California water disposal operator forced to reassess practices

California’s Central Valley Regional Water Quality Control Board (CVRWQCB) on January 7 issued a cease-and-desist letter...
California’s Central Valley Regional Water Quality Control Board (CVRWQCB) on January 7 issued a cease-and-desist letter to Valley Water Management Company (VWMC), ordering it to clean up its McKittrick 1 and 1-3 wastewater disposal ponds or shut them down.
Located in Kern County, California, the ponds receive around 50,000 bbl/d of produced water from Sentinel Peak Resources’ operations at the South Belridge, McKittrick and Cymric fields. Since 1960 however, they have been used to dispose of more than 1.4 billion bbls from various operators.
The CVRWQB’s ultimatum comes on the heels of the shutdown of VWMC’s Fee 34 oil-water separation plant and Race Track Hill sprinkler system disposal site in January 2019. Water that had been sent to those facilities by Edison field operators is now injected into disposal wells. Sentinel may look to adopt this strategy in the future if the McKittrick ponds are shut down and has already begun the application process for permits to drill wastewater injection wells.
It remains to be seen whether recent concerns over pollution from disposal facilities will drive a reassessment of the use of unlined disposal ponds in the Central Valley. For now though, operators and regulators seem to be moving away from ponds and towards other water management options. Dale Harvey, supervising water resource control engineer for the board, told Water in Oil that this is partly due to the increased regulatory burden associated with operating ponds in recent years and water scarcity issues that have incentivized reuse in the oil and gas industry.
“Where the water is of sufficient quality and can be recycled appropriately, we want to see that done. If the water is of poor quality and can’t be treated or is too expensive to treat, then we want to make sure that it’s disposed of in a manner that is protective of water quality,” CVRWQB executive assistant officer Clay Rodgers told Water in Oil.
Water beneath the McKittrick facilities is already considered to be unsuitable for beneficial use outside of oil and gas due to its high salinity. The large volume of produced water discharge has worsened its quality however, creating a toxic plume that has migrated more than two miles northeast and is threatening to pollute groundwater used for farming.
VWMC has until January 2020 to submit a report which demonstrates that water at its McKittrick facilities will not pollute local groundwater or present a plan to close or upgrade the facilities by September 2020. If the company chooses the latter option, “they can treat the water so it meets the standards of what we want in the groundwater, which would be very expensive, or they can somehow build lined ponds and contain it onsite so that it does not percolate,” Rodgers said.
As of January 2019, the Central Valley contains nearly 1,100 disposal ponds, 539 of which are active. When asked if other ponds were being reviewed, Rodgers said the CVRWQCB has received funding to audit ponds that it had been unaware of until about five years ago. So far, around 50 cleanup and abatement orders have been issued to previously unknown disposal sites and the board has less than 100 more ponds to assess.
Harvey pointed out that most of the previously unknown sites are not considered a concern because some were used infrequently and many were small operations.

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