ENVIRONMENTAL ASSESSMENT for the 

Catalina Unit Coalbed Natural Gas 

Produced Water Disposal Project 

Carbon County, Wyoming 

April 2007
MISSION STATEMENT 

It is the mission of the Bureau of Land Managment to sustain the health, diversity, 

and productivity of the public lands for the use and enjoyment of present and 

future generations. 

BLM/WY/PL-07/019+1310 
United States Department of the Interior 

BUREAU OF LAND MANAGEMENT
 

Rawlins Field Office 
 

P.O. Box 2407 (1300 North Third Street)
 

Rawlins, Wyoming 82301-2407
 

April 25, 2007 

In Reply Refer To:

1790 (030) 

Re: 	 Environmental Assessment for the Catalina 

Unit CBNG Produced Water Disposal 

Project 

Dear Reader: 

This is to inform you of the availability of the Catalina Unit Coalbed Natural Gas (CBNG) 

Produced Water Disposal Project (Project) Environmental Assessment (EA) at the Wyoming 

Bureau of Land Management’s (BLM) website: 

http://www.blm.gov/wy/st/en/info/NEPA/documents/nepadocs07.html 

In order to satisfy the requirements of the National Environmental Policy Act, this EA was 

prepared to analyze impacts associated with the construction and operation of a water treatment 

facility and the discharge of up to 1.3 cubic feet per second of produced water to the surface, 

north of Baggs, Wyoming. 

It is expected that this EA can be viewed at our website beginning April 25, 2007. This will 

begin the 30-day public review/comment period for the document. We will review all comments 

and will address substantive comments in the Decision Record. A substantive comment is one 

that would alter conclusions drawn from the analysis based on (1) new information, (2) why or 

how the analysis is flawed, (3) evidence of flawed assumptions, (4) evidence of error in data 

presented, and (5) requests for clarification that bear on conclusions presented in the analysis. 

Your comments should be as specific as possible. Comments on the alternatives presented and 

on the adequacy of the impact analysis will be accepted by the BLM until May 25, 2007. 

Comments may be submitted via regular mail to: 

Travis Bargsten, Project Manager
 

Bureau of Land Management 
 

Rawlins Field Office 
 

P.0. Box 2407 
 

Rawlins, Wyoming 82301
 
2 

or may be submitted electronically at the address shown below (please refer to the Catalina Unit 

CBNG Produced Water Disposal Project): 

e-mail: rawlins_wymail@blm.gov 

Please note that comments, including names, e-mail addresses, and street addresses of 

respondents, will be available for public review and disclosure at the above address during 

regular business hours (7:45 a.m. to 4:30 p.m.), Monday through Friday, except holidays. 

Individual respondents may request confidentiality. If you wish to withhold your name, e-mail 

address, or street address from public review or from disclosure under the Freedom of 

Information Act, you must state this plainly at the beginning of your written comment. Such 

requests will be honored to the extent allowed by law. All submissions from organizations or 

businesses, and from individuals identifying themselves as representatives or officials of 

organizations or businesses, will be made available for public inspection in their entirety. 

The EA may also be reviewed at the following locations: 

Bureau of Land Management Bureau of Land Management 

Wyoming State Office Rawlins Field Office 

5353 Yellowstone Road 1300 N. Third Street 

Cheyenne, Wyoming 82009 Rawlins, Wyoming 82301 

If you require additional information regarding this project, please contact Travis Bargsten, 

Project Manger, at the Rawlins address or phone (307) 328-4387. 

Sincerely, 

 Field Manager 

Enclosure 
Catalina Unit CBNG Produced Water Disposal 	 Environmental Assessment 

U.S. Department of the Interior 
 

Bureau of Land Management 
 

April 10, 2007 
 

ENVIRONMENTAL ASSESSMENT TITLE PAGE 
 

Rawlins Field Office 
 

EA No. WY-030-07-EA-001 

Name or Title of Action: Catalina Unit CBNG Produced Water Disposal Project 

Proponent: Double Eagle Petroleum Company 

File Name, Number, and Location: Oil and Gas Lease WYC-075345A 

Surface Facility Location: T.16N., R.92W., 6th P.M., Sec 12, SW1⁄4SE1⁄4, Carbon County, Wyoming 

Discharge Point Locations: T.16N., R.92W., 6th P.M., Sec 13, SW1⁄4NE1⁄4, Carbon County, Wyoming 

Field Office: Rawlins Field Office (RFO) 

Rawlins Field Office (RFO) Interdisciplinary Team (IDT) 

IDT Member 	 Title 

Travis Bargsten Natural Resource Specialist 

David Simons Environmental Coordinator 

Andy Stone Hydrologist 

Patrick Lionberger Fisheries Biologist 

Andy Warren Rangeland Management Specialist 

Paul Rau Recreation Planner 

Rhen Etzelmiller Wildlife Biologist 

Nina Trapp Archaeologist 

Mark Newman Geologist 

Susan Foley Soil Scientist 

Jerry Dickinson Petroleum Engineer 

Activity Code: 	 1310 

Appendices: 	 A (Wyoming Pollution Discharge Elimination System Permit WY0054038) 

B (Cow Creek CBNG Project Channel Assessment, 08/09/2006) 

C (Discharge Point Information Addendum) 

D (Duck Pond Draw Water Quality Samples- Laboratory Analysis Reports) 
Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

INTRODUCTION 

PURPOSE AND NEED FOR THE PROPOSED ACTION 

The Proposed Action as described in this Environmental Assessment (EA) is necessary for the proponent to 

exercise lease rights and develop domestic natural gas resources. In Coalbed Natural Gas (CBNG) 

operations, water is removed from coal formations allowing for desorption of natural gas, principally methane, 

for production and eventual sale. Disposal of produced water is necessary to allow for continued natural gas 

production. The Proponent has indicated that the Proposed Action is necessary to provide for additional 

options in disposing of water within the Cow Creek/Catalina Unit CBNG development area. 

CONFORMANCE WITH LAND USE PLAN 

Oil and gas development is covered on pages 30-32 in the Great Divide Resource Management Plan (RMP), 

which was approved on November 8, 1990. Development of oil and gas reserves as described in the 

Proposed Action is in conformance with the RMP decisions which state that the Management Objective is to 

provide opportunity for leasing, exploration, and development of oil and gas while protecting other resource 

values. 

The development of this project would not affect the achievement of the Wyoming Standards for Healthy 

Rangelands (August 1997). 

RELATIONSHIP TO STATUTES, REGULATIONS, POLICY, PERMITS OR OTHER PLANS 

Onshore Oil and Gas Order No. 7 provides regulatory guidance regarding the BLM’s consideration of the 

surface disposal of produced water from oil & gas operations: 

“The person applying to use this disposal method shall furnish a copy of the NPDES permit issued by 

the EPA or the primacy State, a current water quality analysis and a Sundry Notice, Form 3160-5, 

describing site facilities (e.g., retention ponds, skimmer pits and equipment, tanks, and any additional 

surface disturbance). Operations from the point of origin to the point of discharge under the 

jurisdiction of the BLM. Operations from the point of discharge downstream are under the jurisdiction 

of EPA or the primacy State.” 

In this case “NPDES” is equal to the State of Wyoming- Department of Environmental Quality (WDEQ) 

“Wyoming Pollution Discharge Elimination System” or WYPDES permit. 

The State of Wyoming, then, has full authority over the issuance of WYPDES permits, except within the Wind 

River Indian Reservation, including their protection measures for water quality concerns. 

The National Environmental Policy Act (NEPA) provides that, among other things, “...the Federal 

Government...use all practical means... to improve and coordinate Federal plans, functions, programs, and 

resources to...attain the widest range of beneficial uses of the environment without degradation, risk to health 

or safety, or other undesirable and unintended consequences...” (42 USC § 4321). 

The BLM has developed guidance to apply this, and other portions of the NEPA. This guidance includes a 

“National Environmental Policy Act Handbook” (H-1790-1). Included in this guidance is direction about how 

and when NEPA is implemented, including: 

“All internally or externally Proposed Actions on or affecting public lands or resources under BLM 

jurisdiction must be reviewed for NEPA compliance” (Page I-1). 
Catalina Unit CBNG Produced Water Disposal 	 Environmental Assessment 

In implementing NEPA for similar actions in the past, the Wyoming BLM considered the relevancy of NEPA in 

considering produced water disposal to the surface in an Instructional Memorandum (IM) dated December 22, 

2004 (WY-IM-2005-014) and titled “Water Disposal and Land Application Disposal (LAD) in the Powder River 

Basin”: 

“BLM's role in the disposal of produced water from Federal CBNG wells, whether through the 

APD/Sundry process or by right-of-way application, is to approve the discharge after ensuring 

appropriate State permits have been obtained and the proposed method of disposal has been 

evaluated in a NEPA document... BLM may deny any application for water disposal that will result in 

serious environmental impacts to public lands after evaluating the proposal with a NEPA document.” 

In 2002, the RFO considered a proposal by Double Eagle to drill exploratory CBNG wells within the Cow 

Creek area in order to, among other things, gain information necessary to refine a Proposed Action for the 

AREIS. This proposal was considered to be an exploratory Plan of Development (POD) that would be 

consistent with the guidance to operators provided by the RFO in a document entitled “Interim Drilling Policy.” 

This exploratory POD (“Cow Creek POD”) was considered by the BLM in an Environmental Assessment (EA), 

and later authorized under a Decision Record/Finding of No Significant Impact (DR/FONSI). The Cow Creek 

POD EA considered produced water disposal by reinjection/disposal wells and by offset surface discharge. 

The surface discharge considered included: 

“...discharge [of] no more than 180,600 gallons of water [0.28 cfs] and/or 1.34 tons of salt per day into 

an ephemeral drainage...” above the existing Little Snake River Conservation District (LSRCD) 

reservoir located in Section 13 (T16N/R92W). 

The reservoir had been constructed in order to capture water released from an apparent casing leak in an old 

oil & gas well (#1X-12). A WYPDES permit (WY0042145) was issued June 19, 2001 by WDEQ to allow for 

surface disposal from the Cow Creek POD as an offset to the #1X-12 flow, once repaired and the leak fixed. 

Water under this WYPDES permit was captured in the reservoir for infiltration/evaporation. In September of 

2005, the WDEQ authorized a major modification to WYPDES WY0042145 to allow for “periodical operational 

releases from the LSRCD reservoir during the months of August-November for the purpose of providing water 

to livestock and wildlife.” This discharge was allowed since the additional salt loading was considered an 

offset to the fixed casing leak; the Colorado River Salinity Forum rules would have otherwise prevented the 

addition of this salt load to the Colorado River System. 

The Cow Creek POD EA also considered the disposal of additional produced waters (above and beyond the 

offset discharge to the LSRCD reservoir and reinjection). The additional surface disposal of produced water 

(“amounts in excess of 180,600 gallons per day (or 1.34 tons of salt per day)...”) was considered in the Cow 

Creek POD EA under alternatives including the use of shallow “aquifer recharge wells”, additional 

reinjection/disposal wells, or construction of additional reservoir capacity. 

The Proposed Action is located within the Atlantic Rim Natural Gas Development Project, which is currently 

being considered under an Environmental Impact Statement (EIS). The Final EIS (FEIS) was released for 

public review on November 27, 2006. The public comment period ended on January 4, 2007. The FEIS 

considers a single alternative for disposal of produced water: 

“Produced water from individual wells would be gathered and routed to centralized water handling and 

storage sites, which would serve as central injection facilities. Produced water would be disposed of 

through re-injection with two exceptions. 

1. 	 One exception could occur when a proposal comes forward from a land owner or an agency 

with surface management responsibilities for water for livestock/ wildlife watering sites. This 

could result in the use of closed watering systems for stock and wildlife. These systems will 

be designed with no discharge of water onto the surface, will have appropriate state permits, 

and will not be a significant portion of the water disposal needs for the project. 

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Catalina Unit CBNG Produced Water Disposal 	 Environmental Assessment 

2. 	 The second exception could occur when landowners or an agency with surface management 

responsibilities comes forward with a request for water to offset for the loss of current artesian 

water sources. De-watering of the coal seams has the possibility of drying up artesian water 

sources as detailed in chapter 4” (FEIS at 2-2). 

“All three alternatives propose the subsurface re-injection of produced water as a disposal method, 

with a limited surface discharge under permits issued previously by the State of Wyoming. If 

alternative uses of the produced water are identified and proposed, they can be considered and 

approved separately under another NEPA analysis and decision.” (FEIS at 2-10) 

The cumulative impacts analysis for the AREIS also discusses this proposed action: 

“A recently approved WYPDES permit for treated surface discharge of water (WDEQ permit 

#WY0054038) can be described as a pilot project. This discharge was permitted under the freshwater 

waiver conditions for the Colorado River Salinity Forum and would require treatment of the water to 

below 500 mg/L. BLM is considering this discharge under a separate analysis to determine 

significance. If the proposal is determined to be significant, a separate EIS will be required.” 

The Proposed Action includes the surface disposal of produced water, and represents an “alternative use of 

the produced water.” This proposal, then, is being considered separately from the Atlantic Rim Natural Gas 

Development Project, under this individual EA. 

The new proposal has not been considered under existing NEPA analysis. The Proposed Action is not 

exempted or categorically excluded from NEPA analysis, and requires consideration under a new NEPA 

analysis. 

The Proposed Action falls within an area where current CBNG exploration and development are taking place, 

known as the Cow Creek CBM Pod. This area is within what is currently known as the Cow Creek Unit. A 

new Unit is being formed in this area, inclusive of the project, called the Catalina Unit. The Proponent has 

submitted Applications for Permit to Drill (APDs) that would be considered under an eventual Record of 

Decision (ROD) for the Atlantic Rim Natural Gas Development Project EIS (AREIS). As such, the Proposed 

Action has been named the Catalina Unit CBNG Produced Water Disposal Project. 

PROPOSED ACTION AND ALTERNATIVES 

Proposed Action 

The general location of the proposed facility and discharge points is approximately 28 miles north of Baggs, 

Wyoming (Figure 1). The entire Proposed Action is located on BLM-administered public lands. Access to the 

proposed water treatment facility would be provided by existing roads off of State Highway 789. 

On December 7, 2005, the Rawlins Field Office received a Sundry Notice from the Proponent to: 

“...construct an Emit water treatment facility at this well site to receive production water from operator’s coal 

bed methane wells in the Cow Creek Field. Production water will be treated to reach standards required by 

the Wyoming Department of Environmental Quality in accordance with a newly issued NPDES permit that 

complies with standards of the Colorado River Salinity Forum. The well site [CCU#34-12, where the EMIT 

treatment facility is proposed to be located] would be enlarged to a maximum of 5 acres for the treatment 

facility. Reclamation of the enlarged well site area will conform to the existing well site reclamation 

requirements.” 

The Sundry Notice included a diagram showing the situation and arrangement of the proposed water 

treatment facility. 

3 

Catalina Unit CBNG Produced Water Disposal 	 Environmental Assessment 

In compliance with the regulations provided in Onshore Oil and Gas Order #7, the RFO responded to the 

Proponent in a letter dated February 8, 2006 and stated that “...we will delay consideration of your Sundry 

Notice until you have received approval of your WYPDES permit from the [WDEQ].” 

The Proponent had submitted a WYPDES permit application to the WDEQ in October of 2005. The WDEQ 

released the draft WYPDES permit (#WY0054038) for public comment on November 15, 2005. 

The draft WYPDES allowed for: 1) the release of no more than 0.84 million gallons per day (~1.3 cfs) of 

produced water; 2) the establishment of effluent limits for discharged water such as no more than 500 mg/L 

Total Dissolved Solids (TDS), 9μg/L Selenium, and a Sodium Adsorption Ratio (SAR) of no more than 3; and 

3) sampling of water quality parameters at designated stations on the Little Snake River, some 41 channelmiles from the project. 

On December 15, 2005, the RFO provided public comment to the WDEQ in order to provide RFO comment on 

a proposal that would directly affect BLM-administered public lands. The RFO comment letter included the 

following concerns: 

1. 	 Potential for impacts to water quality as a result of the release of treated water into ephemeral 

watercourse channels; 

2.	 Potential for erosion as a result of introducing a very different flow regime (higher volumes, continuous 

flow) into ephemeral channels with broad, shallow geomorphological characteristics; 

3. 	 Potential impacts to the Muddy Creek fisheries as a result of an altered flow regime and water quality 

changes; and 

4. 	 Inadequate monitoring design to assess impacts to water quality 

On March 31, 2006, the WDEQ authorized the WYPDES permit (WY0054038, Appendix A). The WDEQ 

provided a response to the RFO’s comment letter, and indicated that the approved WYPDES was changed to 

address the RFO concerns as follows: 

1. 	 Two additional water quality monitoring stations were included in the permit at Muddy Creek (above 

and below the confluence with Cow Creek) whenever discharge reaches that point. 

2. 	 Chronic and acute Whole Effluent Toxicity (WET) testing was added as a requirement. 

3. 	 A “stream channel survey” was added in which the proponent is required to “identify, map, and 

describe all constriction points and areas of high erosion potential.” The WYPDES requires that the 

proponent “revisit these locations on an annual basis...” and “Should erosional changes unrelated to 

runoff from large precipitation events occur at any of the constriction points and/or areas of high 

erosional potential, the permittee is required to mitigate the erosional damage... If the constriction 

point and/or area of high erosional potential shows movement of more than four (4) feet, either 

laterally or vertically, within a calendar year, the permittee must submit for review and approval a 

mitigation plan.” 

On August 10, 2006, the proponent’s contracting hydrogeologist provided a “Channel Assessment” 

(Appendix B) meant to satisfy the requirement of the WDEQ to conduct a “stream channel survey.” 

On September 12, 2006, the RFO met with WDEQ at the project site to review and discuss the proposal. 

The Proposed Action includes the treatment and release of water as provided for in the approved WYPDES 

permit WY0054038. Surface-disturbing actions are described in the Sundry Notice, and include the short-term 

5 
Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

surface disturbance of up to 5 acres at the well pad. Preparation of the site for equipment installation would 

include the removal and storage of topsoil and grading of the area. Buried pipelines would be installed from 

the treatment facilities to the two discharge points (see Figure 2). These pipelines would total approximately 

1,800 feet in length, and would result in a short-term disturbance width of up to 50 feet. The pipelines would 

result in the short-term surface disturbance of approximately 2.1 acres. Pipelines are expected to be buried to 

a depth of approximately 4 feet below the ground surface. 

In total, the Proposed Action would result in the short-term disturbance of up to 7.1 acres. Reclamation of the 

pipelines would be initiated within one year in accordance with the Master Surface Use Plan for the Cow 

Creek/Catalina Unit PODs. The facility area would remain in a disturbed state until the end of operations, for 

up to 20 years. Upon the end of operations at this facility, the above-ground equipment would be removed, 

and below-ground pipelines evacuated and buried in-place. Reclamation would then be initiated on any 

remaining areas in a disturbed state. 

Reclamation success is dependent upon a variety of factors, including precipitation. Reclamation would be 

expected to meet BLM standards for successful revegetation within five years. 

Traffic to and from the facility would increase during the construction phase and during the establishment of 

the facility. After this, traffic would decrease and would be similar to what currently exists in the maintenance 

of the existing CBNG development, with the addition of intermittent hauling traffic to carry away waste brine 

from the water treatment facility. 

Double Eagle has indicated that hazardous materials may be used and stored at the water disposal facility for 

this Proposed Action. Two 300-gallon tanks would store hydrochloric acid (HCl) to be utilized in the water 

treatment process. These tanks would be bermed to contain any accidental releases. 

The water treatment facility would utilize the Higgins LoopTM Continuous Ion Exchange process to reduce the 

concentration of solutes (lower the TDS). This would result in a discharge that would meet the WYPDES 

effluent criteria. A small amount (~1% of the waste stream) of concentrated brine would be formed. This brine 

would be stored on-location and then removed by trucks to the CCU #3-12 (located north of the treatment 

facility) where it would be reinjected as authorized by an Underground Injection Control (UIC) permit from the 

WDEQ. The treatment facility would include a 30’-tall tower. An EMIT “Applications Bulletin” provides a 

photograph of an installed typical “field unit” (Figure 3). 

Figure 3 

6 

Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Treated effluent from the facility would be transported by buried 12”-diameter pipeline to both of the 

discharge points, and released on the ground surface in the ephemeral channels. The discharge points 

will be constructed to reduce erosion at the point where effluent is released. This would include the 

construction of a cement box structure (See Appendix C). This structure would reduce water velocity, 

reducing potential for erosion at the discharge points. There would be adequate pressure head from the 

treatment facility; no pumps or water transfer stations would be necessary to transport the water from the 

facility to the discharge points. 

On June 8, 2006, the RFO Interdisciplinary Team (IDT) met with the proponent and the proponent’s consulting 

hydrogeologist at the proposed project site to conduct an onsite review of the proposal. The proposed facility, 

pipelines, and discharge points were reviewed and discussed. 

Development of Alternatives 

In the development of alternatives for this analysis, guidance from BLM policy contained in Washington Office 

Instructional Memorandum (WY-IM) 2005-247, dated September 30, 2005: 

“The alternatives that must be analyzed are those (1) which meet the purpose and need for the 

proposed action; (2) which reduce the adverse environmental effects of the proposed action; (3) which 

are feasible; (4) whose effects can be analyzed; and (5) which are not substantially similar in effects 

to an alternative that is analyzed.” 

No Action Alternative 

NEPA regulations require that alternative analyses in NEPA documents “include the alternative of no action” 

(40 CFR 1502.14(d)). For this analysis, “no action” means that the BLM would reject the proponent’s proposal 

and “the proposed activity would not take place.” 

Alternative A: Drilling of Additional Water Reinjection/Disposal Wells 

Under this alternative, additional reinjection/disposal wells would be considered to allow for subsurface 

reinjection of produced water from the CBNG operations to acceptable geologic formations and with the 

approval of necessary WDEQ Underground Injection Control (UIC) permits. 

The Proponent has submitted reinjection well APDs to the RFO for consideration appurtenant to development 

that is being contemplated under the AREIS. The RFO could consider additional reinjection well APDs for the 

existing development, also, if necessary. 

The typical reinjection well in this field is anticipated to accept approximately 5,000 bbls of produced water per 

day (the ARFEIS predicts the average water reinjection well will accept between 5,000 to 15,000 bbl water per 

day, and see Table 1). Disposal at a rate of 5,000 bbls/day equals approximately 0.32 cfs. It would be 

necessary, then, to drill up to 4 additional reinjection wells to dispose of the produced water proposed for 

disposal (1.3 cfs) in the Proposed Action (1.3 divided by 0.32 equals 4.1). 

Table 1: Injection Records for Cow Creek Unit Injection Wells (Source WOGCC) 

Injection Volume 

WELL NAME Injection Formation Average 

bbls/month 

Average 

bbls/day 

Cow Creek Unit 22-13i Deep Creek 149,691 4,990 

Cow Creek Unit 3-12i Nugget 147,200 4,907 

Cow Creek Unit 34-12 Mesaverde 170,194 5,673 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

The drilling of additional reinjection wells would result in approximately 3-4 acres of short-term surface 

disturbance per well. It is assumed that the reinjection wells could be located adjacent to existing access 

roads, and so additional disturbance to construct access roads would be unnecessary. In total, it is estimated 

that this alternative would result in the short-term surface disturbance of approximately 16.0 acres. Each 

reinjection well would require facilities to remain in a disturbed state for the duration of reinjection operations. 

This area would be approximately 0.8 acres of long-term surface disturbance per reinjection well. Pipelines to 

transport produced water from the CDP to the reinjection wells would be necessary, and may result in several 

acres of surface disturbance, depending upon where the reinjection wells would be located relative to the 

CDP. In total, it is estimated that this alternative would result in the short-term surface disturbance of 

approximately 24 acres, depending upon where the additional reinjection wells were located. 

Interim reclamation of the reinjection well pads would be initiated within 1 year of drilling and completion, and 

final reclamation would be completed upon plugging and abandoning of the reinjection wells. The wells could 

remain in service for up to an estimated 30 years, or the duration of CBNG development in the vicinity. 

Operations at these locations would result in additional traffic and activity associated with drilling, completing, 

and maintaining these facilities. 

Drilling of additional reinjection wells would require approved APDs from the BLM prior to drilling. 

ALTERNATIVES CONSIDERED, BUT ELIMINATED FROM FURTHER ANALYSIS 

Construction of Additional Storage Reservoir 

Under this alternative, a proposal from the Proponent would be considered (none has yet been received) to 

allow for the construction of additional reservoir capacity to store produced water from the CBNG operations. 

This alternative was developed in response to the effects expected from effluent discharge into ephemeral 

drainages, as detailed in this document and in other NEPA analyses (see Seminoe Road DEIS). 

Currently, the LSRCD reservoir has a capacity of approximately 121 acre-feet. This reservoir is approximately 

15.8 acres in areal extent. Under WYPDES WY0042145, the reservoir is accepting flow at a rate of no more 

than 0.28 cfs (0.1806 MMgpd). The reservoir is filled to capacity, and the evaporation, infiltration, and belowreservoir discharge allowed under WYPDES modification is not sufficient to reduce the level of the reservoir to 

allow additional flow. 

Thus, flow of 0.28 cfs exceeds the disposal capacity of the 121 acre-foot reservoir. Assuming that the water 

balance at this reservoir was exactly met, than it would take approximately 562 acre-feet of storage to dispose 

of the 1.30 cfs of flow in the Proposed Action. This would be equal to approximately 5 reservoirs the size of 

the LSRCD reservoir. 

Feasible locations for several large reservoirs is limited in this vicinity. Because of this impediment to analysis, 

and because the predicted impacts from the construction of 5 reservoirs may exceed those of the proposed 

action, this alternative was eliminated from detailed analysis. 

Transport Effluent By Pipe to Downstream Point 

This alternative was developed in response to the effects expected from effluent discharge into ephemeral 

drainages, as detailed in this document and in other NEPA analyses (see Seminoe Road DEIS). Under this 

alternative, the effluent from the water treatment plant would be transported by pipeline to the nearest 

perennial watercourse capable of handling the discharge volume, in order to reduce the potential for water 

quality changes, flow regime, and erosion along the route traveled by the discharge. 

Since the impacts from this alternative are extremely difficult to predict without a specific proposal (route of 

pipeline, knowledge of receiving watercourse, etc.), this alternative was eliminated from further consideration. 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

AFFECTED ENVIRONMENT 

The following critical elements of the human environment (Table 2) were considered in the course of this 

analysis. 

Table 2 

The Affected Environment is, in detail, described in the Cow Creek POD EA (2002) and the Atlantic Rim Draft 

EIS (ARDEIS, 2005). Those documents are incorporated by reference to this EA. 

Where no measurable effects are anticipated to a Critical Element or resource, descriptions (Affected 

Environment and Environmental Consequences) of that element or resource are limited in order to focus this 

analysis on the principal issues to be considered in making a decision. RFO IDT review of the proposal was 

used to identify what the principal issues are for this project. Where determined by the IDT to be necessary, 

Affected Environment descriptions are provided when that information is crucial for the context of considering 

the Proposed Action and alternatives. 

Geology/Paleontology 

Dry Cow Creek and its tributaries are principally located within the Cretaceous Lewis Shale Formation. The 

Lewis shale is a complex unit consisting of deltaic, interdeltaic, near shore and deep marine deposits. 

Although relatively resistant beds of deltaic sandstone exist in the Lewis Shale, the primary substrate on which 

drainage occurs in Dry Cow Creek consists of clay-rich sediment with a high degree of erodability. 

No known paleontological resources are present in the project area. 

Climate & Air Quality 

The Project Area is located in a continental dry, cold-temperature-boreal climate (Trewartha 1968). This 

climate is characterized by a deficiency of precipitation (i.e., evaporation exceeds precipitation), and generally 

has cold temperatures where fewer than eight months of the year have an average temperature greater than 

50° F, with warm summer days, cool summer nights, and cold winters. 

The wind is often strong and gusty, reflecting and channeling flows in response to complex terrain. During the 

winter months, strong winds are often accompanied by snow, producing blizzard conditions and drifting snow. 

The region experiences extreme wind gusts, especially during thunderstorm activity. Distinct diurnal changes 

occur, with surface wind speeds generally increasing during the day and decreasing during the night. Winds 

are generally out of the south or southwest, funneled out of the Little Snake River valley into the Muddy Creek 

drainage. Violent weather is relatively common in the area; thunderstorms occur an average of 30 days per 

year and hail an average of three days per year. These meteorological and climatological characteristics of 

the project area combine to produce a predominantly dry, cool, and windy climate punctuated by quick, intense 

precipitation events. 

Affected Affected 

Critical Element Yes No Critical Element Yes No 

Air Quality X T & E Species X 

ACEC’s X Wastes, Hazardous/Solid X 

Cultural Resources X Water Quality X 

Prime/Unique Farmlands X Wetlands/Riparian Zones X 

Floodplains X Wild & Scenic Rivers X 

Native American Religious Concerns X Wilderness X 

Environmental Justice X Invasive, Nonnative Species X 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Mean annual precipitation is about 7 - 9 inches in the project area depending on elevation. Precipitation is 

somewhat evenly distributed throughout the year with May being the wettest month (1.5 inches at Baggs and 

1.3 inches at Rawlins) followed by June, July, and October. January is the driest month (0.5 inches at both 

Baggs and Rawlins). The majority of precipitation falls as rain from frontal systems and thunderstorms. In 

regard to intensity of rainfall events, the 50-year, 24-hour precipitation rate ranges from 2.2 inches to 2.6 

inches in the project area (Miller et al. 1973). Precipitation in this region varies significantly from year to year. 

For example, at Rawlins, the month of May has had as little as 0.03 inch and January as much as 1.9 inches 

of precipitation. The greatest annual precipitation recorded at Rawlins was 12.6 inches in 1998, while the least 

was 4.9 inches in 1954 (WRCC 2005). 

