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Management and Effects of Coalbed Methane Produced Water in the Western United States
CHAPTER FIVE
Environmental Effects of Coalbed Methane Development and Produced Water Management
An element of the committee’s charge includes identifying documented positive and negative effects of coalbed methane (CBM) produced water on the quality and quantity of surface water and groundwater resources, soil resources, and ecological communities. This chapter is weighted toward discussion about the Powder River Basin because large volumes of CBM produced water are discharged to surface waters or impoundments or are being put to beneficial use there, relative to other western CBM basins. Correspondingly, most of the scientific literature on the environmental effects of CBM produced water and most of the controversy that has precipitated litigation or media attention about CBM produced water management has originated from research conducted in this basin. With deep re-injection the primary method of CBM produced water management in the other western CBM basins, fewer perceived or documented effects on the surface environment or shallow groundwater have contributed to less litigation, less media attention, and fewer studies of environmental effects being completed in those basins. Data that characterize the quality of waters in the geologic formations used for reinjection are not readily available, but can be inferred from borehole logs.
Reports from private citizens on the effects of CBM produced water on the environment were also instrumental in focusing some committee attention to examining potential research or information gaps associated with CBM produced water management. This chapter contains a review of registered citizen complaint information from several official state websites and identifies several cases in which the complaints were brought to court.
GROUNDWATER
The primary substantiated effects of CBM produced water on groundwater resources include (1) drawdown of groundwater levels in coalbeds as a result of pumping water from coalbeds during CBM extraction and (2) changes in groundwater quality associated with
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Management and Effects of Coalbed Methane Produced Water in the Western United States
CBM produced water in surface impoundments. These effects and their potential causes are addressed below. Although adverse effects from hydraulic fracturing have not been documented in CBM fields, the issue is of concern to the public. A brief discussion of hydraulic fracturing is included at the end of this section.
Effects of Groundwater Withdrawal on Aquifers
Research demonstrates that a principal effect of CBM withdrawals on groundwater is reduction of water volume and hydrostatic head within coalbeds from which methane is being extracted. Typically, the CBM well is pumped to reduce the hydrostatic pressure in the coalbed to a pressure approximately equal to atmospheric. However, water is still retained within the coal and generally the head level of water in the coalbed is maintained relatively close to the uppermost physical surface of the coalbed. Any effects of water withdrawal from methane-bearing coalbeds on water levels in other aquifers are a function of the depth of the target coalbeds and the degree of hydraulic connection between CBM targets and the other local or regional aquifers (see Chapter 2 for discussion of hydraulic connectivity).
Pumping water during CBM extraction in basins with deep methane-bearing coals, such as the San Juan, Raton, Uinta, and Piceance basins, is unlikely to cause lowering of the water table of shallow alluvial aquifers because of lack of hydraulic connectivity between the deep coals and shallow aquifers coupled with the great vertical separation between the coalbeds and the shallow groundwater systems (upward of thousands of feet; see also Chapter 2). Typically, methane-bearing coalbeds in these basins are bounded above and below by either aquitards or aquicludes (see Chapter 2) that are responsible for both the positive hydrostatic pressure within the coalbeds and the lack of hydraulic connectivity or communication between the coalbeds and overlying and underlying aquifers. An exception to this circumstance is that reported by Riese et al. (2005) for the San Juan Basin, in which the authors documented movement of water from below the methane-bearing coalbeds upward and into the coalbeds (see Chapter 2).
In contrast, depths to methane-bearing coalbeds in the Powder River Basin are relatively shallow and less consolidated than those of the other western CBM basins (see Chapter 2). Consequently, the coalbeds generally consist of porous and permeable formations capable of releasing large amounts of water during methane production (see Table 2.1). Some of the coalbeds or fringes of coalbeds in the Powder River Basin are also sufficiently close to the land surface that they serve as sources of domestic, residential, wildlife, and livestock water supply (Frost et al., 2010; Wheaton et al., 2005; Campbell et al., 2008). These supplies often surface as flowing springs and wells. In some instances wells are drilled into the coalbeds and the water is used for stock watering or domestic supplies. However, direct physical connections between water-bearing coalbed aquifers from which CBM is being extracted and other alluvial groundwater that supplies water wells and springs in the basin are not widely
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Management and Effects of Coalbed Methane Produced Water in the Western United States
established; geochemical data suggest that coal aquifers and other alluvial groundwater aquifers do not interact to any great degree in studied parts of the Powder River Basin (see discussion in e.g., Frost et al., 2010; Bartos and Ogle, 2002; see also Chapter 2). Anecdotally, CBM production has been linked to some losses of drinking water or dry wells where the water wells were close to the CBM development and/or were completed in the coals which serve as a primary aquifer.
