MEMORANDUM

TO: Record

FROM: James K. O’Connell, ERG

DATE: June 9, 2016

SUBJECT: US Shale Plays Produced Water Management 2015: Cost Reduction 

Strategies Notes (DCN SGE01243)

On October 28 through 29, 2015, ERG attended the US Shale Plays Water Management 

Conference in Houston, TX. The conference materials are provided as attachments to this 

memorandum.

The conference notes are presented in order of the conference agenda. The corresponding 

presentation Document Control Numbers (DCNs) are indicated at the beginning of each notes section.

Key:

Blue text indicates text from the conference agenda.

Black text indicates ERG’s notes from the conference.

DAY 1: LONG-TERM WATER MANAGEMENT, PRODUCED WATER TREATMENT 

TECHNOLOGIES AND DOWNSIZED WATER FACILITIES

KEYNOTE CASE STUDY: A 360 DEGREE VIEW ON WATER MANAGEMENT COST 

OPTIMIZATION

9.10 Examining a Cradle-To-Grave Water Management Overview to Streamline Strategies for 

Ensuring Maximum Operational Margins

 Presenting an overview of the SandRidge Mississippi Lime produced water infrastructure to 

inform cost-effective water handling logistics

 Comparing sourcing and fresh water versus produced water to determine the most cost 

effective option for a given operation

 Considering an economic overview of produced water recycling to ensure quantifiable cost 

reduction in the short-term as well as the long-term

 Contrasting trucking with permanent infrastructure to ascertain the most financially beneficial

option

 Detailing the opportunities and pitfalls of midstream water management to advise prescient 

upstream operations
Cathy Pocock, Director of Marketing Produced Water, SandRidge Energy

Presentation – DCN SGE01243.A01

SandRidge: 

 Robust salt water capacity system with excess capacity

 Premier operator in Mississippi Lime 

 Producing over 1 million barrels of water a day

 Own the largest saltwater (produced water) gathering system in US

 Own and operate their own electric grid

2014 Reuse volume data on slide 8 (along with Characterization of the reused water)

Treatment options presented on slide 9 – best alternative to injection >$2.00/Bbl of produced water

Suggested that salt left over from treatment would flood the salt market if sold as a commodity 

Slide 10 compares treatment for various basins – disposal in MS Lime is still most cost effective 

Gathering is more efficient than trucking in basins where high volumes of wastewater are generated

Sub 75 cents/barrel disposal cost in the Mississippi Lime Basin

HOLISTIC WATER MANAGEMENT STRATEGY: PERMIAN CASE STUDY

9:50 Developing a Full Cycle Short and Long Term Water Management Strategy for the Delaware 

Basin Assets: Presenting the ConocoPhillips Permian Unconventional Water Management Team's 

Process

 Outlining the criteria for holistic water management solutions developed for the assets and 

decision analysis used select water management strategy for implementation

 Highlighting the cost and operational benefit of functional collaboration and integrated 

solutions

 Detailing the successfully piloted produced water treatment strategies that will maximize 

produced water reuse opportunities for ConocoPhillips in the Delaware Basin

Dr. Kristie McLin, Water Management Project Lead, ConocoPhillips

Presentation – DCN SGE01243.A02

If they reused all of their produced water, they could meet their frack schedule and still have water 

leftover

Produced water disposal costs can represent over 25% of lifting costs (also called production costs, the 

costs to operate and maintain wells and related equipment and facilities per barrel of oil equivalent of oil 

and gas produced after the hydrocarbons have been found, acquired, and developed for production)

Developed short-term strategies to immediately improve costs without investing in long-term 

infrastructure (the presenter did not elaborate with examples)

Water treatment goals focused on treating water for reuse
Reuse of produced water requires storage and gathering systems to be cost effective

Treated high iron in produced water – treatment shown in slide 14

Water management is a key piece of the cost effective delivery of oil production

ROI OF WATER RECYCLING

DEMONSTRATING THE EFFECTIVENESS OF WATER RECYCLING TO DELIVER A RISKAVERSE AND PROFITABLE WATER MANAGEMENT PROGRAM

FRAC FLUID COMPATIBILITY

11:00 Bacterial Disinfection vs. Compatibility - Supplier Case Study

 Reviewing how residual oxidation can affect Frac fluids

 Presenting methods to reduce compatibility issues while maintaining disinfection

 Discussing why residual oxidation is important for disinfection

 Reviewing field methods to monitor disinfection, residual oxidation and compatibility.