Average total snowfall depth for the year at Baggs and Rawlins is approximately 38 inches and 52 inches, 

respectively, with the greatest snowfall occurring in December and January (WRCC 2005). Due to the effect 

of ablation and snow drifting, a discontinuous snow cover is usually present during the winter. Snow drifts in 

the headwaters of drainages provide critical water storage for shallow springs, streams and stockponds used 

as water sources in the late summer. 

Mean annual pan evaporation for this portion of southern Wyoming is about 75 inches, while the mean annual 

lake evaporation is around 55 inches. The potential annual evapotranspiration is roughly 20 inches (Martner 

1986). Compared to the average annual precipitation of 10 inches, this gives an average annual deficit of 

approximately 10 inches. 

Soils 

Runoff is medium to rapid and the hazard of water erosion is moderate to severe. 

Refer to Cow Creek POD EA (2002) and ARDEIS (2005) for a description of the soils in the project vicinity. 

Water Resources 

Drainage from the project area flows south and west to Muddy Creek, a tributary of the Little Snake River 

(Hydrologic Unit Code [HUC] 14050003) in the Colorado River Basin. Muddy Creek joins the Little Snake just 

above Baggs Wyoming, and the Little Snake River joins the Yampa-White river system within the Colorado 

River Basin (Figure 4). The Yampa-White river system is important for native fish recovery programs for the 

humpback chub, bonytail, Colorado pikeminnow, and razorback sucker. The Colorado River is probably one 

of the most utilized river systems in the west with innumerable municipal, industrial, and agricultural uses. 

Much of the Muddy Creek watershed is managed by the BLM and the land has historically been managed 

primarily for its range resources (agricultural uses, primarily grazing), as well as wildlife habitat, energy 

exploration and development, transportation, and recreational uses. Table 3 summarizes the available 

streamflow data from United States Geological Survey (USGS) stations in Muddy Creek. In 2004, the RFOBLM sponsored USGS surface water gauging Station No. 09258980 (Muddy Creek below Young Draw near 

Baggs). This station site is located immediately upstream of the discontinued USGS Station No. 09259000 

(Muddy Creek near Baggs - period of record 1987–1991). 

11 

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Table 3 Flow Statistics from USGS Gaging Stations Near the Project Area (Source: USGS) 

Station Name 

Muddy Creek 

near Baggs 

Station 

Number 

09259000 

Drainage 

area 

(sq. mi.) 

1,257 

(1,187)4 

Period of 

Record 

10/1/87 ­

9/30/91 

Mean 

Flow1 

(cfs) 

14.8 

Average 

Annual 

Runoff (acft/yr) 

10,690 

Median 

Flow2 

(cfs) 

2.8 

Min. 

Flow2 

(cfs) 

0.03 

Max. 

Flow2 (cfs) 

Date 

632 

3/23/88 

Muddy Creek 

below Young 

Draw near Baggs 

09258980 1,150 4/17/04 ­

present 19.1 13,828 3.7 0.13 236 1/12/05 

Little Snake River 

near Dixon 09257000 988 

10/1/10 ­

9/30/23 

10/1/38 ­

9/30/71 

4/1/72 ­

9/30/973 

514 372,400 100 0 10,400 

5/16/84 

1

 Over period of record

2

 Of mean daily values

3

 Contributing drainage area

4

 Daily flow measurements were only made from April through October during this time; not included in 

calculation of mean or median flow. 

Muddy Creek is described as a high-elevation, cold-desert stream. The watershed encompasses 

approximately 182 square miles, ranges in elevation from about 6,300 feet to about 8,200 feet, and 

extends from the Sierra Madre Range to the Red Desert. The relative yield from rainstorms becomes more 

significant in the lower elevations of the drainage basin. Base flow and intermittency commonly occurs 

from July through September, but can occur as early as April (Goertler 1992). Particularly within the lower 

segment of the Muddy Creek basin, tributary channels are generally dry and prone to flashy, periodic flood 

events from isolated thunderstorm systems from May to October. 

The upland watershed is dominated by sagebrush, while willow, greasewood, sedges and rushes are 

dominate within drainage channels (Beatty 2005). A few areas of wetland habitat has been created around a 

number of CBNG flowing wells near the project area. 

Ephemeral Systems 

An “ephemeral drainage” means a drainage that flows only in direct response to precipitation in the immediate 

watershed or in response to melting snow or ice. Moreover, ephemeral drainages are typically classified as 

“losing” in that the channel bottom is nearly always above the local water table. 

Ephemeral drainage channels dry out between storm events, which reduces infiltration capacity and increases 

surface runoff. Sediment in ephemeral systems moves in pulses with storm events resulting in wide channel 

forms with fine textured bed materials. Due to the dry soils in these channel bottoms, water predominantly 

moves as sheet flow or in macropores created by preferential erosion and/or animal burrows. Abrupt changes 

in flows can result from varying surface roughness (i.e., vegetation), channel gradient, and/or preferential 

channels which form in features like animal trails. These changes can cause water to concentrate and 

velocities to vary. Such changes may increase the rate of erosion in the channel. These flood events are 

usually short lived since a typical summer thunderstorm last less than an hour or two. 

Ephemeral channels are susceptible to erosion where there exist abrupt changes in the channel gradient (i.e., 

the channel slope). These vertical changes are typically referred to as “nick points”, and if large enough (> 1 

foot), “headcuts”. A headcut is an abrupt vertical drop in a channel and acts like a waterfall to accelerate the 

flow velocity (see Figure 5). 

13 
Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Figure 5. Photo on the left shows the early stages of headcut development. The photo on 

the right is the same area several months later. This erosion occurred from the surface 

discharge of produced water at a rate of approximately 1.35 cfs. 

Where a headcut is underlain by soft, easily friable soil, excessive erosion can occur. Erosion can continue in 

the channel below a headcut causing a gulley to form, and can cause the channel to be incised deeper than 

before (down-cutting) and will also erode upstream (a process called “headward erosion”). 

Surface Water Quality Characterization 

In the arid, high plains of southwestern Wyoming, surface water quality, like streamflow, is variable both 

spatially and temporally. Perennial stream water quality is generally of better quality than that of the 

ephemeral and intermittent streams. The quality of runoff is largely dependent upon the rates of salts, 

sediments, and organic materials that accumulate in the dry stream channels between periods of runoff. 

Factors that can govern the rate of buildup of these materials are the basin’s physical characteristics, land 

uses, and season of the year. 

WDEQ classifies water quality based on beneficial uses (current water quality classification for the project area 

are shown in Table 4). A summary of the water quality data from each of seven USGS surface water sampling 

stations located in the Little Snake River watershed (two on Little Snake River, three on Muddy Creek, and 

one each on Cow Creek and Dry Cow Creek) for the respective periods of record are shown on Table 5. The 

two Little Snake River stations represent perennial stream surface water quality in the area, the three Muddy 

Creek stations represent intermittent stream surface water quality, while the water quality in ephemeral 

streams is represented by the Cow and Dry Cow Creek monitoring stations. 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Table 4: Classification of Streams in the Project Area (Source: WDEQ) 

Surface Water Classification 

Little Snake River 2AB 

Muddy Creek (mouth to Sec. 29, T.17N., R.89W.) 2C 

Muddy Creek (remainder) 2AB 

 McKinney Creek 2AB 

 Cow Creek 2C 

Dry Cow Creek 3B 

Table 5: Surface Water Quality In the Project Area 

USGS Surface Water Quality Station 

Little 

Snake 

River 

Little 

Snake 

River 

Muddy 

Creek 

Muddy 

Creek 

Muddy 

Creek 

Cow 

Creek 

Dry Cow 

Creek 

Station Number 0925700 

0 

0925905 

0 

0925890 

0 

0925900 

0 

0925898 

0 

0911508 

0 

0925820 

0 

Sample period 1957­

1988 

1980­

1997 

1976­

1978 

1957­

1991 

May 

2005­

present1 

1978­

1979 

1975­

1980 

# of samples2 107 100 3 41 nm 20 9 

pH 8.1 8.1 8.6 8.2 nm 9.2 8.6 

Conductance, 

μmhos/cm 

(mean) 

259(34) 366(90) 1,350(2) 966(35) 1,300(111) 2,925(18) 2,162(5) 

Conductance, 

μmhos/cm (min.) 

82 87 600 529 598 700 460 

Conductance, 

μmhos/cm (max.) 

460 855 2,100 1,790 3,550 7,500 3,800 

TDS (mean) 158(9) 243(17) 913(2) 346(1) nm 1,801(6) 292(1) 

TDS (min.) 46 87 396 346 nm 561 292 

TDS (max.) 260 540 1,430 346 nm 3,013 292 

Suspended 

solids3 (mean) 

154(101) 228(25) 6,198(2) 3,191(41) nm 133(6) 1111(9) 

Suspended 

solids3 (min.) 

4 6 195 7 nm 30 8 

Suspended 

solids3 (max.) 

1,180 852 12,200 22,500 nm 315 6,180 

Turbidity, JTU 13 167 1,260 nm nm 284 1,013 

Calcium 30 34 54 42 nm 19 9 

Magnesium 8 12 44 40 nm 31 4 

Potassium 2 2 7 9 nm 11 4 

Sodium 11 26 200 286 nm 560 98 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

USGS Surface Water Quality Station 

Little 

Snake 

River 

Little 

Snake 

River 

Muddy 

Creek 

Muddy 

Creek 

Muddy 

Creek 

Cow 

Creek 

Dry Cow 

Creek 

Bicarbonate 159 190 373 308 nm 870 170 

Sulfate 25 54 380 320 nm 181 65 

Chloride 3 2 65 32 nm 132 21 

Iron, μg/L 74 164 105 nm nm 2,903 200 

Hardness 

(CaCO3) 

111 151 315 270 nm 174 37 

Dissolved 

Oxygen 

9 10 11 10 nm 9 11 

1 Daily mean values analyzed: May 27, 2005 to September 14, 2005.

2 Total number of grab samples analyzed; not every parameter was analyzed in every sample.

3

 Total concentration; except as noted here, all reported values represent dissolved concentrations. 

All units are mg/L except as noted. 

nm = not measured 

(34) = Number of samples analyzed for that parameter. 

As Table 5 indicates, considerably more measurements of specific conductance have been recorded than total 

dissolved solids (TDS) concentrations at these seven surface water sampling stations. For individual streams, 

a good relationship can commonly be established between specific conductance and TDS concentration. In 

general, as ionic concentrations increase, conductance increases (Hem 1970). Therefore, specific 

conductance measurements of streams in the project area are related to the dissolved solids concentrations. 

The USGS intends to collect periodic TDS concentration samples at Muddy Creek Station No. 09258980 

beginning in 2006 so that a relationship between conductivity, which is presently monitored hourly on a realtime basis continuously, and TDS concentration can be determined. 

Surface water quality within the Muddy Creek drainage basin, like streamflow, is variable both spatially and 

temporally. The ephemeral stream water quality, represented by the two Muddy Creek tributaries, is 

characterized by high and widely variable conductance and TDS concentrations (ranging from about 560 mg/L 

to over 3,000 mg/L), and the predominant ions are sodium and bicarbonate. The intermittent stream water 

quality, represented by Muddy Creek, is characterized by moderate conductance and TDS concentrations 

(ranging from around 350 mg/L to 1,400 mg/L), and the predominant ions are sodium, sulfate, and 

bicarbonate. The perennial stream water quality, represented by Little Snake River, is characterized by 

significantly reduced conductance and TDS concentrations (ranging from around 50 mg/L to 550 mg/L), and 

the water type is calcium bicarbonate. Note that limited samples were available from the ephemeral 

tributaries, and the samples that were available tended not to always coincide with the infrequent flood events. 

Ephemeral and intermittent channels, as well as the basin’s surface, that have periods of no flow accumulate 

loose material due to weathering, bank caving, livestock and wildlife movement, and wind deposits. This loose 

material is then readily picked up by the turbulent first flows of a flood event. Once the channels and basin 

surface have been flushed, then the suspended sediment concentration is dependent upon the magnitude of 

the runoff event and the erodability of the land surface and stream channel. The relatively high total 

suspended solids (TSS) concentrations recorded in Muddy Creek flows (concentrations averaging about 6,200 

mg/L and a high value of 12,200 mg/L) are indicative of the relatively high percentage of the land surface in 

the basin that has high or moderate to high runoff potential. 

Table 6 presents a summary of all Muddy Creek water quality samples that were available from the State of 

Wyoming’s WRDS database prior to installation of the new USGS Station No. 09258980 in 2004. Constituent 

concentrations on Table 6 represent the geometric mean of all the respective water quality constituents over 

16 
Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

the period of record (being 1933, 1976, 1978, 1979, and 1986 through 1993) at 16 separate water quality 

sampling stations throughout the Muddy Creek drainage basin. The average specific conductance is 

moderate at 599 micromhos per centimeter (μmhos/cm), pH is slightly basic at 8.2, the TDS concentration is 

442 mg/L, and the water is a calcium-bicarbonate type. High TSS (maximum concentration of 22,500 mg/L), 

coupled with high fecal coliform bacteria concentrations indicate that Muddy Creek would likely require 

disinfection and filtration if it were to be used as a potable supply. Naturally occurring radionuclides may also 

restrict the use of Muddy Creek as a drinking water supply. Mean uranium, gross alpha, and gross beta 

concentrations were 11 micrograms per liter (μg/L), 22 picocuries per liter (pCi/L), and 4.6 pCi/L, respectively. 

It is important to emphasize that the values in Table 6 do not necessarily represent the surface water quality at 

any particular location within the Muddy Creek drainage basin during any particular season of the year, but 

rather, are the composite representation of Muddy Creek water quality.] 

Table 6: Muddy Creek Water Quality (Source: WRDS) 

Parameter Unit Mean 1 Count Max Min 

Specific conductance μmhos/cm 599 128 2,450 324 

Total dissolved solids mg/L 442 31 1,430 227 

Total suspended solids mg/L 144 56 22,500 0.2 

Turbidity NTU 23 86 2,500 1.1 

pH standard units 8.2 137 8.7 7.2 

Dissolved oxygen mg/L 9.0 71 17.6 4.0 

Hardness as CaCO3 mg/L 258 134 555 100 

Alkalinity as CaCO3 mg/L 182 113 992 83 

Calcium mg/L 76 136 171 22 

Magnesium mg/L 12 136 84 3.9 

Sodium mg/L 15 135 300 0.3 

Potassium mg/L 4.3 135 51 1.6 

Sodium adsorption ratio none 0.43 135 10 0.01 

Sulfate mg/l 116 136 668 1.1 

Chloride mg/L 12 106 359 0.7 

Bicarbonate mg/L 214 135 2729 109 

Carbonate mg/L 1.2 115 47 < 1 

Fluoride mg/L 0.3 100 2.8 < 0.1 

Silica mg/L 15 8 39 5.6 

Coliforms, fecal count/100 mL 78 41 1,650 3 

Aluminum, dissolved μg/L 50 2 1 < 100 < 100 

Arsenic, dissolved μg/L 2.0 1 2 2 

Barium, dissolved μg/L 50 1 < 100 < 100 

Beryllim, dissolved μg/L nm 3 nm nm nm 

Boron, dissolved μg/L 64 5 360 10 

Cadmium, dissolved μg/L 0.5 1 < 1 < 1 

Chromium, dissolved μg/L 0.5 1 < 1 < 1 

Cobalt, dissolved μg/L nm nm nm nm 

Copper, dissolved μg/L 1.0 1 < 2 < 2 

Iron, dissolved μg/L 51 9 200 < 30 

Lead, dissolved μg/L 0.5 1 < 1 < 1 

17 
Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Parameter Unit Mean 1 Count Max Min 

Mangansese, dissolved μg/L 21 5 90 < 10 

Mercury, dissolved μg/L 0.25 1 < 0.5 < 0.5 

Molybdenum, dissolved μg/L 8 1 8 8 

Selenium, dissolved μg/L 3 1 3 3 

Silver, dissolved μg/L 0.5 1 < 1 < 1 

Uranium, dissolved μg/L 11 2 16 6.9 

Zinc, dissolved μg/L 10 1 < 20 < 20 

Radium 226 pCi/L 0.5 2 1.2 0.17 

Gross alpha pCi/L 22 2 23 22 

Gross beta pCi/L 4.6 2 6.5 3.3 

1 geometric mean

2 assumed half of detection limits for samples reporting “no detect”

3 nm = not measured 

Muddy Creek, as discussed in more detail later, is also critical habitat for three BLM sensitive fish species. 

Muddy Creek is the only known system to support all three of these sensitive fish species. 

Various streams in the project areas are identified in WDEQ’s 2004 Wyoming 305(b) Water Quality 

Assessment Report to the USEPA (WDEQ 2004b) as having water quality impairments or threats. Table 7 

summarizes the streams and potential problem parameters as listed on Wyoming’s 303(d) list of waterbodies 

with water quality threats. Threatened or impaired stream segments in and around the ARPA are depicted in 

the ARDEIS. Impaired or threatened streams in the Little Snake River watershed (HUC 1405003 and 

1405004) include portions of Muddy Creek, McKinney Creek, West Fork Loco Creek, Savery Creek, Haggarty 

Creek, and West Fork Battle Creek. According to the 2004 305(b) report, unstable stream channels and loss 

of riparian functions threaten aquatic life uses in Muddy Creek and McKinney Creek. 

Table 7: 303(d) Waterbodies With Impairments or Threats In the Little Snake River Basin 

(Source: WDEQ) 

Surface 

Water 

Impairments 

or Threats Location Impairments/ Threats 

Use 

Impaired/ 

Threatened 

Date Priority 

Muddy 

Creek 

Threats West of State Hwy 789 Habitat 

degradation; 

Non-game 

fish; aquatic 

life 

1996 Moderate 

Muddy 

Creek 

Threats Above Alamosa Gulch 

to Littlefield Creek 

Habitat 

degradation 

Cold fish; 

aquatic life 

1996 Moderate 

McKinney 

Creek 

Threats Above Muddy Creek to 

Eagle Creek 

Habitat 

degradation 

Cold fish, 

aquatic life 

1996 Moderate 

Groundwater Resources 

Groundwater resources include deep and shallow, confined (artesian) and unconfined (water table) aquifers. 

The unconfined aquifers are generally shallow, “blanket” type deposits of Quaternary or Tertiary age and are 

generally found 400 to 600 feet below the ground surface. Artesian aquifers are confined by relatively 

impermeable rocks and are generally in the deeper formations, such as the Mesaverde. Most of the geologic 

18 
Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

formations of pre-Oligocene age in the area contain water under artesian pressure (Welder and McGreevy 

1966). 

The Project Area occurs in the Colorado Plateau and Wyoming Basin groundwater regions described by Heath 

(1984), the Upper Colorado River Basin groundwater region described by Freethey (1987), or Washakie Basin 

described by Collentine et al. (1981) and Welder and McGreevy (1966). Groundwater resources include deep 

and shallow, confined and unconfined aquifers. Site-specific groundwater data for the project area are limited. 

Existing information comes primarily from oil and gas well records from the Wyoming Oil and Gas 

Conservation Commission (WOGCC), water-well records from the Wyoming State Engineer’s Office (SEO), 

from the USGS (Weigel 1987), and from the Wyoming SEO, from the USGS (Weigel 1987), from existing 

CBNG producing wells, and from three monitoring wells drilled to monitor pressures in producing coals and 

sandstone zones above and below these coals. 

Discharge Water Quality 

Groundwater quality is related to the depth of the aquifers, flow between aquifers, rock type and length of time 

groundwater is in contact with the enclosing rock type. Dissolved mineral content generally increases with 

time. Circulation in deeply buried aquifers is generally sluggish; as such, many confined aquifers contain 

slightly saline to very saline water at depth. TDS, an indicator of salinity, is generally less than 2,000 mg/l 

(slightly saline to saline), with occasional local concentrations of less than 500 mg/l. Elevated TDS is caused 

by a variety of factors, including evapotranspiration, mixing of adjacent aquifers, the presence of soluble 

material, and restriction of flow by faults or impermeable formations. Table 8 present composite Mesaverde 

groundwater results of the three CBNG wells. 

Table 8: Groundwater Quality For Mesaverde Wells In the Project Area 

Parameter Concentration1 Units 

Aluminum 0.045 mg/l 

Ammonia 0.9 mg/l 

Arsenic 0.0006 mg/l 

Barium 0.36 mg/l 

Beryllium <0.002 mg/l 

Boron 0.25 mg/l 

Cadmium <0.0002 mg/l 

Chloride 56 mg/l 

Chromium 0.002 mg/l 

Cobalt NM mg/l 

Copper 0.03 mg/l 

Cyanide <5 mg/l 

Fluoride 1.0 mg/l 

Hydrogen Sulfide NM mg/l 

Iron 3.06 mg/l 

Lead 0.004 mg/l 

Lithium NM mg/l 

Manganese 0.102 mg/l 

Mercury <0.0004 mg/l 

Nickel 0.041 mg/l 

Nitrate <0.03 mg/l 

Nitrite <0.03 mg/l 

Oil & Grease3 <1 mg/l 

Phenol 65 mg/l 

19 
Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Parameter Concentration1 Units 

Selenium <0.005 mg/l 

Silver <0.003 mg/l 

Sulfate 11 mg/l 

TDS 1,322 mg/l 

Uranium NM mg/l 

Vanadium NM mg/l 

Zinc 0.3 mg/l 

pH 8.2 s.u. 

SAR 47.3 <none> 

RSC4 41 meq/l 

Radium 226 + Radium 228 0.9 pCi/l 

Strontium 90 NM pCi/l 

Gross alpha NM pCi/l

1 Boron, ammonia, fluoride, and nitrate/nitrite concentrations from 11 Mesaverde 

groundwater wells (USGS, 1980); remaining concentrations from three Mesaverde 

CBNG wells in the ARPA. 

Dry Cow Creek Baseline Data Collection 

Dry Cow Creek is located in the Colorado River Basin and, as such, point source discharge permits are 

subject to provisions of the Colorado River Basin Salinity Control Forum (CRBSCF). As one of the seven 

member states of the forum, Wyoming reviews point and nonpoint sources of salinity in the Wyoming portion 

of the Colorado River Basin through a watershed protection program administered by the WDEQ/WQD 

(CRBSCF 1999). 

Channel Characterization: 

To document and characterize the geomorphology of Dry Cow Creek, the RFO conducted a detailed inventory 

of channel features was cataloged by photo-point along the entire length of the drainage in 2006. From this 

survey, four representative reaches were selected. In each survey reach, 5 monumented cross-sections were 

established and measured. 

The channel morphology in Dry Cow Creek is typical of ephemeral drainages in southern Wyoming in that the 

active channel and floodplain are nested in a steep-scarped, deeply incised first-order channel that is 6 to 10 

feet deep with paired terraces (Figure 6). Most of the steep scarps survey are unstable. 

Figure 6. Generic cross-section of a typical ephemeral desert drainage in southern 

Wyoming. (Note: water table was not observed as depicted in this figure. At the time of the 

surveys, the water table was below the channel bottom.) 

The active ephemeral channel is characterized by deep (~3 ft.) pools connected by narrow channels with welldeveloped riparian zones (Figure 7). Riparian vegetation primarily consists of Baltic sedges, with some upland 

forbs. Floodplain width varies, but is typically better developed (i.e., wider) adjacent to the shallow narrow 

20 
Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

channels, and on average, the sinuosity is low (Figures 7 and 8). 

Figure 7. The photo on the left shows a typical pool structure. Photo on the right shows the 

narrow intervening channel with a well-developed riparian zone. 

Figure 8. Downstream view of a well-developed riparian zone within a swale of upper Dry 

Cow Creek. 

The longitudinal profile from the head (upstream end) of each pool to the intervening narrow channel is 

typically very steep. Depending on the depth of the pool-head, the vertical transition from pool to channel will 

typically form a nick point (<1 ft.) or headcut (> 1ft.) (Figure 9). 

21 
Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Figure 9. View upstream of pool-head with steep headcut. Upstream migration of this 

headcut would dissect and vertically incise the shallow upstream channel, likely lowering the 

water table and adversely affecting the riparian community. 

Cross-sections from a non-wetted reach of Dry Cow Creek show this typical channel morphology (Figures 10 

and 11). Cross-section #3 (Figure 10) is immediately downstream from cross-section #4 (Figure 11). 

BCSR#1 X-sec #3 

Elevation (feet 106 

104 

102 

100 

98 

96 

94 

92 

0.00 10.00 20.00 30.00 40.00 50.00 60.00 70.00 80.00 

Station LB - RB (feet) 

Pool 

Figure 10. Cross-section through typical pool in lower Dry Cow Creek. 

22 
Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Elevati

on (feet 

Channel 

BCSR#1 X-sec #4 

106 

104 

102 

100 

98 

96 

94 

0.00 20.00 40.00 60.00 80.00 100.00 

Station LB - RB (feet) 

 Figure 11. Cross-section through typical channel in lower Dry Cow Creek. 

Flood Flow Calculations: 

The 25+ year and 1.5 year (i.e., “bankfull”) flood return discharges were calculated for Dry Cow Creek. Flood 

flow calculations used monumented channel cross-sections and longitudinal profiles established and surveyed 

as per the U.S. Forest Service protocol for Stream Classification Inventory (SCI). SCI protocol was used to 

identify bankfull and flood level indicators to calculate channel cross-sectional area (along with measured 

channel gradient), which was then used in the Manning equation to calculate discharge. 

Bankfull flow was calculated in a none-wetted reach of Dry Cow Creek using six monumented cross-sections. 

The intervening channels between pools had the best developed bankfull indicators and were thus used to 

calculate bankfull discharge. The range of bankfull flows calculated were within an order of magnitude, with the 

maximum being ~6 cfs, the minimum being ~1 cfs, and the mean being 2.8 cfs. This methodology is deemed 

more accurate than the USGS peak flow watershed calculations (i.e., Miller 2003), which are best applied to 

perennial systems. 

To calculate the 25+ year flood flow, channel cross-sections with flood indicators were measured as well as a 

crest gauge installed in a non-wetted reach of upper Dry Cow Creek. The crest gauge was used to establish 

the maximum flood elevation since 1972. For comparison, an eight foot (8 ft.) culvert with high water mark 

stains was used to corroborate the crest gauge and channel cross-section data. All methods were in strong 

agreement and showed the 25+ year flood discharge estimate to be ~400 cfs. 

Duck Pond Draw Channel Characterization: 

To compare channel morphology between a natural ephemeral channel (Dry Cow Creek) and a ephemeralturned-perennial channel (here called “Duck Pond Draw”), the BLM surveyed a reach along a draw that has 

been receiving surface discharge water for over 40 years. Three monumented cross-sections were 

established in Duck Pond Draw in an attempt to characterize the channel morphology. As one can see from 

Figures 12 – 14, the pool-channel-pool morphology common to Dry Cow Creek is not present, but rather 

channel adjustment has created a straight, continuous, and relatively deep and wide rectangular channel form. 

23 
Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Duck Pond Draw X-sec #1 

96 

97 

98 

99 

100 

101 

0.00 5.00 10.00 15.00 20.00 25.00 30.00 35.00 40.00 45.00 

Station (feet) 

Elevatio

n (feet

hoof 

damage 

water 

elevation 

Figure 12. Cross-section through the downstream segment of a typical reach in Duck Pond 

Draw. 

Duck Pond Draw X-sec #2 

96 

97 

98 

99 

100 

101 

0.00 5.00 10.00 15.00 20.00 25.00 30.00 35.00 40.00 

Station (feet) 

Elevatio

n (feet

water 

elevation 

Figure 13. Cross-section through the middle segment of a typical reach in Duck Pond Draw. 

24 
Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

0.00 10.00 20.00 30.00 40.00 50.00 

Station (feet) LB-RB 

Ele

v

ation (fe

et

water 

elevation 

Duck Pond Draw X-sec#3 

102
 

101
 

100
 

99
 

98
 

97
 

96
 

Figure 14. Cross-section through the upper segment of a typical reach in Duck Pond Draw. 

Duck Pond Draw Flow Rate Measurements: 

The discharge source for Duck Pond Draw is a flowing well located in Sec. 22, T16N, R91W (Figure 15). The 

water from this well has been dammed, creating a wetland immediately downstream. The water from this 

wetland is discharged downstream into an unnamed ephemeral channel (here called “Duck Pond Draw”). An 

effort was made to calculate the flow rate from the wetland down Duck Pond Draw in order to understand and 

compare how a perennial flow regime might affect Dry Cow Creek. Two open-channel flow rates were 

measured as well as flows calculated from culverts and one weir. All discharge measurements are within an 

order of magnitude and in good agreement. 

Duck Pond Weir: 0.08cfs 

Culvert: 0.11cfs 

Open-channel: 0.08 and 0.07cfs 

Duck Pond Draw Discharge Water Flow Distance: 

Discharge from the wetland downstream of the flowing well is flowing at an average rate of approximately 

0.09cfs. This water becomes a tributary to Dry Cow Creek and continues to flow down Dry Cow Creek into 

Cow Creek and beyond to Muddy Creek, some 8 miles for its point of origin. The distance over which this 

discharge water flows suggests that conveyance loss (i.e., evaporation, transpiration and infiltration) is much 

lower than previously thought. This may result from the channel becoming “armored” and impermeable as a 

result of high SAR values in the discharge water. 

Duck Pond Draw Water Quality Measurements: 

The BLM systematically sampled discharge water from the Duck Pond flowing well to the confluence of Cow 

Creek (Figure 15). The goal of the analysis was to see how water quality changed downstream, that is; were 

the physical properties (temp, pH, etc.) and chemistry relatively constant downstream or was there some 

change? 

To characterize the water quality from the Duck Pond flowing well to the confluence with Cow Creek, four 

water quality samples were taken (Figure 15). At the flowing well, samples were taken for Category I (general 

chemistry and physical properties) and Category III (metals) analyses. The remaining three samples were 

taken for Category I sampling only. Figure 15 summarizes how the TDS, SAR, and pH vary downstream. TDS 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

values steadily increase from 1240 mg/L at the source to 5400 mg/L at the confluence of Cow Creek. 

