# Quality Assurance Project Plan for the Review and Data Entry of the Engineering
Portions of the Coalbed Methane
Questionnaire

Prepared for:



## U.S. Environmental Protection Agency

Engineering and Analysis Division
Office of Water 1200 Pennsylvania Avenue, NW Washington, D.C. 20460

Prepared by:



### Eastern Research Group, Inc. 14555 Avion Parkway
Suite 200 Chantilly, VA 20151

Original prepared July 13, 20 11

EPA Contract No. 68

- C

- 02

- 095 Work Assignment 8

- 37History of the Quality Assurance Project Plan for the Review and Data Entry of the Engineering Portions of the Coalbed Methane Questionnaire

Revision 0

Delivery Date June 23 , 201 1

Work Assignment 8

- 37

Scope Questionnaire management

Comments Received July 12, 2011

Comments Addressed July 13, 2011

Approvali TABLE OF CONTENTS

Page

1.0 D ISTRIBUTION (E LEMENT A.3)

................................ ................................ ................ 1

2.0 P ROJECT M ANAGEMENT E LEMENTS

................................ ................................ ........ 2

2.1 Element A.4: Project Organization

................................ ............................. 2

2.2 Element A.5: Problem Definition/Background

................................ ........... 3

2.3 Element A.6: Project/Task Description

................................ ...................... 4

2.3.1 Receipt and Internal Tracking of Questionnaires

........................... 5

2.3.2 Developing the Questionnaire Database and Database Dictionary 5

2.3.3 Data Review

................................ ................................ .................... 6

2.3.4 Data Transcription

................................ ................................ .......... 6

2.3.5 Data QualityVerification

................................ ................................ . 6

2.4 Element A.7: Quality Objectives and Acceptance Criteria

........................ 6

2.5 Element A.8: Special Training/Certification

................................ ............ 10

2.6 Element A.9: Documents and Records

................................ ..................... 10

3.0 D ATA C OLLECTION AND M ANAGEMENT

................................ ................................ 11

3.1 Element B.3

– Questionnaire Data Handling and Custody

....................... 11

3.2 Element B.5

– Questionnaire Quality Control

................................ .......... 11

3.2.1 Data Review

................................ ................................ .................. 11

3.2.2 Data Transcription

................................ ................................ ........ 13

3.2.3 Data Quality Verification

................................ .............................. 14

3.3 Element B.10

– Questionnaire Data Management and Documentation

... 14

4.0 A SSESSMENT A ND O VERSIGHT E LEMENTS

................................ ............................ 15

4.1 Element C.1: Assessment of QAPP Implementation and Response Actions

................................ ................................ ................................ ................... 15

4.2 Element C.2: Reports to Management

................................ ...................... 15

5.0 U SABILITY E LEMENT

................................ ................................ ............................. 17

5.1 Data Review and Verification

................................ ................................ ... 17

5.2 Reconciliation with User Requirements (Element D.3)

........................... 17

6.0 R EFERENCES

................................ ................................ ................................ .......... 18

A PPENDIX A: PROJECT FILE MANAGEM ENT PLAN

APPENDIX B: DATABASE DESCRIPTION AND DICTIONARY

APPENDIX C: INSTRUCTIONS FOR REVIEW AND CODING

APPENDIX D : INSTRUCTIONS FOR DAT A TRANSCRIPTION

APPENDIX E: DATA QUALITY VERIFICATIONLIST OF TABLES

Page

Table 1

- 1. QAPP Distribution

................................ ................................ ................................ .......... 1

Table 2

- 1. Acceptance Criteria

................................ ................................ ................................ ........ 8

LIST OF FIGURES

Page

Figure 2

- 1. Project

- Level QA Organization for ERG’s Support for the CBM Rulemaking

........... 3

Figure 3

- 1. Exampl e Telephone Call Record

................................ ................................ ................ 13Revision No. 0 June 22, 2011

Page 1 of 1 8

1.0 D ISTRIBUTION (E LEMENT A.3)

This Quality Assurance Project Plan (QAPP) , which covers the review and data

entry of the engineering portions of the coalbed methane (CBM) detailed questionnaire will be

distributed to staff of the U.S. Environmental Protection Agency and ERG (Table 1

- 1 )

. A copy

of the document will be provided to all ERG staff involved in the project, including those who join the project after development of the QAPP.

Table 1

- 1 . QAPP Distribution

Name

Title Contact Information Mailing Address

U.S. Environmental Protection Agency

Meghan Hessenauer Technical Project Officer (202) 566

- 1040 (phone) hessenauer.meghan@epa.gov

U.S. Environmental Protection Agency Office of Science and Technology 1200 Pennsylvania Avenue, NW (4303T) Washington, DC 20460 (202) 566

- 1053 (fax) Marion Kelly Quality Assurance Manager (202) 566

- 1045 (phone) kelly.marion@epa.gov

Marla Smith Work Assignment Manager (202) 566

- 1047 smith.marla@epa.gov

Ahmar Siddiqui Alternate Work Assignment Manager (202) 566

- 1044 siddiqui.ahmar@epa.gov

Janet K. Goodwin Technology & Statistics Branch

Chief (202) 566

- 1060 (phone) goodwin.janet@epa.gov

Eastern Research Group, Inc

Deborah Bartram ERG Program Manager (703) 633

- 1669 deborah.bartram@erg.com

Eastern Research Group, Inc. 14555 Avion Parkway

Suite 200 Chantilly, VA 20151

- 1102 (703) 263

- 7280 (fax) Mary Willett

ERG Project Quality Assurance

Coordinator (703) 633

- 1615 mary.willett@erg.com

Lori Weiss Work Assignment Manager (703) 633

- 1658 lori.weiss@erg.com

Betsy Bicknell

Technical Reviewer (703) 633

- 1612 betsy.bicknell@erg.com

Dan

- Tam Nguyen

Team Member (703) 633

- 1617

dan

- tam.nguyen@erg.com

Chris Krejci

Team Member (512) 407

- 1835 chris.krejci@erg.com

Carissa Erickson

Team Member (703) 633

- 1688 carissa.erickson@erg.com

Lauren Wingo

Team Member (703) 633

- 1692 lauren.wingo@erg.com

Sarah Hays

Team Member (703) 633

- 1661 sarah.hays@erg.comRevision No. 0 June 22, 2011

Page 2 of 1 8

2.0 P ROJECT M ANAGEMENT E LEMENTS

This section addresses project management, including project history and objectives, roles and responsibilities, and project goals

. In addition, this secti on presents the

mechanisms ERG will use to ensure that all participants understand the goals and the approach to

be used for the questionnaire portion of the coalbed meth ane ( CBM ) rulemaking project

.

EPA Requirements for Quality A ssurance Project Plans (1) identifies the following nine project management elements :

**•** A.1: Title and Approval Sheet;

**•** A.2: Table of Contents;

**•** A.3: Distribution List;

**•** A.4: Project Organization;

**•** A.5: Problem Definition/Background;

**•** A.6: Project/Task Description;

**•** A.7: Quality Objectives;

**•** A.8: Special Training/Certification; and

**•** A.9: Project Documents and Records.

Elements A.1 through A.3 have been provided earlier in this document. The remaining el ements are presented below.

2.1 Element A.4: Project Organization

Project Organ ization is depicted in Figure 2

- 1

, listing the staff with program management and technical responsibilities and those with QA/QC roles. It shows the relationship

and lines of commun ication among all project participants, including those from EPA

.

The ERG Work Assignment Manager ( WAM ) will be the principal contact for the EPA WAM on project issues, deliverables, and schedule. The ERG WAM will be responsible

for :

**•** E nsuring that ERG’s q uality of work, schedule, and budget meet the requirements

of the EPA effluent guidelines program;

**•** P roviding technical direction to ERG staff and managing the daily activities on the project;

**•** O btain ing appropriate technical review of all ERG deliverabl es and ensuring deliverables conform to EPA’s technical review requirements ; and

**•** Keeping the ERG Project QA Coordinator and the ERG Pro gram Manager advised of any quality problems that arise

.

Ms. Mary Willett will serve as Project QA Coordinator, responsible for ensuring that the requirements of this QAPP are implemented and documented. She also serves as ERG’sRevision No. 0 June 22, 2011

Page 3 of 1 8

overall Corporate QA Manager and as such ensure s that project

- specific QA/QC programs are

commensur ate with project objectives and with ERG’s quality system

.

Figure 2

- 1. P roject

- Level QA Organization for ERG’s Support for the CBM Rulemaking

2.2 Element A.5: Problem Definition/Background

ERG is providing technical support to the U.S. EPA for development of effluent limitations g uidelines and standards (effluent guidelines) for the CBM extraction industry. CBM is a form of natural gas that is found in coal seams and is extracted by drilling wells into the coal seams. Unlike extraction of conventional natural gas, CBM extraction re quires the removal of groundwater to reduce the pressure in the coal seam, which allows CBM to flow to the surface through the well. This recovered ground water , referred to as produced water

, may be permitted for discharge directly or indirectly via a publicly owned treatment works (POTW) to surface

water. ERG Corporate
QA Manager

ERG Project QA Coordinator

ERG Technical

Reviewers ERG Program Manager

ERG Work Assignment

Manager EPA Work Assignment Manager

EPA QA Manager

Lines of Communication Reporting and Authority EPA Project Officer

ERG

StaffRevision No. 0 June 22, 2011

Page 4 of 1 8

In 2005, EPA identified the CBM extraction industry as a candidate for a preliminary study

. F or the 2006 annual review under Section 304m of the Clean Water Act ( CWA ) , EPA began collecting data on a n umber of active basins producing CBM and their produced water disposal practices . In 2007

, EPA began a more detailed study of the CBM industry. EPA gathered information on this industry through a series of site visits and public meetings and through an ind ustry survey. Information on these data collection efforts is

documented in Coalbed Methane Extraction: Detailed Study Report , dated December 2010 (2)

.

EPA will continue to collect information and data on the CBM industry to support

a proposed rulemaking which the y plan to publish in December 2012. EPA will evaluate the

sources and characteristics of CBM produced water and the technologies and practices available

to control the pollutants discharged. EPA’s rulemaking activities concentrate on identifying t he best technologies available for controlling pollutants discharged with CBM produced water and evaluating the performance, economic achievability, and non

- water quality impacts of these technologies.

2.3 Element A.6: Project/Task Description

EPA plans to gather information on pollutant control technologies through a site visit program , an industry questionnaire, and potentially a sampling program

. Data sources include both secondary and primary data collection, which includes a detailed indust ry questionnaire.

Under a separate contract, EPA created and distributed detailed questionnaires comprising technical (Parts A and C) and economic (Part B) sections following the statistical approach described in Battelle’s memorandum “Comparison of Ori ginal to Final Detailed Questionnaire Sample Design” dated May 27, 2011 and PG Environmental’s spreadsheet

“ Detailed Survey Mail

- out List .xls” which identifies the sample draw including the judgment sample

. This QAPP addresses tasks required to ensure the engineering portion of the questionnaire s produce reliable data that can be used to meet the project's overall objectives and goals. This QAPP addresses the following tasks related to the detailed questionnaire engineering portions (Parts A and C) :

1. Receiving copies of the questionnaire from EPA and tracking the copies through the review and data entry process ;

2. Developing a database to house the engineering data and database dictionary to
facilitate database use ;

3. Performing a technical review of the responses to Questionnaire Parts A and C to prepare them for data entry;

4. Entering data into the engineering questionnaire database;

5. Verifying the quality of the data entered into the engineering questionnaire

databaseRevision No. 0 June 22, 2011

Page 5 of 1 8

The final product delivered under this QAPP will be the engineering questionnaire database . ERG will deliver a draft engineering questionnaire database in August

2011. The following sections provide additional details on the specific questionnaire tasks ERG will complete to develop the eng ineering questionnaire database . Section 3.2 describes ERG’s approach for completing each of these tasks.

2.3.1 Recei pt and Internal Tracking of Questionnaires

EPA provided ERG with the original hardcopy questionnaire s received from the

operators and a working h ard copy. The original questionnaire will be filed and not marked. The working copy will be marked during ERG’s review to facilitate data entry. ERG will log the original and working copies of the questionnaires into the project file according to the proced ures in the Coalbed Methane Project File Management Plan , which is attached in Appendix A. In addition, ERG created a questionnaire review tracking database t o track the questionnaires through the review, coding, data entry, and quality control p rocess

. Th e tracking database table contains the following fields:

**•** Questionnaire operator ID;

**•** ERG r eviewer name;

**•** Date review completed;

**•** ERG s econd reviewer name ;

**•** Date second review completed;

**•** Second review issues found;

**•** Indication of whether the questionnaire is r eady for data entry;

**•** Data entry date;

**•** Data entry reviewer name ;

**•** Data entry issues found; and

**•** Date data entry review complete.

In addition to the fields above which are used to track review status , ERG added the following fields to the database to record whether operators provided any supplemental data

with the ir questionnaire response :

**•** Diagram (yes/no);

**•** Well number information (yes/no);

**•** Permit (yes/no); and

**•** Water characteristic data (yes/no).

2.3.2 Developing the Questionnaire Database and Database Dictionary

EPA developed a draft questionnaire database in Microsoft® Access under a

separate contract and provided the database to ERG for completion . ERG has finalized the

database structure and developed additional forms to aid in data entry. Appendix B contains a description of the database and the database dictionary

, which describes each field in the

database.Revision No. 0 June 22, 2011

Page 6 of 1 8

2.3.3 Data Review

ERG will review Parts A and C of each detailed questionnaire following the

instructions in the Instructions for Review and Coding of the En gineering Portion of the Questionnaire (Appendix C). Section 3.2 provides additional details on the data review task.