 Discussing the delicate balance between residual oxidation for disinfection and compatibility 

with Frac fluids

Mark Patton, Vice President of Sales & Marketing, Hydrozonix LLC

Presentation not provided 

Bacterial disinfection is a fundamental part of any water treatment program

Oxidizers provide a real-time method for disinfection by providing immediate results (fast-acting)

Comparison of oxidizers and non-oxidizers: oxidizers are better in every way except they create 

compatibility concerns; non-oxidizers are not better, but they do not create compatibility concerns

Source waters change from beginning to end of a frack

Titrations are the most accurate in field measurements for residual testing – may require dilution

Test strips are not accurate for produced water – too much interference

Have to be very careful with residual testing because free chlorine test methods can be inconsistent

Real Time Testing: Residual Disinfection – Free Chlorine and ATP (tests at Bold Johnson 56-T1-34 #1H)

Proppant does not appear to be source of bacteria

Prevent bacterial spikes with pretreatment systems – aeration (Hydrozonix have mobile aeration units)

Residual disinfection – less is more

Currently operating in Marcellus, Permian, and Eagle Ford 

TREATMENT VS. DISPOSAL
11.35 Presenting a Cost and Risk Assessment of Water Recycling Versus Water Disposal to 

Demonstrate the Financial Potential of a Smart Water Recycling Program

 Aggregating the capital expenditure on well cost, well drilling and price-per-barrel of water 

disposal to establish an accurate comparison with the cost of water recycling

 Investigating future regulatory direction and liability on disposal, induced seismicity and 

produced water spills to ensure a financially feasible long-term water recycle-reuse strategy

 Demonstrating chemical and mechanical water recycling techniques and methods to allow 

conservation of freshwater sources

 Exploring cost-effective and environmentally friendly uses for recycled water, including 

irrigation, to enhance public perception of operations

 Analyzing on-site and mobile water treatment methods to eliminate water transportation costs

Abhishek Gaurav, Reservoir Engineer, Texas Standard Oil

Presentation – DCN SGE01243.A03

Industry has moved towards water recycling since 2014

Slide 2 shows total water costs in different basins. Table 1 shows costs to obtain freshwater for fracking.

60% cost reduction when water is recycled compared to using only fresh water for drilling shale wells

Average TDS in flowback and produced water in various basins shown on slide 3

New treatment methods use chlorine dioxide (sodium hypochloride can also be used as oxidizing agent). 

This is discussed further on slides 5 and 6. 

12.15 Discussing Methods for Matching Energy Companies with Water Supplies And Water 

Services to Maximize Recycling, Secure Water Supplies, and Minimize Water Management Costs

 Cutting water management cost by instantly finding the closest, best and most competitive 

offers for water sourcing, trucking and disposal to save operators money on trucking and 

disposal "fare sales" while service companies sell more of their daily capacity for higher 

profits.

 Ensuring the water supply chain by providing multiple alternatives for water supplies and 

water services such as hauling and disposal at all times on short notice.

 Reducing environmental and community impacts of energy production by reducing average 

hauling distances, replacing some disposal well usage with recycling and offering nonfreshwater fluid sources.

