SANDIA REPORT 

SAND2006-0312 

Unlimited Release 

Printed January 2006 

Technical Review of Proposed Changes 

in Montana Water Quality Standards for 

Coal Bed Natural Gas Produced Water 

Allan R. Sattler, Malynda A. Aragon, M. Michael Hightower 

Prepared by

Sandia National Laboratories

Albuquerque, New Mexico 87185 and Livermore, California 94550 

Sandia is a multiprogram laboratory operated by Sandia Corporation, 

a Lockheed Martin Company, for the United States Department of Energy’s 

National Nuclear Security Administration under Contract DE-AC04-94AL85000. 

Approved for public release; further dissemination unlimited. 

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SAND2006-0312 

Unlimited Release 

Printed January 2006 

TECHNICAL REVIEW OF PROPOSED CHANGES IN 

MONTANA WATER QUALITY STANDARDS FOR 

COAL BED NATURAL GAS PRODUCED WATER 

Allan Sattler

Geotechnology and Engineering Department 

Malynda Aragon 

Geochemistry Department 

Mike Hightower 

Energy Systems Analysis Department 

Sandia National Laboratories 

P.O. Box 5800 

Albuquerque, New Mexico 

January 2006 

ABSTRACT

In November 2005, the United States Department of Energy requested that Sandia National 

Laboratories provide a technical review and evaluation of proposed changes in the Montana Water 

Quality Standards related to Coal Bed Natural Gas produced water treatment and discharge. The goal 

of Sandia’s technical evaluation was to assist the Department of Energy in understanding the technical 

feasibility and costs associated with meeting the proposed standards and the potential impact on coal 

bed natural gas production in the region and impacts on natural gas production and supplies nationally.

This report summarizes the results of the Sandia review of the proposed standards, with a focus on the 

technical issues associated with coal bed natural gas produced water reinjection and treatment. Based

on our review, there appear concerns with the proposed new standards. These concerns include

inconsistencies in treated water constituent standards, identification of treatment standards for arsenic 

and other constituents that are not currently attainable, lack of the use of EPA recommended methods 

to assess innovative treatment technology cost and performance impacts, limitations on the use of

commonly recognized alternative water management options, and identification of water treatment 

levels that will make the treated water highly reactive and negatively impact use for irrigation and 

wildlife. The results of the Sandia review and the technical evaluations of various parts of the 

proposed standards are summarized in this report. 

 3 
ACKNOWLEDGEMENTS 

The authors received technical, programmatic, and editorial support on this project from a number of 

individuals and organizations both inside and outside Sandia. We would particularly like to express 

our thanks for their support and guidance in the technical evaluations and development of this report. 

To support the technical analysis required for this project, the authors worked with many

organizations, including industry and state and federal agencies to collect background information on

current operations, existing regulations, and technical data. 

The following organizations were especially helpful in supporting our efforts, including: 

Bureau of Land Management – Miles City Office 

Wyoming Oil and Gas Commission 

Montana Board of Oil and Gas Conservation 

Montana Bureau of Mines and Geology 

ALL Consulting – Tulsa Oklahoma 

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CONTENTS

ACRONYMS .............................................................................................................................................. 6 

 1. EXECUTIVE SUMMARY ................................................................................................................... 7 

 2. INTRODUCTION AND PURPOSE .................................................................................................... 10 

 3. PROPOSAL TO IDENTIFY SAR AND EC AS HARMFUL ................................................................ 12 

4. PROPOSAL TO REQUIRE INJECTION OF CBNG PRODUCED WATER ...................................... 13 

5. PROPOSED CBNG PRODUCED WATER TREATMENT AND DISCHARGE STANDARDS.......... 23 

6. PROPOSED LIMITS ON CBNG PRODUCED WATER MANAGEMENT OPTIONS........................ 30 

 7. CONCLUSIONS................................................................................................................................. 31 

 

REFERENCES .......................................................................................................................................... 49 

APPENDIX A - PROPOSED CHANGES TO MONTANA WATER QUALITY REGULATIONS............. 33 

 

LIST OF FIGURES

Figure 1. General Geologic Cross-section of the Powder River Basin ................................................... 14 

Figure 2. Soil Infiltration Impact based on SAR and Salinity ................................................................... 27 

Figure 3. Crop Yield and Irrigation Water Salinity ................................................................................... 29 

 

LIST OF TABLES

Table 1. Electrical Conductivity Ranges for Various Water Uses............................................................. 12

Table 2. Typical Geologic Formation Depths of the Powder River Basin of Montana ............................. 15 

Table 3. Comparions of Common Water Quality Standards with the Proposed Montana CBNG

Treatment Standards................................................................................................................. 24 

Table 4. General Livestock Water Quality Requirements......................................................................... 26 

Table 5. Estimated PRB CBNG Produced Water Treatment Costs ......................................................... 28 

 

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LIST OF ACRONYMS 

BER Board of Environmental Review 

CBNG Coal bed natural gas 

cm Centimeter

DOE Department of Energy 

dS/m Deci-Siemens per meter 

EC Electrical conductivity 

EPA United States Environmental Protection Agency 

L Liter 

M meter 

mg Milligrams

mg/L milligrams per liter 

MT Montana 

NETL National Energy Technology Laboratory 

NPRC Northern Plains Research Council 

PRB Powder River Basin – Wyoming and Montana 

S Siemens

SAR Sodium abruption ration 

TDS Total dissolved solids 

WY Wyoming 

μS/cm micro Siemens per centimeter 

$K Thousand dollars 

$M Million dollars 

 6 
1. EXECUTIVE SUMMARY 

In September 2005, the Montana Board of Environmental Review announced proposed 

changes to the Montana Water Quality Regulations related to Coal Bed Natural Gas produced 

water treatment and discharge. The proposed regulations, if adopted in their current form, 

could significantly impact and possibly reduce CBNG development and production in 

Montana. The impact could also extend to CBNG production in other states, such as 

Wyoming, through greater restrictions on CBNG produced water quality. 

The U. S. Department of Energy (DOE) reviewed the proposed changes and believed that 

they could significantly restrict CBNG production in Montana and Wyoming. To aid in the 

evaluation and assessment of the proposed changes, the DOE requested that both Argonne 

National Laboratory (Argonne) and Sandia National Laboratories (Sandia) review the 

proposed changes and prepare written evaluations on various technical, policy, and regulatory 

aspects. Argonne focused on regulatory and policy issues and their interrelationships with 

technology, and Sandia focused on major technical issues associated with the proposed water 

treatment requirements and the engineering, hydrologic, and geologic technical issues 

associated with the produced water discharge aspects of the proposed changes. 

This report represents Sandia’s review, observations, and assessments. The main themes of 

these comments address the technical issues associated with: 

• The proposal to identify sodium adsorption ratio (SAR) and electrical conductivity 

(EC), measures of normal ionic constituents in all surface and ground water, as 

harmful parameters. 

• The proposal to limit CBNG produced water disposal to shallow reinjection unless the 

reinjection is shown to be infeasible. 

• The proposed strict treatment and discharge standards; the potential impact of these 

limits on the environment and ecology; and the maturity, performance, and cost 

effectiveness of technologies to meet the proposed effluent discharge standards. 

• The proposal to limit the exemption for CBNG produced water reinjection or 

treatment to only livestock watering, neglecting other innovative or beneficial water 

management approaches and technologies. 

The rationale presented for making the proposed changes to the water quality regulations does 

not appear to adequately address the severe technical and cost challenges associated with the 

proposed changes nor the impacts the proposed changes could have on use of the produced 

could have on wildlife and irrigation. 

Based on our reviewed of both the proposal and the petition outlining the rationale for the 

proposed changes our evaluations include: 

• Electrical Conductivity (EC) and the Sodium Adsorption Ratio are not harmful 

 7 
parameters as the proposal relates. These parameters are used to describe chemical 

properties of any water and both EC and SAR provide a metric to help identify general 

overall water quality. EC and SAR can be used to identify safe levels, intermediate 

levels, and undesirable levels of water quality, but themselves are not harmful 

parameters or constituents. In reality, some level of chemical ions in a water are 

actually considered beneficial for human, plant, and wildlife uses.

• There appear to be limited systematic and successful approaches to reinjection into 

coal seams or injection into other formations of CBNG produced water in the Powder 

River Basin. Geology and other geotechnical factors severely limit injection options. 

The success rate of establishing reinjection wells based on today’s available data is 

less that 30%.

 

• As written, the proposed waiver from zero discharge (Proposed New Rule III) process 

will be an extreme burden on both developers submitting the requests and the 

regulatory agencies having to review the numerous requests, which could severely 

curtail CBNG development and production. 

There were several major technical and environmental issues with the proposed produced 

water effluent treatment limits. These include: 

• Inconsistent effluent treatment levels for various parameters, especially for Ca, Mg, 

and Na, 

• Water effluent levels that are far below commonly accepted water quality standards, 

especially for As, Ca, Mg, and Na, 

• The proposed produced water treatment levels will create an effluent water quality that 

could negatively impact both aquatic species and irrigation, 

• Identification of proposed treatment technologies that have not been fully 

demonstrated to meet the proposed effluent guidelines consistently in operational 

settings across the range of produced water qualities in the region following EPA 

recommended technology cost and performance verification guidelines, and 

 

• The lack of consideration of the waste treatment costs and environmental impacts that 

could be generated from handling and moving the waste streams from the proposed 

water treatment processes.

Additionally, the proposed rule changes limit the use of innovative produced water 

management technologies. With only an exemption for CBNG water used for livestock 

watering, no other management options are permitted for CBNG produced water in the 

proposed changes. This limits several common produced management options and 

approaches and emerging approaches that might be applied in an environmentally sound and 

cost effective manner and reduce the use if fresh water resources. The issues identified 

include: 

 8 
• The proposed restrictions effectively preclude the direct use of CBNG water without 

treatment for many beneficial purposes. The CBNG produced water quality in the 

PRB is appropriate for a number of applications with either little or no treatment. 

Some approaches have been used with CBNG produced water to provide affordable 

produced water management to operators while providing direct benefits to 

landowners. For example, managed water treatment and use for irrigation has proven 

successful in several Powder River Basin applications. 

• Operators, land owners, and land management agencies may be interested in other 

uses of this produced water for a range of other applications including recreational 

opportunities, irrigation, oilfield make up water, electrical power generations, and use 

of water for other industrial or domestic applications to offset fresh water demands. 

• The proposed provision also restricts the use of emerging innovative technologies that 

could be used to manage CBNG produced water in an environmentally and 

ecologically sound manner. 

Overall, the proposed changes are inconsistent with the common understanding of water 

quality requirements for treating slightly impaired brackish surface or ground water, as exists 

with the CBNG produced water in the Powder River Basin, to meet various uses and 

applications. With minor adjustments of water quality, much of the CBNG produced water in 

the Powder River Basin can be used for a number of beneficial purposes. 

 9 
2. INTRODUCTION AND PURPOSE 

In May 2005, a group of petitioners led by the Northern Plains Resource Council (NPRC) 

submitted a petition to revise water quality requirements to the Montana Board of

Environmental Review (BER). Under Montana law, the BER had to consider the petition and 

either reject it or propose it as a new regulation. In September 2005, the BER announced 

proposed changes to the Montana water quality regulations. The proposal, which is presented 

in Appendix A of this report, included almost the exact language found in the petition and was 

directed toward discharges of water from coal bed natural gas (CBNG) production. The key 

elements of the proposal included: 

1. The Sodium Adsorption Ratio (SAR) and Electrical Conductivity (EC) would be 

reclassified as “harmful parameters,” thereby greatly restricting the ability for CBNG 

discharges to be allowed under Montana’s nondegradation regulations. 

2. The Montana water quality standards for the SAR and EC would be evaluated using 

the 7Q10 flow (lowest 7-consecutive-day flow in a ten-year period) rather than a 

monthly flow that is currently used. 

3. No discharges of CBNG water are allowed to Montana surface waters unless operators 

can demonstrate that injection to aquifers with the potential for later recovery of the 

water is not feasible. Producers would be required to provide extensive injected water 

rate and transport modeling, geologic evaluation data, and pump test data on aquifers 

and confining layers to prove injection was unfeasible. 

4. When operators can demonstrate the injection is not feasible, the CBNG water to be

discharged must meet very strict discharge limits for multiple constituents. 

The proposed regulations, if adopted in their current form, could significantly impact and 

reduce CBNG development and production in Montana. The impact also extends to 

Wyoming CBNG production through much greater restrictions on water quality that must be 

met at the interstate border. 