2.3.4 Data Transcription

Using the data entry forms developed for the questionnaire database, ERG will

enter data into the database. Appendix D contains the Instructions for Data Entry of the Engineering Portion of the Questionnaire and Section 3.2 provides additional details on the data transcription task.

2.3.5 Data Quality Verification

Once all the questionnaire response s have been entered into the database, ERG will perform database queries to verify the data quality . Appendix E contains a description of the queries which will be used for data quality verification and Section 3.2 provides additional

details on this task.

2.4 Element A.7: Quality Objecti ves and Acceptance Criteria

T his QAPP is intended to ensure that the engineering data in the questionnaire

database are of the quality necessary to support EPA in developing effluent guidelines. ERG will

assess the quality the engineering database by condu cting a question

- by

- question technical

review of all questionnaire responses , performing checks of the data entry of the data, and performing database queries on the compiled data

. The criteria ERG will consider in reviewing

the completeness, accuracy, and reasonableness of the engineering portions of the questionnaire

are listed in Table 2

- 1

. ERG will evaluate the quality of individual questionnaire response s , the questionnaire as a whole (o perator

- level), and the data set as a whole (final database)

. The economic portion of the questionnaire is being reviewed under a separate QAPP. In addition, ERG will evaluate the following items under this QAPP:

1. Unit response rate, that is, c ompleteness of the overall questionnaire data set (number of questionnaires returned compared to number distributed) EPA with ERG’s support will identify key questions (e.g., amount of treated produced water from question C2

- 3) that must have responses for the entire questionnaire (unit) to be considered essentially complete. Item nonresponse (missing information for individual questions) will be addressed in QAPPs for models and data analyses.

Because EPA does not intend to follow

- up with operators if information is missing, EPA will consider using other strategies such as imputation, if necessary.

2. Accuracy of individual responses

– Accuracy of individual response pertains to whether the respondents provided the correct answer to the question asked and whether the respondent interpreted the question correctly. To a ddress this aspect,Revision No. 0 June 22, 2011

Page 7 of 1 8

ERG will provide cursory review of the questionnaires for internal consistency. For example, ERG will compare the schematic with the responses to questions.

. In addition, ERG will ensure the accuracy of data transcription by using the

methods described in Section 3 and Appendix D

.Revision No. 0 June 22, 2011

Page 8 of 1 8

Table 2

- 1

. Acceptance Criteria

Data Element Acceptance Criteria Evaluation Method Documentation

Individual Questionnaire Response

- Completeness **•** Units of measure are identified;

**•** Responses to open

- ended questions are clear; and

**•** Response is legible

. **•** Evaluated during questionnaire review step following question specifications in Appendix C

. Blank and illegible responses are coded so that they are noted in the

databa se. They will not be used in an y subsequent analyses.

**•** Second review of 2 5 percent of the questionnaires by ERG WAM or survey task lead. **•** Working copy of the questionnaire

**•** Database codes transcribed to database (e.g.,

- 666 for illegible

response,

- 999 if a required response is blank)

Individual Questionnaire Response

- Reasonableness **•** Response is within the expected range of results for that response. **•** Evaluated using database queries in Appendix E to evaluate range of responses for the individual response (average, minimum, maximum). ERG will report the results of the queries to EPA. ERG will no t eliminate responses from the database. The EPA WAM will

determine follow

- up action required for outliers. **•** Query development and QA

documentation

**•** Query results

**•** Summary report to EPA

Operator

- Level

- Reasonableness **•** Response is consistent with other answers provided. **•** Initial evaluation through review procedures in Appendix

C

.

**•** Additional evaluation using database queries in Appendix E to evaluate internal consistency (e.g., amount of water produced from the wells is the amount of produced water dischar ged). Results of the queries will be reported to EPA. The EPA WAM will determine

follow

- up action required. **•** Working copy of the questionnaire

**•** Review documentation (tracking database and Form B)

**•** Query development and QA

documentation

**•** Query results

**•** Summary r eport to EPA

Operator

- Level

- Completeness **•** Operator provided the produced water

volumes for their projects. **•** Initial evaluation during review. ERG will flag any questionnaires that do not contain produced water

volumes to EPA.

**•** Additional evaluation using database queries in Appendix E to evaluate the number of complete response compared to the total number of required responses. ERG will report the results to EPA. The EPA WAM will

determine follow

- up action required and usability of the

data

. **•** Working copy of the questionnaire

**•** Review documentation (tracking database and Form B)

**•** Query development and QA

documentation

**•** Query results

**•** Summary report to EPA

Database

- Completeness **•** Database contains all detailed questionnaires passing the operator

level completeness test **•** Data entry performed using database forms by ERG staff member following instructions in Appendix D.

**•** Second review of 25 percent of the questionnaires by CBM engineering staff member. **•** Data entry documentation (tracking

database and change form in database)Revision No. 0 June 22, 2011

Page 9 of 1 8

Table 2

- 1

. Acceptance Criteria

Data Element Acceptance Criteria Evaluation Method Documentation

**•** Compare operator identification numbers in the tracking

database to the identification numbers in the engineering

database

.

Database

- Accuracy **•** Data entry was performed correctly **•** Data entry performed using database forms by ERG staff member following instructions in Appendix D

.

**•** Second review of 25 percent of the questionnaires by CBM engineering staff member. **•** Data entry documentation (tracking database and change form in

database )

Database

- Reasonableness **•** Results are consistent with expected

results **•** Evaluated using database queries in Appendix E to evaluate range of responses provided. ERG will report the results of the queries to EPA. The EPA WAM will

determine follow

- up act ion required and whether the

data is usable. **•** Query development and QA

documentation

**•** Query results

**•** Summary report to EPARevision No. 0 June 22, 2011 Page 10 of 1 8

2.5 Element A.8: Special Training/Certification

Confidential Business Information . Information and data collected may be

claimed as C BI by the operators

. Therefore, project staff will be trained in CBI handling procedures as outlined in ERG’s CBI security plan entitled Security Plan for Handling Confidential Business Information Under the Clean Wate r Act , dated September 25, 2008 and approved by Ahmar Siddiqui , EPA’s Document Control Officer for this contract, on March 12,

2009 ( 3 )

. ERG’s Document Control Officer maintains a list of ERG staff demonstrating their understanding of CBI handling procedur es by passing a written test and attending annual refresher training

. The ERG WAM will refer to the list to verify that staff have permission to

access CBI and document their clearance status. Because it is likely that respondents will claim a portion of their response as CBI, ERG will handle all questionnaires as CBI until the CBI status of the questionnaire has been confirmed by the review process.

2.6 Element A.9: Documents and Records

ERG has developed and instituted document control mechanisms for the rev iew, revision, and distribution of QAPPs. Each QAPP has a signed approval form, title page, table of contents, and EPA

- approved document control format (shown below) that appears in the upper right

- hand corner of each page:

Revision No.

Date

During the course of the project, the ERG WAM will circulate any revision to the QAPP to the project distribution list

.

Standard controls for project

- related data, documents, and records are presented in

Section 5 of ERG’s 2002 QMP ( 4 ) . ERG’s WAM is respon sible for designating an individual to

maintain all project files. The Coalbed Methane Project File Management Pla n , located in Appendix A

, provide s instructions for maintaining a centralized record containing all data

collected or accessed from other sour ces, and documents analyses of data collected (e.g., site visit reports, memoranda, industry profiles). The contents of the record will be indexed using a

Microsoft® Access database.

ERG will store all electronic information on the either the CBI or non

- CBI server at ERG’s facility, which will be backed up daily. All questionnaire files and the questionnaire

database will be stored on the CBI server. Project files will be stored in a limited access section

of ERG’s server s . ERG’s network administra tor will grant project staff access to the project network area only after access is authorized by the ERG WAM.

Management of project data is specifically described in Section 3.0 of this QAPP.Revision No. 0 June 22, 2011 Page 11 of 1 8

3.0 D ATA C OLLECTION AND M ANAGEMENT

In its Requirements of Quality Assurance Project Plans (EPA, 2001a) (1) , EPA identifies 10 elements to ensure that appropriate methods for data collection and generation are employed and documented. The 10 elements are:

**•** B.1 Sampling process design;

**•** B.2 Sampling methods;

**•** B.3 Sample handling and custody;

**•** B.4 Analytical methods;

**•** B.5 Quality control;

**•** B.6 Instrument/equipment testing, inspection and maintenance;

**•** B.7 Instrument/equipment calibration and frequency;

**•** B.8 Inspection/acceptance of supplies and consumables;

**•** B.9 Non

- direct measurements; and

**•** B.10 Data management.

The detailed questionnaires were distributed, completed, and returned under a separate EPA contract. This section covers how ERG will handle, analyze, and document the

returned questionnaires

. Therefore, only e lement s B.3, B. 5

, and B.10 are applicable to ERG’s questionnaire review

.

3.1 Element B.3

– Questionnaire Data Handling and Custody

ERG received the original c ompleted hardcopy questionnaires and a working

hard copy from EPA and will log them into the CBM record database. ERG established a database tracking system to track each questionnaire through the review , data entry, and quality assurance steps. The questionnaires are tracked by the unique operator identification number. Appendix C contains a database form with the data fields used to track the questionnaire.

ERG is entering data from Parts A and C of th e questionnaire into the engineering questionnaire database. Data entry staff will use the procedures in Appendix D to complete the data entry tasks. Additional information on the data entry is contained in Section 3.2.2 . ERG is handling all questionnaires as CBI during the review, coding, and data entry steps.

3.2 Element B.5

– Questionnaire Quality Control

ERG is implementing the following quality control procedures to review and data

enter questionnaire responses.

3.2.1 Data Review

ERG is conducting a question

- by

- question review of Parts A and Part C of the questionnaire responses using the Review Instructions (Appendix C )

. Each questionnaire is reviewed by a member of the ERG’s CBM engineering staff. The reviewer marks any changes

r equired on the working copy of the questionnaire in red ink. The ERG reviewer assigned to each questionnaire is identified in the tracking database. The reviewer documents the date the reviewRevision No. 0 June 22, 2011 Page 12 of 1 8

was complete d and completes a checklist documenting that they co mpleted all review items listed in Appendix C. In addition, the reviewer documents all changes to the questionnaire and the reason for the change on a form that is stored electronically in Microsoft® Word as described in Appendix C . The reviewer names the file with the operator identification number and stores

the file on ERG’s secure project area. These comments will also be added into the database during the data entry steps. The ERG WAM or Questionnaire T ask L ead will perform a second review of 25 percen t of the questionnaire responses. ERG will prioritize facilities that operate produced water treatment systems for second review. The tracking database notes the questionnaires selected for second review and a memo field for the second reviewer to note any

comments. T he assigned reviewer indicates the questionnaire response is ready for data entry in the questionnaire tracking database after she has completed the first review or incorporated

comments from the second review for those selected.

The distributi on and receipt of the questionnaires was handled under a different

contract ; as such, ERG will not conduct activities related to obtaining missing questionnaires. If directed by EPA, ERG will conduct follow

- up (e.g., telephone respondents) when respondent s submitted questionnaires but failed to submit substantial port ions of Part A and Part C . ERG will provide information to EPA detailing which respondents require follow

- up and EPA will decide which method for collecting questionnaire data should be implem ented, which may include

, as necessary, additional follow

- up phone calls and letters, criminal fines, civil penalties, and other sanctions, as provided by law. These activities are helping to improve the completeness of

respons es on individual questionnaires.

Certain questions if not completed, or if a large number of key questions are incomplete, are identified as triggering a phone call to the operator . After receiving EPA approval, ERG will call respondents when questionnaires are found to b e substantially incomplete and not ready for further processing. During the questionnaire review, ERG will

evaluate verify that responses match the schematic in Question C2

- 1 and that responses are internally consistent. ERG also will conduct a comprehensi ve e valuation following data entry using d atabase queries to identify inconsistent and/or unreasonable responses for EPA’s review. If directed by EPA, ERG will call the respondent to obtain a complete, consistent response to each question. ERG will documen t those communications and change the original questionnaire response based on the follow

- up communication. The communications will be logged, and the communication record will be stored in the survey file in ERG’s CBI

- secured room. After review

and follow

- up are completed, ERG will report the number of valid responses provided for each question, so that EPA statisticians will be able to determine the accuracy of the estimates made using those responses.

To ensure any data added or changed in the questionnaires or database are accurate, ERG will provide a letter to each survey respondent (as relevant) following completion of data entry, checking, callbacks, and data changes, outlining what was changed and why. The letters will request that the resp ondents review and sign a statement indicating acceptance of the additions or changes.

ERG is using a form (Figure 3

- 1 ) to document all telephone conversations with respondents which will be stored in the applicable questionnaire file folder in the secur e CBI

room

.Revision No. 0 June 22, 2011 Page 13 of 1 8

Project Name: CBM Detailed Study

Project No:

Operator ID:

Operator Name:

Contact Name: Contact Phone No: Contact Email Address:

Date: Staff Name:

Time: AM PM

This document
contains CBI:

_____ Yes

_____ No Type of Contact:

Email Telephone

General Subject(s)

Discussed:

CBI = Yes (Y) Question

No. Topics Discussed

Figure 3

- 1. Example Telephone Call Record

3.2.2 Data Transcription

ERG finalized a Microsoft® Access database to store the engineering questionnaire data. Appendix B describes the database. In addition, ERG developed simple data entry forms to aid in data entry. A CBI

- cle ared ERG employee with familiarity with Microsoft® Access will enter the data from the hardcopy into the database following the instructions in Appendix D. The data entry staff will review the information on each data entry form as they move through the da ta entry process. When the data entry is complete, the data entry staff will mark the date completed in the tracking database.

