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: 29 December 2009 

SUBJECT: Notes from the 16th Annual International Petroleum & Biofuels 

Environmental Conference, 3 - 5 November 2009, Houston, TX (DCN 

07146)

 I participated in the 16th Annual International Petroleum Environmental & 

Biofuels Conference, 3 - 5 November 2009, Houston, TX.1 My presentation was titled, 

“Update on EPA’s Clean Water Act Review of the Coalbed Methane (CBM) Extraction 

Sector,” and is located in the record (see DCN 07147). The agenda for this conference is 

presented in Attachment A. 

 This memorandum highlights some of my notes from this conference. Table 1 

lists the conference presentations or abstracts in the record supporting the 2010 Effluent 

Guidelines Program Plan. In particular, I included presentations related to coalbed 

methane (CBM). I also included the Marcellus Shale gas development presentations on 

Wednesday, November 4th. The CBM sector was identified for additional review in the 

final 2006 and 2008 Effluent Guidelines Program Plans.2 Issues related to Marcellus 

shale gas development were identified by commenters to the final 2008 Plan. I also 

presented at the 14th IPEC (see DCN 05138, EPA-HQ-OW-2006-0771-0864). 

Conference Presentations

Fred Yarger: “A Hybrid Treatment Process for high TDS Oil-Field Produced 

Water” 

 Southeastern New Mexico produces 400 million barrel of produced water per year 

with Total Dissolved Solids (TDS) in the range of 200,000 mg/L. 

 Their target is to treat produced water at approximately $1/bbl. 

 

1

 See http://ipec.utulsa.edu/Conf2009/Agenda%2010-3-09/Agenda09.htm. 

2

 See 21 December 2006 (71 FR 76644) and 15 September 2008 (73 FR 53218). 
2

 Their technology is forward osmosis and their ultimate disposal for the treated 

produced water is beneficial use. 

 They use pretreatment to remove BTEX and TSS. 

Tor Pamgren: “Analytical Characteristics of Flowback Waters in the Field” 

 As the development of unconventional gas sources increases, larger amounts of 

fresh water are needed in fracturing operations and more flowback water is being 

produced. Water use in various gas shale plays is becoming an issue due to 

limited availability of water resources, transportation issues, contamination 

concerns and regulatory pressures. 

 Flowback waters are generally characterized by significant amounts of heavy 

metals, hardness, solids, salts, organic elements, polymers, biocides, and traces of 

oils. 

Kerry Sublette: “A New Generation of Tracers for Surface Water and 

Groundwater Flow” 

 This company has pioneered the manufacture and detection of DNA-based 

tracers. These new tracers are capable of tracking the source of pollution to a 

single point or assessing what proportion of waste comes from multiple 

geographic sources. 

 They have conducted multiple studies in Europe and are looking to bring the 

technology to the United States. 

Reza Mastouri: The Investigation of Induced Gas Flotation (IGF) Performance at 

Elevated Temperatures and High Total Dissolved Solids (TDS) Produced Water” 

 This study investigated treating produced water with temperatures in excess of 

212 o

F and 300,000 mg/L. 

 Kharg Island is responsible for approximately 90% of the oil exports from Iran. 

DeWitt Dees: “Managing Flowback and Produced Water” 

 His company, 212 Resources, is looking to find a market for the brine produced 

from treatment as a potential product. Currently they are using the produced brine 

as a kill fluid. 

 They operate in Texas, Wyoming, and are likely to expand into Pennsylvania 

(Marcellus Shale). They have a ‘Water Treatment Cost Calculator’ which may be 

helpful to operators in evaluating produced water treatment options. 
3

Robert S. Beard: “Obtaining Water to Develop Natural Gas Wells in the Marcellus 

Shale of Pennsylvania” 

 There are no approvals yet for Marcellus shale gas in the Delaware River Basin 

Commission district. 

 Operators are looking for multiple sources of water for fracture fluids. They are 

looking at mine pool water and POTW effluent. 

