### 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 SGE 00 596 )

T his memorandum describes the data and methods used to compile information on centralized waste treatment (CWT) facilities fo r the Technical Development Document for Proposed Effluent Limitations Guidelines and Standa rds for Oil and Gas Extraction (TDD) ( DCN SGE00704 ). T his memorandum focuses on information included in Chapter D .4 of the TDD and describes the sources and methodologies used to create Figure D

- 8 and Table D

- 6 in the TDD. This memorandum is organiz ed 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 a nd a description of how ERG creat ed Figu re 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 th e s e 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 wi ll refer to the following terms also u sed throughout the TDD , the supporting memoranda, and memoranda attachments :

 Unconventional oil and gas (UOG) resources 1

- crude oil and natural gas 2 produced by a well drilled 3 into 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 sa nd 5

.

 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

an d to counterbalance formation pressure.

 P roduced 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 fracturi ng 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 O VERVIEW OF CWT F ACILIT IES T HAT A CCEPT UOG E XTRACTION W ASTEWATER

Information in the record indicates that s ome UOG well operators utilize centralized waste treatment (CWT) facilit ies to man age 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 S GE00139; DCN S GE00182 ). EPA defines a CWT facilit y 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 tech nologies that are not designed
to reduce the level of the total dissolved solids (TDS) . F or treatment prior to discharge

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

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 qu ality 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 Unco nventional Oil and Gas (UOG) Drilling Wastewater memorandum (DCN SGE00740).Memorandum

March 31 , 2015 Page 3

 Non

- TDS removal technologies

– Technologies that remove non

- dissolved 6

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 u p more than 50 percent o f the TDS in UOG extraction wastewater, as well as some other dissolved constituents that contribute to TDS.

 TDS removal tech nologies

– T echnologies 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 the se types of CWT facilities.

 Zero D ischarge

– CWT faci lities that do not discharge wastewater to waters of the U.S. ( surface water s) 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., D ischarge, Zero Discharge)

– CWT facilities that have the option of d ischarging treated w astewater, 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 C OMPILATION OF CWT F A CILITY D ATA

Th e following sub section s 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 di ssolved 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 typic ally 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 undergro und injection wells ( DCN SGE00 374).Memorandum

March 31 , 2015 Page 4

The “O&G CWT List” tab in Attachment 1 to this memorandum (DCN SGE00596.A 0 1) contains the full list of CWT facilities that accept or plan to accept UOG extraction wastewater of which ERG is aware . This tab includes all of the relevant information associated with these CWT facilities that ERG found in the available data source s desc ribed in Section 2.1 in this memorandum

.

2.1 Discussion of Primary References Used to Identify CWT Facilities Accepting UOG

Extraction Wastewater

ERG p rimarily used state agency websites supplemented with miscellaneous sources (e.g., CWT f

acility websites ) to compile CWT facility information

. ERG listed a ll of the sources used to de velop the “O&G CWT List ” tab in A ttachment 1 to this memorandum (DCN SGE00596.A 0 1 ) in Section 4.0 of this memorandum

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

.

2.1.1 Pennsylvania Department of Environmental Protection (PA DEP)

ERG compiled information from the Pennsylvania Department of Environmental Protection (PA DEP) statewide data downloads (i.e., waste reports data) (DCN SGE00188)

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

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

, including the facility name, permit number, and location

. ERG used the statewide data downloads to compile a list of CWT f acilities that have accepted UOG extraction wastew ater generated by UOG wells in Pennsylvania

. In some instances, t h e PA DEP statewide data downloads also capture d waste facilities located in states other than Pennsylvania . This occurred when the operator hauled 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 ab out the PA DEP statewide data downloads

.

2.1.2 Other State Websites

ERG searched for lists of CWT f acilities published by other state agencies to identify CWT f acilities that accept or plan to accept UOG extraction wastewater

. ERG identified the following s tate agency sources :

 Wyoming Department of Environmental Quality (WY DEQ) permits all commercial oilfield wastewater disposal facilities 8 in Wyoming and publishes a list of these facilities that includes the facility name, operator, and address (DCN SGE0 1004)

.

