# Site Visit Report

US Gas Field Fluid s Management ( formerly Clean Streams) Marcellus Shale Gas Operations

May 2 2 , 2014i TABLE OF CONTENTS

Page

1.0 I NTRODUCTION

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- 1

2.0 B ACKGROUND AND O BJECTIVES

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

- 1

3.0 C LEAN S TREAMS W ILLIAMSPORT CWT F ACILITY

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

- 1 3.1 Wastewater Services

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

- 1 3.2 Plant Flow Description

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

- 2 3.3 Wastewater Accepted for Treatment

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

- 4 3.4 Treated Wastewater Streams

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

- 5 3.5 Facility Waste Streams

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

- 6 3.6 Costs

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

- 7

4.0 O VERVIEW OF D RILLING F LUID W ASTEWATER AND C UTTINGS

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

- 8 4.1 Drilling Fluid Wastewater Characteristics

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

- 8 4.2 Drilling Fluid Wastewater Volumes

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

- 9 4.3 Management and Disposal Options

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

- 9

A PPENDIX A: L IST O F P ARTICIPANTS ON THE C LEAN S TREAMS C ONFERENCE C ALLS AND S ITE V ISIT

................................ ................................ ................................ ....................... A

- 1ii LIST OF TABLES

Page Table 3

- 1. Wastewater Acceptance Criteria

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

- 5

Table 3

- 2. Chemically Treated Wastewater Target Quality

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

- 5

Table 3

- 3. Waste Stream Descriptions

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

- 7

Table 3

- 4. Clean Streams Treatment Costs

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

- 7

Table 3

- 5. Solid Waste Disposal Costs Incurred by Clean Streams

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

- 8

LIST O F FIGURES Page Figure 3

- 1. Plant Flow Diagram

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

- 41

- 1

1.0 I NTRODUCTION

On June 14, 201 2

, the U.S. Environmental Protection Agency (EPA) held a conference call with U

. S

. Gas Field Fluid s Management ( owned by US Environmental; formerly Clean Streams, LLC; referred to as Clean Streams in this report) to discuss th eir plant operation in Williamsport, Pennsylvania

. The conference call attendees are listed in Appendix A. Discussion topics from this conference call included:

 Waste water Services

 Plant Flow Description

 Treated Wastewater Streams

 Waste Streams

 Costs

On S eptember 17, 2012, EPA met with Clean Streams and visited their plant in Williamsport, Pennsylvania. 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

Lis a Biddle Tom Born Brian D’Amico Erik Helm Pooja Parikh

E astern R esearch G roup, Inc

. (ERG) (EPA Contractor)

Casey Mac Q ueen Brent Ruminski

U.S. Gas Fields Fluid Management (Clean Streams)

Tim Miller Richard Weaver

On May 6, 2014, EPA held a follow

- up conference call with Clean Streams to discuss drilling waste (i.e., drilling fluids, drilling cuttings) characteristics, volumes, and disposal or management practices

. Conference call attendees are listed in Appendix A. Discussion topics included:

 Status of Clean Streams CWT Facility

 Drilling Fluids/Cuttings Volumes

 Drilling Fluids/Cuttings Characteristics

 Drilling Fluids/Cuttings Management and Disposal Options2

- 1

2.0 B ACKGROUND AND O BJECTIVES

The Clean Streams Marcellus Shale site visit was the third in a series of site visits that the EPA plan ned for this industry. The purpose of the site visit was to collect background information on the shale gas extraction wastewater treatment industry and observe wastewater treatment operations. To initiate site visits, the EPA reviewed information about Marce llus shale gas producers and their wastewater management practices. During this review, the EPA identified Clean Streams as a recipient of shale gas extraction wastewater for treatment, active in the Marcellus Shale Play.

Tim Miller , Director of Gas Field Services, and Richard Weaver , President of Clean Streams, led the discussion of the company’s Marcellu s operations, the site tour, and the May 2014 conference call.