In addition to geochemical information that can help determine the degree of connectivity between CBM coalbeds and other groundwater aquifers, groundwater monitoring networks are being used to measure the degree to which CBM production may affect water levels in shallow aquifers. The Montana Bureau of Mines and Geology (MBMG) maintains and samples a regional network of groundwater monitoring wells that includes wells installed in the late 1970s and early 1980s to monitor the effects of coal mine dewatering, a separate activity from CBM operations, and more recent wells installed specifically to monitor CBM production. The MBMG receives funding from the Bureau of Land Management (BLM) in support of this monitoring program. In Wyoming, in response to concerns about potential effects to groundwater from CBM development in the Powder River Basin, BLM established a regional groundwater monitoring program that is outlined as part of the Wyodak CBM Final Environmental Impact Statement (BLM, 1999). The program was designed to collect information regarding hydraulic connectivity between producing coals and adjacent sandstone units and to measure the extent of groundwater drawdown in the CBM-producing coal zone on federally owned lands. Results from both the Montana and Wyoming groundwater well monitoring programs are briefly summarized below.
MONTANA
Many of the monitoring wells are completed in the Dietz (associated with the Anderson coalbeds) and Canyon coalbeds in the Powder River Basin (Wheaton and Metesh, 2002; see also Figure 2.4b). The monitoring network has been sampled for seven consecutive years (2003–2009), in addition to sporadic monitoring for nearly three decades before CBM development was initiated in the area, and the data are available in annual reports through the 2008 sampling event.1
Data from this network indicate that static water levels in the Dietz coalbeds, from which CBM is being extracted, have been lowered by as much as 150 feet. Static water levels in the Canyon coal, also a coalbed from which CBM is being extracted, have been lowered as much as 600 feet in limited areas (Meredith et al., 2008). CBM-related drawdown of 20 feet of the static water level in the Canyon and Dietz coalbeds currently extends to
1
See, for example, Wheaton and Donato (2004), Wheaton et al. (2005, 2006, 2007, 2008), Meredith et al. (2008), and Wheaton and Meredith (2009).
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Management and Effects of Coalbed Methane Produced Water in the Western United States
roughly 1 to 1.5 miles outside the CBM fields. Although little change in the water levels of the monitored coalbeds in Montana has been observed since 2004, the areal extent of water drawdown in the coalbeds is predicted to increase in the future as CBM production increases (see also Chapter 1). Meredith et al. (2008) predicted the 20-foot drawdown contour to expand to 4 miles beyond the edges of the large production fields. Results from these studies apply specifically to drawdown in the Dietz and Canyon coalbeds, which are uniquely identifiable and distinguishable coal- and methane-bearing aquifers; however, as noted above and in Chapter 2, these coalbeds, while regionally pervasive, are not necessarily the same as shallow alluvial coalbed aquifers that may supply substantial domestic and livestock water or contribute to significant base flow of perennial water resources in this area.
Groundwater models and monitoring results have been interpreted to indicate that water levels in the Anderson-Dietz and Canyon coals will take decades to return to original levels (Wheaton and Meredith, 2009). The extent of water level drawdown in the coalbeds and the time to recovery depend on (1) proximity to CBM production, (2) site-specific aquifer characteristics, (3) proximity to recharge areas, and, potentially also, (4) connection or access in the coalbeds to water from deeper horizons (Meredith et al., 2008). On the edge of the basin, near recharge areas, 75 percent recovery occurred within five years of the monitoring period when pumping was discontinued in the Anderson coal formation. In the center of the area monitored, where pumping was most aggressive, groundwater levels in the Anderson coal have recovered 65 percent in 10 years (Wheaton and Meredith, 2009). An example of groundwater drawdown and recovery in several wells in the Anderson-Dietz coal aquifer in Montana is shown in Figure 5.1. Sufficient data have not been collected at this point to either (1) characterize the contributing sources to recharge or (2) determine through geochemistry comparisons whether the recharge water is the same as or uniquely different from water currently within the coalbeds. In the latter case, recharge could be attributed to redistribution of water due to pressure (or head) gradients resulting from several years of pumping.
WYOMING
In the Wyoming portion of the Powder River Basin, the Wyoming State Geological Survey, in collaboration with BLM, analyzed data from 111 wells in the BLM deep-well monitoring network, collected from 1993 to 2006 (Clarey, 2009). The data indicate that drawdown occurs within the coalbeds or coal aquifers (“confined coals”) and that the magnitude of drawdown is greater nearer to monitoring wells located in areas of CBM development than in areas peripheral to development, consistent with that reported by Meredith et al. (2008). The measured impacts include a maximum groundwater-level drawdown of up to 625 feet within the coals in Fort Union coal monitoring wells and maximum groundwater-level drawdowns of more than 260 feet in the overlying Wasatch sandstone.
