Memorandum
From:
Carey
A.
Johnston,
P.
E.
USEPA/
OW/
OST
ph:
(
202)
566
1014
johnston.
carey@
epa.
gov
To:
Public
Record
for
the
2006
Effluent
Guidelines
Program
Plan
EPA
Docket
Number
OW­
2004­
0032
Date:
18
July,
2006
Subject:
Final
Statewide
Oil
and
Gas
EIS
and
Proposed
Amendment
of
the
Powder
River
and
Billings
RMPs
The
Montana
Department
of
Environmental
Quality
(
MDEQ),
in
a
Final
Environmental
Impact
Statement
analyzing
coal
bed
methane
extraction,
warns
that
"
clayey"
soil,
like
that
in
the
Tongue
River
Valley,
is
vulnerable
to
damage
from
high
SAR
water
(
see
OW­
2004­
0032­
03148
"
Montana
FEIS,
Soils
Appendix
SOI­
1").

For
example,
the
MDEQ
FEIS
cautioned
that
unregulated
discharge
of
CBM
water
would
cause
"[
s]
urface
water
quality
in
some
watersheds
[
to]
be
slightly
to
severely
degraded,
resulting
in
restricted
downstream
use
of
some
waters,"
(
see
OW­
2004­
0032­
03148
"
Page
4­
72,
Montana
FEIS").
