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Section 4−The EPA’s Outreach to Stakeholders the discharges to meet water quality standards and be protective of the environment. Some tribes currently have discharges of produced water to water bodies located within tribal lands, consistent with the beneficial reuse provisions of 40 CFR 435 Subpart E. Continued discharge of this water is important for both economical as well as ecological and wildlife considerations. Tribes would also be interested in identifying additional uses for treated produced water outside of agriculture and wildlife propagation, including direct use by the tribe to supplement water supplies. However, they indicated that additional information on the performance of treatment technologies, as well as financial assistance, would be needed. 4.3 Major Themes from Oil and Gas Industry Members Most in industry were supportive of additional discharge options for treated produced water. The exception were some producers who were currently discharging under the Subpart E beneficial reuse provisions, who did not see the need for additional discharge options and did not support regulatory changes. Industry indicated that while reuse of produced water within the oil and gas field is their preferred management option, this is not feasible in some cases. Examples include when demand for reuse decreases as drilling activity decreases or when produced water transportation costs make reuse not cost-competitive with other water sources. Where reuse is not feasible, and where injection disposal well capacity is limited, treatment followed by surface discharge may be a viable option if it were a more widely available option. This includes treatment and discharge by CWT facilities and/or discharge by industry themselves if regulations were changed to allow this. Some in industry also indicated that indirect discharge via POTWs should continue to be an available option and would prefer that the EPA establish non-zero numerical pretreatment standards. A common theme among discussions with industry representatives is that options for produced water should be expanded. Those in the oil and gas extraction industry pointed to other industries that are permitted to discharge wastewater and would like there to be equity in this respect. An example given was petroleum refineries, which can discharge wastewater yet the oil and gas extraction industry that supplies petroleum to the refineries has limited discharge options. Some indicated that the technology is available to treat produced water to a level that meets water quality standards and is protective of the environment. Industry representatives noted that this may not have been the case when the oil and gas extraction ELGs were written, but treatment technology has changed since then. They believe that the EPA can determine what technology is necessary to treat produced water to be suitable for discharge, pointing to the EPA’s 2018 CWT study. Industry representatives indicated that technology on the production side has also changed since the oil and gas extraction ELGs were written. An example is the continued advances in horizontal and directional drilling. The volume of water used in drilling and fracturing these wells is much greater than was previously used. Therefore, more produced water is generated which presents management challenges. Also, some formations produce much greater quantities of water as compared to oil and gas. While drilling and well development activities are taking place, there is a demand for reuse of produced water Study of Oil and Gas Extraction Wastewater Management 23PDF Image | Study of Oil and Gas Extraction Wastewater
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