During the May 6, 2014 conference call, Tim Miller provided EPA with more information on dr illing fluid and drilling fluid wastewater. He also updated EPA on the status of the Clean Streams CWT facility. Clean Streams Williamsport CWT facility shut down due to financial complications. Mr. Miller said that he is currently involved in other oil an d gas services such as hauling materials via rail [truck] and truck. Mr. Miller also has experience consulting with oil and gas companies regarding management of their waste streams (e.g., UOG process
wastewater 1 , drilling fluid wastewater and cuttings).

The remainder of this report summarizes information discussed during the June 14, 2012

, conference call; September 17, 2012

, site visit; and May 6, 2014 conference call.

1 In this report, UOG process wastewater is referred to as flowback and long

- term produced water.3

- 1

3.0 C LEAN S TREAMS W ILLIAMSPORT CWT F ACILITY
During the June 2012 con ference call and p rior to a tour of Williamsport, Pennsylvania

, operations

, EPA and Clean Streams discussed information specific to their operations at their CWT facility . Topics discussed include :

 W astewater Services

 Plant Flow Description

 Accepted Wastew ater for Treatment

 Treated Wastewater Streams

 Waste Streams

 Costs

3.1 Wastewater Services

The Clean Stre ams wastewater treatment plant wa s a zero discharge facility that accepted long

- term produced water, flowback water, top hole water 2 , and drilling fluid wastewater . Al l of the influent wastewater wa s treated and returned to the field for reuse in shale gas extraction activities . Because the treatment included an evapo ration/condensation unit, it had potential to meet Pennsylvania’s Chapter 95 discharge sta ndards for publicly

- owned treatment works (POTWs). 3 The company worked with the Williamsport Sewage Authority to come up with an agreement allowing Clean Streams to discharge to a nearby POTW. However, the Sewage Authority’s proposed pretreatment standards we re more stringent than P ennsylvania ’s Chapter 95 requirements (e.g., copper must be less than 20 parts per trillion). According to Clean Streams, there wa s no technology that could meet the more stringent standards. Therefore, all of the treated wastewa ter from Clean Streams wa s returned to the field for reuse and wa s not discharged to a POTW.

The company offered two main services:

 Disposal

— Operators pa id to drop off a load of wastewater for treatment and le ft

. Clean Streams had to find another operator to take the treated wastewater.

 Recycling

— Operators paid to drop off a load of wastewater and pick ed up a load of treated wastewater. They could choose from the following treatment levels:

— Filtration

— t his treatment level wa s the least common. If an operator chose this option, the truck dropping the load off wa s required to remain onsite to take back the treate d wastewater. Each truck remained onsite for approximately one hour.

— Chemical T reatment and F iltration

— t his treatment level wa s the most common. Wastewater wa s chemically treated, filtered, and stored until an operator took it for reuse. Operators typically reuse d this wastewater for hydraulic fracturing or drilling.

2 Water that flows to the surface during the initial drilling process.
3 http://www.pacode.com/secure/data/025/chapter95/chap95toc.html

.3

- 2 — Chemical Treatment, Filtration, and Evaporat ion/Condensatio n

—
a pproximately 25 percent of incoming wastewater to the plant went through this treatment (at the time of the site visit) . When gas prices were higher in 2010, almost all incoming wastewater went through this treatment but this has decrea sed since gas prices have remained low. Distilled water wa s typically used for rig cleaning and cementing

— not for hydraulic fracturing.

According to Clean Streams, larger gas companies use d the recycling service (i.e., drop off and pick up), while smaller companies use d the disposal service (drop off only). This is because even during periods of low drilling activity, large companies we re continuously fracturing and/or drilling at least one well and had an immediate demand for treated water. Small companie s may only have fracture d several wells per year leaving months between jobs. Therefore, if smaller companies took treated wastewater they must have had the infrastructure to store it. Because storage infrastructure requires capital investment and freshwat er in Pennsylvania is abundant, it wa s cheaper for them to dispose of the wastewater. During the September 2012 site visit, Clean Streams stated that only one of their customers use d the disposal option; all other Clean Streams custo mers use d the recycling service.

