MEMORANDUM

TO: Lisa Biddle, EPA

FROM: James K. O’Connell, ERG

Brent Ruminski, ERG

DATE: March 31, 2015

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

Extraction Wastewater (DCN SGE00596)

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

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

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

(DCN SGE00704). This memorandum focuses on information included in Chapter D.4 of the 

TDD and describes the sources and methodologies used to create Figure D-8 and Table D-6 in 

the TDD. This memorandum is organized into the following sections:

 Section 1.0 discusses background information about CWT facilities that accept

UOG extraction wastewater.

 Section 2.0 describes the primary references and methodology that were used to 

create a list of CWT facilities that accept or plan to accept UOG wastewater and a 

description of how ERG created Figure D-8 and Table D-6 in the TDD using this 

list of CWT facilities.

 Section 3.0 describes ERG’s quality assurance procedures.

 Section 4.0 lists the references used for these analyses.

Attachment 1 presents the Microsoft Excel spreadsheet attachment that contains the 

underlying data and analyses used to create the TDD tables and figures discussed in this 

memorandum. 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. Appendix F in the TDD contains a crosswalk of all tables and figures in 

the TDD and the name of the relevant supporting memorandum, where applicable.

This memorandum will refer to the following terms also used throughout the TDD, the 

supporting memoranda, and memoranda attachments: 

 Unconventional oil and gas (UOG) resources

1

- crude oil and natural gas2

produced by a well drilled3into a low porosity, low permeability formation.

 

1 UOG resource types are categorized into shale and tight formations.

2 Natural gas can include “natural gas liquids,” components that are liquid at ambient temperature and pressure.

3 UOG wells may be drilled using horizontal, vertical, or directional well trajectories. Literature sometimes refers to 

well trajectory as “drill type”.
Memorandum

March 31, 2015

Page 2

 UOG extraction wastewater - sources of wastewater pollutants associated with 

production, field exploration, drilling, well completion, or well treatment for 

unconventional oil and gas extraction.

4 UOG extraction wastewater includes 

produced water, drilling wastewater, and produced sand5.

 Drilling wastewater – The liquid waste stream separated from recovered drilling 

fluid (mud) and drill cuttings during the drilling process. Drilling fluid is the 

circulating fluid used in the rotary drilling of wells to clean and condition the hole 

and to counterbalance formation pressure.

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

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

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

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

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

1. Flowback –the produced water generated in the initial period after hydraulic 

fracturing prior to production (i.e., fracturing fluid, injection water, any 

chemicals added downhole, and varying amounts of formation water).

2. Long-term produced water (LTPW) –the produced water generated during the 

production phase of the well after the initial flowback process (includes 

increasing amounts of formation water).

1.0 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 

where other wastewater disposal options (e.g., Class II disposal wells) are not available or are not 

as cost effective in the region where they are operating (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:

 

4

Stormwater is not considered a source of UOG extraction wastewater. In general, no NPDES permit is required for 

discharges of stormwater from any field activities or operations associated with oil and gas production, except as 

specified in 40 C.F.R. 122.26(c)(1)(iii) for discharges of a reportable quantity or that contribute to a violation of a 

water quality standard. States may impose additional requirements for management of drilling site stormwater. 

5 Drilling wastewater and produced sand are not discussed in this memorandum. Additional information about 

drilling wastewater can be found in ERG’s Unconventional Oil and Gas (UOG) Drilling Wastewater memorandum 

(DCN SGE00740).
Memorandum

March 31, 2015

Page 3

 Non-TDS removal technologies – Technologies that remove non-dissolved6

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 waters of the 

U.S. (surface waters) or to a POTW. These CWT facilities typically return the treated 

wastewater to the UOG operator for reuse/recycle in fracturing.7

 Discharge – CWT facilities that discharge treated wastewater to waters of the U.S. 

(surface waters), either directly or indirectly via a POTW.

 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-8 and Table D-6 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 Figures D-8 and Table D-6 in the TDD.

 

6 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.

7 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

March 31, 2015

Page 4

The “O&G CWT List” tab in Attachment 1 to this memorandum (DCN SGE00596.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 Discussion of Primary References Used to Identify CWT Facilities Accepting UOG 

Extraction Wastewater

ERG primarily used state agency websites supplemented with miscellaneous sources 

(e.g., CWT facility websites) to compile CWT facility information. ERG listed all of the sources 

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

SGE00596.A01) in Section 4.0 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 SGE00188), 

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 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 

(DCN SGE00739) 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 facilities8in Wyoming and publishes a 

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

SGE01004).