Josh Adler, Founder & CEO, Sourcewater

Presentation – DCN SGE01243.A04

Water Management is #1 operating cost for O&G production 

Water hauling and disposal have a fixed capacity each day, and it behooves operators to fill that capacity 

because their operation cost is the same regardless of filling their disposal capacity

Economics = Markets Work
“Disposal Wells are like restaurants that don’t take reservations”

One of the main goals of the Sourcewater market place is to increase the use of non-freshwater resources 

PLAY-SPECIFIC CASE STUDIES

FEATURING WATER RECYCLING CASE STUDIES FROM THE PERMIAN AND THE EAGLE 

FORD TO ADDRESS PLAY-SPECIFIC CONCERNS AND TO INFORM PROFITABLE 

EXPENDITURE

PERMIAN: COST-EFFECTIVE WATER RECYCLING CASE STUDY

1.45 Showcasing a Profitable Permian-Based Water Recycling Program to Demonstrate the 

Financial Benefit of Water Treatment in Texas

 Determining how a successful operation disposed of less than 10% of the over 3.5 million 

bbls of water produced using an effective water treatment strategy

 Examining water chemistries, blended water mixtures and additives to prevent issues with 

scaling, corrosion and bacteria

 Evaluating costs to demonstrate the financial benefit of water recycle-reuse

Greg Wilkes, Permian Basin Operations Manager, Broad Oak Energy

Presentation – DCN SGE01243.A05

Perception that oilfield activity is drying up West Texas towns

Drilled water wells to pull from local aquifers

Built fresh water pit with evaporative cover

Have produced water tanks (open tops) – 2 on the north end, 5 on the south end

Able to reuse over 90% of water; ability to do so is relative to the quality of water – no barium, slickwater 

fracks

 Note: They are still using freshwater. They reuse over 90% of their produced water, but they still 

mix that with freshwater before sending downhole

Simple treatment to prepare for reuse

 Treat with chlorine dioxide – removes oil from water, lowers iron concentrations, and kills 

bacteria

 Filter water before heading to produced water tanks 

 Add chlorine dioxide before sending downhole

Bacteria is a very large concern

Run a scale inhibitor and friction reducer that can handle high chlorides on frack itself (no clay stabilizer 

needed)

Costs outlined on slides 29 – 31 
 Saving $200,000 per frack by using mixed water (approximately 1 frack per month)

Attempting to make an effort to minimize the use of fresh water

Currently no permits for reuse of produced water in Texas

Leak detection system and compliance with Texas Railroad Commission (TX RRC) pit standards are only 

requirement to reuse produced water in Texas

PERMIAN WATER TRENDS - SERVICE PROVIDER'S PERSPECTIVE

2.25 Examining the Trends in Water Use, Technology and Disposal To Identify Storage and 

Transfer Techniques Used in the Permian Basin for Hydraulic Fracturing

 Discussing water use for hydraulic fracturing and utilization of disposal, storage and transfer 

techniques to gauge trends that have evolved in the Permian Basin and the drivers for these 

trends

 Outlining trends in water treatment technology as well as fluid chemistry for hydraulic 

fracturing

 Reviewing the selection criteria for treatment technologies to clarify economic tradeoff and 

production impacts associated with these technologies

 Detailing case history examples on the total solutions of integrated projects to 

advise economically viable selection of technology and infrastructure

Walter Dale, Executive Director of Solutions, Bosque Systems

Presentation – DCN SGE01243.A06

Infrastructure costs are more limiting than treatment technology costs

Shift from advanced water treatment (Multi step total dissolved solids (TDS) removal) to removal of total 

suspended solids (TSS) and microbes along with water mixing to meet operator requirements for fluid 

specifications on challenging ions (B, Ca, Cl) & scale inhibition program.

Water treatment costs are decreasing

Waste removal costs are decreasing (discussed on slide 9)

Technology is one very small piece of return on investment (ROI)

While being environmentally conscious, the monetary bottom line will often be the biggest motivator

Produced water recycling is no longer limited by technology – many technologies are now available at 

low costs

Challenge to recycling is getting the buy-in of the landowner – some landowners may see recycled 

produced water as a competitor to fresh water. Because landowners are being paid for their fresh water, 

they may not want to encourage reuse.