Likewise, pH increases from 8.48 to 9.53, and SAR increases from 66.9 to 90.9 over the same distance. The 

full chemical analysis of each water sample can be found in Appendix D. 

Vegetation/Wetlands/Invasive Weeds 

The Proposed Action is located in the sagebrush steppe plant community typical of the high inter-mountain 

desert of south-central Wyoming, composed primarily of Wyoming big sagebrush (Artemisia tridentata ssp. 

wyomingensis. Greasewood (Sarcobatus vermiculatus) is present along the riparian flats adjacent to the 

ephemeral channels proposed to conduct discharged produced water. Baltic rush (Juncus balticus) and other 

riparian plants are sproadically present in the ephemeral channels. 

The riparian vegetation and characteristics of Muddy Creek are described in detail in the ARDEIS (2005). 

No known protected-status plants are known to occur where surface disturbance is proposed. 

Salt-cedar (Tamarix spp.) is known to occur down-stream of the project. How close salt-cedar may be to the 

project is unknown, as the depth of many ephemeral channels in the vicinity preclude readily identifying 

populations from a distance. 

Halogeton (Halogeton glomeratus) is present in substantial quantity and over a large extent throughout the 

project vicinity, mostly on disturbed sites associated with previous oil & gas development. 

The project is located within the 85,375-acre Doty Mountain allotment. The season of livestock use extends 

from April 1 to December 1. 

Refer to Cow Creek POD EA (2002) and ARDEIS (2005) for a complete description of the vegetation, 

wetlands, and invasive weeds in the project vicinity. 

Wildlife/Fisheries 

There are many species of birds, mammals, amphibians, and reptiles within and adjacent to the project area. 

Several protected-status species are present or have been sighted in the vicinity, including sage grouse 

(Centrocercus urophasianus), mountain plover (Charadrius montanus), bald eagle (Haliaetus leucocephalus). 

Several other raptor species are known to be present, and several nests are located near the project. 

The area provides habitat for a number of large and small predators. Included in this group are mountain lion, 

bobcat, coyote, badger, red fox, weasel, skunk, and their allies. The area provides habitat for a number of 

small game and non-game animals. Included in this group are white-tailed jackrabbits, cottontail rabbits, 

amphibians, reptiles, and rodents. The project area and downstream affected environments provide yearround habitat for these animals. 

The proposed facility location provides nesting and rearing habitat for a number of passerine migratory birds 

as well as foraging habitat for raptor species. The area downstream of the proposed facility location provides 

nesting and rearing habitat for a number of waterfowl and shorebird species as well as the passerine birds and 

raptors. 

The proposed action occurs within mule deer herd unit 427. According to the WGFD, there are approximately 

22,500 mule deer associated with this herd unit. The herd unit encompasses approximately 1,843,500 acres 

and extends to the state border with Colorado. There is identified crucial mule deer winter range within 1⁄2 mile 

of the proposed facility location. Considering the increased amount of human activity present in the area, the 

project area is currently considered poor mule deer habitat. 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

The proposed action occurs within pronghorn herd unit 438. According to the WGFD, there are approximately 

12,700 pronghorn associated with this herd unit. The herd unit encompasses approximately 890,700 acres 

and extends to the state border with Colorado. There is identified crucial winter range within about 1⁄2 mile if 

the proposed facility location. Considering the increased amount of human activity present in the area, the 

project area is currently considered poor pronghorn habitat. 

This area is transition range for pronghorn antelope (Antilocapra americana), and provides important plant 

communities necessary to maintain adjacent crucial winter range along Muddy Creek. 

Sensitive Wildlife Species 

Raptors 

The burrowing owl is a BLM sensitive species known to associate with prairie dog towns. The area 

downstream of the proposed facility location contains active prairie dog towns and is potential habitat for 

burrowing owls. The ferruginous hawk is known to occur in the immediate vicinity of the proposed action. 

There are a total of 5 active and historic nests within 1 mile of the facility location. Three of these nests have 

been built on in the recent past, and one of them is within 1200 feet of the proposed facility location. Nest 

sites are generally located in areas of sufficient prey abundance. The area affected by the proposed surface 

discharge is considered foraging habitat for the ferruginous hawk. 

Sage grouse 

There are 3 known sage grouse leks within 2 1⁄2 miles of the proposed facility location. One of these leks (East 

Dad Road lek) is approximately 1.6 miles directly south of the proposed facility. An un-named lek was found in 

2006, and is located approximately 1.9 miles east-southeast of the proposed facility. The third lek (Dry Cow 

#4 lek) is located approximately 2.3 miles north of the proposed facility location. The East Dad Road lek was 

last known to be active in 1989 with 40 birds attending the lek that year. The newly identified lek had 4 males 

strutting in 2006. The Dry Cow #4 lek had 41 males in attendance in 2006. Given the proximity of these leks, 

it is highly likely that the sagebrush habitat in the area is nesting and brood rearing habitat for sage grouse. It 

is well known that early brood rearing habitat also includes riparian areas. As such, it is expected that sage 

grouse use the perennial systems downstream of the proposed facility location as early brood rearing habitat. 

The sagebrush habitat in the surrounding area also provides year-long habitat and winter habitat for sage 

grouse in the area. 

Bats 

There are four species of BLM sensitive bats that could be expected to occur in the project area. They are the 

long-eared myotis, fringed myotis, spotted bat, and Townsend’s big-eared bat. These species forage in 

riparian areas. Roosting habitat in the vicinity of the proposed action is limited, and there are no known 

colonies of bats roosting in the area. 

Prairie dog 

There are known active prairie dog towns in close proximity to the proposed facility location. The proposed 

effluent would pass adjacent to two identified towns that encompass approximately 479 acres. At the onsite 

inspection, the water treatment facility, pipelines, and water discharge points were reviewed. No white-tailed 

prairie dog (Cynomys leucurus) burrows were observed where in the immediate vicinity. 

Waterfowl and Shorebirds 

The trumpeter swan, white-faced ibis, and long-billed curlew, are all BLM sensitive species that may occur in 

the riparian areas downstream of the proposed facility location. 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Perching birds 

The sage thrasher, loggerhead shrike, Brewer’s sparrow, sage sparrow, and mountain plover are all BLM 

sensitive species that may occur in the habitat surrounding the proposed action. All of these species are 

associated with sagebrush, saltbush, or greasewood habitats which are found within the area affected by the 

proposed action. Sagebrush provides breeding, nesting, and brood rearing habitat for Brewer’s sparrows, 

sage thrashers, and sage sparrows. The loggerhead shrike can be found breeding and nesting in desert scrub 

habitat, sagebrush, and greasewood habitat. The mountain plover is breeds and nests in Gardner’s saltbush, 

short grass prairies, and open grassland habitats which can be found in close proximity to the proposed action. 

Threatened and Endangered Terrestrial and Avian Species 

Bald eagle 

The bald eagle is currently listed as a Threatened species under the Endangered Species Act. However, 

there is a petition to de-list the species that is currently under review by the USFWS and a determination is 

expected sometime in the summer of 2007. The eagle may potentially be found foraging in the area of the 

proposed action. However, no breeding, nesting, or roosting habitat exists in the area of the proposed action. 

The bald eagle is likely a year-round resident of the Little Snake River. There is a known bald eagle nest on 

the Little Snake River approximately 24.5 miles from the proposed action. The nest was last known to be 

active in 1996. 

Black-footed ferret 

The black-footed ferret is listed as an Endangered species under the Endangered Species Act. The proposed 

action lies within the Dad non-block cleared complex. Non-block cleared habitat is considered by the USFWS 

to be the only areas in which a wild black footed ferret could potentially exist. 

Threatened and Endangered Fish Species 

Four federally endangered fish species may occur as downstream residents of the Colorado River system: 

Colorado pikeminnow (Ptychocheilus lucius), bonytail (Gila elegans), humpback chub (Gila cypha), and 

razorback sucker (Xyrauchen texanus) (FWS 2004). All four of these fish species share similar habitat 

requirements and historically occupied the same river systems. Declines in populations of these species are 

mainly attributed to impacts of water development (e.g., dams and reservoirs) on natural temperature and flow 

regimes, creation of migration barriers, habitat fragmentation, the introduction of competitive and predatory 

non-native fishes, and the loss of inundated floodplains and backwater areas (Minckley and Deacon 1991, 

FWS 1993). 

The last documentation of any of these fish species occurring in the Little Snake River was of a single 

Colorado pikeminnow in 1990 (Baxter and Stone 1995). Subsequent survey attempts by the WGFD to collect 

Colorado pikeminnow from this area of the Little Snake River yielded no additional specimens. Critical habitat 

for these species has not been designated in Wyoming (Upper Colorado River Endangered Fish Recovery 

Program 1999). These species are not likely to be found in the main stem of the Little Snake River within 

Wyoming or its tributaries. However, the potential for project-related impacts to these tributaries of the 

Colorado River warrant their inclusion in this NEPA document. 

Sensitive Fish Species 

Fish species that are not listed as threatened or endangered under the ESA, but may be rare or declining 

within the state, have been included on the BLM Wyoming Sensitive Species policy and List (BLM 2002b). The 

intent of the sensitive species designation is to ensure that actions on BLM administered lands consider the 

welfare of these species and do not contribute to the need to list any of these species under the provisions of 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

the ESA (BLM 2002b). Muddy Creek contains one of the few relics of a native fish assemblage that once 

occupied the majority of the Colorado River Basin from southwestern Wyoming to Mexico. BLM Wyoming 

sensitive species within the Upper Muddy Creek watershed include the roundtail chub (Gila robusta), bluehead 

sucker (Catostomus discobolus), flannelmouth sucker (Catostomus latipinnis), and Colorado River cutthroat 

trout (Oncorhynchus clarki pleuriticus) (BLM 2002b). 

The BLM is also a signatory to the “Range-wide Conservation Agreement and Strategy for [3 of 4 sensitive 

species]” (UDNR 2006). This agreement establishes the BLM’s commitment to implement conservation 

strategies developed at both the range-wide and state-wide scales for these three species. 

These sensitive warm water fish species can be found within the Muddy Creek watershed upstream and 

downstream of the project area (WGFD 1998, 2004, Beatty 2005, Bower 2005). The proposed discharge 

would flow via an unnamed tributary into Dry Cow Creek, which enters Cow Creek 2.7 river miles above the 

confluence with Muddy Creek. These tributaries of Muddy Creek may be used by fish as spawning or rearing 

habitat on a seasonal basis. 

Research conducted during the summer and fall of 2003 and 2004 within the upper Muddy Creek watershed, 

including the project area, found the two most consistent habitat associations among roundtail chubs, 

bluehead suckers, and flannelmouth suckers to be positive associations with both rock substrates and deep 

pools (Bower 2005). These areas are most common where pool-riffle sequences are present (Bower 2005). 

Diets of bluehead sucker and flannelmouth suckers consist primarily of algae and some small invertebrates 

whereas, roundtail chubs feed on insects and some algae (Baxter and Stone 1995) Declines in the distribution 

of these species have been associated with the construction of mainstream dams, alteration of river flows and 

water temperatures, and hybridization and competition with non native fishes (Bezzerides and Bestgen 2002). 

Other Colorado River basin fishes that occur within Muddy Creek and its tributaries includes speckled dace 

and introduced species such as creek chub, fathead minnow, redside shiner, sand shiner, and white sucker. 

Refer to Cow Creek POD EA (2002) and ARDEIS (2005) for a complete description of the wildlife and fisheries 

in the project vicinity. 

Recreation and Visual Resources 

The Atlantic Rim area is very popular for dispersed recreational activities such as hunting, camping, hiking, 

wildlife viewing, OHV use, and sightseeing. The scenic qualities, large amount of unrestricted BLM surface 

outside of the checkerboard land ownership pattern, abundance of wildlife, and the solitude and primitive 

nature create a very opportunistic recreational environment attracting recreationists year round. Hunting is the 

most popular recreational activity in the area. Wyoming Game and Fish reported hunting use in this area as 

one of the most popular in southern Wyoming. A report of 2004 hunting pressure shows that Deer hunt area 

82 pooled a total of 10,488 recreational days during October 1 through 31; Antelope hunt area (with a limited 

quota) pooled a total of 1,222 from September 1 through October 14. Small game data indicates additional 

use outside the big game use. Cottontail rabbit pooled a total of 353 user days, and sage grouse pooled a 

total of 920. 

The project is located within Class III Visual Resource Management (VRM). The objective of this class is to 

partially retain the existing character of the landscape. The level of change to the characteristic landscape 

should be moderate. Management activities may attract attention, but should not dominate the view of the 

casual observer. Changes should repeat the basic elements of form, line, color, and texture found in the 

predominant natural features of the characteristic landscape. 

Refer to Cow Creek POD EA (2002) and ARDEIS (2005) for a complete description of the recreation and 

visual resources in the project vicinity. 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Cultural Resources 

A cultural resources inventory has been previously-conducted for the area directly impacted by the Proposed 

Action (water treatment facility, pipelines, and discharge points). No previous survey of the watercourse 

channels affected by the proposed discharge have been conducted, or to only a limited extent. Inventories 

conducted for other projects in the area, indicate that site density along the affected drainage would be high. 

No National Register of Historic Places-eligible sites were discovered where new surface disturbance is 

proposed, however, according to a recently conducted visibility analysis, the project area would be visible from 

one or more historic trails in the vicinity. 

Refer to Cow Creek POD EA (2002) and ARDEIS (2005) for a complete description of the cultural resources in 

the project vicinity. 

Socioeconomics 

Oil & gas development represents an important and significant contributor to the economy of Carbon County 

and the State of Wyoming. Natural gas production is important for the region and nation as a source of 

energy. 

Refer to Cow Creek POD EA (2002) and ARDEIS (2005) for a complete description of the socioeconomic 

setting of the Proposed Action. 

Health & Safety 

Hazards associated with this existing activities in the project area include occupational hazards from 

construction and development activity, increased traffic on roads, and low-probability events such as 

rangeland fires. 

Refer to Cow Creek POD EA (2002) and ARDEIS (2005) for a complete description of the health & safety 

setting of the Proposed Action. 

Noise 

Artificial noise within the project area currently arises from on-going oil & gas operations, vehicle traffic, and jet 

over-flights at high altitudes. The wind common to this area plays an important role in directing artificiallygenerated noise and in the background noise present. 

Refer to Cow Creek POD EA (2002) and ARDEIS (2005) for a complete description of the noise sources 

known to occur within the project area. 

ENVIRONMENTAL CONSEQUENCES 

Environmental consequences from produced water disposal in a manner similar to the Proposed Action are 

discussed in detail in the Seminoe Road Natural Gas Development Project Draft EIS (SRDEIS, 2005). The 

information and discussion in that document is incorporated by reference. 

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Catalina Unit CBNG Produced Water Disposal 	 Environmental Assessment 

Environmental Consequences- Proposed Action 

Geology/Paleontology 

No measurable impacts to geologic or paleontologic resources are predicted. 

Climate & Air Quality 

The construction and operation of the water treatment facility would have an impact, though immeasurable, on 

air quality. The impacts would include the addition of dust and vehicle emissions during construction, and the 

release of various production gases. The airborne pollutant concentrations that would result from emissions at 

the location and along the access road would meet all Wyoming and federal ambient air quality standards. 

Likewise, the impact to air quality-related values (visibility, acid deposition, and soils/vegetation) would not be 

noticeable. 

Soils 

Approximately 7.1 acres of surface disturbance would directly impact soils. Soil productivity on disturbed 

areas would be reduced until reclamation is effectively complete. Erosion from the constructed facilities would 

be controlled by the operator in accordance with the Master Surface Use Plan (Double Eagle 2002). 

The WDEQ-approved WYPDES permit would allow up to 4 feet of lateral or vertical stream channel erosion 

per year. Should this erosion occur (refer to discussion on Water Resources, below), large quantities of soil 

would be eroded and transported through the watercourses, and the proponent would be required to “submit 

for review and approval a mitigation plan.” This would not prevent accelerated erosion from beginning, but 

would “...prevent further erosion and potentially address the transport of sediment downstream” (WDEQ 

2007). 

Water Resources 

The Clean Water Act of 1987, as amended (33 U.S.C. 1251), established objectives to restore and maintain 

the chemical, physical, and biological integrity of the nation’s water. The act also requires permits for point 

source discharges to navigable waters of the United States and the protection of wetlands, and includes 

monitoring and research provisions for protection of ambient water quality. Wyoming Water Quality 

Regulations implement permitting and monitoring requirements for the Wyoming Pollutant Discharge 

Elimination System (WYPDES), operation of injection wells, groundwater protection requirements, prevention 

and response requirements for spills, and Water Quality Standards for Salinity in Colorado River System as 

recommended by the Colorado River Basin Salinity Control Forum and adopted by the State of Wyoming, 

Department of Environmental Quality. 

Assumptions for Surface Water Discharge 

The analysis for surface water discharge is based on the following specific assumptions: 

•	 Disturbance to soil and vegetation cover would increase water runoff and downstream sediment 

loads, and lower soil productivity thereby degrading water quality, channel structure, and overall 

watershed health in some locations. 

•	 The degree of impact attributed to any one disturbance or series of disturbances is influenced by 

several factors including location within the watershed, geology, time and degree of disturbance, 

existing vegetation, and precipitation. 

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Catalina Unit CBNG Produced Water Disposal 	 Environmental Assessment 

•	 Increased pollutants in surface waters from sediment and mineral-loading would degrade habitat used 

by aquatic life and would affect other beneficial uses (e.g., stock-watering, irrigation, and/or drinking 

water supplies). 

•	 Non-lithified, fine-textured, clay-rich soils are more susceptible to water erosion than bedrock and 

coarse-textured soils. 

Direct and Indirect Impacts 

Impacts from treated CBNG surface water discharge could include: 

•	 Accelerated erosion and runoff altering the physical channel characteristics beyond what would be 

expected with natural processes or the alteration of stream channel geometry or gradients that causes 

undesirable effects such as aggradation, degradation, or side-cutting. 

•	 Downcutting and vertical adjustment of the main channel will cause corresponding vertical 

adjustments to upland tributaries, accelerating erosion rates and resulting in a drop in local water 

tables, thus potentially affecting upland plant communities 

•	 Increased salt loading and degradation of water quality downstream (beyond “end of pipe”). 

•	 Degradation of water quality beyond the designated use of the receiving water body, or other 

violations of federal or state water quality standards or negatively impacting a water body listed on the 

State 303d list of Impaired or Threatened Waterbodies. 

•	 Reduced infiltration capacity of bed materials in the channel bottom. 

•	 Unmitigated loss of wetlands and wetland function (Executive Orders 11990 and 11988). 

•	 Removal (by loss of wetland function) of vegetation from channel bottom will reduce roughness 

thereby increasing flood runoff velocity and erosive energy. 

Salt and Sediment Loading in Surface Waters 

Duck Pond Draw Water Quality Measurements: 

It has been suggested that, although initial leaching may increase the salt load of waters discharged into 

ephemeral systems (“salt-flushing”), over time the quality of such water should stabilize with no appreciable 

net change or degradation. To test this assumption, the BLM systematically sampled discharge water from the 

Duck Pond flowing well to the confluence of Cow Creek (Figure 15). Since this well has been flowing for more 

than 40 years, it might be safe to assume that salt flushing has ceased and the water quality stabilized, yet the 

water chemistry tells a very different story. 

Figure 15 summarizes how the TDS, SAR, and pH vary downstream. TDS values steadily increase from 1240 

mg/L at the source to 5400 mg/L at the confluence of Cow Creek. Likewise, pH increases from 8.48 to 9.53, 

and SAR increases from 66.9 to 90.9 over the same distance (Figure 15). 

An aerial photo review and ground-truth surveys of the Duck Pond Draw drainage showed no distinct springs 

or other flowing wells that could be contributing salt or other constituents to the discharge water. Thus, salt 

loading must be occurring from the in-situ channel materials. 

Water sampling down Duck Pond Draw clearly indicates a degradation of water quality downstream, even after 

40 years of continuous discharge. Since the geology (Lewis Shale) and corresponding clay-rich soil type do 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

not vary appreciably between Duck Pond Draw and Dry Cow Creek, it is very likely that the proposed disposal 

of treated discharge waters down Dry Cow Creek will also degrade downstream, adding both mineral and 

sediment constituents to the water already flowing to Muddy Creek. CBNG water contributions to Muddy Creek 

are a concern because of the sensitive species issues identified for that drainage. The BLM has documented 

three warm water fish species (roundtail chub, bluehead sucker, flannelmouth sucker) found within the Muddy 

Creek watershed downstream of the project area (Beatty 2005). The Muddy Creek watershed appears to be 

the only stream system in Wyoming where populations of these three native, warm water fish species exist 

together (WGFD 2004). 

Channel “Armoring” 

Water quality data from Duck Pond Draw suggests a similar phenomenon will likely occur with discharge 

waters in Dry Cow Creek, that is, water discharged into Dry Cow Creek will likely degrade downstream. One 

result of such degradation would be an increase in the SAR value. With a SAR over 10, reduced infiltration 

capacity of the clay-rich soils making up the channel bottom is likely. This “armoring effect” would allow 

discharge waters to flow for long distances downstream. Observations from Duck Pond Draw suggest that 

discharge down Dry Cow Creek would reach the confluence with Cow Creek and likely Muddy Creek on a 

perennial basis. This could have adverse impacts on the three sensitive fish species identified in Muddy 

Creek. 

Erosion and Sedimentation 

As evidenced by Duck Pond Draw (Chapter 3, Figures 12 - 14), even extremely low discharge rates of 0.09 cfs 

in a low gradient system are sufficient to modify channel form (i.e. pool headcuts eroding upstream to link with 

other pools with subsequent vertical incision). The proposed continuous discharge rate of 1.27cfs for Dry Cow 

Creek is two orders of magnitude higher than the discharge volume moving down Duck Pond Draw. This rate 

is equivalent to approximately 50% bankfull flow (i.e., a 1.5-year flood flow return interval). The channel 

morphology of Dry Cow Creek has developed in response to infrequent and short-lived flood flows over the 

last several thousand years. By radically modifying the flow regime from ephemeral to near bankfull perennial 

discharge, the likelihood of severe channel modification is high. It is anticipated that the pool-heads 

(headcuts) in Dry Cow Creek will erode upstream, vertically incising the intervening channel, and eventually 

linking the pools. This, coupled with vertical incision, will increase sediment loads, mineral loads, and could 

negatively impact riparian communities by lowering the groundwater table. Similarly, rapid vertical incision of 

the main channel would cause an abrupt gradient change between the main channel and any tributary, thus 

creating a vertical instability, (i.e., headcut) at the tributary mouth. Once this instability is established, the 

headcut would propagate up the tributary, adversely affecting upland plant communities and increasing 

sedimentation beyond what would occur in a natural ephemeral system at equilibrium with its tributaries. 

In terms of lateral erosion, the existing first-order cut-banks are highly susceptible to sloughing and collapse 

because most are undercut. Continuous discharge will undermine these already unstable channel features, 

adding a long-term source of sediment to the system. 

Vegetation/Wetlands/Invasive Weeds 

Vegetation 

Construction of the water treatment facilities and pipeline would result in the short-term disturbance of 

approximately 7.1 acres of surface area. The range site carrying capacities in the Doty Mountain allotment are 

generally low (~9-11 acres/animal-unit month (AUM)), and it is predicted that less than approximately one 

AUM (~780 pounds, air-dry) of forage would be lost during construction operations. 

However, if downcutting, vertical adjustments, and corresponding upland erosion occur, the long-term loss of 

25-50% of the AUMs would occur, as the upland plant communities are stranded by a dropping water table 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

and increased erosion, further resulting in increased bare ground and gully erosion. The areal extent of this 

potential effect is unknown. In the short-term this effect is expected within the sub-watershed area draining to 

the confluence of the unnamed ephemeral channel with Dry Cow Creek. This sub-watershed area is 

approximately 5,300 acres in size. In the long-term, this effect is likely to occur within the watershed draining 

to the confluence of Dry Cow Creek and Cow Creek, with a much larger area potentially affected (the area of 

the Dry Cow Creek watershed, 43,178 acres). The potential for this type of impact to the Cow Creek 

watershed or Muddy Creek watershed is unknown. 

With the addition of a perennial watersource in the transition range bordering crucial winter range, it is 

expected that mule deer and pronghorn could increase grazing pressure on already-declining sagebrush 

communities. This would further decrease forage condition. 

Wetlands 

Dry Cow Creek currently maintains several riparian/wetland corridors dominated by Baltic rush with some 

upland forbs. The current functioning condition of these riparian areas is adequate to dissipate energies 

imparted by the infrequent, short-lived flood event. However, with the proposed perennial discharge of 1.27 

cfs, it is unlikely that Baltic rush will be able to sustain a stabilizing condition. 

Headward erosion of the pools and vertical incision can destabilize the banks and possibly lower the local 

groundwater table. Unless mitigated, this problem would only increase with time. Lowering of the local 

groundwater table will reduce the presence of riparian vegetation by stranding plants from taking up water 

throughout much of the growing season, particularly Baltic rush. 

If one compares the riparian characteristics between natural non-wetted reaches of Dry Cow Creek with that of 

the wetted reaches, one can see a marked difference in the width and vigor of the riparian system (Figure 16). 

Figure 16. Photo on the left shows a wetted reach of Dry Cow Creek that has received 

discharge water for over 40 years. Note the narrow band of vegetation along the banks as 

compared to the photo on the right where the distribution and vigor of the vegetation is 

markedly higher. 

In the case of Figure 16, the non-functional condition of this reach (left photo) is a result of more than 40 years 

of continuous surface discharge and channel erosion. The additional proposed input of 1.27cfs will only 

exacerbate the problem and make these channels and floodplains more susceptible to damage during natural 

flood events. Loss of riparian vegetation from continuous discharge will decrease the roughness of the channel 

bottom, thereby increasing the velocity and erosive power of flood flows. 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Invasive Weeds 

The disturbance associated with construction activities may result in the subsequent infestation of projectrelated disturbances by Halogeton, which is present on adjacent disturbances in the Cow Creek/Catalina Unit 

area. Altering of the channel geomorpohology and water table below the discharge points may result in the 

spread and increased vigor of salt-cedar populations, should they be present in affected areas. 

The Proponent will be required to control weed infestations arising from their operations; the identification and 

monitoring of salt-cedar populations (if present) would be necessary to determine if the Proposed Action 

results in the spread of salt-cedar. 

Wildlife/Fisheries 

Wildlife 

The project is located near sage grouse leks, mule deer crucial winter range, and raptor nests, but outside the 

Controlled Surface Use areas for sage grouse leks (See Figure 17). Seasonal restrictions will be applied to 

avoid potential effects to these protected species and habitats. 

The short term impacts from the proposed action would include displacement of wildlife from the immediate 

area of the proposed facility location during the construction of the site facility. However, given the proximity of 

the location to existing activity in the project area, the likelihood of displacement and associated amount of 

impact is small. There is also a possibility of direct mortality of small game and non-game species that could 

not avoid the construction activity and are crushed or otherwise killed during the construction of the site facility. 

The long term impacts from the proposed action for all affected wildlife could be extensive, and potentially 

beneficial or detrimental. The reasonably foreseeable long term impacts are associated with the produced 

effluent and the perennial systems downstream of the discharge points. There are a number of potentially 

harmful or fatal substances identified in CBNG produced water that is utilized by wildlife for foraging or other 

uses. Some of the potential impacts include genetic mutation, loss of endocrine function, cancer, anemia, 

embryonic malformation, sterility, and general loss of vigor and fitness. 

Produced water constituents of particular concern for terrestrial and avian species are ammonia, boron, 

cyanide, selenium, and phenol as well as TDS. It is not known at what concentrations ammonia is lethal to 

terrestrial vertebrates. Boron and selenium are both metals that have the potential to bio-accumulate in the 

environment. A CBNG produced water report for the Powder River Basin states “The WDEQ aquatic life 

chronic criterion of 5 μg/L (parts per billion) of selenium is not adequate for preventing adverse effects on fish 

and aquatic birds. Several scientific experts on selenium have recommended a 2 μg/L criterion because 

concentrations exceeding 2 μg/L may create a bioaccumulation risk for fish and sensitive species of aquatic 

birds (Hamilton 2002, Skorupa and Ohlendorf 1991; Lemly 1993). Discharge of produced water containing 

selenium greater than 2 μg/L also can result in impacts to fish and aquatic birds inhabiting downstream 

receiving waters” (Ramirez, 2005). Top level consumers in aquatic systems, such as waterfowl can readily 

accumulate selenium concentrations leading to low reproduction, embryonic deformities and increased 

mortality” (Ohlendorf et al. 1988). The water quality test results from the Mesa Verde formation had detection 

limits 5 μg/L for selenium. The WYPDES permit authorizing surface discharge of this effluent allows 9 μg/L. 

An assessment of selenium in the range of 2-4 μg/L is not possible at this time. Without this assessment, it is 

unknown if the potential for selenium to bioaccumulate exists. However, it is also known that there are current 

concentrations of ~ 3 μg/L of selenium in Muddy creek, which is above some recognized recommendations. 

Cyanide is a known toxicant that kills by not allowing oxygen to be transported by the vascular system and 

utilized by the body’s cells. Phenol is a known toxicant to fish species and also is known to target and destroy 

liver and kidney function in mammals. The WYPDES permit that authorizes surface water discharge does not 

specify effluent criteria for phenol, or include monitoring for phenol concentrations. 

36 

Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

There has been no analysis of the soils that would be contacted by the effluent to determine if and what 

constituents the water could leach and accumulate. There is potential for accumulated constituents in the 

effluent to be harmful to wildlife. 

Depending on the extent of accelerated erosion resulting from water discharge, sedimentation and erosion 

could cause a reduction in available riparian habitat within Muddy Creek and possibly beyond. 

There are some potentially beneficial impacts from the proposed action to wildlife. If the water that will be 

produced is of sufficient quality such that it will provide drinking water for terrestrial wildlife, the additional 

source of perennial water could result in beneficial impacts to wildlife for the period of time the water is 

discharged. 

