Submitted by Steve Conrad, Ph.D. groundwater hydrology
The recent op-ed by Sherry Robinson entitled “Step into the future with Produced Water” exhorts us to “trust technology and step into the future.” The problem with her premise is that the oil and gas wastewater treatment technology she suggests that we trust is unproven to be even remotely economically viable. In addition, no specified standards of what constitutes “clean” have been set. The treated water will necessarily have some solutes remaining after treatment. Will the water be safe enough for its intended use? We need unambiguous quantitative cleanup standards and we need them up-front before we get too far down the road to turn back. Many current peer-reviewed studies characterizing produced water from the Permian Basin state exactly that.
I have a Ph.D. in groundwater hydrology from New Mexico Tech and I worked at Sandia Labs for 26 years. I worked on safe radioactive waste disposal, a variety of groundwater cleanup projects, and DOE and EPA-funded research. It is my professional opinion that the proposed oil and gas wastewater reuse rule is based on inadequate data, and unspecified cleanup standards and fails to adequately protect New Mexico water from significant degradation.
As Robinson’s op-ed lays out, the oil and gas industry has a waste problem — 5 to 7 barrels of wastewater are produced for every barrel of oil — and it is running out of disposal options. Re-injection into the subsurface using disposal wells is causing deleterious seismic activity and has been curtailed in both New Mexico and Texas. Since 2019 when the Produced Water Act was passed industry supporters have been trying hard to sell the idea that all of this wastewater, aka Produced Water, can somehow be utilized as a plentiful new source of clean water for “agriculture, irrigation, potable water supplies, aquifer recharge, industrial processes or environmental restoration.”
So, here’s the thing: you don’t need any fancy pilot projects or demonstration studies to evaluate this scheme. All you need is a calculator — a calculator to tally up all the costs of treating this wastewater using current technologies. Simple, right?
Maintaining open access to information is the hallmark of good science and of good governance. So, let’s open the books and let technical professionals and the public see how much it will currently cost to clean up produced water. And if it’s not currently economically viable, show us what new technologies you plan to develop to reduce cleanup costs. Show us that it works and show us the cost. And show this to us up front.
One more consideration: it is expensive to move water from one location to another. Will all these industries slated to use this water move to the Permian Basin? Or will it be piped long distances away? And how much will that cost? How can we know if the plan is viable without this basic information?
Now, about cleanup standards for this wastewater. Will the treated water be safe enough for its intended use? What technologies will be used to meet them? These are simple, easily answerable, questions. And it is entirely reasonable that the public and the technical community receive answers before we proceed.
This scheme — especially given how little information the public and technical evaluators have been given to date about the specifics — doesn’t add up. It doesn’t make sense. What are we missing? If the technology we are being asked to trust is ready for prime time, then show us.
This produced water carries a whole host of dissolved petroleum hydrocarbons. This water also carries dissolved radionuclides and other solutes from the rock in which this water resides. And perhaps most importantly, this wastewater can often be far saltier than seawater. If removing this salt were economically viable, every coastal community would be meeting their water needs by desalinating sea water. But they don’t. Because it isn’t.
So the plan is that we will take treated produced water off the oil industry’s hands. The governor’s proposal is for the state to buy this water with the supposed intent to create a market for the treated wastewater and to eventually entice private enterprise to build treatment facilities themselves. One might ask, why must the state intervene to “create a market”? The answer is because there is no natural market for very expensive water that would recover the high cost of treatment. So the oil industry will sell treated water to the state at a high price so they can recover their treatment costs. And since the state will have no buyers for this high-priced water they will sell it at the far lower going-market rate. There will no longer be any need for the industry to independently find buyers for this treated wastewater. Instead, the state will take possession of this wastewater and then sell it to a variety of water users at a huge loss. This makes the industry’s wastewater disposal problem go away and it amounts to a huge hidden subsidy to the oil industry. If this were actually a viable scheme, the industry wouldn’t need state involvement at all. They could just treat this wastewater to accepted quantitative standards themselves and sell it on their own. But they aren’t. Because it isn’t.
