES reported that their LAD facility no longer accepts “high chloride” wastewater at their LAD facility. This facility now accepts only stormwater, compressor station wastewater, and other low chl oride wastewater streams from oil and gas operations.

RES indicated that the Mount Pleasant CWT facility

, located on 133 acres of land in southwest Pennsylvania

, was the state’s first CWT facility to treat UOG extraction wastewater. RES indicated that t he Pennsylvania Department of Environmental Protection (PA DEP) had no guidelines in place when RES applied for permits. As a result, many of the guidelines set in place today were formed through work between PA DEP and RES. The facility is permitted to
accep t only wastewaters from the oil and gas industry, and therefore does not accept any wastewaters from other industrial operations. At the time of the January 2012 call, the plant had been operating for 18 months, treating approximately 100 million gallons t o date.3

- 2

The Mt. Pleasant facility is the largest treatment facility operated by RES. The facility was originally part of a picture tube plant that had an existing wastewater treatment plant designed to remove metals, specifically antimony. The plant had be en shut down for five years when RES leased it in 2006

. RES spent $1.2 million converting the existing treatment plant to a zero discharge operation. RES indicated that it would cost approximately $7 million in capital costs to build an equivalent plant

. By comparison, the Butler facility cost about $3.5 million and is about 1/3 the size of the Mt. Pleasant facility. RES plans to continue expanding to meet demand, but stressed the importance of having an “anchor client” who can provide a commitment of busi ness to undertake expansion . Without such an arrangement, RES indicated that they will not establish new facilities. For example, a fifth RES location has been permitted for construction in Avis, PA near the State College Area

, however RES has not broken g round as they have yet to identify an anchor client.

Customers

During the 2012 conference call, RES explained that their Mount Pleasant customers include approximately 16 operators with wells located in Pennsylvania and West Virginia. Due to the high cost of trucking UOG wastewater more than one to two hours from the well site, RES’s Mount Pleasant facility has an approximate 60 to 90 mile radius of service area. Although customers will occasionally truck UOG wastewater f a rther distances, the recurring cust omers operate within a 90

- mile distance of Mount Pleasant, PA. This includes some portions of West Virginia. Specific operators mentioned included XTO, Atlas, Rice Energy , Range Resources, and Williams Energy Production

. Although RES’s customers include 16 operators 1 , RES explained how it is difficult to predict how much UOG wastewater they will treat on any given day. This is because the wells owned by their customers are in different stages of production and produce different volumes of UOG wastewater dep ending on the current production activities at the well. Typically, at any given time, there are at least 5 or 6 customers who are fracturing and deliverin g UOG wastewater for treatment.

As of the time of the site visit in July 2014, t he Mt. Pleasant facil ity had treated about 300 million gallons of wastewater since its opening in 2010. It has a maximum operating capacity of 1.2 million gallons/day (MGD) or 30,000 barrels/day . The facility accepts wastewater from unconventional oil and gas extraction operat ions

, but primarily from the Marcellus shale play and some from the Utica play

. RES indicated that a ccepted wastewater includes oil and gas extraction wastewater, produced waste water, compression station waste water, drilling
waste water
, conventional (coal

- bed methane) wastewater, flowback water, containment water, and sludge waste.

While the facility is zero discharge, they do have a NPDES permit (PA0254185) with PA DEP because they are categorized as a Major Industrial Waste site. PA DE P noted that they have zero discharge and have never had any DMR violations. All processed waste water is recycled to drill ing site s

.

1 SGE00246 contains a list of operators that dumped or recycled wastewater at the plant between 1 November 2011 and 31 December 2011.3

- 3

RES is an integrated business that owns 7 tru cks and vehicles that transport wastewater to and from their clients’ sites

. T he RES Mt. Pleasant facility has a 10

- million gallon

, double

- lined pond that allows their clients to store waste water onsite if needed. RES indicated that t his feature is an advantage for them because when drilling companies are in the process of moving th eir rigs

, there is a n approximately 60

- day window in which th ey do not need their recycled
waste water back. In addition

, RES Mt. Pleasant also has a 100,000

- gallon auxiliary reservoir tank for temporary storage. When both the pond and the auxiliary tank are full

, RES accepts additional wastewater in a barrel

- in/ barrel

- out mode

.