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 additio n to wastewater treatment facilities.Memorandum

March 31 , 2015 Page 5

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

and surface waste facilities 9 with permit number and expiration date information. Commercial recycling and surface waste f acilities are organized in to the following groups: Recycling 10 , Pits 11 , Stationary Treatment Facilities 12

, Landfarm/Landtrea t ment Facilities 13 , and Reclamation Plants 14 (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. Usi ng 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.A 0 1), and a complete list of sources can be found in Section 4.0 in th is memorandum

.

2.2 Generation of the List of CWT Facilities

The “O&G CWT List” tab in Attachment 1 to this memorandum ( DCN SGE00596.A 0 1) 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 S tore, handle, trea t and reuse fresh water , water

- based drilling fluids, and oil

- base d 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 D ispose of w ater base drilling fluid and associated cuttings (maximum chloride concentration of 3,000 mg/l).
12 T reat non

- hazardous oil and gas wastes, including oil and gas waste

. 13 D ispose of non

- hazardous oil and gas waste, including water base drilling fluid and as sociated 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.A 0 1)

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

o rganizational n ame of the CWT facility o perator Formation The name of the formation served by the CWT facility Facility City The municipality in which the CWT f acility is located Facility State The s tate in which the CWT f acility is located Latitude The latitude value, in decimal degrees, for the CWT facility location Longitude The longitude value, in decimal degrees, for the CWT facility location Lat Long Comment ERG’s notes on the source or specific address of the latitude and longitude coordinates

Permit Number The NPDES permit number of the CWT facility. If no NPDES permit number applies or no permit was available, other types of permit numbers may be used in this field.
First Operational Year The first year each CWT facility accepted UOG wastewater. If the CWT had not begun accepting UOG wastewater, but had plans to, ERG noted th ese as “pending ” Not Yet Constructed Indicator An “x” indicates that the CWT facility had not yet been constructed

Commercial or Operator Indicates whether the CWT facility is owned and operate d by oil and gas companies. “C ommercial” is shorthand used to indicate that the facilities generally are not owned and operated by oil a nd gas companies and “ operator ” is used to describe facilities that generally are owned and operated by oil and gas companies.

CWT Fac ility Type The type of CWT facility, classified according to the type of discharge used for treated
wastewater (i.e., zero discharge, discharge, multiple discharge options )

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

TDS removal. Filtration or Chemical Precipitation An “x” indicates a CWT facility that use s filtration and/or chemical precipitation

. ERG categorized this as non

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

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

RO An “x” indicates a CWT facility that use s reverse osmosis (RO) . ERG categor ized this as TDS removal. Other Indicates the type of “other” treatment that is used at the given CWT facility Accepts WW From Other Industries Yes/No indicator about w hether or not the CWT facility accepts wastewater from in dustries other than oil and gas extraction Design/ Permitted Capacity (gpd) Indicates the CWT facility’s design or permitted capacity in gallons per day.Memorandum

March 31 , 2015 Page 7

Table 1

. Data Dictionary for “O&G CWT List” Tab in Attachment 1 to this Memorandum (DCN SGE00596.A 0 1)

Field Name Description

References All of the sources (listed by DCN number) that ERG use d to popu late data for each CWT facility CWT Facility Website C WT facility website (if any) Notes ERG’s notes on the treatment technologies employed by the CWT facilit y

2.3 Generation of TDD Figure D

- 8 and Table D

- 6

This section explains how ERG create d Table D

- 6 and Figure D

- 8 in the TDD using data from the “O&G CWT L ist ” tab in Attachment 1 to this memorandum (DCN SGE 00596 .A 0 1)

.

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 fa c ilities in each
state using the data in the “O&G CWT List” tab in Attachment 1 to this memorandum (DCN SGE00596.A01 ). ERG separated t he total number of CWT fac ilities in each state into three categories related to the type of CWT facility : zero discharge

, discharg e , or multiple discharge options

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

- TDS removal

. 17 The “ Summary by State ” tab in Attachment 1 to this memorandum (DCN SGE00596.A01 ) shows the total number of CWT fac ilities 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 show n 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 underestimate s 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 Figu re D

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

Marcellus and Utica Shale Formation s
ERG created Figure D

- 8 in the TDD using some of the CWT fac ilities in the “O&G CWT List” tab in Attachment 1 to this memorandum (DCN SGE00596.A01 ) along with Ohio spud 19 data (DCN SGE00 561 ) , W est Virginia spud data (DCN SGE00407) , and Pennsylvania spud data (DCN SGE00 712 )

. ERG used the following steps:

Step 1

– Count the Facilities

17 If a facility had TDS removal technologies, even if it di d 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

c ounted the number of active CWT fac ilities accepting UOG extraction wastewater between 2004 and 2013 in Pennsylvania, Ohio, and West V irginia

. 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.A 0 1) 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 data 22 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.A 0 1).