3.2 Plant Flow Description

The treatment plant wa s permitted for 10,000 barrels per day. However, in the configuration that EPA saw during the site visit , it could only treat 2,500 barrels per day. Clean Streams wa s in the process of upgrading the pl ant configurations by minimizing the number of tanks. During the site visit , there we re 14 different 500 bbl tanks throughout the plant. Clean Streams intend ed to replace 12 of these tanks with two new 6,000 bbl tanks to increase capacity.

Figure 3

- 1 presents a flow diagram of the treatment system. Treatment steps include:

 Screening : Each load wa s core sampled for pH, total dissolved solids (TDS), ba rium, strontium, iron, and total suspended solids (TSS). The water wa s characterized as high TSS wastewater (e.g., top hole water, drilling muds) or low TSS wastewater (e.g., long

- term produced water, flowback).

 Chemical Batch Treat ment : Two chemical batc h treatment tanks we re operated in parallel : one for high TSS wastewater and one for low TSS wastewater. E ach treatment tank had an approximate capacity of 360 to 430 barre ls

. When the tanks reach ed full capacity, various chemicals we re added depending on the constituents targeted for removal from the specific wastewater batch:

— pH wa s raised to 9.2 or 9.3 to promote metals precipitation ;

— Tank fluids we re mixed for 15 to 20 minutes ;

— Polymers we re added to promote solid binding ;

— Tank fluids we re mixed for 15 to 20 minutes ; and/or

— Tank fluids were settled so that sludge could be pumped from the bottom

.3

- 3

 Sludge D ewatering : Tank bottoms from chemical treatment flow to a filter press that generated solid waste and decant water . The solid waste wa s hauled to a lan dfill. Decant wat er wa s routed back to the influent stream to the chemical treatment tanks.

 Multiple Stage Media Fil tration : From the chemical batch treat ment tanks, the wastewater flowed through 100, 50, 25, and 10 micron filt ers to remove suspended soli ds.

 Evaporation/ C ondensation : If an operator wanted distilled wat er quality, the wastewater flowed from the filtration units to an AltelaRain® evaporation/

c onden sation unit. This unit generated concentrated brine and distilled water. The concentrated brine wa s hauled to Ohio underground injection wells or returned to the operator for reuse.

 Treated W astewater and D istillate S torage : Chemically treated wastewater and distilled water we re stored in separate 4,000

- barrel storage tanks until an operator picked it up for reuse.3

- 4 Figure 3

- 1 . Plant Flow Diagram

3.3 Wastewater Accepted for Treatment

Clean Streams accept ed drilling fluid wastewater, flowback, and long

- term produced water from operators. During EPA’s preliminary call and site visit, Clean Stream’s provided information on wastewater acceptance criteria

. Clean Streams’ criteria for accepting UOG wastewater inc lude d specifications on: (1) f racturing fluid composition; (2) radioactivity levels; and (3) TSS and barium content. In deciding whether or not to accept wastewater , Clean Streams d id not require operators to provide comprehensive disclosure of drilling fluid or fracturing fluid composition. Clean Streams ha d enough familiarity with the industry that they decide d whether or not to accept wastewater based

on operators providing the name of the service provider used. Operators also submit ted “waste profile” forms for each waste load.

Clean Streams screen ed all incoming loads with a Geiger counter for radioactivit y. If the Geiger counter detected radioactivity greater than 10 μrem per hour, Clean Streams had to follow additional procedures outline d in their radiological plan. First, the load wa s moved to a3

- 5

quarantine ar ea. Next, Clean Streams notified PA DEP a nd waited for a permit to transport it as a hazardou s waste. PA DEP typically issued this permit within two days, and C lean Streams
return ed the load to the generator. Only o ccasionally we re incoming loads identified as radioactive

, when solids ha d accumulated at the bottom of a vessel. Clean Streams also monitored TSS and barium and would issue a sur charge per barrel for loads exceeding confor mance criteria.