One of the U.S. Department of Energy’s (DOE’s) missions is to ensure an abundant supply of 

affordable energy for the nation. One way in which DOE supports that mission is to evaluate 

proposed federal and state regulatory actions that would restrict or impede energy production 

to assess whether the environmental or other benefits of those actions are commensurate with 

the energy impacts. DOE’s National Energy Technology Laboratory (NETL) reviewed the 

BER proposal and believed that the proposal could significantly restrict CBNG production in 

Montana and Wyoming. To aid in the review of the proposal, DOE asked two other national 

laboratories – Argonne National Laboratory (Argonne) and Sandia National Laboratories 

(Sandia) – to prepare written evaluations on various aspects of the proposal. Argonne focused 

on regulatory and policy issues and their interrelationships with technology, and Sandia 

focused on the major technical issues associated with the proposed water treatment 

requirements and the engineering, hydrologic, and geologic technical issues associated with 

the zero discharge aspects of the proposal. 

 10 
This report represents Sandia’s review and observations. The main themes of these comments 

address the technical issues associated with: 

• The proposal to identify sodium adsorption ratio (SAR) and electrical conductivity 

(EC), measures of normal ionic constituents in all surface and ground water, as 

harmful parameters. 

• The proposal to limit CBNG produced water disposal to shallow reinjection unless the 

reinjection is shown to be infeasible. 

• The proposed very strict treatment and discharge standards; the potential impact of 

these limits on the environment and ecology; and the maturity, performance, and cost 

effectiveness of technologies to meet the proposed effluent discharge standards. 

• The proposal to limit the exemption for CBNG produced water reinjection or 

treatment to only livestock watering, neglecting other innovative or beneficial water 

management approaches and technologies. 

The rationale presented for making the proposed changes does not adequately address the 

severe technical issues and challenges associated with the proposed changes. We have

reviewed both the proposal and the petition outlining the rationale for the changes. Each of 

the sections discusses in detail the major technical issues that have been identified in both the 

proposal and the background information in the petition. These themes will be discussed 

sequentially. 

 11 
3. PROPOSAL TO IDENTIFY SAR AND EC AS HARMFUL

One of the revisions included in the proposal is classifying the Sodium Adsorption Ratio 

(SAR) and Electrical Conductivity (EC) as undesirable substances with deleterious properties. 

The proposed language reads: 

17.30.670 NUMERIC STANDARDS FOR ELECTRICAL CONDUCTIVITY (EC) AND 

SODIUM ADSORPTION RATIO (SAR)

(1) through (5) remain the same. 

(6) EC and SAR are harmful parameters for the purposes of the Montana Water 

Quality Act, Title 75, chapter 5, MCA.

EC and SAR are measures of the chemical characteristics of water. They provide information 

on the level of the quantity of total dissolved solids (TDS) or salts such as calcium, sodium, 

chloride, sulfates, carbonates, and other salts in a water sample (Israelsen 1950). All natural 

waters contain ions, salts, and TDS and the parameters EC and SAR are used to identify the 

level and ratio of dissolved salts in water. EC is simply a measure of the total amount of 

dissolved salts or salinity in a water sample. It does not measure a specific chemical 

substance that could be construed as harmful. SAR is a ratio of the levels of sodium, calcium, 

and magnesium dissolved in a water sample. 

Both EC and SAR provide a metric to help identify general overall water quality. Like most 

other water quality parameters, lower levels of EC and SAR suggest higher quality water and 

high levels suggest that the water can begin to pose a risk to aquatic life, humans, plants, 

and/or soils. In other words, EC and SAR can be used to identify safe levels, intermediate 

levels, and undesirable levels of water quality, but themselves are not harmful parameters. 

Table 1 lists general water quality data showing the level of EC considered beneficial and the 

levels considered detrimental for a few general water use applications taken from several 

sources including (Israelsen 1950)(Batmanghelidj 1995)(EPA 2005). 

 

Table 1. Electrical Conductivity Ranges for Various Water Uses 

Application EC, μS/cm 

Beneficial Level Limitations on Use 

Drinking water 200-400 >1600 

Irrigation Water 200-3000 > 3000 

Livestock Water1 500 - 3000 > 5000 - 6000 

Fresh water Aquatic 

Species 

Up to 5000 > 8000-10000 

1

Water quality parameters for most livestock is summarized here and in more detail in Table 4

Therefore, from a technical perspective, EC as shown above is indicative of water quality, but 

very low to zero levels of EC are not necessarily the most beneficial level for water quality. 

Therefore, water with moderate EC and SAR levels are common and necessary for good 

water quality and should not be identified as harmful parameters as suggested in the proposal. 

Very low levels of EC and SAR could lead to infiltration problems, and potentially not 

provide the nutrients for both crops and aquatic life. 

 12 
4. PROPOSAL TO REQUIRE INJECTION OF CBNG 

PRODUCED WATER

Proposed New Rule II requires zero discharge of CBNG produced water and directs that the 

water be re-injected to a suitable geologic formation. It appears that the requirement to reinject is based on the desire to keep water in the aquifers from which it came or at least in 

other nearby aquifers from which it could be recovered later for beneficial uses. The 

proposed language reads: 

NEW RULE II ZERO DISCHARGE REQUIREMENT

(1) Except as provided in [New Rules III through IX], point sources of methane 

wastewater shall achieve zero discharge of pollutants, which represent s the 

minimum technology-based requirement. Zero discharge shall be accomplished 

by reinjection of methane wastewater into suitable geologic formations in the 

project area in compliance with all other applicable federal and state laws and 

regulations.

The technical issues and challenges of reinjection of Montana’s CBNG produced water into 

the same or another coal seam, or injection of the produced water into another receiving 

formation in the Powder River Basin (PRB) are discussed below. CBNG produced water is a 

valuable resource with relatively low TDS compared to waters of many naturally saline inland 

formations. Opportunities to save such a resource are important. The material presented in 

the following sections and certain cited references strongly suggest that reinjection of CBNG 

produced water into the coal seam being produced, as a rule, is not a reasonable option. 

The Fort Union Formation (Rice et al 2001; Arthur et al 2005, Pritchett 2002) as shown in 

Figure 1 and presented in Table 2, contains all the water producing coal beds in the Montana 

PRB (MBMG 2001). In the Montana portion of the PRB the bulk of the coals are confined to 

the Tongue River Member of the Fort Union Formation. The Lobo and Tullock members are 

predominantly shale and shaley-sand (McLellan et al, 1990). 

The following reinjection /injection schemes are potentially possible and were considered: 

• Simultaneous reinjection into the same coal seam that is being produced, 

• Simultaneous multiple coal seam production vs. sequential production and reinjection

into vertically stacked coal seams, 

• Reinjection into under-pressurized or non-productive coal seams, 

• Injection into sandstones within the Fort Union formation and the formations above 

the Fort Union formation, and 

• Other injection considerations. 

The technical issues and concerns associated with produced water injection or coal seam

reinjection options for each scheme are discussed. Additionally, the chemical compatibility 

between CBNG produced water and the waters of the receiving formation/aquifer are 

discussed. 

 13 
Simultaneous Reinjection into the Coal Seam That is being Produced 

Simultaneous reinjection of CBNG produced water into the coal seam that is being produced 

is not a reasonable option. Reinjection of CBNG produced water into the same coal seam that 

is being produced would be an ideal solution if it is feasible from an operational and technical 

basis. It would allow secure geologic storage of this valuable produced water in the aquifer 

from where it came, ideally matching with the remaining waters in that coal seam, and “put 

things back where they were.” In most instances such an option is difficult in practice from

an operational and process viewpoint, and may be unwise from a resource management 

viewpoint. It may have potentially negative environmental consequences. 

 Figure 1. General Geologic Cross Section of the Powder River Basin (Rice 2000) 

 

 14 
Table 2. Typical Geologic Formation Depths in the Powder River Basin of Montana 

Formation Approximate Formation 

Depth in feet 

Wasatch Sands, Quaternary Alluvium <500 

Fort Union ~50-2500 

Lance, Fox Hills ~2500-4000 

Paleozoic Carbonates ~10,000-14,000 

Production of CBNG typically requires a reduction in the hydrostatic pressure. This is 

accomplished by producing water from the coal seam. Reinjection would require raising the 

hydrostatic pressure. This would directly impair production. Simultaneous injection 

and withdrawal from the same coal seam is analogous to emptying and filling a bucket at the 

same time.

A tendency has been noted for some coal seams to compact during the lowering of the 

hydrostatic pressure of the coal seam with subsequent degasification of the coal seam (Palmer 

and Varzi, 2004). This could impair the original water storage ability of the original coal 

seam implying attendant higher pressures necessary to re-inject into a seam whose storage 

capacity has been reduced by compaction. Attempts to re-inject produced water then would 

have the potential of hydrofracturing outside the coal seam resulting in water migration

outside the injection zone, an unintended result and a potentially serious situation. Exceeding 

the fracture pressure is generally prohibited under EPA’s Underground Injection Control 

program (EPA, 2002). The tendency to compact may vary from coal seam to coal seam. 

More research is necessary to determine which coal seams are more or less prone to 

compaction. 

It has been estimated that 50% of the natural gas reserves are recoverable by present methods. 

Enhanced recovery methods such as CO2 injection are possibilities that could be considered in 

future years. (Cox, 2001; ORNL, 2002). If the coal seam is first produced and the CBNG 

produced water is held on the surface in a holding pond, and then later reinjected into that 

same, now depleted, seam, the possibilities of enhanced recovery can be lost or significantly 

impaired. This is more of a sequenced scenario which will be detailed more in the subsequent 

section. 

An Environmental Impact Statement (BLM 2003) relating in part to CBNG produced water in 

the Powder River Basin, written by the Bureau of Land Management (Miles City and Billings, 

Montana Field Offices), the Montana Board of Oil and Gas Conservation and the Montana 

Department of Environmental Quality mentions injection, treatment, impoundment, and 

discharge as options for handling CBNG produced water as disposal options in the preferred 

alternative. In this same EIS, Page 2-3, however, it specifically states that reinjection in the 

same coal seam being produced is not a suitable option. 

 15 
Simultaneous Multiple Coal Seam Production vs. Sequential Production and Reinjection 

into Stacked Coal Seams

Simultaneous multiple coal seam production is more efficient and economically preferable to 

sequential production and reinjection into stacked coal seams. It allows exploitation of thin 

coal seams, disturbs the land surface less because it is more efficient, and it avoids potential 

leaseholder complications. When producible seams are stacked, the possibility exists to 

produce one seam and draw its hydrostatic pressure down and then produce a second seam

above or below it and re-inject the water into the first seam that is called sequenced coal seam

production. This option may appear desirable as water from the coal seams is placed back in 

coal seams. (In this scenario, the water from the first seam produced would have to be 

impounded in a holding pond or handled in some other manner). Before such a step by step 

production reinjection operation should be ventured, efforts should be first made to ascertain 

the geologic/hydrologic isolation of such coal seams from each other. 

In practice there are several drawbacks to sequenced production from a resource extraction 

management and conservation perspective, also from an economic and environmental 

perspective. The utilization of the CBNG resource of the thinner coal seams could require 

extraction in a simultaneous production mode, as extraction of the CBNG from thin seams on 

an individual basis could be unattractive economically. The simultaneous production rather 

than sequenced production of the coal seams would normally be more efficient from a cost 

and operational point of view. Any injection from sequenced production/reinjection could 

impair possible future extraction of the remaining gas resource, is more expensive, and would 

keep the extraction operation on the land for a longer period of time with the attendant surface 

disturbance. 

The storage capacity of the receiving, produced coal seam would have to be reinvestigated in 

each case. Production can alter the storage capacity of a given seam as described in the 

previous section. The sequential production mode could also be a cause for leaseholder 

concern and complications. Lease ownership often resembles a checkerboard between 

federal, state, and private holders. Unless the production sequence of these individual seams is 

coordinated among different holders, draw-down possibilities across lease boundaries could 

create concerns. 

The above referenced EIS encourages multiple seam completions from the same well as 

technology permits. Multiple seam completions from the same well would create less 

attendant land disturbance. Otherwise, Montana resource managers and oversight agencies 

have shown no additional preference in the EIS between simultaneous multiple seam

production and staggered coal seam production. In the record of decision the Montana Board 

of Oil and Gas and the BLM both restated no preference for sequential vs. simultaneous 

production of stacked seams (BLM 2003a) (MBOGC 2003). 

 16 
Reinjection into Under-pressurized or Non Productive Coal Seams 

Reinjection into an under-pressurized coal seam could be potentially environmentally harmful 

if the seam has no hydraulic seal. Injection into a naturally under-pressurized coal seam is 

another possibility to handle produced CBNG water. Under-pressurized coal seams, if 

geotechnically suitable, would be a good option for handling CBNG produced water. 

However, such an under-pressurized coal seam may be under-pressurized for a reason, 

specifically the lack of a hydraulic seal. As such, an under-pressurized seam may be caused 

by a number of reasons. These could include the outcropping of the seam into a stream or 

spring or elsewhere. Faulting and fracturing can impair the seam’s ability to hold pressure 

and water. Injection into such a seam has the potential to lead to potential unintended release 

of injected water. Standard reservoir tests in such a situation may not give a complete 

geologic/hydraulic picture of the under-pressurized coal seam. 

