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some producers are currently installing water management infrastructure to centralize their water recycling operations, and that this may lead to construction of treatment plants for discharge in the future. While issuing a permit to such a fixed facility may still require considerable time, they indicated that such an option may be feasible. However, there were questions about how to permit centralized waste treatment facilities and what the governing ELGs would be, particularly if such a facility treats only oil and gas extraction wastewater. There were requests for the EPA to clarify this, and to revisit the definitions in the CWT ELGs to provide more flexibility for oil and gas operations such as to allow a CWT facility to accept oil and gas wastewater via pipeline. In some states, the EPA issues NPDES permits which means the state has less control of the permit issuance process. State agency representatives acknowledged that obtaining authorization for the NPDES program would be an option, however they identified barriers to delegation such as staffing and funding. 4.2 Major Themes from Tribes Some tribes were not supportive of additional discharge options for produced water. These tribes indicated that they were concerned about the environmental and human health implications of discharge. In addition, many surface waters have important tribal uses such as fishing or ceremonial practices, and these tribes were concerned about potential impacts to water quality that may affect those uses. There were also questions about which specific water bodies would potentially be affected. Section 4−The EPA’s Outreach to Stakeholders While state agency representatives indicated that reuse of produced water within the oil and gas field is desirable, there are some existing state laws or regulations that can interfere with reuse, particularly sharing water between producers. As a result, there is less recycling occurring than could potentially occur. According to these state agency representatives, changes to state legislation would be necessary to remove these barriers. They also indicated that in some cases, land owners require producers to purchase freshwater from them as part of the lease. If freshwater must be purchased, then there is less incentive to reuse produced waters for E&P activities. Consequently, additional produced water is generated that would subsequently require disposal. They indicated that as the total volume of wastewater requiring disposal increases, additional management options including discharge may be desirable. Some state agency representatives indicated that better data on produced water generation, reuse and injection well utilization could help manage disposal well capacity concerns. For example, they indicated that if some areas are becoming over-pressurized, then remedial actions such as limiting the volumes that specific injection disposal wells can accept could be implemented. They indicated that requiring injection disposal well operators to report volumes of water accepted or well pressures at a greater frequency could help with management of those wells. Additionally, requiring more reporting from producers on produced water disposition was identified as an aid for management of injection disposal wells. Other tribes were supportive of additional discharge options as this would allow for continued development of oil and gas resources on tribal lands. However, they would want Study of Oil and Gas Extraction Wastewater Management 22PDF Image | Study of Oil and Gas Extraction Wastewater
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