Services

The plant is a 100% recycle, zero discharge facility. This means that all of the influent wastewater is treated and returned to the field for reuse. The company offers two main services (dumping and recycling) and also provides temporary storage, if needed :

 D isposal

— Operators pay to drop a load of UOG wastewater off and truck le ave s empty

.

 Recycling

— Operators pay to drop off a load of UOG wastewater and pick up a load of treated UOG wastewater at the same time. They use the treated UOG wastewater for the next fracturing job. The price for this service is lower than dumping, but may involve signing a c ontract. This arrangement may be beneficial
to o perators because it can reduce trucking costs

.

 Temporary S torage

— RES operates a 10 million gallon holding pond and 100,000

- gallon auxiliary reservoir tank where an operator can pay to tempora ri ly store UOG wastewater.4

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4.0 P LANT P ROCESS F LOW D ESCRIPTION

Although t he facility has a maximum treatment capacity o f 1.2 MGD ( 30,000 barrels per day )

, it treats around 40 0,000 gallons on a typical day

. A process flow diagram provided by RES can be fou nd in Appendix C.

Most RES clients require treated wastewater with less than 5 mg/L of TSS, and about 150,000 ppm TDS. The facility noted that in previous years drill sites would not take back treated wastewater unless the TDS levels were between 60,000 to 100,000 ppm because operators were concerned about higher levels of friction reducers required by the recycled water. However, now they have more flexibility and will accept TDS levels between 1 5 0,000 an d 200 ,000 ppm.

The desired level of metals returni ng to the field varies by producer . Previously customers had criteria for taking back water including pH, b arium, s trontium, and 30 ,000 to 60,000 mg/L TDS due to friction reducers

. Current friction reducers now allow customers to take back a wider range of components in the recycled water. The following are some specific changes in water metals characteristi cs that customers will accept.

 Iron

– less than 1 mg/L ;

 Strontium

– previously needed to provide 50% removal ; however, strontium concentrations are no longer a concern ( perhaps due to down hole chemistry ch anges ) ;

 Sulfates

– previously wanted zero, but now will acce p t up to 10 0 mg/L ( concern is the formation of Ba SO4 , which can plug wells ); and

 Barium

– previously limited to less than 100 mg/L, but now 1

, 000 mg/L is acceptable

. RES also noted that less stringent requirements for barium have resulted in lower radioactivity in wastewater treatment residuals (sludge)

. The following descri bes each step in the RES treatment proce ss , along with photos from the site visit. Photos are not included for s ome treatment steps to comply with RES confidentiality request s.

Treatment S teps

1. Receiving and “Clearing House”

— RES collects a sample from e ach tank truck that enters the facility

, us ing a sampling port built into the top of the tank . The sample is analyzed before any of the wastewater enters the treatment system. The sampling effort typically requires three employees and operates 24/7. Tested parameters include :

 Flash t est to detect the p resence of “drip gas” (natural gas condensate) ;

 Oil and grease ;

 Total s uspended solids ;4

- 2  pH , and

 Conductivity ( Figure 1 )

.
Any wastewater that test s po sitive for drip gas is rejected as it is an explosion hazard. Facility personnel noted that currently about 1 out of 1

, 000 trucks test s positive (i.e.

, RES has not had a positive hit in 3 or 4 months)

, while a few years
ago drip gas was more common at about 1 out of 100 trucks. RES attributes this reduction to the d rillin g companies having learned to identify the presence of drip gas and having developed procedures to prevent it from leaving the drilling site

. RES indicated that c omp anies have adopted these procedures for two reasons : (1) to ensure that their wastewater is not rejected at the CWTs

, and (2) to retain the drip gas for sale because it has a current market value of $2.50/gallon

. During the January 2012 conference call, R ES noted that they do not accept the following materials :

 Condensates

— No hydrocarbons are allowed to be unloaded into the main treatment train. If possible, an RES worker will withdraw UOG wastewater from the bottom of a truck load leaving floating oils behind. Prior to January 2012, i f the customer desire d , they may have du mp ed the remaining oil in a hydrocarbon recovery tank located on site. Periodically RES deliver ed the content of this recovery tank to a different company who processe d the material to produce fuel. RES terminated this practice January 2012 and no longer accepts any condensates or oils.

