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Jul 16 02 02:53p <br />Honorable T.A. Patalan. <br />Page 1 <br />February 4, 1998 <br />the proportions of water contributed by each well varies depending upon operating <br />conditions, the quality _ he pit will vary. i would, therefore, <br />recommend requiri periodic testing a both the water from the wells and the pit, <br />and the soils on tiv thew plied. The analytical results can then be used <br />to determine whether the water is and continues to remain suitable for its intended <br />purpose of irrigation and that it does not cause a build up of salts in the soils. <br />PRODUCED WATER GENERALLY IS NOT SUITABLE FOR MOST BENEFICIAL USES. <br />In the San Juan Basin, the concentration of dissolv ed. constituents In produced <br />water varies substantially depending upon the distance of the gas well from the <br />outcrop of the Fruitland Formation. Close to the outcronon the northern edge of <br />the basin where recharge occurs the TDS concentrations may be as low as 450 <br />mg /l. The gas wells sourcing the water in the Baird case are relatively c+ose to the <br />outcrop; therefore, the produced water has a relatively low TDS and may be suitable <br />for irrigation or .other intended beneficial uses. <br />However, in other portions of the San Juan Basin and in other areas of the state <br />produced water quality is so poor that it would not be suitable for most beneficial <br />uses unless significant treatment occurred, with the possible exception of using <br />some waters for dust suppression by road spreading or one time applications for <br />such things as fire fighting. For example, in the desper portions of the San Juan <br />Basin the TDS concentratio iga r p, he Fruitland Formation gas <br />wells typically range from 20,0/I to 30 000 mg/l. The TDS concentrations of <br />approximately 90 percent of all produced in Co oral exceed 10,000 mg /i. In <br />addition, produced water often contains a wide spectrum of dissolved hydrocarbon <br />compounds. <br />HIGH COST OF PROPER DISPOSAL OF PRODUCED WATER. <br />Because of potential impacts to surface water, ground water, soils, and biological <br />resources from the mishandling of produced water with high TDS concentrations <br />and dissolved or free hydrocarbons, the COGCC has rules that prescribe what can <br />be done with this waste. The cost for proper disposal of produced water is one of <br />the industry's largest operational expenses. <br />Ninety percent of produced water is placed back into the interior of the earth <br />through permitted injection wells. Most of the remaining 10 percent is disposed by <br />percolation and evaporation in pits with a very small fraction used for dust <br />suppression on lease roads. A few operators have received discharge permits from <br />CDPHE -WQCD and ere actually allowed to discharge produced water to surface <br />water, but the vast majority of the water produced in Colorado can not meet <br />discharge permit requirements without treatment and treatment is considered by <br />most operators to be prohibitively expensive. <br />P. 11 <br />nT•d des:ZT co 03 Raw <br />