Table 3

- 1 lists the general target levels for constituents in wastewater for acceptan ce

.

Table 3

- 1 . Wastewater Acceptance Criteria

Constituent Appro ximate Concentration or Range (mg/L)
TSS < 2%
TDS ≤ 10,000
Barium ≤ 2,000
Iron ≤ 300

3.4 Treated Wastewater Streams

Two treated wastewater streams left the plant:

 Chemically Treated Was tewater : p icked up by operator for reuse in fracturing or drilling.

 Distillate : p icked up by operator for reuse in shale gas activities

.

Chemic ally treated wastewater contained approximately 100,000 mg/L TDS. Clean Streams monitor ed treated wastewater for pH, TSS, TDS, iron, barium, and strontium to en sure t hat the water quality met operator specifications. Clean Streams also screen ed all exiting loads for radioactivity. Approximately three of every seven treated loads per day we re identified as radioactive. According to Clean Streams, all of their custom e rs specified targets for pH, TDS, TSS, and iron. Some companies would also specify barium concentrations. However, because barium is a component of barite, which is a common additive for drilling fluid that increases density, some companies do not care abo ut the barium concentrations in the treated wastewater. Table 3

- 2 lists the general target levels for constituents in the treated wastewater.

Table 3

- 2 . Chemically Treated Wastewater Target Quality

Constituent a Approximate Concentration or Range (mg/L , unless otherwise noted )
TDS 70,000

— 100,000
TSS < 50
Iron < 10
Barium < 10

— 1,000 b

Sulfate <250 pH 6 to 7 S.U.

a

— Clean Streams reported low to no oil content is required for treated wastewater. b

— Clean Streams reported the barium criteria as less than 2 0 0 mg/L on the 6 May 2014 conference call.3

- 6

The Clean Streams CWT facility was not concerned with the TDS concentrations in the effluent water, because operators were often interested in receiving “ high TDS ” waste streams (e.g., 70,000 to 80,000 mg/L typically; 200,000 mg/L during winter months) for reuse.

Clean Streams operate d their evaporator to generate distillate containing approximately 2,000 mg/L TDS. According to Clean Streams, distillate with too low TDS concentra tion is
oxygen

- starved and removes ions from piping surface , leading to corrosion . Therefore, if operators chose to take distillate for reuse, it c ould no t be used directly in fracturing. Typically, operators blend ed it with freshwater, flowback or long

- te rm produced water to use in fracturing

or for other things without blending such as cleaning rigs or cementing. According to Clean Streams’ permit, distillate had to be returned to a well pad instead of being discharged or used for other purposes

.
Clean Streams considered adding crystallization 4 to their evaporation process. The company investigated at least eight different vendors and concluded the technology wa s too expensive given the existing price of gas. The biggest problem wa s the lack of market for the solid waste (i.e., salt). One potential use would be road salt. However, public perception would be that the salt would be derived from a “hazardous” source (i.e., shale gas wastewater). Through their research, Clean Streams estimated that the crys tallization process, alone, would cost operators $10.5 to $14.7 per barrel. After including pretreatment the total cost would range from $15 to $18 per barrel.

3.5 Facility Waste Streams

Table 3

- 3 describe s the waste stream s generated from the treatment operations at the Clean Streams facility . Waste st reams leaving the plant include concentrated brine (t rucked to Ohio for underground injection or picked up by operator for reuse ) and s olid waste (t rucked to landfill )

.
Clean Streams use d third

- party

- owned waste trucks with 18 ton capacity. Contents we re approximately 42 to 45 percent solids. Solids containing freefloating water or thixot ropic 5 fluids are not accepted at landfills for disposal

. Concentrated brine wa s either trucked to Ohio for underground injection or given back to the operators. Because truc king this waste stream to Ohio

wa s expensive, Clean Streams offer ed it to operators for a credit to their account. Operators could have use d concentrated brine during the drilling process when high density fluids we re desired.

