American Oil and Gas Reporter - January 2012 - 27

WASHINGTONWATCH
EPA Considers Rule
For Shale Gas And CBM
Water Discharges
While 2010 may seem like ancient history-given the fast
pace at which developments occur in the energy industry-it
was the year the Environmental Protection Agency announced
its intention "to develop effluent guidelines and standards for
(discharging) wastewater from the coalbed methane extraction
industry and will develop pretreatment requirements . . . for
(discharging) wastewater from the shale gas extraction (SGE)
industry."
However, there are concerns as to whether EPA's resources
and efforts are justified by the ultimate environmental outcome,
and whether the wastewater discharge permitting process will
change appreciably.
EPA initiated a detailed study of the CBM industry-a subcategory of the Oil and Gas Extraction Point Source
Category-and its wastewater discharges. EPA issued surveys in
2009, and mandatory responses were submitted in early 2010.
From those survey results, EPA issued a final study report on
CBM in December 2010. The study notes coalbed methane
represents 8 percent of natural gas production and discharges
22 billion gallons of produced water to surface waters annually. Based on these findings and the availability of technologies
to treat produced water, EPA initiated a rule making.
As with many environmental statutes, permitting regulations
typically are delegated to state agencies under the Clean Water
Act. The National Pollutant Discharge Elimination System permitting process is structured for such delegation. The current
oil and gas extraction effluent limitation guideline (ELG) does
not specifically address CBM. However, this does not mean
CBM wastewater discharges are unregulated or unpermitted.
The same state regulatory agencies that would be delegated
NPDES authority under a new CBM ELG are developing discharge permits under a sanctioned approach that relies on best
professional judgment.
In comments submitted to EPA in late November, the
Independent Petroleum Association of America notes that the
state programs have processes in place that evaluate the specific
circumstances that arise with each situation-a more comprehensive approach than an ELG provides. IPAA contends that the proposed ELG would worsen the permitting process because it could
not distinguish between typical industrial uses of water (usually
for cooling, steam generation, or for process operations) and
CBM production, where the water is a product of the operation.
A CBM producer has no ability to alter the water quality it
encounters. In CBM operations, the treatment options are
defined by the nature of the water source, and potential exists
for beneficial uses of the water. In addition, an ELG is based on
existing technologies applied to existing operations, and therefore cannot anticipate the appropriate technologies for future
developments. IPAA argues that EPA's pursuit of a CBM ELG
will not provide significant environmental benefits and could
create some disadvantages.
IPAA also questioned the results of EPA's final study, which
assumed wellhead gas prices for CBM ranging from $6.94 an
Mcf to $9.65 an Mcf. While those prices may have been reflective of the market in 2008, they bear no resemblance to today's

"As with many environmental concerns,
the existence and success of state regulatory

"

efforts need to be assessed.

natural gas market or projected prices. Using estimates from
the U.S. Energy Information Administration's 2011 Annual
Energy Outlook, the 2011 average lower-48 wellhead price is
$4.09 an Mcf, and is forecast to remain below $5.00 an Mcf
until 2026. If EPA plans to assess best available technology
economically achievable-the standard for regulation under the
CWA-in the context of pursuing a CBM ELG, it should at least
base its economic analysis on accurate price information.
IPAA expressed similar concerns with EPA's consideration
of an ELG for shale gas. As with CBM, the composition of produced water is not within the control of the producer. However,
with SGE, the scope of an ELG for produced water management
would be very narrow-possibly irrelevant. The predominant
management system for SGE produced water is injection under
the Safe Drinking Water Act Class II Underground Injection
Control program.
Only in Pennsylvania has there been any widespread discharge of SGE produced waters, either through publicly owned
treatment works or centralized waste treatment facilities. On its
own, the Pennsylvania Department of Environmental Protection
has limited these discharges dramatically. Therefore, it is questionable as to whether there is any rationale for federal ELGs for
shale gas. The mandated reliance of ELGs on data from other
producing areas would ignore the unique water composition
from the Marcellus formation, relative to other producing
regions. Additionally, past information may not accurately predict the future as the industry moves to recycle its wastewater.
As with many of the environmental concerns raised in connection with producing natural gas, the existence and success
of state regulatory efforts need to be assessed. EPA's newest
plan for ELGs is no different. The appropriateness of EPA's
actions is questionable. Yet, if the agency proceeds, it must
have current and correct data on which to base its decisions.
IPAA is participating in discussions to develop accurate information.
r

