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Study of Oil and Gas Extraction Wastewater

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Study of Oil and Gas Extraction Wastewater ( study-oil-and-gas-extraction-wastewater )

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more quickly than an individual permit. Industry also indicated that were the EPA to revise its regulations to allow for broader surface discharge, there are potential barriers at the state level to issuing NPDES permits that may be difficult to overcome in some cases. Examples given were meeting water quality-based effluent limitations and antidegradation requirements. The primary concern raised by NGO representatives was the potential toxicity and human health and ecological implications of discharges of produced waters. This is due to the large number of chemical compounds used in hydraulic fracturing, well maintenance and other E&P activities. There are also constituents naturally present in producing formations that are contained in the resulting produced water. NGO representatives observed that many chemicals have little data on toxicity. In addition, they noted that disclosure requirements may be incomplete and much of the data that is disclosed is proprietary, further complicating assessment of toxicity and risk. They further noted that the chemistry of produced water is constantly changing as new chemical formulations enter the market and as advances in hydraulic fracturing occur, and that activities such as well maintenance and stimulation may use different chemistries. Another concern was the transformation of chemical constituents into other chemical compounds due to the high temperature and pressures that may occur within the well. NGO representatives indicated that little is known about these transformations and the toxicity of the transformation products that may occur. Section 4−The EPA’s Outreach to Stakeholders With respect to produced water characterization, producers noted that they disclose much of the constituents used in hydraulic fracturing. While noting that some constituents are proprietary, they indicated that in many cases it is the provider of the additive that claims confidentially and not the producer. Thus, they can provide the name of the additive but not the actual composition of the additive. They also noted that many of these proprietary constituents are non-toxic and would not pose a risk to the environment if discharged. However, they did note that some constituents can exhibit aquatic toxicity and they work with service companies to reduce the toxicity of constituents they use. They also indicated that treatment technologies are effective in removing the range of constituents present in produced waters and that the level of treatment can be adjusted based on the intended use of the treated produced waters. 4.4 Major Themes from Members of NGOs Some NGO representatives were also concerned that analytical methods do not exist for many of the chemical compounds used in E&P activities. In addition, they indicated that the high salinity of many produced waters can interfere with certain analytical approaches, complicating quantification of constituents in produced water. They were concerned that analytical shortcomings can complicate assessment of the human health and environmental risk associated with discharges of produced water. Another concern was that limited treatment technology performance data exists for many compounds present in produced water. They were concerned that it would be difficult to determine the appropriate treatment technologies, and to assess whether those Study of Oil and Gas Extraction Wastewater Management 26

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