It should be mentioned that there are a series of under-pressurized coal seams in the Wyoming 

portion of the Powder River Basin. A preliminary account of this feature has been given by 

Geoff Thyne at the Petroleum Environmental Research Forum (Thyne, 2005). The data is 

presently being synthesized and analyzed at Stanford University. The geologic circumstances 

of such potential sources for reinjection are not yet fully understood. 

Whether an analogy of this Wyoming Powder River Basin system exists in the Montana 

Powder River Basin is as yet unknown. As more data from Montana coal seams is 

accumulated, the existence or non existence of such an analogous system will become known. 

If a Montana analogy exists, the detailed geologic settings of such seams must still be 

determined to find out whether such systems would be suitable for CBNG produced water 

reinjection. 

The above referenced EIS mentions the possibility of injection into non-productive coal 

seams but does not elaborate. 

Injection into Sandstones within the Fort Union Formation and the Formations above 

the Fort Union Formation 

The geology of the shallow Fort Union and overlying sand formations generally make 

reinjection possibilities limited. The sandstones of the Fort Union Formation (~50-2500 ft) 

are terrestrial (Arthur et al, 2005) in nature; the sandstones are not continuous and are 

relatively small. The chances of finding suitable sandstones in these formations that can take 

the required volumes of water are quite small. Many of these sandstones in the Fort Union 

adjoining the coals are also water saturated and as a rule these sandstones are less extensive 

than the coal seams. Attempts to inject in such situations could entail relatively high injection 

pressures with a diminished chance of injecting reasonable amounts of CBNG produced 

water. On a general basis injection into these formations is difficult but this has been done in 

a few cases (Likwartz, 2005). 

The Montana Bureau of Mines and Geology very recently began investigating and 

documenting large channel sands in the Lower Tongue River Member (~50-500 ft) of the Fort 

 17 
Union Formation. These individual sands may be extensive individually, but generally are 

not laterally continuous, rather more compartmentalized (John Wheaton and David Lopez, 

2005). 

Lower saturation and less injection pressure may exist in the sands overlying the Fort Union 

Formation, or in the Wasatch Sands/Quaternary Alluvium (<500ft). These sands are also 

terrestrial in nature. Well logs could be examined to determine the vertical extent of such 

Wasatch sands. Models exist to make estimates of the lateral extent of any lenticular sands 

seen on the logs based on sedimentalogical principles. Widespread existence of such 

unsaturated sands, extensive enough to be an adequate injection target in this 

sedimentological environment is not the rule. However there may be some instances where 

such suitable injection sands overlying the Fort Union Formation Coals could exist. 

Fluid Compatibility 

The compatibility of CBNG produced water being re-injected back into the original formation 

or injected into another formation/aquifer needs to be considered in each case. The CBNG 

produced water injection must be chemically compatible with the receiving formation and 

generally should have no adverse effect on the water quality of the injected formation. The 

design of any reinjection system into a given formation/receiving aquifer should account for 

possible vertical and horizontal variations of the water chemistry. When CBNG produced 

water is brought to the surface, carbon dioxide and methane can be released, and the pH can 

rise. The chemistry of the water can be altered, and it may become aerated. A determination 

should be made to see that the altered state of the produced water brought to the surface for 

later reinjection is compatible with the original water chemistry before reinjection. 

Treatment of the produced water prior to injection or reinjection may improve its 

compatibility with the receiving formation. Any concentrate resulting from such treatment 

would have to be handled separately however, such as injection into a class I or II injection 

well. Moreover the treatment/handling of any concentrate disposal will add significantly to 

operation costs, 

Success Rate of Drilling Injection Wells 

The overall success rate of establishing successful reinjection wells is quite limited. Ample 

statistics on the success rates of injection wells are not available on either side of the 

Wyoming/Montana Powder River Basin. Some preliminary data was provided on the similar 

Wyoming Powder River Basin formations by the Wyoming Oil and Gas Commission 

(Likwartz, 2005). Forty four (44) injection wells were actually drilled. Among these 44 wells 

there were 24 in the Fort Union, 4 in the Fox Hills 1 in the Lantz/Fox Hills Formations. Of 

these only 12 were in operation after one year. The accumulated injection of these wells 

accounts for only about 2% of the current Wyoming CBNG produced water. 

Commonly, an injection well is expected to function for about four years. While injection 

may seem to be a desirable way of handling the CBNG produced water, the available data 

indicate that the success of a given injection well venture cannot be guaranteed in the geologic 

 18 
formations available in the Power River Basin region. Failures mean additional expense and 

land disturbance and injection wells can be expensive. Completed well costs in the shallow 

Fort Union Formation can be in the one hundred fifty thousand dollar range depending on 

depth while those drilling costs in the Lance/Fox Hills Formation can range around one 

million dollars. Unfortunately, the success ratio of disposal wells at these shallower depths 

has been limited, driving up overall produced water injection costs. An injection well in the 

Paleozoic Carbonates of the Powder River Basin at depths ~12,000 ft, drilled today, would 

cost in the neighborhood of five and one half million dollars, completed, with surface 

facilities. Dry hole drilling costs would comprise approximately 50% of the costs, completion 

30%, and surface facilities just under 20%. 

Conclusions on the Technical Feasibility of CBNG Produced Water Reinjection as the 

Primary Water Management Option 

Reinjection of CBNG produced water into the coal seam being produced as a rule is not a 

reasonable option. The above referenced EIS, prepared by Montana resource managers and 

oversight agencies concur with this conclusion 

Sequential production and reinjection of stacked coal seams is less efficient than simultaneous 

coal seam production. It is not preferable economically; especially if relatively thin coal 

seams are involved. The EIS prepared by the three above agencies encourages multiple seam

production technology but otherwise shows no preference on which extraction mode should 

be utilized. Sequential production has the potential of causing leaseholder complications. 

The storage capacity of one or more of the produced seams may be altered during production. 

The desirability of reinjection into an under-pressurized coal seam depends largely on 

whether that coal seam has an adequate hydraulic seal. However, the fact that the seam is 

under-pressured may be an indication that the hydraulic seal is inadequate and could allow 

injected water to flow into other formations, streams, or springs. 

The geology of the shallow Fort Union and overlying sand formations generally make 

reinjection possibilities in those formations limited. 

There appear to be limited systematic and successful approaches to reinjection into coal seams 

or injection into other formations of CBNG produced water in the Powder River Basin. 

Geology and other geotechnical factors limit options. These options must be considered on a 

case-by case basis. Nonetheless, when successful, reinjection or injection would at least in 

principle preserve the produced water for future use. 

While some reinjection in the Montana and Wyoming Powder River Basins is feasible, the 

overall success is limited. The success rate, based on today’s available data is less than 30%. 

The results of these 44 wells drilled indicate reinjection or injection options are generally 

limited in the Powder River Basin. Thus the proposed regulations would require roughly 

three injection wells drilled for one successful injection well with very substantial 

environmental disturbance in the form of surface disturbance, air emissions, noise, and

vehicle traffic. 

 19 
While produced water injection may be feasible in other geologic settings across the western 

oil and gas producing states, produced water injection must be considered on a case by case 

basis and feasibility will be controlled by water and gas volumes per well, infrastructure 

requirements, produced water quality, and regional geology. In some regional settings in 

Montana, injection will be feasible, but in most cases produced water injection opportunities 

currently appear to be geologically limited. It is therefore technically inappropriate, based on 

the current understanding of the subsurface geology, to identify injection as the primary 

disposal option for CBNG produced water in Montana. 

Waivers for CBNG Produced Water Injection 

New Rule III recognizes that there may not be suitable geologic formations available to 

receive some or all of the water to be injected. It allows operators to apply for a waiver under 

those circumstances. The proposed language reads: 

NEW RULE III WAIVER FROM ZERO DISCHARGE REQUIREMENT 

(1) The department may grant a waiver from the zero discharge requirement if the 

owner or operator of a point source discharge of coal bed methane wastewater 

demonstrates by clear and convincing evidence to the department through site specific 

studies that the requirement is not technically feasible because estimated wastewater 

production rates exceed the estimated cumulative reinjection rates of all suitable 

geologic formations in the project area. 

(2) The department shall limit the waiver to the volume of methane wastewater for 

which the owner or operator shows that zero discharge is not technically feasible. The 

volume of methane wastewater for which the department grants a waiver from the 

zero discharge requirement shall be limited to the difference between estimated 

wastewater production rates and the estimated cumulative reinjection rates for all 

suitable geologic formation in the project area. 

(3) The department may limit the waiver to the initial phases of development when the 

volume of methane wastewater produced by wells is highest, which may make 

reinjection of all such water technically unfeasible. 

(4) The department may also grant a waiver from the zero discharge requirement if 

the EPA will not authorize the reinjection pursuant to a permit under the Safe 

Drinking Water Act (SDWA), 42 USC 300f to 300j-26(5). The operator shall attain 

zero discharge for the volume of methane wastewater for which the department does 

not grant a waiver. 

New Rule IV outlines the information that must be provided in the waiver application. 

NEW RULE IV INFORMATIONAL REQUIREMENTS FOR WAIVER 

DETERMINATION (1) An owner or operator requesting a waiver from the zero 

discharge requirement for coal bed methane wastewater shall submit an application 

to the department for the department to make a determination on whether to grant the 

waiver. 

(2) The application shall include, but is not limited to, the following: 

 20 
(a) a description and map of the coal bed methane project and project area 

showing the location of wells, pipelines, roads, compressors, and related 

infrastructure; 

(b) a description of the surface owners in the project area; 

(c) an estimate of pumping rates for coal bed methane wells in the target coal 

seams and an estimate of the volume of wastewater likely to be produced per 

well per year; 

(d) for each targeted coal seam, data showing areas characterized by high 

concentrations of vertical fractures where wastewater production wells may be 

higher; 

(e) an inventory and map of geologic formations, aquifers, and confining 

layers including significant fractures, fissures, and faults within the project 

area. The following information is required for each geologic formation and 

aquifer in the project area: 

(i) lateral extent, thickness, and depth. Maps and cross sections indicating the 

vertical and lateral limits of each formation; 

(ii) hydraulic properties including, but not limited to, transmissivity, storage 

coefficient, effective porosity, and hydraulic conductivity. The results of pump 

tests, analysis of core samples, and other geophysical studies; 

(iii) water quality characterization including the geochemical compatibility of 

the receiving aquifer minerals with methane wastewater; 

(f) an inventory and map of the locations of natural recharge in the project 

area and near the reinjection location; 

(g) an inventory of the wells, springs, and seeps in the project area including 

pumping rates for wells. A tabulation of data on all wells within the project 

area including a description of each well’s type, construction, date drilled, 

location, depth, record of plugging and/or completion, and any additional 

information known about the well; 

(h) the results of ground water modeling showing the relationship and 

hydrologic connectivity of the identified geologic formations and aquifers, the 

effects of fractures, fissures, faults, and other significant geologic features on 

ground water movement in the project area; 

(i) the results of pump tests of confining layers quantifying potential leakage 

through such layers; 

(j) a description of all potentially suitable geologic formations for reinjection 

within the project area. For each such suitable geologic formation, the 

operator shall submit the following information: 

(i) the results of reinjection well testing; 

(ii) based upon the results of testing and other studies, an estimate of 

the short-term and long-term reinjection rates that each suitable 

geologic formation is capable of receiving; 

(iii) the results of ground water modeling showing the effects of 

reinjection into suitable geologic formations on other aquifers, surface 

waters, and regional flow systems; and 

(k) all other information required by the EPA as part of the Class V UIC 

Program. 

 21 
(3) The department shall notify the applicant in writing, within 60 days after receipt of 

an application for a waiver, that the application does or does not contain all the 

information necessary for the department to make a determination. If the information 

from the supplemental submittal or any subsequent supplemental submittal is 

inadequate, the department shall notify the applicant in writing, within 30 days of 

receipt of the supplemental submittal, what additional information must be submitted. 

The department shall notify the applicant in writing when the application is deemed 

complete. 

As discussed previously, zero discharge through reinjection will be technically and 

economically feasible well less than 30% of the time and therefore waivers for reinjection 

infeasibility will probably be the norm rather than the exception. As written, the proposed 

waiver process will be an extreme burden on both developers submitting the requests and the 

regulatory agencies having to review the numerous requests, which could severely curtail 

CBNG development and production. 

The waiver information needed to show infeasibility for injection or reinjection as proposed 

are extremely cumbersome, expensive, and time consuming. They require data on all wells in 

the vicinity, local and regional ground water modeling, pump test data, and injection well 

data. The requirements are redundant, in that the same information is required for every 

injection well, even if in similar formations, regions, and similar conditions. 

Overall, the proposed process needs to be significantly streamlined and more realistically 

follow accepted EPA guidelines for underground injection control and oil and gas produced 

water injection wells. 

