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Coalbed Methane
We've been busy the past couple of weeks working on learning as much as we can about coalbed methane and water produced with natural gas during a coalbed methane well's lifetime. West Virginia is accepting comments for the revised general permit for land application of coalbed methane produced water.
While the new permit is different from the general permit for land application of liquid drill waste in that the allowed chloride concentrations are much lower (maximum of 1,000 mg/l), coalbed methane produced water would be discharged on the forest floor daily for years (just how long depends on the well and location).
Bernardo Garcia of the Office of Oil and Gas at the state's Department of Environmental Protection opened his office to us on 20 August where we spent hours examining discharge reports, vegetation surveys, permit applications and more so that we'd be able to understand how the program works. A rough survey of discharge reports seems to indicate that the majority of discharges have chloride under 250 mg/l and we saw wells where the chloride was under 100 mg/l. There were instances where the chloride concentration went over 1,000 mg/l (some wells have produced water with highly variable concentrations of chloride) but those instances were not usual.
We also saw reports for surface water monitoring. Chloride does not stay in soil and will eventually end up in ground and surface water. There were instances where there were momentary surges in chloride in surface water but they seemed unrelated to land application. It's hard to be absolutely sure though.
We'll be making comments for the permit but we believe that the state is moving in the right direction with baseline laboratory analysis of ground or surface water and soil before land application begins and continual analysis during the long-term discharge at each site. A hydrogeologic study will be required for the site as part of the permit application for operators expecting to discharge at the upper concentrations of chloride allowed. The state will require the monitoring of some heavy metals (barium and selenium).
Coalbed methane used to be released into the atmosphere -- it was a way to remove methane from coal seams before mining. Today coalbed methane is about 5% of the country's total natural gas production and that level is increasing. The U.S. EPA didn't determine effluent limitation guidelines (ELGs) for coalbed methane when they made guidelines for the oil and gas industry (40CFR435) and the EPA is in the midst of a study toward such guidelines. The docket for that study provides a wealth of source material.
Two items of local interest in the docket are a report on a visit to two wells operated by CDX in West Virginia (docket number EPA-HQ-OW-2006-0771-0968) and notes from a teleconference between the EPA and people at the state's Department of Environmental Protection (EPA-HQ-OW-2006-0771-1010). The teleconference unfortunately shows just how little information the DEP had when they were creating the original permit in 2007. We can't provide direct links for these documents, but they and others can be found on the docket (on our computer the CDX well report was on page 155 of the docket) and downloaded.
Part II of the EPA's 2006 Technical Support Document for the Effluent Guidelines program (section 6) was useful in providing information about the regulatory framework, various state programs, and methods of dealing with coalbed methane produced water.
Another document that has been helpful was created at Canada's The Pembina Institute -- Protecting Water, Producing Gas. This lengthy paper focuses on issues with coalbed methane exploration but also deals with conventional and nonconventional (tight shales like Marcellus) natural gas exploration and environmental issues.
While the new permit is different from the general permit for land application of liquid drill waste in that the allowed chloride concentrations are much lower (maximum of 1,000 mg/l), coalbed methane produced water would be discharged on the forest floor daily for years (just how long depends on the well and location).
Bernardo Garcia of the Office of Oil and Gas at the state's Department of Environmental Protection opened his office to us on 20 August where we spent hours examining discharge reports, vegetation surveys, permit applications and more so that we'd be able to understand how the program works. A rough survey of discharge reports seems to indicate that the majority of discharges have chloride under 250 mg/l and we saw wells where the chloride was under 100 mg/l. There were instances where the chloride concentration went over 1,000 mg/l (some wells have produced water with highly variable concentrations of chloride) but those instances were not usual.
We also saw reports for surface water monitoring. Chloride does not stay in soil and will eventually end up in ground and surface water. There were instances where there were momentary surges in chloride in surface water but they seemed unrelated to land application. It's hard to be absolutely sure though.
We'll be making comments for the permit but we believe that the state is moving in the right direction with baseline laboratory analysis of ground or surface water and soil before land application begins and continual analysis during the long-term discharge at each site. A hydrogeologic study will be required for the site as part of the permit application for operators expecting to discharge at the upper concentrations of chloride allowed. The state will require the monitoring of some heavy metals (barium and selenium).
Coalbed methane used to be released into the atmosphere -- it was a way to remove methane from coal seams before mining. Today coalbed methane is about 5% of the country's total natural gas production and that level is increasing. The U.S. EPA didn't determine effluent limitation guidelines (ELGs) for coalbed methane when they made guidelines for the oil and gas industry (40CFR435) and the EPA is in the midst of a study toward such guidelines. The docket for that study provides a wealth of source material.
Two items of local interest in the docket are a report on a visit to two wells operated by CDX in West Virginia (docket number EPA-HQ-OW-2006-0771-0968) and notes from a teleconference between the EPA and people at the state's Department of Environmental Protection (EPA-HQ-OW-2006-0771-1010). The teleconference unfortunately shows just how little information the DEP had when they were creating the original permit in 2007. We can't provide direct links for these documents, but they and others can be found on the docket (on our computer the CDX well report was on page 155 of the docket) and downloaded.
Part II of the EPA's 2006 Technical Support Document for the Effluent Guidelines program (section 6) was useful in providing information about the regulatory framework, various state programs, and methods of dealing with coalbed methane produced water.
Another document that has been helpful was created at Canada's The Pembina Institute -- Protecting Water, Producing Gas. This lengthy paper focuses on issues with coalbed methane exploration but also deals with conventional and nonconventional (tight shales like Marcellus) natural gas exploration and environmental issues.
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