The short term impacts for BLM sensitive species would include displacement during construction operations, 

however most of the BLM sensitive species would not be present during the time of construction. 

Timing restrictions for grouse nesting and brood rearing habitat would be imposed for the construction of the 

project so that construction would not adversely affect grouse during this critical time of year. However, 

grouse could be in the immediate vicinity of the project and would likely be displaced by the construction 

activities at any time of the year. 

Timing restrictions will also be in place to protect ferruginous hawk nesting. There would be a loss of foraging 

habitat for the hawks in the area directly related to the extent of surface disturbance. The proposed water 

treatment facility is located within the 1200 feet Controlled Surface Use buffer of an active ferruginous hawk 

nest. No actual egg laying attempts have been documented at the site for more than 7 years. However, this 

particular location would not result in short term adverse impacts to the ferruginous hawk nor would it result in 

a take under the Migratory Bird Treaty Act, because of the proximity to existing activity. This is supported by 

the evidence that the hawks have chosen not to nest (lay eggs) for the last 7 years. 

There are no expected short term impacts to the bald eagle or the black footed ferret from the construction 

phase of the proposed action. 

Bald eagles forage on fish, upland terrestrial species, and carrion. The species of forage fish that are likely to 

inhabit this stretch of the Little Snake River and Muddy Creek are rainbow trout, round-tail chub, flannelmouth 

sucker, white sucker, bluehead x white sucker, common carp, and channel catfish. There are other fish 

species that occur as well, but they are not of sufficient size to be forage for bald eagles. If fish abundance or 

species distributions are adversely affected by the proposed action, adverse indirect impacts to bald eagle 

may occur. 

Reduction of available forage and useable habitat is expected to mostly correspond with the extent of surface 

disturbance planned under this alternative. Some additional potential impacts are expected to sagebrush 

communities as a result of increased grazing pressure arising from the use of perennial water (discharged 

water) distributed throughout transition range for mule deer and pronghorn. However, if erosion is occurs 

within the watercourse channels, riparian and upland productivity would be adversely affected, reducing forage 

throughout an unknown portion of the project vicinity. This would negatively impact pronghorn antelope 

transition range and adjacent crucial winter range. Subsequently, adverse impacts to riparian and upland 

plant communities would result in adverse effects to herd size by increasing mortality rates. 

The WYPDES permits sets forth effluent criteria, or the maximum allowable concentration of particular 

elements, compounds, and conditions for discharged produced water. The WYPDES permit sets a standard 

whereby the concentration of Selenium, a metal that can bioaccumulate in wildlife, can not exceed 9 μg/L in 

the effluent. The U.S. Fish & Wildlife Service has found that the reproductive success of some birds can be 

adversely affected at concentrations as low as 2 μg/L. The WYPDES permit also sets a required detection 

limit for Selenium of 5 μg/L. It is possible that Selenium concentrations of less than 5 μg/L but more than 2 

38 
Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

μg/L could be present in the water discharged (keeping in mind that the mean concentration of Selenium in 

Muddy Creek is 3 μg/L (see Table 6). If so, there is potential for adverse impacts to birds who forage in or 

utilize the effluent. 

Fisheries 

Threatened and Endangered Fish Species 

Critical habitat for these species has not been designated in Wyoming (Upper Colorado River Endangered 

Fish Recovery Program 1999). These species are not likely to be found in the main stem of the Little Snake 

River within Wyoming or its tributaries. If any of these species is identified within the downstream portion of 

Muddy Creek or immediately downstream in the Little Snake River, the BLM would consult with the FWS and 

develop a protection plan for the fish. Based on this information the Section 7 Endange4red Species Act 

(ESA) determination for Colorado pikeminnow, bonytail, humpback chub, and razorback sucker is “May Affect 

but Not Likely to Adversely Affect.” This determination is based on the assumption that harmful substances 

would become highly diluted before reaching any downstream waters where these species occur. 

Sensitive Fish Species 

Impacts to sensitive fish species from the proposed action would include increased erosion altered chemical 

composition of streams, bioaccumulation of chemicals toxic to aquatic biota, alteration of water temperature, 

and alteration seasonal flow regimes. Long term impacts would result in the alteration of the natural aquatic 

ecosystem including changes in channel morphology and the local water table, and alteration of the aquatic 

community or loss of species. 

The channel morphology of Dry Cow Creek has developed in response to infrequent and short-lived flood 

flows over the last several thousand years. The proposed continuous discharge rate of 1.27cfs for Dry Cow 

Creek is equivalent to approximately 50% bankfull flow. Altering this once ephemeral system into a perennial 

stream would result in increased erosion and sedimentation of downstream habitat important to BLM sensitive 

fish species. 

Pool and run habitats with abundant hard substrates (e.g., cobble and gravel) in the Muddy Creek watershed 

have been identified as important habitat for warmwater BLM sensitive fish species (Beatty 2005; Bower 

2005). Increased sediment delivery to stream bottoms can embed gravels and reduce spawning success via 

decreased embryo survival (Magee et al. 1996). Large quantities of suspended sediment can also impair 

sources of food for fish (macroinvertebrates), fill in rearing pools, and reduce complexity of the habitat in 

stream channels. Loss of these stream attributes would threaten the persistence of BLM sensitive fish species. 

Deposition of sediment can also decrease populations and species composition of aquatic macroinvertebrates 

that are highly dependent on interstitial spaces for different life stages. These community changes can be 

detrimental to fisheries that depend on macroinvertebrates as primary food supplies and can change the 

abundance and diversity of the fish population. 

The channel morphology of Dry Cow Creek has developed in response to infrequent and short-duration flood 

flows typical of the Colorado River Basin. BLM sensitive fish that inhabit the Muddy Creek watershed are 

frequently exposed to disturbances from floods and droughts and have evolved to survive environments that 

are characterized by fluctuating flows. Potential negative effects to fish and invertebrates caused by changes 

in flow regimes include physical, behavioral, habitat and diet changes, and alteration of species composition. 

Modification of the flow regime from an ephemeral system to near bank full perennial discharge would 

increase the amount of suitable fish habitat available in the watershed. However, stable stream conditions 

would be most beneficial to non-native fish species and likely have an adverse impact on native BLM sensitive 

species adapted to fluctuating conditions. Competition and hybridization with non-native species has been 

attributed to the decline of these species (Bezzerides and Bestgen 2002). 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Several deleterious substances have been identified in typical CBNG produced water. Potential impacts to 

fisheries from water quality parameters associated with effluent from the proposed action include mortality, 

lowered reproductive success or complete reproductive failure, slowed growth, deformities, and general 

edema. However, the effects that water quality parameters would have on fish assemblages in Muddy Creek 

and its tributaries is uncertain. Acute WET tests of the effluent would be required to determine the toxilogical 

effects on aquatic life, and are required by the WYPDES permit from water collected end-of-pipe. 

Water quality parameters have been tested from the production aquifer (Mesa Verde formation) and surface 

water in the project area and are identified in Tables 5,6, and 8. Substances/properties from this list that have 

been identified as potentially harmful to the aquatic environment include ammonia, arsenic, barium, boron, 

chromium, copper, cyanide, iron, manganese, mercury, nickel, phenol, silver, zinc, TDS, and salinity. In 

addition, there are other substances that could potentially occur in the CBNG produced water that have not 

been identified. For a comprehensive list of toxilogical benchmarks for aquatic biota refer to Sutter and Tsao 

(1996). 

An additional concern with water quality in the project area is the increased degradation of water quality as 

effluent flows downstream. Results from water quality sampling of Duck Pond Draw indicated degradation of 

water quality downstream, even after 40 years of continuous discharge. Since the geology and corresponding 

clay-rich soil type do not vary appreciably between Duck Pond Draw and Dry Cow Creek, it is likely that the 

proposed disposal of treated discharge waters down Dry Cow Creek will also degrade downstream, adding 

both mineral and sediment constituents to the water and increasing impacts to the aquatic system 

downstream. 

Bioaccumulation of unwanted elements downstream of the discharge area could have a negative impact to 

fish and wildlife species by elevating the environmental toxicity past the tolerable threshold of the organism. 

Of particular concern is the bioaccumulation of selenium. Toxicity levels of selenium to aquatic organisms is 

variable and depends on concentration, form, type of organism and life stage, period of exposure and 

environmental factors (e.g., water temperature, water hardness and presence of other substances). The 

WYPDES permit for the proposed action only requires reporting at or above 9 μg/L of selenium. Sorensen 

(1988) reported substantial impacts and mortality to fish at selenium concentrations of 5 μg/L. Selenium 

concentrations as low as 2 μg/L were reported to have chronic toxicity effects on invertebrates (Crane et al. 

1992). 

Although the literature suggests a wide range of tolerance levels for aquatic organisms several 

recommendations for maximum total selenium concentrations have been made. A CBNG produced water 

report done for the Powder River Basin states “The WDEQ aquatic life chronic criterion of 5 μg/L of selenium 

is not adequate for preventing adverse effects on fish and aquatic birds”. Other research on selenium levels 

has suggested a 2 μg/L criterion because concentrations exceeding 2 μg/L may create a bioaccumulation risks 

for fish and sensitive species of aquatic birds (Hamilton 2002, Skorupa and Ohlendorf 1991; Lemly 1993). 

It is likely that the produced water (treated to less than or equal to 500 mg/L TDS) would gather salts while 

traveling along its flow path. The amount of salt accumulation is uncertain (i.e., tons/year), and so this impact 

can be generally predicted, but not easily quantified. Relatively minor changes in salinity levels have the 

potential to alter the structure and composition of a fish assemblage (Ostrand and Wilde 2001; Higgins and 

Wilde 2005) Exposure to elevated salinity levels such as sodium bicarbonate (NaHCO3), the major salt 

associated with CBNG produced water, can result in decreased survival, fecundity and in some cases death. 

Laboratory tests on fathead minnow, Pimphales promelas (a relatively salt tolerant species), to determine 

acute toxicity of salts resulted in 96-h LC50 values of KHCO3 (<510mg/L), NaHCO3 (<850mg/L), KCl 

(<880mg/L), and K2SO4 (<850mg/L; Mount et al. 1997). Aquatic invertebrates are also sensitive to increases 

in salinity, with adverse effects appearing in some taxa at 1,000 mg/L TDS. The most sensitive of the 

invertebrate taxa are benthic invertebrates such as stoneflies, mayflies, caddisflies, and dragonflies (Hart et al. 

1991). 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Based on the information provided above, impacts from the proposed action would have a negative effect on 

BLM sensitive fish species and potentially contribute towards the listing of these species under the provisions 

of the ESA. 

Recreation and Visual Resources 

The Proposed Action will affect recreational use and experiences in the immediate area and affect the 

recreational setting within and around the viewshed surrounding the project area. Visual resources will be 

impacted due to the introduction of contrasting elements of form, line, color, and texture against the natural 

elements. These new elements will direct observations away from the natural surroundings to the project 

area, which deviates away from VRM Class III objectives. The contrasting visual elements would be 

minimized by following the BMPs listed in ARDEIS (BLM 2005) Appendix H. Such mitigation would include 

painting above ground facilities, re-contouring during intermediate and final reclamation, and utilizing specific 

revegetation seed mixtures for disturbances. 

Cultural Resources 

No NRHP-eligible resources were found to be present where surface-disturbing activities are proposed, and so 

no impacts to cultural resources are expected as a result of construction. However, there is a high likelihood 

of impacts resulting from water discharge to cultural sites along the drainage margin, should erosion as 

allowable under the WYPDES authorization occur. 

If any cultural artifacts or materials are located during project construction activities, work will stop and the 

Authorized Officer of the BLM will be notified. 

If erosion allowable under the WYPDES authorization were to occur, the soils in the vicinity of the watercourse 

channels through which discharged produced water flow could be affected. These soils may contain 

undiscovered or presently unknown cultural resources. Should erosion displace cultural resources, the value 

of the resource may be affected by removing the context in which the cultural material would be found. The 

scientific information potentially gleaned from such sites would be negatively affected. 

Socioeconomics 

The activity associated with the Proposed Action would result in additional wage-earning revenue for workers 

participating in development activities, and potentially additional royalties, taxes, and other benefits to Federal, 

State, and local governments. 

Surface-disposal of produced water may prove to be economically advantageous to the Proponent, relative to 

continued use of disposal by reinjection. The RFO does not have any information with which to make this 

judgment, however. 

Should watercourse channel erosion occur, as allowed under the WDEQ-authorized WYPDES permit, 

additional costs would emerge for the control of erosion and related impacts. 

Health & Safety 

There would be some increased risk caused by the Proposed Action. Risks include higher vehicle accident 

potential due to increased traffic, as well as the normal hazards to industry workers from construction 

operations. 

Hazardous Substances/Wastes 

The Proponent has indicated in their Sundry Notice that hazardous substances will be used in water treatment 

41 
Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

facility operations. The term "hazardous materials" as used here means: 1) any substance, pollutant, or 

contaminant (regardless of quantity) listed as hazardous under the Comprehensive Environmental Response, 

Compensation, and Liability Act (CERCLA) of 1980, as amended, 42 U.S.C. 9601 et seq., and the regulations 

issued under CERCLA; 2) any hazardous waste as defined in the Resource Conservation and Recovery Act 

(RCRA) of 1976, as amended; and 3) any nuclear or nuclear byproduct as defined by the Atomic Energy Act of 

1954, as amended, 42 U.D.C. 2011 et seq. 

The Proponent will be required to comply with the Hazardous Materials Management Summary provided in the 

Atlantic Rim Natural Gas Development Project Final EIS (ARFEIS), Appendix C of the FEIS. This would 

include compliance with applicable laws, rules, and regulations. The Proponent would be required to provide a 

contingency plan to the RFO to address accidental releases of hazardous substances, produced water, and/or 

hydrocarbons. 

Depth to groundwater is estimated to be less than 50 feet bgs. The water treatment facility is located 

approximately 500 feet from the flowing water in the channel to the west, above the LSRCD reservoir. Should 

accidental releases of hazardous substances, produced water, and/or hydrocarbons occur, adverse 

environmental impacts may occur. 

Impacts to soils, surface and groundwater resources, wildlife, vegetation, and human health could result from 

the accidental release of hazardous materials. Since the project operation would be designed to comply with 

all applicable federal and state laws concerning hazardous materials, no impacts are anticipated. 

Noise 

The Proposed Action would increase noise levels in the immediate area during construction and water 

treatment operations. Construction activities and associated increased noise levels would be temporary, 

lasting as long as the construction activities were ongoing. At the treatment facility, operations noise would 

occur for the duration of operations. 

EPA has established a level of 55 dBA as a guideline for acceptable environmental noise. A noise level of 60 

dBA is generated between two people engaged in normal conversation standing five feet apart. Anticipated 

background noise levels in rural areas is anticipated to be approximately 40 dBA. Given that the project 

vicinity is subject to frequent winds, the natural noise levels in the project area may approximate 50 dBA 

during the daylight hours. Wind typically adds 5 to 10 dBA. Damage to the unprotected human ear can occur 

at noise levels of 115 dBA and above. The 55 dBA EPA standard represents very low noise levels and 

indicates the level below which no environmental effects could reasonably be expected. 

Based on an average noise level of 85 dBA measured at 50 feet from a typical construction site, the expected 

noise levels would be 85 dBA at 50 feet, 65 dBA at 100 feet, 59 dBA at 500 feet, 55 dBA at 1,500 feet, and 53 

dBA at 2,000 feet from the construction equipment. Therefore, an area of somewhat less than 288 acres 

around the project site would temporarily experience noise levels in excess of the EPA standard. An area of 

approximately 72 acres around the project location would experience temporary noise levels in excess of 

those associated with normal human conversation. The absence of any residence or human receptor likely to 

experience extended noise levels associated with this development under the Proposed Action limits potential 

impacts due to temporary and intermittent increases in noise levels for the duration of drilling and construction 

activity. 

Impacts to wildlife from project-related noise are addressed in this section titled “Wildlilfe/Fisheries.” 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Environmental Consequences- No Action Alternative 

Under the No Action alternative, the construction, installation, maintenance, and use of the proposed water 

treatment facility, water transport pipelines, and discharge points would not be authorized. Surface discharge 

of produced water from this proposal would not be authorized. As such, no additional direct or indirect impacts 

to human health and the environment would occur. On-going natural gas development would continue to 

occur, reinjection of produced water would continue, and future actions would be considered as submitted by 

proponents in the project area. 

Environmental Consequences- Alternative A (Additional Reinjection Wells) 

Under Alternative A, up to four additional reinjection wells would be authorized by the BLM and WDEQ (UIC), 

constructed, installed, and operated in order to dispose of approximately 1.3 cfs of produced water from the 

Catalina Unit CBNG operations. The reinjection wells would result in up to 24 acres of short-term surface 

disturbance from construction of the well pads, access roads (if any), and pipelines to gather produced water 

to the well. Total long-term surface disturbance is estimated to equal 3.2 acres, and would be present until the 

wells are plugged & abandoned in accordance with Wyoming Oil & Gas Conservation Commission rules and 

regulations. 

The BLM has received a number of additional APDs for the installation of additional reinjection wells withi n the 

ARPA (to be considered upon finalization of the AREIS ROD), but not to specifically address the disposal of 

produced water from the existing operations. So, the locations and predicted impacts from Alternative A is 

somewhat speculative. However, should this alternative be chosen, and should four additional reinjection well 

APDs be submitted to the RFO for consideration, the RFO would assess whether the impacts from the 

submitted APDs were adequately disclosed and analyzed in this EA. Should that be the case, no further 

NEPA analysis would be necessary to authorize the four reinjection well APDs. If unforeseen impacts or 

impacts arising from the site-specific proposals were predicted, additional NEPA analysis would be required 

before rendering a decision. 

Geology/Paleontology 

Alternative A would result in the additional capacity to dispose of produced water from the existing operations; 

additional gas could potentially be produced, resulting in the sale and transporting to market of additional 

natural gas, an important national resource for energy production. Those additional reserves, if produced, 

would be irrecoverably lost in their development and consumption for beneficial uses. Produced water would 

be injected into geologic strata as approved by the BLM and under an approved WDEQ UIC permit. 

The likelihood of paleontogical resources near the surface has been determined to be low. Standard 

mitigation requirements would be attached as Conditions of Approval to the APDs requiring that the operator 

cease operations should paleontological resources be discovered. Operations would be held in abeyance until 

the resource has been identified and protection measures established. No impacts to paleontological 

resources are foreseen. 

Climate and Air Quality 

The construction and operation of additional reinjection wells would result in some minor, additional production 

of diesel emissions and fugitive dust. These impacts are predicted to be non-measurable. 

Soils 

The disturbance of up to 24 acres of soils would reduce soil productivity over the disturbed area until 

reclamation is satisfactory. Mitigation measures would be developed and implemented, as necessary, upon 

43 
Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

review of the site-specific actions. With these mitigation measures (i.e., drainage control, reclamation 

requirements, etc.), no adverse impacts to soils are expected. 

Water Resources 

Surface waters would be protected by development of appropriate mitigation measures upon review of the 

site-specific proposals, and would include avoidance of steep topography, maintenance of buffers between 

surface disturbance and watercourse channels, and road construction to appropriate standards. 

Groundwater aquifers would be affected by the disposal of produced water to WDEQ-approved formations 

under the UIC program. In accordance with the UIC program administered by WDEQ, produced water 

disposed of into aquifers would be of a better quality than the receiving aquifer, preventing degradation of the 

receiving aquifer. 

Vegetation/Wetlands/Invasive Weeds 

The plant communities on disturbed areas would be removed, and the forage value lost, until reestablishment 

of native plants by reclamation. No wetlands would be affected, as there are feasible well locations away from 

wetlands. Halogeton is present in the project area, and would likely colonize disturbed sites. The operator 

would be required to treat and monitor weed populations as a condition of authorization. 

Wildlife/Fisheries 

Depending upon where the reinjection wells were located, impacts to wildlife would vary. In the project area, 

there are a number of potentially-present mammals, birds, and insects. Sensitive or protected species 

potentially affected include sage grouse, mountain plover, raptors, and wintering big game. 

Seasonal restrictions in compliance with land use planning decisions under the Great Divide Resource 

Management Plan, and any subsequent decisions, would be utilized to reduce impacts to sensitive species. 

On-going development in the area has occurred with the use of the identical seasonal restrictions that would 

be applied, as necessary, to proposed reinjection well APDs. These restrictions have been supported by the 

Wyoming Department of Game & Fish as a means to reduce impacts to wildlife. 

Analysis of reinjection in the AREIS has considered impacts from depletion of water-contributing formations 

through CBNG development. No impacts to fisheries are foreseen. 

Recreation and Visual Resources 

This alternative will affect recreational use and experiences in the immediate area and affect the recreational 

setting within and around the viewshed surrounding the project area. Visual resources will be impacted due to 

the introduction of contrasting elements of form, line, color, and texture against the natural elements. These 

new elements will direct observations away from the natural surroundings to the project area, which deviates 

away from VRM Class III objectives. The contrasting visual elements would be minimized by following the 

BMPs listed in ARDEIS (BLM 2005) Appendix H. Such mitigation would include painting above ground 

facilities, re-contouring during intermediate and final reclamation, and utilizing specific revegetation seed 

mixtures for disturbances. 

Cultural Resources 

Prior to authorization, the BLM would require that the operator have a BLM-approved third party 

archaeological contractor survey the specific locations where surface disturbance is proposed. NHRP-eligible 

resources would be avoided or appropriate mitigation measures would be implemented. Historic trail 

viewsheds may be affected, but allowable impacts and mitigation would be determined in consultation with the 

44 
Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

State Historic Preservation Office (SHPO). No impacts to cultural resources that could not be mitigated are 

foreseen. 

If any cultural artifacts or materials are located during project construction activities, work will stop and the 

Authorized Officer of the BLM will be notified. 

Socioeconomics 

The activity associated with Alternative A would result in additional wage-earning revenue for workers 

participating in development activities, and potentially additional royalties, taxes, and other benefits to Federal, 

State, and local governments. 

Health & Safety 

There would be some increased risk caused by the implementation of Alternative A. Risks include higher 

vehicle accident potential due to increased traffic, as well as the normal hazards to industry workers from 

construction operations. 

Hazardous Substances/Wastes 

Drilling of wells frequently involves the transportation, storage, and use of hazardous materials. 

The Proponent will be required to comply with the Hazardous Materials Management Summary provided in the 

Atlantic Rim Natural Gas Development Project Final EIS (ARFEIS), Appendix C of the FEIS. This would 

include compliance with applicable laws, rules, and regulations. The Proponent would be required to provide a 

contingency plan to the RFO to address accidental releases of hazardous substances, produced water, and/or 

hydrocarbons. 

Impacts to soils, surface and groundwater resources, wildlife, vegetation, and human health could result from 

the accidental release of hazardous materials. Since the project operation would be designed to comply with 

all applicable federal and state laws concerning hazardous materials, no impacts are anticipated. 

Noise 

Alternative A would increase noise levels in the immediate area of well pad, access road, and pipeline 

construction activities. Increased noise levels would be temporary, lasting as long as the construction 

activities were ongoing. At the injection wells, additional noise would occur for the duration of operations. 

Environmental Consequences: Cumulative Impacts 

Cumulative impacts are those impacts to the environment resulting from incremental impacts of an action 

when added to past, present, and reasonably foreseeable future actions. The Cumulative Impacts 

Assessment Area (CIAA) for the Proposed Action and alternatives is primarily the HUC-12 watershed inclusive 

of the project. Although the domain used for a CIAA typically varies by resource or jurisdictional boundary, the 

predicted impacts from the Proposed Action and alternative actions are expected to be fairly local in scope, 

with the exception of effects from produced water discharge at the surface. In addition, where impacts are 

expected to be un-measurable, cumulative impacts analysis may serve to only document existing impacts 

within a CIAA. As a result, the CIAA for this section of the impacts analysis is limited to the affected HUC-12 

watershed, excepting when surface disposal of produced water is being considered. 

New surface disturbance arising from construction operations would be located, in all alternatives, within the 

Dry Cow Creek HUC-12 watershed. This watershed is equal to 43,178 acres in size. 

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Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Cumulative Impacts- Existing Setting 

Within the CIAA, primary existing and reasonably foreseeable activities include oil & gas development (existing 

exploratory PODs and proposed development PODs associated with the Atlantic Rim Natural Gas 

Development Project), livestock production, and hunting & other recreation activities. There is a single public 

road leading into the project area. Primary landscape-scale perturbations have arisen from oil & gas 

development activities. 

There are 61 wells producing, shut-in, or in the process of being drilled within the Hydrologic Unit Code (HUC) 

12-level watershed (Dry Cow Creek) in which the project is located (Figure 18). There are, in addition, 102 

approved APD’s (not yet drilled) on file at the Wyoming Oil & Gas Conservation Commission as of September 

2006. In total, then, there are 163 existing and reasonably foreseeable APDs in the watershed. 

The ARFEIS assumes that an average of 7.9 acres of short-term surface disturbance will occur in the 

development of each well location within the AREIS area. 

Using an assumption of 7.9 acres of disturbance per well, the 163 existing and reasonably foreseeable wells 

would result in a total cumulative oil & gas development disturbance (short-term) of 1,287.7 acres within the 

watershed. This equals approximately 3.0% of the 43,178-acre watershed area. Undoubtedly, some unknown 

proportion of the existing wells has had reclamation initiated or even successfully completed for production 

operations. 

Cumulative Impacts- Proposed Action 

In total, the approval of this project would add approximately 7.1 acres of construction-related surface 

disturbance to the area. This represents approximately a 0.6% increase in extant surface disturbance within 

the CIAA, and corresponding .changes in forage availability and soil productivity. 

Incremental increases in measurable impacts to soils, vegetation, invasive weed infestations, terrestrial 

wildlife, recreation, and noise are expected, but would be small. 

Cumulative impacts to water resources (and obligate aquatic wildlife) for the Proposed Action have the 

potential to yield impacts over a larger area. For this alternative, the CIAA for water resources and aquatic 

wildlife has been expanded downstream to the confluence of Muddy Creek and the Little Snake River. The 

rationale for choosing this CIAA is that the impacts from the Proposed Action would likely not be measurable 

upon reaching the Little Snake River, as the size of the River may eliminate measurable incremental impacts. 

This, of course, depends upon the receiving waterbody flows; the Little Snake River would be receiving any 

flow discharged from the Proposed Action, less evaporation and infiltration (some infiltration would be 

conveyed by subsurface, potentially re-emerging in a surface tributary to the Little Snake River). 

It is possible, as previously discussed, that the produced water would leach and accumulate salts as it traveled 

along its flow path. The amount of salt is uncertain (i.e., tons/year), and so this impact can be generally 

predicted, but not easily quantified. Data collected from the Duck Pond Draw effort strongly suggest that 

additional salt loading will be measurable at the confluence of Cow Creek and Muddy Creek, and perhaps at 

the confluence of Muddy Creek and the Little Snake River. 

Another authorized discharge from the existing development in this area is occurring seasonally under the 

modified WYPDES authorization #WY0042145. This authorization allows for up to 0.28 cfs to be discharged 

seasonally during the months of August – November below the LSRCD reservoir. In 2006, the proponent 

initiated these discharges. This flow, when discharged, would cumulatively result in up to approximately 

1.6 cfs of produced water in the unnamed tributary to Dry Cow Creek when added to the Proposed Action. 

46 

Catalina Unit CBNG Produced Water Disposal Environmental Assessment 

Cumulative Impacts- No Action Alternative 

Under this alternative, no additional impacts would be created; existing development and activities would 

remain, and future activities from oil and gas development are likely to occur. 

Cumulative Impacts- Alternative A 

Under Alternative A, approximately 24 acres of additional short-term disturbance would be added to the CIAA. 

This represents a 1.9% increase in extant surface disturbance within the CIAA, and corresponding changes in 

forage availability and soil productivity. 

Incremental increases in measurable impacts to soils, vegetation, water resources, invasive weed infestations, 

terrestrial wildlife, recreation, and noise are expected, but would be small. 

Additional reinjection of produced water would occur, and this reinjection volume would be added to the 

existing volumes of water currently being reinjected within the project area. There are currently 5 active 

injection wells within the vicinity of the project. Cumulatively, the additional injection volume in this area would 

remain small relative to the apparent capacity of acceptable receiving formations (refer to ARFEIS). 

Consultation and Coordination 

As previously discussed, the RFO has consulted with the WDEQ regarding this project, including the conduct 

of a field visit to the location of the Proposed Action. In addition the RFO has consulted, formally or informally, 

with the following organizations or agencies: 

• Double Eagle Petroleum Company (Casper, Wyoming): proponent 

• Carl Babb, PG (Casper, Wyoming): proponent’s consulting hydrogeologist 

• EMIT Water Discharge Technology, LLC (Sheridan, Wyoming) 

• Wyoming Department of Game & Fish (Cheyenne, Wyoming): State agency 

• U.S. Fish & Wildlife Service (Cheyenne, Woming): Federal agency 

The BLM-RFO Interdisciplinary Team (IDT) prepared this EA, conducted field reviews and data gathering, and 

consulted with the above entities. 

• Travis Bargsten, Natural Resource Specialist, Project Lead 

• David Simons, Environmental Planner 

• Andy Stone, Hydrologist 

• Patrick Lionberger, Fisheries Biologist 

• Andy Warren, Rangeland Management Specialist 

• Paul Rau, Recreation Planner 

• Rhen Etzelmiller, Biologist 

• Nina Trapp, Archaeologist 

• Mark Newman, Geologist 

• Susan Foley, Soil Scientist 

• Jerry Dickinson, Petroleum Engineer 

48 
Catalina Unit CBNG Produced Water Disposal 	 Environmental Assessment 

References & Citations: 

•	 Babb, 2006. Channel Assessment: Cow Creek CBNG Project. 

•	 Baxter, G. T., and M. D. Stone 1995. Fishes of Wyoming. Wyoming Game and Fish Department. 

290pp. 