 22 
5. Proposed CBNG Produced Water Treatment and 

Discharge Standards 

The proposal acknowledges that the geologic formations in reasonable proximity to the coal 

seams may not be able to accept all of the CBNG produced water that has been withdrawn, 

and therefore has allowed the waiver process, albeit through a lengthy and complicated 

application procedure. When a waiver is granted, the produced water discharge limits are 

intended to represent a level of treatment. New Rule VIII establishes the numerical water 

discharge standards for CBNG produced water that is not reinjected and is granted a waiver. 

The proposed language reads: 

NEW RULE VIII TREATMENT-BASED EFFLUENT LIMITATIONS 

(1) If the department grants a waiver from the zero discharge requirement for all or a 

portion of the wastewater pursuant to [New Rules II and III], the amount of 

wastewater that obtains the waiver shall achieve the following minimum technologybased effluent limitations at the end of the pipe prior to discharge: 

(a) calcium average concentration between 0.1 mg/L and 0.2 mg/L; 

(b) magnesium average concentration between 0.1 mg/L and 0.6 mg/L; 

(c) sodium average concentration of 10 mg/L; 

(d) bicarbonate average concentration of 30 mg/L and instantaneous 

maximum concentration of 115 mg/L; 

(e) sodium adsorption ratio instantaneous maximum of 0.5; 

(f) electrical conductivity average concentration of 233 μmhos/cm; 

(g) total dissolved solids average concentration of 170 mg/L; 

(h) ammonia average concentration of 0.1 mg/L and instantaneous maximum 

concentration of 0.3 mg/L; and 

(i) arsenic concentration of <0.0001 mg/L. 

There are several major technical and environmental issues with these proposed effluent 

limits. These include: 

• Inconsistent effluent treatment levels for various parameters, 

• Water effluent levels that are far below commonly accepted water quality 

standards, 

• Treatment levels that will create an effluent water quality that will negatively 

impact both aquatic species and irrigation in the region, 

• Identification of treatment technologies that have not been fully demonstrated to 

meet the proposed effluent guidelines consistently in operational settings across 

the range of produced water qualities in the region, using recommended EPA 

technology cost and performance verification guidelines, 

• the proposed treatment requirements could significantly increase environmental 

issues associated with waste disposal, and 

• The proposed water quality standards are ambiguous in discussing minimum and 

maximum allowed levels. 

 23 
Each of these major technical, environmental, and cost issues and concerns associated with 

the proposed produced water treatment guidelines are discussed below. For reference, Table 

3 summarizes the proposed treatment standards, and compares them to several current effluent 

standards. 

Table 3. Comparison of Common Water Quality Standards with the Proposed 

Montana CBNG Treatment Standards 

 Current MT 

Water Quality 

Standards 

Proposed MT 

CBNG Effluent 

Standards 

WY CBNG 

Produced Stds 

into Class II

Water

EPA Aquatic 

Life Stds 

Conductivity 

(μS/cm) 

2000-2500 233 7,500 <21,000a

Ca (mg/L) No Standard 0.1-0.2 No Standard No Standard 

Mg (mg/L) No Standard 0.1-0.6 No Standard No Standard 

Na (mg/L) No Standard 10 No Standard No Standard 

SAR 5.0-7.5b 0.5c, d 10e No Standard 

Bicarbonate 

(mg/L) 

No Standard 30 average 

115 maximum 

No Standard >20f

As (mg/L) 0.15 average, 

0.34 maximum

<0.0001 No Standard 0.15 (acute) 

0.34 (chronic) 

a Based on primary source of dissolved solids from NaCl, reduce to 2900 if Ca, Mg, and K chlorides 

are present

b Monthly average SAR, depends on season c Instantaneous maximum SAR

d Calculated SAR based on proposed Ca, Mg, and Na levels is 2.5 to 5.3 e Requires site–specific PR

f Criterion Continuous Concentration (CCC), chronic level for freshwater fish is 20,000 mg/L

Inconsistent Treatment Limits of Various Parameters 

The two major inconsistencies are the treatment limits for EC and SAR. EC is based on the 

ionic concentrations of salts, such as the cations Ca, Mg, Na, and the anions Cl, sulfate, and 

carbonate, and other ions in water. Ca and Mg are the most common anions in fresh water, 

and removing Ca, Mg, and Na to the levels identified in the proposed standards will create an 

EC value much less than the 233 μS/cm level proposed. 

Since there is a minimum value given for Ca and Mg, attaining a maximum value of SAR of 

0.5 would violate these standards. The proposed maximum value for SARof 0.5 can not be 

attained using the proposed average treatment standards for Na, Ca, and Mg. SAR is 

calculated as a ratio of the Na, Ca, and Mg ionic concentrations in water as shown below: 

 24 
SAR = Na / [(Ca + Mg)/2]0.5

Where: Na, Ca, and Mg are in meq/L a

The formula for calculating SAR, an explanation of milliequivalents vs. mg/L, and a handy SAR calculation 

tool are provided at: 

http://www.coopext.colostate.edu/TRA/PLANTS/index.html#http://www.colostate.edu/Depts/CoopExt/TRA/PL

ANTS/sar.html

As indicated in Table 3, the SAR range based on the proposed limits for Na, Ca, and Mg 

would be about 2.5 to 5.3. Therefore, several of the proposed treatment limits are 

inconsistent. 

Proposed Water Effluent Levels far below Accepted Water Quality Standards 

The extremely low effluent limits proposed could actually create water that could be 

detrimental to humans, animals, and the environment as discussed in detail below. 

As shown in Table 1, some level of ions in water, such as Ca and Mg, are beneficial for most 

uses and therefore limits on these constituents are often not specifically controlled. Limits on 

these ions and salts is generally controlled through the development of EC or TDS levels, 

putting minimum and maximum levels on salts in a water. Common TDS criteria for drinking 

water consider Ca and Mg concentrations of 100 mg/L as appropriate and beneficial, with 

levels above 300 mg/L as near upper limits. Levels below this are not recommended because 

of the aggressiveness due to the resulting water’s ability to leach heavy metals and toxic 

minerals into the water. In addition, the low alkalinity level will significantly reduce the 

buffering capacity of the water. 

For irrigation purposes and livestock uses, Ca, Mg, and EC values can be significantly higher 

than for drinking water as shown Tables 1 and 4. Therefore, the proposed treatment standards 

for Ca and Mg of 0.1-0.6 mg/L, depending on the ion, are at least 1000 times below the 

generally accepted levels for drinking water and almost 10,000 times below the general levels 

appropriate for livestock and irrigation use. 

The proposed arsenic treatment limit of less than 0.0001 mg/L is 100 times lower than the 

current arsenic standard of 0.010 mg/L for drinking water and over 1000 times lower than 

required for ecologic impacts. The proposed level cannot be accurately measured by current 

monitoring technology, and is lower than current technology treatment performance by a 

factor of ten. 

 25 
Table 4. General Livestock Water Quality Requirements

Conductivity 

(μS/cm) 

Rating Comments

<1,500 Excellent Usable for all classes of livestock and poultry. 

1,500 – 5,000 Very 

Satisfactory 

Usable for all classes of livestock and poultry. May 

cause temporary diarrhea in livestock not accustomed 

to such water; watery droppings in poultry. 

Satisfactory for 

Livestock 

May cause temporary diarrhea or be refused at first 

by animals not accustomed to such water. 5,000 – 8,000a

Unfit for 

Poultry 

Often causes watery feces, increased mortality and 

decreased growth, especially in turkeys. 

8,000 – 11,000 

Limited Use 

for Livestock, 

unfit for 

Poultry 

Usable with reasonable safety for dairy and beef 

cattle, sheep, swine and horses. Not acceptable for 

poultry. 

11,000 – 

16,000 

Very Limited 

Use 

In general, use should be avoided although older 

ruminants, horses, poultry and swine may subsist on 

waters such as these under certain conditions. 

>16,000 Not 

Recommended 

Risks with such highly saline water are so great that 

it cannot be recommended for use under any 

conditions. a Water less than 5000 μS/cm is suitable for most livestock, 

Negative Environmental and Ecological Impacts of Proposed Water Quality Standards 

Treatment to the levels identified could be detrimental to the environment and ecology of the 

area. As mentioned above, treatment to the very low proposed levels of SAR of 0.5, EC of 

233 μmhos/cm, and alkalinity of 30 mg/l will create water that is very aggressive and will 

tend to leach minerals and metals from the soil. This could impact downstream water quality 

and toxicity and have a negative impact on stream and river habitat. It will also have a 

potential negative impact on irrigation efficiency. 

 

From a river and surface water ecology standpoint, EPA recommends water alkalinity of 

greater than 20 mg/L and up to 20,000 mg/L and an EC of about 2900 μS/cm for inland 

surface waters such as the Powder River Basin with high levels of Ca and Mg. Based on 

aquatic life parameters, the proposed treatment levels for both alkalinity and EC are 

substantially below the minimum recommended thresholds set by EPA and could be expected 

to negatively impact aquatic ecology. This is an issue in Wyoming where the Wyoming 

Department of Game and Fish has objected to the level of discharges of very low TDS water 

because of the impact on aquatic ecosystems in the region (Osborne and Adams 2005). 

Treating the water to the required SAR and EC will negatively impact water infiltration in 

soils and negatively impact irrigation. As identified in Table 1, irrigation water quality with 

an EC of 500 to 3000 μS/cm can be appropriately used. As shown in Figure 2, treating the 

water to the identified SAR and EC values will create a water quality with very poor 

 26 
infiltration characteristics, and therefore negatively impact irrigation efficiency. The 

information in Figures 2 and 3 suggest that significantly higher values of SAR and EC (a 

factor of ten or more) would be much more beneficial to irrigation efficiency without 

negatively impacting crop yields for most of the common crops in this region. 

CBM Prod. Water 

(minimum)

CBM Prod. Water 

(maximum)

CBM Prod. Water

(mean)

0

5

10

15

20

25

30

35

0 1000 2000 3000 4000 5000 6000

Salinity (μS/cm)

SAR

SEVERE REDUCTION IN

RATE OF INFILTRATION

SLIGHT TO MODERATE

REDUCTION IN RATE OF

INFILTRATION

NO REDUCTION 

IN RATE OF 

INFILTRATION

Current Powder River 

Characteristics (WY & MT data)

Proposed 

MT SAR

Standards:

red values 

calculated by

Ca, Mg, Na

values

blue - SAR

maximum

Figure 2. Soil Infiltration Impact based on SAR and Salinity 

(modified from Ayers and Westcott) 

 (CBM Produced Water and Powder River Characteristics from USGS) 

Concerns with the Performance and Cost of the Proposed Water Treatment 

Technologies 

To meet the proposed treatment guidelines, reverse osmosis and ion exhange were identified 

as the technologies recommended meeting the proposed “technology-based standards”. 

Technology-based requirements must insure that the proposed technology is cost-effective, 

and economically, environmentally, and technologically feasible. Before a technology can be 

recommended for use, it must be demonstrated that the proposed treatment limits can be 

consistently met across the range of expected waste stream parameters and characteristics 

under typical field and operating conditions. While some data do exist on the evaluation of the 

performance of these technologies for some produced water treatment applications, these data 

are limited, and neither of the technologies identified has been evaluated fully following the 

current EPA guidelines for verification of the cost and performance data of innovative 

treatment technologies (EPA 1997). 

 27 
The problems with verification of the cost and performance of the proposed treatment 

technologies is highlighted by the fact that the proposed treatment level identified for arsenic 

is a factor of ten lower than currently available technology performance. 

From an economic and cost-effectiveness standpoint, the proposed technologies can be 

expensive. Table 5 provides better information on the expected costs of reverse osmosis 

treatment for brackish water. These are based on Bureau of Reclamation data discussed in the 

Desalting Handbook for Planners (BoR 2003). It provides a baseline for cost estimates for a 

small brackish water Reverse Osmosis (RO) plant with similar chemistry and disposal needs 

as the PRB. Pretreatment and other site-specific costs would have to be included. The values 

are based on a water gathering and treatment system to handle about one million gallons per 

day from about 96 CBNG wells. 

Table 5. Estimated PRB CBNG Produced Water Treatment Costs 

Water Disposal Method Water Disposal Costs 

Total Capital 

Costsa

Capital Costs/Well O&M Costs/Bblb

Active Treatment (RO) with 

pipelines, 

$1-2 M $10-20K $0.13-0.16 

 Injection Disposal of 

Concentrate 

$1-2M $10-20K $0.05-0.10

 Trucking of Concentrate 

and Deep Disposal 

$200-300K $2-3K $0.20- $1.00

a Includes building, equipment, water gathering, and infrastructure 

b Assumes 320 bbl/day per well, 96 wells, during first 2 years of operation 

The proposed treatment technologies, based on current practices, would generate large 

volumes of concentrate, approximately 10-20% of the water treated, that would have to be 

disposed. This will significantly increase the cost and impact of the proposed treatment 

processes and could have major impacts on the environment. Since injection disposal options 

are limited, other concentrate disposal options, such as trucking to a disposal site will be 

required. This could require extensive infrastructure including additional roads, storage tanks, 

and could generate significant tanker truck traffic. These will have negative impacts on the 

environment, landscape, and increase erosion, dust, and noise. 

