## Final Site Visit Report: Calpet, LLC Disposal Facility Pinedale Anticline Area Coalbed Methane Detailed Study

November 15, 2010

Prepared For:

U.S. Environmental Protection Agency Office of Water, Office of Science and Technology Engineering and Analysis Division 1200 Pennsylvania Avenue, NW Washington, D.C. 20460

Prepared By:

PG Environmental, LLC 447 B Carlisle Drive Herndon, VA 20170

EPA Contract EP-C-07-029; Work Assignment Numbers 1 -01 and 1-03i TABLE OF CONTENTS

Page



### 1.0 S ITES 

### V ISITED AND 

### D ATES



### .................................................. .................. 3

2.0 A TTENDEES



### .................................................. ......................................... 3

3.0 B ACKGROUND AND 

### O BJECTIVES



### .................................................. .......... 3

4.0 O VERVIEW OF 

### C OALBED 

### M ETHANE 

### P RODUCTION AND THE 

### P INEDALE



### A NTICLINE 

### A REA



### .................................................. ................................. 5

5.0 O VERVIEW OF THE 

### C ALPET 

### D ISPOSAL 

### F ACILITY FOR 

### O IL AND 

### G AS



### E XPLORATION AND 

### P RODUCTION 

### W ASTES 

### ............................................ 8

6.0 R EFERENCES



### .................................................. ...................................... 10

Appendix A MAPS SHOWING GLOBAL POSITIONING SYSTEM ( GPS) POINT

LOCATIONS FOR SITES VISITED

Appendix B LIST OF ATTENDEES

Appendix C EPA INFORMATION REQUEST MEMORANDUM DATED JUNE 10, 2009

Appendix D MICROSOFT EXCEL® SPREADSHEET TEMPLATE FO R DATA

SUBMISSION TO EPA ADDITIONAL INFORMATION PROVIDED B Y WASTEWATER SOLUTIONSii LIST OF FIGURES

Page

Figure 4-1. Overview Map of the Pinedale Anticline , Wyoming ......................................... .......7

Figure 5-1. Cell Layout at Calpet Facility .......

................................................... .........................9

Figure 5-2. View of Cell No. 4 ...................

................................................... ............................103

1.0 S ITES V ISITED AND D ATES

On June 18, 2009, representatives from the U.S. Env ironmental Protection Agency (EPA) and the Wyoming Department of Environmental Quality (DEQ) met with representatives from Calpet, LLC (“Calpet”) to discuss and observe their disposal facility for exempt oil and gas exploration and production (E&P) wastes. The site visit took place at the Calpet treatment and disposal facility (“Calpet facility”) located appro ximately 14 miles southwest of Big Piney in Sublette County, Wyoming (Latitude 42 o 23’ 40.7” North, Longitude 110 o 16’ 25.0” West). See Appendix A for a map and GPS coordinates of the sit e visited. Mr. Quinn Ellingford and Mr. Cole Ellingford, Calpet, greeted the participants a nd provided an operational overview of the Calpet site.

2.0 A TTENDEES

Meeting participants are listed below. Contact inf ormation for the participants is listed in Appendix B.

U.S. EPA Office of Water, Engineering and Analysis Division

Carey Johnston, Coalbed Methane Detailed Study Proj ect Lead, Washington, D.C. Tom Born, Environmental Assessor, Washington, D.C.

Wyoming Department of Environmental Quality (WYDEQ) Dennis Lamb, CBM Group Supervisor, Casper, WY

PG Environmental (Contractor to EPA) Paul Hanson, Golden, CO

Calpet Quinn Ellingford, Evanston, WY

Cole Ellingford, Evanston, WY

3.0 B ACKGROUND AND O BJECTIVES

The EPA organized a site visit to the Pinedale Anti cline and Powder River Basin in Wyoming as part of the data collection efforts for EPA’s Coalbed Methane Detailed Study. The4

Coalbed Methane (CBM) sector was identified for add itional review in the final 2006 Effluent Guidelines Program Plan. 1 EPA is conducting this review to determine if it would be appropriate to revise the effluent guidelines for the Oil and G as Point Source Category to control pollutant discharge in CBM produced water. EPA is working wi th a range of stakeholders (e.g., industry representatives; Federal, State, and Tribal represe ntatives; public interest groups and landowners; and water treatment experts) throughout the CBM Det ailed Study to obtain the best information available on the industry. To initiate stakeholder involvement, EPA conducted seven teleconferences in June and July 2007 to identify i nterested parties and provide an overview of the study and data collection needs. During the st akeholder calls EPA provided information on the following topics:

 EPA Regulation Development Process;

 Initial Review of CBM Sector;

 CBM Information Collection Request (ICR); and

 Schedule and Next Steps.