•	 Beatty, R. J. 2005. Catostomid Spawning Migrations and Late-Summer Fish Assemblages in Lower 

Muddy Creek, an Intermittent Watershed in Southern Carbon County, Wyoming. Laramie, Wyoming: 

M.S. Thesis, Department of Zoology and Physiology, University of Wyoming. 

•	 Bezzerides, N. and K. Bestgen 2002. Status Review of Roundtail Chub (Gila robusta), Flannelmouth 

Sucker (Catostomus latipinnis), and Bluehead Sucker (Catostomus discobolus) in the Colorado River 

Basin 2002. Fort Collins, Colorado: Colorado State University Larval Fish Laboratory. 

•	 BLM, 2002a. Cow Creek POD Environmental Assessment. 

•	 BLM, 2002b. BLM Wyoming sensitive species policy and list, September 20, 2002. Bureau of Land 

Management, Cheyenne, Wyoming. U.S. Department of the Interior, Bureau of Land Management. 

14pp. 

•	 BLM, 2005. Draft Environmental Impact Statement for the Seminoe Road Natural Gas Development 

Project. 

•	 BLM, 2005. Draft Environmental Impact Statement for the Atlantic Rim Natural Gas Development 

Project. 

•	 BLM, 2006. Final Environmental Impact Statement for the Atlantic Rim Natural Gas Developoment 

Project. 

•	 Bower, M.R. 2005. Distributions and Habitat Associations of Bluehead Suckers, Flannelmouth 

Suckers, and Roundtail Chubs in the Upper Muddy Creek Watershed of Southern Carbon County, 

Wyoming. Laramie, Wyoming: M.S. Department of Zoology and Physiology, University of Wyoming. 

•	 Crane, M., T. Flower, D. Holmes, and S. Watson. 1992. The toxicity of selenium in experimental 

freshwater ponds. Arch. Environ. Contam. Toxicol. 23: 440-452 (Cited from USEPA 1995). 

•	 DOE, Office of Environmental Management, Lockheed Martin Energy Systems, INC. Suter II, G. W. 

and Tsao C. L. 1996. Toxicological Benchmarks for Screening Potential Contaminants of Concern 

for Effects on Aquatic Biota. Office of Science and Technical Information. 

•	 Double Eagle Petroleum Company, 2002. Cow Creek POD Master Surface Use Plan. 

•	 EMIT, 2006. Applications Bulletin: CBM Produced Water Purification. 

•	 FWS 1993. Colorado River Endangered Fishes Critical Habitat. Draft Biological Support Document. 

Salt Lake City, Utah: U.S. Department of the Interior, Fish and Wildlife Service. 

•	 Hamilton SJ. 2002. Rationale for a tissue based selenium criterion for aquatic life. Aquat Toxicity 57: 

85-100. 

•	 Hart, D.D., B.D. Clark, and A. Jasentuliyana. 1996. Fine-scale field measurement of benthic Flow 

environments inhabited by stream invertebrates. Limnology and Oceanography. 41: 297-308. 

•	 Higgins, C.L., and G.R. Wilde. 2005. The role of salinity in structureing fish assemblages in a prairie 

stream system. Hydrobiologia. 549:197-203. 

•	 Lemly, A.D. 1993. Guidelines for evaluating selenium data from aquatic monitoring and assessment 

studies. Environmental Monitoring Assessment 28:83-100. 

•	 Minckley, W. L. and J. E. Deacon 1991. Battle Against Extinction: Native Fish Management in the 

American West. University of Arizona Press. 

•	 Mount D.R., P.E. O’Neil, and J.M. Evans. 1993. Discharge of coalbed product water to surface 

waters: assessing , predecting , and preventing ecological effects. Quarterly Review of Methane from 

Coal Seams Technology. 11: 18-25. 

•	 Ohlendorf, H.M., A.W. Kilness, J.L. Simmons, R.K. Stroud, D.J. Hoffman, and J.F. Moore. 1988. 

Selenium toxicosis in wild aquatic birds. Journal of Toxicology Environment and Health 24:67-92. 

•	 Ostrand, K.G., and G.R. Wilde. 2001. Temprature, dissolved oxygen, and salinity tolerances of five 

prairie stream fishes and their role in explaining fish assemblage patterns. Transactions of the North 

American Fisheries Society. 130: 742-749. 

49 
Catalina Unit CBNG Produced Water Disposal 	 Environmental Assessment 

•	 Ramirez, P. 2005. Assessment of Contaminants Associated with Coal Bed Methane-Produced 

Water and Its Suitability for Wetland Creation or Enhancement Projects. U.S. Fish and Wildlife 

Service, Ecological Services, Cheyenne, WY. Contaminant Report Number: R6/721C/05. 

•	 Skorupa, J.P., and H.M. Ohlendorf. 1991. Contaminants in drainage water and avian risk thresholds. 

In: A. Dinar and D. Zilberman, eds., The Economics and Management of Water and Drainage in 

Agriculture. Kluwer Academic Publishers. Norwell, Massachusetts. Pages 345-368. 

•	 Sorensen, E.M.B. 1988. Selenium accumulation, reproductive status, and histopathological changes 

in environmentally exposed redear sunfish. Arch. Toxicol. 61: 324-329. 

•	 Sutter, G.W., and C.L. Tsao. 1996. Toxilogical benchmarks for screening potential contaminants of 

concern for effects on aquatic biota: 1996 revision. Risk Assessment Program Health Sciences 

Research Division, Oak Ridge Tennessee. 

•	 UDNR 2006. Range-wide Conservation Agreement for Roundtail Chub, Gila robusta, Bluehead 

Sucker, Catostomus discobolus, and Flannelmouth Sucker, Catostomus latipinnis. Salt Lake City, 

Utah: Utah Department of Natural Resources. 

•	 Upper Colorado River Endangered Fish Recovery Program 1999. Website of the Upper Colorado 

River Endangered Fish Recovery Program. Online at: http://www.r6.fws.gov/coloradoriver 

•	 WDEQ, 2006. WYPDES #WY0054038: Statement of Basis & Permit Addenda (obtained from WDEQ 

website: http://deq.state.wy.us/wqd/events/index.asp). 

•	 WDEQ, 2005. WYPDES #WY0042145: Statement of Basis & Permit Addenda (obtained from WDEQ 

website: http://deq.state.wy.us/wqd/events/index.asp). 

•	 WDEQ 2007. Letter of clarification dated March 14, 2007. 

•	 WGFD 1998. Muddy Creek Basin Management Plan. Cheyenne, Wyoming: Wyoming Game and Fish 

Department 

•	 WGFD 2004. Warmwater Stream Assessment Manual. Cheyenne, Wyoming: Wyoming 

•	 Game and Fish Department. 

•	 WGFD, 2005. Annual Report of Big & Trophy Game Harvest 

•	 WGFD, 2005. Annual Report of Small & Upland Game Harvest 

•	 WOGCC, 2006. GIS Data for State APDs, Carbon County, Wyoming. 

•	 WSEO, 2007. Ground & Surface Water Appropriations Data (obtained from WSEO website: 

http://seo.state.wy.us/wrdb/index.aspx). 

50 
Appendix A 

Wyoming Department of Environmental Quality

Wyoming Pollution Discharge Elimination System (WYPDES) Permit 

WY0054038 
Wyoming Department of Environmental Quality 

Water Quality Division

WYPDES Program 

STATEMENT OF BASIS

Major Modification 

APPLICANT NAME: Double Eagle Petroleum Company

MAILING ADDRESS: P. O. Box 766 

 Casper, WY 82602 

FACILITY LOCATION: Cow Creek CBNG Project, which is located in the NWNE, Section 13, Township 

16 North, Range 92 West, Carbon County. The facility will discharge water 

treated using the Higgins Loop (EMIT process) into an unnamed, ephemeral 

tributary (3B) of Dry Cow Creek (3B). Dry Cow Creek (3B) is tributary to the 

Little Snake River (2AB), via Cow Creek (2C) and Muddy Creek (2C). The 

permit establishes a total maximum daily flow limit of 0.84 million gallons per 

day (MGD), and requires that the produced water being discharged from this 

facility originate from the Mesaverde coal seam. 

NUMBER: WY0054038

This permit is being modified at the request of the permittee to extend the expiration date of the permit to a full 

five-year term, the maximum allowable.

This change is the only portion of the permit that is being re-opened and changed, and is the only portion upon

which comments will be accepted during public notice. 

General Facility Information

This facility is a typical coal bed methane production facility in which groundwater is pumped from a coal 

bearing formation resulting in the release of methane from the coal bed. The permit authorizes the discharge to 

the surface of groundwater produced in this way provided the effluent quality is in compliance with effluent limits 

that are established by this permit. In developing effluent limits, all federal and state regulations and standards 

have been considered and the most stringent requirements incorporated into the permit. The EPA Effluent 

Guidelines and Standards for Oil and Gas Extraction Point Source Category (Part 435, Subpart E) predate the 

development of coal bed methane extraction technology; however the technology is similar enough to 

conventional gas extraction that, in the professional judgement of the WDEQ, this effluent limit guideline is 

appropriately applied to coal bed methane gas production. The guideline limits oil and grease effluent 

concentrations to less than 35 mg/l and requires that discharges of produced water be used for agricultural 

production and/or wildlife propagation. This permit does not cover activities associated with discharges of 

drilling fluids, acids, stimulation waters or other fluids derived from the drilling or completion of the wells. 

The permittee has chosen option 2 of the coal bed methane permitting options. Under this permitting option, the 

produced water is immediately discharged to a class 2 or 3 receiving stream which is eventually tributary to a 

class 2AB perennial water of the state. The permit establishes effluent limits for the end of pipe, which are 

protective of all the designated uses defined in Chapter 1 of Wyoming Water Quality Rules and Regulations. This 

Statement of Basis – Page 1 
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may include drinking water, game and non-game fish, fish consumption, aquatic life other than fish, recreation, 

agriculture, wildlife, industry and scenic value. 

Whole Effluent Toxicity (WET) Testing

WDEQ has determined that discharges from this facility have a reasonable potential to exert a toxic effect on 

aquatic life in the receiving stream(s). Therefore, in accordance with 40 CFR 122.44(d)(1), the permit contains a 

requirement to conduct annual static replacement toxicity tests on a grab sample of the discharge from the end of 

pipe. Each year during the life of this permit, a minimum of 20% of the discharging outfalls are to be sampled 

and tested for toxicity as described in Part I of the permit below. Since the discharge from this facility is expected 

to reach a perennial water body (Cow Creek) on a frequent or continual basis, WDEQ has determined that both 

acute and chronic toxicity testing is appropriate at these outfalls to characterize the impact that this discharge may

have on aquatic life in the receiving waters. 

Acute WET Testing: The permittee will conduct acute 48-hour static tests using Daphnia magna (water flea) 

and acute 96-hour static tests using Pimephales promelas (fathead minnow) at all outfalls permitted for discharge. 

The acute whole effluent toxicity tests will be conducted in accordance with the latest procedures set forth in 40

CFR 136.3 and the “Region VIII EPA NPDES Acute Test Conditions – Static Renewal Whole Effluent Toxicity 

Tests”. In the case of conflicts in method, the Region VIII document will prevail. If the results of two 

consecutive annual reports indicate no acute toxicity (as defined in part I of the permit below), the permittee may

reduce the monitoring to annual acute toxicity testing on only one species on an alternating basis. The test 

procedures for alternating species shall be the same as specified above. 

Chronic WET Testing: The permittee will also conduct chronic short-term tests using Pimephales promelas

(fathead minnow). The chronic whole effluent toxicity tests will be conducted in accordance with the latest 

procedures set forth in 40 CFR 136.3 and the “Region VIII EPA NPDES Chronic Test Conditions – Static

Renewal Whole Effluent Toxicity Tests”. In the case of conflicts in method, the Region VIII document will 

prevail. 

Effluent Limits

Permit effluent limits are based on federal and state regulations and are effective as of the date of issuance. The 

permit requires that the pH must remain within 6.5 and 9.0 standard units. Effluent limits for total radium 226 

(60 pCi/l), dissolved fluoride (2000 μg/l), and sulfates (3,000 mg/l), are included to protect for stock and wildlife 

watering. Typically, the WDEQ has not established total radium 226 effluent limits for CBM facilities located 

more than 10 miles from a class 2 water, if the permittee can demonstrate that the discharges will not exceed 12 

pCi/l. Likewise, the WDEQ has not been establishing total petroleum hydrocarbons effluent limits for CBM 

facilities. Although the permittee has provided a water quality sample indicating that the discharge will be well 

below 12 pCi/l, and can meet a TPH limit of 10 mg/l, the permittee has also indicated that two conventional oil 

and gas wells will contribute to the discharges from this facility. As discharges from conventional oil and gas 

wells typically have much higher total radium 226 and TPH concentrations that CBM wells, the WDEQ believes 

that, based upon the information provided, total radium 226 and TPH limits are appropriate in this instance. 

These limits are based upon Wyoming Water Quality Rules and Regulations, Chapter 2 and apply to discharge 

from any permitted outfall. 

A wasteload allocation (WLA) (see page 5 of the statement of basis) was performed to calculated effluent limits 

protective of the class 2 receiving water (the Little Snake River). The calculations consider a 7Q10 critical low 

flow of 10.6 cfs in the Little Snake River. A 7Q10 critical low flow, according to and calculated by the United 

States Geological Survey, is the lowest consecutive 7-day flow with the statistical probability of occurring once 

every 10 years. By using the 7Q10 critical low flow in the wasteload allocation, the “worst case scenario” with 

regards to critical-low-flow to effluent-flow is protected. In cases where the WLA calculated values were above 

Statement of Basis – Page 2 
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the water quality standards as established in Chapter 1 of the Wyoming Water Quality Rules and Regulations, the 

water quality standards as established in Chapter 1 of the Wyoming Water Quality Rules and Regulations were 

established as effluent limits for this facility (see WLA calculations, page 5 of the statement of basis – values 

established as effluent limits in this permit are shaded gray and in bold font). The following effluent limits were 

established in the WLA process – a dissolved zinc limit of 65 μg/l, a total recoverable barium limit of 2000 μg/l, a 

total recoverable selenium limit of 9.0 μg/l, a dissolved copper limit of 7.0 μg/l, a chlorides limit of 405 mg/l, a 

dissolved iron limit of 430 μg/l, a dissolved manganese limit of 90 μg/l, a total recoverable arsenic limit o f 12.8 

μg/l, a dissolved lead limit of 2.2 μg/l, a dissolved nickel limit of 53 μg/l, a dissolved cadmium limit of 2.0 μg/l, 

and a dissolved silver limit of 1.0 μg/l. Effluent limits for hardness-based metals – cadmium, lead, zinc, silver, 

nickel, and copper - were based on a post-treatment estimated hardness of 50 mg/l, which was provided by the 

permittee. The WLA indicated that dissolved chromium was not a pollutant of concern, effluent limits for total 

chromium are not being established in this permit. 

A limit for total recoverable aluminum – 750 μg/l – is also being established in this permit. This limit is based 

upon the acute aquatic life standard established in Chapter 1 of the Wyoming Water Quality Rules and 

Regulations. In the case of total recoverable aluminum, the chronic aquatic life value does not apply, based upon 

the hardness and pH of the receiving stream. This limit applies at the end of pipe. 

The permit also establishes a total dissolved solids (TDS) limit of 500 mg/l, this limit is to be met at the end of 

pipe, and is being established as per the requirements of the Colorado River Salinity Control Forum. This forum

requires that all discharges into the Colorado River and its tributaries be limited for TDS in one of two 

ways...either the permittee is limited to a one-ton-per-day-per-operator TDS load, or, if the permittee can 

demonstrate compliance with the “freshwater waiver” as described in the forum, a limit of 500 mg/l for TDS is 

then established in the permit. The permittee has committed to, and will be required to, reduce TDS 

concentrations in their produced water to 500 mg/l prior to discharge into the unnamed, ephemeral tributary of 

Dry Cow Creek upon which the treatment facility is located. The permittee has also provided information 

indicating that the selected treatment option – the Higgins Loop (EMIT) counter-current ion exchange technology 

– can achieve the desired level of treatment. The permittee may not, under any circumstances, solely discharge 

untreated produced water at the outfalls being authorized for discharge under this permit. Discharging untreated 

water from this facility will be considered to be a violation of this permit, and subject to enforcement actions. 

The permit also establishes an electrical conductivity effluent limit of 750 micromohs/cm, and a sodium

adsorption limit of 3 (to be calculated as the unadjusted for bicarbonate ratio). These effluent limits are being 

established in part to protect the TDS limit established above, and in part to protect the existing quality of the 

Little Snake River and existing irrigation uses. An EC limit of 750 micromohs/cm equates to a TDS limit of 500 

mg/l (TDS is approximately equal to EC/1.5). Even though the most saline-sensitive crop being irrigated in the 

Little Snake drainage has been identified as alfalfa, the TDS limit dictates that the discharge’s EC limit will be 

limited by the Colorado Salinity Control Forum, rather than the salt sensitivity of alfalfa. Using Figure 3 (page 

44) of Agricultural Salinity and Drainage, Hanson et al., 1999 revision “USDA Hansen Chart”, the maximum

allowable SAR limit for discharge waters having an EC of 750 micromohs/cm is 3. 

The mixing analyses submitted by the permittee were based upon an estimated flow volume of 0.84 MGD, and 

water quality representative of constituent concentrations present in produced water originating from the 

Mesaverde coal seam in the surrounding geographical area. Therefore, the permit establishes a flow limit of 0.84 

MGD, and requires that the produced water being discharged by this facility originate from the Mesaverde coal 

seam. 

Statement of Basis – Page 3 
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Monitoring and Reporting

The permit requires monitoring and sampling at designated water quality monitoring stations located on the Little 

Snake River and Muddy Creek. Little Snake River monitoring stations are located in the main channel of the 

Little Snake River, upstream and downstream of this facility (see ULSR and DLSR locations in Table 1, Part 

I.B.12 of the permit below). Muddy Creek water quality monitoring stations are located in the main channel of 

Muddy Creek, upstream and downstream of the confluence of Muddy Creek and Cow Creek (see UMC and DMC 

locations in Table 1, Part I.B.12 of the permit below.) Effluent samples at the designated water quality monitoring 

stations must be collected on a monthly basis in the event flow containing effluent is present at any of the water 

quality monitoring stations and are to be reported quarterly. If no discharge occurs at the outfalls, then “no 

discharge” is to be reported and samples need not be collected at the water quality monitoring stations for that 

monthly sampling period. At the designated water quality monitoring stations, monitoring will be required for 

calcium, magnesium, sodium, sodium adsorption ratio, temperature, and specific conductance. Information 

gathered from the water quality monitoring stations may result in modification of the permit to protect existing 

uses on the tributary and mainstem. 

Results are to be reported on a quarterly (once every three months) basis, and if no discharge occurs at an outfall 

then “no discharge” is to be reported. The permit also requires that an initial monitoring of the effluent at the 

outfalls be conducted within the first 60 days of discharge and the results submitted to WDEQ and the U.S. 

Environmental Protection Agency within 120 days of the commencement of discharge. 

Prior to commencement of discharge from this facility, the permittee is required to perform a channel survey from

the outfall to the confluence of Cow Creek. Within the identified stream segment, the permittee is required to 

identify, map, and describe all constriction points and areas of high erosional potential. Once identified, the 

permittee is then required to revisit these locations on an annual basis, with the purpose of monitoring potential 

change in the constriction points and areas of high erosional potential. Should erosional changes unrelated to 

runoff from large precipitation events occur at any of the constriction points and/or areas of high erosional 

potential, the permittee is required to mitigate the erosional damage. In the event that the permittee attributes 

erosional changes to one or more large precipitation events, the permittee must be able to provide substantive 

information demonstrating that the erosional changes are due to one or more large precipitation events, and must 

provide this information to the WYPDES Program if requested. 

General Permit Requirements

Reservoir and/or discharge water is to be released at a rate which does not cause significant erosion to the channel 

or receiving lands. 

There shall be no discharge of floating solids or visible foam in other than trace amounts, nor shall the discharge 

cause formation of visible deposits of iron, hydrocarbons or any other constituent on the bottom or shoreline of 

the receiving water. In addition, erosion control measures will be implemented to prevent significant damage to 

or erosion of the receiving water channel at the point of discharge. 

The discharge of wastewater and the effluent limits that are established in this permit have been reviewed to 

ensure that the levels of water quality necessary to protect the designated uses of the receiving waters are 

maintained and protected. An antidegradation review has been conducted and verifies that the permit conditions, 

including the effluent limitations established, provide a level of protection to the receiving water consistent with 

the antidegradation provisions of Wyoming surface water quality standards. 

Self monitoring of effluent quality and quantity is required on a regular basis with reporting of results quarterly. 

The permit is scheduled to expire on March 31, 2011. 

Statement of Basis – Page 4 
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Kathy Shreve 

Water Quality Division 

Department of Environmental Quality 

Draft Date: October 25, 2005 

Amended: May 8, 2006 

Statement of Basis – Page 5 
WLA Calculations 

Double Eagle - Cow Creek Treatment WY0054038 

Calculations assume an average posttreatment discharge hardness of 50 

Parameter 

Low 

Flow, cfs 

(7Q10) 

Low 

Flow, 

MGD 

(7Q10) 

Discharge 

Rate, MGD 

Combined 

Flow, 

MGD 

Water 

Quality 

Standard, 

Chronic 

Background 

Con. (LA) 

Assimilative 

Capacity of 

Stream 

Allowable 

Standard 

WLA 

calculated 

effluent 

limit 

Dissolved Zinc (ug/l) Little Snake 10.6 6.837 0.84 7.677 65.7 0 65.7 13.14 120 

Total Recoverable Selenium (ug/l) Little Snake 10.6 6.837 0.84 7.677 5 0 5 1 9.1 Dissolved Copper (ug/l) Little Snake 10.6 6.837 0.84 7.677 5 0 5 1 9.1 Chlorides (mg/l) Little Snake 10.6 6.837 0.84 7.677 230 17.3 212.7 59.84 406 Dissolved Iron (ug/l) Little Snake 10.6 6.837 0.84 7.677 300 144 156 175.2 429 Dissolved Manganese (ug/l) Little Snake 10.6 6.837 0.84 7.677 50 0 50 10 91 Total Recoverable Arsenic (ug/l) Little Snake 10.6 6.837 0.84 7.677 7 0 7 1.4 12.8 Snake 10.6 6.837 0.84 7.677 1.2 0 1.2 0.24 2.2 Dissolved Nickel (ug/l) Little Snake 10.6 6.837 0.84 7.677 28.9 0 28.9 5.78 53 Dissolved Cadmium (ug/l) Little Snake 10.6 6.837 0.84 7.677 1.3 0 1.3 0.26 2.4 

Parameter 

Low 

Flow, cfs 

(7Q10) 

Low 

Flow, 

MGD 

(7Q10) 

Discharge 

Rate, MGD 

Combined 

Flow, 

MGD 

Water 

Quality 

Standard, 

Acute* 

Background 

Con. (LA) 

Assimilative 

Capacity of 

Stream 

Allowable 

Standard 

WLA 

calculated 

effluent 

limit 

Dissolved Silver* (ug/l) Little Snake 10.6 6.837 0.84 7.677 1 0 1 0.2 1.8 

* There is no chronic water quality standard for dissolved silver Irrigation Protection: Background EC in Little Snake is 510 umhos/cm. Assuming most sensitive irrigated crop is alfalfa, EC in discharge will be limited by Colorado Bby most senstive crop. Effluent limit would be 500 mg/l TDS or approximately 750 umhos/cm EC.For EC = 750 umhos/cm, allowable SAR = 3, based on USDA Hansen Chart.

Statement of Basis – Page 6 
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AUTHORIZATION TO DISCHARGE UNDER THE

WYOMING POLLUTANT DISCHARGE ELIMINATION SYSTEM

In compliance with the provisions of the Federal Water Pollution Control Act, (hereinafter referred to as “the Act”), 

and the Wyoming Environmental Quality Act, 

Double Eagle Petroleum Company

is authorized to discharge from the wastewater treatment facilities serving the 

Cow Creek CBNG Project,

which is located in the 

NWNE, Section 13, Township 16 North, Range 92 West, Carbon County, 

to receiving waters named

an unnamed, ephemeral tributary (3B) of Dry Cow Creek (3B). Dry Cow Creek (3B) is tributary to the 

Little Snake River (2AB), via Cow Creek (2C) and Muddy Creek (2C), 

in accordance with effluent limitations, monitoring requirements and other conditions set forth in Parts I, II and III 

hereof. 

This permit shall become effective on the date of signature by the Director of the Department of Environmental 

Quality. 

This permit and the authorization to discharge shall expire March 31, 2011, at midnight . 

___________________________________________ ____________________________________ 

John F. Wagner Date 

Administrator – Water Quality 

___________________________________________ ____________________________________ 

John V. Corra Date 

Director – Department of Environmental Quality

Page 1 
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PART I

A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

Effective immediately and lasting through March 31, 2011, the quality of effluent discharged by the 

permittee shall, at a minimum, meet the limitations set forth below. The permittee is authorized to 

discharge from outfalls(s) serial numbers 001 – 002. 

1.a. Discharges from all outfalls shall be limited as specified below: 

Effluent Limits

Effluent Characteristic

Daily Maximum,

Outfall

Chlorides, mg/l 405 

Dissolved Iron, μg/l 430 

Dissolved Manganese, μg/l 90 

pH, standard units 6.5 – 9.0 

Specific Conductance, micromohs/cm 750 

Sodium Adsorption Ratio, calculated as unadjusted for 

bicarbonate ratio 3 

Sulfates, mg/l 3000 

Total Recoverable Arsenic, μg/l 12.8 

Total Recoverable Barium, μg/l 2000 

Total Dissolved Solids, mg/l 500 

Total Flow Volume, MGD* 0.84 

Total Recoverable Aluminum, μg/l 750 

Dissolved Fluoride, μg/l 2000 

Total Radium 226, pCi/l 60 

Total Recoverable Selenium, μg/l 9.0 

Dissolved Zinc, μg/l 65 

Dissolved Copper, μg/l 7.0 

Dissolved Lead, μg/l 2.2 

Dissolved Nickel, μg/l 53 

Dissolved Cadmium, μg/l 2.0 

Dissolved Silver, μg/l 1.0 

Total Petroleum Hydrocarbons, mg/l 10 

Whole Effluent Toxicity Testing (chronic)** Pass 

Whole Effluent Toxicity Testing (acute)** Pass 

*Total Flow volume will be calculated as the sum of all discharge from all permitted outfalls. 

**See Part I.A.2-5 of the permit for additional details regarding WETT. 

The pH shall not be less than 6.5 standard units nor greater than 9.0 standard units in any single grab sample. 

Page 2 
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There shall be no deposition of substances in quantities which could result in significant aesthetic degradation, or 

degradation of habitat for aquatic life, plant life or wildlife; or which could adversely affect public water supplies 

or those intended for agricultural or industrial use. 

The permittee may, if so desired, discharge effluent from any authorized well to any permitted outfall, as long as 

all permit limits and requirements can be met. This facility, as originally permitted, consisted of 2 outfalls and 14 

wells. The permit requires that the effluent being discharged by this facility originate the Mesaverde coal seam. 

Information gathered from the water quality monitoring stations may result in modification of the permit to 

protect existing uses on the tributary and the mainstem. 

There shall be no discharge of floating solids or visible foam in other than trace amounts, nor shall the discharge 

cause formation of a visible sheen or visible hydrocarbon deposits on the bottom or shoreline of the receiving 

water. 

Reservoir and/or discharge water is to be released at a rate which does not cause significant erosion to the channel 

or receiving lands. 

The permittee has committed to, and will be required to, reduce TDS concentrations in their produced water to 

500 mg/l prior to discharge into the unnamed, ephemeral tributary of Dry Cow Creek upon which the treatment 

facility is located. The permittee has also provided information indicating that the selected treatment option – the 

Higgins Loop (EMIT) counter-current ion exchange technology – can achieve the desired level of treatment. The 

permittee may not, under any circumstances, solely discharge untreated produced water at the outfalls being 

authorized for discharge under this permit. Discharging untreated water from this facility will be considered to be 

a violation of this permit, and subject to enforcement actions. 

2. Effluent Limitations (Toxic Pollutants)

Effective immediately, there shall be no acute or chronic toxicity occurring in the effluent from outfalls serial 

numbers 001 – 002. 

3. Whole Effluent Testing (Acute) 

Upon issuance of this permit, the permittee shall, at least once annually, conduct acute static replacement toxicity

tests on a grab sample of the discharge. If initial monitoring of the effluent is required for this permit (within 60 

days of commencement of discharge), then the first annual acute toxicity test is to be conducted at that time. At a 

minimum, 20 percent of all discharging outfalls that immediately flow to Class 3 waters and 20 percent of all 

discharging outfalls that immediately flow to Class 2 waters are to be sampled and tested annually for acute whole 

effluent toxicity (WET). Each year, a different 20 percent minimum portion of the discharging outfalls is to be 

sampled and tested for acute whole effluent toxicity. Consecutive yearly samples may not be collected from an 

identical outfall unless the outfall is the only discharging outfall that complies with the criteria listed above. The 

permittee may select the outfall(s) that will be sampled each year unless the permit issuing authority specifically

identifies which outfalls must be sampled. The permittee must also provide written notification to the permit 

issuing authority at least two weeks prior to WET-related sampling. The written notification will specify which 

outfall(s) are discharging and which outfalls will be selected and sampled for the WET test. 

The replacement static toxicity tests shall be conducted in accordance with the procedures set forth in 40 CFR 

136.3 and the “Region VIII EPA NPDES Acute Test Conditions Static Renewal Whole Effluent Toxicity Tests”. 

In the case of conflicts in method, the 40 CFR 136.3 will prevail. The permittee shall conduct an acute 48-hour 

static toxicity test using Daphnia magna and an acute 96 hour static toxicity test using Pimephales promelas. All 

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tests will be conducted utilizing a multi-dilution series consisting of at least five (5) concentrations and a control 

as defined below: 

100% effluent 

 85% effluent 

67% effluent 

50% effluent 

25% effluent 

control (or 0% effluent) 

All tests will be conducted utilizing a minimum of 5 replicates for each test. In the event of inconclusive test 

results, the WDEQ reserves the right to require the permittee to perform additional tests at alternate dilutions

and/or replicates. The WDEQ also reserves the right to require the submission of all information regarding all 

initiated tests, regardless of whether the tests were carried to completion or not. 

