American Oil and Gas Reporter - June 2020 - 65

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EPA Considers Produced Water Use
WASHINGTON-Several states are beginning to question why wastewater from
oil and gas operations is simply injected
underground in disposal wells instead of
being put to productive use, the U.S. Environmental Protection Agency says.
In its report examining wastewater
produced from onshore conventional
and unconventional wells, "Summary
of Input on Oil and Gas Extraction
Wastewater Management Practices Under
the Clean Water Act," the agency considers how federal policies governing
water management under the CWA can
interact more effectively with state and
tribal regulations and requirements, and
asks whether federal regulations may
allow for broader discharges of treated
produced water to surface waters.
Oil and gas activities generate large
volumes of wastewater, and projections
show those amounts are likely to increase, the report observes. Most of the
produced water is managed by reuse
within the field for practices such as
enhanced oil recovery or by disposal in
injection wells. However, EPA warns,
the limits of injection are evident in
some areas and new approaches are becoming necessary.
In response, the agency has conducted
a study to evaluate managing produced
water from onshore extraction activities,
seeking a better understanding of produced
water generation, management and disposal options at the regional, state and
local levels. EPA notes that for the purposes of the study, it considers produced
water to be the water (brine) brought up
from the hydrocarbon-bearing strata during oil and gas extraction. It includes
formation water, injection water and any
chemicals added down hole or during
the oil/water separation process.
"Summary of Input" follows EPA's
earlier studies on facilities that treat and
discharge wastewater to surface waters
that are regulated under the CWA, including its "Centralized Waste Treatment
Study" published in 2018.
"During the EPA's outreach activities,
stakeholders raised several concerns regarding additional discharge options for
treated produced waters," the report notes.
"The main concerns were related to the
amount of available data on the chemistry
of produced waters and the performance
of treatment technologies. A related concern was the availability of analytical
methods for measuring the constituents
in produced water, and the potential toxicity of these constituents."

Using Produced Water
While opportunities exist to recycle
or reuse produced water outside of the
oil field, EPA says these approaches are
rare. Some produced water is used for
crop irrigation or spread on roads for
dust or ice control, while some manage
wastewater at off-site centralized water
treatment (CWT) facilities. In addition,
some produced water is managed at publicly owned treatment works (POTW).
Discharging oil and gas wastewater
to surface waters occurs in limited geographic areas in the United States, the
agency describes:
· Discharges west of the 98th meridian for agriculture and wildlife propagation takes place primarily in Wyoming,
where produced water generally receives
limited treatment-primarily settling
and/or skimming.
· Indirect discharge through POTWs
primarily occurs in Pennsylvania, with
produced water receiving little or no treatment before it is transferred to the facility.
· CWT sites usually are found in the
Marcellus and Utica shale areas of Pennsylvania, Ohio and West Virginia, and
wastewater typically undergoes varying
treatments, ranging from simple
physical/chemical treatment to advanced
treatments using membranes or distillation.
In limited instances, produced water
is used for agricultural irrigation. EPA
says this occurs primarily in California,
although limited use has occurred in other
states. In California, produced water is
used to irrigate a variety of crops, including
those for human consumption. The agency
points out using produced water in agriculture that doesn't involve discharges to
surface waters doesn't require a CWA
permit.
"Representatives of state agencies that
the EPA engaged for this study generally
supported increasing opportunities for
management of oil and gas wastewaters
including discharge of oil and gas extraction and production wastewater. Reasons included providing additional flexibility for producers, opportunities to address water scarcity concerns and to provide additional water for agriculture," the
agency describes.
Other agencies expressed concerns
about the treatability of produced waters
and the unknown human health and ecological risks, EPA says, including treating
residuals, particularly the salts and possible
radioactive materials. It adds those risks
primarily are a function of the unknown
chemical composition of produced waters

Several tribal representatives expressed
unease about increasing opportunities for
discharge while others supported discharges to address water scarcity and to
allow for continued resource development
on tribal lands. The report notes another
concern was raised about the possible
impacts to surface waters with important
cultural uses.
User Satisfaction
Nationally, EPA says there is broad
support among oil and gas companies and
their service providers for additional wastewater management options, including treating produced waters more broadly. However, the agency notes support is not universal, as some operators are satisfied with
the existing regulatory structure and others
perceive potential liability concerns associated with alternatives such as discharge.
While discharging produced water
west of the 98th meridian currently is an
option for oil and gas producers, the
report says the beneficial reuse provision
outside of Wyoming is rare. Based on
data it collected, EPA says this primarily
is because other lower-cost wastewater
management options, such as reuse within
the field or disposal in Class II underground injection control wells, along with
the costs associated with treating produced
waters to a level suitable for discharge.
According to "Summary of Input,"
industry experts indicate that unless the
produced water's total dissolved solids
concentrations generally fall short of a
few thousand milligrams a liter, membrane
treatments, including reverse osmosis, or
distillation is needed to generate water
suitable for agricultural uses or for discharge to surface waters. It notes those
treatment costs are currently uncompetitive
where other wastewater management options are available.
"However, treatment for discharge
may be cost-competitive where other options are limited," EPA describes. "For
example, producers indicated that in some
areas of Pennsylvania, treatment for discharge would currently be cost-competitive
with other available wastewater management options. This is primarily driven by
the cost for trucking produced water to
other management or disposal options."
Some environmental nongovernment
organizations have raised concerns about
expanding options for discharging produced waters, as well as current available
options, the agency points out. Those
worries relate to the unknown nature of
produced water chemistry, documented
JUNE 2020 65



American Oil and Gas Reporter - June 2020

Table of Contents for the Digital Edition of American Oil and Gas Reporter - June 2020

Contents
American Oil and Gas Reporter - June 2020 - Intro
American Oil and Gas Reporter - June 2020 - 1
American Oil and Gas Reporter - June 2020 - 2
American Oil and Gas Reporter - June 2020 - Contents
American Oil and Gas Reporter - June 2020 - 4
American Oil and Gas Reporter - June 2020 - 5
American Oil and Gas Reporter - June 2020 - 6
American Oil and Gas Reporter - June 2020 - 7
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