To further ensure the accuracy of the transcription, an ERG engineering team
member will review 25 percent of the questionnaires for data entry accuracy. The engineering

team member will visually compare all the information contained in the database to the working copy of the questionnaire. If any changes to the database are required, the data entry reviewer

will correct the data an d document the change in the database change tracking table located in the engineering questionnaire database. The ERG WAM will review the database change tracking table weekly to evaluate the extent of data entry errors. The ERG WAM will provide updates o n the data entry changes required to the EPA WAM as part of the weekly questionnaireRevision No. 0 June 22, 2011 Page 14 of 1 8

status report. ERG will coordinate with the EPA WAM to determine, based on the resources available and the type of changes made, the extent of additional review required ( e.g., greater than 25 percent).

3.2.3 Data Quality Verification

ERG will verify data quality by comparing questionnaire responses to the acceptance criteria listed in Table 2

- 1. ERG will use database queries to identify questionnaire

response completeness, inco nsistent and/or unreasonable responses

, and perform database clean

up tasks to allow the analysis of the data (e.g., converting units to standard units). An ERG engineering staff member will develop the queries and a second engineering staff member will

re view the query design and logic. Appendix E documents the queries that ERG will use to complete this task. ERG will provide documentation describing the queries and summaries of the query results for review by the EPA WAM. ERG will work with the EPA WAM to determine if any additional database quality control procedures or changes should be pe r formed prior to using the database for regulatory analyses.

3.3 Element B.10

– Questionnaire Data Management and Docu mentation

E RG’s standard controls for project

- related data, documents, and records are presented in the Coalbed Methane Project File Management Plan

. Standard controls for project

related data, documents, and records are also presented in Section 5 of ERG’s 2002 QMP ( 4 )

. ERG will enter completed questionnaires and the working copy into the CBM record

.

Any questionnaire i nformation that is clai med as C BI by the CBM operators will be handled according to the proce dures outlined in ERG’s CBI security plan entitled Security Plan for Handling Confidential Business Information Under the Clean Water Act , dated September 25, 2008 and approved by Ahmar Siddiqui, EPA’s Document Control Officer for this contract, on March 12, 2009 ( 3 )

. Only staff demonstrating their underst anding of CBI handling procedures by passing a written test will be permitted to access CBI on this project.

ERG will transfer questionnaire data that meet the quality criteria from paper copy to electronic copy following the procedures discussed in the pr evious sections

. ERG will transfer all questionnaire responses (CBI and nonCBI) received into one questionnaire database. The questionnaire database as a whole will be handled as CBI until such later time as a sanitization plan is made to create a nonCBI v ersion for the public docket. The database will be stored electronically on ERG’s CBI server.

Documentation for the questionnaire includes the original hardcopy questionnaire responses, revisions or edits made by the response reviewer in the working copy of the questionnaire

, the questionnaire database, and t he completed questionnaire tracking and review quality assurance documentation . The questionnaire review task leader or his/her designee will inspect the questionnaire review documentation to ensure th at all records are legible and complete. ERG’s standard controls for project

- related data, documents, and records are presented

in Section 5 of the 2002 QMP ( 4 ).Revision No. 0 June 22, 2011 Page 15 of 1 8

4.0 A SSESSMENT A ND O VERSIGHT E LEMENTS

This section describes the methods ERG will use to assess the quality of the questionnaire data

.

4.1 Element C.1: A ssessment of QAPP Implementation and Response Actions

This section describes the technical review, audits, and corrective actions that will be p erformed to ensure the QAPP is implemented as approved

.

ERG will subject all work conducted on this project to review. Lori Weiss, ERG’s

WAM for ERG’s support to EPA for the CBM rulemaking, or her designee will ensure the proper review has been completed

. Ms. Weiss will ensure that review staff are following the procedures outlined in this QAPP and are documenting their review. In addition, reports and

memoranda that use the questionnaire data will be subject to technical review. Technical review

is a docum ented critical review of work that has been performed within the “state of the art.” Betsy Bicknell, the assigned technical reviewer for this project, or her designee will perform this

review. All deliverables will subsequently be reviewed by the EPA WAM. ERG will document all reviews of project deliverables using the CBM QA database

.

Mary Willett will serve as the Project QA Coordinator for this project. She will use the following tools to assess the implementation of QA/QC procedures on this project:

**•** Revi ew of the QAPP (this document) for completeness a nd applicability; and

**•** Audit project files to ensure and verify the following:

— That project staff have developed QC procedures and that these procedures are used ; and,

— That project staff are documenting the ir use of these QC procedures by completing the tracking database and documenting the review procedures.

At any time or at the end of the project or work assignment Mary Willett, or her designee, m ay inspect the project QA files and communicate any quali ty deficiencies, in writing, to the ERG WAM. The ERG WAM is responsible for ensuring that appropriate corrective action is taken and reported to the Project QA Coordinator. ERG will include any reports of corrective actions in the project QA files. If the issue may impact the schedule or budget, the issue will be discussed with the EPA WAM. In either case, the results of the QA audit and the resolution of any issues will be documented in the monthly QA report.

4.2 Element C.2: Reports to Management

ERG will d es cribe QA activities conducted for major deliverables, when such

documents are delivered to EPA. These descriptions may be included in the document or in the transmittal email, as directed by EPA. Additionally, the ERG WAM will provide the EPA WAM

with mont hly reports on the status of QA activities. These reports will be incorporated into our monthly technical progress reports which will be supplemented to include the following:Revision No. 0 June 22, 2011 Page 16 of 1 8

**•** Quality assurance activities performed during the reporting period as part of the implementation of the work assignment;

**•** Identification of any problems encountered;

**•** Identification of any deviations from the QAPP; and

**•** Identification of problem resolution and/or corrective actions taken during the reporting period, if any.

ERG will provide copies of completed data quality checklists upon request by the EPA WAM. If data do not meet all the quality specifications but is needed for rulemaking analysis, ERG will obtain approval to use the data from EPA and include the approval i n the

checklist database. In addition, a ny quality deficiencies detected by technical reviewers or the Project QA Coordinator will be communicated, in writing, to the ERG WAM

. The ERG WAM is responsible for ensuring that appropriate corrective action is ta ken and reported to the Project QA Coordinator.Revision No. 0 June 22, 2011 Page 17 of 1 8

5.0 U SABILITY E LEMENT

ERG will compare the quality of collected data and analyses to quality objectives

described in Section 2.4 and report our findings to the EPA WAM to enable her to determine whether the collected and analyzed data are of sufficient quality for use in the CBM rulemaking

. This subsection discusses how ERG will review data quality a nd report the results.

5.1 Data Review and Verification

Data review is an in

- house examination of the data to ensure that the data have

been recorded

, transm itted, and processed correctly. ERG will complete the data review following the procedures in Section 3.2 .1 and 3.2.2 to review and transcribe questionnaire data. ERG will document the review through the questionnaire tracking database, review form, working copy of the questionnaire , and database change tracking table

.

Data verification is the process of evalua ting the database to determine if it is of acceptable quality for use in the CBM rulemaking. ERG will complete the data quality checklists

and follow the procedures in Section 3.2 to perform the data verification. ERG will provide the

results of the database queries used to perform the verification to EPA.

5.2 Reconciliation with User Requirements (Element D.3)

ERG will provide a copy of the engineering questionnaire database to EPA along with the following items:

**•** Database dictionary

– ERG developed a d atabase dictionary (Appendix B) to describe each data field;

**•** Tracking database report

– ERG will print a report from the tracking database that includes the following items:

— Operator identification number;

— Overall status (non

- response, available for techn ical review);

— Reviewer name;

— Date review completed;

— Second reviewer (if applicable);

— Date second review completed;

— Data entry date;

— Date entry review (if applicable);

— Date data entry review completed; and

**•** Data verification summary

– ERG will provide the results of the data verification queries described in Section 3.2.3

.

The EPA WAM will use the information provided by ERG to determine whether

the questionnaire data is acceptable for use in the CBM rulemaking

.Revision No. 0 June 22, 2011 Page 18 of 1 8

6.0 R EFERENCES

1. U.S. Environmental Protec tion Agency, EPA Requirements for Quality Assurance Project Plans QA/R

- 5 , EPA/240/B

- 01/003, Office of Environmental Information. March

2001.

2. U.S. Environmental Protection Agency, Coalbed Methane Extraction Detailed Study Report , EPA

- 820

- R

- 10

- 022, December 2010.

3. Eastern Research Group, Inc. Security Plan for Handling Confidential Business

Information Under the Clean Water Act . September 25, 2008.

4. Eastern Research Group, Inc. Quality Management Plan for Technical Support for the Strategy for National Clean Water Industrial Regulations

, June 2002.

# Coalbed Methane Project File Management Plan

Prepared for:



## U.S. Environmental Protection Agency

Engineering and Analysis Division
Office of Water 1200 Pennsylvania Avenue, NW Washington, D.C. 20460

Prepared by:



### Eastern Research Group, Inc. 14555 Avion Parkway
Suite 200 Chantilly, VA 20151

May 2011

EPA Contract No. 68

- C

- 02

- 095 Work Assignment 8

- 37i TABLE OF CONTENTS

Page

1.0 I NTRODUCTION AND D EFINITIONS

................................ ................................ ......... 1

- 1

1.1 Background

................................ ................................ .............................. 1

- 1

1.2 Coalbed MethaneProject File

................................ ................................ ... 1

- 1

1.3 Docket

................................ ................................ ................................ ...... 1

- 2

1.4 Federal Docket Management System (FDMS)

................................ ........ 1

- 3

1.5 Electronic Project Fil e

................................ ................................ .............. 1

- 3

1.6 Contract File

................................ ................................ ............................. 1

- 3

1.7 Personal Files

................................ ................................ ........................... 1

- 4

1.8 Project F ile Index

................................ ................................ ..................... 1

- 4

1.9 FDMS Metadata

................................ ................................ ....................... 1

- 4

1.10 Confidential Business Information (CBI)

................................ ................ 1

- 4

1.11 CBI

- Deducible Information

................................ ................................ ..... 1

- 4

2.0 G ENERAL P ROCEDURES

................................ ................................ ........................ 2

- 1

2.1 Submitting Material to the Project File

................................ .................... 2

- 1

2.1.1 Step

- By

- Step Process for Submitting Project File Materials

....... 2

- 1

2.1.2 Detailed Discussion of Document Submission Process

............... 2

- 9

2.2 Document Control Numbers (DCNs)

................................ .................... 2

- 11

2.2.1 Appendices and Attachments

................................ ..................... 2

- 11

2.2.2 Copies

................................ ................................ ........................ 2

- 12

2.2.3 CBI Documents

................................ ................................ .......... 2

- 12

2.3 Project File Index

................................ ................................ ................... 2

- 12

2.3.1 Index Structure

................................ ................................ ........... 2

- 12

3.0 Q UALITY C ONTROL P ROCEDURES

................................ ................................ ......... 3

- 1

3.1 Responsibilities

................................ ................................ ........................ 3

- 1

3.2 Project File Quality Review Procedures

................................ .................. 3

- 1

3.2.1 Project File Index

................................ ................................ ......... 3

- 1

3. 2.2 Project File and Filing Review

................................ .................... 3

- 2

3.2.3 Project File Plan Revision

................................ ............................ 3

- 3

4.0 D OCKET A SSEMBLY

................................ ................................ .............................. 4

- 1

Attachment 1 COALBED METHANE PROJECT FILE OUTLINE

Attachment 2 COALBED METHANE PROJECT FILE LOG

- IN FORM

Attachment 3 FDMS GUIDELINES FOR FREE TEXT FIELDS1

- 1 1.0 I NTRODUCTION AND D EFINITIONS

This document is a plan for the preparatio n of the Coalbed Methane project file

. It

is intended to be a living document and will be revised and reissued, as necessary. This plan includes definitions and procedures so that all Coalbed Methane project team members will have the same understanding of our file system. The definitions and procedures are project

- specific and may differ from terms used for other regulatory development work.

ERG will manage all reports, documents, and other materials developed for the

Coalbed Methane project file in acco rdance with the procedures set forth in our approved Security Plan for Handling Confidential Business Information Under the Clean Water Act (September 25, 2008) or its successor approved plans. All Coalbed Methane team members will

be trained and tested in CBI procedures before they are permitted to access CBI.

1.1 Bac kground

The U.S. Environmental Protection Agency (EPA), acting through its Office of Science and Technology (OST), Engineering and Analysis Division (EAD), is studying whether it would be appro priate to revise the effluent guidelines for the Oil and Gas Point Source Category to control pollutant discharges from coalbed methane (CBM) produced waters. Discharges from CBM operations are not covered by existing effluent limitations, guidelines,

and standards (ELGs) because at the time the ELGs were established, CBM extraction was not a standard practice. Such extraction, however, has increased in recent years, raising the question of whether specific discharge restrictions should be developed.

EP A required more detailed information on the characteristics of CBM produced water and of the technologies available to treat such discharges. To obtain these data, EPA undertook a Detailed Study, including a screener questionnaire and a detailed industria l survey.

EPA ta sked PG Environmental, LLC

, (PG) with supporting the Agency in its Detailed Study under Work Assignment 2

- 01 of Contract N o. EP

- C

- 07

- 029 . Specifically, EPA tasked PG with finalizing and distributing the detailed questionnaires

.

