Coalbed Methane Produced Water In The Western Us

groundwater monitoring to help determine the degree of hydrological connection, if any, between the impoundment and surface water (EPA, 2002a, 2002b).


The six western states included in this study have varying approaches to produced water management. Water quality standards being applied to management of produced water may be narrative or numeric. Agencies have greater latitude in translating narrative criteria to permit limits for CBM produced water discharge and enforcement of provisions of discharge than with numeric criteria. State-specific approaches for regulating CBM produced water for the five states that presently have active CBM development are described below with respect to water rights issuance, CBM production permitting, and CBM water management. Produced water management for conventional oil and gas operations is described for North Dakota, where no CBM production presently occurs. The states are presented in a general geographical and geological sequence, which groups states that produce CBM from shared basins; this presentation order is designed to facilitate comparison of produced water management approaches between states that may share CBM basins with similar geological and hydrogeological conditions. North Dakota is described first, followed by Montana and Wyoming (with the shared Powder River Basin), Utah and Colorado (which share basin similarities in the Uinta and Piceance), and New Mexico (which shares the San Juan and Raton basins with Colorado).

North Dakota

The North Dakota State Water Commission, through the Office of the State Engineer, oversees issues related to water rights. The North Dakota Department of Health's Environmental Health Section administers the state's water quality rules and regulations, reviews and issues NPDES permits for surface discharges, and administers the UIC program for the state, with exception of Class II injection wells, which are overseen by the North Dakota Industrial Commission, through its Oil and Gas Division (Table 3.1). The latter agency also has jurisdiction over oil and gas exploration and production permits on state and private lands. Although no CBM production has yet occurred in North Dakota (EIA, 2009), management options for produced water from conventional oil and gas operations are described here for completeness.

The North Dakota Source Water Protection Program, developed in the late 1990s and approved by the EPA, is an umbrella under which North Dakota fulfills the provisions of the SDWA.19 A primary goal of the program is to prevent the contamination of public

19See (accessed March 4, 2010).

water supplies, including surface water and groundwater sources (Table 3.1). The program includes designating a well head protection area for groundwater-dependent public water systems, or a source water protection area for surface-water-dependent public water systems. Both numerical and narrative standards are established to preserve the state's water resources (Schafer and Sagsveen, 1999).

Underground injection, disposal to surface waters, and disposal to the ground are the primary management options in the state, with respect to produced water management from oil and gas production activities. Any saltwater liquids or brines produced during oil and gas operations are considered wastes and are required to be processed and disposed of in ways that do not pollute freshwater supplies and are not allowed to pool on the surface or infiltrate the soil. Although beneficial uses for produced water are recognized by the state (Table 3.1), reinjection is the preferred method of disposal for 96 percent of all produced water from conventional oil and gas operations (Clark and Veil, 2009). Discharge to surface waters is permitted only if the discharge does not endanger public health or degrade water quality. Surface facilities for disposal of produced water are acceptable primarily in storage tanks constructed of materials resistant to the effects of saltwater liquids, brines, or chemicals. Open ponds and pits are generally allowed only through special approval or in the case of an emergency (NDIC, 2006).


Montana is the only state in the West that addresses CBM produced water directly in its statutes, with several state agencies responsible for various aspects of CBM development and produced water management on state- and privately owned lands. The Montana Department of Natural Resources and Conservation (DNRC) oversees issues of water rights, the Montana DEQoversees surface discharges through MPDES, and the Montana Board of Oil and Gas Conservation oversees oil and gas operations, including those for CBM, and has been delegated jurisdiction by EPA over the UIC program for Class II wells (see Table 3.1).20

The specification for CBM activities and produced water statutes in Montana stems from an order in 1999 when the DNRC created the Powder River Basin groundwater area for private and state land (but not tribal land). In addition to allowing for reduction of water levels in targeted aquifers near CBM project areas, this order included the need for monitoring water resources before, during, and after CBM production. The order also includes a requirement for the CBM operator to offer mitigation agreements to owners of wells or springs that may be impacted by CBM activities.21

20See (accessed March 4, 2010).

21See (accessed March 4, 2010).

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