Letter to the Editor: Rebuttal Response to Op-Ed on Produced Water
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Submitted by Steve Conrad, Ph.D. groundwater hydrology
The recent op-ed by Sherry Robinson entitled “Step into the future with Produced Water” exhorts us to “trust technology and step into the future.” The problem with her premise is that the oil and gas wastewater treatment technology she suggests that we trust is unproven to be even remotely economically viable. In addition, no specified standards of what constitutes “clean” have been set. The treated water will necessarily have some solutes remaining after treatment. Will the water be safe enough for its intended use? We need unambiguous quantitative cleanup standards and we need them up-front before we get too far down the road to turn back. Many current peer-reviewed studies characterizing produced water from the Permian Basin state exactly that.
I have a Ph.D. in groundwater hydrology from New Mexico Tech and I worked at Sandia Labs for 26 years. I worked on safe radioactive waste disposal, a variety of groundwater cleanup projects, and DOE and EPA-funded research. It is my professional opinion that the proposed oil and gas wastewater reuse rule is based on inadequate data, and unspecified cleanup standards and fails to adequately protect New Mexico water from significant degradation.
As Robinson’s op-ed lays out, the oil and gas industry has a waste problem — 5 to 7 barrels of wastewater are produced for every barrel of oil — and it is running out of disposal options. Re-injection into the subsurface using disposal wells is causing deleterious seismic activity and has been curtailed in both New Mexico and Texas. Since 2019 when the Produced Water Act was passed industry supporters have been trying hard to sell the idea that all of this wastewater, aka Produced Water, can somehow be utilized as a plentiful new source of clean water for “agriculture, irrigation, potable water supplies, aquifer recharge, industrial processes or environmental restoration.”
So, here’s the thing: you don’t need any fancy pilot projects or demonstration studies to evaluate this scheme. All you need is a calculator — a calculator to tally up all the costs of treating this wastewater using current technologies. Simple, right?
Maintaining open access to information is the hallmark of good science and of good governance. So, let’s open the books and let technical professionals and the public see how much it will currently cost to clean up produced water. And if it’s not currently economically viable, show us what new technologies you plan to develop to reduce cleanup costs. Show us that it works and show us the cost. And show this to us up front.
One more consideration: it is expensive to move water from one location to another. Will all these industries slated to use this water move to the Permian Basin? Or will it be piped long distances away? And how much will that cost? How can we know if the plan is viable without this basic information?
Now, about cleanup standards for this wastewater. Will the treated water be safe enough for its intended use? What technologies will be used to meet them? These are simple, easily answerable, questions. And it is entirely reasonable that the public and the technical community receive answers before we proceed.
This scheme — especially given how little information the public and technical evaluators have been given to date about the specifics — doesn’t add up. It doesn’t make sense. What are we missing? If the technology we are being asked to trust is ready for prime time, then show us.
This produced water carries a whole host of dissolved petroleum hydrocarbons. This water also carries dissolved radionuclides and other solutes from the rock in which this water resides. And perhaps most importantly, this wastewater can often be far saltier than seawater. If removing this salt were economically viable, every coastal community would be meeting their water needs by desalinating sea water. But they don’t. Because it isn’t.
So the plan is that we will take treated produced water off the oil industry’s hands. The governor’s proposal is for the state to buy this water with the supposed intent to create a market for the treated wastewater and to eventually entice private enterprise to build treatment facilities themselves. One might ask, why must the state intervene to “create a market”? The answer is because there is no natural market for very expensive water that would recover the high cost of treatment. So the oil industry will sell treated water to the state at a high price so they can recover their treatment costs. And since the state will have no buyers for this high-priced water they will sell it at the far lower going-market rate. There will no longer be any need for the industry to independently find buyers for this treated wastewater. Instead, the state will take possession of this wastewater and then sell it to a variety of water users at a huge loss. This makes the industry’s wastewater disposal problem go away and it amounts to a huge hidden subsidy to the oil industry. If this were actually a viable scheme, the industry wouldn’t need state involvement at all. They could just treat this wastewater to accepted quantitative standards themselves and sell it on their own. But they aren’t. Because it isn’t.