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Management and Effects of Coalbed Methane Produced Water in the Western United States
FIGURE 5.1 Measured groundwater elevations in Anderson-Dietz coal seams during and after coal mining dewatering and then following the initiation of CBM-related dewatering. The larger drawdown (80 to 233 feet, starting in 2001) is related to CBM production, and recoveries of 73 to 87 percent over a seven-year period are related to a gradual decrease in CBM production. Full recovery is predicted to take 20 to 30 years. These wells are located in the CX CBM field in the southwestern corner of the Montana portion of the Powder River Basin near the Wyoming border. The original drawdown (pre-1995) in Figure 5.1 was from coal mine dewatering, and water levels largely recovered before CBM production began. SOURCE: Meredith et al. (2008).
Since 1997, hydrological impacts in the Powder River Basin from CBM development have been regionally confined to some of the Tongue River Member coals of the Fort Union Formation and some of the sandstone beds in the overlying Wasatch Formation. The latter sandstones are deeper beds that are in physical contact with the coalbeds. Importantly, these drawdowns are being measured in coals that are the same as the coals being pumped for methane extraction.
Recent modeling studies have shown that CBM impacts to groundwater levels in the upper coal member of the Fort Union Formation are slightly less than the drawdowns modeled and predicted for the year 2006 (AHA and GEC, 2002; Clarey, 2009). The observed drawdowns in the Wasatch sandstone wells were also compared with modeled (predicted)
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Management and Effects of Coalbed Methane Produced Water in the Western United States
drawdowns (AHA and GEC, 2002). The different sandstone zones within the Wasatch did not show drawdown of Wasatch water levels except for a few limited areas, suggesting limited connectivity of the units. Thus, although pumping of water in Wyoming has been much more aggressive and local to the CBM wells compared to Montana, the conclusions of this analysis in Wyoming are consistent with those reported by Wheaton and Meredith (2009) and in various MBMG reports (see references above).
IMPORTANCE OF FOSSIL WATER
Determining the extent to which CBM produced water is actually fossil water (see Chapter 2) is also important to analyzing the effects on groundwater drawdown. Multiple lines of evidence suggest that CBM produced water in the San Juan Basin and potentially also in the Raton Basin is fossil water with an age of thousands to tens of millions of years. Prior to extraction, the water rested underground in aquifers in these basins over geological timescales, without interacting with or being affected by surface events such as rainfall. Recharge of the San Juan and Raton coalbed aquifers is low because of hydrogeological compartmentalization and the fact that evaporation usually exceeds precipitation in the dry western climate. Data from the Powder River Basin suggest that some of the CBM aquifer water there is also likely at least thousands of years old in aquifers with limited connectivity (see Chapter 2).
Long-term implications of mining fossil water have not been studied or included as part of the discussion of management approaches for CBM produced water. Similarly, basin-wide and comprehensive analyses of the degree of hydraulic connectivity between CBM aquifers and other groundwater aquifers are needed to understand the degree to which CBM waters may be considered “fossil.” Such studies have not been thoroughly completed for any basin except the San Juan.
HYDRAULIC FRACTURING
In CBM operations where hydraulic fracturing is regularly used, expressions of concern by the public prompted a study by the U.S. Environmental Protection Agency (EPA) to assess the potential for contamination of underground sources of drinking water (USDWs) as a result of the practice (see also Box 2.1). The study (EPA, 2004) found that, while fracturing fluids contain various chemicals, the identities of which are not generally a reporting requirement for operators, no conclusive evidence of drinking water contamination by hydraulic fracturing fluid injection was found to be associated with CBM wells. Lack of comprehensive datasets and studies, and continued development of domestic oil and gas fields since the release of that report, have continued to focus attention on hydraulic fracturing. The EPA has announced it is conducting a broader analysis of the potential effects
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Management and Effects of Coalbed Methane Produced Water in the Western United States
on water quality and public health from hydraulic fracturing throughout the entire oil and gas industry (EPA, 2010).
CBM Impoundments and Produced Water Quality
Surface impoundments hold produced water until it evaporates or infiltrates into the subsurface, or they store the water for future beneficial uses (see Chapter 4). In 2008, 64 percent of the CBM produced water in the Wyoming portion of the Powder River Basin was managed in surface impoundments (see Box 4.1). Surface impoundments are not used extensively in the other western CBM basins or in the Montana portion of the Powder River Basin (see Table 4.1 and Chapter 3), although some impoundments (lined and unlined) are used in the Raton Basin in Colorado. Impoundments strictly for storage or disposal (evaporation or infiltration) are no longer permissible in Montana. In the Raton Basin the Colorado Oil and Gas Conservation Commission (COGCC) has indicated some issues related to leaks or seepage from the impoundments either to the surface water or groundwater, but the committee was not able to identify specific data on the extent of any effects of seepage from the impoundments (Ash and Gintautas, 2009). Thus, the remaining discussion focuses specifically on impoundments in the Wyoming portion of the Powder River Basin.
