BOX 3.2

EPA’s Detailed Study of the CBM Extraction Sector Under the CWA

The CWA requires the EPA to review its effluent limit guidelines annually to determine if amendments might be appropriate to existing regulations. In cases where an amendment is being considered, the EPA first conducts a screening-level review to identify effluent categories needing further characterization. Candidates for potential review are then prioritized based on various factors such as industrial categories, pollutant discharges, and economic considerations. Pending the outcome of the screening and prioritization, a particular industry sector and/or pollutant category may undergo an in-depth, detailed review prior to any decision being made with regard to amending the CWA regulations. At various stages of this process, EPA results are published and open for public comment.

Motivated by the growth of the CBM extraction industry and the potential impacts to surface waters from discharge of CBM produced water, the EPA began considering the potential to designate CBM extraction as a specific subcategory with its own guidelines under the Oil and Gas Effluent category of the CWA. A “detailed study” of the CBM extraction industry was therefore recently begun by EPA to consider the possibility of recommending such a designation for the CBM industry.

The objective of the study for CBM extraction is to evaluate the potential environmental issues associated with the discharge of CBM produced water. The study is national in scope, with each CBM basin being considered separately with respect to potential pollutants in produced water discharges and water volumes.

The work plan for the detailed study includes conducting industry surveys to collect technical, economic, and environmental data from a wide range of CBM operations across the United States; site visits and collection of ancillary data from other sources such as the Energy Information Agency; and conducting stakeholder meetings in the major CBM basins. The EPA received approval from the Office of Management and Budget to distribute the mandatory survey for the detailed study in February 2009, at which time EPA distributed a screener questionnaire. Approximately 290 operators with three or more CBM wells received the questionnaire. A detailed questionnaire was distributed to approximately 250 CBM projects in October 2009. EPA will analyze the survey results from the detailed questionnaire and identify whether to initiate a rulemaking in the final 2010 Effluent Guidelines Program Plan. To date, EPA has contacted over 700 people in eight states in over 70 outreach and data collection activities since 2007 in connection with this activity. The results of the detailed study were not available at the time of the writing of the present report.

More information about effluent guideline limits under the CWA can be found at www.epa.gov/guide/304m/ (accessed March 4, 2010). Information specific to the coalbed methane extraction detailed study can be found at water.epa.gov/scitech/wastetech/guide/cbm_index.cfm (accessed August 23, 2010).

SOURCE: Johnston (2009).

below sources of drinking water). Under this program, oil and gas industry injection wells are generally regulated as Class II injection wells, which also generally cover enhanced oil recovery projects or projects involving the disposal of nonhazardous exploration and production wastes. An explanation of the distinction among classes of wells regulated under the SDWA is provided in Table 3.2. Regulatory authority for these types of wells is sometimes



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