 

8

“Disposal facility” is a term used directly by WY DEQ. Based on the facilities listed by WY DEC, this term 

includes types of facilities outside the scope of this analysis such as evaporation pond facilities in addition to 

wastewater treatment facilities.
Memorandum

March 31, 2015

Page 5

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

and surface waste facilities9 with permit number and expiration date information.

Commercial recycling and surface waste facilities are organized into the 

following groups: Recycling10, Pits11, Stationary Treatment Facilities12, 

Landfarm/Landtreatment Facilities13, and Reclamation Plants14 (DCN 

SGE01005).

 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.15

2.1.3 Miscellaneous

ERG also conducted internet searches and reviewed information from technical 

presentations related to UOG to identify CWT facilities not reported by state agencies. 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.16 These sources are noted in Attachment 1 to this memorandum (DCN 

SGE00596.A01), and a complete list of sources can be found in Section 4.0 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 SGE00596.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 

 

9

“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.

10 Store, handle, treat and reuse fresh water, water-based drilling fluids, and oil-based drilling fluids, and cuttings for 

the reuse for the following load bearing structures: lease roads, drilling pads, tank batteries, compressor station pads, 

and county roads.

11 Dispose of water base drilling fluid and associated cuttings (maximum chloride concentration of 3,000 mg/l).

12 Treat non-hazardous oil and gas wastes, including oil and gas waste.

13 Dispose of non-hazardous oil and gas waste, including water base drilling fluid and associated solids, oil base 

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.

14 Receive, store, handle, treat and dispose of certain non-hazardous oil and gas wastes.

15 ERG did not include CWT facilities that only accept COG extraction wastewater.

16 ERG did not include CWT facilities that only accept COG extraction wastewater.
Memorandum

March 31, 2015

Page 6

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 SGE00596.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, 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 oil and gas companies. 

“Commercial” is shorthand used to indicate that the facilities generally are not owned and 

operated by oil and gas companies and “operator” is used to describe facilities that 

generally are owned and operated by oil and gas companies.

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)

Discharge Type

If the CWT facility discharges, this field indicates whether it discharges indirectly (i.e., 

through a POTW) or directly (i.e., to waters of the U.S.). 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 nonTDS 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 nonTDS 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.
Memorandum

March 31, 2015

Page 7

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

(DCN SGE00596.A01)

Field Name Description

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-8 and Table D-6

This section explains how ERG created Table D-6 and Figure D-8 in the TDD using data 

from the “O&G CWT List” tab in Attachment 1 to this memorandum (DCN SGE00596.A01). 

2.3.1 Table D-6 in the TDD. Number, by State, of CWT Facilities That Have Accepted or 

Plan to Accept UOG Extraction Wastewater

To create Table D-6 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 

SGE00596.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.

17 The “Summary by State” tab in Attachment 1 to this 

memorandum (DCN SGE00596.A01) shows the total number of CWT facilities by state, CWT 

facility type, and treatment level. Although ERG searched for CWT facilities by a number of 

different methods, the information presented may not be exhaustive. ERG searched for more 

states than what are shown in TDD Table D-6 and only presented data for the states with useful 

information. Because there is no national inventory of CWT facilities and few states maintain 

comprehensive lists of CWT facilities, Table D-6 in the TDD likely underestimates the number

of CWT facilities accepting UOG extraction wastewater.

18

Table D-6 also presents the 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-8 in the TDD. Number of Known Active CWT Facilities over Time in the 

Marcellus and Utica Shale Formations

ERG created Figure D-8 in the TDD using some of the CWT facilities in the “O&G CWT 

List” tab in Attachment 1 to this memorandum (DCN SGE00596.A01) along with Ohio spud19

data (DCN SGE00561), West Virginia spud data (DCN SGE00407), and Pennsylvania spud data 

(DCN SGE00712). ERG used the following steps:

Step 1 – Count the Facilities

 

17 If a facility had TDS removal technologies, even if it did not always use the TDS removal, ERG still assigned it as 

“TDS removal”.

18 It is also possible that some CWT facilities in Table D-6 have closed since ERG identified them.

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

March 31, 2015

Page 8

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 2013 in Pennsylvania, Ohio, and West Virginia.

20 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 SGE00596.A01)21.

ERG also included facilities that were planning but not yet accepting 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 data22 from Pennsylvania, Ohio, and West Virginia; 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 2013 (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 SGE00596.A01). 