ERG will use information from the Detailed Study, the returned questionnaires, plus additional data collected to provide technical support to EPA in a variety of regulatory development activities including participating in site visits, developing an industry datab ase, estimating pollutant discharges, and assessing the costs and benefits of regulatory alternatives.

1.2 Coalbed Methane Project File

The Coalbed Methane project file will contain items that are collected or developed during the development of the Coalbed M ethane ELGs and will ultimately be published in a public docket supporting the rulemaking effort

. These items may include:1

- 2 **•** Meeting minutes;

**•** Summaries and transcripts of public meetings and hearings;

**•** Records of communications with parties outside of EPA, including telephone calls, memoranda, and letters;

• Non

- confidential databases containing information used in the rulemaking;

**•** Public statements made by EPA employees in their official capacities;

**•** Public comments, including written opinions, data, and other information;

**•** Items submitted to EPA that agree, disagree, and/or suggest alternatives to the proposed action ; and

**•** Bibliographies of materials to potentiall y add to the Coalbed Methane

record

.

The project file may also contain certain material that would not be appropriate

for inclusion in the public docket , such as:

**•** Internal b riefing packages and project plans ;

**•** “Deliberative” items, including memoranda from ERG to EPA that present regulatory alternatives;

**•** Drafts of Site Visit Reports and Sampling Episod e Reports with affected facility review comments (where only the final version is placed in the public docket);

**•** Confidential databases containing information used in the rulemaking;

**•** EPA Work Group briefing materials and reports;

**•** EPA management briefing mat erials;

**•** EPA internal transmittal memoranda for the rulemaking package; and

**•** Other internal EPA communications.

The project file should not contain contractual materials , such as :

**•** ERG’s contracts with EPA or our subcontractors;

**•** Work assignments, work plan s, and monthly reports ;

**•** Contract performance evaluations; and

**•** Any other material relating to the contract between ERG and EPA.

All items in the Coalbed Methane project file will be assigned an ERG document control number (DCN) for document management pur poses. Documents that are identified as part of the Coalbed Methane project file and become part of an EPA docket will be assigned an additional document number through the Federal Docket Management System (FDMS). See

Section 2.2 for more information.

1.3 Doc ket

An official docket serves as the repository for the collection of documents or information related to a particular agency action or activity. The official docket generally consists of the documents specifically referenced in the Federal Register notic es, any public1

- 3 comments received, and other information used by decision

- makers, or otherwise related to the Agency action or activity. Agencies most commonly use dockets for regulatory actions, but dockets may also be used for various other non

- rulemaking activities, such as Federal Register notices seeking public comments on draft guidance, policy statements, information collection requests under the Paperwork Reduction Act, and other non

- rule activities. Each time an Agency

action is announced in the Fed eral Register , a docket is established and assigned a tracking number to accumulate materials throughout the development process.

1.4 Federal Docket Management System (FDMS)

FDMS is designed for use by over a hundred federal agencies and entities. FDMS

is built on a document management system platform and has Internet access for both public users and agency personnel. FDMS is used to establish the public docket, index the docket contents,

and

, to the extent feasible, provide the electronic version of public ly available docket materials. On November 28, 2005 FDMS replaced EDocket as EPA’s docketing system. The public interface with FDMS can be accessed at http://www.regulations.gov.

1.5 Electronic Project File

The electronic project file is the network area in which ERG stores the electronic

version of items in the Coalbed Methane project file. These files are named by DCN. Electronic versions of any CBI items in the Coalbed Methane project file will be stored in the Coalbed

Methane project area on ERG’s CBI ser ver.

1.6 Contract File

The contract file contains materials specific to ERG’s management of the contract

with EPA. These materials would not be passed on to a succeeding contractor and would be retained by ERG at the conclusion of the contract. The contract file contains the following:

**•** The contract;

**•** Work assignments;

**•** Work plans and cost estimates;

**•** Contract and task instructions;

**•** Weekly and monthly reports;

**•** Invoices;

**•** Contract performance evaluations;

**•** Project wrap

- up meeting notes and reports;

**•** ERG document re view sign

- off sheets (completed for all project deliverables); and

**•** Correspondence with the EPA Contracting Officer.

Items in the ERG contract file are filed separately from the Coalbed Methane project file and are not assigned DCNs.1

- 4 1.7 Personal Files

Pers onal files include project team member notes that are not necessarily interpretable by others, as well as copies of non

- CBI materials that are referred to frequently. Copies will be minimized to keep file space requirements under control. Working drafts o f CBI and CBI computer files are managed according to ERG’s CBI Plan.

1.8 Project File Index

The project file index is a listing of all documents in the Coalbed Methane project

file. The index is a computerized database that allows for sorting and searching the project file by key word, section, date, DCN, docket number, etc. The project file index lists all documents,

CBI and non

- CBI. Index entries should not contain CBI information. The index includes a field that designates the CBI status of each item. Se e Section 2.3 for more details on the project file

index.

1.9 FDMS Metadata

Metadata are descriptive information about the elements of a set of data. For FDMS the “elements” are documents and the “set of data” is the docket. Thus, FDMS metadata

are informati on that describes each document in a docket. FDMS metadata are similar to the information contained in the project file index, and include among other information, the title, abstract, author, author date, source citation

, and page count.

1.10 Confidential Bu siness Information (CBI)

At the time a business or trade association supplies information to EPA, they may assert a business confidentiality claim covering all or part of the information. If no such claim accompanies the information, EPA may make it avail able to the public without further notice to

the business. If EPA receives a request from an outside party for information claimed confidential, it will determine if the information is entitled to confidential treatment (see 40 CFR Part 2). Please refer to ERG’s Security Plan for Handling Confidential Business Information

Under the Clean Water Act , dated September 25, 2008 , for further information on handling CBI.

As specified in ERG’s CBI Plan, documents containing CBI will be stored in a designated lock ed archive or file cabinet. Electronic files containing CBI will be stored on ERG’s separate, limited

- access CBI server. Documents containing CBI will be sanitized prior to their placement in the public docket. The original non

- sanitized version of the doc ument will be

maintained as a CBI document.

1.11 CBI

- Deducible Information

CBI

- deducible information is information that is not CBI, but when used in conjunction with other publicly

- available materials, can be used to deduce CBI. Examples of

documents contain ing CBI

- deducible information include pre

- test questionnaires and non

- CBI screener questionnaires which contain both facility identifier information (e.g., facility name, address, contacts, etc.) and facility codes. To prevent the deduction of CBI, documen ts containing CBI

- deducible information will be sanitized prior to their placement in the public1

- 5 docket. The sanitization step will be designed to remove the information that allows CBI to be

deduced. ERG will develop a sanitization plan that discusses the steps ERG will use to endure all CBI is protected in the final sanitized vers ion. The EPA WAM will a pprove ERG’s sanitization plan prior to ERG per forming the sanitization steps. ERG wil l deliver the final sanitized

document as a CBI document . The EPA WA M will review the document to confirm all CBI has been removed and approve the relea se of the document into the non CBI public docket. The original non

- sanitized version of the document will be maintained as a CBI document.2

- 1 2.0 G ENERAL P ROCEDURES

All Coalbed Methane project file items (i.e., excluding ERG contract file items) will be recorded in the project file index and assigned a unique DCN (discussed in section 2.2). Project file items are those items and materials which are defined in Section 1.2 of this project file plan. Team members will submit items that are ready to be entered into the project file, using the steps detailed in this section, to the ERG staff member with primary responsibility for the project file index (the index keeper). The index keeper will issue DCNs as individual documents are generated and submitted.

The outline for the project file, which specifies project file sections, is included as Attachment 1 to this plan. The project file outline will be modified as needed during the performance of this work. Except for CBI documents, project file materials will be stored in the

Coalbed Methane electronic project file on ERG’s network. CBI documents will be stored on the CBI server. Hard copy documents will be phy sically placed in the Coalbed Methane archive filed by record section. Within eac h section, documents will be filed in ascending numerical

section and DCN order.

As ERG is directed by EPA to assemble a docket supporting an Agency action, a

subset of t he items included in the Coalbed Methane project file will be identified for inclusion

in that docket. The appropriate docket number will be added to the project file index database to identify these items. Electronic files of these documents will be moved from the project file folder to the appropriate docket folder.

If any items identified for inclusion in the docket contain CBI or CBI

- deducible information, upon direction from the EPA WAM, a sanitized version of the item will be prepared using the step s discussed in Section 1.11

. If CBI is removed from a document to create a “sanitized” version of the document, that document will receive a new DCN. The “sanitized” version of the document will be designated with a non

- CBI cover sheet and noted “sanitized version.” In some cases it may be impossible to produce a sanitized version of the document. In these cases, the document will be described in the index and the CBI document will be stored on

the CBI server.

2.1 Submitting Material to the Project File

This section presents the processes to be used to submit materials to the Coalbed

Methane p roject f ile, first as step

- by

- step procedures (Section 2.1.1) then in a more detailed discussion of the submission process (Section 2.1.2)

2.1.1 Step

- By

- Step Process for Subm itting Project File Materials

Documents will be submitted to the project file following the steps below:

1. If the document is in a format that can easily be converted to a PDF (e.g., Word document, Web site, Visio diagram, email), convert the document to

P DF. If the document is hard copy, either scan the document in as a pdf or request assistance from ERG docket staff for scanning support.2

- 2 2. Complete an electronic project file log

- in form (see Attachment 2 ) using

the instructions below

.

• DCN : Leave this entr y blank; the index keeper will assign this number. For logging in placeholder documents, put the DCN of the placeholder. For logging in attachments to a document, put MAIN in the DCN for the main document, and A1, A2, A3, etc. for the

attachments to the do cument. For subsequent versions of the same database, use V1, V2, etc. to denote the different version numbers.

**•** Placeholder (Y or N): If the document is not finalized and the metadata was entered to get a DCN for references, enter TRUE. If

the document is finalized, enter FALSE.

**•** Title : This should be the full title of the article, study, or report, limited to 400 characters. For memoranda, letters, and e

- mail correspondence, use the format:

**** Memorandum to Angela Beard, Vice President, Medical

Research Dep artment, Flonasd Corporation: Subject Subject ;

**** Letter to Susan Clark, Citizen: Subject Subject ; or

**** Email to John Wright, Contractor, Viztronix : Subject Subject

.

For records of telephone conversations (only informal; formal telephone conversations (e.g., conference call notes) are written as memoranda) , use the format:

**** Notes from telephone conversation between John Smith, ERG and Jane Doe, XYZ Corporation, August 6, 2001 : Subject Subject

.

For permits, fact sheets, and permit applications, use the format:

**** NPDES Permit: CF Industries, Inc., Donaldsonville, Louisiana;

**** NPDES Permit Fact Sheet: CF Industries, Inc., Donaldsonville, Louisiana; or

**** NPDES Permit Application: CF Industries, Inc., Donaldsonville, Louisiana.

For databases, use the format:

**** Database: Database Title Version Number.

For CBI documents, use the format:2

- 3 **** CBI_ Document Title ;

For Placeholder submittals, use the format:

**** PLACHOLDER: Document Title

.

**•** Abstract : This field is used to provide additional description of

th e individual document. It may be the continuation of a lengthy

title. 1 The subject of a memorandum, email, or letter should be entered as the abstract. Be descriptive; do not simply repeat

information that is contained in the title. For permits, fact sheet s, and permit applications, the abstract should be the NPDES permit

number. Abstracts are limited to 500 characters.

**•** Document Sub

- type: This is an FDMS field with a drop

- down menu of allowable document subtypes. C hoose from the following

types.

Sub

- Type Description Analysis A review and summation of data or facts which might be used in a report and/or study or which might serve as the basis of an audit, assessment, or

evaluation. Comment Response Agency responses to public comments.

Data Facts and fig ures used to support a position or for the modeling or forecasting of outcomes. Typically these records are provided electronically as data dumps on alternative media or as listings or spreadsheets. Economic Analysis A review and summation of economic dat a or facts.

Fact/Data Sheet This subtype includes Material Safety Data Sheets (MSDS). Formalized information regarding a particular event, chemical, product, or other used as a tool to disseminate knowledge in a standardized factual manner. Broad

announce ments of events or information might otherwise be classified as "Press Releases, Public Announcements, Public Notices." Federal Register

Document A draft or formal document published or to be published in the Federal Register which is used as a supporting document as opposed to authorizing a comment period or other action.

Form Any government form not specific elsewhere or not part of a larger subtype category such as audit forms which should be classified under "Audit, Assessment, Evaluation."
Guidance, Interpretation, Policy,

Procedure Documents which provide direction to Agency employees, contractors, or the public including Standard Operating Procedures, methodologies, and guidelines. Documents which alert others to events used primarily to

distribute broad knowledge in a standardized manner. ICR Supporting

Statement The supporting statement which accompanies an ICR.

Index A listing of materials or cross

- reference of sources or citations in a publication, report or study.

1 Docket staff also use the abstract to explain aspects of the document that might otherwise be confusing to the user (for examp le, if a document file is not included because it is CBI or a duplicate of another document).2

- 4 Sub

- Type Description Interagency Review Draft ma terials reviewed by outside entities which show signs of being edited including redline/strikeouts. Do not include specific OMB reviews of documents in this category. See "Office of Management and Budget" below.
Letter, Memorandum,

Email Correspondence bo th internal and external to the Agency.

Map A stand

- alone map not included in the body of a report, study, presentation,

etc. Meeting or

Teleconference

Materials Telephone contact reports, meeting minutes, and materials used to schedule, inform, conduct or summarize a meeting, teleconference, or less formal telephone call including but not limited to: agenda, presentations/handouts/slides, and attendee lists/sign

- in sheets. Office of Management and Budget (OMB) Correspondence to and from and drafts revie wed by specifically by OMB.

