TWCA Annual Convention 2019

1. Protecting the Waters of the State…

2. } Political Subdivision of the state
} Established 1969
} Can operate statewide
} Fully funded by service fees
} No ad valorem taxes
} Mission

3. Bayport Industrial
WWTP
40-Acre Industrial
WWTP
Odessa South Industrial
WWTP
Washburn Tunnel WWTP
• POTW
• Designed to treat the
wastes they receive
• Industrial TPDES
Permits
Industrial

4. } State Water Quality Standards
} Federal Industry Specific Direct Discharge Standards
(Effluent Guidelines)
} All permits include Whole Effluent Toxicity testing
} Include Pretreatment Program
} Federal Exemption

7. } Onshore Production- Direct Discharge (1979)
◦ Subpart C-no discharge
◦ Subpart E- West of 98th, discharge allowed for agriculture, live stock or
wildlife
– Limits on Oil and Grease
– Need to be “good enough quality”
◦ Discharge to CWTs and injection well disposal allowed
} Unconventional production- Indirect Discharge (2016)
◦ No discharge to POTW
◦ Discharge to CWTs and injection well disposal allowed

8. } Must have waste from multiple sources
} A POTW cannot be a CWT
} CWT can accept produced water and treat for direct discharge
or discharge to a POTW

9. } CWT Study
◦ Report issued with recommendation for non-specific regulatory action
} EPA doing a “comprehensive” study on produced water
◦ Met with stakeholders
◦ Public meeting Oct 9
◦ White paper to be issued 1st qtr 2019
◦ Comment period
◦ Recommendations summer 2019
◦ https://www.epa.gov/eg/study-oil-and-gas-extraction-wastewater-
management

10. } Majority of Stakeholders-
◦ Benefit for keeping in hydraulic cycle
◦ Need adequate discharge standards
} Technical issues
◦ Complex waste
◦ A lot of variability
◦ High TDS
◦ Some waters contain NORM
◦ Specific compounds of concern
◦ Analytical methods

11. } Establish nation wide direct discharge standards
} Allow POTW with properly installed technology to accept
water for treatment
} Modify CWT regulations to allow a POTW to be a PW CWT
provided:
◦ Permit includes appropriate 40 CFR 437 discharge limitations
◦ Technology installed to meet CWT standards
◦ Residual managed under appropriate regulations
◦ Pretreatment program in place to place controls on discharges to
insure permit compliance

12. } Groundwater Protection Council
} Joint EPA/New Mexico

13. } Groundwater Protection Council (www.gwpc.org )
} Multi-stakeholder working group
} “facilitate the development of Produced water as a supplement
to freshwater resources”
} Final Draft to Board of Directors for approval April 2019
} Three modules
◦ Regulatory and Legal Frameworks
◦ Produced Water Use in the Oilfield
◦ Produced Water Use and Research Needs Outside the Oilfield

14. } Ag water $35/ac-ft
} City Water $3.50/1000 gal
} Bottled Water $3.50/ liter
} Raw water for oil field operations $0.35- $1.00 /bbl
} $1.00/ bbl is ~$24 /1000 gal (>$7,000/ac-ft)

15. } One Water
} Technology exists and will
advance if there is a demand

19. } Dissolved inorganic salts
} Residual Disposal
} Trace Organics
} Current technology very costly
} New promising technologies are under development but lack
strong driver

20. } Limitation on injection well capacity
} Seismic issues in some areas
} More produced water produced than used for well
development
} Mature fields (no more new well development)
} Need options

21. } Producer
} Surface Owner
} Royalty Owner
} Treatment Facility Owner

22. } Anti-backsliding on 435 rules
} There has not been a strong driver to develop technology due
to existing regulations
} Analytical methods