Recycling

Recycling is the generic term that encompasses all types of processing of industrial water, a discarded or waste material, for a subsequent use.  Two specific types of industrial water recycling can be implemented under Colorado’s regulations.

• Beneficial Use

Benefical Use is a specific regulatory way to recycle industrial water. The designation of a beneficial use is a formal regulatory decision (Beneficial Use Determination or BUD) by Colorado’s Solid Waste and Materials Management Program (Colorado Department of Public Health and Environment). According to this program’s regulations, beneficial use is the use of industrial water as an ingredient in a manufacturing process, or as an effective substitute for natural or commercial products, in a manner that does not pose a threat to human health or the environment. Avoidance of processing or disposal cost alone does not constitute beneficial use.

• Commercial Product

Extending the use of industrial water into a commercial product is another specific type of recycling. For example, the use of industrial water, or any of its components as an ingredient in commercial fertilizer, soil conditioner, or plant amendment would be recycling this material to a commercial product. This type of recycling is done under a license granted by Colorado’s Department of Agriculture (Inspection and Consumer Services Division).

Emerging Opportunities

The recycling of industrial waters is conducted in various ways, but the approaches under various state agencies is not consistent.

• Colorado Oil and Gas Conservation Commission (COGCC)

Industrial water generated as a by-product by oil/gas operations is termed produced water and can be recycled under certain regulatory conditions, which are complex in Colorado.

Under Colorado’s water laws, the oil/gas operator may recycle only produced water when they have the water right and accompanying water-well permit. However, recycling of non-owned water can occur if the operator replaces the produced water with water from other water rights.

Under the rules of the COGCC, produced water can be recycled for enhanced recovery, drilling, and other uses approved by the Director. Interestingly, produced water can be used for dust control, but this is considered as a disposal method. Also, the produced water may be supplied as an alternative supply of domestic water to surface owners within the oilfield. However, oil wells must obtain a water-well permit before the produced water can be directed to a beneficial use.

Beneficial Use Determinations have been made for produced waters from commercial recycling facilities, which are not facilities regulated by COGCC.

• Solid Waste and Materials Management Program

This state program recognizes beneficial uses of industrial waters under a specific approval process for each case. With the recent revision to their rules, there is encouragement for expanding beneficial uses of industrial waters.

Past Benefical Use Determinations have been made for-

• application of industrial water from water-treatment plants to amend roadway soils and control dust
• return of treated produced water to oil/gas operators for use in oilfield operations
• use of treated produced water, with high chlorides, for suppression on unpaved roads
• Other Practices

Industrial waters are commonly used for dust control within the boundaries of the industrial or commercial activity, as a Best Management Practice (BMP). One of the key requirements in air permits for fugitive dust control is application of water to control dust from disturbed land and unpaved roads. When available, on-site industrial water is used to meet this requirement. While not specifically approved, this activity is often extended to adjacent land areas. There are other instances under the terms of a discharge permit where treated industrial waters are used for agricultural waters (i.e., livestock truck washing operation, rinse water from milk tanks at commercial diary, increasing moisture content of material at composting facility).

The extension of industrial waters into a commercial product is a limited practice and mostly involves waters with solids having a valuable nutrient content.

With the increased recognition of the recycling opportunities available under Beneficial Use Determination (BUD) and Commercial Product regulations especially where those opportunities lead to additional revenues, there will be many of these projects in Colorado’s future.