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MEMORANDUM

TO: Public Record for the 2010 Effluent Guidelines Program Plan EPA Docket Number EPA-HQ-OW-2008-0517 (www.regula tions.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 (COG 840000)

The U.S. Environmental Protection Agency (EPA) held a teleconference with Mr. Gary Beers of Colorado’s Department of Public Health and Environm ent (CDPHE) Water Quality Control Division (WQCD), on 29 January 2010 to discuss deta ils 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 Gener al 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 4 35) to control pollutants discharged in CBM produced water. Participants are included in Table 1.

Mr. Beers provided an overview of the development o f WQCD’s General NPDES Permit for Produced Water Treatment Facilities (COG840000). In formation 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 Color ado that utilizes advanced treatment to reduce Total Dissolved Solids (TDS) concentratio ns in the produced water discharged to surface waters. From the current operator, deta iled 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 ec onomic analysis of disposal alternatives (i.e., injection, advanced treatment, pollutant tra ding 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 techn ologies and provided cost information

will be set to EPA.

• New treatment and disposal facilities are being bui lt 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.,2 evaporation lagoons), several are complex facilitie s that accept many types of E&P wastes for treatment/recovery and re-sale to oil an d gas operations. The information provided by these proponents/operators to WQCD in a nticipation 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 t o 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 di scharge 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 fa cilities. For example, Mr. Beers noted that there are approximately 8 discharge permits for ope rators in the Raton CBM basin (near Trinidad, CO). Among the pollutants controlled in these permi ts is sodium. Mr. Beers also noted that one CBM operator has discharged very high volumes of pr oduced 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 E PA.

Mr. Beers noted that some rural communities west of the small town of Walsenberg (North of Trinidad, Colorado) have seen groundwater levels dr op by hundreds of feet and the water from several rural water wells have dangerously high le vels 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 effe cts of oil and gas extraction. The best sources

of additional information on this issue are: the Co lorado Oil and Gas Conservation Commission, the Petroglyph Operating Company, and some of the r esidents in the vicinity of Walsenburg.

Finally, Mr. Beers noted that he has observed a dis connect 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 pro perly 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 Publ ic Health and Environment 29 January 2010

Name Organization Phone Number Email Carey Johnston EPA/OW 202-566-1014 johnston.carey@e pa.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