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 1-03 
i

TABLE OF CONTENTS 

Page 

1.0 SITES VISITED AND DATES .................................................................... 3

2.0 ATTENDEES ........................................................................................... 3

3.0 BACKGROUND AND OBJECTIVES ............................................................ 3

4.0 OVERVIEW OF COALBED METHANE PRODUCTION AND THE PINEDALE 

ANTICLINE AREA ................................................................................... 5

5.0 OVERVIEW OF THE CALPET DISPOSAL FACILITY FOR OIL AND GAS 

EXPLORATION AND PRODUCTION WASTES ............................................ 8

6.0 REFERENCES ........................................................................................ 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 FOR DATA 

SUBMISSION TO EPA ADDITIONAL INFORMATION PROVIDED BY 

WASTEWATER SOLUTIONS 
ii

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 ..................................................................................................10
3

1.0 SITES VISITED AND DATES

On June 18, 2009, representatives from the U.S. Environmental 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 approximately 14 miles southwest of Big Piney in 

Sublette County, Wyoming (Latitude 42 o 23’ 40.7” North, Longitude 110o 16’ 25.0” West). See 

Appendix A for a map and GPS coordinates of the site visited. Mr. Quinn Ellingford and Mr. 

Cole Ellingford, Calpet, greeted the participants and provided an operational overview of the 

Calpet site. 

2.0 ATTENDEES

Meeting participants are listed below. Contact information for the participants is listed in 

Appendix B. 

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

Carey Johnston, Coalbed Methane Detailed Study Project 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 BACKGROUND AND OBJECTIVES

The EPA organized a site visit to the Pinedale Anticline and Powder River Basin in 

Wyoming as part of the data collection efforts for EPA’s Coalbed Methane Detailed Study. The 
4

Coalbed Methane (CBM) sector was identified for additional 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 Gas Point Source Category to control pollutant 

discharge in CBM produced water. EPA is working with a range of stakeholders (e.g., industry 

representatives; Federal, State, and Tribal representatives; public interest groups and landowners; 

and water treatment experts) throughout the CBM Detailed 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 interested parties and provide an overview of 

the study and data collection needs. During the stakeholder 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 site visits to view production in the 

following basins: 

 Black Warrior (Alabama); 

 Upper Appalachian (southwestern Pennsylvania, eastern Ohio, northern 

West Virginia); 

 Lower Appalachian (southern Virginia and West Virginia); 

 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 spacing); produced water reuse and disposal 

methods; treatment methods; and economic information such as descriptions of factors affecting 

decisions to begin production or shut-in a well, lease, or other area. 

EPA visited the Pinedale Anticline area to identify additional technologies to treat and/or 

dispose of CBM produced water, to observe differences and similarities in production and 

 

1

 See 21 December 2006; 71 FR 76644. 
5

treatment, and to gather additional cost information and monitoring data for use in developing 

technology costs and associated pollutant reductions. 

In 1980, Congress conditionally exempted certain oil and gas E&P wastes from being 

regulated as hazardous wastes under Subtitle C of the Resource Conservation and Recovery Act 

(RCRA). Calpet owns and operates a commercial disposal site that accepts exempt E&P wastes 

such as drilling fluids and produced water (including those generated by CBM operations). 

Representatives from Calpet led a tour of their treatment and disposal facility for exempt 

E&P wastes. Mr. Quinn Ellingford and Mr. Cole Ellingford greeted the participants and 

provided an operational overview of the Calpet facility. This report presents an overview of the 

tour, as well as an overview of CBM production in the Pinedale Anticline area located 

approximately 25 miles northeast of the Calpet facility. Because exempt E&P wastes are 

generated by a variety of oil and gas operations and 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 OVERVIEW OF COALBED METHANE PRODUCTION AND THE PINEDALE 

ANTICLINE AREA

The geologic process that progressively converts plant 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 removed 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, large 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 coal 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 the Pinedale Anticline. In September 2008, 

BLM signed the record of decision (ROD) for continued development (drilling and production 

operations for natural gas wells) of the Pinedale Anticline 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-permeability (tight) gas reservoir developed in 

this area, is located to the west of and adjacent to the Pinedale Anticline. See Figure 4-1. 

Since 2000, most natural gas development in the PAPA 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, which originates in the Wyoming and Wind 

River ranges to the north and northwest. Three other perennial streams flow through the PAPA 

including: Duck Creek; East Fork River; and Pine Creek, all of which are tributary to the New 

Fork River. Most of the PAPA is drained by numerous 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 OVERVIEW OF THE CALPET DISPOSAL FACILITY FOR OIL AND GAS 

EXPLORATION AND PRODUCTION WASTES

Calpet owns and operates a commercial disposal site that accepts exempt E&P wastes 

such as drilling fluids and produced water (including those generated by CBM operations). The 

Calpet facility is located on a 420-acre site approximately 14 miles southwest of Big Piney in 

Sublette County, Wyoming (Latitude 42 o 23’ 40.7” North, Longitude 110o

 16’ 25.0” West). 

Calpet manages waste deliveries using controlled access (e.g., gate key cards) and a video 

surveillance security system that allows for continuous operation 24 hours per day, 365 days per 

year. Calpet maintains a recordkeeping system which 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 single 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 geomembrane liner. Calpet representatives explained 

that the liner system is designed to enable the identification of a leak and narrow the location to 

within a 2-acre zone. Site representatives estimated that the water table ranges between 10 to 25 

feet below the Calpet site, and the local aquifer is located approximately 20 feet below the water 

table. 

The contents of each cell are managed for certain waste characteristics. Figure 5-1 

depicts the layout of the cells. Most exempt E&P wastes are directed to Cell No. 4 (refer to 

Figure 5-2). Cell No. 4 is covered with netting and the surface is skimmed using various 

methods. This cell is primarily equipped with a surface 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 process, the wastes are conveyed to Cell No. 5, an 

open impoundment used for biological treatment of the remaining hydrocarbons. Biological 

treatment is intended to reduce the hydrocarbon constituents 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 in Cell No. 6 are eventually transferred to other 

cells for final placement. When these cells have filled, a final cover (cap) is placed on the cell 

for closure. Cell Nos. 1, 2, and 3 have already been 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 evaporators that use a programmable logic 

controller to adjust the evaporators based on weather conditions (e.g., wind and air temperature). 

The Calpet representatives explained that the design is intended to double the natural evaporation 

rate, but have found that evaporation is more successful 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 $16,000 in evaporator equipment damage had 

occurred due to a recent lightening strike, and also noted that the cold and wet weather 

experienced during the site visit would have precluded use of the evaporators had they not been 

damaged. 

6.0 REFERENCES

U.S. Department of the Interior, Bureau of Land Management, 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 VISITED
Overview Map 
Detail Map 
 

Appendix B 

LIST OF ATTENDEES 
B-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.com 
B-1