 Synthetic Drilling Fluid Wa stewater

— Drilling fluids with a synthetic oil base. Treatment of this fluid requires a special treatment unit that RES does not have. RE S made it clear that this fluid is not accepted at their plant. They also mentioned this fluid is very valuable and costs $13 per gallon. Synthetic muds may be picked up from a well site by truck driver s thinking it is a waste fluid.

Once the truck load h as been approved

, all paperwork, manifests, and analytical data are entered into a tracking database. Approximately 2 0 minutes are required for testing and offloading

, and another 10 minutes are required for the truck to reload for a total of 30 minutes wi th treated waste water and leave. The facility has three lines for unloading wastewater. All trucks are equipped with GPS systems that track how long each process takes and helps the facility stagger loading and offloading.4

- 3 Figure 1

. Mr. Kicinski Testing for Conductivity in the Receiving Area

2. Sedimentation Tanks

— Wastewater is pumped through a series of three lines of sedimentation tanks ( “ rock boxes ” ). The facility operates two of these tanks, in parallel. The parallel tank set up allows for t hree trucks to offload wastewater at the same time. Each sequential box removes smaller and smaller pieces of sediment. According to Mr. Kicinski

, about 80 to 100 tons of rocks and sediment

are collected every 3 months and are disposed of at landfills

. R ocks are removed from the bottoms of the tanks while residual oil is skimmed from the top of the tanks and recycled as waste oil . The water is withdrawn from the middle layer and is sent to a flash mix box.

3. Flash Mix Box

— The flash mix box has a detention time of 2 minutes. Chemicals (e.g., sodium hypochlorite , sodium hydroxide) are added to assist in removal of iron and other metals. The treatment chemicals added depend on the treatment requirements for each batch of waste water. Sodium hydroxide is added to adjust the wastewater pH

, and sodium hypochlorite is added for disinfection

. R aw waste water pH generally ranges between 5 and 6 and is adjusted to 8.5 to 9.0.

4. Equalization and Aeration Tanks

— After chemicals are added

, wastewater is pumped to two 100,000

- gallon e qualization/ aeration tanks operated in parallel to precipitate dissolved iron and other metals

. Aeration is achieved using p ositive displacement blowers and a diffuser at the bottom of the tanks. Th e s e tank s also provide wastewater storage capacity as needed.

5. Reaction Tanks

— RES operates three 7 ,000

- gallon reaction tanks in series

, to coagulate and flocculate precipitated metals ( Figure 2 and Figure 3 ). C oagulant is4

- 4 added to the first tank and polymers are added to the second two tanks . At this point

, the pH of the waste water is between 7.7 and 8.0. RES noted that the
waste water in the reaction tanks is analyzed every 2 hours for pH and percent solids, and to adjust the levels of additives ( Figure 4 )

. Treatment chemicals used in the reaction tanks include polyaluminum chloride and sodium sulfate (for barium removal).

Figure 2

. Green Piping Transports W astew ater to the Three Reaction Tanks4

- 5 Figure 3

. View of the Three R eaction Tanks f rom Above

Figure 4

. Bench Setup in the Wet Chemistry Lab4

- 6

6. Clarifiers

— T wo 110 ,000

- gallon parallel tanks ( Figure 5 and Figure 6 ) provide a 4

- hour retention time for sludge settl ing

.

Figure 5 . Parallel Clarifiers Figure 6 . Parallel Clarifiers

7. Filter Feed Tank

— Anti

- foam ing agent s and sodium hy pochlorite are added to the wastewater entering the filter system ( Figure 7 )

. At this stage

, any crude oil that appears at the surface is periodically skimmed from the surface . RES collects about 1 quart of crude oil for every 500,000 gallons of waste water treated (i .e. , about 1 quart per day). The collected crude oil is recycled as part of waste oil

.

Figure 7

. Filter Feed Tank w ith S ome Crude Oil Floating at the Surface4

- 7

8. Coal Filters

— After skimming, the clarified wastewater passes through a n anthracite coal filter to remove total organic carbon and suspended solids ( Figure 8 )

. RES operates three 4

- foot deep filters in parallel. Each filter lasts about a year before regeneration. There is an additional chlorination step following the filtration process.