Conclusions on Proposed CBNG produced water treatment and effluent discharge 

standards

The proposed treatment standards for the CBNG produced water identify very low effluent 

levels for SAR, electrical conductivity, calcium, magnesium, sodium, and extremely low 

levels for arsenic. The levels identified in the proposal in many case are from 100 to 1000 

times lower than recommended for appropriate concentrations. 

The proposed treatment levels for SAR, EC, Ca, Mg, and Na, are ambiguous, inconsistent, 

and will create an effluent water quality that is not appropriate for drinking water or irrigation 

 28 
use, is aggressive in picking up metals and soil constituents, and could have a negative impact 

to aquatic ecology and river and stream habitat. 

The technologies identified have not been evaluated using EPA technology verification 

guidelines for developing cost and performance data on treatment technologies. Therefore, it 

is unknown whether the proposed treatment levels are technically feasible, cost effective, or 

consistently achievable across for the range of CBNG produced waters in the region. In the 

case of the arsenic treatment level it is doubtful that this level can be consistently met with 

current technology. 

 The treatment technologies identified, and the level of treatment needed to meet the proposed 

standards, will generate significant amounts of wastes that must be managed and could lead to 

unintended environmental impacts from handling and moving these waste streams. 

Therefore, a much broader approach to developing standards for handling, treating, and 

managing CBNG produced water should be considered. As written, the proposed effluent 

standards will have significant ecological, environmental, and cost impacts that were not fully 

considered.

Crop Yield & Irrigation Water Salinity

0%

5%

10%

15%

20%

25%

30%

35%

40%

45%

50%

55%

60%

65%

70%

75%

80%

85%

90%

95%

100%

0.0 1.0 2.0 3.0 4.0 5.0 6.0 7.0 8.0 9.0 10.0 11.0 12.0

Salinity (ECw, dS/m)

% Yield

Moderately

Sensitive Crops 

(incl. alfalfa)

Moderately

Tolerant Crops 

(incl. wheat)

Tolerant Crops

(incl. barley)

Unsuitable 

for Crops

Sensitive Crops 

(incl. apples)

PROPOSED 

MONTANA 

STANDARD

Current Powder 

River EC Range

Current Powder 

River EC Median

Figure 3. Crop Yield and Irrigation Water Salinity (modified from Ayers and Westcott)

 29 
6. PROPOSED LIMITS ON CBNG PRODUCED WATER 

MANAGEMENT OPTIONS 

The proposal requires reinjection to suitable geologic formations wherever possible. When 

reinjection is not possible, and if the operator can make a successful waiver application, some

or all of the CBNG produced water can be discharged as long as the effluent meets some very 

strict standards. With the exception of New Rule IX, which provides an exemption for CBNG 

water used for livestock watering, no other management options are permitted for CBNG 

water. Another portion of the proposal offers some degree of flexibility and relief, where 

applicable. New Rule IX allows some of the CBNG produced water to be used for livestock 

watering. 

NEW RULE IX STOCK WATERING EXEMPTION (1) The requirements of [New 

Rules I through VIII] shall not apply to any quantity of wastewater used for stock 

watering purposes if all the following conditions are satisfied: 

(a) the surface owner and operator sign a written agreement to use the 

wastewater for stock watering purposes; 

(b) the wastewater is stored in a stock tank; and 

(c) the surface owner has obtained a beneficial use permit from the department 

of natural resources and conservation pursuant to Title 85, chapter 2, MCA. 

(2) The stock watering exemption shall be limited to the quantity of water for which 

the department of natural resources and conservation issues a beneficial use permit. 

This proposed restriction effectively precludes the direct use of CBNG water without 

treatment for many beneficial purposes. Some of these existing uses of CBNG produced 

water provide affordable produced water management to operators while providing direct 

benefits to landowners. For example, managed irrigation has proven successful in several 

Powder River Basin applications. In a recent paper, (Harvey et al. 2005) describes case 

studies of managed irrigation to reuse CBNG produced water in an ecologically sound manner 

without treatment. 

Operators, land owners, and land management agencies may be interested in other uses such 

as off-channel impoundments that can provide livestock watering and recreational 

opportunities for landowners, use of water for industrial uses to offset fresh water demands, or 

other applications. The proposed provision also restricts the introduction of future innovative 

technologies for managing CBNG produced water in an environmentally and ecologically 

sound manner. 

Water quality standards should incorporate the best available technology and allow for 

beneficial use of the CBNG water directly where possible. The CBNG produced water 

quality in the PRB is appropriate for a number of applications either with little or no 

treatment. As discussed in Tables 1 and 4, beneficial uses could include not only livestock 

watering, but irrigation, supplemental water for aquatic systems, and makeup water for other 

oil and gas industry uses such as drilling and completions, use by other industries such as 

electric power generation, or other purposes and should not be minimized nor ignored. 

 30 
7. CONCLUSIONS 

Electrical Conductivity (EC) and the Sodium Adsorption Ratio are not harmful parameters as 

the proposal relates but rather can be used to describe certain chemical properties of the 

CBNG produced water. 

There appear to be limited systematic and successful approaches for produced water 

reinjection into coal seams or injection into other formations of CBNG produced water in the 

Powder River Basin. Geology and other geotechnical factors limit options. Moreover the 

success rate of establishing reinjection wells, based on today’s available data, is less that 30%. 

As written, the proposed waiver from zero discharge (Proposed New Rule III) process will be 

an extreme burden on both developers submitting the requests and the regulatory agencies 

having to review the numerous requests, which could severely curtail CBNG development 

and production. 

Several major technical and environmental issues exist with the proposed new effluent limits 

which include: 

• Inconsistent effluent treatment standards, 

• Effluent levels far below commonly accepted water quality standards,

• Treatment levels that will create an effluent water quality that could negatively impact 

aquatic species and irrigation, 

• Identification of treatment technologies that have not been fully demonstrated using 

recommended EPA technology cost and performance verification guidelines, and 

• The treatment needed to meet the proposed standard will generate significant amounts 

of waste and waste water that must be managed.

The proposed limits on the use of innovative produced water management technologies also 

raise serious concerns. 

• The proposed restrictions preclude the direct use of CBNG water without treatment for 

many beneficial purposes. Some of these existing uses of CBNG produced water 

provide affordable produced water management to operators while providing direct 

benefits to landowners. 

• Operators, land owners, and land management agencies may be interested in other 

uses such as off-channel impoundments, use of water for power generation or 

industrial uses to offset fresh water demands, or other applications. The proposed 

provision restricts the introduction of future innovative technologies for managing 

CBNG produced water in an environmentally and ecologically sound manner. 

• The CBNG produced water quality in the PRB is appropriate for a number of 

applications either with little or no treatment, thus, with water site-specific water 

analysis much of the CBNG produced water could be used for beneficial purposes. 

 31 

 
 32 

 
 33 

 

APPENDIX A 

Proposed Changes to Montana Water Quality Regulations 

As announced in September 2005 

by the Board of Environmental Review 

of the State of Montana 
19-10/6/05 34 MAR Notice No. 17-231

 

BEFORE THE BOARD OF ENVIRONMENTAL REVIEW 

OF THE STATE OF MONTANA 

 

In the matter of the amendment of 

ARM 17.30.670 and 17.30.1202 

pertaining to nondegradation 

requirements for electrical 

conductivity (EC) and sodium 

adsorption ratio (SAR) and 

definitions for technology-based 

effluent limitations, and the 

adoption of new rules I through X 

pertaining to minimum technologybased controls and treatment 

requirements for the coal bed 

methane industry 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

NOTICE OF PUBLIC 

HEARING ON PROPOSED 

AMENDMENT AND 

ADOPTION (WATER QUALITY) 

 TO: All Concerned Persons 

 

 1. On November 9, 2005, at 10:30 a.m., at the Lame Deer 

Charging Horse Casino, 1/2 Mile East Lame Deer Hwy. 212, Lame Deer, 

Montana; November 10, 2005, at 8:00 a.m., at Miles City Community 

College, Room 106, 2715 Dickinson, Miles City, Montana; and December 

1, 2005, at 1:30 p.m., at the Metcalf Building, Room 111, 1520 East 

Sixth Avenue, Helena, Montana, the Board of Environmental Review 

will hold public hearings to consider the proposed amendment and 

adoption of the above-stated rules. 

 

 2. The Board will make reasonable accommodations for persons 

with disabilities who wish to participate in these public hearings 

or need an alternative accessible format of this notice. If you 

require an accommodation, contact the Board no later than 5:00 p.m., 

November 1, 2005, to advise us of the nature of the accommodation 

that you need. Please contact the Board Secretary at P.O. Box 

200901, Helena, Montana 59620-0901; phone (406) 444-2544; fax (406) 

444-4386; or email ber@mt.gov. 

 

 3. The rules proposed to be amended provide as follows, 

stricken matter interlined, new matter underlined: 

 

17.30.670 NUMERIC STANDARDS FOR ELECTRICAL CONDUCTIVITY (EC) 

AND SODIUM ADSORPTION RATIO (SAR) (1) through (5) remain the same. 

(6) Changes in existing surface or ground water quality with 

respect to EC and SAR are nonsignificant according to the criteria 

in 75-5-301(5)(c), MCA, provided that the change will not have a 

measurable effect on any existing or anticipated use or cause 

measurable changes in aquatic life or ecological integrity. EC and 

SAR are harmful parameters for the purposes of the Montana Water 

Quality Act, Title 75, chapter 5, MCA. 

(7) For purposes of determining compliance with the water 

quality standards and nonsignificance criteria for all parameters of 

concern in any new or increased discharges of unaltered ground water 

from coal bed methane development of methane wastewater, the 

department shall determine effluent or compliance limits (e.g., 

evaluate the design of disposal systems) by using a flow-based 

analysis that considers a range of flows or monthly flow 

probability. With respect to EC and SAR, the department shall also 

use the median chemistry for the specified flow range or monthly 

flow by using 7Q10 flows. 
19-10/6/05 35 MAR Notice No. 17-231

 

(8) If any of the provisions of (6) or (7), or both of them, 

are declared to be invalid, then the numeric water quality standards 

and requirements specified in (1) through (7) shall be void.

 AUTH: 75-5-301, 75-5-303, MCA 

 IMP: 75-5-301, 75-5-303, MCA 

 

 17.30.1202 DEFINITIONS For the purposes of this subchapter, 

the following definitions apply: 

(1) "Board" means the Montana board of environmental review 

established by 2-15-3502, MCA. "Average" means the highest 

allowable average of daily discharges over a calendar week, 

calculated as the sum of all daily discharges measured during a 

calendar week divided by the number of daily discharges measured 

during that week.

(2) "Department" means the Montana department of environmental 

quality established by 2-15-3501, MCA. "Coal bed methane 

extraction" means the extraction of methane gas from any coals or 

associated geologic formations. 

(3) "Daily discharge" means the discharge of pollutants 

measured during a calendar day or any 24-hour period that reasonably 

represents the calendar day for purposes of sampling. The daily 

discharge is calculated as the average measurement of the pollutant 

over the day.

(3) and (4) remain the same, but are renumbered (4) and (5). 

(6) "Geologic formation" means a body of rock characterized by 

a degree of lithologic homogeneity which is prevailingly, but not 

necessarily, tabular and is able to be mapped on the earth’s surface 

or traceable in the subsurface. 

(7) "Instantaneous maximum" means the maximum concentration 

measured in any single sample of the discharge effluent. 

(8) "Methane wastewater" means water produced from coal bed 

methane extraction during exploration or development activities.

(5) remains the same, but is renumbered (9). 

(10) "Project area" includes the entire geographic area leased 

by the operator or any person legally related to the operator for 

coal bed methane extraction.

(11) "Reinjection" means putting methane wastewater back into 

a suitable geologic formation. 

(12) "Suitable geologic formation" means a geologic formation 

with water quality similar enough to that of the methane wastewater 

in the project area to ensure that, after reinjection of methane 

wastewater, the water of the receiving formation will remain 

suitable for the same beneficial uses as the methane wastewater. 

(13) "Surface owner" means the person who holds record title 

to or has a purchaser’s interest in the surface of the land. 