As of 2005, about 2,500 of the approximately 3,000 CBM impoundments in the Powder River Basin were “on-channel” impoundments sited within a water feature (including perennial and ephemeral streams and rivers, dry washes, marshes, and lakes) or within the floodplain or alluvium of a water feature. Roughly 200 impoundments were “off-channel” and unlined, with the intent to recharge underlying groundwater. The remaining off-channel impoundments are lined to reduce, minimize, or prevent leakage and infiltration into underlying soils. According to Wyoming state policy, off-channel impoundments may not be sited within 500 feet of a designated water feature (and must be located at least 500 feet from the outermost floodplain or alluvium; Fischer, 2005a).
In Wyoming, impoundments were initially permitted for the purpose of storage of produced water, although the intent was to facilitate disposal by evaporation, enhanced by atomization, infiltration, or for storage for land spreading or irrigation. Under Wyoming DEQ permitting provisions, a limited number of impoundments were permitted for the purpose of infiltration. Wyoming DEQ presently permits some off-channel impoundments for the purpose of infiltration, but not necessarily with the intent of recharging underlying groundwater. Changes to the guidelines for construction and monitoring of unlined impoundments in Wyoming are outlined in Chapter 3.
Potential groundwater effects from off-channel CBM produced water impoundments relate to the leaching of salts, metals, or metalloids that occur naturally in soils in or under the impoundments and that may be dissolved and mobilized by CBM produced water infiltrating beneath the impoundments (McBeth et al., 2003; Jackson and Reddy, 2007;
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Management and Effects of Coalbed Methane Produced Water in the Western United States
Healy et al., 2008). The measured chemical elements of interest include sulfate, selenium, arsenic, manganese, barium, and total dissolved solids (TDS). Geochemical processes involving these constituents can also affect infiltration rates of water into soil over time. Healy et al. (2008) have indicated that high TDS and nitrate and chloride concentrations exist under some CBM water impoundments in the Powder River Basin. The researchers concluded that large amounts of chloride (12,300 kg) and nitrate (13,500 kg) were being leached from soil materials below impoundments into perched groundwater resulting from water infiltrating from the impoundments. Several additional studies in the Powder River Basin of different impoundments (including both on- and off-channel impoundments) and associated groundwater effects are described below to illustrate the various scales at which groundwater data related to impoundments may be analyzed and the effects of the results on management and monitoring requirements.
A preliminary study in 2005 by the Water Quality Division of the Wyoming DEQ on the potential effects on groundwater of CBM impoundments indicated high concentrations of TDS, selenium, and sulfate in groundwater beneath four on-channel impoundment facilities (Fischer, 2005a,b). These concentrations had increased as a result of the infiltration of CBM produced water below the impoundment and subsequent dissolution of minerals and other compounds in the underlying soils. The impact on groundwater quality beneath the impoundments caused the Class of Use of the groundwater to be changed from Class III2 (livestock use; 3,000 mg/L TDS) to Class IV (industrial use) because of TDS, selenium, and sulfate in excess of Class III standards (Fischer, 2005a,b). As a consequence of these results, the Wyoming DEQ implemented new compliance monitoring guidelines for new CBM impoundments in the state. Continued studies were recommended to determine the effects on groundwater over the entire basin. As mentioned previously, the new guidelines which were developed on the basis of the 2005 study have been updated again and were issued by Wyoming DEQ in April 2010 (see Chapter 3).
As part of its continuing investigation of the extent of groundwater and surface water impacts from impoundments (on- and off-channel) and the length of time these impacts may persist following closure, the Wyoming DEQ Water Quality Division recently completed a comprehensive review of five years of groundwater monitoring data associated with CBM produced water impoundments (on- and off-channel) and their effects on shallow groundwater in the Powder River Basin. Between August 2004 and May 2010, the Wyoming DEQ reviewed data for more than 2,000 CBM produced water impoundments
2
Class III groundwater in Wyoming is water that is suitable for livestock. The majority of CBM produced water in the Powder River Basin of Wyoming is designated as Class III. Infiltration impoundments in Wyoming are not allowed to be sited over Class I or Class II groundwater.
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Management and Effects of Coalbed Methane Produced Water in the Western United States
(Fischer, 2009a,b; see also ALL Consulting, 2008)3,4 which were drilled to investigate the presence or absence of groundwater. Approximately half of the sites lack groundwater resources to the required depth of investigation, which is either 150 feet or 200 feet below ground surface depending on the size of the impoundment. Those sites that encountered groundwater were sampled and the reports were submitted to DEQ (approximately 900 reports). The Wyoming DEQ has issued permits and associated compliance monitoring programs for approximately 296 impoundments. Many of the impoundments have either never been constructed, have not received discharge, or will not be used. The Wyoming DEQ has issued groundwater monitoring exemptions for approximately 1,485 impoundments because either groundwater was not encountered during the drilling program, or groundwater was Class IV (industrial) quality.
