COMMENTS ON PROPOSED GENERAL PERMIT IN COLORADO - CDPS PERMIT NUMBER COG-840000 DISCHARGES ASSOCIATED WITH PRODUCED-WATER TREATMENT FACILITIES

Sep 29, 2026

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Comments submitted by Pioneer Natural Resources USA Inc. address Colorado’s proposed general permit for discharges from produced-water treatment facilities processing water from oil and gas operations, with focus on coalbed methane (CBM). The letter challenges the practical need and applicability of the permit, arguing CBM treatment technologies remain largely unproven in Colorado and adoption would be costly and high risk. It also critiques stringent, conservatively derived effluent limits and urges a compliance schedule and flexible adjustments to support feasible compliance and reduce permit backlog.

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COMMENTS ON PROPOSED GENERAL PERMIT IN COLORADO

Need for the permit

Disadvantages of the general permit as proposed

Compliance Schedule

SAR and EC limits

# COMMENTS ON PROPOSED GENERAL PERMIT IN COLORADOCDPS PERMIT NUMBER COG-840000DISCHARGES ASSOCIATED WITH PRODUCED-WATER TREATMENT FACILITIES Pioneer Natural Resources USA Inc.Prepared by Gerald JacobJune 5,2009 The Water Quality Control Division of the Colorado Department of Public Health and Environment(CDPHE)has proposed a general permit for discharges from treatment facilities thatprocess produced water from oil and gas operations,including coalbed methane(CBM)operations.With this letter,Pioneer Natural Resources USA Inc.(Pioneer)is submittingcomments on the proposed general permit,specifically as it pertains to the treatment of producedwater from coalbed methane operations.Pioneer operates a major CBM project in the RatonBasin of Colorado.It also has a pilot CBM project in northwest Colorado at which it has pilot-tested two different produced water treatment plants. Pioneer endorses the comments on the proposed general permit that were submitted by DeltaPetroleum Corporation.In addition,Pioneer offers the following comments that would make thegeneral permit option more attractive to producers and encourage the use of water treatmenttechnologies for discharge of produced water. Need for the permit.According to the CDPHE,the proposed permit was developed to addressthe “pressing need”(Fact Sheet p.3)to address the backlog of permit applications for thedischarge of produced water.Pioneer has several permit renewals pending with CDPHE.However,the proposed general permit only applies to treated surface water discharged from acentralized facility or a commercial disposal facility.As one of the two largest CBM producersin Colorado,Pioneer is surprised to learn that there is a pressing demand for permits that wouldapply to CBM treatment facilities.In our experience,treatment of CBM water is still in itsinfancy.With one or two exceptions water treatment technologies suitable for Colorado's CBMproduced waters are untested or have only limited operational history which makes the adoptionof any treatment system a costly,high risk experiment.Pioneer no longer operates its CBM watertreatment plant (an ion exchange plant)in northwest Colorado and knows of only one or twopossible CBM treatment plants to which this general permit might apply.To date,CBM watertreatment technologies have not been feasible or applicable to CBM operations in Colorado.Pioneer requests clarification in the Fact Sheet as to the current,practical need for andapplicability of such a general permit to water treatment plants and CBM operations in Colorado. Disadvantages of the general permit as proposed.There are a number of disadvantages withthe requirements of the proposed general permit that need to be addressed in order for the generalpermit to be useful and to encourage oil and gas producers to pursue costly treatment,which has ahigh risk of not meeting all the permit general requirements.One major disadvantage of thegeneral permit is that all effluent limitations set in this permit are based upon the most stringent water quality standards,the regulations for effluent limitations,and/or the federal effluentlimitation guidelines.More reasonable and practical effluent limits may be obtained with anindividual permit because an individual permit can include determinations of the assimilativecapacity of the receiving stream based on the dilution that results from mixing with receivingwaters that already have ambient concentrations lower than the target stream standard.Thus,thegeneral permit pushes more costly treatment in excess of that required to protect stream qualitywhich will have the effect of encouraging a producer to pursue an individual permit or considernon-discharge options(such as deep injection)rather than to adopt more costly levels of treatmentin excess of that required to protect environmental quality.If the objective of the general permitis to reduce permit backlog and encourage the use of water treatment technologies,adopting morereaso

FAQs

Why does Pioneer question the need for the proposed general permit?

Pioneer argues that CBM produced-water treatment is still early-stage in Colorado and technologies are untested or have limited operational history, making adoption a costly, high-risk experiment. It requests clarification on the current practical need and applicability of the general permit.

What disadvantages does Pioneer identify with the proposed general permit requirements?

Pioneer states that effluent limitations are based on the most stringent standards and guidance, which may push treatment beyond what is necessary to protect stream quality. It suggests individual permits could use assimilative capacity via dilution, and it notes the permit could increase reliance on individual permits or non-discharge options.

What changes does Pioneer request to improve compliance feasibility?

Pioneer requests that the general permit include a compliance schedule allowing operators to adjust effluent limits based on technological and site-specific circumstances. It also asks for an option to modify a specified effluent limit when stream segment water quality standards are demonstrated to be attained.

Sep 29, 2026

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