Scale inhibitors are important for using mixed water for fracking
EAGLEFORD: TREATMENT FOR REUSE - 'FRACK TO TAP'

3.25 Positing Unrealized Water Recycling Potential to Treat Produced Water to a Potable Standard 

to Convert Contaminated Water into a Monetary Asset

 Gauging future potential for treating produced water to drinking quality to demonstrate the 

financial incentive for the development of water treatment techniques

 Investigating the immediate possibility of 'treat-to-discharge' into public water bodies to 

avoid the risks and liabilities of disposal

 Examining desalination processes to replace freshwater use with use of brackish within 

regulatory and OPEX limits

John Tintera, Regulatory Advisor, Texas Alliance of Energy Producers

Presentation – DCN SGE01243.A07

Former Exec Director of TX RRC

Frack to Tap – provocative concept: treating frac wastewater to be used as municipal drinking water.

Texas will be at the forefront of reuse among other US states because of drought conditions

 Nexus of arid climates and O&G developments

 Reusing half of the currently disposed of produced water could reduce Texas water debt by 25%

Texas has largest underground injection control (UIC) program in the world – issued 50,000 permits 

(30,000 still active)

EPA delegated permit granting status to TX RRC with a lot of oversight

More and more, surface landowners are claiming ownership of reused produced water

Toilet to Tap is beginning to emerge in the U.S. (treating sewage to be used as municipal drinking water)

 E.g., Wichita Falls during drought 

 Need was so dramatic in Wichita Falls that they were able to overcome public perception of 

Toilet to Tap

 Manure to Tap at Michigan State University (treating CAFO wastewater to be used as municipal 

drinking water)

Regulatory framework needs to foster reuse:

 Waters of the US definition seems to be expanding

 NPDES Permits pose high hurdles in Texas

 98th Parallel runs through the middle of Texas creating an odd situation for state regulators

because beneficial reuse is allowed west of the 98th

 EPA has focused on injection for disposal as the fate for produced water

Need incentives, not mandates for water treatment

“Water is where you find it, not where you need it” – will either need to transport it or treat it

Negative public perception of fracking adds an extra layer of public perception difficulty for frack to tap

(people are not just concerned about safety (or ick-factor), they are also concerned about frack operations)
Frack to Tap needs:

1) Decide who owns water

2) Regulatory vs. civil definitions

3) Landowner permission

4) Address local government

5) Work up to state level

6) Work up to federal level

Regulator’s priorities

1) Public safety

2) Environmental health

3) Economic prosperity

WATER TREATMENT

SHOWCASING PRODUCED WATER TREATMENT ACROSS FILTRATION, OXIDATION AND 

USE OF CHLORINE DIOXIDE TO ASCERTAIN THE BEST OPTION FOR A GIVEN OPERATION

PANEL: PRODUCED WATER TREATMENT TECHNOLOGIES - COMPARATIVE STUDY

4.05 Comparing a Variety of Water Recycling Technologies to Guarantee Effective and Economical 

Treatment Options

 Exploring technological advances in bacteria control and water holding facilities to reduce 

recycling costs while maintaining operational efficacy

 Inspecting friction reducers, subfractants and scale inhibitors to inform an appropriate 

stimulation fluid design

 Scrutinizing mobile water treatment units and passive lagoon systems to ascertain the faults 

and benefits of each method

 Investigating multi-purpose recycle systems to allow the treatment of flowback to frac water, 

deionized or fresh water standard

Moderator: Timothy Smith, President, Petro Lucrum

Panelist: Jason Boyd, Senior Chemical And Water Engineer, QEP Resources

Panelist: Robert Mitchell, VP Technology, Bosque Systems

Panelist: Mark Patton, VP Sales & Marketing, Hydrozonix

No presentation

Most treatment technologies are not new; the applications of the technologies are new

There is not an adequate understanding of how produced water quality and composition change over time 

and location

Need technology that can deliver in a wide variety of oilfield conditions
Treatment vendors have to have better business acumen for their technologies to properly penetrate the 

market

Scaling and logistics pose treatment challenges

Regulatory agencies want to see that treatment technologies are leak-proof, have a well-documented 

waste stream, use proper infrastructure

Operators are not required to report produced water spills, but they are required to clean them up