 There is no official process for treating re-using produced water from Marcellus 

shale gas development. 

Kayli Clements: “Drilling Fluids Chosen to Enhance the Development of Marcellus 

Shale” 

 Her company, M-I SWACO, predicts significant drilling in Pennsylvania as they 

predict there will be 130 rigs in Pennsylvania by 2015. 

 Her presentation shows the current disposal options for Marcellus shale gas 

drilling cuttings. 

Brent Halldorson: “Marcellus Shale Water Management” 

 Chesapeake and Devon are two of the biggest operators in the Marcellus Shale. 

 Mr. Halldorson estimates that between 10 to 40% of the water using in fracture 

operations comes back as flowback water (with 20% being the average 

percentage). 

 Mr. Halldorson’s company, Aqua Pure, is using Mechanical Vapor 

Recompression evaporator technology to treat Marcellus shale gas produced 

water. 

Ron Schlicher: “An Innovative Approach to Managing Produce Water and Frac 

Flowback in the Marcellus Shale Play” 

 Mr. Schlicher noted that Marcellus shale gas produced water contains benzene 

and other VOCs. He noted that these are naturally occurring in this formation. 

 His company is combining mine drainage with Marcellus shale flow back and 

produced water to reduce the TDS concentrations for treatment with membranes. 
4

Bill Hochheiser: “Lifecyle Water Management: Considerations and Challenges for 

Marcellus Shale Gas Development” 

 Mr. Hochheiser noted that some produced waters and facture waters from this 

formation are being disposed via truck and rail transport to Ohio underground 

injection wells. 

Matthew E. Mantell: “Deep Shale Natural Gas: Abundant, Affordable, and Water 

Efficient” 

 Mr. Mantell compared water usage between shale gas development and other 

energy sources (e.g., biofuels). 

Jörg E. Drewes: “Opportunities, Challenges, and Research Needs for Beneficial Use 

of CBM Produced Water” 

 The Colorado School of Mines (CSM) in collaboration with the Argonne National 

Laboratory (ANL) and the Kennedy/Jenks Consultants has launched a research 

program entitled, “An Integrated Framework for Treatment and Management of 

Produced Water.” 

 This work is funded by the Research Partnership to Secure Energy for America 

(RPSEA). 

John Veil: “Regulations and Impediments for Treatment and Beneficial Use of 

CBM Produced Water” 

 Mr. Veil is a contributing member of the CSM RPSEA project. His presentation 

focused on: (1) regulatory requirements affecting produced water management; 

(2) regulatory requirements affecting beneficial reuse; and (3) potential barriers.

Katharine Dahm: “Predicting Water Quality Variability to Design Treatment 

Processes for Beneficial Use” 

 CSM has conducted CBM produced water sampling to supplement its industry 

supplied data on CBM produced water. 

 Ms. Dahm noted that understanding water quality of CBM produced water is 

essential to the proper selection of treatment technologies and to facilitating 

greater beneficial use of CBM produced water. 

 The CSM produced water data is separated by CBM basin and coal formation. 

This database should be available by April 2010. 
5

Nathan Hancock: “Selection and Design of Integrated Treatment Processes for 

CBM Produced Water Purification” 

 This paper discussed CSM’s Treatment Module” for their forthcoming tool 

facilitating the beneficial use of CBM produced water. 

 His presentation discussed some of the technical challenges for deploying CBM 

produced water treatment, the target levels for different types of beneficial uses, 

and treatment technology issues (e.g., brine disposal). He noted that brines 

generated as a by-product of treatment can concentrate naturally occurring 

radionuclides. 

 Mr. Hancock described how his module would rate and rank different treatment 

technologies based on the user input for the amount and quality of the CBM 

produced water and the designated beneficial use. 