SUSAN GINSBERG is vice
president of crude oil and natural gas regulatory affairs for
the Independent Petroleum
Association of America. She
covers legislation and regulation, focusing on the CFTC
and FERC. Her experience in
natural gas regulatory affairs
spans 25 years.
JANUARY 2012 27



American Oil and Gas Reporter - January 2012

Table of Contents for the Digital Edition of American Oil and Gas Reporter - January 2012

The American Oil and Gas Reporter - January 2012
Contents
Reports
Calendar
Oil & Gas Counts
State Legislative
Industry Digest
Tech Connections
Washington Watch
Federal Legislation
EPA
Gulf of Mexico
Resource Plays Providing Wealth of Opportunities
Tight Plays Poised to Transform U.S. Crude Supply
El Paso Project Optimizes Eagle Ford Completion Design
Real-Time Forward Modeling Improves Bakken Horizontals
Cover Story
Financial Firms Expand Oil and Gas Divisions
Multicomponent 3-D Poised for Growth in Shale Plays
Cloud Computing Driving Business Step Changes
Advanced Attributes Improve 3-D Interpretation
3-D Data Improve Knowledge of Shale Heterogeneity
HBUR RSS Solves Granite Wash Drilling Challenges
Technologies Improve Production Consistency in Resource Plays
SaaS Helps Operator Streamline Data Management
Automation Enhances Operations in Challenging Applications
Dispersant Chemistry Combats Plugging in Low-Gravity Oil Wells
New Technologies Optimize Production
PIOGA
Drilling Regs
IOGAWV
The Presidential Papers
Energy Education
Conventions
Shale Gas
New Lits & Products
Computer Currents
Industry Focus
Classified Advertising
Advertisers Index
American Oil and Gas Reporter - January 2012 - The American Oil and Gas Reporter - January 2012
American Oil and Gas Reporter - January 2012 - 2
American Oil and Gas Reporter - January 2012 - 3
American Oil and Gas Reporter - January 2012 - 4
American Oil and Gas Reporter - January 2012 - Contents
American Oil and Gas Reporter - January 2012 - Reports
American Oil and Gas Reporter - January 2012 - 7
American Oil and Gas Reporter - January 2012 - 8
American Oil and Gas Reporter - January 2012 - 9
American Oil and Gas Reporter - January 2012 - Calendar
American Oil and Gas Reporter - January 2012 - 11
American Oil and Gas Reporter - January 2012 - 12
American Oil and Gas Reporter - January 2012 - 13
American Oil and Gas Reporter - January 2012 - Oil & Gas Counts
American Oil and Gas Reporter - January 2012 - 15
American Oil and Gas Reporter - January 2012 - Industry Digest
American Oil and Gas Reporter - January 2012 - 17
American Oil and Gas Reporter - January 2012 - 18
American Oil and Gas Reporter - January 2012 - 19
American Oil and Gas Reporter - January 2012 - 20
American Oil and Gas Reporter - January 2012 - 21
American Oil and Gas Reporter - January 2012 - 22
American Oil and Gas Reporter - January 2012 - 23
American Oil and Gas Reporter - January 2012 - 24
American Oil and Gas Reporter - January 2012 - Tech Connections
American Oil and Gas Reporter - January 2012 - 26
American Oil and Gas Reporter - January 2012 - Washington Watch
American Oil and Gas Reporter - January 2012 - Federal Legislation
American Oil and Gas Reporter - January 2012 - 29
American Oil and Gas Reporter - January 2012 - 30
American Oil and Gas Reporter - January 2012 - 31
American Oil and Gas Reporter - January 2012 - 32
American Oil and Gas Reporter - January 2012 - 33
American Oil and Gas Reporter - January 2012 - 34
American Oil and Gas Reporter - January 2012 - 35
American Oil and Gas Reporter - January 2012 - EPA
American Oil and Gas Reporter - January 2012 - 37
American Oil and Gas Reporter - January 2012 - 38