Relative to the 296 impoundments for which permits and associated compliance monitoring programs have been issued, permit-holders for 144 impoundments with 170 associated monitoring wells submitted monitoring reports as of May 2010. The monitoring wells are part of the state’s impoundment performance compliance monitoring process and are currently sampled on a scheduled basis (e.g., quarterly, semi-annually, or annually) as required in the monitoring well permit to construct. The impoundments overlie Class III (livestock) quality groundwater and the monitoring reports documented exceedance of groundwater standards beneath 17 impoundments since 2004. The primary constituents identified in groundwater were TDS, sulfate, and/or selenium, largely related to dissolution of soil-associated selenium and pre-existing gypsum (calcium sulfate) salts above the water table. In addition, some impoundments exceeded surface water standards for iron and barium. The state also found about 50 leaking reservoirs that required corrective action (e.g., pump-back systems or cessation of discharge).
In an assessment of the 170 monitoring wells associated with 144 impoundments,5 specific changes in groundwater level and chemistry of groundwater sampled from the wells were based on identification of four qualitative trends in water geochemistry: (1) stable (no upward or downward trend during the measurement period), (2) upward (increasing salinity and sulfate concentrations), (3) flushed (increasing concentrations followed by decreasing concentrations), or (4) improved (decreasing concentrations of salinity and sulfate). In the majority of instances (72 percent), the trend analyses indicated that CBM water from impoundments resulted in no apparent water quality trend (stable trend) as a result of interaction with the underlying soils. Eighteen percent showed increasing salinity
3
The study by ALL Consulting was supported by the National Energy Technology Laboratory and was performed in cooperation with the Wyoming DEQ, the Montana Board of Oil and Gas Conservation (MBOGC), the U.S. Geological Survey, and the U.S. Department of Energy. MBOGC provided some funding for the groundwater analysis portion of the study.
4
Updated figures regarding the ongoing study were provided in June 2010 by D. Fischer (pers. comm.)
5
C. Steinhorst, Wyoming DEQ Water Quality Bureau, personal communication, Nov. 30, 2009 and August 23, 2010.
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Management and Effects of Coalbed Methane Produced Water in the Western United States
and sulfate concentrations at some point in their history (flushed or upward trend), and 6 percent showed improved groundwater quality (see Figure 5.2). Eight of the wells did not clearly fit into any category. Of the 170 wells, 12 exceeded Class III standards (changed from Class III to IV): seven of the monitored wells exceeded standards for sulfate or TDS and five exceeded standards for selenium only. Confined artesian aquifers6 generally had greater depths to groundwater and lower percentages of wells exhibiting a decrease in water quality. In analysis of some of the same data, the ALL Consulting (2008) study concluded that impacts of CBM produced water impoundments on shallow groundwater were site specific and influenced in large part by the shallow subsurface geology of the area (on-channel versus off-channel). Data gaps identified by the 2008 study included lack of knowledge of the volumes of water discharged into impoundments; absence of analysis of groundwater and CBM produced water for major cations and anions such as calcium, magnesium, sodium, sulfate, chloride, and bicarbonate; and need for evaluation of impoundment inflows to deeper groundwater in order to continue to monitor the effects of CBM produced water infiltration.
Summary of Groundwater Studies
Primary considerations with respect to CBM produced water and effects on groundwater are (1) drawdown of groundwater levels in coalbeds as a result of pumping water during CBM extraction and (2) changes in groundwater quality beneath surface impoundments associated with leakage of stored CBM produced water. Groundwater drawdown in any shallow groundwater aquifer as a result of water and methane extraction from CBM operations is a function of the depth to the target coalbeds and the degree of hydraulic connection between CBM targets and other local or regional aquifers. Due to the great distance between the deep coalbeds and shallow groundwater aquifers and to aquifer compartmentalization, pumping water during CBM extraction in basins with deep methane-bearing coals (e.g., the San Juan and Raton basins) is unlikely to cause lowering of the water table of shallow alluvial aquifers.
Groundwater monitoring networks established for coalbeds in the Powder River Basin in Montana and Wyoming have measured the degree to which CBM production has affected water levels in coalbed aquifers, either in proximity to areas of CBM development or near the fringes of the coalbed outcrops. Measured drawdowns ranged between 20 and 625 feet below prepumping levels. These coalbed aquifers are not necessarily the same as shallow alluvial aquifers used frequently as the principal source of water in the area. On the edge of
6
An artesian aquifer is a confined aquifer (bounded by impermeable geological strata) that contains groundwater that can flow upward through a well (an “artesian well”) without pumping.
