produced water discharge presentation

8/12/2019 Produced Water Discharge Presentation

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MCA Petroleum Corp., San Marcos & Flatonia, Texas

Mike Shellman, 53 years of oilfield experience; SPE, AAPG and STGS Catherine Shellman, Aquatic Assessment and Toxicology

Sellers Lease Service, Inc., Flatonia, Texas

Bobby Sellers,35 years of oil and natural gas production managementexperience & produced water management

Consultants

Pat Behling, P.E. Pastor, Behling & Wheeler

Jim Horne, Senior Scientist, Atkins North America

Dwight Cassell, P.G. Consulting Geologist; MCA

Dick Sorrell, V.P. of Partnership Relations; MCA


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TXG330000 General Permit

Current permit issued in 2012

Regulates discharges from Coastal and Stripper Subcategories

Stripper Well Definition (40 CFR 435.60)

Onshore, Produce


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Abundant, Clean Surface Water for Texas


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Consistent, homogenous reservoirs with similar formationand water characteristics long region strike.

Alkalinity and conductivity values for the Carrizo Wilcox

and Bartosh formations are much lower than Reklawand help explain ion composition imbalances


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Since 1943 over 21,000,000barrels of crude oil have beenproduced from shallow Reklaw,Carrizo-Wilcox and Bartosh oilwells in Fayette, Gonzales,

Bastrop and Milam Counties inCentral Texas.

Today, nearly 300 BOPD is stillbeing produced fromfreshwater reservoirs in these

four counties.


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Type Logs; Fayette County


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Water becomes enriched in sodium and depleted in calcium with

depth (BEG Report, 1988)

Greater than 1500 feet deeplow calcium, high sodium, highalkalinity (BEG Report, 1988)

Ion composition of water varies with depth and specific formations;shallower sands have higher alkalinity values

Migrating clays present (Davies Report, 1984)

Kaolinite, illite and chlorite

Typically


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Discharged since mid-1940s with NO Environmental Harm !!

Not produced from groundwater sources fit for humans

50 barrels of water generated per barrel of oil More than 400 Million gallons discharged each year to Texas

surface waters

TDS < 1,000 mg/L typical

< 5 ppm oil in water concentrations

Critical source of water supply in drought conditions A horrible waste of a valuable natural resource to re-inject

below ground into brackish formations.


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Discharged to dry creeks ( Water in those creeks

is 100% effluent 8-9 months each year)

Only water available in area for livestock, wildlifeand aquatic life

Produced water discharged since the mid-1940s

without adverse environmental impacts

More than 250 comments submitted to EPA insupport of discharges and their importance to

surface water and local economies


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Ecological Impact Study (LWM, 2014)Produced water is essential to ecosystems

Ephemeral drainages are transformed to

perennial creeks with high quality, riparian

habitat and abundant/diverse wildlife

Elimination of discharges would

Kill riparian vegetation, affecting bank stabilityand increasing sediment erosion during storms

Remove habitat for wildlife, some of which arefederal/state designated species of concern

Reduce current high level of avian diversity

Be catastrophic to current fish, reptile andamphibian populations!!


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Economic Impacts

Oil production will cease without discharges!

Operators are small businesses.

Operations support numerous other small businesses

and royalty owners. Over 800 people are directlyaffected by these fresh, produced water discharges.

Hundreds of thousands of tax dollars to state, localgovernments and school districts.


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Photograph by Dave Wilson


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Permits Issued by both TRC and EPA

TRC- Individual permits underStatewide Rule 8

EPANPDES General Permit

TXG330000


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First issued in 1995, Re-issued in 2012

Flow: Monitor monthly

TDS: Monitor annually

Limit: 3,000 mg/L Oil in water concentrations (OIW) monitored monthly

Limit: 25 mg/L avg, 35 mg/L max

Acute 24-hr WET Test annually

Marine organisms (mysid shrimp and inland silverside minnows)

100 percent effluent, LC50

Discharge terminated after one failed WET test resumed only

after two passing WET tests


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TDS Limit

All discharges less than 3,000 mg/L

OIW Limit

All discharges less than 25 mg/L avg, 35 mg/L max Marine WET Testing

All discharges pass acute 24-hr marine WET tests

at 100 percent effluent

Typically 100% survival for mysid shrimp and inlandsilverside minnows


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Proposed modifications published in December 2, 2013

Federal Register

Permit Coverage (adds inland dischargers)