Other Non

- copyright protected web pages. Permit, Registration A form which registers or permits the holder to perform a certain action or to use a specific chemical (e.g., NPDES discharge permit). Physical Item Any item which is considered a record under the NARA definition but which cannot be otherwise classified as a document or be imported as an image into the system such as a brick, paper plate, or bag.
Press Release, Public

Announcement/Notice Documents which alert other s to events used primarily to distribute broad knowledge in a standardized manner. Public Hearing Transcript, Deposition, Testimony Documents that reflect the words spoken during a legal or administrative law proceeding or interview, typically created by a court reporter.

Publication; Copyrighted Material Any non

- governmental work which appears to be afforded US copyright protection including journal or magazine articles, abstracts, books or any portion thereof, newspaper articles, online/trade articles, online news wires or services including MSN.com or CNN.com
Publication; Other

Governmental Federal/state/local government publication other than EPA publications.

Publication; USEPA USEPA publication; include an EPA Publication Number in the title.
Repo rt A statement of fact and findings usually formalized. This subtype includes status reports on projects or contracts as well as outcomes and findings from the analysis, audit, review or study of processes or procedures whether

scientific or business in fu nction. Signed Federal Register

Document Document authorizing the submission to and release of a Federal Register by

NARA Speech Presentation or transcript of a speech Statistical Analysis Documentation that support the statistical sample design and co mpany/project selection for the questionnaire. Also includes documentation of any limitations development. Study A study is a compilation of analysis, data, multiple assessment or audits to ascertain the strength, accuracy or outcome of a position or met hodology. Studies differ from reports in that a study offers more detailed scientific data, facts or figures from a variety of sources.

Test Data

• Author Name: N ame of the individual who authored, edited, compiled or wrote the memorandum, report, study, article, or book.

Author Na me is limited to 25 characters. For documents with multiple authors, use the format: Bartram, Deborah, et. al.2

- 5 • Author Affiliation : The affiliation of the author. For documents written by ERG staff, use the format: Eastern Resea rch Group, Inc. For documents written by EPA staff, use the format: U.S. EPA.

• Author Date: Enter as MM/DD/YYYY. Provide the date of publication, issue, edition, or version. Letters and memoranda usually bear a date in their respective headings. Reports, reviews, and studies usually have a date located within their respective forwards. Publications bear copyright dates. For meeting and telephone notes provide the date of the actual event. If only the month and year are known, enter the first day of the mon th. For example: use 05/01/2002 rather than 05/2002.

• Page Count: Enter the total number of pages of the PDF

. If the document was not converted to PDF (e.g., Excel file or Access database), leave the page count blank. If the document is copyrighted, includ e the page count of the paper document. This is the total page count so be sure to include all blank pages. Page

Count is limited to five characters.

• Copyright Protected (Y or N): If the document is copyrighted, enter TRUE, and make sure the document sub

- type is “Publication; Copyrighted Material.” If the document is not copyrighted, enter

FALSE.

• Source Citation: For copyright protected material, this is a mandatory field. It consists of a bibliographic citation the public can use to identify the document and to locate a copy through alternative means such as a reference library. Source citation is an important part of the metadata for copyright protected documents because it allows FDMS to link back to the paper record. The

source citation does NOT need t o include the title or the author name because those metadata are captured elsewhere in the system. The citation should, however, include such standard information as the publisher’s name and city, date of publication, editor or compilers’ names, and volum e or serial numbers. Source citations

are limited to 150 characters.

If the copyrighted document is a Web site, use the format:

**** Internet Materials: < WEBSITE >. (Accessed DATE ).

If the website i n above format is longer than 150 characters, just put the w ebsite. If the copyrighted document is a journal article,

use the format:

**** Journal Article: Nature 393(2002):639

- 40; or2

- 6 **** Article in Electronic Journal: JAMA. 287, no. 5 (2001), http:/jama.ama

- assn.org/issues/v287n5/rfull/joc10108.html (accessed January 7, 2 002).

See the ERG Style Guide, Appendix C (available under tools on the ERG Intranet) for additional bibliographic formats.

• Confidential Business Information (Y or N): If the document

contains CBI or is CBI

- deducible, enter TRUE, and make sure

“CBI” is a t the beginning of the title. If the entire document is non

confidential or has been sanitized, enter FALSE.

• Keyword 1 and Keyword 2: This entry is specific to the Coalbed

Methane project file index; however, the key words will be

included in FDMS metadat a in the abstract field. Enter keywords

about the document that could be used to search the index for specific documents. Do not repeat information in other index fields (e.g., title, abstract). When completing the key word entry line on the log

- in form, r efer to the key words in the existing index

database to ensure correct and consistent spelling, abbreviation, and punctuation are used.

• Electronic Copy File Location: This entry is specific to the

Coalbed Methane project file index and will not be include d in the

FDMS metadata. This field refers to the source location of the

document on ERG’s network area. Copy the full file path, including document title, into this field. For example: Q: \ Coalbed

Methane \ QAPP \ QAPP_092509.doc . Identify if the item is stored on the CBI network by putting “CBI” in front of the file path. Once the document is submitted to the index keeper for addition to the project file, it will be re

- saved with the DCN as the file name and stored in the electronic project file. CBI i tems will be stored in the electronic project file on the CBI server.

• Docket Item (Y or N): If the document is for the docket, enter TRUE; if the document is for the project file only, enter FALSE. If a decision has not yet been made as to whether to include the

d ocument in the docket, enter FALSE.

• Project File Section Number: To help locate documents addressing related topics or subjects ERG created a subject outline

of the Coalbed Methane project file (see Attachment 1). Enter the project file section number for the subject outline of the Coalbed

Methane project.

3. Submit the log

- in form and documents to the index keeper. If you have :2

- 7 • A non

- CBI electronic file, email the file and the log

- in form to the

index k eeper

. Be sure to include the filename and path to the network area on the log

- in form.

• A CBI electronic file, email only the log

- in form to the i ndex keeper

. Be sure to include the filename and path to the CBI network area on the log

- in form.

• A hard copy item that cannot be scanned (such as a large map or a physical specimen):

 Email the log

- in form to the index keeper and indicate in the message that the document is not electronic; and

 Print out the log

- in form, attach it to the item, and put the item with the log

- in form in the Coalbed Methane project

file inbox.

• A database or other file that must be saved to CD instead of being uploaded:

 Email the log

- in form to the index keeper and indicate in the message that the document will be provided on CD or DVD; and

 Print out the log

- in form, make two copies of the CD or DVD, attach the log

- in form to th e disks , and place them in

the Coalbed Methane project file inbox.

Adding the Document to the Record and Electronic Project File

4. The index keeper will add the documents to the record index on a bi

weekly basis during slow periods (less than 10 items per week) and weekly during high paced periods (more than 10 items per week).

5. The index keeper will import the log

- in file into the record index and append it to the Coalbed Methane Index table using the steps outlined in Attachment 2. The index keeper will a lso update the following fields when the log

- in file is appended to the Index table:

• Input Date: The date the index keeper added the item to the index.

• Metadata Checked (Y or N): This field indicates if the metadata

has been checked. All documents added to the Coalbed Methane

Index will initially have ‘N’ in this column.

• File Checked (Y or N): This field indicates if the file in the electronic project file areas has been checked. All documents

added to the Coalbed Methane Index will initially have ‘N’ in this

column.

• Metadata Approved (Y or N) : This field indicates if the metadata has been approved for upload to FDMS. All documents added to

the Coalbed Methane Index will initially have ‘N’ in this column.2

- 8 6. The index keeper will compare the imported table to the updated Coalbed

Methane Index to make sure the information was added correctly.

7. The index keeper will save the documents to the designated electronic project file areas.

• If the item is not CBI and:

 Not copyright protected, the index keeper will s ave the document as dcn.pdf to: non

- CBI network Q: \ Coalbed

Methane \Record \ Electronic Project File (with appropriate subfolder)

.

 Copyright protected, the index keeper will save the document as dcn.pdf to: non

- CBI network Q: \ Coalbed

Methane \Record \ Electronic Project File \ Copyrighted

 Hardcopy, the index keeper will scan the document and save it to the respective electronic project file area.

• If the item is CBI, the index keeper will use the Electronic Copy File Location to save the document to the proper proj ect

- related area on the CBI network ( Q: \ Coalbed Methane \ CBI Electronic Project File ).

8. The index keeper will email the submitter the DCNs to the documents they submitted when they are added to the Coalbed Methane Index.

QA Process for Metadata, Document, and Upload to FDMS

9. The index keeper will generate quarterly reports and provide them to the appropriate project file section leads to review the metadata. The reports will include at least the following fields from Coalbed Methane Index:

• DCN;

• Placeholder ;

• Title;

• Abstract;

• Document Sub

- Type;

• Author;

• Copyright Protected;

• CBI;

• Docket Item;

• Project File Section Number;

• Metadata Checked;

• File Checked; and

• Metadata Approved.

10. The ERG WAM or task lead will review the metadata and identify any changes for the ind ex keeper to make. The project file section lead will2

- 9 change the Metadata Checked field from ‘N’ to ‘Y’ for metadata that do not need changed.

11. The index keeper will update the metadata based on the project file section leads’ comments. The index keeper wi ll update the Metadata Checked field for the metadata that does not need changing to ‘Y.’

12. For a selected quarterly report, repeat steps 9 through 11 until all the Metadata Checked fields are changed to ‘Y.’

13. The index keeper will perform quarterly audit s of the documents identified as Placeholder ‘N’ in the electronic project file areas and compare the files

to the metadata.

• For documents that match the metadata, the index keeper will update the File Checked field from ‘N’ to ‘Y;’

• For documents that do not match the metadata or are missing but

not identified as Placeholder ‘N:’

• The index keeper will email the project file section lead the

DCN and document title.

• The project file section lead will locate the document and email either the electronic copy f ile location or document to the index keeper.

• The index keeper will update the electronic project file area with the correct document and update the File Checked

field from ‘N’ to ‘Y.’

2.1.2 Detailed Discussion of Document Submission Process

Because the offici al dockets supporting EPA actions consist, with a few exceptions, of electronic files, you should submit materials to the project file in electronic format as much as possible. In addition to final reports supporting the EPA action, project file materials include ERG deliverables and background materials such as telephone contact reports, journal articles, and NPDES permits. These materials should be submitted to the project file as they are finalized even if EPA has not determined if they will be part of a n official docket.

As of November 28, 2005

, EPA is using the Federal Docket Management System (FDMS) to store and manage its dockets. FDMS is a web

- based database that holds document records (metadata) that describe each document in a docket and electro nic copies of the

documents. To expedite development and delivery of the docket, the Coalbed Methane project

file will be stored in the Coalbed Methane electronic project file. Because the FDMS

- preferred format for documents is portable data format (pdf), ERG will store project file documents as pdf files in the electronic project file network area. The electronic project file will have read

- only access to preserve the integrity of the project file items. In addition to standard network backups,

the index k eeper will back up additions to the electronic project file on CD or DVD on a regular

basis. The DCN will serve as the filename. For example, SE 00066.pdf will be the electronic

version of document SE 00066. If a DCN is comprised of multiple documents, a fol der will be2

- 10 created using the DCN as the folder name, and each document will be available within the folder. Within each folder, there will be one assigned m ain document that will keep the DCN as the

filename. In addition , the attachments to the main docu ment will be assigned consecutive numbers in order that the attachment corresponds to the main document. For example, if the main document has three attachments, the corresponding names of the a dditional documents w ill

be SE 0006 6 A 0 1.pdf, SE 00066A 0 2.pdf, a nd SE 00066A 0 3.pdf.

The first step in submitting materials to the project file is to complete an electronic project log

- in form and e

- mail it to the index keeper with the item to be added to the project file. The index keeper will add the data from the l og

- in form to the project file index and assign the item a DCN. The project file index is used to complete the FDMS metadata description for the document, so it is essential that the log

- in form is completed properly. The index keeper will store project fi le documents in the electronic project file (electronic form)

, with a few exceptions described later.

Project deliverables

. If the item submitted to the project file is a project deliverable, print out the project file log

- in form and attach printouts of the transmit tal e

- mail or

transmittal letter . After the index keeper assigns a DCN to the document, she will record the

DCN on the cover letter and file them in the contract file.

Related materials . Related materials that do n ot need to be indexed separately can be logged in as one item and given one DCN. Examples of materials that may be included under

one DCN are:

**•** Materials presented by several participants in one meeting;

**•** A series of telecons between two people about one subject;

**•** Correspondence between two people on one subject; and

**•** A related series of calculation sheets.

CBI. Team members submitting CBI items for the electronic project file must include on the log

- in form the full CBI Server path and filename for the electronic version of the item that is to be added to the CBI Server electronic project file. That electronic version will then be added to the CBI Server electronic project file area and renamed using the DCN.

Electronic f iles on compact disk (CD) or di gital video disk (DVD. As noted above, pdf is the FDMS preferred file format. Some docket items, such as databases and large spreadsheets cannot be saved as pdf files. These items will be submitted to the EPA docket on

DVD or CD. Copies will be stored in t he ERG Coalbed Methane archive, similar to h ard copy printouts of documents and will be identified in the project file index in the title field as being on

CD or DVD. CDs and or DVDs will be clearly marked with the item name and DCN and filed in

the ERG Co albed Methane archive in pouches/envelopes attached to the project file item file

folder.