All solid waste generated by the plant wa s disposed of via landfill. As required by their permit 6 from Pennsylvania Department of Environmental Protection (PA DEP), Clean Streams submit ted a new analysis for every 400 tons of material that wa s disposed of at a landfill. The State reviews these analyses and decides whether or not it is appropriate to approve the operator to dispose of the solid waste at the given landfill. For many Pennsylvania oil and gas operators, a new analysis wa s required approximately every four weeks.

4 Crystallization is a treatment process that converts water containing high TDS concentrations into solid crystals and distillate.
5 Becomes less viscous when agitated.
6 WMGR123NC006

.3

- 7 Table 3

- 3

. Waste Stream Descriptions

Level of Treatme nt Waste Stream Destination Waste Stream Description
Filtration Solids Hauled to one of two landfills.

-- Chemical Treatment and Filtration Sludge Hauled to one of two landfills.

--
Chemical Treatment, Filtration, and Evaporation/ Condensation Concentrated Brine Returned to operators for

credit or hauled to Ohio for underground injection. Concentrated brine from evaporation/condensation is approximately 250,000 mg/L TDS.

3.6 Costs

Cost to operators depend ed on the waste type, treatment level, and service type. If the operator wa s able to take a load of treated wastewater, they c ould ch o ose the level of treatment that wa s performed. If the operator wa s unable to take a load of treated wastewater, Clean Stream s charge d them for full treatment (i.e., chemical treatment, filtration, evaporation). Clean Streams provided cost information for different levels of treatment, which is summarized in Table 3

- 4 . Clean Streams e stimated that their cos t to customers reflect ed a 10 to 15 percent profit margin over operation and maintenance cost. Table 3

- 5 provides solid waste disposal costs.

Table 3

- 4 . Clean Streams Treatment Costs

Waste Type Level of Treatment Service Type

Notes Recycling Cost (Dollars per bbl) Disposal Costs

(Dollars per bbl) c

Flowback and long

- term produced water a Filtration 1.00 Not an option Trucks remain onsite for approximately 1 hour to receive the exact same wastewater unloaded.
Chemical treatment and filtration 3.60 Not an option

--

Chemical treatment, filtration, and evaporation/condensation 6.30

— 6.50 6.30

— 6.50

+ 1.68

— 1.75 Assumes the next operator

will want full treatment. Maximum 2% TSS for acceptance; otherwise a surcharge calculated by solids content applies.

Tophole water b Chemical treatment and filtration 9.2

— 9.50 9.2

— 9.50

+ 1.68

— 1.75 --

Water

- based and synthetic based drilling fluid b Chemical treatment and filtration 13.60 13.60

+ 1.68

— 1.75 --

a

— Low TSS wastewater. b

— High TSS wastewater.

c

— Clean Streams charges an additional $1.68 to $1.75 fee for not taking a treated load.4

- 8 Table 3

- 5 . Solid Waste Disposal Costs Incurred by Clean Streams

Landfill Trucking Distance Transportation Cost (Dollars per Load) Disposal Cost

(Dollars per Ton) Additional Fee for

Hazardous Waste (Dollars per T on)

Landfill A 1 to 1.5 hour truck drive

. 300 40 200 Landfill B 3 to 4 hour truck drive

. 700

a

— Each solid waste truck load is ap proximately 18 tons.

4.0 O VERVIEW OF D RILLING F LUID W ASTEWATER AND C UTTINGS
During EPA’s follow

- up call with Clean Streams in May 2014, the primary topic s of discussion were drilling fluid s , drilling fluid waste water, and drill ing cuttings. The following subsections describe the information provided by Mr. Tim Miller, of Clean S treams.

4.1 Drilling Fluid Wastewater Characteristics

EPA asked Clean Streams to provide information on typical characteristics of drilling fluid waste water and any variations based on the completion methods used (i.e., conventional, unconventional), drill typ e (i.e., horizontal, vertical, directional), and/or well location. Clean Streams provided the following information regarding characteristics of drilling fluid
wastewater.

