### MEMORANDUM

TO: Public Record for the 2010 E ffluent 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 Intern ational 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 abstract s in the record suppor ting the 2010 Effluent Guidelines Program Plan. In particular, I included presentations related to coalbed methane (CBM). I also included the Marce llus Shale gas development presentations on Wednesday, November 4 th . 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 co mmenters to the final 2008 Plan. I also presented at the 14 th IPEC (see DCN 05138, EPA-HQ-OW-2006-0771-0864).

Conference Presentations

Fred Yarger: “A Hybrid Treatment Pro cess for high TDS Oil-Field Produced Water”

 Southeastern New Mexico produces 400 milli on barrel of produced water per year with Total Dissolved Solids (T DS) 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) an d 15 September 2008 (73 FR 53218).2  Their technology is forward osmosis and th eir 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 opera tions and more flowback water is being produced. Water use in various gas shal e plays is becoming an issue due to limited availability of water resources , transportation issues, contamination concerns and regulatory pressures.

 Flowback waters are gene rally characterized by significant amounts of heavy metals, hardness, solids, salts, organic elem ents, polymers, biocides, and traces of oils.

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

 This company has pioneered the manuf acture and detection of DNA-based tracers. These new tracers are capable of tracking the source of pollution to a single point or assessing what propor tion 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 Indu ced Gas Flotation (IGF) Performance at Elevated Temperatures and High Total Di ssolved Solids (TDS) Produced Water”

 This study investigated treat ing produced water with te mperatures in excess of 212 o F and 300,000 mg/L.

 Kharg Island is responsible for approxima tely 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. Cu rrently they are using the produced brine as a kill fluid.

 They operate in Texas, Wyoming, and ar e 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 De velop 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 wate r and POTW effluent.

 There is no official process for treati ng 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 signifi cant drilling in Pennsylvania as they predict there will be 130 rigs in Pennsylvania by 2015.

 Her presentation shows the current dis posal 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 Pu re, 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 shal e 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 concentr ations for treatment with membranes.4 Bill Hochheiser: “Lifecyle Water Manageme nt: 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 Natura l Gas: Abundant, Affordable, and Water Efficient”

 Mr. Mantell compared water usage betw een 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 C onsultants has launched a research program entitled, “An Integrated Framework for Treatment and Management of Produced Water.”

 This work is funded by the Research Pa rtnership to Secure Energy for America (RPSEA).

John Veil: “Regulations a nd 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 bene ficial reuse; and (3) potential barriers.

Katharine Dahm: “Predicting Water Qualit y Variability to Design Treatment Processes for Beneficial Use”

 CSM has conducted CBM produced water sa mpling to supplement its industry supplied data on CBM produced water.

 Ms. Dahm noted that understanding wa ter quality of CBM produced water is essential to the proper selection of tr eatment technologies and to facilitating greater beneficial use of CBM produced water.

 The CSM produced water data is separa ted 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 us e 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., br ine disposal). He noted that brines generated as a by-product of treatment can concentr ate naturally occurring radionuclides.

 Mr. Hancock described how his module woul d rate and rank different treatment technologies based on the user input fo r the amount and quality of the CBM produced water and the desi gnated beneficial use.

 In total, the CSM team reviewed 34 f undamental treatment technologies and 21 integrated systems/processes agains t 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 woul d 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 a ffect 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 us e 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 (Impoundme nts, Fisheries, Constructed wetlands). Ms. Xu noted that bicarbona te and selenium can concentrate in impoundments.

o Industrial use during oil and gas production (Dust control, Hydraulic fracturing, Drilling operation). For exampl e, 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 betwee n 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 noti ng that there is a great opportunity for beneficial use of produced water for a vari ety of applications. She also noted that the quality and quantity of produced wate r is highly variable spatially and temporally to meet beneficial use requi rements. She stated a need to overcome operational, economic and institutional barriers.

Jean Debroux: “An Integrated Framew ork 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 overvi ew of the CSM CBM tool and how it can be used by multiple stakeholders. The tool is compri sed of three parts: 1) Water Quality module, 2) Treatment Technology Selec tion 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 pr oducers, potential bene ficial users, and various other stakeholders to identify th e technical, logisti cal, regulatory, legal, and other institutional issues that can inhibi t the beneficial use of produced water.7  Mr. Debroux noted that due to these in stitutional issues, a traditional linear problem-solving framework is not ideal for assisting energy companies and the water industry to develop bene ficial use partnerships.

 In contrast, the CSM CBM Tool uses a bi-directional, or “matchmaking”, approach. This approach allows the stak eholders 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 participa tion of third parties, or “brokers”, if needed, to help resolve key institutional issues, uncertainties and risk. The completed tool will allow a stakehol der to use the first two modules independently or use the ove rall tool, which entails th e three modules interacting with each other.

Tzahi Cath: “Emerging Treatment Processes for CBM Produced Water Purification”

 Mr. Cath noted some of the requirem ents 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, minima l environmental disturbance).

 During the technology review, several nove l technologies were identified that might be appropriate and utilized fo r treatment of CBM produced water

 Some of these technologies can utilize re sources already existing in the field and may treat water at reduced O&M co sts. 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 Elect rodialysis Reversal (EDR)

o Capacitive Deioniza tion 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 Osmosi s (limited to 20,000 mg/L TDS).

 He noted that many novel and improved pr ocesses are emerging and that site specific conditions will dictate the type of suitable technologies. Mr. Cath noted8 that the CSM team will both lab and field scale demonstrations of some of these technologies.

Tzahi Cath: “CBM Produced Water Treatme nt 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 evol ution for the reverse osmosis/ recovery reverse osmosis process (R O/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 cost s by maximizing system recovery using pretreatment techniques and an aerati on pond for evaporating and concentrating the brine.

 The plant design includes a bypass and blend pr ovisions 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 cont rolling silica (Si). The Mitchell Draw plant was designed to handle Si concentra tions at 10 ppm or less. However, the actual water quality influent ranged from8 to 12 ppm. His company used antiscalants to allow the membrane filters to treat the CBM produced water with concentrations of Si greate r 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 m onitoring the Langelier Saturation Index (LSI) of the CBM produced water. 3

David Cameron: “CBNG Produced Water Res ervoir Reclamation Strategies in the Powder River Basin of Wyoming”

 Mr. Cameron noted that unlined reservoi rs are commonly used for produced water management in the Powder River Basin.

 Capacities typically range from 5 to ove r 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 su rface). 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 samp ling should be conducted to support development of reclamation strategies.

 Mr. Cameron noted that there are severa l 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 calci um carbonate stability of wate r; that is, whether water will precipitate, dissolve, or be in equilibrium w ith calcium carbonate. The LSI is expressed as the difference between the actual system pH and the satura tion pH. If the actual pH of the water is below the calculated saturation pH, the LSI is negative and the wate r has a very limited scaling potential. If the actual pH exceeds the saturation pH, the LSI is po sitive, and being supersaturated with CaCO 3 , the water has a tendency to form scale. At increasing positive index values, the scaling potential increases.Table 1: IPEC 2009 Presentations in the R ecord Supporting the 2010 Plan Including the Coalbed Methane Detailed St udy (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 Fl owback 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 Flot ation (IGF) Performance at Elevated Temperatures and High Total Diss olved 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, Afford able, 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 Benefi cial Use Informati on 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 Re view of the Coalbed Methane (CBM) Extraction Sector 11/5/09 0716911 Attachment A: Agenda for 16th Annual International Petr oleum & Biofuels Environmental Conference, 3 – 5 November 2009 Houston, TX.