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

Data Report” (DCN SGE00712). 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 SGE00596.A01). ERG accessed this database and downloaded 

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

23 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 SGE00407). 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 

SGE00596.A01). ERG searched the database and downloaded well records that were 

associated with the “Marcellus shale” formation.24 ERG selected wells flagged in the 

“status field” as active well, drilling, plugged, or under construction.25 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 

 

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

contain limited Marcellus/Utica shale resources.

21 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.”

22 These were spud databases. “Spud” is an industry term for the commencement of drilling a new well (DCN 

SGE00763).

23 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.

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

25 Blank status fields were also included but only if there was a valid completion date provided.
Memorandum

March 31, 2015

Page 9

permitted to be drilled into the Utica shale formation in Ohio (DCN SGE00561). 

ERG downloaded this spreadsheet and included the results in the “OH Wells” tab in 

Attachment 1 to this memorandum (DCN SGE00596.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 SGE00596.A01), which is also 

Figure D-8 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 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 proposed 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 proposed rulemaking. ERG used a 

combination of sources, including reports, papers, and online databases from state regulatory 

agencies such as departments of environmental protection and oil and gas commissions. As 

shown in Table 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 verified26 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 

 

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

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

author’s affiliation with the UOG industry. 
Memorandum

March 31, 2015

Page 10

 Source Flag D – Documents prepared by a source that could not be verified and that 

do not include citation information.

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

 An ERG senior staff member familiar with Effluent Limitation Guidelines (ELGs)

and the UOG proposed rulemaking reviewed the results from the CWT Facility 

List and Analysis spreadsheet provided in Attachment 1 to this memorandum

(DCN SGE00596.A01).

4.0 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: Argonne National Laboratory: E. 2010. Water Management Technologies 

Used by Marcellus Shale Gas Producers.

A

SGE00139 John Veil. 2006. Offsite Commercial Disposal of Oil and Gas Exploration and 

Production Waste: Availability, Options, and Costs. Argonne National Laboratory. A

SGE00182 Clark, C.E., et. Al. 2009. Produced Water Volumes and Management Practices in the 

United States.

A

SGE00188 O'Connell, James, ERG.2014. Pennsylvania Department of Environmental Protection’s 

(PA DEP) Statewide Oil and Gas Waste Reports. (December).

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, Tom. 2012. Barnett and Appalachian Shale Water Management and Reuse 

Technologies 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 US EPA. 2012. Site Visit Report US Gas Field Fluids Management

(formerly Clean Streams) Marcellus Shale Gas Operations. A

SGE00300 US EPA. 2012. Site Visit Report Eureka Resources, LLC Marcellus Shale Gas 

Operations. A
Memorandum

March 31, 2015

Page 11

Table 2. References

DCN Full Citation

Source 

Flaga

SGE00363 Alanco Energy Services, Inc. 2012. New Subsidiary Alanco Energy Services, Inc. To 

Provide Produced Water Disposal Services to Natural Gas Industry. Available online at: 

http://www.alanco.com/news_040912.asp

C

SGE00364 Alanco Energy Services, Inc. 2012. Alanco Energy Services, Inc. Commences 

Commercial Operation of New Colorado Oil & Gas Produced Water Treatment Facility. 

Available online at: http://www.alanco.com/news_081512.asp

C

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

Texas).Available online at: http://www.aqua-pure.com/operations/shale/ford/ford.html C

SGE00366 Clarion Altela Environmental Services (CAES). Unknown. Clarion Altela 

Environmental Services. Available online at: http://caeswater.com/ C

SGE00367 CARES. Unknown. CARES McKean. Available online at: 

http://www.caresforwater.com/location/cares-mckean C

SGE00368 US EPA Region 3. 2012. Key Documents About Mid-Atlantic Oil and Gas Extraction. 

Available online at: http://www.epa.gov/region3/marcellus_shale/ A

SGE00369 Anticline Disposal, LLC. Unknown. Anticline Disposal, LLC. Available online at: 

http://www.highsierrawater.com/high-sierra-water/ A

SGE00374 Red Desert. Unknown. Red Desert: Facilities. Available online at: 

http://reddesertwater.com/facilities.html C

SGE00375 Rigzone. 2011. Sionix to Build Bakken Water Treatment Plant. Available online at: 

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. SRWR: Our Services. Available 

online at: http://www.srwr-pa.com/services2.html C

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

Comments of Waste Management. Available online at: 

http://www.state.nj.us/drbc/library/documents/NGC/Industry/WasteManagement041411.

pdf

C

SGE00379 Wyoming Energy. 2012. The Future is NOW for Water Recycling in the Niobrara. 