If regulators discover a spill/leak that hasn’t been properly cleaned up, the operator will be held 

accountable, not the treatment technology vendor

98th meridian is a distinction which marks a divide in the permit requirements for produced water, 

although the panelists believe this current distinction is out of date

Need adequate testing to be able to compare treatment technologies in real time

Challenges to reuse:

 Downturn in oil prices makes recycling less profitable

 Variety of oilfields and state regulations

 In Oklahoma, for example, one small spill of produced water could leave an operator broke, so 

it’s not worth the risk of recycling it

 Overregulation picks winners and losers



 The almighty dollar – reuse can be costly

5-year technology challenges for O&G wastewater:

 Where will the price of oil be then?

 Water will become a top commodity

 Not one single magic technology

 Will need to use more produced water with less treatment

 No desalinization – more savvy fracking techniques

 Future is reflection of lack of past communication

 O&G only uses 1% of industrial water use – Agriculture uses 40%

 Other industries will also be facing water issues which will cause more communication

Efficient desalination could lead to reuse of produced water for other industries

Texas legislature is mapping brackish water as a potential resource

Will likely see frack additives that are more compatible with produced water to encourage recycling

Once an operation is complete, the water does not simply go away – something will have to be done with 

it

May have to find alternatives to injection wells for disposal if there is continued public outcry over 

induced earthquakes

Technology trend: do what you did last year, but for half the price
From regulatory perspective: larger organizations don’t listen as well as small organizations

Lean more on unbundling frack packages and using less water (perhaps waterless fracking)

State driven regulatory incentives in tax packages that are cross-industry could be the future

DAY 2: COST OPTIMIZATION, REGULATORY DEVELOPMENTS, WATER 

SOURCING, STORAGE, TRANSFER AND COLLABORATION

WATER MANAGEMENT COST OPTIMIZATION

DISCUSSING CUTTING EDGE STRATEGIES FOR WATER TREATMENT, STORAGE, REUSE 

AND DISPOSAL TO GUARANTEE INSTANT COST REDUCTION AND COMPLIANCE WITH 

REGULATION

KEYNOTE CASE STUDY: REDUCING WATER MANAGEMENT COSTS

8.40 Analyzing Water Recycling Techniques, Repurposing of Produced Water and the Cost of 

Fresh Water Versus Produced Water to Ensure Cost Reduction in the Short and Long Term

 Contrasting the expenditure required for water recycling versus first party and third party 

disposal to determine the most cost-effective option

 Comparing the cost of fresh water versus produced water to guarantee economically viable 

frac operations

 Delineating strategies across frac water storage, treatment and reuse to ensure compliance 

with regulations

Frederick Schoch, Division Production Specialist, BOPCO

Presentation not provided

BOPCO:

 450 wells – located in Delaware, Bone Spring, Morrow, Atoka, and Strawn formations

 90,000 gallons of produced water per day

 200,000 net acres of contiguous land, mostly in Eddy County, New Mexico

 Want to reuse as much water as possible – find that using it for stimulation yields results as good 

as fresh water use

Industry may be moving towards sharing nearby produced water from other operators to conserve 

freshwater

Water in west Texas is an extremely important commodity – BOPCO wants people to see that the O&G 

industry is environmentally responsible 

Primarily use produced water to frack wells, but trying to do it without having to change frack fluid

About half of their acreage is dedicated to fracks using produced water 

243,000 – 312,000 ppm TDS in their produced water

Have to do scaling tests when using produced water in Delaware, for example, from Bone Spring
Treatment for produced water – filtration (50-100 microns), chlorine dioxide, and scale inhibitors

The cost of using produced water can be more effective if planned properly (sharing frack tanks for 

multiple wells, simpler well stages)

Developing infrastructure for a gathering system to connect three major areas

Holistic model to control water supply – even in the event of a leak, can still deliver water to frack jobs

