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treatment could be significantly greater than other management options. They noted that in most areas, the nature of produced water would require extensive treatment to remove constituents such as barium, TENORM, hardness, organics, and dissolved solids such as chlorides. Treatment consisting of technologies including chemical precipitation, reverse osmosis, and thermal evaporation were identified as necessary to generate discharge- quality water. Also, treatment residuals such as concentrated brines, crystallized salts and sludges would require management, which would add to costs. Management of TENORM- containing sludges was identified as a particular challenge. Where produced waters contain radium, it was described that treatment will concentrate radioactivity in sludges or other residuals. Depending on the radioactivity of these materials, management options were identified as being limited and costly. In addition, they noted the potential for release to the environment through spills or through landfill leachate. Given the extensive treatment that may be appropriate, as well as residuals management concerns, doubts were raised as to whether treatment for discharge would be cost-competitive with other options such as reuse within the oil and gas field or disposal in Class II UIC disposal wells. However, states agency representatives did indicate that recovering valuable co-products, such as lithium or rare-earth metals from the treatment residuals, could improve the economics of treatment for discharge. They noted that this might spur growth of other industries that can utilize these co-products, such as battery manufacturing. Some state agency representatives reported that they lack technical expertise in permitting discharges under the NPDES program and would look to the EPA to provide this expertise. NPDES permits include both technology-based and water quality-based effluent limitations, and they indicated that determining the water quality limitations could be challenging since standards and criteria do not exist for many constituents in produced water. In addition, they noted that production may occur in areas where receiving waters are high quality and therefore it could be difficult for dischargers to meet stringent water quality standards. In particular, meeting standards for chlorides in receiving waters was identified as a potential challenge. Also, some state agency representatives indicated that there are no surface waters in the vicinity of much E&P activities, so discharge to surface waters would not be a viable option even if regulations allowed for it. They also indicated that there would be a public perception challenge associated with allowing discharge to surface waters. Many state agency representatives indicated that the timeline required to obtain NPDES permits could be an impediment to broader discharge. They indicated that producers may desire the ability to discharge for a short-duration as the need arises, perhaps at multiple locations within their operations. This is different than typical NPDES dischargers which tend to be established facilities discharging long-term. Given the many steps involved in issuing permits, they observed that producers may not be able to obtain permits in the timeframe desired. They indicated that a general permit might be a good option for this industry to address concerns over the time required to issue permits. Another option would be for producers to utilize fixed CWT facilities that manage produced waters from multiple production operations. This could be a commercial facility that accepts produced waters from multiple operators, or a facility owned and operated exclusively by one producer for just their wells. State agency representatives indicated that Study of Oil and Gas Extraction Wastewater Management 21 Section 4−The EPA’s Outreach to StakeholdersPDF Image | Study of Oil and Gas Extraction Wastewater
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