 In total, the CSM team reviewed 34 fundamental treatment technologies and 21 

integrated systems/processes against a number of different factors: 

o Commercial status of technology; 

o Feed and product water quality; 

o Removal efficiencies; 

o Recovery; 

o Infrastructure considerations; 

o Energy consumption; 

o Chemical demand; 

o Life cycle; and 

o O&M considerations. 

 Mr. Hancock noted that his module would also be ready in the Spring of 2010. 

Pei Xu: “Beneficial Use Options and Limitations of CBM Produced Water” 

 Ms. Xu discussed the main factors that affect choices of beneficial use options. 

These factors include: 

o Regulations and permitting; 

o Price of gas and disposal costs; 

o Produced water quality; 

o End users; 

o Costs of transportation and treatment; 

o Liability; and 

o Water rights. 

 Ms. Xu noted a number of beneficial use options for CBM produced water. These 

include: 

o Surface water discharge/instream flow augmentation; 

o Aquifer recharge, storage and recovery; 
6

o Agricultural use (Livestock watering, Crop irrigation); 

o Domestic/municipal (Potable use, Non-potable use); 

o Environmental restoration (Impoundments, Fisheries, Constructed 

wetlands). Ms. Xu noted that bicarbonate and selenium can concentrate in 

impoundments. 

o Industrial use during oil and gas production (Dust control, Hydraulic 

fracturing, Drilling operation). For example, produced water or brines with 

20,000 to 30,000 mg/L TDS concentrations can be used by operators for 

frac water. 

 Ms. Xu noted a number of challenges in implementing beneficial uses of CBM 

produced water. These included: 

o Transient Location (Distance between produced water sources and end 

users, High cost of water transportation and treatment) 

o Operational Issues (Sustainable water quantity, Fluctuating gas prices that 

might deter investments in treatment technology) 

o Complexity of water rights issues 

o Variation of environmental, water quality and permitting requirements 

among states 

o Challenges in identifying, quantifying, mitigating, and compensating 

impacted third parties 

o Uncertainties and liability issues regarding conveyance and end use 

o Barriers between private management of gas and oil resources and the 

public management of water resources. 

 Ms. Xu concluded her presentation by noting that there is a great opportunity for 

beneficial use of produced water for a variety of applications. She also noted that 

the quality and quantity of produced water is highly variable spatially and 

temporally to meet beneficial use requirements. She stated a need to overcome 

operational, economic and institutional barriers. 

Jean Debroux: “An Integrated Framework for Treatment and Management of 

CBM Produced Water – A Microsoft Excel©-based Tool to Help Bring Producers 

and Beneficial Users Together” 

 Mr. Debroux gave an overview of the CSM CBM tool and how it can be used by 

multiple stakeholders. The tool is comprised of three parts: 1) Water Quality 

module, 2) Treatment Technology Selection module, and 3) Key Elements 

modules. [Note: See previous CSM presentations.] 

 Mr. Debroux gave the range of the tool’s costs as being between -30% and +50%, 

which is sufficient for most scoping and planning needs. 

 He noted that the tool that allows producers, potential beneficial users, and 

various other stakeholders to identify the technical, logistical, regulatory, legal, 

and other institutional issues that can inhibit the beneficial use of produced water. 
7

 Mr. Debroux noted that due to these institutional issues, a traditional linear 

problem-solving framework is not ideal for assisting energy companies and the 

water industry to develop beneficial use partnerships. 

 In contrast, the CSM CBM Tool uses a bi-directional, or “matchmaking”, 

approach. This approach allows the stakeholders to consider the institutional 

complexity and the economic viability of multiple beneficial uses, either locally 

or outside of the basin and/or state. 

 This framework also identifies the participation of third parties, or “brokers”, if 

needed, to help resolve key institutional issues, uncertainties and risk. The 

completed tool will allow a stakeholder to use the first two modules 

independently or use the overall tool, which entails the three modules interacting 

with each other. 

Tzahi Cath: “Emerging Treatment Processes for CBM Produced Water 

Purification” 

 Mr. Cath noted some of the requirements for CBM produced water treatment 

technologies. These include: 

o High recovery & high rejection of contaminants; 

o Robustness and self sufficiency; 

o Low-maintenance; and 

o Modular (small footprint, minimal environmental disturbance). 