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Management and Effects of Coalbed Methane Produced Water in the Western United States
FIGURE 5.2 Graphical distribution of the classification of groundwater data from 162 compliance monitoring wells associated with 144 CBM produced water impoundments. The data showed stable, upward, flushed, or improved geochemical trends in shallow groundwater beneath impoundments. “Improved” indicates reductions in TDS and sulfate concentrations in groundwater over time. Importantly, qualitative classifications based on trend analyses do not imply magnitude or cause of changes to groundwater quality. Another eight wells did not fit clearly into any of the four categories. SOURCE: Adapted from C. Steinhorst, Wyoming DEQ Water Quality Bureau (WQB), personal communication, Dec. 22, 2009 and August 23, 2010.
the basin in Montana, near recharge areas, 75 percent recovery of the water levels in one of these coalbed aquifers occurred within five years when pumping was discontinued. In the center of the area monitored, where pumping was most aggressive, groundwater levels in the affected coalbed for which data were available have recovered 87 percent in 10 years.
Observed drawdowns were less than those predicted in modeling. Although model results predict that recovery to original water levels in the absence of pumping may take decades, the extent of water level drawdown in the coalbeds and the time to recovery depend on proximity to CBM production wells, site-specific aquifer characteristics, and proximity of drawdown monitoring sites to recharge areas. The water in coalbeds used for methane extraction in the San Juan and Raton basins, and in at least some portions of the Powder River Basin, has been documented to be nonrenewable fossil water (see Chapter 2). The long-term implications of mining fossil water, or the degree to which waters may be considered fossil, have not been thoroughly studied nor included as part of the discussion of management approaches for CBM produced water.
About 83 percent of the impoundments in the Powder River Basin of Wyoming are on-channel and about 6 percent are unlined and off-channel, with intent to recharge groundwater beneath impoundments. The remaining impoundments are lined and off-channel, with the aim to reduce or prevent leakage and infiltration of CBM produced water into underlying shallow alluvial groundwater. The natural and human-influenced differences between individual impoundments—including the substrate (e.g., soil or bedrock) on which
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new wells, to protect themselves and nearby well owners. However, no legal requirement exists for collection of baseline water quality or water level data.18
One registered complaint from the Powder River Basin in Wyoming cited increased erosion from unmanaged CBM produced water discharge (see Figure 5.6). A sustained period of CBM produced water entering the headwaters of a seasonally ephemeral channel resulted in substantial channel scouring, bank erosion, and head cutting, with the eroded channel migrating progressively upgradient. In this particular case, the water entering the channel was the result of overflow discharges from an upslope-produced water impoundment. Through litigation the CBM operator responsible for the overflow and subsequent produced water management was ordered to bring impoundment overflows into control and to discontinue discharge to the ephemeral channel.
In another documented case in Wyoming, a private citizen’s complaint was filed against the state and a private CBM operator over CBM water discharges that were permitted and regulated. The private landowner charged that CBM waters released into ephemeral channels upstream from his property were altering portions of the land and preventing irrigation of hay meadows.19 The state and the CBM operator were charged with violating the Clean Water Act and the Wyoming Environmental Quality Act.
Other citizen complaints have reached the courtroom. As of 2007, at least 20 farmers and ranchers in Wyoming, Montana, and Colorado had sued CBM operators and state agencies for damages related to CBM water discharges (McGuire, 2007). In 2003 a district court in Wyoming ruled that CBM operations had damaged nearby land used for cattle grazing. The plaintiffs testified that the CBM crews drove across the rangeland, mixed topsoil with salt-laden subsoil, and let hillsides erode away.20 Landowners have also filed suit against permitting agencies and permitting procedures in some cases where the landowners have indicated adverse impacts on their land from produced water discharges. For example, in 2010 ranch owners in Wyoming contested before the Wyoming Environmental Quality Council (EQC) the terms of a discharge permit and the consequence of produced water discharges to private property under the terms of a Wyoming DEQ-issued discharge permit held by a nearby private CBM operator. The landowners claimed they lost productivity of agricultural land and trees due to salt buildup from CBM waters flowing across their Powder River Basin property. The Wyoming EQC sided with the plaintiffs. This complaint was presented before the Wyoming EQC following an EPA and private consultant finding of fault with the scientific basis of permitting being used by Wyoming DEQ.21 The state of
18
J. Harju, Wyoming SEO, personal communication, April 2009.
19
See billingsgazette.com/news/state-and-regional/wyoming/article_5906e25d-058e-56fc-8b49-17ee4b5e012e.html (accessed April 29, 2010).
20
See billingsgazette.com/news/state-and-regional/wyoming/article_1b83a02c-c303-504c-8365-068c5952a02d.html (accessed May 27, 2010).
