January/February 2020

The 98th meridian is a longitudinal line that travels around the world. It just so happens to split right through Texas, just west of Austin.

You really can’t discuss the 98th meridian without bringing up Walter Prescott Webb, a Texan by the way. You see, Webb was director of the Texas State Historical Association, president of the American Historical Association, a University of Texas history professor, Harmsworth Professor of American History at Oxford and Nobel Prize nominee.

spwm patton33In 1950, his book, “The Great Plains,” was considered the most significant book by a living historian by a poll of professional historians. In it, he identifies a geographical shift from woods and tallgrass to more arid plains. Some people referred to this area as the “Great American Desert,” but Webb’s book changed this to the “Great Plains.”

This wasn’t just a geographical shift, but a lifestyle shift. Travel went from train and waterways to horses and wagons. Boots went from riding or cavalry boots to Western style or cowboy boots, wood and stone houses to sod and adobe houses, and food went from fresh to dried and barbequed.

In 1878, about 10 years prior to Webb’s birth, John Wesley Powell identified this same arid change along the 100th meridian in his “Report on the Lands of the Arid Region of the United States” issued to Congress. He pointed out a dramatic change in rainfall. Unfortunately, this report seemed to be largely ignored.

In the 70 years that passed, it was noted that this arid climate had shifted closer the 98th meridian. This transition into no man’s land was also associated with other significance. For example, insurance companies and lending institutions famously would not, as an agreed policy, lend a “shiny dime” west of this line.

So why do I bring up the 98th meridian? Well, the EPA has selected the 98th meridian as the demarcation where agricultural reuse is allowed west of this line and not allowed east of this line.

It’s important to note that this line represents a change in rainfall, and the need for water is more significant west of this line. But if produced water can be safely applied for agricultural reuse, why limit it to west of the 98th meridian? If water is a valuable resource, then isn’t it better to conserve it regardless of where you are?

The good news is this policy is under review thanks to the good work of many industry groups and the 98th Meridian Foundation.

There is more than this antiquated policy that needs to change. In addition to some specific exclusions like stripper wells, onshore produced water cannot be discharged to Waters of the United States (WOTUS).

The definition of WOTUS is also being changed as the current administration repeals changes made in 2015. Many considered the changes in 2015 to be an overreach that was procedurally incorrect and launched legal challenges to the rulemaking.

This administration’s changes would roll back the definition of WOTUS to the pre-2015 definition. This change is important as it plays an important role in where you can discharge and who has jurisdiction.

Another important step here is Texas’ recent move to gain primacy over produced-water discharges, making Texas and not the EPA responsible for issuing permits. These actions are moving us in the right direction and are critical to our future as an industry.

In contrast to the onshore prohibition of discharges of produced water, offshore produced water can be discharged into the ocean. If offshore, then why not onshore? Again, another antiquated policy that needs to change.

We have identified discharge standards for many discharges from chemical plants, refineries and even toxic-waste sites. These effluents concern me much more than produced water does.

“We don’t know what we don’t know”
One of the concerns that has been brought up for the case against produced water is that we don’t know everything that is in it. But I challenge that argument and say we know enough about produced water to identify treatment standards for discharge.

The idea that we don’t know everything can be applied to every discharge there is. We have just started to identify pharmaceuticals in our municipal discharges. I can guarantee we will continue over the next decade or two to find new chemical constituents in municipal water that are concerns.

Another important step here is Texas’ recent move to gain primacy over producedwater discharges, making Texas and not the EPA responsible for issuing permits.

There exist general toxicity tests that can be applied even if we may not know all the chemical constituents. But in most industries, we never know all the chemical constituents. You see, we may know what we introduce into water, but there are many byproducts formed and reactions taking place, and there does not exist test methods for all these possible interactions.

In other industrial applications, a practicality is considered, what are the key constituents I am worried about and can I identify them? Armed with this information, they identify treatment requirements for discharge. But in the case of produced water, the argument is we need to study and understand all the constituents.

Let’s look at scale inhibitors, for example. There are no test methods for every scale inhibitor used, but they are used in every industry around the world and not a concern in other industries.

I’m all for clean water, but it’s time we consider practicality like we do in other industries. It is very likely that we will be considering a membrane-type step for produced-water discharge to remove the dissolved constituents like salts, and as a result, we are removing constituents on a molecular level. We can perform general toxicity tests (i.e. bio-assays) to eliminate concerns that these discharges are toxic to fish and plant life.

Sustainability and Reputation
The problem is we have a bad reputation. And the alternative-energy folks and environmental groups continue to push that narrative.

A few years ago, natural gas was the bridge fuel to cleaner air. We transitioned buses and fleet vehicles to compressed natural gas (CNG). Then hydraulic fracturing brought us a significant supply of natural gas, and prices dropped to the lowest in decades. So much so that alternative energy couldn’t compete even with subsidies, and overnight natural gas was targeted as an even more dangerous threat to climate change than carbon dioxide.

I understand the chemistry behind the argument, but the argument wasn’t even considered until natural gas became a threat to the alternativeenergy industry.

If we want the oil-field watermanagement industry to prosper, we need to look to our future, and our future means focusing on sustainability. In the next five years, a technology will emerge to give us cost-effective discharge-quality water from produced water.

When we can transition into a producer of discharge-quality water, we can push back against sustainability arguments. We can recharge aquifers, provide water for agricultural reuse, and we will be impacting more than just the energy industry. We will be a net producer of water.

But we need to eliminate bad policy and archaic rules to pave the way to our future, and our future lies beyond the 98th meridian.

If we want the oil-field watermanagement industry to prosper, we need to look to our future, and our future means focusing on sustainability.




Authored by Mark Pattonspwm markpatton

Mark Patton is president of Hydrozonix. He has more than 25 years’ experience in the development, design, implementation and operation of treatment technologies. Mr. Patton’s oil and gas background includes treatment systems for waters, wastewaters, drilling muds, tank bottoms and process residuals. He holds one produced-water patent with two additional patents pending.

Mr. Patton earned his B.S. in chemical engineering from the University of Southern California in 1985.