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I am Texan through and true. Water is important to me. There will come a time in the not-so-distant future that water will be far more important, more valuable to all of us in Texas than oil. Most simply don't know it yet.
The oil and natural gas industry in Texas, I am sorry to say, has done a
masterful job of hiding how much fresh water it uses when frac'ing HZ wells and where, exactly that water come from. A typical 11,000 foot HZ lateral in, for instance arid West Texas can require up to 600,000-700,000 barrels of water to drill and complete. Thats nearly 30,000,000 gallons of water and if that water is potable, and usable for human consumption, that is enough water for 367,000 people to use in one day. Now multiply that times 16 times a day in the Permian alone and enough water is used every day in West Texas to service nearly 6,000,000 people.
Then there is the issue of produced water coming out of these wells and what to do with it. Some 22 MM bbls. of produced water per day must be reinjected into the subsurface every day to get rid of it. In many places in West Texas injection volumes and pressure causes the earth to tremble and in other places simply to bubble out of the ground.
Produced water is the biggest threat to the Permian's future, more so than hydrocarbon scarcity and related monetary affordability
to get it out of the ground. The West Texas oil industry has a big problem with water. New Mexico does as well but it sends a great deal of its produced water down to Texas to be disposed of, where we stupidly accept it. It's such a problem the industry wants to start discharging produced water to the land surface and, believe it or not, directly into waters of the State, like the Pecos River. It is seeking ways to circumvent the 1995 Federal mandated National PollutantDischarge Elimination System (NPDES) prohibiting, among other things, produced water discharges from oil and gas facilities.
National Pollutant Discharge Elimination System (NPDES) | US EPA
Its powerful lobbyists are hammering on the Texas Commission on Environmental Quality to grant special permits for these discharges. The TCEQ, however, is bound by law to regulate wastewater discharges in strict accordance with the Texas Constitution, its Natural Resource Code, Texas Surface Water Quality Standards and the Federal Clean Water Act. The TCEQ is dragging its feet, so the oil industry has called on the current president to make the EPA waive parts of the Federal Clean Water Act and the NPDES. The EPA is following orders from headquarters and has now proposed an Amending General Permit to the CWA and is in its comment period. The TCEQ can then probably give the Permian oil industry what is wants, up to a certain point, save directly dumping toxic water into waters of the State. The industry anxiously awaits.
It's GOT to get rid of its water.
What to Know About the EPA’s Proposed Clean Water Act Revision
Actually I don't think the sector is very anxious about being able to discharge at all as it generally speaking gets whatever it needs in the way of regulatory relaxation to lower its costs and keep Texas crude oil and natural gas flowing to the beach for exports to foreign countries. The EPA, under Trump, will come through.
The sector is going wide open telling folks how well it can clean up its produced water to render it useful...I've read it all. Nobody is paying attention to applicable laws that already exist regarding Texas Surface Water Quality Standards, and the TCEQ mandate, because it will all be changed, those standards. They think.
And mind you, please, the stuff from HZ tight oil wells in the Permian is nasty, nasty shit. It's full of heavy metals, chlorides and total dissolved solids that would kill anything it came in contact with, not to mention benzene and, in some places in the Basin, radium. Whole effluent toxicity testing of wastewater in Texas (WET) is the standard for discharges in other industry, there is no way Permian produced water passes WET standards set forth in the CWA. It is gets dumped directly into the Pecos River, or a tributary of the Pecos River, or during a rain runoff washes into the Pecos, everything in that River will die.
Why do I think I know so much about all this, where did I get all my information about the Federal Clean Water Act, the NPDES, the TCEQ and TSWQS? Who am I, besides a concerned Texan, to be butting heads with the mighty Permian Basin HZ oil and gas sector?
Well, I've been to war over produced water, with the Environmental Protection Agency of the United States, twice, once in 1995 and again in 2014 and beat them. Twice. I was able to render my produced water compliant with the Federal Clean Water Act and all applicable Texas laws and now have site specific EPA and TCEQ permits to discharge to the land surface, even indirectly into waters of the State of Texas. My produced water IS a valuable source of surface water to Texas, complies with WET testing standards and almost meets Texas drinking water standards. I helped write the current TX General EPA Permit that allows these discharges.
I know what good, produced water is and Permian water is not good. Not even close. It will cost them an arm and both legs to clean it up to meet Texas Surface Water Quality Standards. The Texas Observer article does not state the radium in West Texas groundwater has anything to do with the HZ tight oil play and produced water injection; it probably doesn't. But its existence is going to make it just that much tougher to get discharge permits for Permian age water from the Wolfcamp, etc. It should.
What I was able to do with my water is perhaps the greatest accomplishment of my long oily life. I took my oilfield waste and turned into something Texas needs, desperately; surface water for livestock, wildlife and aquatic life. My water is so clean that rare Texas River Otters live in it and get fat eating tens of millions of minnows. They have their families in my produced water.
I am proud.
Cerodaphnia (water flea); if she can't live in your produced water it cannot go on the ground
The most exciting fish I've ever caught in 50 years of fishing around the world.
Click each image to read published articles on produced water discharges