MEMORANDUM

TO: Record

FROM: EPA

DATE: March 8 , 2013

SUBJECT: Changes to CBM Operating Status Between 2008 and 2010 , DCN CBM007 15

This memorandum summarizes changes in CBM o perating status between 2008 and 2010 for projects 1 that discharged produced water to surface water as of 2008

. E PA reviewed information

on operators in six of the seven discharging basins ( Appalachian, Black Warrior, Cahaba, Green River, Powder River , and Raton) to determine whether:

**•** The operator is still producing CBM ; and

**•** The operator is still producing water

.

EPA did not review information for operators in the Illinois Basin because the State of Illinois provides very little informa tion on oil and gas production. EPA reviewed the publicly availab le
database s listed below:

**•** Colorado Oil and Gas Conservation Commission (COGCC, 2012) (Raton Basin): http://cogcc.state.co.us/

**•** Geological Survey of Alabama

– Oil and Gas Board (GSA

- OGB, 2012) (Black Warrior, Cahaba) : http://www.gsa.state.al.us/ogb/production.aspx

**•** Montana Department of Natural Resource Conservation

- Board of Oil and Gas Conservation (MT DCNR

- BOGC, 2012) (Powder River) : http://www.bogc.dnrc.mt.gov/WebApps/DataMiner/Production/ProdAnnualOperGas.asp

x

**•** Pennsylvania Department of Conservation and Natural Resources (PA DCNR, 2012) (Appalachian) : http://www.dcnr.state.pa.us/topogeo/cbm/ofreport1101.aspx

**•** West Virginia Department of Environmental Protection (WV DEP, 2012) (Appalachian) : https://apps.dep.wv.gov/oog/wellsearch_new.cfm

**•** Wyoming Oil and Gas Conservation Commission (WYOGCC, 2012) (Powder River, Green River): http://wogcc.state.wy.us/

Operator Changes For the existing sour ce analysis, EPA wanted to determine the most recent operating status of the 74 direct discharging projects that were identified in the Detailed Questionnaire as dischargers in

1 EPA defined project as a well, group of wells, lease, group of leases, or some other recognized unit that the establishment operates as an economic unit when making production decision.Memorandum March 8, 2013 Page 2

2008. 2 EPA determined that seven of the 74 direct discharging projects were no longer producing either CBM or water in 2010 . EPA did not include these projects in the existing source analysis. Table 1 summarizes the key changes and whether the operator was included in

EPA’s existing source analysis.

Table 1. 2010 CBM Data Review Findings for Surface Discharging Projects Operator

Name 2010 Findings Existing Source Analysis Green River ( Wyoming )

Pioneer Project was temporarily abandoned according

to non

- CBI screener comment

. Colorado website showed no production for 2010. Assumed this project is shut in (no lon ger operating). Not
included in analysis.

Powder River Basin ( Wyoming )

DNR No CBM or water production reported in 2010
or later ; no change in operator. Assumed this project is shut in. Not included in analysis.

Duncan Oil No CBM or water production reported in 2010
or later ; no change in operator

. Assumed this project is shut in. Not included in analysis. Hilcorp No CBM or water production reported in 2010
or later ; no change in operator. Assumed this project is shut in. Not included in analysis.

M e rit Energy (2 projects) Producing from some Powder River Wyoming wells, but many wells have been acquired by Langl e y Energy (through Saga Petroleum) and
Atomic Oil and Gas

. Saga shut in the wells and Langl e y has not started producing fr om those wells as of early 2012 . The wells retained by Merit Energy are no longer (2010 and later) producing water. Not included in the analysis
because there is no water production or the acquired projects are assumed shut in

.

Peabody
Natural Gas No CBM or water production reported in 2010
or later ; no change in operator. Assumed this project is shut in. Not included in analysis.

2 See the Technical Development Document for the Coalb ed Methane Industry ((EPA

- HQ

- OW

- 2010

- 0824, DCN:
CBM00 669) and Economic Assessment for Existing and New Projects in the Coalbed Methane Industry (EPA

- HQ

OW

- 2010

- 0824, DCN: CBM00 680) for more information about EPA’s analyses.