Figure 8

. Two of the Three Parallel Coal Filters

9. Final S ampling

— An automatic sampler takes an aliquot from the anthracite coal filter effluent stream every hour . RES staff uses a portable GC/MS to measure the hydrocarbon content and BTEX

. TOC is also analyzed. In addition to verifying the quality of the treated effluent, the GC/MS results help inform changes in treatment chemical dosages fo r the entire treatment system. Chemistry is adjusted every two hours, if needed.

10. Reservoir Tank/Pond

— Treated wastewater is routed to t he 100,000

- gallon reservoir tank , which hold s the treated waste water before it is pumped onto trucks . T he 10 million gallon storage pond is used to store treated waste water for longer periods of time ( Figure 9 and Figure 10 )

.4

- 8

Figure 9

. Mr. Kicinski Collecting a W astew ater Sample f rom the Reservoir Tank

Figure 10

. Close Up View of the Treated W astew ater from the Reservoir Tank in the

F oreground and Red Frac Tank in the Background

11. Frac Tanks

— RES uses 500 BBL (21,000 Gallon) frac tanks to store treated effluent withdrawn from the storage tanks before it is loaded into trucks

. O ne frac tank is located after the reservoir tank (Figure 10) and two are located after the pond.4

- 9

12. Sludge Thickening Tank

— The sludge collect ed from the bottom of the circular clarifiers described in S tep 6 is sent a sludge thickening tank ( Figure 11 )

.

Figure 11

. Sludge Thickening Tank

13. Sludge Dewatering Box/Filter Press

— RES uses either dewatering tanks to
store s ludge and allow it to dry through evaporation or uses a filter press to further dry the sludge (Figures 12) . Solids and sludges are solidified using cement kiln dust before disposal at a landfill , if needed

. RES indicated that the sludge is generally composed of 23 percent suspended solids . The remaining liquid is composed of sodium chloride, calcium chloride , and has a small magnesium chloride component ( s ee Error! Reference source not found. 3 and 1 4 )

.

* Photo was provided by the facility in February 2015 following the site visit.

Figure 12

. Sludge Filter Press4

- 10 * Photo was provided by the facility in February 2015 following the site visit. Figure 13

. Inside View of the Sludge Dewatering Tank

* Photo was provided by the facility in February 2015 following the site visit. Figure 14

. Close

- Up View of Sludge Cake5

- 1

5.0 C OSTS

RES offers recycling of wastewater and temporary storage of treated wastewater at their Mt. Pleasant facility

. Operators pay to have wastewater picked up and treated wastewater delivered to their sites. RES charges a flat rate of $4.00 per barrel to recycl e wastewater (i.e., for every barrel of wastewater brought in, a barrel of treated wastewater is returned to the operator) and $7.00 per barrel for final disposal (i.e., treated wastewater is not returned to the operator that brought it in 2 ). RES adds a su rcharge to wastewater that contains more than 2 percent solids to account for increased landfill costs. RES provides treated wastewater to the end user at no additional charge.

2 In January 2012, RES reported cost for dumping wastewater was $5.25/barrel.6

- 1

6.0 A DDITIONAL I NFORMATION

 In addition to the wet chemistry laboratory, t he facility also has a portable mass spectrometer used to analyze treated effluent for an array of pollutant s every hour

. RES uses this analysis to ensure the treatment system is operating properly and to guarantee the quality of the waste wate r leaving t he facility.

 Mr. Kicinski noted that in his experience producers have no interest in running their own CWTs and all prefer to contract out their waste water treatment because their operations are mobile. While there are mobile CWT units

, he indi cated that they have many disadvantages such as inability to operate in the winter time; inability to handle sludge; and lack of capacity to handle the range of wa stewater volumes generated

.

 Mr. Kicinski noted that a bout 20 companies are currently drillin g wells in the

area . Installation and development of each well cost s about $ 4

- 6 million.