 AUTH: 75-5-305, MCA 

IMP: 75-5-305, MCA 

 

REASON: ARM 17.30.670 and 17.30.1202 are being amended for the 

following reasons: 

 

ARM 17.30.670

 The Board is proposing the amendment of ARM 17.30.670 in 

response to a petition filed by Northern Plains Resource Council, 

Tongue and Yellowstone Irrigation District, Surface Owners of the 

Wolf Mountains Area, Bear Creek Council, Stillwater Protective 

Association, Bull Mountain Land Alliance, Rosebud Protective 

Association, Dawson Resource Council, Carbon County Resource 
19-10/6/05 36 MAR Notice No. 17-231

 

Council, Bones Brothers Ranch, Muggli Brothers, Huggo Muggli Inc., 

Golder Ranch, Greenleaf Cattle Company, Rocker 6 Cattle Company, FL 

Ranch, and Fix Ranch (collectively referred to as "petitioners"). 

The petitioners are requesting that the Board amend ARM 

17.30.670(6) to modify the nondegradation criteria applicable to 

electrical conductivity (EC) and sodium adsorption ratio (SAR); to 

amend ARM 17.30.670(7) to clarify that determining compliance with 

water quality standards and nondegradation thresholds for discharges 

of coal bed methane wastewater shall be done using 7Q10 flows; and 

to delete the non-severability clause in ARM 17.30.670(8). 

The existing nondegradation criteria for EC and SAR are based 

upon a narrative criteria that provides: "changes in existing 

surface or ground water quality with respect to EC and SAR are 

nonsignificant . . . provided that the change will not have a 

measurable effect on any existing or anticipated use or cause 

measurable changes in aquatic life or ecological integrity." The 

petitioners argue that the narrative criteria effectively exempt 

methane discharges, including discharges from methane development in 

Wyoming, from the state of Montana’s nondegradation policy. 

Montana’s nondegradation policy is necessary to protect the existing 

water quality of the Tongue River from degradation from methane 

discharges in Montana and Wyoming. Montana’s nondegradation policy 

will be critical to protect the existing water quality of rivers 

such as the Clark Fork of the Yellowstone, Rock Creek, Stillwater 

River, Flathead River, and the pristine streams of Park County if 

methane development occurs in these watersheds. 

The proposed amendments also restore a conservative approach to 

determining compliance with numeric water quality standards and 

nondegradation thresholds by requiring the Department to require 

compliance at low flow events. The Department uses this 

conservative approach for all other dischargers. The methane 

industry should not be granted special treatment. 

Since salinity, as measured by EC and SAR, is harmful to soils, 

vegetation, and aquatic life, the appropriate nondegradation 

criteria for EC and SAR are the criteria for harmful parameters. 

For harmful parameters, changes in existing water quality are 

considered nonsignificant, if the change is less than 10% of the 

applicable standard and the existing water quality in the receiving 

stream is less than 40% of the applicable standard. See ARM 

17.30.715(1)(f). If a proposed discharge of EC and SAR will exceed 

the criteria for harmful parameters, then the permittee must request 

the Department to issue an authorization to degrade pursuant to 75-

5-303, MCA. 

 

ARM 17.30.1202 

 

 The definitions in ARM 17.30.1202 are being amended to add 

definitions that will be necessary to clarify the technology-based 

controls and treatment requirements the Board is proposing to adopt 

in New Rules I through X. The new definitions are being added to 

ARM 17.30.1202, because that rule contains the Board's existing 

definitions applicable to effluent limitations for point source 

discharges to surface waters. 

 

4. The proposed new rules provide as follows: 

NEW RULE I APPLICABILITY (1) The requirements of [New Rules 

II through IX] are applicable to those facilities engaged in 

exploration, drilling, production, and development in the coal bed 

methane industry. 

 
19-10/6/05 37 MAR Notice No. 17-231

 

AUTH: 75-5-305, MCA 

IMP: 75-5-305, MCA 

 

NEW RULE II ZERO DISCHARGE REQUIREMENT (1) Except as 

provided in [New Rules III through IX], point sources of methane 

wastewater shall achieve zero discharge of pollutants, which 

represents the minimum technology-based requirement. Zero discharge 

shall be accomplished by reinjection of methane wastewater into 

suitable geologic formations in the project area in compliance with 

all other applicable federal and state laws and regulations. 

 

 AUTH: 75-5-305, MCA 

 IMP: 75-5-305, MCA 

 NEW RULE III WAIVER FROM ZERO DISCHARGE REQUIREMENT

(1) The department may grant a waiver from the zero discharge 

requirement if the owner or operator of a point source discharge of 

coal bed methane wastewater demonstrates by clear and convincing 

evidence to the department through site specific studies that the 

requirement is not technically feasible because estimated wastewater 

production rates exceed the estimated cumulative reinjection rates 

of all suitable geologic formations in the project area. 

(2) The department shall limit the waiver to the volume of 

methane wastewater for which the owner or operator shows that zero 

discharge is not technically feasible. The volume of methane 

wastewater for which the department grants a waiver from the zero 

discharge requirement shall be limited to the difference between 

estimated wastewater production rates and the estimated cumulative 

reinjection rates for all suitable geologic formation in the project 

area. 

(3) The department may limit the waiver to the initial phases 

of development when the volume of methane wastewater produced by 

wells is highest, which may make reinjection of all such water 

technically unfeasible. 

(4) The department may also grant a waiver from the zero 

discharge requirement if the EPA will not authorize the reinjection 

pursuant to a permit under the Safe Drinking Water Act (SDWA), 42 

USC 300f to 300j-26(5). The operator shall attain zero discharge 

for the volume of methane wastewater for which the department does 

not grant a waiver. 

 

AUTH: 75-5-305, MCA 

IMP: 75-5-305, MCA NEW RULE IV INFORMATIONAL REQUIREMENTS FOR WAIVER 

DETERMINATION (1) An owner or operator requesting a waiver from 

the zero discharge requirement for coal bed methane wastewater shall 

submit an application to the department for the department to make a 

determination on whether to grant the waiver. 

(2) The application shall include, but is not limited to, the 

following: 

(a) a description and map of the coal bed methane project and 

project area showing the location of wells, pipelines, roads, 

compressors, and related infrastructure; 

(b) a description of the surface owners in the project area; 

(c) an estimate of pumping rates for coal bed methane wells in 

the target coal seams and an estimate of the volume of wastewater 

likely to be produced per well per year; 

(d) for each targeted coal seam, data showing areas 

characterized by high concentrations of vertical fractures where 

wastewater production wells may be higher; 
19-10/6/05 38 MAR Notice No. 17-231

 

(e) an inventory and map of geologic formations, aquifers, and 

confining layers including significant fractures, fissures, and 

faults within the project area. The following information is 

required for each geologic formation and aquifer in the project 

area: 

(i) lateral extent, thickness, and depth. Maps and cross 

sections indicating the vertical and lateral limits of each 

formation; 

(ii) hydraulic properties including, but not limited to, 

transmissivity, storage coefficient, effective porosity, and 

hydraulic conductivity. The results of pump tests, analysis of core 

samples, and other geophysical studies; 

(iii) water quality characterization including the geochemical 

compatibility of the receiving aquifer minerals with methane 

wastewater; 

(f) an inventory and map of the locations of natural recharge 

in the project area and near the reinjection location; 

(g) an inventory of the wells, springs, and seeps in the 

project area including pumping rates for wells. A tabulation of 

data on all wells within the project area including a description of 

each well’s type, construction, date drilled, location, depth, 

record of plugging and/or completion, and any additional information 

known about the well; 

(h) the results of ground water modeling showing the 

relationship and hydrologic connectivity of the identified geologic 

formations and aquifers, the effects of fractures, fissures, faults, 

and other significant geologic features on ground water movement in 

the project area; 

(i) the results of pump tests of confining layers quantifying 

potential leakage through such layers; 

(j) a description of all potentially suitable geologic 

formations for reinjection within the project area. For each such 

suitable geologic formation, the operator shall submit the following 

information: 

(i) the results of reinjection well testing; 

(ii) based upon the results of testing and other studies, an 

estimate of the short-term and long-term reinjection rates that each 

suitable geologic formation is capable of receiving; 

(iii) the results of ground water modeling showing the effects 

of reinjection into suitable geologic formations on other aquifers, 

surface waters, and regional flow systems; and 

(k) all other information required by the EPA as part of the 

Class V UIC Program. 

(3) The department shall notify the applicant in writing, 

within 60 days after receipt of an application for a waiver, that 

the application does or does not contain all the information 

necessary for the department to make a determination. If the 

information from the supplemental submittal or any subsequent 

supplemental submittal is inadequate, the department shall notify 

the applicant in writing, within 30 days of receipt of the 

supplemental submittal, what additional information must be 

submitted. The department shall notify the applicant in writing 

when the application is deemed complete. 

(4) The application for a waiver submitted pursuant to this 

subchapter shall comply with the signature and certification 

requirements of ARM 17.30.1323. The board adopts and incorporates 

by reference ARM 17.30.1323, which sets forth signature and 

certification requirements for MPDES permit applications. Copies of 

ARM 17.30.1323 may be obtained from the Department of Environmental 

Quality, P.O. Box 200901, Helena, Montana 59620-0901. 

 
19-10/6/05 39 MAR Notice No. 17-231

 

AUTH: 75-5-305, MCA 

IMP: 75-5-305, MCA 

 

NEW RULE V DEPARTMENT PROCEDURES FOR MAKING WAIVER DETERMINATIONS (1) Upon a determination by the department that an application 

submitted under [New Rule IV] is complete, the department shall 

prepare a preliminary decision approving or denying the waiver 

pursuant to the procedures in [New Rule VI]. 

(2) The department shall deny an application for a waiver 

unless the applicant has affirmatively demonstrated and the 

department finds, based on clear and convincing evidence, that 

reinjection is not technically feasible, using the standards set 

forth in [New Rule III]. The department shall consider an analysis 

by the applicant and any substantive relevant information either 

submitted by the public or otherwise available. 

(3) The department shall make its preliminary decision either 

authorizing or denying the waiver within 180 days after receipt of a 

complete application from the applicant. This time period may be 

extended upon agreement of the applicant or whenever an 

environmental impact statement must be prepared pursuant to Title 

75, chapter 1, parts 1 and 2, MCA. 

(4) To the maximum extent possible, the department shall 

coordinate any application for a waiver with the permitting and 

approval requirements of other laws or programs administered by the 

department or by any other local, state, or federal agency. 

 

AUTH: 75-5-305, MCA 

IMP: 75-5-305, MCA 

NEW RULE VI DEPARTMENT PROCEDURES FOR MAKING PRELIMINARY AND 

FINAL WAIVER DECISIONS (1) The department shall issue a 

preliminary decision either denying or authorizing a waiver from the 

zero discharge requirement and shall provide a 60-day public comment 

period prior to issuing a final decision. The department’s 

preliminary and final decisions shall include the following: 

(a) a description of the proposed coal bed methane project and 

project area; 

(b) a determination of the estimated methane wastewater 

production rate for the project and the scientific basis supporting 

such determination; 

(c) a determination of the reinjection rate for each suitable 

geologic formation, determination of the cumulative reinjection rate 

for all suitable geologic formations in the project area, and the 

scientific basis supporting such determinations; 

(d) a determination that the waiver from the zero discharge 

requirement is necessary because estimated methane wastewater 

production rates exceed estimated cumulative reinjection rates for 

all suitable geologic formations in the project area or because the 

EPA will not authorize the reinjection pursuant to the SDWA; 

(e) a determination of the volume of methane wastewater for 

which reinjection is not technically feasible (and thus a waiver is 

necessary) and the scientific basis supporting such determination; 

(f) a detailed description of all the conditions applied to any 

waiver from the zero discharge requirement including, but not 

limited to, the conditions required in [New Rule III(2) through 

(4)], monitoring requirements, reporting requirements, limitations 

on the waiver granted, and methods for determining compliance with 

the waiver; 

(g) a description of the procedures for reaching a final 

decision on the waiver including: 
19-10/6/05 40 MAR Notice No. 17-231

 

(i) the beginning and ending dates of the comment period and 

the address where comments will be received; 

(ii) procedures for requesting a hearing and any other 

procedures by which the public may participate in the final 

decision; and 

(iii) name and telephone number of a person to contact for 

additional information. 

(2) The preliminary decision, accompanying a statement of 

basis, must be publicly noticed and made available for public 

comment for at least 30 days, but not more than 60 days, prior to a 

final decision. In providing public notice, the department shall 

comply with the following: 

(a)procedures for public notice set forth in ARM 17.30.1372; 

and 

(b) procedures for the distribution of information set forth in 

ARM 17.30.1041. 

(3) During the public comment period, any interested person may 

submit written comments on the preliminary decision and may request 

a public hearing. A request for a public hearing must be in writing 

and must state the nature of the issues proposed to be raised at the 

hearing. The department shall hold a hearing if one is requested. 

Any public hearing conducted under this section is not a contested 

case hearing under the provisions of the Montana Administrative 

Procedure Act, Title 2, chapter 4, MCA. 