SCADA system allows management of whole water system

110 miles of pipe in the ground – gathering system

WATER DISPOSAL AND SEISMICITY STUDIES

DELIVERING AN OVERVIEW OF STUDIES ON WATER DISPOSAL AND INDUCED 

SEISMICITY TO ENSURE ADHERENCE TO CLARIFY CAUSATION AND TO AVOID 

FINANCIAL PENALTIES

INDUCED SEISMICITY - KNOWNS AND UNKNOWNS

9.20 Analyzing Historical and Contemporary Evidence for Induced Seismicity to Ascertain 

Causality of Recent Earthquakes Across the Lower-48

 Presenting evidence for induced earthquakes during the 20th century to clarify causation

 Describing the scientific consensus about induced earthquakes associated with wastewater 

injection versus production and hydraulic fracturing to inform safe operations

 Comparing the hazard from induced earthquakes with the hazard from tectonic (natural) 

earthquakes

 Analyzing induced earthquakes to quantify their hazard level

 Discussing evidence for the potential for larger induced earthquakes than have occurred 

previously

Dr. Susan Hough, Seismologist, US Geological Survey

Presentation – DCN SGE01243.A08

Earthquakes in the midcontinent cluster over time

Induced earthquakes have been a threat to public safety for over 100 years

Fracking itself is not the cause of induced seismicity; evidence that deep injection is the cause of induced 

earthquake

 High-rate injection wells seem more dangerous than simply high-volume

Induced earthquakes, even more so than natural ones, are unlikely to be large

Details of how an earthquake breaks can determine how much shaking there is and how much damage it 

will cause

Shaking from induced earthquakes are a notch lower than from natural ones 
Induced earthquakes are shallow compared to natural ones, so it’s worse to be right on top of them

In general, people are afraid of the wrong things – earthquakes in the US are not a big hazard

PRODUCED WATER TREATMENT - COST REDUCTION

11.10 Managing Chemistry and Biology in Produced Water to Lower Total Reuse Costs

 Reviewing the chemical and biological composition of produced water to ascertain how these 

components affect water quality

 Outlining monitoring programs to identify causes of problem issues, verify treatment 

effectiveness and maintain water quality

 Discussing how levels of hydrocarbons, residual chemicals and degradable organics influence 

biological load, metabolic content and water quality dynamics

 Detailing water treatment processes for produced water including stages of treatment, 

components and product use, guidelines for operational parameters and quality targets

Dr. Scott Bailey, Senior Scientist, Flex-Chem

Presentation – DCN SGE01243.A10

Reuse quality targets drive treatment – formation requirements, chemical and biological stability, and 

fluid systems compatibility 

Water constituents and associated issues are discussed on slide 3

General water treatment process (for reuse) described on slide 4 overview

 Treatment train: TSS --> Oil & Grease --> COD/BOD --> Bacteria --> TDS

Slides walk through general treatment process, describing individual processes (primary separation, 

secondary separation, oxidation processes, organics & COD/BOD utilization, disinfection, filtration, and 

advanced treatment)

WATER SOURCING, TRANSPORTATION AND REFRACKING

PRESENTING NEW TECHNOLOGIES IN WATER MANAGEMENT AND REFRACKING TO 

MAXIMIZE OPERATIONAL EFFICIENCY AND TO ENSURE REGULATORY COMPLIANCE

WATER INFRASTRUCTURE COST-REDUCTION - BRINGING THE NEXT WAVE TO 

WATER MANAGEMENT

12.40 Analyzing Water Transportation Systems, Strategies and Regulations to Minimize 

Expenditure and Operational Liability

 Assessing water transportation and central logistics strategies to minimize water transport 

costs

 Comparing the pros and cons of trucking, pipeline and closed loop systems to ensure an 

accurate economic analysis of water transportation options
 Reviewing water use permits and regulations in Texas, New Mexico and Oklahoma to clarify 

issues surrounding water salinity, water spills and crossing state lines

 Considering terrain-appropriate pipe, pump and booster technologies to effectively cope with 

geographical elevation changes

 Contrasting temporary transfer pipelines, lay flat lines, high density polyethylene pipe and 

leak detection and prevention technology to create fail safe measures against water spills