Acute toxicity occurs when 50 percent or more mortality is observed for either species at any effluent 

concentration at any outfall. If acute toxicity occurs at any outfall during a sampling period, then WDEQ will 

assume that all outfalls, which have not yet been sampled, exhibit similar acute toxicity characteristics as well. 

If more than 10 percent control mortality occurs, the test is not valid. The test shall be repeated until satisfactory

control survival is achieved.

If acute toxicity occurs, an additional test on the failing outfall(s) shall be initiated within two (2) weeks of the 

date of when the permittee learned of the test failure. If only one species fails, retesting may be limited to this

species. Should acute toxicity occur in the second test, the Toxicity Identification Evaluation (TIE) and Toxicity

Reduction Evaluation (TRE) process described below shall be implemented on a schedule established by the 

DEQ. 

Annual test results shall be reported on a Discharge Monitoring Report (DMR) that must be submitted by

February 15th of each year. The format for the report shall be consistent with the latest revision of the “Region 

VIII Guidance for Acute Whole Effluent Reporting”, and shall include all chemical and physical data as specified. 

If the results of two consecutive annual reports indicate no acute toxicity for all sampled outfalls, the permittee 

may reduce the monitoring to annual acute toxicity testing on only one species on an alternating basis. The test 

procedures for alternating species shall be the same as specified above. 

4. Whole Effluent Testing (Chronic) 

Upon issuance of this permit, the permittee shall, at least once annually, conduct chronic static replacement 

toxicity tests on a grab sample of the discharge. If initial monitoring of the effluent is required for this permit 

(within 60 days of commencement of discharge), then the first annual chronic toxicity test is to be conducted at 

that time. At a minimum, 20 percent of all discharging outfalls that immediately flow to Class 3 waters and 20 

percent of all discharging outfalls that immediately flow to Class 2 waters are to be sampled and tested annually 

for chronic whole effluent toxicity (WET). Each year, a different 20 percent minimum portion of the discharging 

outfalls is to be sampled and tested for chronic whole effluent toxicity. Consecutive yearly samples may not be 

collected from an identical outfall unless the outfall is the only discharging outfall that complies with the criteria 

listed above. The permittee may select the outfall(s) that will be sampled each year unless the permit issuing 

authority specifically identifies which outfalls must be sampled. The permittee must also provide written 

notification to the permit issuing authority at least two weeks prior to WET-related sampling. The written 

notification will specify which outfall(s) are discharging and which outfalls will be selected and sampled for the 

WET test. 

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The chronic toxicity tests shall be conducted in accordance with the procedures set forth in 40 CFR 136.3 and the 

“Region VIII EPA NPDES Chronic Test Conditions Static Renewal Whole Effluent Toxicity Test”. In the case 

of conflicts in method, the 40 CFR 136.3 procedure will prevail. Test species shall consist of Pimephales 

promelas. All tests will be conducted utilizing a multi-dilution series consisting of at least five (5) concentrations 

and a control as defined below: 

100% effluent 

85% effluent 

67% effluent 

50% effluent 

25% effluent 

control (or 0% effluent) 

All tests will be conducted utilizing a minimum of 5 replicates for each test. In the event of inconclusive test 

results, the WDEQ reserves the right to require the permittee to perform additional tests at alternate dilutions

and/or replicates. The WDEQ also reserves the right to require the submission of all information regarding all 

initiated tests, regardless of whether the tests were carried to completion or not. 

Chronic toxicity occurs when, during a chronic toxicity test, 25 percent or more inhibition (calculated on the 

basis of test organism survival and growth or survival and reproduction) is observed in either species at any

effluent concentration at any outfall. If chronic toxicity occurs at any outfall during a sampling period, then

WDEQ will assume that all outfalls, which have not yet been sampled, exhibit similar chronic toxicity

characteristics as well. 

If a test acceptability criterion is not met for control survival, growth, or reproduction, the test shall be considered 

invalid. In such cases, the test shall be repeated until all test acceptability criteria are met and valid results are 

obtained. 

If chronic toxicity occurs, an additional test of the failing outfall(s) shall be initiated within two (2) weeks of the 

date of when the permittee learned of the test failure. Should chronic toxicity occur in the second test, the 

Toxicity Identification Evaluation (TIE) and Toxicity Reduction Evaluation (TRE) process described below shall 

be implemented on a schedule established by WDEQ. 

Annual test results shall be reported on a Discharge Monitoring Report (DMR) that must be submitted by

February 15th each year. The format for the report shall be consistent with the latest revision of the “Region VIII 

Guidance for Chronic Whole Effluent Reporting”, and shall include all chemical and physical data as specified. 

5. Toxicity Identification Evaluation (TIE) and Toxicity Reduction Evaluation (TRE)

Should toxicity be detected in the permittee’s discharge, a TIE-TRE shall be undertaken by the permittee to 

establish the cause of the toxicity, locate the source(s) of the toxicity, and develop control of, or treatment for the 

toxicity. Failure to initiate, or conduct an adequate TIE-TRE, or delays in the conduct of such test, shall not be 

considered a justification for noncompliance with the whole effluent toxicity limits contained in this permit. A 

TRE plan needs to be submitted to the permitting authority within 45 days after confirmation of the continuance 

of effluent toxicity. 

If acceptable to the permit issuing authority, and if in conformance with current regulations, this permit may be 

reopened and modified to incorporate TRE conclusions relating to additional numerical limitations, a modified 

compliance schedule, and\or modified whole effluent protocol. 

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6. Discharges shall be monitored by the permittee as specified below:

a. Monitoring of the initial discharge

Within 60 days of commencement of discharge, a sample shall be collected from each outfall and 

analyzed for all constituents specified below, at the required detection limits. Within 120 days of 

commencement of discharge, a summary report on the produced water must be submitted to the Wyoming 

Department of Environmental Quality and the U.S. EPA Region 8 at the addresses listed below. This 

summary report must include the results and detection limits for each of the constituents listed below. In 

addition, the report must include written notification of the established location of the discharge point 

(refer to Part I.B.11). This notification must include a confirmation that the location of the established 

discharge point(s) is within 1,510 feet of the location of the identified discharge point(s), is within the 

same drainage, and discharges to the same landowner’s property as identified on the original application 

form. The legal description and location in decimal degrees of the established discharge point(s) must 

also be provided. After receiving the monitoring results for the initial discharge, the effluent limits and 

monitoring requirements established in this permit may be modified. 

Parameter* (See notes following 

the table on chemical states) Required Detection Limits and Required Units

Alkalinity, Total 1 mg/l as CaCO3

Aluminum, Total Recoverable 50 μg/l 

Arsenic, Total Recoverable 1 μg/l 

Barium, Total Recoverable 100 μg/l 

Bicarbonate 10 mg/l 

Cadmium, Dissolved 5 μg/l 

Calcium, Dissolved 50 μg/l, report as me/l 

Calcium, Dissolved 50 μg/l, report as mg/l 

Chlorides 5 mg/l 

Copper, Dissolved 10 μg/l 

Dissolved Solids, Total 5 mg/l 

Fluoride, Dissolved 100 μg/l 

Hardness, Total 10 mg/l as CaCO3

Iron, Dissolved 50 μg/l 

Lead, Dissolved 2 μg/l 

Magnesium, Dissolved 100 μg/l, report as me/l 

Magnesium, Dissolved 100 μg/l, report as mg/l 

Manganese, Dissolved 50 μg/l 

Mercury, Dissolved 1 μg/l 

Petroleum Hydrocarbons, Total 1mg/l 

pH to 0.1 pH unit 

Radium 226, Total 0.2 pCi/l 

Selenium, Total Recoverable 5 μg/l 

Silver, Dissolved 5 μg/l 

Sodium Adsorption Ratio Calculated as unadjusted ratio 

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Sodium, Dissolved 100 μg/l, report as me/l 

Sodium, Dissolved 100 μg/l, report as mg/l 

Specific Conductance 5 micromhos/cm 

Sulfates 10 mg/l 

Temperature, degrees Celsius +/- 0.5 degree C 

Zinc, Dissolved 50 μg/l 

TOTAL: Value is expressed in terms of total recoverable metal in the water column. 

NOTE: Except for aquatic life values for metals and where otherwise indicated, the values given refer to the total 

recoverable (dissolved plus suspended) amount for each substance. For the aquatic life values for metals, the 

values refer to the dissolved amount. 

DISSOLVED: Value is based on the dissolved amount which is the amount that will pass through a 0.45 μm

membrane filter prior to acidification to pH 1.5 – 2.0 with nitric acid. 

Initial monitoring reports are to be sent to the following addresses:

Planning and Targeting Program, 8ENF-PT 

Office of Enforcement, Compliance, and Environmental Justice 

U.S. EPA Region 8 

999 18th St., Suite 300 

Denver, CO 80202-2466 

 and 

Wyoming Department of Environmental Quality

Water Quality Division 

Herschler Building, 4 West 

122 West 25th Street 

Cheyenne, WY 82002 

b. Routine Monitoring End of Pipe – 001-002 

For the duration of the permit, at a minimum, samples for the constituents described below shall be 

collected at the indicated frequencies. The first routine monitoring for the time frame during which the 

monitoring of initial discharge occurs will, at a minimum, consist of flow measurements for the duration 

of the three-month monitoring time frame. Monitoring will be based on quarterly time frames, from

January through March, from April through June, from July through September, and from October 

through December. 

Parameter Measurement Frequency Sample Type

Bicarbonate (mg/l) Monthly Grab 

Hardness (mg/l) Monthly Grab 

Dissolved Calcium (mg/l) Monthly Grab 

Parameter* (See notes following 

the table on chemical states) Required Detection Limits and Required Units

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Dissolved Calcium (me/l) Monthly Grab 

Chloride (mg/l) Annually Grab 

Dissolved Iron (μg/l) Annually Grab 

Dissolved Manganese (μg/l) Annually Grab 

Dissolved Magnesium (mg/l) Monthly Grab 

Dissolved Magnesium (me/l) Monthly Grab 

pH (standard units) Once Every Three Months Grab 

Total Radium 226 (pCi/l) Once Every Three Months Grab 

Dissolved Sodium (mg/l) Monthly Grab 

Dissolved Sodium (me/l) Monthly Grab 

Sodium Adsorption Ratio (unadjusted for 

bicarbonate) 

Monthly Calculated 

Specific Conductance (micromohs/cm) Monthly Grab 

Sulfate (mgl) Annually Grab 

Total Alkalinity (mgl) Annually Grab 

Total Recoverable Arsenic (μg/l) Annually Grab 

Total Recoverable Barium (μg/l) Annually Grab 

Total Flow – (MGD) Monthly Continuous 

Temperature – degrees C Once Every Three Months Grab 

Total Recoverable Aluminum (μg/l) Annually Grab 

Dissolved Fluoride (μg/l) Once Every Three Months Grab 

Total Recoverable Selenium (μg/l) Annually Grab 

Total Dissolved Solids (mg/l) Monthly Grab 

Dissolved Zinc (μg/l) Annually Grab 

Dissolved Lead (μg/l) Annually Grab 

Dissolved Nickel (μg/l) Annually Grab 

Dissolved Cadmium (μg/l) Annually Grab 

Dissolved Silver (μg/l) Annually Grab 

Parameter Measurement Frequency Sample Type

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Total Petroleum Hydrocarbons (mg/l) Annually Grab 

Dissolved Copper (μg/l) Annually Grab 

Samples taken in compliance with the monitoring requirements specified above shall be taken at the 

following location(s) – at the outfalls, prior to any dilution or admixture with any other waters. Outfalls 

are located as described in Table 1, Part I.B.12 of the permit. 

c. Water Quality Monitoring Stations TRIB1, ULSR, DLSR, UMC and DMC

For the duration of the permit, at a minimum, samples for the constituents described below shall be 

collected at the indicated frequencies. Monitoring will be based on monthly time frames, and reported 

quarterly. 

Parameter Measurement Frequency Sample Type

 Dissolved Calcium (mg/l) Monthly Grab 

 Dissolved Calcium (me/l) Monthly Grab 

Dissolved Magnesium (mg/l) Monthly Grab 

Dissolved Magnesium (me/l) Monthly Grab 

Dissolved Sodium (mg/l) Monthly Grab 

Dissolved Sodium (me/l) Monthly Grab 

Sodium Adsorption Ratio (calculated as 

unadjusted for bicarbonate ratio) 

Monthly Calculated 

Specific Conductance (micromohs/cm) Monthly Grab 

Temperature (degrees C) Monthly Grab 

Flow (CFS)* Monthly Instantaneous 

Total Dissolved Solids (mg/l) Monthly Grab 

*Flow monitoring and reporting is only required at the tributary monitoring station location on Muddy Creek, 

identified as “TRIB1” in Table 1, Part I.B.12 of the permit, and at the subsidiary tributary water quality

monitoring stations located on Muddy Creek upstream and downstream of confluence with Cow Creek, 

identified as “UMC “ and “DMC” in Table 1, Part I.B.12 of the permit. The permittee is not required to 

measure or report flow at the mainstem monitoring locations on the Little Snake River, identified as ULSR and 

DLSR on Table 1, Part I.B.12 of the permit. 

Samples taken in compliance with the monitoring requirements specified above shall be taken at the following 

locations: designated water quality monitoring stations identified as TRIB1, UMC, DMC, ULSR, and DLSR in 

Table 1, Part I.B.12 of the permit below. Established water quality monitoring stations on the mainstem are to 

be located outside the mixing zone with the tributary and the mainstem. Monthly water quality samples are to 

Parameter Measurement Frequency Sample Type

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be collected at the ULSR and DLSR water quality monitoring stations during any month in which discharges 

from this facility contribute to flows within the Little Snake River. At the designated water quality monitoring 

stations, monitoring will be required for calcium, magnesium, sodium, sodium adsorption ratio and specific 

conductance. Information gathered from the water quality monitoring stations may result in modification of the 

permit to protect existing uses on the tributary and mainstem. 

The permittee is required to monitor the subsidiary tributary water quality monitoring stations located on 

Muddy Creek upstream and downstream of confluence with Cow Creek, identified as UMC and DMC in Table 

1, Part I.B.12 of the permit on a monthly basis in the event flow containing effluent from this facility reaches 

the confluence of Muddy Creek and Cow Creek. Once effluent from this facility reaches the confluence of 

Muddy Creek and Cow Creek, the permittee is to visit these sites on a monthly basis and collect samples at 

these stations to characterize concentrations for all the parameters listed in the table above. If no flow or flow 

not containing discharges from this facility is present at these stations, the permittee is not required to collect 

samples characterizing concentrations for the parameters listed in the table above, and is to report “no 

discharge” on their monthly discharge monitoring reports. 

d. Pre-Discharge Stream Channel Survey Requirements

Prior to commencement of discharge from this facility, the permittee is required to perform a channel survey for 

the stream segment beginning at the outfalls to the confluence of Cow Creek. Within the identified stream

segment, the permittee is required to identify, map, and describe all constriction points and areas of high 

erosional potential. Once characterized and mapped, the constriction points and areas of high erosional 

potential will be revisited on an annual basis to determine the amount of erosional change, if any, in the sites. 

The permittee is to submit an annual report, due January 28th of each year, that will describe baseline 

conditions, any changes to these sites over time, and possible causes for any significant changes detected in 

these sites. The first such annual report following issuance of this permit is due January 28, 2007. Should 

erosional changes unrelated to runoff from large precipitation events occur at any of the constriction points 

and/or areas of high erosional potential, the permittee is required to mitigate the erosional damage. In the event 

that the permittee attributes erosional changes to one or more large precipitation events, the permittee must be 

able to provide substantive information demonstrating that the erosional changes are due to one or more large 

precipitation events, and must provide this information to the WYPDES Program if requested. On an annual 

basis, the constriction points and areas of high erosional potential must be evaluated to determine if there has 

been a change in either the lateral movement or the vertical drop in the identified constriction points and/or

areas of high erosional potential. If the constriction point and/or area of high erosional potential shows 

movement of more than four (4) feet, either laterally or vertically, within a calendar year, the permittee must

submit for review and approval a mitigation plan. Within three months of approval of the mitigation plan, the 

plan must be implemented. If the plan is not implemented, the WYPDES Program may require the permittee to 

cease discharge from the outfalls until the plan is implemented. 

Headcuts which are already being mitigated in conjunction with separate BLM requirements will not require a 

mitigation plan to be submitted in association with this general permit. In addition, if an operator demonstrates 

that their effluent has not reached a particular downstream constriction point and/or area of high erosional 

potential, then the operator will not be required to submit a mitigation plan for that constriction point or area of 

high erosional potential. In the absence of such a demonstration from the operator, WDEQ will assume that the 

effluent is contributing to the headcut. 

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B. MONITORING AND REPORTING

 1. Representative Sampling

Samples and measurements taken as required herein shall be representative of the volume and

nature of the monitored discharge. All samples shall be taken at the monitoring points specified 

in this permit and, unless otherwise specified, before the effluent joins or is diluted by any other 

waste stream, body of water, or substance. Monitoring points shall not be changed without 

notification to and approval by, the permit issuing authority. 

2. Reporting

Results of initial monitoring, including the date the discharge began, shall be summarized on a 

Monitoring Report Form for Monitoring of Initial Discharge and submitted to the state water 

pollution control agency at the address below postmarked no later than 120 days after the 

commencement of discharge. 

Results of routine end of pipe, irrigation compliance point, and water quality station monitoring 

during the previous three (3) months shall be summarized and reported quarterly on a Discharge 

Monitoring Report Form (DMR). If the discharge is intermittent, the date the discharge began 

and ended must be included. The information submitted on the first quarterly DMR shall contain 

a summary of flow measurements and any additional monitoring conducted subsequent to the

submittal of the initial monitoring report. Whole effluent toxicity (biomonitoring) results must be 

reported on the most recent version of EPA Region VIII's Guidance for Whole Effluent 

Reporting. Monitoring reports must be submitted to the state water pollution control agency at 

the following address postmarked no later than the 15th day of the second month following the 

completed reporting period. The first report due following issuance of this major modification is 

due February 15, 2007. 

Legible copies of these, and all other reports required herein, shall be signed and certified in 

accordance with the Signatory Requirements contained in Part II.A.11. 

Wyoming Department of Environmental Quality

Water Quality Division 

Herschler Building, 4 West 

122 West 25th Street 

Cheyenne, WY 82002 

Telephone: (307) 777-7781

If no discharge occurs during the reporting period, "no discharge" shall be reported. If discharge 

is intermittent during the reporting period, sampling shall be done while the facility is 

discharging. 

3. Definitions

a. The "monthly average" shall be determined by calculating the arithmetic mean 

(geometric mean in the case of fecal coliform) of all composite and/or grab samples 

collected during a calendar month. 

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b. The "weekly average" shall be determined by calculating the arithmetic mean (geometric 

mean in the case of fecal coliform) of all composite and/or grab samples collected during 

any week. 

c. The "daily maximum" shall be determined by the analysis of a single grab or composite 

sample. 

d. "MGD", for monitoring requirements, is defined as million gallons per day.

e. "Net" value, if noted under Effluent Characteristics, is calculated on the basis of the net 

increase of the individual parameter over the quantity of that same parameter present in 

the intake water measured prior to any contamination or use in the process of this facility. 

Any contaminants contained in any intake water obtained from underground wells shall 

not be adjusted for as described above and, therefore, shall be considered as process input 

to the final effluent. Limitations in which "net" is not noted are calculated on the basis of 

gross measurements of each parameter in the discharge, irrespective of the quantity of 

those parameters in the intake waters. 

f. A "composite" sample, for monitoring requirements, is defined as a minimum of four 

grab samples collected at equally spaced two hour intervals and proportioned according 

to flow. 

g. An "instantaneous" measurement for monitoring requirements is defined as a single 

reading, measurement, or observation. 

h. A "pollutant" is any substance or substances which, if allowed to enter surface waters of 

the state, causes or threatens to cause pollution as defined in the Wyoming Environmental 

Quality Act, Section 35-11-103. 

i. "Total Flow" is the total volume of water discharged, measured on a continuous basis and 

reported as a total volume for each month during a reporting period. The accuracy of 

flow measurement must comply with Part III.A.1. 

4. Test Procedures

Test procedures for the analysis of pollutants, collection of samples, sample containers, sample 

preservation, and holding times, shall conform to regulations published pursuant to 40 CFR, Part 

136, unless other test procedures have been specified in this permit.

5. Recording of Results

For each measurement or sample taken pursuant to the requirements of this permit, the permittee 

shall record the following information: 

a. The exact place, date and time of sampling; 

b. The dates and times the analyses were performed; 

c. The person(s) who performed the analyses and collected the samples; 

d. The analytical techniques or methods used; and 

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e. The results of all required analyses including the bench sheets, instrument readouts, 

computer disks or tapes, etc., used to determine the results. 

6. Additional Monitoring by Permittee

If the permittee monitors any pollutant at the location(s) designated herein more frequently than

required by this permit, using approved analytical methods as specified above, the results of such 

monitoring shall be included in the calculation and reporting of the values required in the 

Discharge Monitoring Report Form. Such increased frequency shall also be indicated. 

7. Records Retention

The permittee shall retain records of all monitoring information, including all calibration and 

maintenance records and all original strip chart recordings for continuous monitoring 

instrumentation, copies of all reports required by this permit, and records of all data used to 

complete the application for this permit, for a period of at least three years from the date of the 

sample, measurement, report or application. This period may be extended by request of the 

administrator at any time. Data collected on site, copies of Discharge Monitoring Reports and a 

copy of this NPDES permit must be maintained on site during the duration of activity at the 

permitted location. 

8. Penalties for Tampering

The Act provides that any person who falsifies, tampers with or knowingly renders inaccurate, 

any monitoring device or method required to be maintained under this permit shall, upon 

conviction, be punished by a fine of not more than $10,000 per violation, or by imprisonment for 

not more than two years per violation, or both. 

9. Compliance Schedules

Reports of compliance or noncompliance with, or any progress reports on interim and final 

requirements contained in any Compliance Schedule of this permit shall be submitted no later 

than 14 days following each schedule date. 

10. Facility Identification

All facilities discharging produced water shall be clearly identified with an all-weather sign 

posted at each outfall and flow monitoring locations (points of compliance). This sign shall, as a 

minimum, convey the following information: 

a. The name of the company, corporation, person(s) who holds the discharge permit, and the 

NPDES permit number; 

b. The contact name and phone number of the person responsible for the records associated 

with the permit; 

c. The name of the facility (lease, well number, etc.) and the outfall number as identified by

the discharge permit. 

11. Identification and Establishment of Discharge Points

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According to 40 CFR 122.21(k)(1), the permittee shall identify the expected location of each 

discharge point on the appropriate NPDES permit application form. The location of the discharge 

point must be identified to within an accuracy of 15 seconds. This equates to a distance of 1,510 

feet. 

Public notice is not required if the location of the established discharge point is within 1,510 feet 

of the location of the discharge point originally identified on the permit application. In addition, 

the discharge must be within the same drainage and must discharge to the same landowner's 

property as identified on the original application form. If the three previously stated requirements 

are not satisfied, modification of the discharge point location(s) constitutes a major modification 

of the permit as defined in Part I.B.12. The permittee shall provide written notification of the 

establishment of each discharge point in accordance with Part I.A.7.a above. 

12. Location of Outfalls, Flow Monitoring and Water Quality Monitoring Stations

As of the date of permit issuance, authorized points of discharge were as follows: 

SEE TABLE 1 FOR A LIST OF OUTFALL AND WATER QUALITY MONITORING 

STATION LOCATIONS 

Requests for modification of the below list will be processed as follows. If the requested modification 

satisfies the definition of a minor permit modification as defined in 40 CFR 122.63 modifications will 

not be required to be advertised in a public notice. A minor modification constitutes a correction of a 

typographical error, increase in monitoring and/or reporting, revision to an interim compliance schedule 

date, change in ownership, revision of a construction schedule for a new source discharger, deletion of 

permitted outfalls, and/or the incorporation of an approved local pretreatment program. 

A request for a minor modification must be initiated by the permittee by completing the form titled 

Wyoming Pollutant Discharge Elimination System Permit Modification Application For Coal Bed 

Methane. Incomplete application forms will be returned to the applicant. 

The outfalls listed in Table 1 (located at the end of Part I) may be moved from the established 

location without submittal of a permit modification application provided all of the following 

conditions are satisfied: 

1. The new outfall location is within 2640 feet of the established outfall location. 

2. The new outfall location is within the same drainage or immediate permitted receiving 

waterbody. 

3. There is no change in the affected landowners. 

4. Notification of the change in outfall location must be provided to the NPDES Permits Section on 

a form provided by the WQD Administrator within 10 days of the outfall location change. The

form must be provided in duplicate and legible maps showing the previous and new outfall 

location must be attached to the form. 

Moving an outfall location without satisfying the four above listed conditions will be considered a 

violation of this permit and subject to full enforcement authority of the WQD. 

An outfall relocation as described above will not be allowed if the new outfall location is less 

than one mile from the confluence of a Class 2 waterbody and the dissolved iron limits 

established in the permit for the outfall are based upon Class 3 standards. 

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Outfall # Immediate

Receiving Stream

Distance from outfall to

mainstem (stream miles) Qtr Qtr Sec Twn Rng Latitude Longitude

001

Unnamed,

ephemeral 

tributary, Dry Cow

Creek

45 NW NE 13 16 N 92 W 41.36278 -107.693470

002

Unnamed,

ephemeral 

tributary, Dry Cow

Creek

45 NW NE 13 16 N 92 W 41.36213 -107.692122

Station Immediate

Receiving Stream Station Description Qtr Qtr Sec Twn Rng Latitude Longitude

TRIB1 Muddy Creek

Tributary water quality

monitoring station

located upstream of the 

Muddy Creek - Little

Snake River confluence

SE SE 32 13 N 91 W 41.04757 -107.650266

UMC Muddy Creek

Tributary water quality

monitoring station

located upstream of the 

Muddy Creek - Cow

Creek confluence

SE NE 2 15 N 92 W 41.30122 -107.710541

DMC Muddy Creek

Tributary water quality

monitoring station 

located downstream of

the Muddy Creek - Cow

Creek confluence

NE SW 19 15 N 91 W 41.25646 -107.679890

ULSR Little Snake River

Upstream mainstem

water quality monitoring 

station

SW NE 5 12 N 91 W 41.03795 -107.648054

DLSR Little Snake River

Downstream mainstem

water quality monitoring 

station

NW SW 4 12 N 91 W 41.04014 -107.656577

TABLE 1: OUTFALL AND WATER QUALITY MONITORING STATION LOCATION INFORMATION,

WY0054038

IRRIGATION COMPLIANCE AND WATER QUALITY MONITORING STATION LOCATION INFORMATION

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PART II

A. MANAGEMENT REQUIREMENTS

1. Changes

The permittee shall give notice to the administrator of the Water Quality Division as soon as 

possible of any physical alterations or additions to the permitted facility. Notice is required 

when: 

a. The alteration or addition to a permitted facility may meet one of the criteria for 

determining whether a facility is a new source as determined in 40 CFR 122.29 (b); or 

b. The alteration or addition could change the nature or increase the quantity of pollutants 

discharged. 

2. Noncompliance Notification

a. The permittee shall give advance notice of any planned changes in the permitted facility

or activity which may result in noncompliance with permit requirements. 

b. The permittee shall report any noncompliance which may endanger health or the 

environment as soon as possible, but no later than 24 hours from the time the permittee 

first became aware of the circumstances. The report shall be made to the Water Quality

Division, Wyoming Department of Environmental Quality at (307) 777-7781. 

c. For any incidence of noncompliance, including noncompliance related to non-toxic 

pollutants or non-hazardous substances, a written submission shall be provided within 

five (5) days of the time that the permittee becomes aware of the noncompliance 

circumstance.

The written submission shall contain: 

(1) A description of the noncompliance and its cause; 

(2) The period of noncompliance, including exact dates and times; 

(3) The estimated time noncompliance is expected to continue if it has not been 

corrected; and 

(4) Steps taken or planned to reduce, eliminate and prevent reoccurrence of the 

noncompliance. 

d. The following occurrences of unanticipated noncompliance shall be reported by

telephone to the Water Quality Division, Watershed Management Section, NPDES 

Program (307) 777-7781 as soon as possible, but no later than 24 hours from the time the 

permittee first became aware of the circumstances.

(1) Any unanticipated bypass which exceeds any effluent limitation in the permit; 

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(2) Any upset which exceeds any effluent limitation in the permit; or 

(3) Violation of a maximum daily discharge limitation for any toxic pollutants or 

hazardous substances, or any pollutants specifically identified as the method to 

control a toxic pollutant or hazardous substance listed in the permit. 

e. The administrator of the Water Quality Division may waive the written report on a caseby-case basis if the oral report has been received within 24 hours by the Water Quality

Division, Watershed Management Section, NPDES Program (307) 777-7781. 

f. Reports shall be submitted to the Wyoming Department of Environmental Quality at the 

address in Part I under Reporting and to the Planning and Targeting Program, 8ENF-PT, 

Office of Enforcement, Compliance, and Environmental Justice, U.S. EPA Region 8, 999 

18th St., Suite 300, Denver, CO 80202-2466. 

g. The permittee shall report all instances of noncompliance that have not been specifically

addressed in any part of this permit at the time the monitoring reports are due. 

3. Facilities Operation

The permittee shall, at all times, properly operate and maintain all facilities and systems of 

treatment and control (and related appurtenances) which are installed or used by the permittee to

achieve compliance with the conditions of this permit. Proper operation and maintenance also

includes adequate laboratory controls and appropriate quality assurance procedures. This 

provision requires the operation of back-up or auxiliary facilities or similar systems which are 

installed by the permittee only when the operation is necessary to achieve compliance with the 

conditions of the permit. However, the permittee shall operate, as a minimum, one complete set 

of each main line unit treatment process whether or not this process is needed to achieve permit

effluent compliance. 