 During the technology review, several novel technologies were identified that 

might be appropriate and utilized for treatment of CBM produced water 

 Some of these technologies can utilize resources already existing in the field and 

may treat water at reduced O&M costs. These technologies included: 

o Low Pressure Membrane Water Softening; 

o Distillation Through Membranes; 

o Vacuum Enhanced Membrane Distillation 

o Osmotically-driven Membrane Processes 

o Electrodialysis (ED) and Electrodialysis Reversal (EDR) 

o Capacitive Deionization Technology (CDT) 

o Vibratory Shear Enhanced Membrane Filtration (VSEP) 

o Ceramic Ultrafiltration and Nanofiltration 

o Near ZLD and ZLD Technology Summary (AltelaRain, Crystallizer, SALPROC (Geo-Processors USA)) 

o High Efficiency Reverse Osmosis (limited to 20,000 mg/L TDS). 

 He noted that many novel and improved processes are emerging and that site 

specific conditions will dictate the type of suitable technologies. Mr. Cath noted 
8

that the CSM team will both lab and field scale demonstrations of some of these 

technologies. 

Tzahi Cath: “CBM Produced Water Treatment and Beneficial Use Information 

Center: A New Website” 

 The CSM CBM tool and supporting documentation will be available on a 

dedicated website. 

 Beta version of the website will be completed by February 2010. 

 Internal review (including input from IAC and SAC members) will be completed 

by March 2010. 

 The website will be uploaded and available to the public by May 2010 

James Welch: “Coalbed Methane Produced Water – An Evolution in Treatment” 

 Mr. Welch discussed the pretreatment evolution for the reverse osmosis/ recovery 

reverse osmosis process (RO/RRO), treating produced water from Powder River 

Basin coalbed methane wells. 

 The reverse osmosis/recovery reverse osmosis design (RO/RRO) used at the 

Mitchell Draw plant is permitted through the Wyoming DEQ’s Chapter 3 process, 

which requires review and monitoring by WYDEQ. 

 The Mitchell Draw plant optimizes costs by maximizing system recovery using 

pretreatment techniques and an aeration pond for evaporating and concentrating 

the brine. 

 The plant design includes a bypass and blend provisions so that the plant can ratio 

blend the product water according to discharge specifications. 

 The plant maximizes membrane performance with filtration and scale control. 

 Mr. Welch noted the importance of controlling silica (Si). The Mitchell Draw 

plant was designed to handle Si concentrations at 10 ppm or less. However, the 

actual water quality influent ranged from 8 to 12 ppm. His company used antiscalants to allow the membrane filters to treat the CBM produced water with 

concentrations of Si greater than 10 ppm. They used approximately 20 gallons per 

day of acid to control calcium scaling as well. 
9

 Mr. Welch noted the importance of monitoring the Langelier Saturation Index 

(LSI) of the CBM produced water.3

David Cameron: “CBNG Produced Water Reservoir Reclamation Strategies in the 

Powder River Basin of Wyoming” 

 Mr. Cameron noted that unlined reservoirs are commonly used for produced water 

management in the Powder River Basin. 

 Capacities typically range from 5 to over 100 acre-feet. He noted that there are 

over 4,000 permitted CBNG reservoirs in the PRB. 

 In 2009 Wyoming DEQ issued guidance for reclamation and bonding on-channel 

CBM reservoirs (non-federal surface). Main issues included: 

o Bonding for new reservoirs; 

o WYPDES permit renewal; 

o Soil salvage requirements; and 

o Soil testing requirements. 

 Mr. Cameron noted that soil sampling should be conducted to support 

development of reclamation strategies. 