D rilling fluid waste water that returns to the surface typically has the same proper ties as the drilling fluid that goes downhole, with the addition of pulverized shale pieces and grit that is collected during the drilling process. The following are constituents commonly found in drilling
waste:

 Oils

 Gels

 TPH (hydrocarbon level) 7

 pH

– varies between 5 and 13 S.U.

 TSS

Further, Clean Streams discussed the following stream characteristics in more detail. L iquids off of the drill ing cuttings typically have low TPH (hydrocarbons) concentrations and high oil concentrations , while the presence of bentonite in drilling fluid wastewater typically indicates high pH (12 to 13 S.U.). Waste streams with a pH greater than 12.5 SU are considered hazardous wastes and ; therefore , can be more difficult to manage and/or dispose of

. T he presence of gels in drilling fluid wastewater typically indicates high salt concentrations

. However, t he concentration of TDS in drilling fluid wastewater depends on the location of the shale/tight formation. As previously noted, t he Clean Streams CWT facility tar geted influent drilling fluid
wastewater with TDS concentrations less than 10,000 mg/L.

7 If TPH concentrations are greater than 10,000 mg/L, oil and gas operators cannot land apply in Pennsylvania.4

- 9

The concentration of TSS in drilling fluid waste water depend s on the oil and gas company’s management practices. Operators typically run drilling waste through a shaker / separator to separate the drilling fluid wastewater stream from the solid drill ing cuttings . If this is done correctly, the liquid stream would contain less suspended solids than it otherwise would contain

.
4.2 Drilling Fluid Wastewater Volumes

EPA asked Cle an Streams to provide information on typical volumes of drilling fluid used per well, typical volumes of drilling fluid waste water generated per well and any variations in these volumes based on the completion methods used (i.e., conventional, unconventional), drill type (i.e., horizontal, vertical, directional), and/or well location. Clean Streams provided the following information regarding drilling fluid wastewater generated. Clean Streams did not provide any information about volumes of dril ling fluid used per well.

Drilling fluid waste water volumes vary dramatically by operat or, formation, and even by well pad. Mr. Miller, of Clean Streams, reported that t ypically, between 10% and 33% of the drilling fluids used during the drilling process re turn to the surface as wastewater . The remaining drilling fluids are lost to the formation, similar to fracturing fluid. The percent of drilling fluid that returns to the surface is formation specific, and heavily depends on the characteristics of the rock face. Mr. Miller noted that i n Pennsylvan ia , it is typical to see low drilling fluid return rates (~8%). One reason for low return rates is that operators may hit fractures during the drill and lose the drilling fluid into the formation. Mr. Miller also n oted that “pad water” (in Pennsylvania, in particular) consists of drilling fluid wastewater as well as other wastewater streams generated onsite (e.g., equipment washing wastewater). For comparison, Mr. Miller reported that in Texas it is typical to see h igh drilling fluid return rates (~31%). Operators may also get up to 1,300 tons of drill cuttings back from the well head during drilling.

In Pennsylvania, operators that reuse d the same drilling fluid for all of the wells on a wellpad commonly generate d a pproximately 2,000 barrels (84,000 gallons) of drilling fluid wastewater once they finish drilling all of the wells on the wellpad.

4.3 Management and Disposal Options

EPA asked Clean Streams to provide information on disposal and management practices used by oil and gas operators for drilling fluid wastewater and how these practices var ied across the United States

. Clean Streams provided the following information in response

. Operators run drilling waste through a shaker/separator to separate the drilling fluid
wastewater stream from the solid drill cutting stream

. Drilling fluid wastewater is typically reused in subsequent well drilling operations until the characteristics of the fluid are no longer ideal for drilling or until the operator no longer has ad ditional wells to drill. The solid drill ing cuttings out of the shaker/separator are typically disposed of at a landfill.