(4) Within 60 days after the close of the public comment 

period, the department shall issue a final decision accompanied by a 

statement of basis for the decision and, if applicable, a statement 

of conditions. The final decision and statement of basis will be 

prepared according to the requirements of this section. In 

addition, the statement of basis for a final decision must include 

the following: 

(a) which provisions, if any, of the preliminary decision have 

been changed in the final decision and the reasons for the change; 

and 

(b) a description and response to all substantive comments on 

the preliminary decision raised during the public comment period or 

during any hearing. 

(5) Upon issuing a final decision, the department shall notify 

the applicant and each person who has submitted written comments or 

requested notice of that decision. The notice must include 

reference to the procedures for appealing the decision. 

(6) The final decision is effective 30 days after the service 

of notice of the decision unless: 

(a) a hearing is requested pursuant to [New Rule VII], in 

which case the decision is effective 30 days after the final 

decision of the board; or 

(b) no comments are received on the preliminary decision, in 

which case the decision is effective upon issuance. 

(7) The board adopts and incorporates by reference ARM 

17.30.1041, which sets forth requirements for distribution and 

copying of public notices and permit applications, and ARM 

17.30.1372, which sets forth procedures for issuing public notices 

of MPDES permit applications and hearings. Copies of ARM 17.30.1041 

and 17.30.1372 may be obtained from the Department of Environmental 

Quality, P.O. Box 200901, Helena, MT 59620-0901. 

 AUTH: 75-5-305, MCA 

IMP: 75-5-305, MCA 

 NEW RULE VII REVIEW (1) An interested person wishing to 

challenge a final department decision may request a hearing before 
19-10/6/05 41 MAR Notice No. 17-231

 

the board within 30 days of the final department decision on a 

waiver. The contested case procedures of Title 2, chapter 4, part 

6, MCA, apply to a hearing under this rule. 

 AUTH: 75-5-201, MCA 

IMP: 75-5-201, 75-5-305, MCA 

 NEW RULE VIII TREATMENT-BASED EFFLUENT LIMITATIONS

(1) If the department grants a waiver from the zero discharge 

requirement for all or a portion of the wastewater pursuant to [New 

Rules II and III], the amount of wastewater that obtains the waiver 

shall achieve the following minimum technology-based effluent 

limitations at the end of the pipe prior to discharge: 

(a) calcium average concentration between 0.1 mg/L and 0.2 

mg/L; 

(b) magnesium average concentration between 0.1 mg/L and 0.6 

mg/L; 

(c) sodium average concentration of 10 mg/L; 

(d) bicarbonate average concentration of 30 mg/L and 

instantaneous maximum concentration of 115 mg/L; 

(e) sodium adsorption ratio instantaneous maximum of 0.5; 

(f) electrical conductivity average concentration of 233 

μmhos/cm; 

(g) total dissolved solids average concentration of 170 mg/L; 

(h) ammonia average concentration of 0.1 mg/L and 

instantaneous maximum concentration of 0.3 mg/L; and 

(i) arsenic concentration of <0.0001 mg/L. 

 AUTH: 75-5-305, MCA 

 IMP: 75-5-305, MCA 

 NEW RULE IX STOCK WATERING EXEMPTION (1) The requirements of 

[New Rules I through VIII] shall not apply to any quantity of 

wastewater used for stock watering purposes if all the following 

conditions are satisfied: 

(a) the surface owner and operator sign a written agreement to 

use the wastewater for stock watering purposes; 

(b) the wastewater is stored in a stock tank; and 

(c) the surface owner has obtained a beneficial use permit 

from the department of natural resources and conservation pursuant 

to Title 85, chapter 2, MCA. 

(2) The stock watering exemption shall be limited to the 

quantity of water for which the department of natural resources and 

conservation issues a beneficial use permit. 

 

AUTH: 75-5-305, MCA 

IMP: 75-5-305, MCA 

 

NEW RULE X SEVERABILITY (1) If any provision of [New Rules 

II through IX] is determined to be invalid or unenforceable, such 

provision shall be fully severable and the other provisions thereof 

shall remain in full force and effect. The remaining provisions 

shall be liberally construed to carry out the provisions of this 

subchapter. 

 AUTH: 75-5-305, MCA 

IMP: 75-5-305, MCA 

 

REASON: Why Minimum Technology-Based Controls and Treatment 

Requirements are Necessary 

 
19-10/6/05 42 MAR Notice No. 17-231

 

The Board is proposing the adoption of New Rules I through X to 

establish minimum technology-based controls and treatment 

requirements for the coal bed methane industry in response to a 

petition filed by Northern Plains Resource Council, Tongue and 

Yellowstone Irrigation District, Surface Owners of the Wolf 

Mountains Area, Bear Creek Council, Stillwater Protective 

Association, Bull Mountain Land Alliance, Rosebud Protective 

Association, Dawson Resource Council, Carbon County Resource 

Council, Bones Brothers Ranch, Muggli Brothers, Huggo Muggli Inc., 

Golder Ranch, Greenleaf Cattle Company, Rocker 6 Cattle Company, FL 

Ranch, and Fix Ranch (collectively referred to as "petitioners"). 

The minimum technology-based controls and treatment 

requirements proposed by the petitioners are a combination of "zero 

discharge" and treatment-based effluent limitations. The effluent 

limitations proposed by the petitioners will prohibit the discharge 

of wastewater by requiring reinjection into suitable geologic 

formations unless the operator can demonstrate that site-specific 

geologic conditions make zero discharge technically unfeasible. To 

the extent zero discharge is not technically feasible because of 

site-specific geologic limitations, the rules impose effluent 

limitations at the end of the pipe prior to discharge based upon 

existing treatment technologies such as ion exchange or reverse 

osmosis. 

The reasons for adopting minimum technology-based controls and 

treatment requirements for the coal bed methane industry are stated 

in the petition and are summarized as follows: 

 

1. Currently, there are no technology-based treatment 

requirements for the coal bed methane industry adopted by the U.S. 

Environmental Protection Agency (EPA) under the federal Clean Water 

Act (CWA). Since the Board has the authority to adopt treatment 

requirements for a particular industry when EPA has failed to do so, 

the petitioners have requested the Board to initiate rulemaking to 

establish technology-based controls and treatment requirements for 

discharges from the coal bed methane industry. See 75-5-305(1), 

MCA. 

2. The purpose of the treatment requirements is to require 

coal bed methane operators to use the best available technology that 

will minimize the discharge of wastes and make substantial progress 

toward the ultimate national goal of eliminating the discharge of 

all pollutants. 

3. The reason for requiring reinjection of all coal bed 

methane wastewater into suitable geologic formations (unless reinjection is technically unfeasible) is to maximize the volume of 

water that will be put back into aquifers from which it was taken. 

This requirement will alleviate the draining of aquifers and the 

drying up of wells and springs that are used by petitioners. 

4. The reason that water must be reinjected into "suitable 

geologic formations" (i.e., aquifers with water of similar quality 

to coal bed methane wastewater) is to ensure that the water resource 

is available for beneficial use in the future. For this reason, 

reinjection into deep geologic formations that are considered Class 

II wells under the Safe Drinking Water Act's Underground Injection 

Control (UIC) program is not allowed under the rules because the 

water quality in those formations typically will not qualify as 

being "suitable geologic formations." 

5. The reason for adopting technology-based effluent limits 

for discharges of coal bed methane wastewater to surface water is to 

ensure that treatment to a minimum level is used on the volume of 

methane wastewater that cannot be reinjected due to technical 

infeasibility. 
19-10/6/05 43 MAR Notice No. 17-231

 

 

The Board's Authority to Adopt Minimum Treatment Requirements 

 

Under 75-5-305(1), MCA, the Board may adopt minimum treatment 

requirements for an industry when there are no federally promulgated 

treatment requirements for the industry. Prior to adopting such 

requirements, the Board must ensure that: (1) the technology-based 

standards address parameters that "are likely to affect beneficial 

uses;" and (2) the technology-based requirements are "costeffective and economically, environmentally, and technologically 

feasible." The petitioners' scientific, economic, and technical 

basis for the Board's adoption of minimum treatment requirements are 

described in the Petition and are summarized as follows: 

 1. Parameters that are likely to affect beneficial uses 

 The proposed new rules will establish effluent limitations for 

the following parameters found in methane wastewater: Sodium 

adsorption ratio (SAR) and its individual constituents (sodium, 

magnesium, and calcium); salinity as measured by electrical 

conductivity (EC); ammonia; bicarbonate; total dissolved solids 

(TDS); and arsenic. All of these parameters are likely to affect 

beneficial uses of surface waters. 

Specifically, high levels of salinity, as measured by EC and 

SAR, may adversely impact native soils, native vegetation, and 

irrigated crops. Water with high salinity levels causes changes in 

soil structure that make water less available to plants and, at very 

high levels, can directly harm or kill plants. The EC levels of 

methane wastewater have a high salinity hazard with a mean value of 

between 2000-2300. The SAR value affects plant production by 

reducing the permeability of soils and slowing water infiltration. 

This lower availability of water reduces plant productivity. The 

SAR level of methane wastewater is high with a mean value of 34 to 

51. Soils with high clay content or with poor drainage are most 

vulnerable to these impacts. 

Salinity levels (EC) can also adversely impact aquatic life. 

During the 2003 rulemaking process, the Montana Department of Fish, 

Wildlife, and Parks raised these concerns. 

Bicarbonate can also be harmful to aquatic life. Methane 

discharges from Fidelity’s CX Field are characterized by bicarbonate 

concentrations of between 1400-1600 mg/L. 

Ammonia is listed as a toxic pollutant in Montana's Water 

Quality Standards. Ammonia can pose acute and chronic toxicity to 

aquatic life at extremely low levels. Methane discharges are 

characterized by ammonia concentrations averaging 2.0 mg/L. 

 

 2. Technological feasibility of the treatment requirements 

 

(a) Reinjection 

Reinjection of methane wastewater is a widespread control 

technique in many geologic basins, including the Wyoming portion of 

the Powder River Basin. The methane industry employs two types of 

reinjection. Where the water quality of the methane wastewater has 

extremely high salinity levels and is not suitable for any 

beneficial uses, the wastewater is reinjected into deep geologic 

formations through Class II injection wells under the Safe Drinking 

Water Act (SDWA), 42 USC 300f to 300j-26, Underground Injection 

Control (UIC) program. Where the water quality of the methane 

wastewater has lower salinity levels and is marginally suitable for 

some beneficial uses, the wastewater is reinjected into shallower 
19-10/6/05 44 MAR Notice No. 17-231

 

geologic formations through Class V injection wells under the UIC 

program. The purpose of the UIC program is to protect aquifers from 

the adverse impacts of reinjection and to protect aquifers that 

serve as sources of drinking water. 

In the San Juan Basin of Colorado almost 100% of methane 

wastewater is reinjected to deep geologic formations through Class 

II injection wells. In the West Uinta Basin of Utah, approximately 

97% of the methane wastewater is reinjected to deep geologic 

formations through Class II injection wells. In the Raton Basin of 

Colorado, approximately 30% of methane wastewater is reinjected to 

deep geologic formations through Class II injection wells. In the 

Raton Basin of New Mexico, 100% of methane wastewater is reinjected 

to deep geologic formations through Class II injection wells 

including methane development on Ted Turner’s Vermejo Ranch. 

In the Wyoming portion of the Basin, there are approximately 

160 active reinjection wells of the approximately 324 permitted by 

WDEQ, most of which are shallow Type V injection wells. The WDEQ 

has drafted three general permits authorizing reinjection. 

According to John Passehl (Personal Communication April 15, 2005), 

the Program Principal of UIC program at WDEQ, about 25 companies 

have done reinjection including Anadarko, JM Huber, Bill Barrett, 

Continental Industries, Devon, Double Eagle, Marathon, McCartney, 

Merritt, Northwestern, Petrox, Prima, and Wolverine. Nance 

Petroleum is reinjecting wastewater from its methane operations into 

shallow sandstone formations just south of the Montana board in 

Hanging Woman Basin, a tributary of the Tongue River. 

Achieved reinjection rates are highly dependent on sitespecific conditions and vary widely within a range of 12 to 117 gpm 

per reinjection well. Currently approximately 150,000 

gallons/day/well is being reinjected. The WDEQ limits reinjection 

to aquifers with the same classification as methane wastewater to 

ensure the water remains suitable for beneficial use. 

 

(b) Reverse Osmosis 

Reverse osmosis is used to treat methane wastewater in the San 

Juan and Raton Basins of Colorado. The WDEQ has approved one NPDES 

permit requiring treatment using reverse osmosis prior to discharge. 

The EPA issued a permit requiring reverse osmosis treatment of 

methane wastewater on the Southern Ute Indian Reservation (NPDES 

Permit COG-075000). Encana Oil and Gas, Inc. is also using reverse 

osmosis to treat methane wastewater in Colorado, Permit No. COG600633, Colorado Water Quality Control Division, Department of 

Public Health and Environment. 