21
See billingsgazette.com/news/state-and-regional/wyoming/article_5f8ece00-2e57-11df-854d-001cc4c002e0.html (accessed April 29, 2010).
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FIGURE 5.6 Stream bank erosion caused by headwater flows in ephemeral drainage of Barber Creek, Wyoming; water sourced from upgradient CBM storage impoundment releases, Powder River Basin. SOURCE: Used with permission from Gregory Wilkerson, Southern Illinois University Carbondale.
Wyoming ruled that the permit, which had been issued using rules since criticized by the EPA and state consultants, was no longer valid.
CHAPTER SUMMARY
Concerns about environmental effects associated with CBM production and produced water management are related to short- and long-term consequences associated with two general activities: (1) groundwater withdrawal associated with CBM extraction and (2) the disposal, management, and permitted discharge of produced water. Much of the information on effects derives from the Powder River Basin of Wyoming, where over 90 percent
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of CBM produced waters are discharged to the land or surface water or are applied as irrigation water to soils.
Groundwater
The potential effects on groundwater quality and quantity are related to groundwater withdrawals and infiltration from surface disposal impoundments that store CBM produced water. The extent of groundwater drawdown depends on the density of wells, the rate of pumping water from the coalbed by CBM operators, and the length of time that pumping has been ongoing. The time for the CBM-bearing aquifer to return to its original water pressure or level is a function of the extent of drawdown; site-specific aquifer characteristics such as porosity, permeability, and depth to the coalbed aquifer; climatic and hydrogeological conditions; and proximity and connectivity to recharge sources. Due to the distance between the deep coalbeds and the shallow groundwater aquifers and to aquifer compartmentalization, CBM extraction in the San Juan, Raton, Uinta, and Piceance basins is unlikely to cause lowering of the water table in shallow alluvial aquifers. However, research in the Powder River Basin, which has relatively shallower coal seams, has shown that hydrostatic heads in the coalbeds have been lowered between 20 and 625 feet in CBM production areas. Estimated recovery of groundwater levels in areas of the Powder River Basin where CBM production has ceased in recent years varies from 65 percent in the center of the area near the locus of the CBM wells to 87 percent near the edge of the basin over 10 years. This drawdown has been measured only in the coalbeds from which CBM has been extracted and which are not necessarily the same as groundwater aquifers used extensively as water supplies. An important characteristic that has not yet been thoroughly substantiated is the degree of local hydraulic connection between coalbed aquifers from which CBM and water are withdrawn and other aquifers in the Powder River Basin. Although an EPA study found no conclusive evidence of drinking water contamination by hydraulic fracturing fluid injection associated with CBM wells in a 2004 study (see Box 2.1), lack of comprehensive datasets and studies, and continued development of domestic oil and gas fields, including CBM, since the release of that study have continued to focus attention on hydraulic fracturing. The EPA is conducting a broader analysis of the potential effects on groundwater quality and public health from hydraulic fracturing throughout the entire oil and gas industry.
A primary mode for disposal of CBM produced water, especially in the Powder River Basin of Wyoming and somewhat in the Colorado portion of the Raton Basin, is in surface impoundments. Infiltration and percolation of impounded water can dissolve and mobilize preexisting salts or naturally occurring constituents such as sulfate, selenium, arsenic, manganese, barium, chloride, nitrate and soil solution TDS below impoundments. Studies in
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Wyoming indicated no apparent change in groundwater quality as a result of interaction with underlying shallow alluvial groundwater for a substantial majority of impoundments studied; an increase in TDS, selenium, and sulfate in groundwater beneath some impoundment facilities; and improved water quality beneath a small fraction of impoundments. A monitoring well network and a monitoring program are integral parts of CBM produced water management plans that include disposal in surface impoundments.
Surface Water
The potential effects of CBM production and produced water discharge to surface water include water quality effects to perennial and ephemeral drainages and stream depletion from dewatering of coalbed aquifers. Studies that have been conducted on the effects of CBM produced water discharge on perennial stream water quality have produced equivocal results. Background (historical) data prior to CBM development are limited, making assessing the influence of climatic influences on in-stream flows difficult. Specific conductance and SAR of water resources may not be the most meaningful diagnostic or representative measures of CBM produced water influence on receiving water bodies, particularly in the Powder River Basin. Isotope analyses may provide more representative characterization of the influence of CBM produced water on groundwater and surface water.
Carbon isotopic “fingerprinting” studies have distinguished the presence of CBM produced water in the Powder River near areas of CBM production. These carbon isotope fingerprints become less evident as downstream flows are influenced by tributaries that are not themselves influenced by CBM produced water discharges. Use of isotope ratios or other isotope signatures of CBM produced water presence and effects may be useful to monitor and assess the presence and effects of CBM produced water on surface water and groundwater resources.