Once the operator determines that the drilling fluid wastewater is no longer re usable, they
must decide on a wastewater management alt ernative to use

. Operators may decide to t ransfer the drilling fluid waste water to a CWT facility (commercial or operator

- owned) for treatment4

- 10

followed by disposal 8 or reuse (e.g., zero discharging CWT facilities like the Clean Streams Williamsport facilit y). Another option is for operators to t ransfer the drilling fluid wastewater to

an underground inject ion for disposal well

. The three main problems encountered while treating drilling waste at a CWT facility include :

 High Oil Con centrations

– CWT facil ities are typically not designed to remove oil

.

 High Salt Co ncentrations

– CWT facilities may experience influent TDS concentrations as high as 300,000 mg/L

.

 Presence of Me thanol

– Methanol has a flash point less than 140oF and therefore, is considered a hazardous waste.

Chesapeake and Anadarko (oil and gas operators) re

- treat their own waste streams 9 . Chief (oil and gas operator) implements filtration processes to treat their own waste streams. Other operators simply allow waste streams time to settle out solids prior to reuse.

Operators may hire multiple service provide r s to complete the different phases of well development (i.e., drilling, hydraulic fracturing, flowback/production ) ; t herefore, waste stream management may vary throughout the different phases. For example, UOG process wastewater (i.e., flowback, long

- term produced water) may be reused in subsequent fracture jobs while drilling fluid waste water may be disposed of via underground injection. The waste management decisions are typically made by the service provider

.

8 Wastewater disposed of at CWT facilities is either discharged to surface water or indirectly discharged through a POTW.
9 Mr. Miller did not elabor ate about how these operators re

- treat their waste streams (e.g., operator

- owned CWT, on

site treatment).A ppendix A :

L IST O F P ARTICIPANTS ON THE C LEAN S TREAMS C ONFERENCE C ALLS AND S ITE V ISITA

- 1 Table A

- 1. List of Attendees on June 2012 Conference Call

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

- 0350 Biddle.Lisa@epa.gov
Brent Ruminski ERG, Energy Engineer (703) 633

- 1701 Brent.Ruminski@erg.com Meghan Camp ERG, Chemical Engineer (703) 633

- 1684 Meghan.Camp@erg.com Betsy Bicknell ERG, Senior Engineer ( 703 ) 633

- 1612 Betsy.Bicknell@erg.com Tim Miller, P.E. Clean Streams, Director of

Gas Field Services (610) 518

- 5800 Tmiller@usenv.com

Richard Weaver Clean Streams, President ( 610 ) 637

- 7282 Rweaver@usenv.com

Table A

- 2 . List of Attendees on Site Visit

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

- 0350 Biddle.Lisa@epa.gov

Tom Born U.S. EPA, SGE

Environmental Scientist (202) 566

- 1001 Born.Tom@epa.gov

Brian D’Amico U.S. EPA, SGE Engineer (202) 566

- 1069 Damico.Brian@epa.gov
Erik Helm U.S. EPA, SGE Economist (202) 566

- 1049 Helm.Erik@epa.gov Pooja Parikh U.S. EPA, SGE Attorney (202) 564

- 0839 Parikh.Pooja@epa.gov Casey MacQueen ERG , Chemical Engineer (703) 633

- 1686 Casey.Macqueen@erg.com
Brent Ruminski ERG , Energy Engineer (703) 633

- 1701 Brent.Ruminski @erg.com Tim Miller, P.E. Clean Streams, Director of

Gas Field Services (610) 518

- 5800 Tmiller@usenv.com

Richard Weaver Clean Streams, President (888) 884

- 9700 Rweaver@usenv.com

Table A

- 3 . List of Attendees on May 2014 Conference Call

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

- 0350 Biddle.Lisa@epa.gov
Sarah Yates ERG, Environmental Engineer (703) 633

- 1661 Sarah.Yates@erg.com Tim Miller, P.E. Clean Streams, Director of Gas

Field Services (610) 518

- 5800 Tmiller@usenv.com