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Some state agency representatives were supportive of additional discharge options for treated produced water. The reasons identified were varied. One primary theme was that treated produced water could be an additional source of water to augment surface and groundwater supplies. Some states with significant oil and gas extraction activity are also arid or semi-arid where water scarcity is a current and growing problem. If produced water could be treated to a level suitable for discharge, these state agency representatives see this as a benefit. Potential downstream users of the water that were identified include agriculture, municipalities and industry. In addition to providing water to downstream users, state agency representatives indicated that discharge of treated produced water could help meet downstream water allocations and interstate water compacts. The concept of re-branding produced water from a waste product requiring management to a potential valuable resource was a common theme. State agency representatives also indicated that allowing producers to treat and discharge produced water closer to where it is generated would reduce the need for transport via trucks or pipelines. Transport of produced water can be costly and brings with it the risks of spills or illicit discharge. In addition, truck traffic can damage roads and increase the risk of traffic accidents and associated injuries and fatalities. Also, truck traffic can be disruptive to those located along trucking routes. State agency representatives indicated that reducing trucking could provide benefits to air quality as well due to reduced emissions. In states where water rights and water allocation law are established, there were questions about who would own produced water that is treated for discharge. Representatives of some state agencies indicated that there has been or is ongoing work to clarify ownership and water rights for discharged produced water, while others indicated that this question has yet to be addressed. Regardless of ownership, selling or obtaining royalties from discharge of treated produced water was identified as another potential benefit, as someone (either the state, a landowner, industry or some other entity) would own the water and therefore could benefit financially from selling the water and any mineral co-products extracted from the water. Representatives of some state agencies indicated that there are existing and emerging constraints on Class II UIC disposal well capacity due to over-pressurization of Study of Oil and Gas Extraction Wastewater Management 19 Section 4−The EPA’s Outreach to Stakeholders Some state agency representatives noted that the oil and gas industry can be a significant user of fresh water in certain areas, given that water is often required for drilling and hydraulic fracturing activities. In many cases, industry relies on withdrawal from surface water or groundwater supplies to obtain needed water. After use in E&P activities, this water may be reused within the oil and gas field, but in many cases, is ultimately disposed of in Class II UIC wells where it is no longer part of the water cycle. State agency representatives indicated that treating this water for discharge and reintroduction to the water cycle would help to preserve or augment freshwater supplies. On a related note, representatives of one state agency indicated that there has been discussion of recovering water injected into Class II UIC disposal wells for reuse within oil and gas operations; this could reduce freshwater imports into the oil and gas sector.PDF Image | Study of Oil and Gas Extraction Wastewater
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