Internet w ebsite m aterial. Because web addresses and web site content may change over time and become unavailable electronically, Internet website materials should be saved as a pdf file (or html file if the team member’s computer is not equipped with Adobe

Writer ® ) and printed out. Log

- in information should include the URL and date accessed. The2

- 11 index keeper will convert any html files to pdf and add the electronic version to the electronic project file.

E

- mail c orrespondence. E

- mail correspondence to be added to the project file should be saved as a pdf file and managed like other project file documents. DO NOT simply forward the message on to the index keeper.

Copyright p rotected m aterial

. Copyright protected material is often part of an

official docket. However, these materials cannot be stored in FDMS. FDMS will include the metadata for the copyright protected material, but will not include an electronic cop y of the

document. ERG will provide electronic copies of copyright protected material to the docket via

CD or email. The docket staff will produce h ard copies of copyright protected materials that will

be available in the docket office for public review

. F or ERG’s project files, copyright protected

material will be saved in a separate section of the electronic project file area of the network

Hard

- c opy i tems. Items that are only available in hard copy format must be converted to an electronic file, typic ally by scanning and saving the material in pdf format. The team member will provide the hard copy and completed log

- in form to the index keeper, who will arrange for creation of the electronic version. Exceptions include copyright protected material (e.g. , books and other published material) and physical objects (maps, aerial photos, colored charts, etc.).

NPDES Permits

. For NPDES permits and permit fact sheets, ERG will use the following conventions:

**** Title is “NPDES Permit: Name of Plant ” or “Draft NPD ES Permit: Name of Plant” ; and

**** Abstract is the NPDES permit number (e.g., PAXXXXXXX).

NPDES Permit Fact Sheets . For NPDES permits and permit fact sheets, ERG will use the following conventions:

**** Title is “NPDES Permit Fact Sheet: Name of Plant ”; and

**** Abst ract is the NPDES permit number (e.g., PAXXXXXXX).

2.2 Document Control Numbers (DCNs)

All Coalbed Methane project file items will be assigned a unique document control number (DCN). The ERG staff member with primary responsibility for the project file

index (the index keeper) will issue DCNs as individual documents are generated and submitted. The index keeper may also issue batches of DCNs to the E PA WAM to assign to materials received or generated at EAD. Each DCN will consist of CBM

, five digits , and exte nsions (e.g.,

CBM XXXXX)

.

2.2.1 Appendices and Attachments

Major appendices and attachments to documents, such as the analytical data reports attached to Sampling Episode Reports, will be given the same DCN as the parent2

- 12 document with an extension added to des ignate the appendix. For example, CBM05011 A 0 1 will designate Appendix 1 to document CBM05011

.

2.2.2 Copies

In accordance with ERG’s CBI plan, each individual copy of a CBI document will be tracked in a separate electronic copy log (the CBI copy log). The copy log tracks the copy numbers, date generated, destination, and ultimate disposition (e.g., returned to ERG, destroyed). The copy number of a CBI document will be incorporated into the DCN as an extension. For example, 09287C1 will designate copy 1 of docume nt 09287. Multiple copies of non

- CBI materials will not be tracked or designated.

2.2.3 CBI Documents

CBI documents will be designated in the project file index as a “yes” in the CBI

column of the index. A sanitized version of a CBI document will receive a uni que DCN. CBI documents will be stored in a designated, locked storage space. CBI electronic files will be

stored on the CBI server. Names of all files containing CBI will begin with CBI (e.g.,

CBI

_ 0 0 661.pdf).

2.3 Project File Index

The project file index wil l list all project file items. The index will be maintained using Microsoft Access® 200 7 database software. Entries to the index will be made by the index keeper, or the designee. Coalbed Methane project team members will have read

- only access to

the index via the network. The file will be located under Q: \ Coalbed Methane \ Record \

.

2.3.1 Index Structure

The following 14 index key fields were previously described in Section 2.1.1

. The se fields are included on the project file log

- in form and will be completed by the document

submitter. These entries are used to complete the FDMS metadata description of the document, so it is essential that the log

- in form entries are consistent with FDMS metadata requirements. Additional index fields are completed by the index kee per as described below. An asteri sk (*) preceding the index field name indicates that it is included in the FDMS system. 2

**•** *Title

**•** *Abstract

**•** *Document type

**•** * Source Citation

• *Author Name

• Author Affiliation

• *Auth or Date

• Page Count

• *Copyright Protected (Y or N)

2 Only two fields are required to upload a document into FDMS: the document title and document type. However,

ERG will include information from all fields listed in this document as part of its record

- keeping support to EPA.2

- 13 • Confidentia l Business Information (Y or N)

• Keyword 1 and Keywo rd 2

• Electronic Copy F ile Location

• Docket Item (Y or N)

• Project File Section Number

Four of the index fields that will be included in FDMS (Document Title, Abstract, Source Citation, Author Name) are free text format. However, information should be recorded in a consistent format to ensure easy retrieval. Because the Document Title is a searchable field, it is especially important that it be free of typos and use consistent abbreviations, punctuation, and capitalization. FDMS guidelines for free text fields are presented in Attachment 3

.

FDMS free text fields are size limited, in terms of number of characters (including blank spaces). The c haracter count of an index entry can be checked using tools/word count in MS

Word.

The index keeper adds the following information to the index as they manage the project file.

• Document Control Number (DCN) : This entry is specific to the Coalbed

Methan e project file index; however, our DCN will be included in FDMS

metadata at the end of the document title. FDMS will assign a separate, unique document ID to every document added to a docket. The index keeper will use the following convention for assignin g DCNs:

 DCN CBM XXXX X ;

 Attachments to the DCN will be DCN CBM XXXX X A01, DCN

CBM XXXX X A02, etc

.

• Input Date: This field is the date the index keeper adds the item to the

index.

• * Date to Docket: This field lists the date the item was delivered to the

EPA docket or uploaded to FDMS.

• Placeholder: This field indicates if the DCN is being assigned as a placeholder until a document has been created. Once the document is complete, the index keeper completes the metadata for the document and updates the Placeholder f ield.3

- 1 3.0 Q UALITY C ONTROL P ROCEDURES

Only fully legible, complete documents should be added to the project file, unless specifically noted as a document excerpt. All documents prepared by ERG will be reviewed prior

to submission to the project file. This review will be documented in the CBM QA database.

R eview of all deliverables includes checking and reviewing for completeness of supporting

documentation. Data and calculations will be checked as part of the document review. The

documen tation (such as backup calculations, spreadsheets, and telephone contact reports) will be added to the project file at the same time as the document. In most cases, a document will be

added to the Coalbed Methane project file when it is delivered to EPA.

No item will be added to the project file index unless it is available in hard copy to be filed in the archive and/or electronic form for the electronic project file. No changes will be made to section assignments in the index unless the project file item is physically re

- filed. Correct spelling, standard key words, accepted abbreviations, and consistent format are required

to ensure the index can function as a database.

3.1 Responsibilities

The overall responsibility for the quality of the project file and index belongs to the ERG Work Assignment Manager (WAM). The index

- keeper is responsible for the quality of the index (i.e., correct spelling, consistent format) and for correct filing of project file materials. Each team member is responsible for submittin g materials to the project file in a timely fashion and is responsible for completing project file log

- in forms when submitting materials.

The Coalbed Methane technical team member providing the technical lead for a particular activity (e.g., sampling) w ill be responsible for project file submittals on the activity, including index entries. They will also be responsible for ensuring that this plan is carried out and that materials are submitted to the project file in a timely manner.

Periodically, the E RG WAM will divide the project file into parts and assign each

part to a Coalbed Methane technical team member for review. In general, the team member providing the technical lead for the activity included in a project file section will be assigned that

se ction for review.

3.2 Project File Quality Review Procedures

ERG will perform quality assurance/quality control checks on the project file index, hard copy project file, and the electronic project file on a periodic basis to ensure completeness and accuracy. ERG will also periodically review this plan for possible revision.

3.2.1 Project File Index

After the index keeper or their designee completes a batch of new index entries (approximately 50 entries or fewer), they will print a list of the new entries. The list will be reviewed for spelling and format consistency. Approximately o nce a quarter, the index keeper will run database queries on the index to check for the following:3

- 2 • Errors in the metadata, such as m issing fields , d uplicate DCNs , d uplicate

entries

, and t ypos

.

• Copyright protected material or other restricted use material that is not

marked as such . For example, some site visit reports contain materials provided by the facility that was visited. The map or other document provided may contain a copyri ght symbol or a statement that the document’s use is restricted. In these cases, ERG project team members or EPA staff should obtain permission to make the document public or

exclude the protected information from the document being uploaded. As

another ex ample, web sites are often copyright protected , but the registry symbol appears only on the home page. This type of document should also be marked as copyright protect ed.

• Non

- CBI material that contains the word “confidential” in the document. For example, facilities may provide a document to EPA that is not claimed as CBI; however, pages within the document have been marked with the words “For Internal Use Only” or “Confidential

– Draft.” In these cases, ERG project team members or EPA staff should obtain permission to make the document public or exclude information marked “Confidential” from the document being uploaded. This check is important because if a document is uploaded to FDMS containing any indication of confidential or internal material, the FDMS docket staff will automatically designate it

as CBI.

3.2.2 Project File and Filing Review

Review of the project file content and filing will occur semi

- annually. The index keeper will conduct the following checks:

• Prepare a current printout of the Coalbed M ethane project file index;

• Ensure all items listed in the index are filed in the archive in the section listed in the index;

• Ensure all filed materials in the archive and electronic project file are listed in the index with complete and accurate informa tion;

• Ensure all deliverable items listed in the monthly reports are indexed and filed in the archive and electronic project file; and

• Communicate all discrepancies to the ERG WAM for resolution.

The ERG WAM will divide the index into parts and assign e ach part to a Coalbed

Methane technical team member. The technical team reviewers will conduct the following

checks:3

- 3 • Resolve discrepancies identified by the index keeper;

• Ensure all appropriate documents (e.g., deliverables, reference materials, etc.) ha ve been entered into the project file;

• Ensure all back

- up materials (i.e., references, calculations, etc.) for each

document are indexed and filed;

• Ensure index entries accurately represent the material; and

• Ensure the CBI and copyright status identific ation in the index and on the

document is accurate and consistent.

When the project file reviews are complete, the team will meet to discuss and resolve discrepancies and to discuss any possible changes needed in the project file plan.

3.2.3 Project File Plan Revision

This plan will be reviewed each year after the index

- keeper and technical team have completed their annual reviews. As necessary, the ERG WAM will ensure the plan will be

revised and submitted to EPA for review. All revisions to the plan will be communicated to the ERG team, following approval from EPA.4

- 1 4.0 D OCKET A SSEMBLY

The Coalbed Methane project file supports revisions to the Coalbed Methane

ELGs

. EPA opens a new docket for each proposed rulemaking effort

. T he Federal Reg ister (FR)

notice of the proposed rulemaking and supporting documents are added to the docket. Public

comments on the proposal are added next. Finally, documents supporting the final rulemaking

, including responses to comments, and the final F ederal R egist er notice are added to complete

the docket.

EPA staff is responsible for opening the docket and working with the EPA Docket

staff to create the docket in FDMS. The FDMS web page can be accessed at http://www.fdms.gov ; however, only approved users can upload files and access other FDMS

tools. The ERG index keeper and support staff ha ve an FDMS user ID and password. EPA/EAD staff (the “docket contact” in FDMS) must grant permission, by FDMS user ID, for ERG staff to

acc ess a specific docket. Once access is granted, ERG staff can create documents by entering metadata and uploading document files.

EPA Docket staff conducts a series of QC steps on the created documents, eventually identifying the document s as “Pending Po st.” The document s will not be released to the publicly accessible side of FDMS until a date (“docket phase posting date”) specified by the

EPA/EAD docket contact.

ERG can create document records (enter metadata) without uploading the

document files. Onc e a document file is uploaded to FDMS , ERG cannot delete it. If the document has not been posted (released to the public), ERG can request the docket staff to delete the entire record (Document ID, metada ta, and document) by moving it to an FDMS area calle d

the “sandbox

. ” If the document has been posted, the docket cannot change or delete a posted entry, but will add the revised file and insert a comment to the original entry that a revised document has been uploaded with the new assigned FDMS number. Beca use of these limitations, it is essential that only final documents be uploaded to FDMS. However, the document record can be created, and a Document ID assigned, without uploading the document

file. Note , ERG can edit document records before public posting

.

ERG will identify items from the project file to be included in the docket and designate those items in the record index, as discussed in Section 2.3.1. These items will include

references cited in the Federal Register notice and other supporting docum entation. Periodically during the rule development , a printout of the index of the suggested docket materials will be

submitted to EPA for review. Upon approval from EPA, ERG will add documents to the docket using FDMS by completing the document metadata a nd upload ing the pdf files from ERG’s electronic project file. When appropriate, in addition to pdf versions, ERG will upload databases and spreadsheets to allow the public an opportunity to analyze the data in support of their

comments and other uses. For electronic databases and large spreadsheets that can’t be rendered to pdf, ERG will complete the document metadata and obtain an FDMS “Document ID” for the document. ERG will provide electronic copies of these materials on removable media labeled

with th e Document ID number.4

- 2 All documents will be added to the docket as pdf files, with the following exceptions:

• Copyright protected material. ERG will provide electronic copies on

removable media of these materials.

• Physical objects (maps, aerial photos , colored charts, etc.).

• Large documents that present an undue burden for ERG (as contractor to the EPA program office) to scan (determined after consultation with EPA/EAD and docket staff).