 Mr. Kicinski noted that RES actively screens all trucks entering the facility for radioactivity using a Geiger counter. Although they know that radioactive isotopes are present in the wastewater

, they have measured very little activity

. RES has contracted with Pace Laboratories to test treated wastewater and wastewater treatment sludge for r a dium 226. RES has never detected any radium 226 in the treated waste water usi ng a Ludlum meter

, but they have found measureable amounts in the clarifier sludge. RES personnel believe that the radium is removed along with the barium

, and because the sulfate added to the clarifiers precipitates out the barium , radium also precipitate s

. All RES sludge is disposed of at municipal landfills. At the time of the site visit, RES use d five different landfills for sludge disposal and indicated that they have had no issue s meeting their radioactivity limits. The receiving landfill requires that RES test the sludge for radioactivity

. In January 2012, RES reported that radioactivity was detected in the sludge waste typically around 80 mrem per hour, below the landfill’s limit of 1 4 0 mrem per hour for accepting waste. During the July site visit , RES explained that o il and gas operators are becoming more willing to accept higher levels of barium in the treated waste water . For this reason, the CWT generates less barium precipitate

, and the sludge from wastewater treatment contains decreasing conce ntrations of radium and radioactivity, as well.

 In addition to its wastewater treatment operations, RES Mt Pleasant also purchases freshwater at 0.5 center per gallon, which they sell to customers for 1.5 cents per gallon.

 Treated waste water that leaves the facility is accompanied with monitoring data that can include pH, iron, sulfate, barium, strontium, conductivity, chlorine residual, TOC, TDS, and TSS. Generally, the parameters are dictated by each individual operator.

 During a standard 400,000

- gallon per day treatment flow rate , approximately 3 0
to 4 0 tons of solids are captured in the sludge and disposed of at a landfill

.6

- 2 Residuals are tested every 6 months using toxicity characteristic leaching procedure to evaluate for toxicity.7

- 1

7.0 A DDITIONAL I NFORMATION P ROVIDED DURING C ONFERENCE C ALLS

 During the January 2012 call, RES commented that they have maintained detailed manifest records (see Appendix B for an example ) since they first started operations. These records i nclude well operator name, well name, type of UOG wastewater, and volume of UOG wastewater. They also have adopted a strict policy that truckers who deliver UOG wastewater must provide detailed proof of identification.

 During the June 2014 call, RES and EPA discussed characteristics of UOG drilling fluid wastewater. RES explained that there are three types of drilling fluid wastewater streams generated during drilling:

— Top hole;

— Water

- based; and

— Synthetic oil

- based.

Top hole water is generated when UOG operators use “air rigs” to drill through aquifer layers and is usually representative of groundwater. Water

- based and synthetic based fluids are generated when operators use larger rigs to drill the remaining length of the wellbore. RES reported that they treat only top hole and
water

- based drilling fluids at their CWT facilities.

During the drilling process, RES explained that cuttings are removed from drilling fluids when they return to the surface so that the drilling fluids can be recirculated down ho le. Operators remove the cuttings using technologies such as shale shaker tables and centrifuges. RES described characteristics of drilling fluid wastewater after the operator removes cuttings, which is also typically how RES receives the
wastewater.Appendix A LIST OF PARTICIPANTS ON THE RES SITE VISITA

- 1 Table A

- 1. List of Attendees

First Name Organization Phone Number Email
Lisa Biddle U.S. EPA (202) 566

- 0350 Biddle.Lisa@epa.gov
Joel Blanco

- Gonzalez U.S. EPA Region 3 (215) 814

- 2768 Blankco

- gonzalez.joel@epa.gov
Katie Boone PADEP (724

- 92505423 Kaboone@pa.gov
Jan Goodwin U.S. EPA (202) 566

- 1060 Goodwin.Janet@epa.gov
Nick Haden RES (412) 784

- 3399 nhaden@reswater.com Adrain Hanley U.S. EPA (202) 564

- 1564 Hanley.Adrian@epa.gov Cortney Itle ERG (703) 424

- 8360 Cortney.Itle@erg.com
Andrew Kicinski RES (724) 454

- 1611 A Kicinski @reswater.com
Michael Kaufman PADEP (724) 925

- 5404 mkaufman@pa.gov Pam McQuistian PADEP (412) 680

- 6793 pmcquistia@pa.gov
Karen Milam U.S. EPA (202) 564

- 9752 Milam.Karen@epa.gov
Jesse Pritts U.S. EPA (202) 566

- 1038 Pritts.Jesse@epa.gov
Kathleen Wu ERG (703) 633

- 1625 Kathleen.Wu @erg.comAppendix B

SAMPLE OF RES MANIFEST RECORDS (MOUNT PLEASANT FACILITY)B

- 1Appendix C

-- RES MOUNT PLEASANT, PA PLANT PROCESS FLOW DIAGRAMC

- 1