4. Adverse Impact

The permittee shall take all reasonable steps to minimize any adverse impact to waters of the state 

resulting from noncompliance with any effluent limitations specified in this permit, including

such accelerated or additional monitoring as necessary to determine the nature and impact of the 

noncomplying discharge. 

5. Bypass of Treatment Facilities

a. Bypass means the intentional diversion of waste streams from any portion of a treatment 

facility. 

b. The permittee may allow any bypass to occur which does not cause effluent limitations to 

be exceeded, but only if it is for essential maintenance to assure efficient operation. 

These bypasses are not subject to the provisions of paragraphs c. and d. of this section. 

Return of removed substances to the discharge stream shall not be considered a bypass 

under the provisions of this paragraph. 

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c. Notice: 

(1) Anticipated bypass. If the permittee knows in advance of the need for a bypass, 

it shall submit prior notice at least 60 days before the date of the bypass. 

(2) Unanticipated bypass. The permittee shall submit notice of an unanticipated 

bypass as required under Part II.A.2. 

d. Prohibition of bypass. 

(1) Bypass is prohibited and the administrator of the Water Quality Division may

take enforcement action against a permittee for a bypass, unless: 

(a) The bypass was unavoidable to prevent loss of life, personal injury or 

severe property damage; 

(b) There were no feasible alternatives to the bypass, such as the use of 

auxiliary treatment facilities, retention of untreated wastes or 

maintenance during normal periods of equipment downtime. This 

condition is not satisfied if adequate back-up equipment should have 

been installed to prevent a bypass which occurred during normal periods 

of equipment downtime or preventive maintenance; and 

(c) The permittee submitted notices as required under paragraph c. of this 

section. 

e. The administrator of the Water Quality Division may approve an anticipated bypass, after 

considering its adverse effects, if the administrator determines that it will meet the three 

conditions listed above in paragraph d. (l) of this section. 

6. Upset Conditions

a. Upset means an exceptional incident in which there is unintentional and temporary

noncompliance with technology based permit effluent limitations because of factors 

beyond the reasonable control of the permittee. An upset does not include 

noncompliance to the extent caused by operational error, improper designed treatment 

facilities, inadequate treatment facilities, lack of preventive maintenance, or careless or 

improper operation. 

b. An upset constitutes an affirmative defense to an action brought for noncompliance with 

technology based permit effluent limitations if the requirements of paragraph c. of this 

section are met. 

c. A permittee who wishes to establish the affirmative defense of upset shall demonstrate, 

through properly signed, contemporaneous operating logs or other relevant evidence that: 

(1) An upset occurred and that the permittee can identify the cause(s) of the upset; 

(2) The permitted facility was at the time being properly operated; 

(3) The permittee submitted notice of the upset as required under Part II.A.2; and 

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(4) The permittee complied with any remedial measures required under Part II.A.4. 

d. Burden of proof. In any enforcement proceeding, the permittee seeking to establish the 

occurrence of an upset has the burden of proof. 

7. Removed Substances

Solids, sludges, filter backwash or other pollutants removed in the course of treatment or control 

of wastewaters or intake waters shall be disposed of in a manner such as to prevent any pollutant 

from such materials from entering waters of the state. 

8. Power Failures

In order to maintain compliance with the effluent limitations and prohibitions of this permit, the 

permittee shall either: 

a. In accordance with a schedule of compliance contained in Part I, provide an alternative 

power source sufficient to operate the wastewater control facilities; or 

b. If such alternative power source as described in paragraph a. above is not in existence and 

no date for its implementation appears in Part I, take such precautions as are necessary to 

maintain and operate the facility under its control in a manner that will minimize upsets 

and insure stable operation until power is restored. 

 9. Duty to Comply

The permittee must comply with all conditions of this permit. Any permit noncompliance 

constitutes a violation of the federal act and the Wyoming Environmental Quality Act and is 

grounds for enforcement action; for permit termination, revocation and reissuance, or 

modification; or for denial of a permit renewal application. The permittee shall give the 

administrator of the Water Quality Division advance notice of any planned changes at the 

permitted facility or of any activity which may result in permit noncompliance. 

10. Duty to Mitigate

The permittee shall take all reasonable steps to minimize or prevent any discharge in violation of 

this permit which has a reasonable likelihood of adversely affecting human health or the 

environment. 

11. Signatory Requirements

All applications, reports or information submitted to the administrator of the Water Quality

Division shall be signed and certified. 

a. All permit applications shall be signed as follows: 

(1) For a corporation: by a responsible corporate officer; 

(2) For a partnership or sole proprietorship: by a general partner or the proprietor, 

respectively;

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(3) For a municipality, state, federal or other public agency: by either a principal 

executive officer or ranking elected official. 

b. All reports required by the permit and other information requested by the administrator of 

the Water Quality Division shall be signed by a person described above or by a duly

authorized representative of that person. A person is a duly authorized representative 

only if: 

(1) The authorization is made in writing by a person described above and submitted 

to the administrator of the Water Quality Division; and 

(2) The authorization specified either an individual or a position having

responsibility for the overall operation of the regulated facility or activity, such 

as the position of plant manager, operator of a well or a well field, 

superintendent, position of equivalent responsibility or an individual or position 

having overall responsibility for environmental matters for the company. A duly

authorized representative may thus be either a named individual or any individual 

occupying a named position. 

c. If an authorization under paragraph II.A.11.b. is no longer accurate because a different 

individual or position has responsibility for the overall operation of the facility, a new 

authorization satisfying the requirements of paragraph II.A.11.b must be submitted to the 

administrator of the Water Quality Division prior to or together with any reports, 

information or applications to be signed by an authorized representative. 

d. Any person signing a document under this section shall make the following certification: 

"I certify, under penalty of law, that this document and all attachments were prepared 

under my direction or supervision in accordance with a system designed to assure that 

qualified personnel properly gather and evaluate the information submitted. Based on my

inquiry of the person or persons who manage the system or those persons directly 

responsible for gathering the information, the information submitted is, to the best of my

knowledge and belief, true, accurate and complete. I am aware that there are significant 

penalties for submitting false information, including the possibility of fine and 

imprisonment for knowing violations." 

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B. RESPONSIBILITIES

1. Inspection and Entry

If requested, the permittee shall provide written certification from the surface landowner(s), if 

different than the permittee, that the administrator or the administrator’s authorized agent has 

access to all physical locations associated with this permit including well heads, discharge points, 

reservoirs, monitoring locations, and any waters of the state. 

The permittee shall allow the administrator of the Water Quality Division or an authorized 

representative, upon the presentation of credentials and other documents as may be required by 

law, to: 

a. Enter upon the permittee's premises where a regulated facility or activity is located or 

conducted or where records must be kept under the conditions of this permit; 

b. Have access to and copy, at reasonable times, any records that must be kept under the 

conditions of this permit; 

c. Inspect, at reasonable times, any facilities, equipment (including monitoring and control 

equipment), practices or operations regulated or required under this permit; and 

d. Sample or monitor, at reasonable times, for the purpose of assuring permit compliance or 

as otherwise authorized by the federal act, any substances or parameters at any location. 

2. Transfer of Ownership or Control

In the event of any change in control or ownership of facilities from which the authorized 

discharges emanate, the permittee shall notify the succeeding owner or controller of the existence 

of this permit by letter, a copy of which shall be forwarded to the regional administrator of the 

Environmental Protection Agency and the administrator of the Water Quality Division. The 

administrator of the Water Quality Division shall then provide written notification to the new 

owner or controller of the date in which they assume legal responsibility of the permit. The 

permit may be modified or revoked and reissued to change the name of the permittee and 

incorporate such other requirements as described in the federal act. 

3. Availability of Reports

Except for data determined to be confidential under Section 308 of the federal act, all reports 

prepared in accordance with the terms of this permit shall be available for public inspection at the 

offices of the Wyoming Department of Environmental Quality and the regional administrator of 

the Environmental Protection Agency. As required by the federal act, effluent data shall not be 

considered confidential. Knowingly making any false statement on any such report may result in 

the imposition of criminal penalties as provided for in Section 309 of the federal act. 

4. Toxic Pollutants

The permittee shall comply with effluent standards or prohibitions established under Section 307 

(a) of the federal act for toxic pollutants within the time provided in the regulations that establish 

those standards or prohibitions, even if the permit has not yet been modified to incorporate the 

requirement. 

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5. Changes in Discharge of Toxic Substances

Notification shall be provided to the administrator of the Water Quality Division as soon as the 

permittee knows of, or has reason to believe: 

a. That any activity has occurred or will occur which would result in the discharge, on a 

routine or frequent basis, of any toxic pollutant which is not limited in the permit, if that 

discharge will exceed the highest of the following "notification levels": 

(1) One hundred micrograms per liter (100 μg/l); 

(2) Two hundred micrograms per liter (200 μg/l) for acrolein and acrylonitrile; five 

hundred micrograms per liter (500 μg/l) for 2,4-dinitrophenol and for 2-methyl4,6-dinitrophenol; and one milligram per liter (1 mg/1) for antimony; 

(3) Five (5) times the maximum concentration value reported for that pollutant in the

permit application in accordance with 40 CFR 122.21 (g) (7); or 

(4) The level established by the director of the Environmental Protection Agency in

accordance with 40 CFR 122.44 (f). 

b. That any activity has occurred or will occur which would result in any discharge, on a 

non-routine or infrequent basis, of a toxic pollutant which is not limited in the permit, if 

that discharge will exceed the highest of the following "notification levels": 

(1) Five hundred micrograms per liter (500 μg/l); 

(2) One milligram per liter (1 mg/1) for antimony; 

(3) Ten (10) times the maximum concentration value reported for that pollutant in 

the permit application in accordance with 40 CFR 122.21 (g) (7); or 

(4) The level established by the director of the Environmental Protection Agency in

accordance with 40 CFR 122.44 (f). 

6. Civil and Criminal Liability

Nothing in this permit shall be construed to relieve the permittee from civil or criminal penalties 

for noncompliance. As long as the conditions related to the provisions of "Bypass of Treatment

Facilities" (Part II.A.5), "Upset Conditions" (Part II.A.6), and "Power Failures" (Part II.A.8) are 

satisfied then they shall not be considered as noncompliance. 

7. Need to Halt or Reduce Activity not a Defense

It shall not be a defense for a permittee in an enforcement action that it would have been 

necessary to halt or reduce the permitted activity in order to maintain compliance with the 

conditions of this permit. 

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8. Oil and Hazardous Substance Liability

Nothing in this permit shall be construed to preclude the institution of any legal action or relieve 

the permittee from any responsibilities, liabilities or penalties to which the permittee is or may be 

subject under Section 311 of the federal act. 

9. State Laws

Nothing in this permit shall be construed to preclude the institution of any legal action or relieve 

the permittee from any responsibilities, liabilities or penalties established pursuant to any

applicable state or federal law or regulation. In addition, issuance of this permit does not 

substitute for any other permits required under the Clean Water Act or any other federal, state, or 

local law. 

10. Property Rights

The issuance of this permit does not convey any property rights in either real or personal 

property, or any exclusive privileges, nor does it authorize any injury to private property or any

invasion of personal rights nor any infringement of federal, state or local laws or regulations. 

11. Duty to Reapply

If the permittee wishes to continue an activity regulated by this permit after the expiration date of 

this permit, the permittee must apply for and obtain a new permit. The application should be 

submitted at least 180 days before the expiration date of this permit. 

12. Duty to Provide Information

The permittee shall furnish to the administrator of the Water Quality Division, within a 

reasonable time, any information which the administrator may request to determine whether 

cause exists for modifying, revoking and reissuing or terminating this permit or to determine 

compliance with this permit. The permittee shall also furnish to the administrator, upon request, 

copies of records required by this permit to be kept. 

13. Other Information

When the permittee becomes aware that it failed to submit any relevant facts in a permit 

application or submitted incorrect information in a permit application or any report to the 

administrator of the Water Quality Division, it shall promptly submit such facts or information. 

14. Permit Action

This permit may be modified, revoked and reissued, or terminated for cause. The filing of a 

request by the permittee for a permit modification, revocation and reissuance, or termination, or a 

notification of planned changes or anticipated noncompliance does not stay any permit condition. 

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PART III

A. OTHER REQUIREMENTS

 1. Flow Measurement

At the request of the administrator of the Water Quality Division, the permittee must be able to 

show proof of the accuracy of any flow measuring device used in obtaining data submitted in the 

monitoring report. The flow measuring device must indicate values of within plus or minus ten 

(10) percent of the actual flow being measured. 

 2. 208(b) Plans

This permit may be modified, suspended or revoked to comply with the provisions of any 208(b) 

plan certified by the Governor of the State of Wyoming. 

 3. Reopener Provision

This permit may be reopened and modified (following proper administrative procedures) to 

include the appropriate effluent limitations (and compliance schedule, if necessary) or other 

appropriate requirements if one or more of the following events occurs: 

a. The state water quality standards of the receiving water(s) to which the 

permittee discharges are modified in such a manner as to require different effluent limits 

than contained in this permit; 

b. A total maximum daily load (TMDL) and/or watershed management 

plan is developed and approved by the state and/or the Environmental Protection Agency

which specifies a wasteload allocation for incorporation in this permit; 

c. A revision to the current water quality management plan is approved and 

adopted which calls for different effluent limitations than contained in this permit; 

d. Downstream impairment is observed and the permitted facility is 

contributing to the impairment; 

e. The limits established by the permit no longer attain and/or maintain 

applicable water quality standards; 

f. The permit does not control or limit a pollutant that has the potential to 

cause or contribute to a violation of a state water quality standard. 

g. If new applicable effluent guidelines and/or standards have been 

promulgated and the standards are more stringent than the effluent limits established by

the permit. 

h. In order to protect water quality standards in neighboring states, effluent 

limits may be incorporated into this permit or existing limits may be 

modified to ensure that the appropriate criteria, water quality standards and 

assimilative capacity are attained. 

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 4. Permit Modification

After notice and opportunity for a hearing, this permit may be modified, suspended or revoked in

whole or in part during its term for cause including, but not limited to, the following: 

a. Violation of any terms or conditions of this permit; 

b. Obtaining this permit by misrepresentation or failure to disclose fully all relevant facts; 

c. A change in any condition that requires either a temporary or permanent reduction or 

elimination of the authorized discharge; or 

d. If necessary to comply with any applicable effluent standard or limitation issued or 

approved under Sections 301(b) (2) (C) and (D), 304 (b) (2) and 307 (a) (2) of the federal 

act, if the effluent standard or limitation so issued or approved: 

(1) Contains different conditions or is otherwise more stringent than any effluent 

limitation in the permit; or 

(2) Controls any pollutant not limited in the permit. 

 5. Toxicity Limitation - Reopener Provision

This permit may be reopened and modified (following proper administrative procedures) to 

include a new compliance date, additional or modified numerical limitations, a new or different 

compliance schedule, a change in the whole effluent protocol or any other conditions related to 

the control of toxicants if one or more of the following events occur: 

a. Toxicity was detected late in the life of the permit near or past the deadline for 

compliance; 

b. The TRE results indicate that compliance with the toxic limits will require an 

implementation schedule past the date for compliance and the permit issuing authority

agrees with the conclusion; 

c. The TRE results indicate that the toxicant(s) represent pollutant(s) that may be controlled 

with specific numerical limits and the permit issuing authority agrees that numerical 

controls are the most appropriate course of action; 

d. Following the implementation of numerical controls on toxicants, the permit issuing 

authority agrees that a modified whole effluent protocol is necessary to compensate for 

those toxicants that are controlled numerically; 

e. The TRE reveals other unique conditions or characteristics which, in the opinion of the 

permit issuing authority, justify the incorporation of unanticipated special conditions in 

the permit. 

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 6. Severability

The provisions of this permit are severable and if any provision of this permit, or the application 

of any provision of this permit to any circumstance is held invalid, the application of such 

provision to other circumstances and the remainder of this permit, shall not be affected thereby. 

 7. Penalties for Falsification of Reports

The federal act provides that any person who knowingly makes any false statement, 

representation or certification in any record or other document submitted or required to be 

maintained under this permit, including monitoring reports or reports of compliance or 

noncompliance shall, upon conviction, be punished by a fine of not more than $10,000 per 

violation or by imprisonment for not more than two years per violation or both. 

Page 26 
Appendix B 
 

Carl Babb, PG, Consulting Hydrogeologist 
 

Channel Assessment 
 

(Map and Photo Points Not Included) 
 

Cow Creek CBNG Project 
 
DOUBLEEAGLE PETROLEUM 

COW GREEK CBNGPRO'EGT 

T16N.R91W& R92W
 

CARBONCOUNTY,WYOMING
 

CHANNELASSESS']'EtT 

Prepared for Double Eagle Petroleum 

Preparedby CarletonS. Babb,PG 

Hydrogeologist 

P.O.Box 4146 

Casper, Wyoming 82604 

307t234-7376 

cnlbabb@wyoming.com 

OunuO9,2006 

,-.* 

: l'-- -, .' I i 

i----i 

i

: i

j ltG l^u2A06 f 

i 

i

I 

,,..,,ii*r;, fl -. -_ _ : I Ll,\tf ---:r:::-fj!*!S!= ) & '" . ;_c" t;trur/

| 

____:,=--­ i 
DoubleEagle Petroleum Company
 

Cow Creek CBNG Project
 

CarbonCounty,Wyoming
 

ChannelAssessmenf
 

Table of Contents 

Purposeof Study. . . . . . . . . . . . . . . ...... . . . . . 1 

Summary....... .....................1 

Locationof Study......... ....................2


FieldMethods. ...".. ........2 


Existing Project........ .. .............
....2


Historyof Project......."... ....."....................3 


Channel Morphologies.. ........................3 


Unnamed TributaryofDryCow Creek. ... . ... . " ^ ......... ... ... ....4

DryCow Creek fromConfluencewithUnnamedTributaryto Confluence 

with Tributary from BLM Flowing WellinSection22, T16N-R91W........5 

DryCow Creek fromConfluencewith Tributary from BLM Flowing Well in 

Section22, T'l6N-R91W to Confluence with Cow Creek......... 
 .......... 
 .5

AreaAnalogies ........."."6
 

ConveyanceLoss...... ...................
 ......7 

Sediment Samoles........ 
 ...........7

Monitoring...... ....................8 


Mitigation....... ............8 


Beneficial " Use..... ... . . . ... . ... .... ... ..........,8


Conclusions... . .. . .. . .. .. ......,..... .9

Ma0 

1:24,000TopographicMapwithGPSWaypoints& Cross-SectionLocations 

Tables 

1. WaypointLocations& Channel Data 

2. PhotoDescriptions 

3" Cross-SectionLocations& Channel Data 

4. SedimentAnalvses 

AqpendixA 

RepresentativePhotos 

CD.ln Binder Po.ckeJ 

AllAssessmentPhotos 

DoubleEagleCharnel Assessment 8/A9/06 
DoubleEaglePetroleurnComPanY 

Cow Creek CBNGProiect 

CarbonCouniy,Wyoming ffih ftt- 'z'- r"ilj:T b;ff

Channel^Assessmenf 

Purpose of Study 

\ 1Y0054038 	 

Double Eagle Petroleum Companyon March31, 2006. Thestudyis to be completed 

priortothedischargeof treated CBNG water into an unnamedtributaryof Dry Cow 

Creek.The study isto identifyareasof high erosion potential,whichwillthenbe 

monitoredon an annual basis.Surveyed andphotos any 

Thisstudyisa requirement ofWPDESpermit issued by WDEQIIA/QDto 

cross-sections willdocument

changes occuning at these sites. This study will also be forwarded to the BLM, Rawlins 

to support DoubleEagle's Sundry Noticeto construct a water-treatment plantusingEmit 

Technologies' HigginsLoop Process. 

Summary 

Inmyprofessional opinion, therewillbeno significant 	 impact due to erosioninthe

subject channel reachesbythe release of treated water from Double Eagle's Cow 

Creek CBNG Piect. Thisconclusionis supported by the follo\A/ing facts: 

r Theseare established channelswithadequatecapacitythathavepreviously 

receivedflows from the 1X-12 well and LSRCD Section 13 Reservoir 

o Thechannelshave low slopes . There is very little head-cutting 

r The channels have established vegetationand overa!|, are in a stablecondition 

r Thechannelshave varying amountsof clayliningthem now, making themmore 

resistantto erosion; this condition will increase ina wetted condition with the 

growthofalgae, which will entrap more clay 

. Thereare several wettedanaloguesin the area that demonstrate goodriparian 

vegetatian anda laek af signifiaant ero$iQn . The channels have adjusted to the natural flow rates;the 1.3 cfs projectrate is 

muchless than the 1.5-yearestimatedpeakflows of 22 up to 127 cfs . 	 DoubleEagleholdsapprovedWPDESpermitsto discharge treatedwater to a 

tributary of Dry Cow Creek; to discharge producedwaterto the LSRCD reservoir; 

andto releasewater from thereservoirona seasonal basis 

n Double Eagle alsoholdsClass ll and Class V injectionpermits
 

. A prudenloperatormusthave more than one water-management 
 option
 . DoubleEagle is making a significant commitmentto monitciring 
 erosion
and

waterquality;thisincludesany necessary mitigation. 


| 0 2.006 

DoubleEagleCf,anrel Assessment 8/09/06 
Theprojectandstudy area must be putintoperspective.The reach of channels being 

assessed is not "virgin".The lower reach of DryCowCreekfromthe confluence of the 

tributary carrying water from the BLM tlowingwellin Section 2?, T16N-R91\A/ has heen 

wettedforover43years. The 4.7 stream-miles fromtheprojectoutfalls along the 

unnamed tributary of Dry Cow Creek and alongDry Cow Creek to its confluence with 

thewet,"BLMtributary"havecarriedperennialfow from the1X-12well in the Cow 

Creek Unit, and more recently, seasonalflow from theLSRCD reservoir in Section 13, 

T16N-R92W. 

Location of Study 

Thisstudy follows the unnamed tributary of Dry Cow Creek from proposeddischarge pointsDPI and DP2 in Section13,T16N-R92Wto its confluence withDry Cow Creek in 

Section 19, T16N-R91W, thenceio the confluence of Dry Cow Creek with Cow Creek in 

Section5, T15N-R91W (approximately7 stream-miles). 

Field Methods 

Field work for this study wasperformedon June 27,28 and29,2006. A vehicle was 

used to shuttle along the drainages, parkingnear roads and hikingto the channel, then 

hikingupanddown the channel fromthatpoint.A hand-held GPS unit was used to 

regisler vvaypoint WP) locationsto locate cross-sectionlocations,areas of concern, 

observationpointsandphotos. 

Waypointlocationsare displayed on the enclosed map; cross-sections arelabeledin 

red.Apparentgapsbetweenwaypointswereassessedvisuallyandwere similarto the 

waypointsites. Slopes weremeasuredwitha hand-held inclinometerand channel 

dimensionsweremeasuredwitha tape-measure. 

Cross-sectionsweremarkedby fluorescent orangepainton sagebrush, orange flagging 

onbrushand/ororangepin-flags.Thesewill be surveyed by a licensed surveyorinthe 

nearfutureand the resulting cross-sectionswillbe attached to this report for baseline 

data. 

Existing Project 

Thepmjectpresentlyconsistsof fourteen producingwells and three injection wells. 

Fourteenadditionalproducersandoneadditional injectorhavebeenproposed.In 

additiontothe injection wellpermits,DoubleEagle holds approvedwpDEs permitsto 

dischargetreatedwaterto a iributaryof Dry cow creek; to discharge producedwater to the LSRCDreservoir;andto release water from the reservoir ona seasonal basis. A prudentoperatormust have severalwater-management optionsavailableto them. 

DoubleEagleChanrelAssessmentB/09n6 
Double Eagle will movetheproposedoutfalls(DP's1&2) to the banks oftheunnamed 

tributary0A/P's17 & 20) to avoid steeperslopes and the resultanthighervelocitiesand 

erosionpatentialfrorn the proposedlocationsto the north. tl/aypoints18 & 19arenorth 

of the unnamed tributaryof Dry Cow Creek on a gullyleadingto the originally-proposed 

dischargepoint#1 . 

History of Project 

The 1X-12 rnrell isencld exploratory \lell in the Coru Creek Federa! Unit. lt developed a

casing leak and flowed 4300 bpd into the unnamed tributaryof Dry Cow Creek foryears 

as perennialflow. 

The Little SnakeRiverConservationDistrict,withfundingand approval fromtheBLM 

andWyomingGame& Fish, construciedthe LSRCD reservoir(section13)in 1997to 

captu!"ethatwater for beneficia! use. Double Eagle (DE) purchased the Cou,, CreekUnit 

in 1999 to use as a pilot project forCBNGand to develop deeper,conventional natural

gas"DE repaired the casing leak and recompleted the 1X-12 well asa gas producer. 

Theyweregranteda WPDES permitin June, 2001 to continue to discharge waterto the 

LSRCD reservoir. 

Channel Morphologies 

Thechannelswere broken into the tollowing threereachesforanalysis. Tables 1 & 2 

and AppendixA providedocumentationof the data used inthis study. Table 1 is sorted 

hy GPS waypoint(\ffP)numberandp!'esentsthe waypoint location in latitude & 

longitude,GPSelevation,photonumber(s)for that waypoint, channeldata(width, 

depth, slope), Manning calculations forbothproject flowsand 1"5-year peakflows

(Miller,2003)with resultant waterdepths and velocities.Table2 providesphoto 

descriptionsfor all photos.AppendixA containsrepresentativephotos;allphotosare in 

digitalformaton the CD enclosedwiththereport. 

All of the channels includedinthis study lieupon the Lewis Formation, which consists of 

marineshale with interbedded lensesof sandstone andsiltstone. The shales are less 

resistantto erosion than the harder sandstone and siltstone. This is the mostlikely 

causeof the many poolsdevelopedon DryCow Creek" Steep slopes normally promote 

thedevelopment of riffles and pools,but the low slopes existing withinthe study area 

makethis an unlikelyfactor.Thepoolsare connected byvegetated"flats"witha small, 

active channel. 

All of the reaches areperformingtheir natural hydrologicprocessof slowly transporting sedimenteroded from higher elevationsto lower elevations.However,allreachesare 

surprisinglystable, with Veryfewhead-cuts,eslablishedriparianvegelation(sedges, rushes)& grassesanda clay lining in theactive channels. occasionalrockoutcroos 

anddeeperpoolsalsoserve to check channel velocitiesand trap sediment. 

.,",, /:i.l: 1

t,tr'. q)^^

ttjU\ 

DoubleEagleChannel Assessmeft 8/Agn6 
UnnamedTributarv of Dry C$r Creek 

This reanh has rruv nrcr-rinr rslrr reneirred nerennial flnw frnm the 1X- 1 2 u,e!' in the Cov., Creek t i v r reevrt 

Unit for yearsand flow fromtheLSRCD reservoir insection 13, T16N-R92W during 

seasonal releases for several years. Thechannelis entrenched, typicallyfive feet +/-, 

and often displays a compound channel,thatis, a smaller active channel withinthe 

largerchannel.The larger channel is typically I to 11 ft wide; depthsrange from 1 to 2 

fi" Thesmaller sub-channels are 1 to 4 ft wide and Yz 1o 1 ft deep. Theslopetaken 

from the topographicmap for this reach is 0.3"; field slopes, measured with a hand-held 

inclinometer, range from 0.1 to 1.2', with mostbetween 0.1 and 0.4". 

Calculationsweremadeusing the Manning equation to estimate thewaterdepthand 

velocityfortheprojectflow of 1 .3 cfs, assuming no conveyance loss. Estimated water 

denths rence frnm 1 tn 7 inr.hos rvith the laroer rlenfht in the sub-channels. A.t 

waypoints21 &24, the estimated water depths in thesub-channelsaregreaterthanthe 

presentdepthof those channels,so some adjustment ofthe channel at those locations 

might be expected.Velocities range from 0"4to 1 .9 ft/sec; a valueof 2.4 fi/sec was 

calculatedforWP30 in a 2-footwide sub-channel. 

A 1.s-year peakflow of 22cfswasestimatedfortheconfluenceof the unnamed 

tributaryfromtheprojectand Dry Cow Creek using the method of Miller, 2003. This 

flow rate is responsiblefor the formation of the active channels and is much higher than 

the 1 .3 cfs p@ectflow rate. Water depthsin the large channel range from 6 inches to 

1+ feet. Velocities range from 1 .9 to 4.2ftlsec. 

Vegetation,mostlyintheformofgrassesand brush generallyincreasesdown this 

reachtowards the confluencewith Dry Cow Creek. 

The term, mineral depositsis used in thisreport rather than "salts", becauseit more 

accuratelyciescribes ihe makeup oi ihe white deposits occurringnear the ouileiof ihe 

LSRCDreservoir,and decreasing downtothetributarymonitoringpointat WP22. No 

rnineraldepositswere observed belowthe tributary monitoring pointon this reach. The 

accumulationof mineraldepositsobservednear the LSRCDreservoirisanisolated, 

pre-existing condition relatedto dam seepage and high evaporation from standing 

ulater. No{hing of this natur"e has been observed either above the reservoir"or below the 

tributarymonitoringpoini. 

Giventhepastflow history ofthisreach, low slopesand estimated velocities,lack of 

head-cuts,depositsof clay lining the channelandexisting vegetation, itis unlikely that 

theproiectflows will cause significant erosion.An active bank-cutwasobserved at 

WP37(P37);a cross-section will be established at that locationto monitorthe site. 

Ai.'31; 2,:;,6 

DoubleEagleChannelAssessrnent8/09n6 
Drv Cow Creek from Confluence with-UogrmedTributarv to Gonfluence 

with Tributarv fro 

entrenched, valley 

containingwell-establishedgrassesandriparianvegetation.Poolsconnectedby a 

small, active channel through vegetated "flats"are common. Inplaces,compound 

channelshave formed, with a small, active channel within a larger,vegetatedchannel. 