The EPA conducted initial site visits in the second half of 2007 to observe a range of CBM operations that show the typical production and water management options. Because CBM operations vary by basin, EPA conducted five si te visits to view production in the following basins:

 Black Warrior (Alabama);

 Upper Appalachian (southwestern Pennsylvania, easte rn Ohio, northern West Virginia);

 Lower Appalachian (southern Virginia and West Virgi nia);

 Powder River (Wyoming and Montana); and

 San Juan and Raton (Colorado and New Mexico).

During the site visits, EPA collected general site information (e.g., location, operator name, field name, pooling arrangements, well spacin g); produced water reuse and disposal methods; treatment methods; and economic informatio n such as descriptions of factors affecting decisions to begin production or shut-in a well, le ase, or other area.

EPA visited the Pinedale Anticline area to identify additional technologies to treat and/or dispose of CBM produced water, to observe differenc es and similarities in production and

1 See 21 December 2006; 71 FR 76644.5

treatment, and to gather additional cost informatio n and monitoring data for use in developing technology costs and associated pollutant reduction s.

In 1980, Congress conditionally exempted certain oi l and gas E&P wastes from being regulated as hazardous wastes under Subtitle C of t he Resource Conservation and Recovery Act (RCRA). Calpet owns and operates a commercial disp osal site that accepts exempt E&P wastes such as drilling fluids and produced water (includi ng those generated by CBM operations).

Representatives from Calpet led a tour of their tre atment and disposal facility for exempt E&P wastes. Mr. Quinn Ellingford and Mr. Cole Elli ngford greeted the participants and provided an operational overview of the Calpet faci lity. This report presents an overview of the tour, as well as an overview of CBM production in t he Pinedale Anticline area located approximately 25 miles northeast of the Calpet faci lity. Because exempt E&P wastes are generated by a variety of oil and gas operations an d production areas, it is important to note that the wastes received by the Calpet facility are not restricted to the CBM sector or Pinedale

Anticline area.

4.0 O VERVIEW OF C OALBED M ETHANE P RODUCTION AND THE P INEDALE

A NTICLINE A REA

The geologic process that progressively converts pl ant material to coal (coalification) generates large quantities of natural gas that are stored in the coal seams. The natural gas consists of approximately 92-96 percent methane, 3. 5 percent nitrogen, and up to 4 percent carbon dioxide. The natural gas contained in and r emoved from the coal seams is called coalbed methane (CBM). The increased pressures from water in the coal seams force the natural gas to adsorb to the coal. To extract the CBM, operators remove water from the coal seam to lower the hydrostatic pressure in the coal seam, which allows the methane to desorb from the coal and flow to the natural gas gathering lines. Typically, lar ge amounts of water are produced during the early stages of CBM production and then the amounts of water decrease over the life of the well as the methane production increases. The quantity and quality of produced water will vary from basin to basin, within a particular basin, from coa l seam to coal seam, and over the lifetime of a

CBM well.6

The Pinedale Anticline is geologic feature located in western Wyoming within the Greater Green River Basin. The U.S. Department of the Interior, Bureau of Land Management (BLM) manages a jurisdictional area that includes t he Pinedale Anticline. In September 2008, BLM signed the record of decision (ROD) for continu ed development (drilling and production operations for natural gas wells) of the Pinedale A nticline Project Area (PAPA). The PAPA consists of approximately 198,000 acres located in Sublette County, Wyoming, near the Town of Pinedale. The Jonah Field, the first major low-per meability (tight) gas reservoir developed in this area, is located to the west of and adjacent t o the Pinedale Anticline. See Figure 4-1.

Since 2000, most natural gas development in the PAP A has been along the Anticline Crest, which is approximately 2 to 3 miles wide, 25 to 30 miles long, and centered along the length of the PAPA (BLM, 2008).

