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Water Discharge is a Pollutant, Appeals Court Says: Land Letter
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Water Discharge is a Pollutant, Appeals Court Says: Land Letter
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8/17/2012 10:12:31 AM
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Water Supply Protection
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Water Discharge is a Pollutant, Appeals Court Says: Land Letter
State
CO
Date
4/17/2003
Author
Gable, Eryn
Title
Water Discharge is a Pollutant, Appeals Court Says: Land Letter
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N. PLAINS RESOURCE v. FIDELITY EXPLORATION 4815 <br />ing metals: aluminum, arsenic, barium, beryllium, boron, cop- <br />per, lead, iron, manganese, strontium, and radium. <br />The CBM water is "salty," a characteristic measured by <br />total dissolved solids or specific conductance. The mean total <br />dissolved solids for the Tongue River is 475 mg /1 as com- <br />pared to 1,400 mg/1 for the CBM water. Related to the "salti- <br />ness" of the CBM water is the water's high Sodium <br />Absorption Ratio (SAR). SAR measures the ratio of sodium <br />to calcium and magnesium in the water. The SAR of the CBM <br />water discharged by Fidelity is on average 40 to 60 times <br />greater than the background SAR of the Tongue River. For all <br />these reasons, the CBM water is distinctly different from the <br />Tongue River water to which it is added. <br />Farmers who use water from the Tongue River for irriga- <br />tion are concerned with the "saltiness" and high SAR of CBM <br />water because of the potential hazards these characteristics <br />pose to soil structure. High SAR water, such as CBM water, <br />causes soil particles to unbind and disperse, destroying soil <br />structure and reducing or eliminating the ability of the soil to <br />drain water. The Montana Department of Environmental <br />Quality (MDEQ), in a Final Environmental Impact Statement <br />analyzing coal bed methane extraction, warns that "clayey" <br />soil, like that in the Tongue River Valley, is vulnerable to <br />damage from high SAR water. Montana Statewide Final Oil <br />and Gas Environmental Impact Statement and Proposed <br />Amendment of the Powder River and Billings Resource Man- <br />agement Plans (hereinafter "Montana FEIS "), Soils Appendix <br />SOI -1, available at www. deq.state.mt.us /CoalBedMethane/ <br />finaleis.asp. Fidelity's soil expert concluded that "the SAR of <br />CBM water creates a permeability hazard and precludes its <br />use for irrigation without mixing, treatment or addition of soil <br />amendments." The MDEQ cautioned that unregulated dis- <br />charge of CBM water would cause "[s]urface water quality in <br />some watersheds [to] be slightly to severely degraded, result- <br />ing in restricted downstream use of some waters." Id. 4 -72. <br />Some of the CBM water, however, is used by Fidelity's graz- <br />
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