1

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: 17 September 2010

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

Group Regarding the Reclamation of Produced Water A ssociated with Coalbed

Methane Production

The Produced Water Development Group, U.S. Environm ental Protection Agency (EPA), U.S. Geological Service (USGS), Department of Energ y (DOE), and members from a National Academies panel 1 participated in a teleconference on 19 February 20 09 to discuss the beneficial use potential for coalbed me thane extraction (CBM) produced water. Representatives of the Produced Water Develo pment Group briefed meeting participants on current water reclamation projects and discussed the implementation of the produced water program authorized by Congress l ast year. Attachment 1 at the end of this memorandum lists the meeting participants. Att achment 2 is the handout from Produced Water Development Group. The meeting is su mmarized below:

1. The Produced Water Development Group is trying to g et support for demonstration projects in the Colorado Front Range and the Colorado River Basin. Three demonstration projects have been ident ified with two along the Front Range and one along the Little Snake River in the C olorado River Basin. The produced water associated with the CBM production i n 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 re source 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 s urface 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 wa ter 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 que stion was posed as to whether all CBM can be generalized as not being connected t o surface waters. Mr.

1 The National Academies panel is titled, “Managemen t and Effects of Coalbed Methane Development and

Produced Water in the Western United States.” See http://www8.nationalacademies.org/cp/CommitteeView. aspx?key=48996.2 Steward noted that the connectivity to surface wate r 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 i ts early stages so there is still time to change how production is done. He also stat ed that the largest barrier for CBM producers is pumping out the water to release t he 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 i ssue. 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 pro duced 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, eac h basin would have to be looked at separately.

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

withdrawals. It was answered that this would be som ething to monitor during water pumping. 3

6. Mr. Carey Johnston, EPA, asked the question what ar e the stumbling blocks for the use of CBM produced water. Mr. Stewart responde d that operators identify liability and legal issues as limiting the benefici al 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 Geoc hemistry, Volume 22, Issue 10, October 2007, Pages 2240-2256.

3 Ed Note: The following discussion elaborates on th e potential for land subsidence due to oil and gas development. “One of the most compelling examples o f subsidence resulting from oil and gas extraction involves the Wilmington oil field in Long Beach, Ca lifornia. Since the 1930s, more than 1,000 wells withdrew about 2.5 billion bbl of oil and a large v olume 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 fiel d caused extensive damage to Long Beach port industrial and naval facilities. A massive repressu rization program, based on the injection of water i nto the oil reservoirs, reduced the subsidence area from ap proximately 50 km2 to 8 km2. Approximately 2.3 bill ion bbl of water were reinjected through 1969.” Source Testimony of John Veil, Argonne National Laboratory Before The House Committee On Science And Technolog y Subcommittee On Energy And Environment Concerning: “Research To Improve Water-Use Efficien cy And Conservation: Technologies And Practice” OCTOBER 30, 2007, Available at: http://www.ead.anl. gov/pub/doc/testimony_veil_final.pdf

4 EPA, 2007. “Minutes for the Southern Ute Meeting i n Ignacio, Colorado (24 October 2007).” Available from http://www.regulations.gov, Document ID: EPA-H Q-OW-2006-0771-0911.3

7. Mr. Johnston asked about the treatment systems for produced water. Mr. Stewart noted that since CBM wells are spread out over larg e areas, treatment units would

have to be mobile and scalable. He stated that thei r 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. St ewart also noted that there is interest in creating useable products from the trea tment residuals (e.g., brine).

8. The meeting participants raised the possibility of convening another meeting between interested stakeholders (e.g., Department o f the Interior/Bureau of Reclamation, DOE, EPA, and NAS) due to the interest in CBM produced water beneficial use options. The Produced Water Developm ent Group offered to share any updates about their proposed beneficial use pil ot projects at any future meetings.4 ATTACHMENT 1

List of Participants Produced Water Development Meeting (EPA Headquarter s)

19 February 2009

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

Katie Bradshaw PG Environmental

(EPA Contractor) 703-707-8258 katie.bradshaw@pgenv.com5 ATTACHMENT 2

Produced Water Development Group Handout Produced Water Development Meeting (EPA Headquarter s)

19 February 2009