The larger channelshave evidence ofoccasional higher flows (eggrassesand debris 

lodgedinsagebrush).Stablepointbars are evidentand some outcrops of sandstone & 

siltstonearepresent,providinga local source for some increased clasticsedimentsand 

finegravelinthechanneljustbelow the outcrops. 

This reach is characterized by a meandering, small alluvial 

Thealluvialvalley is enirenched approximately6 to 10 fi. Thelarger channel ranges 

from 12 to 30 fi wideand1to 3 ft deep. The smallersub-channelsrangefrom 1 to 5 ft 

wideand 1 to 2 ft deep. Fieldslopesare between 0.3and 1.3'; the topographicmap 

slope is 0.08'. 

Estimatedwater depths fortheprolectflowsof 1.3cfs are between lz and 1 inch in the 

iargerchanneiandfrom 2n to I inches in the sub-channel. Estimaiedvelociiiesinihe 

largerchannel rangefrom 0.7to1.2fVsecand1.2to2.8 ft/secinthesub-channel. The 

estimatesassumeno conveyance loss. 

A 1"s-year peakflowof 22 cfs results inestimatedwaterdepthsrangingfrom 3 to 7 

inches in thelargerchannelwithestimatedvelocitiesbetween2 and3.9 ftlsec. 

Grasses,sedgesandrushesarewellestablishedinthe alluvial valley with brush 

establishedon the pointbars. 

No mineral depositswereobservedinthisreach. 

Gir.,enthelorvslopes and estimated rrelocities. lacknf head-cuts,rtepositsof cla!, lining 

thechannel,establishedvegetationandonly minor erosion from 1.5 yearpeakflows, 

whichare much larger than theproposedprojectflows, it is unlikely that the project 

flowswillcause significant erosionin this reach. Small head-cuts wereobservedat 

WP'S 46 & 50(3'& 2') and active bank-cutting atWP41 A surveyedcross-sectionwill 

be established at WP 50to monitor thesite. 

Dry Gow Creek froqn Cgnfluence with Tlibutarv from BLMElpwinoWell in 

Section22. T16N-R9{W to GonflqgLcewith Cow Greek 

Whenthe field work for this report was performedin late June of this year,this reach 

carriedwaterthroughmostof itslength,but was dryjustaboveits confluence withCow 

Creek. The last water was observed ina siagnant puddleat WP76. The reach i$ 

characterizedby a meandering, entrenched, small alluvial valley,widening-downstream.­ It is a stable reach containingabundantriparianvegetation& grassesinthe valley and 

large sagebrush and salt cedar? ontheflatsabovethe valley. Large poolsa1e 

l 

AUl]10 20tl 

J 

' 

I 

I 

I 

Double Eagle Channel Assessneft 8/A9/A6 
connectedby small, active channels across vegetated "flats'. No significant surface 

flow was observed. A small trickle was observed between poolsatWP63. The rate 

estimatedfor that flow is 0.0027 cfs. Stable pointbars are evident and some outcrops 

of sandstone& siltstonearepresent, providing a local source for some increased fine 

clastic sediments and fine gravelinthe channel immediatelybelow the outcrops. 

10 to 15 ft. The larger channel ranges 

from 8 to 37ftwide and lTzto 3 ft deep, deeper inpools.The smaller sub-channels 

range frorn 1 to 8 ft rnride andTzla 1% ft deep.Fieldslopesare hetween 0.1 and 0.9'; 

theslope derived fromthe topographic map is 0. 13'. 

The alluvial valleyisentrenchedapproximately 


Estimatedwater depths for the projectflows of 1.3cfs are between y2and 2 inches in 


the larger channelandfrom 2 to 5 inches in the sub-channel. Estimatedvelocitiesin 


thelargerchannelrange from 0.5 lo 1.6ft/secand0.7 to 1.8 fllsec inthesub-channel. 


Theestimatesassumeno conveyance loss. 


A 1"S-year peakflow of 127 cfs results inestimatedwater depths rangingfromI inches 


to 21Att in thelargerchannelwithestimatedvelocitiesbetween2 and 3.9 ft/sec. 


Grasses,sedgesandrushesarewellestablishedinthe alluvial valley with brush 


establishedon the pointbars. 


Mineral intermittently 


capillaryzone in the channel bankand the second in the bottom ofdry pools. 


depositswere observed intwosettings;one at the top of the 

No head-cuts were observed in this reach" Given the low slopes and estimated 

velocities,lackof head-cuts,depositsof clay liningthe channel, establishedvegetation 

andonly minor erosion from 1.5 year peak flows, which are much larger than the 

proposedprojectflows, it is unlikely that theprojectflows will causesignificanterosion 

inthisreach.Thisreachhas been wetted by the BLM flowing wellin section 22 for over 

43years.There is no compellingevidencethat storm events have acceleratederosion 

inthis wetted reachof DryCow Creek, 

Area Analogies 

Therearetrvogoodanalogies fa!- the results of per^ennial flow in the area: . Thetributaryinthe SEl4 of Section 12, T16N-R92W carryingproducedwater 

fromthe discharge pointinthe Cow Creekfacilityintothe LSRCD reservoir in 

section 1 3 

r Thetributarycarryingwaterfromthe BLM flowing well in $ection 22, T16NR91Winto Dry esw e reek and the wettedreashofDry Qow Qreek belowthe 

confluencewiththistributarv. 

Both of theseanalogies have developedgoodriparianvegetationand appearquite . stable, with no significanterosionevident.Quentin skinner, a longtime professorat the 

UniversityofWyoming,hasshowninhisWatershed101Seminarthatephemeral 

r , Ail3 1i 2;,:1-t 

DoubleEagleChannel Assessment 8/09/06 
channelsinWyoming receiving asteadyflowofwater will rapidlydevelopa lining of 

clay and algae thatwill stabilize the channel, even during peak-flowevents.ThegroMh 

of riparian vegetationfuriherstabilizesthe channels. The reaches utilizedby this 

projectalreadyhave varying amountsofclayliningthe channels and have some 

riparianvegetationestablished. 

ConveyanceLoss 

Total conveyance loss includes threeprocesses:evaporation, transpiratlon and

infiltration.The BLM flowing well in section 22providesthe best estimate of the total ­ loss. At the time field work was being perforrnedtheweatherwas windy, hot and dry 

conditionsthat should maximizeconveyanceloss. By thetime water from thiswell 

traveledapproximatelysixmiles, the channel of Dry Cow Creek wasdry. This well was 

drilledas an exploratory oil& gaswell in 1962.WyomingStateEngineerrecords 

indicatethe well flowed 20 gpmor approximately 686 bpd. A weir was installed byCK 

Adams(alicensedengineerandOperationsVice-president withDouble Eagle 

Petroleum),inAugust2005to obtain thepresentflow-rate of thiswell. The flow rate 

was 5300 bpd. lf 5300 bpdis lost over six miles,then6183bpd can be expected to be 

lostoverthe seven miles traveled byprojectwater(883bpd/mi). This indicates the 

maximumtotalconveyanceloss expected for the projectwater is 31%. 

SedimentSamples 

Trarn qediment qamnloc rarare nnllanlar{ and analrrzar{ Samnla ntr/nn #1 uzrc nnllonfad 

from the center of the channel atWP17,near the proposeddischargepoints"Sample 

DE/DC-CC#2 was collected near WP73 on Dry CowCreek,justabove the confluence 

of Dry Cow Creek and Cow Creek. Sample #1 was light brown,very fine sand and silt. 

Sample#2 was brown, very fine to fine quartzsand, subrounded andclay.Both 

sampleswere composite samplestaken from the deepest partof the channel down to 

10 inches. 

The laboratory analysesareincludedas Table 4. An SAR of 32.9is reported for 

sample#1 and16.6 for sample#2. This is consistentwiththepriorflows from the 1X12 well and reservoir releases.Downstreamsample#2 is higher in alkalinityand 

bicarbonate. The concentrations of Ca, Mg and Nawere reportedas meq/|. Th-e =._­

concentrations / A:: 't:f)> inmgll are: 

./ 

#1 #2 

Ca 22 5.4 

Mg 71 2.8 

Na 1403 191 i" 

Cf 273 25 "Cl was reported verbally from the lab 

Ailc , ^

t u 2006 

DoubleEagle Chamel Assessment 8/o9/Q6 ' j... 7 

J..iiir' 
Theanalysesindicatethe dorninant constituentin the samples is sulfate and suggest 

that there are fewer mineralspresentin the downstream sediments. Combined withthe 

lack of rrisihlemlneralsin the channels below the tributary monitoringpoint,this 

suggeststhatconcernsabout"salfflushing"are overstated. Certainly,some ofthe 

mineralsinthe upper reachwillgo into solution and the treated water \ /illbe modified by 

travel down the drainage,butany"flushing"will be very short-termand surely the quality 

ofwater in the drainage will not be degraded. The greatestsourceof minerals or salts 

is overland flow from major storm events, a natural process. 

Monitoring 

to monitoringthisproject 

waterquality.Table 3 liststhe waypoint and lat-long locatlonsof seven cross-sections 

that will be established inthenear future to monitorerosioninthe channels withinthe 

study area. The confluence of the unnamedtributary receiving treatedprojectwater 

and Dry Cow Creek is a key location fordistinguishingprojectvs natural impacts. To 

thisend, a cross-section on Dry Cow Creek above the confluence with 

DoubleEagle is making a largeconrmitment for erosion and 

willbe installed 

the tributary and anoiher willbeinsiaiiedon Dry Cow Creek below ihe confiuence. 

Project impacts should only affect the cross-sectionbelow the confluence, while natural 

eventsshouldaffectboth. Cross-sectionswill be re-surveyed andphotographedon an 

annualbasis. To assist with distinguishing between projectandnaturalevents, 

meteorological data will be coliected at the Cow Creek facility.

DoubleEagle will also be conducting annualWETtests on itstreatmentdischargein 

additionto the standard samplingandwill be samplingthree sites on fVluddyCreek and 

two sites on the Little Snake River on a regular basis. Results of this monitoring are 

reportedto WDEQ quarterly. 

Mitigation 

Anyadverse impacts due to erosion will be reported to WDEQ & BLM and prompfly 

mitigatedbyDoubleEagle. 

BeneficialUse 

Ducks,otherbirds, muskrats and other smallmammalswereobservedinthe wet portionof Dry cow creek while doingfield work. Thetreated water released from this proJectwil!be useable andar"railableforagriculture, livestockandwildlife. 

Allc ." , ^

tu 1005 

DoubleEagle Ghannel Assessrnent8/09/06 8 
Conclusions 

ln my profiessional opinion,thereurill be no significant, negativeimpactstothe subject 

channelsdue to erosionresultingfrom the releaseof 1.3cfsoftreatedwaterfrom this 

project.lt is also unlikelythat the waterqualitywithinthedrainagewill be degraded. 

The significant monitoring& mitigation requirements placed on Double Eagleassurethe 

protectionof the publicintere$t. 

Chan sw bd 

Double Eagle Channd AssesEme Angn6 
ENERGY LAEORATOEIEE, lNC. ' 2393 Satr CreekHighway(82ffi1)' P.O. Box 3258 ' Caspet,W 82602 

fo| Free 888235.0515 " 002235.0515. Fax 307.234.1639 . casper@eneryylab.@n ' wtuwenerg)lab.con 

ANA LY TICAL S T]MMA RY REPORT 

- h:Jy 26,2006 

TABLE4 

CSBabbConsulting 

PO Box 4146 

Casper,WY 82604 

WorkorderNo.: C06070041 

Prcject Name: DECC 

Energy Laboratories, Inc.receivedthe following 2 samples fromCSBabb Consulnng on 1/3/20O6 foranalysis. 

Sample ID Client Sample ID Collect Date ReceiveDate Mqtrir Test 

c06070041-001DvDc#l 0612"1/06 12:06 07 /03106 Alkaliniry, Water Extactable 

Satunted Paste Ele.tricalConductivity 

Metals, Soluble 

SolubleMetals from Paste 

SafurationPercentage 

SatulatedPastepH 

SatuEted Paste 

Sodium Adsorption Ratio in Soil 

c06070041-002 DE/DC-CC#2 06/2910616100 07/03/06 Soil SameAs Above 

There were no problems with the analyses and all data for associated QC met EPA or laboratory specifications 

\--__,/ except where noted in the Case Narrative or Report. 

Ifyou haveany questionsregardingthese tests results, pleasecall 

Report Approved By: 

46h
 w
 

T - ack#CA607 OO41 page 
ENEFGY LIBOAATOEIEE l lC. ' 2393 Salt Creek Hbhway (8260, ' PO. Box 3258 . Casperltw 82602 

Tol Free 888.235.0515. 3A7.n5.0515 ' Fax 307.234.7639 . caspet@eneryylab.con ab.con . twwener 

I 

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E 

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I 

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FI 

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I 

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F. 

\-l ? l -io I 

z o 

Fr I 

+ 

J 

b 

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F] 

I 

t 

FI 

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F 

f 

ll3t" a 

r!LJ: -9 

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E;: 

5i; 

TrackJ*CO6OToozr 1 pa.: e 
Appendix C 
 

Discharge Point Information 
 

Double Eagle Petroleum Company 
 


Appendix D 
 

Bureau of Land Management- Rawlins Field Office 
 

Duck Pond Draw Water Quality Samples: 
 

Laboratory Analysis Reports 
 
1673 Terra Avenue 

Sheridan, WY 82801 

Sample Analysis Report 

CLIENT: Bureau of Land Management Date Reported: 8/21/2006 

P. O. Box 2407 Report ID: S0608186001 

1300 North 3rd 


Rawlins, WY 82301 
 Work Order: S0608186 

Project: Dry Cow Creek Collection Date: 8/8/2006 1:56 PM 

Lab ID: S0608186-001 Date Received: 8/8/2006 5:17 PM 

Client Sample ID: Duck Pond Well Sampler: AS 

Matrix: Water 

Analyses Result PQL Qual Units Date Analyzed/Init Method 

General Parameters 

pH 8.48 0.01 s.u. 08/10/2006 1922 WO EPA 150.1 

Electrical Conductivity 2010 5 μmhos/cm 08/10/2006 1922 WO SM 2510B 

Total Dissolved Solids (180) 1240 5 mg/L 08/09/2006 1426 AF SM 2540 

Solids, Total Dissolved (Calc) 1240 10 mg/L 08/17/2006 1547 AO SM 1030F 

Alkalinity, Total (As CaCO3) 1080 1 mg/L 08/10/2006 1922 WO SM 2320B 

Hardness, Calcium/Magnesium (As CaCO3) 10 10 mg/L 08/17/2006 1547 AO SM 2340B 

Silica as SiO2 12.7 0.1 mg/L 08/10/2006 1226 AB EPA 200.7 

Sodium Adsorption Ratio 66.9 0.1 08/17/2006 1547 AO Calculation 

Anions 

Alkalinity, Bicarbonate as HCO3 1260 1 mg/L 08/10/2006 1922 WO SM 2320B 

Alkalinity, Carbonate as CO3 30 1 mg/L 08/10/2006 1922 WO SM 2320B 

Chloride 39 1 mg/L 08/09/2006 1304 LK EPA 300.0 

Fluoride 3.7 0.1 mg/L 08/10/2006 1922 WO SM 4500FC 

Sulfate 19 1 mg/L 08/09/2006 1304 LK EPA 300.0 

Cations 

Calcium 3 1 mg/L 08/10/2006 1226 AB EPA 200.7 

Magnesium 1 1 mg/L 08/10/2006 1226 AB EPA 200.7 

Potassium 5 1 mg/L 08/10/2006 1226 AB EPA 200.7 

Sodium 521 1 mg/L 08/10/2006 1226 AB EPA 200.7 

Cation/Anion-Milliequivalents 

Bicarbonate as HCO3 20.60 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Carbonate as CO3 0.99 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Chloride 1.10 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Fluoride 0.19 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Sulfate 0.39 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Calcium 0.13 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Magnesium 0.09 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Potassium 0.13 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Sodium 22.67 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Cation / Anion Balance 

Cation Sum 23.03 0 meq/L 08/17/2006 1547 AO SM 1030F 

Anion Sum 23.28 0 meq/L 08/17/2006 1547 AO SM 1030F 

Cation-Anion Balance 0.52 0 % 08/17/2006 1547 AO SM 1030F 

These results apply only to the samples tested. 

Qualifiers: * Value exceeds Maximum Contaminant Level B Analyte detected in the associated Method Blank 

E Value above quantitation range H Holding times for preparation or analysis exceeded 

J Analyte detected below quantitation limits L Analyzed by a contract laboratory 

ND Not Detected at the Reporting Limit S Spike Recovery outside accepted recovery limits 

Patricia Quade, Project Manager 

Reviewed by: Page 1 of 5 
1673 Terra Avenue 

Sheridan, WY 82801 

Sample Analysis Report 

Project: Dry Cow Creek 

Client Sample ID: Duck Pond Well 

Matrix: Water 

CLIENT: Bureau of Land Management 

Lab ID: S0608186-001 

P. O. Box 2407 

1300 North 3rd 

Rawlins, WY 82301 

Collection Date: 8/8/2006 1:56 PM 

Work Order: S0608186 

Date Reported: 8/21/2006 

Report ID: S0608186001 

Date Received: 8/8/2006 5:17 PM 

Sampler: AS 

Analyses Result PQL Qual Units Date Analyzed/Init Method 

Dissolved Metals 

Aluminum 

Arsenic 

Barium 

Boron 

Cadmium 

Chromium 

Copper 

Iron 

Lead 

Manganese 

Mercury 

Nickel 

Selenium 

Silver 

Zinc 

ND 

ND 

0.132 

0.8 

ND 

ND 

ND 

ND 

ND 

0.01 

ND 

ND 

0.002 

ND 

0.01 

0.05 

0.001 

0.005 

0.1 

0.0001 

0.001 

0.001 

0.03 

0.002 

0.01 

0.0001 

0.01 

0.001 

0.0005 

0.01 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

mg/L 

08/10/2006 1226 AB 

08/09/2006 1352 MS 

08/09/2006 1352 MS 

08/10/2006 1226 AB 

08/09/2006 1352 MS 

08/10/2006 1226 AB 

08/09/2006 1352 MS 

08/10/2006 1226 AB 

08/09/2006 1352 MS 

08/10/2006 1226 AB 

08/14/2006 828 DG 

08/10/2006 1226 AB 

08/09/2006 1352 MS 

08/09/2006 1352 MS 

08/10/2006 1226 AB 

EPA 200.7 

EPA 200.8 

EPA 200.8 

EPA 200.7 

EPA 200.8 

EPA 200.7 

EPA 200.8 

EPA 200.7 

EPA 200.8 

EPA 200.7 

EPA 245.1 

EPA 200.7 

EPA 200.8 

EPA 200.8 

EPA 200.7 

These results apply only to the samples tested. 

Qualifiers: * 

E 

J 

ND 

Value exceeds Maximum Contaminant Level 

Value above quantitation range 

Analyte detected below quantitation limits 

Not Detected at the Reporting Limit 

B 

H 

L 

S 

Analyte detected in the associated Method Blank 

Holding times for preparation or analysis exceeded 

Analyzed by a contract laboratory 

Spike Recovery outside accepted recovery limits 

Patricia Quade, Project Manager 

Page 2 of 5 Reviewed by: 
1673 Terra Avenue 

Sheridan, WY 82801 

Sample Analysis Report 

CLIENT: Bureau of Land Management Date Reported: 8/21/2006 

P. O. Box 2407 Report ID: S0608186001 

1300 North 3rd 


Rawlins, WY 82301 
 Work Order: S0608186 

Project: Dry Cow Creek Collection Date: 8/8/2006 2:20 PM 

Lab ID: S0608186-002 Date Received: 8/8/2006 5:17 PM 

Client Sample ID: Duck Pond Draw Sampler: AS 

Matrix: Water 

Analyses Result PQL Qual Units Date Analyzed/Init Method 

General Parameters 

pH 9.13 0.01 s.u. 08/10/2006 1953 WO EPA 150.1 

Electrical Conductivity 5170 5 μmhos/cm 08/10/2006 1953 WO SM 2510B 

Total Dissolved Solids (180) 3480 5 mg/L 08/09/2006 1431 AF SM 2540 

Solids, Total Dissolved (Calc) 3260 10 mg/L 08/17/2006 1547 AO SM 1030F 

Alkalinity, Total (As CaCO3) ND 1 mg/L 08/10/2006 1953 WO SM 2320B 

Alkalinity, Total (As CaCO3) 2810 1 mg/L 08/16/2006 1200 WO SM 2320B 

Hardness, Calcium/Magnesium (As CaCO3) 60 10 mg/L 08/17/2006 1547 AO SM 2340B 

Sodium Adsorption Ratio 75.0 0.1 08/17/2006 1547 AO Calculation 

Anions 

Alkalinity, Bicarbonate as HCO3 2920 1 mg/L 08/16/2006 1200 WO SM 2320B 

Alkalinity, Carbonate as CO3 329 1 mg/L 08/10/2006 1953 WO SM 2320B 

Alkalinity, Carbonate as CO3 249 1 mg/L 08/16/2006 1200 WO SM 2320B 

Chloride 128 1 mg/L 08/09/2006 1314 LK EPA 300.0 

Fluoride 6.4 0.1 mg/L 08/10/2006 1953 WO SM 4500FC 

Sulfate 39 1 mg/L 08/09/2006 1314 LK EPA 300.0 

Cations 

Calcium 7 1 mg/L 08/10/2006 1230 AB EPA 200.7 

Magnesium 11 1 mg/L 08/10/2006 1230 AB EPA 200.7 

Potassium 13 1 mg/L 08/10/2006 1230 AB EPA 200.7 

Sodium 1370 1 mg/L 08/10/2006 1230 AB EPA 200.7 

Cation/Anion-Milliequivalents 

Bicarbonate as HCO3 47.93 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Carbonate as CO3 8.28 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Chloride 3.61 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Fluoride 0.33 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Sulfate 0.80 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Calcium 0.36 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Magnesium 0.90 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Potassium 0.32 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Sodium 59.70 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Cation / Anion Balance 

Cation Sum 61.29 0 meq/L 08/17/2006 1547 AO SM 1030F 

Anion Sum 60.98 0 meq/L 08/17/2006 1547 AO SM 1030F 

Cation-Anion Balance 0.25 0 % 08/17/2006 1547 AO SM 1030F 

These results apply only to the samples tested. 

Qualifiers: * Value exceeds Maximum Contaminant Level B Analyte detected in the associated Method Blank 

E Value above quantitation range H Holding times for preparation or analysis exceeded 

J Analyte detected below quantitation limits L Analyzed by a contract laboratory 

ND Not Detected at the Reporting Limit S Spike Recovery outside accepted recovery limits 

Patricia Quade, Project Manager 

Reviewed by: Page 3 of 5 
1673 Terra Avenue 

Sheridan, WY 82801 

Sample Analysis Report 

CLIENT: Bureau of Land Management Date Reported: 8/21/2006 

P. O. Box 2407 Report ID: S0608186001 

1300 North 3rd 

Rawlins, WY 82301 Work Order: S0608186 

Project: Dry Cow Creek Collection Date: 8/8/2006 2:30 PM 

Lab ID: S0608186-003 Date Received: 8/8/2006 5:17 PM 

Client Sample ID: Dry Cow Creek BCSR #4 Sampler: AS 

Matrix: Water 

Analyses Result PQL Qual Units Date Analyzed/Init Method 

General Parameters 

pH 9.45 0.01 s.u. 08/10/2006 2051 WO EPA 150.1 

Electrical Conductivity 6530 5 μmhos/cm 08/10/2006 2051 WO SM 2510B 

Total Dissolved Solids (180) 4410 5 mg/L 08/09/2006 1436 AF SM 2540 

Solids, Total Dissolved (Calc) 4000 10 mg/L 08/17/2006 1547 AO SM 1030F 

Alkalinity, Total (As CaCO3) ND 1 mg/L 08/10/2006 2051 WO SM 2320B 

Alkalinity, Total (As CaCO3) 3400 1 mg/L 08/16/2006 1200 WO SM 2320B 

Hardness, Calcium/Magnesium (As CaCO3) 90 10 mg/L 08/17/2006 1547 AO SM 2340B 

Sodium Adsorption Ratio 79.0 0.1 08/17/2006 1547 AO Calculation 

Anions 

Alkalinity, Bicarbonate as HCO3 2830 1 mg/L 08/16/2006 1200 WO SM 2320B 

Alkalinity, Carbonate as CO3 651 1 mg/L 08/16/2006 1200 WO SM 2320B 

Alkalinity, Carbonate as CO3 744 1 mg/L 08/10/2006 2051 WO SM 2320B 

Chloride 137 1 mg/L 08/09/2006 1352 LK EPA 300.0 

Fluoride 7.5 0.1 mg/L 08/10/2006 2051 WO SM 4500FC 

Sulfate 47 1 mg/L 08/09/2006 1352 LK EPA 300.0 

Cations 

Calcium 9 1 mg/L 08/10/2006 1233 AB EPA 200.7 

Magnesium 17 1 mg/L 08/10/2006 1233 AB EPA 200.7 

Potassium 13 1 mg/L 08/10/2006 1233 AB EPA 200.7 

Sodium 1740 1 mg/L 08/10/2006 1233 AB EPA 200.7 

Cation/Anion-Milliequivalents 

Bicarbonate as HCO3 46.35 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Carbonate as CO3 21.69 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Chloride 3.85 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Fluoride 0.39 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Sulfate 0.98 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Calcium 0.45 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Magnesium 1.37 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Potassium 0.33 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Sodium 75.68 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Cation / Anion Balance 

Cation Sum 77.85 0 meq/L 08/17/2006 1547 AO SM 1030F 

Anion Sum 73.28 0 meq/L 08/17/2006 1547 AO SM 1030F 

Cation-Anion Balance 3.02 0 % 08/17/2006 1547 AO SM 1030F 

These results apply only to the samples tested. 

Qualifiers: * Value exceeds Maximum Contaminant Level B Analyte detected in the associated Method Blank 

E Value above quantitation range H Holding times for preparation or analysis exceeded 

J Analyte detected below quantitation limits L Analyzed by a contract laboratory 

ND Not Detected at the Reporting Limit S Spike Recovery outside accepted recovery limits 

Patricia Quade, Project Manager 

Reviewed by: Page 4 of 5 
1673 Terra Avenue 

Sheridan, WY 82801 

Sample Analysis Report 

CLIENT: Bureau of Land Management Date Reported: 8/21/2006 

P. O. Box 2407 Report ID: S0608186001 

1300 North 3rd 

Rawlins, WY 82301 Work Order: S0608186 

Project: Dry Cow Creek Collection Date: 8/8/2006 3:10 PM 

Lab ID: S0608186-004 Date Received: 8/8/2006 5:17 PM 

Client Sample ID: Dry Cow Creek @ Confl Sampler: AS 

Matrix: Water 

Analyses Result PQL Qual Units Date Analyzed/Init Method 

General Parameters 

pH 9.53 0.01 s.u. 08/10/2006 2120 WO EPA 150.1 

Electrical Conductivity 7740 5 μmhos/cm 08/10/2006 2120 WO SM 2510B 

Total Dissolved Solids (180) 5400 5 mg/L 08/09/2006 1446 AF SM 2540 

Solids, Total Dissolved (Calc) 4970 10 mg/L 08/17/2006 1547 AO SM 1030F 

Alkalinity, Total (As CaCO3) ND 1 mg/L 08/10/2006 2120 WO SM 2320B 

Alkalinity, Total (As CaCO3) 4290 1 mg/L 08/16/2006 1200 WO SM 2320B 

Hardness, Calcium/Magnesium (As CaCO3) 100 10 mg/L 08/17/2006 1547 AO SM 2340B 

Sodium Adsorption Ratio 90.9 0.1 08/17/2006 1547 AO Calculation 

Anions 

Alkalinity, Bicarbonate as HCO3 3310 1 mg/L 08/16/2006 1200 WO SM 2320B 

Alkalinity, Carbonate as CO3 947 1 mg/L 08/16/2006 1200 WO SM 2320B 

Alkalinity, Carbonate as CO3 1010 1 mg/L 08/10/2006 2120 WO SM 2320B 

Chloride 157 1 mg/L 08/09/2006 1402 LK EPA 300.0 

Fluoride 8.9 0.1 mg/L 08/10/2006 2120 WO SM 4500FC 

Sulfate 117 1 mg/L 08/09/2006 1402 LK EPA 300.0 

Cations 

Calcium 8 1 mg/L 08/10/2006 1237 AB EPA 200.7 

Magnesium 19 1 mg/L 08/10/2006 1237 AB EPA 200.7 

Potassium 13 1 mg/L 08/10/2006 1237 AB EPA 200.7 

Sodium 2080 1 mg/L 08/10/2006 1237 AB EPA 200.7 

Cation/Anion-Milliequivalents 

Bicarbonate as HCO3 54.23 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Carbonate as CO3 31.55 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Chloride 4.43 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Fluoride 0.46 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Sulfate 2.44 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Calcium 0.39 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Magnesium 1.58 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Potassium 0.34 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Sodium 90.47 0.01 meq/L 08/17/2006 1547 AO SM 1030F 

Cation / Anion Balance 

Cation Sum 92.79 0 meq/L 08/17/2006 1547 AO SM 1030F 

Anion Sum 93.15 0 meq/L 08/17/2006 1547 AO SM 1030F 

Cation-Anion Balance 0.19 0 % 08/17/2006 1547 AO SM 1030F 

These results apply only to the samples tested. 

Qualifiers: * Value exceeds Maximum Contaminant Level B Analyte detected in the associated Method Blank 

E Value above quantitation range H Holding times for preparation or analysis exceeded 

J Analyte detected below quantitation limits L Analyzed by a contract laboratory 

ND Not Detected at the Reporting Limit S Spike Recovery outside accepted recovery limits 

Patricia Quade, Project Manager 

Reviewed by: Page 5 of 5