How do 210 Water Reuse Authorizations relate to O&G Development? Jaya Zyman-Ponebshek, P.E. Assistant Director Water Quality Division

Who has Jurisdiction over wastewater quality issues? Memorandum of Understanding (MOU): Railroad Commission (RRC) and TCEQ 30 TAC §7.117 adopts, by reference, 16 TAC §3.30 ( p=9&p_dir=&p_rloc=&p_tloc=&p_ploc=&pg=1&p_tac=&ti=16&pt =1&ch=3&rl=30) p=9&p_dir=&p_rloc=&p_tloc=&p_ploc=&pg=1&p_tac=&ti=16&pt =1&ch=3&rl=30 Addresses the “cooperation and division of jurisdiction between the agencies regarding wastes that result from, or are related to, activities associated with the exploration, development, and production of oil, gas, or geothermal resources, and the refining of oil”

So…who do I go to for??? Process wastewater (exploration, production, & transportation) – EPA Region 6 Process wastewater (not associated with exploration production, & transportation) –Water Quality Division Stormwater – EPA Region 6 On-site sewage facilities – RRC Reuse/reclaimed water –Water Quality Division

Reuse/Reclaimed Water Why reuse wastewater? To help ensure an adequate supply of water resources for present and future needs through conservation of potable & raw water; both ground and surface waters resources.

Reuse/Reclaimed Water The option of using reclaimed water is especially attractive when water resources are scarce, as is the case during severe drought conditions.

Reuse/Reclaimed Water Authorizations Wastewater reuse can be authorized through a Chapter 210 authorization; or Directly via the rule in certain circumstances without requiring written authorization; or, Through an individual permit, either TPDES or TLAP.

Reuse under an Individual Permit Land application via a TLAP Site specific authorization with conditions reflecting the operation and location Requirements for the protection of surface and groundwater

Reuse under Chapter 210 Establishes quality criteria, design and operational requirements ( ac_view=4&ti=30&pt=1&ch=210) ac_view=4&ti=30&pt=1&ch=210 Criteria are established for the producer, provider, and end user Does not require public notice

Reuse under Chapter 210 Program is voluntary and on-demand; and, Primary means of wastewater discharge/disposal are required to ensure treated wastewater can be discharged/disposed when reclaimed water users are unable or unwilling to accept reclaimed water.

Reuse under Chapter 210: prohibitions The rule prohibits certain industrial wastewater streams from obtaining a 210 authorization These facilities would be required to obtain a Texas Land Application Permit to land apply wastewater

How can water be reused? Reclaimed water can come from industrial or municipal effluent and can be used to: Examples of reuse activities include: golf course and other irrigation activities dust suppression impoundment maintenance makeup water in industrial processes (e.g. cooling tower make up water), etc. Hydraulic fracturing

Using Reclaimed Water for Fracturing

Types of reclaimed water Municipal Type 1: reclaimed water uses include irrigation or other uses in areas where the public may be present during the time when irrigation takes place or where the public may come in contact with the reclaimed water.

Types of reclaimed water Municipal Type II: includes irrigation or other uses in areas where the public is not present during the time when irrigation activities occur or where the public would not come in contact with the reclaimed water.

Criteria ParameterType IType II (non- pond system) Type II (pond system) BOD 5 5 mg/l20 mg/l30 mg/l CBOD 5 5 mg/l15 mg/lN/A Turbidity3 NTUN/A Fecal coliform or E. coli 20 CFU/100 ml*200 CFU/100 ml* Fecal coliform or E. coli 75 CFU/100 ml** 800 CFU/100 ml** Enterococci4 CFU/100 ml*35 CFU/100 ml* Enterococci9 CFR/100 ml**89 CFU/100 ml** * 30-day geometric mean ** maximum single grab sample Reclaimed water on a 30-day average shall have a quality of:

Reuse under Chapter 210 Industrial Level 1 In specific situations an application/written authorization is not required. Reuse is conducted in compliance with the rule; and, Reused water will be used on-site; and, Industrial operations with low potential impact waste streams

Reuse under Chapter 210 Industrial Level 2 Requires the applicant to submit a request for an authorization; The Request must state the intended purpose(s) of the reclaimed water; The request will be evaluated by WQD staff; and, A written authorization will be issued.

Steps for Obtaining 210 Authorization A primary means of disposal is required for authorized Chapter 210 facilities via maintaining TPDES or a TLAP Permit. Persons who desire to develop projects not included in this rule may apply for a permit. Authorizations are typically processed within 60 days of application submittal. Chapter 210 does not require a public notice. Domestic application = $0 Industrial authorizations under Subchapter E = $100

Any Questions?