American Oil and Gas Reporter - January 2012 - 39
American Oil and Gas Reporter - January 2012 - 40
American Oil and Gas Reporter - January 2012 - 41
American Oil and Gas Reporter - January 2012 - Gulf of Mexico
American Oil and Gas Reporter - January 2012 - 43
American Oil and Gas Reporter - January 2012 - 44
American Oil and Gas Reporter - January 2012 - 45
American Oil and Gas Reporter - January 2012 - 46
American Oil and Gas Reporter - January 2012 - 47
American Oil and Gas Reporter - January 2012 - Resource Plays Providing Wealth of Opportunities
American Oil and Gas Reporter - January 2012 - 49
American Oil and Gas Reporter - January 2012 - 50
American Oil and Gas Reporter - January 2012 - 51
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American Oil and Gas Reporter - January 2012 - 57
American Oil and Gas Reporter - January 2012 - 58
American Oil and Gas Reporter - January 2012 - 59
American Oil and Gas Reporter - January 2012 - 60
American Oil and Gas Reporter - January 2012 - 61
American Oil and Gas Reporter - January 2012 - Tight Plays Poised to Transform U.S. Crude Supply
American Oil and Gas Reporter - January 2012 - 63
American Oil and Gas Reporter - January 2012 - 64
American Oil and Gas Reporter - January 2012 - 65
American Oil and Gas Reporter - January 2012 - 66
American Oil and Gas Reporter - January 2012 - 67
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American Oil and Gas Reporter - January 2012 - 72
American Oil and Gas Reporter - January 2012 - 73
American Oil and Gas Reporter - January 2012 - 74
American Oil and Gas Reporter - January 2012 - 75
American Oil and Gas Reporter - January 2012 - 76
American Oil and Gas Reporter - January 2012 - El Paso Project Optimizes Eagle Ford Completion Design
American Oil and Gas Reporter - January 2012 - 78
American Oil and Gas Reporter - January 2012 - 79
American Oil and Gas Reporter - January 2012 - 80
American Oil and Gas Reporter - January 2012 - 81
American Oil and Gas Reporter - January 2012 - 82
American Oil and Gas Reporter - January 2012 - 83
American Oil and Gas Reporter - January 2012 - 84
American Oil and Gas Reporter - January 2012 - 85
American Oil and Gas Reporter - January 2012 - 86
American Oil and Gas Reporter - January 2012 - Real-Time Forward Modeling Improves Bakken Horizontals
American Oil and Gas Reporter - January 2012 - 88
American Oil and Gas Reporter - January 2012 - 89
American Oil and Gas Reporter - January 2012 - 90
American Oil and Gas Reporter - January 2012 - 91
American Oil and Gas Reporter - January 2012 - 92
American Oil and Gas Reporter - January 2012 - 93
American Oil and Gas Reporter - January 2012 - Cover Story
American Oil and Gas Reporter - January 2012 - 95
American Oil and Gas Reporter - January 2012 - 96
American Oil and Gas Reporter - January 2012 - 97
American Oil and Gas Reporter - January 2012 - 98
American Oil and Gas Reporter - January 2012 - 99
American Oil and Gas Reporter - January 2012 - 100
American Oil and Gas Reporter - January 2012 - 101
American Oil and Gas Reporter - January 2012 - 102
American Oil and Gas Reporter - January 2012 - Financial Firms Expand Oil and Gas Divisions
American Oil and Gas Reporter - January 2012 - 104
American Oil and Gas Reporter - January 2012 - 105
American Oil and Gas Reporter - January 2012 - 106
American Oil and Gas Reporter - January 2012 - 107
American Oil and Gas Reporter - January 2012 - 108
American Oil and Gas Reporter - January 2012 - 109
American Oil and Gas Reporter - January 2012 - Multicomponent 3-D Poised for Growth in Shale Plays
