approximately 2 percent of the CBM water produced annually in the San Juan Basin.2 The primary produced water management method used by Red Willow is reinjection. An estimated 25 percent of the CBM produced water is hauled by truck to a disposal well or facility, where wells inject into deep nonproducing formations 4,600 to 9,500 feet below ground surface. The remaining water is pumped through a network of underground pipes, some extending as far as 10 miles, to be injected into water disposal wells (WDWs). Each well is permitted through the Environmental Protection Agency’s Underground Injection Control Program, and each permit has specific requirements for maximum allowable injection pressure. All permits require annual reporting on volumes disposed, injection pressures, and financial assurance. The Southern Ute Department of Natural Resources Water Resources Division provides for the management, conservation, and use of the tribe’s surface water and groundwater resources. This work includes the installation of water measuring devices, implementation of soil and water conservation projects, protection of existing water rights, acquisition of new water rights, and strategic planning for the continuing development of water resources to benefit the tribal membership.3
Red Willow uses chemical treatments, such as paraffin dispersant, scale inhibitors, biocides, and corrosion inhibitors, to reduce clogging of filters at inlets to disposal wells and to prevent pressure buildup in WDWs (due to plugging with suspended solids). Some of these chemicals may enter the produced water stream; however, they are exempt from regulation under the Resource Conservation Recovery Act, which governs the disposal of hazardous and nonhazardous solid wastes.
Red Willow is involved with a project aimed to put CBM water to beneficial use. The SUIT Growth Fund Alternative Energy Group recently partnered with a biofuels company to use small portions (approximately 100 barrels) of Red Willow’s CBM produced water to grow algae, which is converted to oil feedstock that can be refined into diesel fuel. Red Willow will dispose of wastewater product from the process. This plan will require modification of a Class II permit to a more rigorous Class I permit. If the pilot project is successful, this industrial process may utilize all of Red Willow’s produced water.
At the time of the writing of this report, no CBM production has occurred on the lands of either the Northern Cheyenne or the Crow Tribes in the Powder River Basin of Montana. Although both tribes have taken active steps to examine the possibility of developing CBM on their lands, they do not currently participate in CBM development nor are they involved in CBM produced water disposal. The Crow Tribe, for example, has articulated