The major streams draining the PAPA are the Green and New Fork rivers. The New Fork River originates in the Wind River Range north and east of the Pinedale Anticline, and flows across the PAPA to join the Green River, whic h originates in the Wyoming and Wind River ranges to the north and northwest. Three oth er perennial streams flow through the PAPA including: Duck Creek; East Fork River; and Pine Cr eek, all of which are tributary to the New Fork River. Most of the PAPA is drained by numerou s ephemeral streams, each of which collect water from small sub-watersheds which are tributary to the Green River or New Fork River, respectively (BLM, 2008).7 Figure 4-1. Overview Map of the Pinedale Anticline , Wyoming (Source: Bureau of Land Management, 2008)8

5.0 O VERVIEW OF THE C ALPET D ISPOSAL F ACILITY FOR O IL AND G AS

E XPLORATION AND P RODUCTION W ASTES

Calpet owns and operates a commercial disposal site that accepts exempt E&P wastes such as drilling fluids and produced water (includi ng those generated by CBM operations). The Calpet facility is located on a 420-acre site appro ximately 14 miles southwest of Big Piney in Sublette County, Wyoming (Latitude 42 o 23’ 40.7” North, Longitude 110 o 16’ 25.0” West).

Calpet manages waste deliveries using controlled ac cess (e.g., gate key cards) and a video surveillance security system that allows for contin uous operation 24 hours per day, 365 days per year. Calpet maintains a recordkeeping system whic h contains waste manifest and bill of lading information such as the volume and type of material , generator, and transporter.

The Calpet facility consists of six active cells. All cells are equipped with a doublegeomembrane liner system that consists of two singl e 60-mil liners and leak detection. A geotextile layer separates the geomembrane liners, and a minimum of 1 foot of clay liner (10 -5

cm/sec permeability) is beneath the lower geomembra ne liner. Calpet representatives explained that the liner system is designed to enable the ide ntification of a leak and narrow the location to within a 2-acre zone. Site representatives estimat ed that the water table ranges between 10 to 25 feet below the Calpet site, and the local aquifer i s located approximately 20 feet below the water

table.

The contents of each cell are managed for certain w aste characteristics. Figure 5-1 depicts the layout of the cells. Most exempt E&P w astes are directed to Cell No. 4 (refer to Figure 5-2). Cell No. 4 is covered with netting an d the surface is skimmed using various methods. This cell is primarily equipped with a su rface skimmer system that directs the skimmings to thermal oil water separation units. A portion of the resulting oil is reclaimed and sold to an oil refinery. After the skimming proces s, the wastes are conveyed to Cell No. 5, an open impoundment used for biological treatment of t he remaining hydrocarbons. Biological treatment is intended to reduce the hydrocarbon con stituents of the waste for subsequent disposal.9 Figure 5-1. Cell Layout at Calpet Facility

Solids that are separated during the treatment and disposal process are collected in Cell No. 6. In addition, when Calpet accepts E&P wastes having a high solid content, they are placed directly into Cell No. 6. Solids that accumulate i n Cell No. 6 are eventually transferred to other cells for final placement. When these cells have f illed, a final cover (cap) is placed on the cell for closure. Cell Nos. 1, 2, and 3 have already be en capped, and the surfaces have been revegetated. Cell No. 9 is the next cell that will be capped under current plans.

After biological treatment, the liquids are routed to Cell Nos. 7 and 8 for accelerated evaporation. These cells are equipped with spray e vaporators that use a programmable logic controller to adjust the evaporators based on weath er conditions (e.g., wind and air temperature). The Calpet representatives explained that the desig n is intended to double the natural evaporation rate, but have found that evaporation is more succe ssful in cells that are placed at lower altitudes of the property.10 Figure 5-2. View of Cell No. 4

Calpet generally uses the spray evaporators during warm and dry conditions from mid May to mid October; however, the spray evaporators were not operational during the site visit. The Calpet representatives explained that nearly $1 6,000 in evaporator equipment damage had occurred due to a recent lightening strike, and als o noted that the cold and wet weather experienced during the site visit would have preclu ded use of the evaporators had they not been damaged.

6.0 R EFERENCES

U.S. Department of the Interior, Bureau of Land Man agement, 2008. “Final Supplemental Environmental Impact Statement, Pinedale Anticline Oil and Gas Exploration and Development Project, Sublette County, Wyoming,” Pinedale Field Office. Pinedale, Wyoming, June.Appendix A

MAPS SHOWING GPS POINT LOCATIONS FOR SITES VISITEDOverview MapDetail MapAppendix B

LIST OF ATTENDEESB-1

First Name Last Name Organization Phone Number Email Carey Johnston EPA Office of Water 202-566-1014 Johnston.Carey@epamail.epa.gov

Tom Born EPA Office of Water 202-566-1001 Born.Tom@epamail.epa.gov Dennis Lamb WYDEQ 307-473-3452 dlamb@state.wy.us Quinn Ellingford Calpet 307-789-7585 Cole Ellingford Calpet 307-789-7585

Paul Hanson PG Environmental (contractor to EPA) 303-279-1778 ext. 104 paul.hanson@pgenv.comB-1