American Oil and Gas Reporter - January 2012 - 111
American Oil and Gas Reporter - January 2012 - 112
American Oil and Gas Reporter - January 2012 - 113
American Oil and Gas Reporter - January 2012 - 114
American Oil and Gas Reporter - January 2012 - 115
American Oil and Gas Reporter - January 2012 - 116
American Oil and Gas Reporter - January 2012 - 117
American Oil and Gas Reporter - January 2012 - 118
American Oil and Gas Reporter - January 2012 - Cloud Computing Driving Business Step Changes
American Oil and Gas Reporter - January 2012 - 120
American Oil and Gas Reporter - January 2012 - 121
American Oil and Gas Reporter - January 2012 - 122
American Oil and Gas Reporter - January 2012 - 123
American Oil and Gas Reporter - January 2012 - 124
American Oil and Gas Reporter - January 2012 - 125
American Oil and Gas Reporter - January 2012 - Advanced Attributes Improve 3-D Interpretation
American Oil and Gas Reporter - January 2012 - 127
American Oil and Gas Reporter - January 2012 - 128
American Oil and Gas Reporter - January 2012 - 129
American Oil and Gas Reporter - January 2012 - 130
American Oil and Gas Reporter - January 2012 - 131
American Oil and Gas Reporter - January 2012 - 132
American Oil and Gas Reporter - January 2012 - 133
American Oil and Gas Reporter - January 2012 - 134
American Oil and Gas Reporter - January 2012 - 3-D Data Improve Knowledge of Shale Heterogeneity
American Oil and Gas Reporter - January 2012 - 136
American Oil and Gas Reporter - January 2012 - 137
American Oil and Gas Reporter - January 2012 - 138
American Oil and Gas Reporter - January 2012 - 139
American Oil and Gas Reporter - January 2012 - 140
American Oil and Gas Reporter - January 2012 - 141
American Oil and Gas Reporter - January 2012 - 142
American Oil and Gas Reporter - January 2012 - HBUR RSS Solves Granite Wash Drilling Challenges
American Oil and Gas Reporter - January 2012 - 144
American Oil and Gas Reporter - January 2012 - 145
American Oil and Gas Reporter - January 2012 - 146
American Oil and Gas Reporter - January 2012 - 147
American Oil and Gas Reporter - January 2012 - 148
American Oil and Gas Reporter - January 2012 - 149
American Oil and Gas Reporter - January 2012 - 150
American Oil and Gas Reporter - January 2012 - Technologies Improve Production Consistency in Resource Plays
American Oil and Gas Reporter - January 2012 - 152
American Oil and Gas Reporter - January 2012 - 153
American Oil and Gas Reporter - January 2012 - 154
American Oil and Gas Reporter - January 2012 - 155
American Oil and Gas Reporter - January 2012 - 156
American Oil and Gas Reporter - January 2012 - 157
American Oil and Gas Reporter - January 2012 - 158
American Oil and Gas Reporter - January 2012 - 159
American Oil and Gas Reporter - January 2012 - 160
American Oil and Gas Reporter - January 2012 - SaaS Helps Operator Streamline Data Management
American Oil and Gas Reporter - January 2012 - 162
American Oil and Gas Reporter - January 2012 - 163
American Oil and Gas Reporter - January 2012 - 164
American Oil and Gas Reporter - January 2012 - 165
American Oil and Gas Reporter - January 2012 - Automation Enhances Operations in Challenging Applications
American Oil and Gas Reporter - January 2012 - 167
American Oil and Gas Reporter - January 2012 - 168
American Oil and Gas Reporter - January 2012 - 169
American Oil and Gas Reporter - January 2012 - 170
American Oil and Gas Reporter - January 2012 - 171
American Oil and Gas Reporter - January 2012 - 172
American Oil and Gas Reporter - January 2012 - 173
American Oil and Gas Reporter - January 2012 - 174