Bacteria Limits (applies to sanitary wastewater dischargesonly)

Acute 48-hr WET Test annually

Fresh water organisms (water fleas and fathead

minnows)

100 percent effluent, LC50

Discharge terminated after one failed WET test

resumed only after two passing WET tests


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Numerous tests, evaluations, studies, legal interpretations, reportpreparation, meetings, consulting fees, and TREs at manydischarge facilities over past 18 months resulted in over$389,000 of costs to MCA and SLS

Tests performed on produced water samples collected from

End of pipe Downstream in receiving creeks

End of pipe with additional treatment using organic clay andactivated carbon filtration (OIW concentrations were non-detectable)

Toxicity Identification Evaluations (TIEs) performed on severaldischarge facilities consistently point to natural carbonate andnon-carbonate alkalinity in the water that causes ion compositionimbalances. TDS related toxicity in WET tests is recognized by

the scientific and regulatory community.


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All samples consistently passed acute 48-hr testsusing fathead minnows

Samples collected downstream in creeks

consistently passed acute 48-hr tests using water

fleas

End of pipe samples routinely exhibited mortality to

water fleas during acute 24-hr and 48-hr tests

Treatment with organic clay and activated carbonfiltration did not reduce water flea mortality in end of

pipe samples


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Removal of metals, organic compounds, etc. during TIEs

did not reduce water flea mortality

Mortality to water fleas demonstrated using mock effluent

created from distilled water that approximated ionic

composition of produced water

Water flea mortality in produced water samples often dueto accumulation of extremely fine (approx. 1 micron or

less) formation solids (migrating clays) in flea digestive

tracts causing ion charge irregularities.

Ion composition imbalances come

into equilibrium downstream and WET

tests meet standards in Texas surface

water.

Daphnia pulex


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Clay is a natural element of the earth. Charge of the clay particulate causes ion irregularities.


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There are noclassic chemical related toxins in the water!

Mortality to water fleas in end of pipe samples is notassociatedwith crude oil or chemicals used in oil production separationprocess

Mortality to water fleas in end of pipe samples is due to naturalcharacteristics of groundwater.

Ion imbalances and presence of non-carbonate ions

Extremely fine formation solids (migrating clays) are anatural part of the earths makeup

Discharged produced water meets WET standardsdownstream of end of pipe.


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OPTION 1Keep acute 24-hr marine WET testing

requirements in current permit

Passing marine WET testing confirms that the produced

water does not contain toxic levels of crude oil or oil

production chemicals

TDS Limit of 3,000 mg/L ensures that no discharges ofhighly saline produced water occur


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OPTION 2Exempt permit applicants and permit holders from

toxicity testing if WET test mortality is due to natural inorganic

constituents in source water

Consistent with the TSWQS (30 TAC 307.4(a) and 30 TAC

307.6(e)(2)(B))

Consistent with TDS exemption described in EPA General

Permit TXG260000 (Offshore Subcategory)


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OPTION 3Allow fresh water WET testing to be performed on

samples collected in receiving creeks downstream of dischargepipes where water becomes Texas surface water.

Evaluates ecological exposure of produced water to the

actual ecosystem of the receiving area and is representative

of the true health of the aquatic ecosystem.


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OPTION 4Allow fresh water WET testing using any of the

following adjustments to the WET testing protocol (consistentwith EPA Guidance)

Ion-adjustment protocol

Alternative invertebrate species in place of water flea

Single species testing using fathead minnow only


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Change Definition of WET Test FailureInstead of discharge

termination after only one WET test failure as in the current permit,

define a WET test failure as one failed WET test followed by two

failed confirmation tests within 60 days of the first failed test.

Prevents false test failures due to possible qualative

laboratory/testing errors

Consistent with TSWQS and WET Implementation Guidance


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Compliance ScheduleIn the event of persistent WET test

failures, establish a compliance schedule of up to three years to

perform a TIE/TRE to implement mortality controls

Allows continued discharge until reason for organism

mortality is controlled or compliance period has elapsed

Consistent with TSWQS and Guidance


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Work with EPA to develop permitting approach for producedwater that is

Effective at protecting the environment

Contains requirements that are consistently achievable and

economically attainable

Allows continued use of this valuable fresh water resource

Coordinate findings with TRC to ensure discharge permit

consistency Postpone issuance of Final TXG330000 Permit until all issues

have been addressed


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produced water discharge presentation

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