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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: 17 September 2010 

SUBJECT: Notes from 19 February 2009 Meeting with the Produced Water Development 

Group Regarding the Reclamation of Produced Water Associated with Coalbed 

Methane Production 

The Produced Water Development Group, U.S. Environmental Protection Agency (EPA), 

U.S. Geological Service (USGS), Department of Energy (DOE), and members from a 

National Academies panel1 participated in a teleconference on 19 February 2009 to 

discuss the beneficial use potential for coalbed methane extraction (CBM) produced 

water. Representatives of the Produced Water Development Group briefed meeting 

participants on current water reclamation projects and discussed the implementation of 

the produced water program authorized by Congress last year. Attachment 1 at the end of 

this memorandum lists the meeting participants. Attachment 2 is the handout from 

Produced Water Development Group. The meeting is summarized below: 

1. The Produced Water Development Group is trying to get support for 

demonstration projects in the Colorado Front Range and the Colorado River 

Basin. Three demonstration projects have been identified with two along the Front 

Range and one along the Little Snake River in the Colorado River Basin. The 

produced water associated with the CBM production in this area has the potential 

to be a 1,000 year water resource if the pumping of water continues after the 

energy production is done. This additional water resource has the potential to help 

in areas where water is in short supply. 

2. Mr. Mark Engle, USGS, asked whether there were any studies regarding the 

potential connectivity between produced water and surface water for the 

demonstration projects. Mr. David Stewart, Stewart Environmental Consultants, 

noted that they used geologic analyses to show that the CBM water is not 

connected to the surface. He also noted that the water being brought to surface 

was dated to be millions of years old, which means that the produced water is not 

likely connected to surface waters. A follow-up question was posed as to whether 

all CBM can be generalized as not being connected to surface waters. Mr. 

 

1

 The National Academies panel is titled, “Management and Effects of Coalbed Methane Development and 

Produced Water in the Western United States.” See 

http://www8.nationalacademies.org/cp/CommitteeView.aspx?key=48996. 
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Steward noted that the connectivity to surface water will have to be determined 

for each basin. There is potential for there to be some connectivity, but an 

individual study of the particular basin would have to be conducted. 

3. Mr. Stewart noted that CBM production is still in its early stages so there is still 

time to change how production is done. He also stated that the largest barrier for 

CBM producers is pumping out the water to release the CBM and then reinjecting the water underground. Furthermore, some CBM producers are 

constrained by the volume of water that they can re-inject. Therefore, it is a 

benefit to the CBM producers to address the water issue. Mr. Stewart also noted 

that at this point CBM producers are most concerned about what kind of liability 

they would have discharging to a surface water that is used as reclaimed water. 

4. Mr. Engle, USGS, asked whether organic constituents in CBM produced water 

could limit some beneficial use options for CBM produced water. Mr. Engle 

referenced a USGS paper on this issue.2

 Mr. Stewart replied that produced water 

that is being re-injected is meeting standards more strict than drinking water 

standards. He noted that the major issues with CBM produced water tend to be 

microbiology and dissolved inorganics. However, each basin would have to be 

looked at separately. 

5. Mr. Engle also asked about the potential for subsidence due to produced water 

withdrawals. It was answered that this would be something to monitor during 

water pumping.3

6. Mr. Carey Johnston, EPA, asked the question what are the stumbling blocks for 

the use of CBM produced water. Mr. Stewart responded that operators identify 

liability and legal issues as limiting the beneficial use of produced water. In 

particular, each state has a different set of rules for water rights, which can 

complicate the potential re-use of produced water. Mr. Johnston noted that EPA 

heard similar concerns during its last set of site visits.4

 

2

 Orem, William, et al., 2007. “Organic compounds in produced waters from coalbed natural gas wells in 

the Powder River Basin, Wyoming, USA.” Applied Geochemistry, Volume 22, Issue 10, October 2007, 

Pages 2240-2256. 

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 Ed Note: The following discussion elaborates on the potential for land subsidence due to oil and gas 

development. “One of the most compelling examples of subsidence resulting from oil and gas extraction 

involves the Wilmington oil field in Long Beach, California. Since the 1930s, more than 1,000 wells 

withdrew about 2.5 billion bbl of oil and a large volume of produced water. Between the1940s and the 

1960s, this field experienced a total of 29 feet of subsidence, caused primarily by the withdrawal of 

hydrocarbons. Subsidence in the Wilmington oil field caused extensive damage to Long Beach port 

industrial and naval facilities. A massive repressurization program, based on the injection of water into the 

oil reservoirs, reduced the subsidence area from approximately 50 km2 to 8 km2. Approximately 2.3 billion 

bbl of water were reinjected through 1969.” Source Testimony of John Veil, Argonne National Laboratory

Before The House Committee On Science And Technology Subcommittee On Energy And Environment 

Concerning: “Research To Improve Water-Use Efficiency And Conservation: Technologies And Practice” 

OCTOBER 30, 2007, Available at: http://www.ead.anl.gov/pub/doc/testimony_veil_final.pdf 

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 EPA, 2007. “Minutes for the Southern Ute Meeting in Ignacio, Colorado (24 October 2007).” Available 

from http://www.regulations.gov, Document ID: EPA-HQ-OW-2006-0771-0911. 
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7. Mr. Johnston asked about the treatment systems for produced water. Mr. Stewart 

noted that since CBM wells are spread out over large areas, treatment units would 

have to be mobile and scalable. He stated that their treatment systems will process 

anywhere from 0.5 to 5 million gallons per day (mgd) and may include ultraviolet 

(UV) and ion exchange treatment. He noted that the produced water could be 

piped or trucked to their treatment systems. Mr. Stewart also noted that there is 

interest in creating useable products from the treatment residuals (e.g., brine). 

8. The meeting participants raised the possibility of convening another meeting 

between interested stakeholders (e.g., Department of the Interior/Bureau of 

Reclamation, DOE, EPA, and NAS) due to the interest in CBM produced water 

beneficial use options. The Produced Water Development Group offered to share 

any updates about their proposed beneficial use pilot projects at any future 

meetings. 
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ATTACHMENT 1 

List of Participants 

Produced Water Development Meeting (EPA Headquarters) 

19 February 2009 

Name Organization Phone Number Email 

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

Tom Born EPA/OW 202-566-1001 born.tom@epa.gov 

Elizabeth Eide National Research Council EEide@nas.edu 

Ann S. Maest Stratus Consulting Inc. 

David Stewart Stewart Environmental 

Consultants dave.stewart@stewartenv.com 

Richard Kraus 

Greenwood Village, CO, 

Produced Water 

Development 

 richardckraus@msn.com 

Pat O’Toole Savery, WY, Family Farm 

Alliance h2otoole@gmail.com 

Lynn M. Takaichi Kennedy/Jenks 

Consultants LynnTakaichi@KennedyJenks.com 

Mark A. Limbaugh The Ferguson Group mlimbaugh@tfgnet.com 

Via Phone

Mark Engle USGS engle@usgs.gov 

Natenna Dobson DOE Natenna.Dobson@hq.doe.gov 

Susan Gregersen DOE Susan.Gregerson@hq.doe.gov 

James W. Bauder Montana State University jbauder@montana.edu 

Katie Bradshaw PG Environmental 

(EPA Contractor) 703-707-8258 katie.bradshaw@pgenv.com 
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ATTACHMENT 2 

Produced Water Development Group Handout 

Produced Water Development Meeting (EPA Headquarters) 

19 February 2009