 Mr. Cameron noted that there are several reservoir reclamation options that 

include: 

o Complete embankment removal and reclamation (Restore /stabilize 

channel bottom) 

o Partial removal and reclamation (Minimize area to be reclaimed) 

o Remain for beneficial use (stock watering) 

 

3

 LSI is a calculated value is used to predict the calcium carbonate stability of water; that is, whether water 

will precipitate, dissolve, or be in equilibrium with calcium carbonate. The LSI is expressed as the 

difference between the actual system pH and the saturation pH. If the actual pH of the water is below the 

calculated saturation pH, the LSI is negative and the water has a very limited scaling potential. If the actual 

pH exceeds the saturation pH, the LSI is positive, and being supersaturated with CaCO3, the water has a 

tendency to form scale. At increasing positive index values, the scaling potential increases. 
Table 1: IPEC 2009 Presentations in the Record Supporting the 2010 Plan Including the 

Coalbed Methane Detailed Study (EPA-HQ-OW-2008-0517) 

No. Authors Title Date 

Presented DCN 

1 Fred Yarger A Hybrid Treatment Process for high TDS Oil-Field Produced Water 11/3/09 07148

2 Tor Pamgren Analytical Characteristics of Flowback Waters in the Field 11/4/09 07149

3 Kerry Sublette A New Generation of Tracers for Surface Water and Groundwater Flow 11/4/09 07150

4 Reza Mastouri The Investigation of Induced Gas Flotation (IGF) Performance at Elevated 

Temperatures and High Total Dissolved Solids (TDS) Produced Water 11/4/09 07151

5 DeWitt Dees Managing Flowback and Produced Water 11/4/09 07152

6 Robert S. Beard Obtaining Water to Develop Natural Gas Wells in the Marcellus Shale of 

Pennsylvania 11/4/09 07153

7 Kayli Clements Drilling Fluids Chosen to Enhance the Development of Marcellus Shale 11/4/09 07154

8 Brent Halldorson Marcellus Shale Water Management 11/4/09 07155

9 Ron Schlicher An Innovative Approach to Managing Produce Water and Frac Flowback in the 

Marcellus Shale Play 11/4/09 07156

10 Bill Hochheiser Lifecyle Water Management: Considerations and Challenges for Marcellus Shale 

Gas Development 11/4/09 07157

11 Matthew E. 

Mantell Deep Shale Natural Gas: Abundant, Affordable, and Water Efficient 11/4/09 07158

12 Jörg E. Drewes Opportunities, Challenges, and Research Needs for Beneficial Use of CBM 

Produced Water 11/5/09 07159

13 John Veil Regulations and Impediments for Treatment and Beneficial Use of CBM 

Produced Water 11/5/09 07160

14 Katharine Dahm Predicting Water Quality Variability to Design Treatment Processes for Beneficial 

Use 11/5/09 07161

15 Nathan Hancock Selection and Design of Integrated Treatment Processes for CBM Produced Water 

Purification 11/5/09 07162

16 Pei Xu Beneficial Use Options and Limitations of CBM Produced Water 11/5/09 07163

17 Jean Debroux 

An Integrated Framework for Treatment and Management of CBM Produced 

Water – A Microsoft Excel©-based Tool to Help Bring Producers and Beneficial 

Users Together 

11/5/09 07164

18 Tzahi Cath Emerging Treatment Processes for CBM Produced Water Purification 11/5/09 07165

19 Tzahi Cath CBM Produced Water Treatment and Beneficial Use Information Center: A New 

Website 11/5/09 07166

20 James Welch Coalbed Methane Produced Water – An Evolution in Treatment 11/5/09 07167

21 David Cameron CBNG Produced Water Reservoir Reclamation Strategies in the Powder River 

Basin of Wyoming 11/5/09 07168

22 Carey Johnston Update on EPA’s Clean Water Act Review of the Coalbed Methane (CBM) 

Extraction Sector 11/5/09 07169
11

Attachment A: Agenda for 16th Annual International Petroleum & Biofuels 

Environmental Conference, 3 – 5 November 2009 Houston, TX.