 Pennsylvania

– The PA DEP provides an online searchable database called “ Spud Data Report ” (DCN SGE00712)

. R esults from this data base 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 Prot ection (WVDEP) provides an online searchable database called “ Oil and Gas Well Search ” ( DCN SGE00407)

. R esults from this database can be exported to Microsoft Excel and are included in the “WV Wells” tab in Attachment 1 to this memorandum (DCN SGE00596.A 0 1 )

. 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 fl agged 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 M icrosoft Excel spreadsheet containing a unique list of wells that have been

20 The se 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 wel l (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 th e 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 .A 0 1)

. 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 tha t 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. CWT s over T ime 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 tim e. ERG indicated the number of pending CWT facilities with a dashed line in the figure.

3.0 Q UALITY C ONTROL P ROCEDURES

All of the analyses presented in this memorandum adhered to the Environmental Engineering Support for Clean Water Regulations Programmatic Quality Assurance Project Plan (PQAPP) (DCN SGE00957) and the Unconventional Oil and Gas (UOG) Supplemental Quality Assurance Project Plan (SQAPP) (DCN SGE00 958 ), including collecting, evaluating, and analyzing existing data and information about CWT facil ities

. 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 datab ase. 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 fo lder.

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 r egulatory agencies such as departments of environmental protection and oil and gas commissions. As shown in Table 2 in this memorandum, ERG assigned a source flag (A, B, C or D) to all references used in these analyses

, which are defined below

.

 Source Flag A

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

 Source Flag B

– Documents prepared by a verified 26 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 U OG 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 c itation 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 ent ry

 ERG performed a 100 percent check of all analyse s 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 review ed the results from the CWT Facility List and Analysi s spreadsheet provided in Attachment 1 to this memorandum (DCN SGE00 596 .A 0 1 ).

4.0 R EFERENCES

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

. The references in Table 2 are sorted by DCN.

Table 2

. References

DCN Full Citation Source Flag a

SGE00 011 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: A vailability, Options, and Costs . Argonne National Laboratory. A

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

United States

. A

SGE00 188 O'Connell, James, ERG.2014. Pennsylvania Department of Environmental Protection’s

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

. A

SGE00 244 ERG. 2012. Camp, Meghan; Bicknell, Betsy; Ruminski, Brent. Notes on Conference Call

with 212 Resources on 4 January 2012. (January 9)

. A

SGE00 245 ERG. 2012. Camp, Meghan et. al. Notes on Conference Call with Reserved

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

SGE00 273.A21 Jim Kline. 2012. Examining The Regulations and Restrictions Set by the DEP to

Determine the Operational Feasibility of Disposal. PA DEP. A

SGE00 284 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

SGE00 299 US EPA. 2012. Site Visit Report US Gas Field Fluids Management

(formerly Clean Streams) Marcellus Shale Gas Operations. A

SGE00 300 US EPA. 2012. Site Visit Report Eureka Resources, LLC Marcellus Shale Gas

Operations. AMemorandum

March 31 , 2015 Page 11

Table 2

. References

DCN Full Citation Source Flag a

SGE00 363 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

SGE00 364 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 onli ne at: http://www.aqua

- pure.com/operations/shale/ford/ford.html C

SGE00 366 Clarion Altela Environmental Services (CAES). Unknown. Clarion Altela

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

SGE00 367 CARES. Unknown. CARES McKean. Available online at:

http://www.caresforwater.com/location/cares

- mckean C

SGE00 368 US EPA Region 3. 201 2 . Key Documents About Mid

- Atlantic Oil and Gas Extraction.