Available online at: http://wyomingenergynews.com/2012/11/the-future-is-now-forwater-recycling-in-the-Niobrara/C

SGE00407 West Virginia Department of Environmental Protection (WVDEP). 2012. Oil and Gas 

Well Search. Accessed on 12/21/2012. Available online at: 

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

A

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

the Barnett Shale Regions Report No. 08122-05.09. Research Partnership to Secure 

Energy for America (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. Kadramas, Lee & Jackson, Inc. B

SGE00481 McCutcheon Enterprise, Inc. 2013. Waste Reduction: A Greener Alternative for 

Treating Drilling Muds. McCutcheon Enterprise, Inc. C
Memorandum

March 31, 2015

Page 12

Table 2. References

DCN Full Citation

Source 

Flaga

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

Waste Management Eastern Group. C

SGE00488 Yogesh Patel. 2012. WV0116441 Reserved Environmental Services Ohio County. West 

Virginia Department of Environmental Protection. 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

SGE00561 Ohio Department of Natural Resources (OH DNR). 2013. Utica/Point Pleasant Shale 

Cumulative Permitting Activity through 12/07/2013. Downloaded on 12/12/2013. Last 

updated on 12/6/2013.

A

SGE00568 Pennsylvania Department of Environmental Protection (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 Produced and Frac Flow-back Water in Gonzalez County, Texas. 

Company Website.

C

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

SGE00588 TerrAqua Resource Management (TARM). Unknown. Solutions. Company website 

accessed on 10/28/2013. C

SGE00596.A01 ERG. 2015. Analysis of Centralized Waste Treatment Facilities (CWTs) Accepting UOG 

Wastewater Attachment 1: UOG CWT List and Analysis.

A

SGE00601 U.S. Environmental Protection Agency (U.S. EPA). 2001. Small Entity Compliance 

Guide: Centralized Waste Treatment Effluent Limitations Guidelines and Pretreatment 

Standards (40 CFR 437). EPA 821-B-01-003.

A

SGE00616 U.S. Environmental Protection Agency (U.S. EPA). 2013. Summary of the Technical 

Workshop on Wastewater Treatment and Related Modeling. April 18. A

SGE00625 US EPA. 2015. Site Visit Report Southwestern Energy Fayetteville Shale Operations. 

Sanitized. A

SGE00635 U.S. Environmental Protection Agency (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. Environmental Protection Agency (U.S. EPA). 2013. Summary of the Technical 

Workshop on Water Acquisition Modeling: Assessing Impacts Through Modeling and 

Other Means. September.

A
Memorandum

March 31, 2015

Page 13

Table 2. References

DCN Full Citation

Source 

Flaga

SGE00704 U.S. Environmental Protection Agency (U.S. EPA). 2015. Technical Development 

Document for Proposed Effluent Limitations Guidelines and Standards for Oil and Gas 

Extraction. Office of Water Engineering and Analysis Division.

A

SGE00710 Slutz, James et al. 2012. Key Shale Gas Water Management Strategies: An Economic 

Assessment Tool SPE 157532. Society of Petroleum Engineers. (September 11). B

SGE00711 Devon Energy. Unknown. Cana Water Reuse Project Helps Devon Overcome Drought. C

SGE00712 Pennsylvania Department of Environmental Protection. 2014. Spud Data Report. 

Accessed on 2/21/2014. A

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

SGE00730 Aspen Fluid Logistics. 2014. Aspen Fluid Logistics: Industrial Wastewater Recycling. 

Accessed on 4/15/2014. C

SGE00739 ERG. 2015. Analysis of Pennsylvania Department of Environmental Protection’s Oil and 

Gas Waste Reports. A

SGE00763 Pennsylvania Department of Environmental Protection (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 Eastern Research Group, Inc. 2013. Environmental Engineering Support for Clean Water 

Regulations Programmatic Quality Assurance Project Plan (PQAPP). October 1.

A

SGE00958 Eastern Research Group, Inc. 2014. Unconventional Oil and Gas (UOG) Supplemental 

Quality Assurance Project Plan (SQAPP). August 15. A

SGE01004 Wyoming Department of Environmental Quality. 2014. Permitted Commercial Oil 

Disposal Facilities. (March 19). Retrieved from http://deq.state.wy.us/wqd/www/ A

SGE01005 Railroad Commission of Texas. 2014. Commercial Recycling & Surface Disposal 

Facilities. (July 22). Retrieved from http://www.rrc.state.tx.us/oil-gas/applications-andpermits/environmental-permit-types-information/A

SGE01092 Fairmont Brine Processing. 2012. Company Website. Retrieved from: 

http://fairmontbrine.com/ C

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 SGE00596.A01)