When oil is recovered in California, the produced water is disposed of via underground injection or unlined produced water disposal pond, where the water is disposed through evaporation and percolation. Each barrel of oil is produced with aapproximately 15 barrels of water
California oil production, most heavily regulated in the nation
- California’s energy producers operate under the nation’s most rigorous laws to ensure environmental protection and accountability.
- All water disposal practices are currently overseen by the California Department of Conservation’s Division of Oil, Gas and Geothermal Resources (DOGGR), the State Water Resources Control Board (State Water Board), and the local Regional Water Quality Control Boards (Regional Water Board).
- Disposal ponds are permitted only when the local Regional Water Board determines that they will not adversely impact water that has current or potential future beneficial uses.
- Permitted disposal ponds undergo routine inspections to ensure compliance with waste discharge requirements (WDRs).
“The ability to recycle the water or dispose of this water is crucial to energy production in the state.”
Need for an accurate inventory, clear definition of “ponds”
- The Regional Water Board undertook a review, assessing DOGGR’s records and aerial imaging of California’s energy production facilities in an effort to systematically inventory all of the region’s produced water disposal ponds.
- However, the Central Valley Board’s inventory is not an accurate representation of the region’s “ponds.” The current inventory mistakenly includes structures such as: stormwater management basins, secondary containment basins and lined temporary storage sumps and pits. Additionally, the current inventory includes a number of ponds and secondary containment basins that no longer exist today. Although a number of non-energy industries use secondary containment, the current inventory only includes secondary containment by energy producers.
- The Central Valley Board needs to maintain its focus to produced water disposal ponds, as originally envisioned.
“California’s energy producers operate under the nation’s most rigorous laws created to ensure environmental protection and energy production accountability.”
Also included in the current “ponds” inventory:
- Storm water management basins retain runoff to prevent flooding and improve water quality in neighboring supply sources
- Lined storage facilities are used to hold water supplies until they can be reintroduced into the energy production process, treated and used for agriculture, or transported and disposed
- Secondary containment basins are required control measures that surround storage containers, pumps and other equipment to capture fluid from emergency loss.
Recommendation: Establish appropriate regulatory oversight for California oil production and maintain focus on ponds only
- WSPA recommends that the Central Valley Board revise the applicability of the indefinite prohibition on the use of sumps, pits and ponds for produced water from a well that has undergone WST so that it does not create a de-facto ban on WST operations.
- Requiring the monitoring and reporting of all chemicals used in all aspects of oil production is overreaching and not necessary. Existing laws are in place to ensure that groundwater pollution does not occur from discharge into a surface pond.
- Monitoring and reporting programs established for each General Order need to be appropriate and feasible while continuing to protect water quality and the environment.