American Oil and Gas Reporter - January 2012 - 175
American Oil and Gas Reporter - January 2012 - 176
American Oil and Gas Reporter - January 2012 - Dispersant Chemistry Combats Plugging in Low-Gravity Oil Wells
American Oil and Gas Reporter - January 2012 - 178
American Oil and Gas Reporter - January 2012 - 179
American Oil and Gas Reporter - January 2012 - 180
American Oil and Gas Reporter - January 2012 - 181
American Oil and Gas Reporter - January 2012 - New Technologies Optimize Production
American Oil and Gas Reporter - January 2012 - 183
American Oil and Gas Reporter - January 2012 - 184
American Oil and Gas Reporter - January 2012 - 185
American Oil and Gas Reporter - January 2012 - 186
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American Oil and Gas Reporter - January 2012 - 190
American Oil and Gas Reporter - January 2012 - 191
American Oil and Gas Reporter - January 2012 - 192
American Oil and Gas Reporter - January 2012 - 193
American Oil and Gas Reporter - January 2012 - PIOGA
American Oil and Gas Reporter - January 2012 - 195
American Oil and Gas Reporter - January 2012 - 196
American Oil and Gas Reporter - January 2012 - 197
American Oil and Gas Reporter - January 2012 - Drilling Regs
American Oil and Gas Reporter - January 2012 - 199
American Oil and Gas Reporter - January 2012 - IOGAWV
American Oil and Gas Reporter - January 2012 - 201
American Oil and Gas Reporter - January 2012 - 202
American Oil and Gas Reporter - January 2012 - 203
American Oil and Gas Reporter - January 2012 - 204
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American Oil and Gas Reporter - January 2012 - 207
American Oil and Gas Reporter - January 2012 - The Presidential Papers
American Oil and Gas Reporter - January 2012 - 209
American Oil and Gas Reporter - January 2012 - 210
American Oil and Gas Reporter - January 2012 - 211
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American Oil and Gas Reporter - January 2012 - 247
American Oil and Gas Reporter - January 2012 - 248
American Oil and Gas Reporter - January 2012 - Energy Education
American Oil and Gas Reporter - January 2012 - Conventions
American Oil and Gas Reporter - January 2012 - 251
American Oil and Gas Reporter - January 2012 - Shale Gas
American Oil and Gas Reporter - January 2012 - 253
American Oil and Gas Reporter - January 2012 - 254
American Oil and Gas Reporter - January 2012 - 255
American Oil and Gas Reporter - January 2012 - 256
American Oil and Gas Reporter - January 2012 - 257
American Oil and Gas Reporter - January 2012 - 258
American Oil and Gas Reporter - January 2012 - 259
American Oil and Gas Reporter - January 2012 - New Lits & Products
American Oil and Gas Reporter - January 2012 - 261
American Oil and Gas Reporter - January 2012 - Computer Currents
American Oil and Gas Reporter - January 2012 - 263
American Oil and Gas Reporter - January 2012 - Industry Focus
American Oil and Gas Reporter - January 2012 - 265
American Oil and Gas Reporter - January 2012 - 266
American Oil and Gas Reporter - January 2012 - 267
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American Oil and Gas Reporter - January 2012 - 269
American Oil and Gas Reporter - January 2012 - 270
American Oil and Gas Reporter - January 2012 - 271
American Oil and Gas Reporter - January 2012 - 272
American Oil and Gas Reporter - January 2012 - Classified Advertising
American Oil and Gas Reporter - January 2012 - Advertisers Index
American Oil and Gas Reporter - January 2012 - 275
American Oil and Gas Reporter - January 2012 - 276
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