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MEMORANDUM 

TO: Public Record for the 2010 Effluent Guidelines Program Plan 

 EPA Docket Number EPA-HQ-OW-2008-0517 (www.regulations.gov) 

FROM: Carey A. Johnston, P.E. 

USEPA/OW/OST 

ph: (202) 566 1014 

johnston.carey@epa.gov 

DATE: 27 July 2010 

SUBJECT: Notes from 29 January 2010 Teleconference with Gary Beers, Colorado 

Department of Public Health and Environment, on the Colorado General NPDES 

Permit for Produced Water Treatment Facilities (COG840000) 

The U.S. Environmental Protection Agency (EPA) held a teleconference with Mr. Gary Beers of 

Colorado’s Department of Public Health and Environment (CDPHE) Water Quality Control 

Division (WQCD), on 29 January 2010 to discuss details of WQCD’s General NPDES Permit for 

Produced Water Treatment Facilities (COG840000). Mr. Beers is Unit Manager for the WQCD’s 

Groundwater, Land Application, and Industrial General Permits Unit. 

EPA identified the coalbed methane (CBM) extraction sector as a candidate for a detailed study 

in the final 2006 Effluent Guidelines Program Plan. EPA is conducting this review to determine if 

it would be appropriate to conduct a rulemaking to revise the effluent guidelines for the Oil and 

Gas Extraction Point Source Category (40 CFR part 435) to control pollutants discharged in CBM 

produced water. Participants are included in Table 1. 

Mr. Beers provided an overview of the development of WQCD’s General NPDES Permit for 

Produced Water Treatment Facilities (COG840000). Information and produced water data used to 

develop this general permit will be shared with EPA and includes the following: 

• A small-scale CBM operation exists in western Colorado that utilizes advanced treatment 

to reduce Total Dissolved Solids (TDS) concentrations in the produced water discharged 

to surface waters. From the current operator, detailed information is available on the 

treatment process, as well as chemical profiles for the influent and effluent during a 

multi-year period. From an earlier operator, an economic analysis of disposal alternatives 

(i.e., injection, advanced treatment, pollutant trading with agricultural discharger) is 

available. This information, along with permitting documents, will be provided to EPA. 

• WQCD has issued approximately 3 to 6 permits where advanced treatment is applied to 

produced waters before discharge to surface waters. Discussions were held with 

developers and manufacturers of these technologies with a focus on performance and 

general costs. The information on the various technologies and provided cost information 

will be set to EPA. 

• New treatment and disposal facilities are being built or planned for oil and gas produced 

water in Colorado with locations near the major oil and gas fields (primarily in northwest 

Colorado and northwest of Denver). While some are traditional disposal facilities (i.e., 
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evaporation lagoons), several are complex facilities that accept many types of E&P 

wastes for treatment/recovery and re-sale to oil and gas operations. The information 

provided by these proponents/operators to WQCD in anticipation of applying for 

discharge permits will be sent to EPA. 

• The operator of a very large CBM field in southern Colorado has implemented a program 

of watershed monitoring upstream and downstream of produced water discharges. This 

innovative effort includes providing field access to agricultural irrigators for real-time 

data at monitoring stations and providing acquired monitoring data through a dedicated 

website for public access. The recent renewal of discharge permits for this CBM 

operation includes the watershed monitoring effort. The WQCD information on this 

watershed monitoring effort as well as photographs will be sent to EPA. 

Mr. Beers noted that WQCD has issued approximately 10 to 20 different discharge permits that 

regulated discharges from oil and gas extraction facilities. For example, Mr. Beers noted that 

there are approximately 8 discharge permits for operators in the Raton CBM basin (near Trinidad, 

CO). Among the pollutants controlled in these permits is sodium. Mr. Beers also noted that one 

CBM operator has discharged very high volumes of produced water (4 to 8 million gallons a day) 

for several years with discharges to dry arroyos. The list of WQCD issued individual and general 

permits to oil and gas facilities will be sent to EPA. 

Mr. Beers noted that some rural communities west of the small town of Walsenberg (North of 

Trinidad, Colorado) have seen groundwater levels drop by hundreds of feet and the water from 

several rural water wells have dangerously high levels of methane gas. Some of these locations 

are within CBM fields with active production wells. Mr. Beers noted that this explains why this 

community is focused on the potential negative effects of oil and gas extraction. The best sources 

of additional information on this issue are: the Colorado Oil and Gas Conservation Commission, 

the Petroglyph Operating Company, and some of the residents in the vicinity of Walsenburg. 

Finally, Mr. Beers noted that he has observed a disconnect between Colorado oil and gas 

operators in the field and their corporate officers. It is his observation that corporate officers 

provide little support to field staff on how to properly manage this wastewater and often delegate 

important management decisions to field staff. The result is a less than coordinated approach to 

managing CBM produced water. 

TABLE 1 

List of Participants 

EPA Teleconference with Colorado Department of Public Health and Environment 

29 January 2010 

Name Organization Phone Number Email 

Carey Johnston EPA/OW 202-566-1014 johnston.carey@epa.gov 

Gary Beers EPA/OW 303-692-3524 gary.beers@state.co.us 

Paul Hanson PG Environmental 

(EPA Contractor) 303 279-1778 paul.hanson@pgenv.com