Update on EPA s Clean Water Act Review of the Coalbed Methane (CBM) Industrial Sector. Overview for OK Independent Petroleum Association April 3, 2008

Transcription

1 Update on EPA s Clean Water Act Review of the Coalbed Methane (CBM) Industrial Sector Overview for OK Independent Petroleum Association April 3, 2008

2 Presentation Overview Provide background on EPA s Detailed Study on the coalbed methane (CBM) industry sector. Overview of Clean Water Act (CWA), effluent guidelines, and effluent guidelines planning Overview of scope and schedule for CBM Detailed Study. Provide update on current data gathering activities in support of developing an upcoming survey of CBM operators. April 3, 2008 Page 2 of 17

3 EPA Regulation of Discharges to Surface Waters The major environmental law governing surface water discharges is the Clean Water Act (CWA). Goals of the Clean Water Act are: - Restore and maintain the chemical, physical and biological integrity of the Nation's waters for the protection and propagation of fish, shellfish, and wildlife and provides for protection of human health and recreation in and on the water (e.g., fishing, swimming, boating); and - Zero discharge of pollutants to navigable (surface) waters. EPA and States implement the CWA through publication of regulations and discharge permits for point sources of wastewater pollution. April 3, 2008 Page 3 of 17

4 EPA Regulation of Discharges to Surface Waters Set Standards Technology-Based Approach Effluent limitation guidelines (ELG) (national standards) Best professional judgment (BPJ) (site specific) Water Quality-Based Approach EPA and States develops water quality standards: Designated uses, Criteria to protect those uses, Anti-degradation policy Implement Permit Issue individual permit for a single facility or a general permit for a broad group of similar facilities. Permits must include the most stringent requirements based on water quality and/or technology-based approach. Ensure permits limits are met through compliance assistance, inspections, audits, environmental studies, and review of discharge monitoring reports. NPDES permits should be renewed every five years. April 3, 2008 Page 4 of 17

5 Technology-based Approach: Effluent Guidelines EPA establishes effluent limitations guidelines (ELGs) for categories of U.S. industry. These ELGs are based on technologies that are available and economically achievable for the industrial sector. The ELGs for the oil and gas extraction industry are located in EPA s Federal regulations (40 CFR 435) and were issued in stages: 1979 (onshore & beneficial use), 1993 (offshore), 1996 (coastal), and synthetic-based drilling fluids (SBF) issued in The Oil and Gas Extraction ELGs do not currently regulate pollutant discharges from CBM extraction operations. April 3, 2008 Page 5 of 17

6 Effluent Guidelines Planning The CWA requires EPA to annually review existing ELGs and to revise such regulations if appropriate. The 1987 Clean Water Act Amendments added Section 304(m), which requires EPA to publish a plan every two years after allowing for public comment. In these biennial plans the Agency must announce its schedule for: - Performing its annual reviews of existing ELGs, and - Revising ELGs rulemakings initiated as a result of these annual reviews. More information at: April 3, 2008 Page 6 of 17

7 Effluent Guidelines Planning: Goals Involve stakeholders from the start of the Plan. Assure transparent decisionmaking. Evaluate sound information against broad and balanced decision criteria. April 3, 2008 Page 7 of 17

8 Effluent Guidelines Planning: Process Screening level review (see below) to identify categories needing further investigation Prioritizing candidates In-depth review ( Detailed Study ) to characterize the prioritized industrial sectors Decide on course of action Present findings in final biennial plan Options can include no further action necessary, continue study, identify for ELG rulemaking. April 3, 2008 Page 8 of 17

9 Identification of CBM Sector for Detailed Study Higher natural gas prices and advances in drilling technology have helped prompt recent CBM development. In 2004, CBM accounted for about 10.4% of the total U.S. natural gas production and is expanding in multiple basin across the U.S. DOE/EIA expects CBM production to remain an important source of the domestic natural gas. For example, ~ 5% of WY CBM reserves have been produced Source: Annual Energy Outlook 2006 (DOE/EIA) April 3, 2008 Page 9 of 17

10 CBM Detailed Study: National in Scope Note: Alaska also has CBM reserves Source: Evaluation of Impacts to Underground Sources of Drinking Water by Hydraulic Fracturing of Coalbed Methane Reservoirs, EPA 816-R , June April 3, 2008 Page 10 of 17

11 Example of CBM Produced Water Chemistry Changing with Geographic Location: Powder River Basin (MT/WY) Source: USGS Open-File Report pubs.usgs.gov/of/2000/ofr /of pdf April 3, 2008 Page 11 of 17

12 Coalbed Methane Technology Options (Examples) CBM produced water of a suitable quality can be used for beneficial use. Key controls are TDS and Sodium Adsorption Ratio (SAR). Beneficial use technologies include sub-drip irrigation, irrigation, livestock watering all either with or without treatment. CCIX resin contract chamber (Powder River Basin, WY) Irrigation with CBM Produced Water (Powder River Basin, WY) Treatment options include iron oxidation (aeration), coagulation/precipitation, reverse osmosis (RO), countercurrent ion exchange (CCIX), fixed bed ion exchange, precipitation, surface impoundments, downhole separation, and re-injection. Reduces TDS, SAR, and metals content. Iron oxidation is typically performed at discharge locations as part of BMPs to reduce discoloration of discharge point. April 3, 2008 Page 12 of 17

13 Potential Environmental Impacts from Coalbed Methane Produced Water Discharges Impacts to surface water from discharge of CBM produced water can be severe depending upon the quantity and quality of the CBM produced water. Aquatic and benthic communities can be adversely impacted (e.g., decrease in species diversity, density) by the constituents in CBM produced water (e.g., TDS, sodium, chloride, metals, organics). April 3, 2008 Page 13 of 17

14 EPA CBM Information Collection Request (ICR) EPA is developing a questionnaire that will be used to collect information from CBM projects The questionnaire will collect information specific to individual CBM projects The questionnaire will be sent to a randomly drawn sample of projects not every producer will receive a questionnaire and not every project will be selected. EPA intends to collect technical, economic, and environmental data reflecting the diversity within this sector EPA will use this information to assess technological and economic achievability of produced water controls, and potential environmental impacts Final 2006 Plan April 3, 2008 Page 14 of 17

15 EPA CBM Questionnaire The data to be collected by the questionnaire includes: Information about CBM formations; CBM production levels; Type of CBM drilling; Produced water characteristics and management; Design, capacity, and operation of current CBM-produced water treatment technologies and practices; Costs of produced water treatment, management, or disposal; and Economic and financial data, such as revenues and net income, assets and liabilities, operating costs and expenses (e.g., depreciation, royalty payments, severance tax payments), and April 3, 2008 Page 15 of 17

16 Identification of Schedule and Next Steps Final 2006 Plan Published 21 December 2006 Stakeholder Teleconferences (June/July 2007) Site Visits and Meetings (Summer/Fall 2007) First Federal Register notice (January 25, 2008) - comment period will close on April 24, 2008 Second Federal Register notice (late Spring 2008) - 30 day public comment period Distribute Survey to CBM Operators (Fall 2008) Present Preliminary Results (October 2009) April 3, 2008 Page 16 of 17

17 For More Information Further updates on the CBM ICR and EPA s effluent guidelines program plan can be found at: EPA CBM ICR contacts are: Name Lead Phone Carey Johnston, P.E. Project Manager, Engineering (202) johnston.carey@epa.gov James Covington Economist (202) covington.james@epa.gov April 3, 2008 Page 17 of 17