The committee was unable to find any published data or reports documenting measurable stream depletions due to CBM water production in the basins studied. The reliability of results from stream depletion modeling studies for the Piceance, Raton, and Northern San Juan basins in Colorado has not yet been evaluated against actual stream measurements in areas of CBM production. Similarly, the general assumption of “tributary” groundwater as a primary model input does not comport with the data available from the San Juan Basin.
Soil Quality and Agricultural Production
Several site-specific research studies and natural resource inventories have documented that application of CBM produced water to some soils in of the Powder River Basin has altered plant ecology and resulted in adverse soil with ecological, chemical, and hydrologi-
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cal consequences. The conclusions of these studies have not been extrapolated to wider geographic areas or watershed scales. The CBM produced water sourced from the Powder River Basin generally has lower TDS and constituent concentrations than that of the other western basins, and its utility for irrigation as a sole-source water supply is questionable under many conditions in the basin. Thus, CBM water sourced from other basins would have even less suitability for irrigation.
In cases where CBM produced water is used for irrigation, the practice will likely require intensive management, including selection of crops irrigated, timing and amount of produced water that is applied, and use of soil amendments. After use of CBM produced water ceases, additional soil management, including soil amendments, may be required to restore agricultural resources and impoundment sites to predevelopment crop production conditions.
Ecological Effects
Laboratory studies indicate that exposure to elevated concentrations of one or more of the chemical constituents TDS, bicarbonate, and other ions such as potassium and chloride can be toxic to some freshwater organisms. Most laboratory comparisons are based on mean concentrations and discharges of CBM produced waters and on direct and prolonged exposure of conventional laboratory test species to undiluted, untreated CBM produced water or its constituents. In the field, permitted discharges of CBM produced water often require treatment and a defined mixing zone (mixing between CBM produced water and receiving water) at the site of discharge. Testing these laboratory results against field studies and with species relevant to the study areas in the Powder River Basin has not yet been completed and would be a valuable contribution to determine the potential effects of CBM produced water on organisms.
Mean concentrations of sodium bicarbonate in many CBM produced waters are in the range of or exceed acute toxicity concentrations for some aquatic species tested in the laboratory. In situ (field) tests conducted in the Tongue and Powder rivers showed mortality to some species when levels of bicarbonate exceeded laboratory toxicity threshold concentrations for test species. However, these results were the result of direct exposure to undiluted CBM produced water, a situation that would be unlikely in perennial waters where fish are found because of permitted discharge requirements.
Most information on sensitivity of aquatic organisms to dissolved ions has been derived from short-term laboratory toxicity tests. While laboratory approaches may provide an approximation of potential effects, toxicity tests are limited in their ability to predict effects on natural populations and communities in the field. To date, few field assessments have investigated the effects of CBM produced water discharges on aquatic communities, partly due to the difficulties in conducting robust experiments that account for interacting
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habitats, natural and human-induced differences in water quality, background (pre-CBM development) conditions, limited lengths of time to complete studies involving community transitions, and species migration. Two field studies conducted to date noted difficulty in identifying any direct effects of CBM discharges on fish assemblages in large-volume perennial flowing rivers (the Powder and Tongue rivers). A comprehensive assessment is currently being conducted to establish current conditions for habitat and aquatic communities for the Powder River Basin in order to measure and monitor future changes.
The potential adverse effects of CBM discharge to ephemeral streams and riparian systems are changes in the timing and amount of streamflow, increased stream bank erosion and instability, increased suspended sediment concentrations and turbidity and downstream sediment deposition, changes in riparian plant communities, and increased stream water and sediment salinity. Effects to algae, aquatic invertebrates, fish, amphibians, and other biological aspects of streams and rivers as a consequence of these discharges have not yet been rigorously documented. One study found greater percentages of nonnative plant species in channels receiving produced water than in those that did not receive CBM produced water.
Citizen Complaints
Although the committee was not able to find published evidence of any widespread effects of dynamic alteration in ephemeral stream channels due to regulated and managed CBM produced water discharges, increased erosion from unregulated and/or unmanaged CBM produced water discharge has been reported. Several cases are also documented in which private landowners brought their complaints against CBM operators and state authorities to court over permitted and regulated discharges to ephemeral channels and to the surface of private lands. Citizen complaints related to CBM activities that are cataloged and investigated by several states with CBM production, comprise primarily concerns about water quantity and quality impacts to private domestic water supply wells.
Baseline information on flows was generally not available for complaints related to ephemeral drainages. For drainages already receiving CBM discharges, hydrological and geochemical characteristics of flows in nearby drainages could be used as surrogate baseline conditions. Similarly, the Wyoming SEO advises CBM companies to collect baseline water level data before drilling new wells, to protect themselves and nearby well owners. However, no legal requirement exists for collection of baseline water quality or water level data.
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