 Examining the utilization of permanent hardline systems to economically convey water 

between frac lines and centralized facilities while reducing liability

Michael Dunkel, Member, Texas Independent Producers and Royalty Owners' Association

Presentation – DCN SGE01243.A11

Dunkel is a new VP at CH2M

Infrastructure could be a way to reduce costs long-term

Disposal limitations and risks vary by basin

Infrastructure is needed for both source water and disposal water

Energy Water Initiative’s February Report – possibly available on Anadarko’s website

Desalination is considered lower risk for water treatment

Small companies have often led innovation in drilling, and that seems to also be the case with treatment

Pipeline infrastructure is fairly complicated which is why it may not be widely popular despite seeming to 

pay back very quickly

More infrastructure will provide better opportunities for water treatment companies

PANEL: LONG-TERM WATER SOURCING PLAN: AQUIFER THICKNESS MAPPING

1.20 Proffering an Analysis of Historical Aquifer Thickness and Provincial Water Use Projections 

to Inform Sustainable and Fiscally Prescient Water Sourcing Strategies

 Presenting a long-term aquifer thickness study to recommend sustainable and fiscally 

prescient operational planning

 Inspecting the US Geological Survey's water use intensity map to advise on responsible 

employment of resources

 Assessing long-term population growth and consequent water use projections to apprise of 

necessary water guardianship

 Making a case for non-potable and saline water sourcing and water treatment to ensure water 

conservation and adherence to future regulation

 Interpreting recent EPA legislation to delineate water sourcing options and restrictions

 Considering Oklahoma's annual water-withdrawal limits based on aquifer characterization to 

inform Texas-based procedures

Moderator: Dr. Alan Chamberlain, President & CEO, Cedar Strat
Panelist: Michael Dunkel, Member, Texas Independent Producers and Royalty Owners' Association

Panelist: John Tintera, Regulatory Advisor, Texas Alliance of Energy Producers

Panelist: Josh Adler, Founder & CEO, Sourcewater

No presentation

Blanket regulations may not actually be suitable for all operators

O&G industry has rig exemption – operators can drill water supply wells without a permit

Water supply and waste disposal are two chokes on the O&G industry; they are the biggest limiting 

factors for operators

Rig exemption will likely be challenged, but will probably survive

It appears that operators are turning to brackish aquifers for source water 

Environmental groups will be suing the EPA to reverse the RCRA exemption (O&G waste is considered 

non-hazardous)

Regulators will likely start requiring operators to report produced water spills in Texas

Brackish water is easier to use for fracking than reused produced water 

REFRACKING: POTENTIAL OPPORTUNITIES AND PITFALLS

2.30 Investigating the Potential Economic, Operational and Regulatory Opportunities and Pitfalls 

of Refracturing Operations to Deliver a Financially Rewarding Re-Frac Blueprint

 Detailing the technical and economic differences between frac and re-frac to deliver a 

profitable re-frac strategy

 Reviewing cases of successfully re-fractured wells to provide a viable blueprint for engaging 

in re-frac operations

 Discussing potential discrepancies between frac and re-frac regulations to mitigate 

operational risks

 Describing the minimal footprint left by re-fracturing operations to demonstrate the method's 

potential public relations boon

John Tintera, Regulatory Advisor, Texas Alliance of Energy Producers

Presentation – DCN SGE01243.A12

TX RRC just issued Texas A&M a permit to use treated produced water for the irrigation of cotton crops

under 40 CFR 435 Subpart E

Refracturing will likely become widespread within 18 months (more information on slides 4 and 5)

Halliburton estimates that there are 50,000 wells that could be refracked – Tintera believes there could be 

more

Refracking unconventional shale reservoirs can continue the Texas shale revolution
Regulators often have to play catch up to treatment capabilities

Incentives are better than mandates