• Databases and large spreadsheets that cannot be rendered to pdf

. ERG will provide copies of these documents on DVD or CD or other electronic medium acceptable to the docket.

• Any document containing CBI. ERG will complete the FDMS metadata for CBI documents and include the following in the abstract field: “This

docum ent contains Confidential Business Information. Please contact the Document Control Officer listed in the Federal Register Notice if access is necessary.” ERG will not provide copies of CBI to the docket.

Below are abbreviated instructions for submittin g material to the Docket. The index keeper and other staff will receive more detailed instructions prior to the use of FDMS.

• FDMS Metadata Entry into the project file index, including adding the

ERG DCN at the end of the FDMS document title

.

• EPA approves index entries from Access database printout.

• Index keeper retypes (or block/copies) index information as FDMS

metadata into the interface at http://www.fdms.gov

, and each document is assigned an FDMS Document ID. Use the FDMS “create doc ument” wizard for this process.

• Add descriptions to the abstract of documents that will not be uploaded to

FDMS:

**−** CBI documents,

**−** Copyright protect ed publications,

**−** Databases and large spreadsheets, and

**−** Other materials as directed by do cket staff.

• A ssign a second staff person to open the metadata for a subset of the entries and compare the document details to the Access **** database printout. Any discrepancies will be brought to the attention of the index keeper, who will correct the FDMS metadata, as appropriate. The ERG4

- 3 W ork A ssignment M anager and index keeper will determine the number

of entries to review and the percentage of errors that will require that more

entries be verified

.

• When a DCN is assigned, the pdf file is saved to the Q: \ Coalbed

Methane \ Record \ Electronic Project File \ network area

. A ssign a second staff person to open the pdf files for all entries and compare the pdf to the

metadata . Any discrepancies will be brought to the attention of the index

kee per, who will obtain t he correct PDF from the ERG WAM or project

team member , as appropriate. The ERG W ork A ssignment M anager and index keeper will determine the number of entries to review and the percentage of errors that will require that more entries be verified

.

• Upload el ectronic files

.

– Document files can be added at the same time that the document record is created, or as a separate step.

– Use the "add document" wizard to add files and their metadata individually to ensure all information is transferred to FDMS

.

– Upload pdf files from ERG’s electronic project file to FDMS.

– The ERG index keeper will notify docket staff in advance of

docket activities.

– As specified by the project, the index keeper or her designee will open the uploaded files to confirm they match the m etadata.

• Prepare h ard copy material for docket submittal, if necessary

. The index keeper will try to convert hard copy material in to an electronic file, typically by scanning and saving the material in pdf format . If the material cannot be converted, the index keeper will prepare a hard copy for submittal. This is only expected for the following materials :

– Copyright protected publications;

– Databases and large spreadsheets on DVD, CD or diskette;

– Large Books;

– Physical Objects (maps, and aerial photos); a nd

– Other materials as directed by docket staff.

• Create a document record (metadata) for hard copy material, as described

above. The document record includes the FDMS document ID.

• Create a label for the hard copy material. The label must not obscure any information. The label should include:4

- 4 – Docket n umber ;

– FDMS Document ID (in pencil) ;

– ERG Section number; and

– ERG DCN.

• Prepare paper documents as two

- sided copies.

• Assemble all copies in FDMS Document ID order.

• Place copies in top tab accordion fold ers.

• Submit a hard copy list (index) of the documents at the time they are

delivered.

• Deliver hard copy docket materials by Fed Ex, courier or ERG staff to the following address: EPA Water Docket, EPA

- West Room 3334 , 1301 Constitution Avenue, Washingto n, D.C. 20460.Attachment 1

COALBED METHANE PROJECT FILE OUTLINEA1

- 1 COALBED METHANE PROJECT FILE OUTLINE

1.0 INDUSTRY DESCRIPTION

1.1 Industry Profile (correspondence and general information from trade associations, industry, and others; company reports; industry statistics; description of other industries related to Coalbed Methane power generation.)

1.2 Industry Regulatory Status (Relevant state regulations, permits, and other applicable regulations to the industry to date.)

1.3 Treatment Technologies ( D escription of treatment technologies of equipment, including vendor information.)

1.4 Other Literature (Pollutant descriptions, process chemistry, toxicology information, pollution and environmental concerns, and newspaper an d related press articles.)

1.5 Public Meetings and Stake Holder Meeting Materials

2.0 TECHNICAL DATA

2.1 Industry

- Submitted Data

2.1.1 Monitoring Data ( L ong

- term monitoring data submittals; does not include data submittals with questionnaire.)

2.1. 2 Treatment Data (Pilot

- and bench

- scale studies o r treatment performance data submitted by operators or vendors)

2.1.3 Other Submissions ( O ther industry and industry trade association technical data submissions, discharge data, treatment data, and perfor mance data specific to Coalbed Methane plants not included elsewhere.)

2.2 Questionnaire Data

2.2.1 Development Files ( D raft and final questionnaires, ICR, FRN and

comments, and FAQs

. )

2.2.2 Mailing List Development (Mailing lists, sources/contacts, and

m ailout instructions/tracking

. )

2.2.3 Coalbed Methane Questionnaire Responses ( R eview/coding and helpline guidelines, original and review copy, and helpline/review

telecons and emails

. )

2.2.4 Electronic Questionnaire Databases ( D atabase development,

data e ntry program, data element dictionaries, and tables/queries

. )A1

- 2 2.3 Site Visits

2.3.1 General/Development Items (D evelopment files for site visits, including plant selection

. )

2.3.2 Power River Basin (Each site visit section will contain planning

document ation, materials received from the site, site visit notes, and facility comments for the visits in a particular basin .) Additional sections will be added for each basin

.

2.4 Sampling Program

2.4.1 General/Development Items (D evelopment files for sampling

, including plant selection , generic SAP, and SER template s .)

2.4.2 Methods (Methods optimization work and method SOPs.)

2.4.3 Analy tical Database (Each episode section will contain planning documentation, site

- specific SAP, data collected from the site, t he SER, and facility comments.)

2.5 Supplementary Data ( Material which cannot be easily filed in one of the other background support components, but which is helpful or essential to describing the industry or its current status, such as the rationale fo r the development of regulations, old policies .)

3.0 TECHNICAL DATA INTERPRETATION (Includes evaluations for subcategorization options , pollutants of concern, technology options, and best management practices

. Also i ncludes other aggregate facility data and analysis, summaries, calculations, and conclusions based on the data from more than one facility used to develop or reject options.) This section will be subdivided when we get to d ata interpretation tasks.

4.0 OPTIONS ANALYSIS

4.1 Engineering Co sts

4.1.1 Engineering Cost Model (Memoranda and documentation on cost approach, model development, quality assurance documentation.)

4.1.2 Cost Estimates ( Site

- specific and industry

- level cost estimates and relevant documentation.)

4.2 Pollutant Load s

4.2.1 Pollutant Removals Model (Memoranda and documentation on loadings approach, model development, quality assurance documentation.)

4.2.2 Pollutant Load and Removal Estimates (Facility

- specific and industry

- level loadings estimates and relevant doc umentation.)A1

- 3 4 .3 N on

- Water Quality Impacts

4.3.1 NWQI Model (Memoranda and documentation on NWQI approach, model development, quality assurance documentation.)

4.3.2 NWQI Estimates (Facility

- specific and industry

- level loadings

estimates and relevant documentation.)

5.0 ECONOMIC DATA, INTERPRETATION, AND ANALYSIS (T O BE

PROVIDED BY EPA' S ECONOMIC LEAD

. I NCLUDES SBREFA MATERIALS .)

6.0 STATISTICAL ANALYSIS (To be provided by EPA's statistics lead.)

7.0 BENEFITS ANALYSIS (To be provided by EPA's benefits le ad.)

8.0 ENVIRONMENTAL IMPACT ASSESSMENT (To be provided by EPA’s environmental impact assessment lead. )

9 .0 INTERAGENCY REVIEW (To be provided by EPA.)

10.0 PROPOSED RULEMAKING PACKAGE MATERIALS (Includes Federal Register Notice, Technical Development Document, Preamble.)Attachment 2

COALBED METHANE PROJECT FILE LOG

- IN FORM SA2

- 1 This page illustrates the electronic Microsoft Excel spreadsheet, with dropdown menus available for auto

- population of some fields. The second page shows the alternative login sheet : a table that can be completed in either

Microsoft Excel or Word.

Example Blank Microsoft Excel Login Sheet

Example of Login Sheet Drop

- Down Menu

Example Completed Microsoft Excel Login SheetA2

- 2 

## COALBED METHANE ELECTRONIC PROJECT FIL E INDEX LOG

- IN
SHEET

Submitted by:

DCN: Index Keeper will assign DCN

TITLE:

ABSTRACT:

DOCUMENT_SUB TYPE:

PLACEHOLDER (Yes or No):

SOURCE_CITATION:

AUTHOR:

AUTHOR AFFILIATION:

AUTHOR_DATE:

PAGE_CO UNT:

COPYRIGHT PROTECTED (Yes or No):

CBI (Yes or No):

KEYWORD_1:

KEYWORD_2

ELECTRONIC COPY FILE
LOCATION:

PROJECT FILE SECTION NUMBER:

DOCKET_ITEM (Yes or No)Attachment 3

FDMS GUIDELINES FOR FREE TEXT FIELDSA 3

- 1 Guidelines for Fre e Text FDMS Metadata

Information for free text fields should be recorded in a consistent format to ensure reliable

retrieval.

The guidelines described below cover the most common types of errors: grammar, abbreviations, capitalization, use of numerals, and punctuation. Two additional areas where errors are likely to be generated include spelling and typographical formatting. Use of spell checking software and proofreading entered data can reduce spelling errors. Typographical or formatting errors can be caused by sloppy cut and paste functions, forgetting to close a parenthetical expression, or failing to use quotation marks correctly. These errors can be addressed by using grammar checking software and, again, carefully proofreading data entry.

Within the FDMS system, the Document ID, Document Title, and Document Type are

searchable fields. The search fields are case sensitive. Document Title is a free text field, so special care for consistency in capitalization must be taken with this field. If the us er searches on a term using a mix of upper and lower case letters, the database will only return results that match that specific mix of characters. Searches performed using letters of a single case will return results regardless of specific character comb inations. Since users are most likely to use a mix of upper and lower case letters with proper names, you must be sure that the metadata are entered in the correct format for a proper name. Guidelines are included below on the use of abbreviations, capital ization, numerals, and punctuation. Additional resources that can be used in making formatting decisions include dictionaries and the MLA Handbook for Writers of Research Papers , Sixth Edition (2003).

I. Grammar Review

The same careful thought given to w riting a memorandum or a letter should be used when composing metadata. Fields such as Abstract are designed to allow the data entry operator to present information using anywhere from a single sentence to a full paragraph. It is important, therefore, that this information be presented in proper syntax using complete sentences. Run

- on sentences should be avoided. As with any free text field, it is important that the data be presented in a way that other readers will find clear and concise. Since space in t he field is limited, you may need to redraft text to fit within the parameters of the field. When doing so, it is important be sure that all unnecessary characters have been removed and that the new text conforms to the flow of the existing sentences.

II

. Abbreviations

Abbreviation styling is, unfortunately, inconsistent and depends most often on the organization’s policy. Company names are especially arbitrary as many businesses desire a unique look and feel to distinguish their name and letterhead from other firms. For example, Gulf + Western Industries, Inc. is the actual company name. This firm selected to represent the word “and” not with the more traditional “&” but with a positive or plus sign “+”. In such cases, you should

default to the official name as presented by the organization.

Abbreviations are used for many reasons in document development. The most common reasons include (1) to avoid repetition of long words and phrases that may distract the reader, (2) to saveA 3

- 2 space and time, (3) to re place keystrokes and increase output, and (4) to reflect statistical data in limited space. When using an abbreviation that may be unfamiliar or confusing to the reader, one should give the full form first followed by the abbreviation in parentheses as

S ummary of Orders from the Office of Management and Budget (OMB).....

followed in subsequent references by just the abbreviation, as

At the June 14, 2003, OMB meeting, agents met to discuss......

When abbreviating an Agency employee’s various program af filiations, it is acceptable to use virgules. For example: Dave Beck, USEPA/ESED/CPB/CM

If a position title had been provided, the proper format would have been: Dave Beck, Regulatory Analyst, USEPA/ESED/CPB/CM

Guidelines for Abbreviations

The only te rms which do not require use of the full form before the use of the abbreviation are those business units within the U.S. Environmental Protection Agency or the agency name

itself.

If the full form and abbreviation are used in the docket or document title field, then the abbreviation may stand alone in the docket or document description field.

Guideline Sample

The Environmental Protection Agency should be abbreviated according to Agency Standard. USEPA

Beginning a sentence with an abbreviation

should be avoided unless the abbreviation represents a courtesy title. Page 22 contains.... but not P. 22 contains ....

Dr. Smith is here. or Doctor Smith is here.

Company names are not abbreviated unless abbreviations comprise their official name. Ginn and Comp any Harwood Engineering Co., Inc.