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

SGE00 369 Anticline Disposal, LLC. Unknown. Anticline Disposal, LLC. Available online at:

http://www.highsierrawater.com/high

- sierra

- water/ A

SGE00 374 Red Des ert. Unknown. Red Desert: Facilities. Available online at:

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

SGE00 375 Rigzone. 2011. Sio nix 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_Plan t C

SGE00376 S omerset Regional Water Resources (SRWR). 2012 . SRWR: Our Services. Available

online at: http://www.srwr

- pa.com/services2.html C

SGE00 378 Waste Management. 2011. DRBC Proposed Natural Gas Development Regulations

Comments of Waste Management. Available online at: http://www.state.nj.us/drbc/libr ary/documents/NGC/Industry/WasteManagement041411. pdf C

SGE00 379 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

- for

water

- 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

SGE00 414 Thomas Hayes et al. 2012. Characterization of Flowback Waters from the Marcellus and

the Barnett Shale Regions Report No. 08122

- 05.09. Re search Partnership to Secure Energy for America (RPSEA). A

SGE00 469 Barger, Brian. Unknown. Testimony of Brian P Barger RE: HB 59 on Behalf of Patriot

Water Treatment, LLC. A

SGE00 474 GreenHunter Water, LLC. 2013. GreenHunter Water Acquires Barging Terminal in

Wheeling, Ohio County, West Virginia. GreenHunter Water, LLC. C

SGE00 476 Hydro Recovery, LP. 2013. Company Info. Downloaded on 5/20/2013. C
SGE00478 Kasey, P. 2009. Gas Well Drilling Brine Treatment Facility Opens in F airmont. The

State Journal. D

SGE00 479 Kadramas, Lee & Jackson, Inc. 2012. Power Forecast 2012 Williston Basin Oil and Gas

Related Electrical Load Growth Forecast. Kadramas, Lee & Jackson, Inc. B

SGE00 481 McCutcheon Enterprise, Inc. 2013 . Waste Reduction: A Greener Alternative for

Treating Drilling Muds. McCutcheon Enterprise, Inc. CMemorandum

March 31 , 2015 Page 12

Table 2

. References

DCN Full Citation Source Flag a

SGE00 484 Jim Davis. 2012. WM Environmental Services: Oilfield Solutions in the Marcellus Shale.

Waste Management Eastern Group. C

SGE00 488 Yogesh Patel. 2012. WV0116441 Reserved Environmental Services Ohio County. West

Virginia Department of Environmental Protection. A

SGE00 490 Advanced Waste Services. 2013. Marcellus & Utica Shale Services. Company website. C

SGE00 507 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

SGE00 524 Eureka Resources. 2013. Eureka Resources Announces Plans for New Wastewater

Treatment Plant. January 7. C

SGE00 534 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

SGE00 568 Pennsylvania Department of Environmental Protection (PA DEP). 2010. Oil & Gas

Facility Summary. (August 26). A

SGE00 577 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

SGE00 580 Randy Wells. 2012. CORRALLING WASTEWATER: Treatment company sets up shop

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

SGE00 584 Shallenberger Construction. 2012. Marcellus Water Treatment. Company website

accessed on 10/28/2013. C

SGE00 588 TerrAqua Resource Management (TARM). Unknown. Solutions. Company website

accessed on 10/28/2013. C

SGE00596.A01 ERG. 201 5

. 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

SGE00 616 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. 201 5 . Site Visit Report Southwestern Energy Fayetteville Shale Operations.

Sanitized. A

SGE00 635 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

SGE00 691 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. AMemorandum

March 31 , 2015 Page 13

Table 2

. References

DCN Full Citation Source Flag a

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

SGE00 711 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

SGE00 713 McIntire, Carrol. 2014. Chesapeake Officials Show Off Their New Water Recycling

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

SGE00 729 Iron Eagle. 2014. I ron Eagle Opens Water Recycling Facility to Serve Oil and Gas

Industry. C

SGE00 730 Aspen Fluid Logistics. 2014. Aspen Fluid Logistics: Industrial Wastewater Recycling.

Accessed on 4/15/2014. C

SGE00739 ERG. 201 5 . 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

SGE00 772 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. Commer cial Recycling & Surface Disposal

Facilities. (July 22). Retrieved from http://www.rrc.state.tx.us/oil

- gas/applications

- and

permits/environmen tal

- 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 document s, 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.A TTACHMENT 1 : CWT F ACILITY L IST AND A NALYSIS ( DCN SGE00596.A01 )