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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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