Oil and gas facility construction and expansion has created a situation where, to meet water needs, facilities have had to install water wells or tie into existing water wells to supply operations. Associated regulations begin with the Federal EPA and flow down to state regulators for permitting and enforcement. As the regulations read today, a facility supplied by a water well with over 25 personnel is regulatorily the same as a municipal water supply system (city).
Rather than evolving to accommodate these facilities, the regulations for such situations have grown stricter over the years and have created an obstacle to facility expansion.
Arguments for best management practices of placarding faucets as non-potable, installing a commercial water treatment system, and offering company-provided drinking water as compliance have been challenged by EPA and state primacy programs. An inconsistent regulatory definition of “25 employees” amongst inspectors can further complicate the issue. Two sets of regulations should be adopted; one for municipal water supplies and one for facilities.
In this presentation, I will discuss the value of having two distinct sets of regulations that will ensure safe and responsible use of groundwater while also allowing for economically building or expanding remote facilities.

Primary Author/Conference Presenter:
John Sullivan
Permian Basin Regional Manager
SCS Engineers
Midland, TX, USA

website: www.scsengineers.com