Devon Energy has submitted an application with Region 8 of the 

EPA for a NPDES permit for 5-15 pilot projects on the Wind River 

Indian Reservation and is proposing to use reverse osmosis. The EPA 

is currently drafting the NPDES permit. 

Hydrometrics, Inc., has demonstrated a system by which 95% of 

treated water may be discharged to the surface as usable quality 

water. The company uses a Weak Acid Cation Resin treatment as part 

of their "High Efficiency Reverse Osmosis" (HERO) process to treat 

methane wastewater to remove major cations, anions, and trace 

constituents. 

 (c) Ion Exchange Technology 

Several companies in the Wyoming portion of the Basin are using 

Higgins Loop and Emit ion exchange technology to treat methane 

wastewater prior to discharge. 
19-10/6/05 45 MAR Notice No. 17-231

 

The Montana Department of Environmental Quality recently 

approved a MPDES permit for Powder River Gas, LLC, which intends to 

implement ion exchange treatment technology prior to discharging to 

the Tongue River. Fidelity has proposed using a similar ion 

exchange technology to treat wastewater prior to discharge into the 

Tongue River. Ion exchange technology is capable of reducing sodium 

levels to less than 0.5 mg/L and SAR levels to below 0.1. The 

treatment technology is capable of reducing EC levels to about 233 

μmhos/cm and total dissolved solids to about 170 mg/L. 

In summary, reinjection into suitable geologic formations to 

the maximum extent feasible based on site-specific conditions and 

treatment of the remaining wastewater prior to discharge is 

technologically feasible. As demonstrated above, reinjection and 

treatment are being employed by methane operators in the Basin of 

Montana and Wyoming and other geologic basins in the West. 

 

 3. Economic feasibility 

 

Reinjection and treatment is not only economically feasible, 

but also profitable for the methane industry. Assuming a gas price 

of $3.61 Mcf, methane companies will still earn a 23%-36% return on 

investment in Montana when reinjecting wastewater into suitable 

shallow geologic formations to meet the zero discharge requirement. 

If an operator obtains a limited waiver from the zero discharge 

permit requirement because reinjection of 100% of the wastewater is 

not technically feasible, and uses a combination of shallow 

reinjection wells to meet the zero discharge requirement and reverse 

osmosis technology to treat the volume of wastewater, the operator 

will still earn a 27%-31% return on investment in Montana. While 

cost data on ion exchange treatment technology are not available 

from the industry, use of such technology is clearly profitable for 

the industry given the fact that Powder River Gas, LLC, is currently 

using the technology in Montana and Fidelity has proposed using it. 

 The petitioners rely upon the EPA Region VIII draft economic 

analysis for several control and treatment options being considered 

for the coal bed methane industry, including zero discharge through 

reinjection and reverse osmosis treatment technology. See Petition, 

Exhibit C, "Guidance for Developing Technology-Based Limits for Coal 

bed Methane Operations: Economic Analysis of the Powder River 

Basin". The EPA document was prepared using economic and 

engineering data provided by the methane industry. The EPA report 

assesses economic impacts on the methane industry caused by 

implementing technology-based requirements in terms of impacts to 

economically recoverable methane reserves, number of projects 

developed in the basin, and royalties and taxes generated. Where 

applicable primary source information was available in the draft 

document, it was used. 

The EPA Report found that wellhead gas price had a significant 

effect on the economic impact of technology-based effluent 

limitations. The EPA assessed the economic impacts of the methane 

industry assuming a conservative wellhead price of $1.75 Mcf. The 

average wellhead price between 1986-1999 was $2.05 per Mcf. The EPA 

estimated an equilibrium wellhead price of $2.72 per Mcf. The 

average realized well head price in 2001 was $4.12 per Mcf. The 

Department of Energy conservatively predicts a wellhead price of 

$2.88 per Mcf in 2005 and $3.29 in 2010 Mcf. In recent years, 

realized wellhead prices in the Basin have exceeded $5.00 Mcf. 

At a conservative well head price of $1.75 Mcf, the 

Petitioner's estimate that methane production in the basin will 

generate almost $30 billion in profits to the industry. If the 

wellhead price of gas remains above $1.75, the predicted economic 
19-10/6/05 46 MAR Notice No. 17-231

 

impacts on methane industry will be significantly less than those 

predicted by EPA. 

 

4. Environmental Feasibility 

The proposed rules establish minimum treatment requirements 

that minimize the degradation to the environment compared to other 

disposal methods typically used for coal bed methane wastewater. 

See next section. 

 5. Other Alternatives to the Proposed Control and Treatment 

Requirements Considered by the Petitioners

 

Alternatives to the requirements to reinject CBM wastewater 

into Class V wells as a means to achieve zero discharge have been 

rejected for the following reasons: 

 

a. Reinjection into Class II wells would make it impossible 

for farmers and ranchers to use the reinjected water due to the 

expense of drilling and operating deep wells. In addition, the CBM 

water would likely become contaminated by the much worse water 

quality found in most deep geologic formations. 

b. Evaporation pits were eliminated as a means to achieve zero 

discharge due to the loss of the water resource to future 

generations and the fact that such impoundments disturb large areas 

that would need to be reclaimed. 

c. In-channel impoundments using infiltration and evaporation 

as a means of disposal were rejected because such impoundments could 

result in unauthorized discharges to surface waters resulting from 

impoundment failure or overflow and would also cause saline seep. 

d. Off-channel impoundments using infiltration and evaporation 

as a means of disposal were rejected because such impoundments would 

capture natural surface runoff, interfere with the hydrological 

cycle, and cause impacts to vested water rights. 

e. Land application of CBM wastewater was rejected because 

such disposal methods could adversely impact soil structure, kill 

native vegetation, contaminate shallow aquifers, and increase salt 

loading to nearby streams through return flows. 

5. Concerned persons may submit their data, views or 

arguments, either orally or in writing, at the hearings. Written 

data, views or arguments may also be submitted to the Board 

Secretary at Board of Environmental Review, 1520 E. Sixth Avenue, 

P.O. Box 200901, Helena, Montana, 59620-0901; faxed to (406) 444-

4386; or emailed to ber@mt.gov, no later than 5:00 p.m., December 2, 

2005. To be guaranteed consideration, mailed comments must be 

postmarked on or before that date. 

 

6. The Board of Environmental Review will preside over and 

conduct the hearings. 

 

7. The Board maintains a list of interested persons who wish 

to receive notices of rulemaking actions proposed by this agency. 

Persons who wish to have their name added to the list shall make a 

written request that includes the name and mailing address of the 

person to receive notices and specifies that the person wishes to 

receive notices regarding: air quality; hazardous waste/waste oil; 

asbestos control; water/wastewater treatment plant operator 

certification; solid waste; junk vehicles; infectious waste; public 

water supplies; public sewage systems regulation; hard rock (metal) 

mine reclamation; major facility siting; opencut mine reclamation; 
strip mine reclamation; subdivisions; renewable energy grants/loans;

wastewater treatment or safe drinking water revolving grants and 

loans; water quality; CECRA; underground/above ground storage tanks;

MEPA; or general procedural rules other than MEPA. Such written 

request may be mailed or delivered to the Board Secretary at Board 

of Environmental Review, 1520 E. Sixth Ave., P.O. Box 200901,

Helena, Montana 59620-0901; faxed to (406) 444-4386; emailed to

ber@mt.gov; or may be made by completing a request form at any rules 

hearing held by the Board. 

 8. The bill sponsor notice requirements of 2-4-302, MCA, do 

not apply. 

 

Reviewed by: BOARD OF ENVIRONMENTAL REVIEW 

 

 

 

John F. North BY: Joseph W. Russell 

JOHN F. NORTH JOSEPH W. RUSSELL, M.P.H., 

Rule Reviewer Chairman 

 

Certified to the Secretary of State September 26, 2005. 

19-10/6/05 47 MAR Notice No. 17-231

 
 48 

 
REFERENCES 

Advanced Resources International, 2002, “Powder River Basin Coal Bed Methane 

Development and Produced Water Management Study”, U.S. DOE, Office of Fossil Energy 

and NETL, Strategic Center for Natural Gas, November 2002. 

Arthur et al 2003, “Coal Bed Methane Produced Water: Management and Beneficial Use 

Alternatives, 2003. 

Arthur et al, 2005, “Coal Bed Methane in the Powder River Basin of Montana,” Ground 

Water Protection Council's Annual Forum, Portland, Oregon, September, 2005. 

Ayers and Westcott 1994, “Water Quality for Agriculture”, IRRIGATION AND DRAINAGE 

PAPER, 29 Rev. 1 (Reprinted 1989, 1994), 

http://www.fao.org/DOCREP/003/T0234E/T0234E00.htm#TOC 

Batmanghelidj 1995, “Your Body’s Many Cries for Water”, Global Health Solutions, Falls 

Church, VA., 1995. 

BLM 2003, “Final Statewide Oil and Gas Environmental Impact Statement and Proposed 

Amendment of the Powder River and Billings Resource Management Plans,” Bureau of Land 

Management (Miles City and Billings Field Offices), the Montana Board of Oil and Gas 

Conservation and the Montana Department of Environmental Quality, January 2003. 

BLM 2003a, Record of Decision, Bureau of Land Management, April 2003. 

BoR 2003, “Desalting Handbook for Planners, 3rd Edition”, Bureau of Reclamation, July 

2003. 

Cox, D 2001, “Coal bed Methane in the Rockies, Christmas Past, Present and Future,” SPE 

Symposium on CBM in the Western US, Denver, CO, Jan 2001. 

CSU, http://www.coopext.colostate.edu/TRA/PLANTS/index.html#http://www.colostate.edu/

Depts/CoopExt/TRA/PLANTS/sar.html

EPA 1997, “Guide to Documenting Cost and Performance for Remediation Projects”, Federal 

Remediation Technologies Roundtable, November 1997. 

EPA 2002, “Protecting Drinking Water through Underground Injection Control,” Drinking 

Water Pocket Guide #2 EPA 818-K-02-001, January 2002. 

 

EPA 2005, “Current National Recommended Water Quality Criteria”, 

http://www.epa.gov/waterscience/criteria/wqcriteria.html 

Israelsen and Hanson, Irrigation Principles and Practices, 1950. 

 49 

 
Holdren and Nelson, “Water Supply and Water Quality in Totten Reservoir, Montezuma

County, Colorado Technical Memorandum No. 8220-98-09”, from website: 

http://www.usbr.gov/pmts/eco_research/9809.html#9809d 

Likwartz. D. 2005, Wyoming Oil and Gas Commission, personal communication, 2005. 

MBMG 2001, Montana Bureau of Mines and Geology, Groundwater Information Center 

Database, http://mbmggwic.mtech.edu/, March 2001. 

McLellan M.W. et al 1990, Cross sections showing the reconstructed stratigraphic framework 

of Paleocene rocks and coal beds in the northern and central Powder River Basin, Montana 

and Wyoming. USGS Misc. Invest Map I1959A. 

MBOGC 200, Record of Decision, Montana Board of Oil and Gas Conservation, March 2003. 

ORNL 2002, “Methane Extraction and Carbon Sequestration”, Oak Ridge National 

Laboratory, Review Vol. 35/No. 2, 2002. 

Osborne and Adams 2005, “Coal Bed Natural Gas and Water Management in the Powder 

River Basin”, Southwest Hydrology, Vol. 4/No.4, November 2005. 

Palmer and Varzi, 2004, “Preliminary Changes in a CBM Reservoir during Production, an 

Update and Implications for CO2 Injection,” 2004 International CBM Symposium University 

of Alabama, May 2004. 

Pritchett, R. W., 2002, “Hanging Woman Basin Project,” prepared for Caribou Livestock 

Montana, LLC, February 2002. 

 

Rice, Ellis, and Bullock 2000, “Water Co-Produced with Coal Bed Methane”. 

Thyne, G, 2005, “Produced Water Management and Beneficial Uses,” Petroleum

Environmental Research Forum, Annapolis, Maryland, November 2005. 

USGS 2000, “Water Co-produced with Coal Bed Methane in the Powder River Basin, 

Wyoming: Preliminary Compositional Data”, USGS Report 00-372, 2000. 

USGS 2001, “Water-Resources Investigations Report 01-4279”, December 2001. 

USGS 2005, Water Quality Reports, as found on website: 

http://wy.water.usgs.gov/projects/qw/data2005/index.htm

Wheaton and Lopez 2005, Montana Bureau of Mines and Geology, Personal Communication, 

2005. 

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DISTRIBUTION LIST 

 

 2 MS0755 Mike Hightower, 6202 

 2 MS0706 Allan Sattler, 6113 

 2 MS0706 Malynda Aragon, 6118 

 2 MS0918 Central Technical Files, 8945-1 

 2 MS0899 Technical Library, 9616 

10 William Hochheiser, Manager 

Oil and Gas Environmental Research 

U.S. Department of Energy

Office of Fossil Energy (FE-30) 

1000 Independence Ave. SW 

Washington, DC 20585 

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