Compass points are abbreviated when occurring after street names and they can be unpunctuated. 2122 Apple Street, NW

Geographical and topographical names should

utilize U.S. Postal Service abbreviations. AL AK MN DC

BLVD ST PL RR US

Laws and bylaws when first mentioned are typed in full; however, subsequent references may be abbreviated. first reference Article I, Section 1 subsequent reference Art. I, Sec. 1

Personal names s hould not be abbreviated. George S. Patterson not Geo. S. Patterson

Scientific terms in binomial nomenclature may have the genus abbreviated after the first

full form reference. first reference Escherichia coli subsequent reference E. coliA 3

- 3 Guidelines for Abbreviations

Title s that are invariably abbreviated include Mr., Mrs., Ms., Messrs., and Dr. Honorable

and Reverend when used with The are typed

out. If used without The , these forms of address may be abbreviated. Colonel COL John P. Howe, USA

General GEN John P. Ho we, USA

Private PVT John P. Howe, USA

Versus is abbreviated as the lowercase Roman

letter v. in legal contexts. In general context, it

is abbreviated as vs. Smith v. State of Vermont honesty vs. dishonesty

III. Capitalization

Upper case letters are used for two broad purposes in English: they mark the beginning of a sentence and they signal a proper noun or adjective. Keeping mind that the database’s search function are case sensitive, it becomes even more critical for you to apply the rules of

c apitalization accurately.

Guidelines for Capitalization

Abbreviations are only capitalized if the words they represent are proper nouns or adjectives.

The first word of a sentence, of a sentence fragment, or of a complete sentence enclosed in parenth eses is capitalized.

Guideline Sample

Most acronyms are capitalized unless they have been assimilated into the language as parts of speech.

Consult a dictionary for proper styling. Acronyms that are not part of the daily language: MIRV NOW account

Ac ronyms that are used as part of the daily language: scuba, quasar, laser, radar, sonar,

snafu

Abbreviations of air force, army, coast guard, and navy ranks are all capitalized. Those of the marine corps are capitalized and lower

cased. BG John P. Howe, US A LCDR Mary I. Lee, USN Col. John P. Howe, USMC

Abbreviations of academic degrees and professional ratings may be all capitalized or capitalized and lower

- cased depending on the

term. Consult a dictionary for proper styling. D.D.S. M.B.A.

P.E. C.P.A.

Ph.D.

Branches and units of the armed forces are capitalized, as are easily recognizable short

forms. United States Army and Army Rangers

Popular names of localities are capitalized. Capitol Hill Foggy Bottom Georgetown the Sunshine State

the Corn Belt the Eastern ShoreA 3

- 4 Guidelines for Capitalization

Nouns used with numbers or letters to designate major reference headings are capitalized; however, minor reference headings and subheads are typically

lowercased. Book II Volume V Part 1

Tab le 5 Figure A Appendix III

footnote 14 page 12 line 8

item 16 note 10 paragraph 7

Words in titles of printed matter are capitalized except for internal conjunctions, prepositions, and articles. Introduction to Word Processi ng Before the Fall

Journal of Scientific Medicine

The first word following a colon in a title is capitalized. CBS: Reflections in a Bloodshot Eye Women in Baseball: The Forgotten History

Trademarks, brand names, and service marks are capitalized. the De ll workstation Federal Express

Touch

- Tone

The names of ships, airplanes, and spacecraft are capitalized. space shuttle Columbia Spirit of St. Louis

M. V. West Star

IV. Numerals

In modern business writing, most numerals

- and especially exact numbe rs above 10

- are expressed in figures. Since there is flexibility in expressing monetary units, dates, and other numerical combinations, the overriding consideration is to be consistent in the standard selected.

Provided below are the standards selected f or use of numerals in the FDMS database.

Guidelines for Numerals

Guideline Sample

Ages are expressed in figures. Her 11 year

- old son... A 65 year

- old veteran...

Space permitting, numbers that begin a

sentence are to be written out. Thirty

- two birds di ed.

Dates should be written as Month, Day, and Four Digit Year when expressed in narrative

format. Ordinal numbers should not be used. January 1, 2003

not
the 1 st of January, 2003

Dates may be represented in figures when not

in narrative format bu t must be in the format

of MM/DD/YYYY. 11/21/2003

Exact amounts are usually expressed in figures unless they begin a sentence. Thirty

- two birds died. Due to the chemical spill, 32 birds died.

Percentages will use the % character. 10 % not 10 per cent
Figures over 999 will use a comma except

when the number is a set combination such as a contract number, policy number, check or invoice number, address or room number. 1,135 keystrokes not 1135 keystrokes

Check 34567 the year 2003 page 4526

Room 6000

- B Contract No. W

- 03

- 12456A 3

- 5 V. Punctuation

The English writing system uses punctuation marks to separate groups of words for meaning and emphasis; to convey an idea of the variations of pitch, volume, pauses, and intonation of speech;

and to help avoid contextual ambiguity. Punctuation marks should be used sparingly as special characters can make searching for and retrieving data difficult.

Spacing is an important issue in the use of special characters. There should be no space between

the f ollowing combinations: any word and the punctuation that closes a sentence, quotation marks and the quoted matter, parentheses or brackets and the words or figures that they enclose, between initials comprising abbreviations, between hyphenated compounds, or on either side of a

dash. There should be one space after a comma or semicolon, after a period following an initial in a proper name (Mr. H. C. Milker), before and after mathematical signs, and between U. S.

Postal Service state abbreviations and the ZI P Code.

Guidelines for Punctuation

Virgules (/) are not used to separate items in a list or to divide phrases but can be used if it is part of a title or acronym. (E.g. OEI/OIAA)

Use of the ampersand (&) should be avoided whenever possible. Spell out th e word “and”

instead. Use of the ampersand is permissible when it is a part of a proper noun such as a company name or is part of a legal case title or publication title.

Hyphens/dashes (

- ) are not used to introduce a list of items.

Ellipses (...) are us ed when a title or quote is to long to fit within a field.

Guideline Sample

While apostrophes normally mark the omission of numerals or letters, this use

should be avoided in the FDMS database

where the electronic record will be retained indefinitely. th e class of 1967 not the class of ‘67

fiscal year 1987 not fiscal year ‘87

Apostrophes are used in possessive nouns. One Man’s Junk

The History of the Thirty Years’ War

Brackets set off extraneous data and function as parentheses within parenth eses. The company deceived them [the suspects] and is now paying hefty penalties.

(Bowman Act [also known as the Freedom Act] Ch. 4, sec. 4, p. 50)

Colons introduce a clause or phrase that explains, illustrates, amplifies or restates what has gone on be fore. The Hazards of Benzene: An Inhalation Study

Colons introduce items in a series. Please reference the following dockets: OAR

2002

- 0012, OAR

- 1999

- 0014, and OW

- 2001

- 0142.A 3

- 6 Guidelines for Punctuation

Colons separate elements in set formulas such as ratios, time, volume and page r eferences, biblical citations, and place and publisher. a ratio of 3:5 8:30 a.m.

Words and Phrases 11:261 John 4:10 Springfield, MA: Merriam

- Webster Inc.

Commas divide items in a list and set off cities from states, dates from years, and lines in a n address. ...includes: OAR

- 2002

- 0012, OAR

- 1999

- 0014, and OW

- 2001

- 0142. Shreveport, LA December 7, 2003

Hyphens are used only in numerical sets where dictated by style. OAR

- 2003

- 0012

Contract No. W

- 03

- 125

- 8954A

Hyphens are used between some prefix an d

root combinations.

Consult a dictionary for proper styling. trans

- Atlantic flight

pre

- 2003

re

- publish

non

- road

Hyphens are used in compound words, especially those containing a preposition.

Consult a dictionary for proper styling. chairperson

- elect attorney

- at

- law

Hyphens are used between compound adjectives. light

- duty large

- scale eight

- cylinder

Hyphens are used in expressing written out numbers, between a numerator and denominator, dividing years and pages in a range, or showi ng a distance relationship. forty

- two flowers

a two

- thirds majority pages 40

- 67

the decade 1960

- 1970

US

- Iraq relations

Ellipses (...) are used when a title or quote is too long to fit within the field. The organization replied that it “felt overwhelmed by t he workload required

under...the Clean Air Act.”

Alternative spellings of English terms should

be retained in formal titles and affiliations. In FDMS, include the American spelling of the

term in brackets after the foreign language spelling.

Consult your dictionary for the proper American spelling. organisation [organization] colour [color]
centre [center] glycerine [glycerin]B

- 1 Appendix B
Database Description and Database Dictionary

The engineering questionnaire database follows the same structure as Parts A and C of
the detailed questionnaire (DQ). The DQ relates operators, projects, and produced water
management systems (PWMS) as illustrated in Figure B

- 1. The database assigns an
automatically generated number to each operator, project, and PWMS for ease in linking the

overall database structure

.

An operator may have one or more projects consisting of a group of CBM wells. This is
defined in Part A of the DQ. Each project that is owned by an operator may generate produced
water during CBM operations that is managed by one or more produced wa ter m anagement systems (PWMS). Multiple projects may enter one PWMS. Part C of the DQ requested

information s pecific to a project and PWMS. Operators provided information about final
destinations, residuals treatment, and water treatment operations for each un ique project/PWMS
combination. Figure B

- 2 illustrates how different project and PWMS scenarios should have been
completed by the operator.

Figure B

- 1 . CBM DQ

– Relationship Between Operators, Projects, and PWMSsB

- 2 Figure 2 . CBM DQ

– Relationship Between Operators, Projects, and PWMSs

Database Dictionary

The remaining portions of this document provide the database dictionary for the
engineering questionnaire database. Each table provides the fol lowing information:

**•** Table name

– The name of the Microsoft Access table name is provided at the top of
each table along with the section of the questionnaire containing the data;

**•** FieldName

– List of each field in the table. Field names include the DQ question
number, where applicable;

**•** FieldType

– Data type (e.g., text, yes/no, number, date); and

**•** FieldDescription

– Narrative description of the field.B

- 3 Operators (Part A)

FieldName FieldType FieldDescription

CertFacility Text Facility Name

SID Text If Screener = yes, contains screener ID

Screener Yes/No Indicates whether or not operator received

CertPhone Text Certifying Official's Telephone Number

CertTitle Text Certifying Official's Title

CertName Text Certifying Official's Name

Address Text Company address

A1_1_CBM_scre Yes/No Did operator respond to EPA’s screener

OperatorID AutoNumber Operator Identification Number; unique ID assigned by database

allCBI Yes/No Indicates whether or not entire survey is CBI

SmallBusiness Yes/No Indicates whether or not operator is a small business

Name Text Company name

OperatorIdentifier Text unique code assigned in the survey.

CertDate Text Date of Certification

Projects (Part A, Table A

- 1)

FieldName FieldType FieldDescription

OperatorID Long Integer Unique operator ID, links to Operators table

ProjectID AutoNumber Unique ID assigned by database

NumberOfWells Long Integer Number of wells associated with project

SurveyWeight Long Integer Survey weight (to be provided by statisticians)

ProjectIdentifier Text Unique identifier assigned by survey

ProjectWells (Part A, Table A

- 2)

FieldName FieldType FieldDescription

OperatorID Long Integer Unique operator ID, links to Operators table

ProjectID Long Integer Unique project ID, links to Projects table

APINumber Text API Number

PermitNumber Text Permit NumberB

- 4 ContactInfo (Part C, C1

- 1)

FieldName FieldType FieldDescription

OperatorID Long Integer Operator Identification Number

C1_1_ContactEm Text Primary contact email

C1_1_ContactPh Text Primary contact telephone number

C1_1_ContactTi Text Primary contact time to call

C1_1_ContactNa Text Primary contact name

C1_1CBI Yes/No Is question C1

- 1 CBI?

C1_1_ContactFax Text Primary contact fax

C1_1_ContactTitle Text Primary contact title

Projects_PWMSystems (Database linking table)

FieldName FieldType FieldDescription

ProjPWMSystemID AutoNumber Unique ID for Proj + system combination

PWMSystemID Long Integer Unique system ID, links to Systems table

ProjectID Long Integer Unqiue Project ID, links to Projects table

PWMSystems (Database linking table)

FieldName FieldType FieldDescription

OperatorID Long Integer Unique operator ID, links to Operators table

PWMSystemName Text Unique name assigned by survey reviewer, or taken straight from

survey
PWMSystemID AutoNumber Unique ID assigned by database

PWMSystemGeneral (Part C, Section s 2 and 3)

FieldName FieldType FieldDescription

ProjPWMSystemID Long Integer Unique ID for Proj + system combination

C2_1_Desc Yes/No Is a narrative description attached?

C2

- 1_Narrative Memo Narrative description

C2_1_Diagram Yes/No Is a block diagram attached?

C2_1_CBI Yes/No Is question C2

- 1 CBI?

C2_2_YearBegan Text In what year did this PWMS begin operating?

C2_2_NumDays Integer If the PWMS did not operate for 365 days in 2008, how many days did
it operate?

C2_2_365Days Yes/No Did the PWMS operate 365 days in 2008?

C2_2_CBI Yes/No Is question C2

- 2 CBI?

C2_3_WellsFlow Double Flowrate or volume generated by wells

C2_3_WellsFlowType Text Type of flow data provided (AvgDaily or TotalVol)

C2_3_WellsFlowUnits Text Units of flowrate or volumeB

- 5 PWMSystemGeneral (Part C, Section s 2 and 3)

FieldName FieldType FieldDescription

C2_3_WellsFlowQualifier Text Qualifier that may be associated with flowrate or volume generated
by wells
C2_3_PWMSFlowUnits Text Units of flowrate or volume

C2_3_PWMSFlowQualifier Text Qualifier that may be associated with flowrate or volume managed by

PWMS
C2_3_PWMSFlow Double Flowrate or volume managed by PWMS

C2_3_PWMSFlowType Text Type of flow data provided (AvgDaily or TotalVol)

C2_3_CBI Yes/No Is question C2

- 3 CBI?

C2_4_ProjectWaterPercent Double What percentage of water treated by this PWMS is from the project

from Part A listed at the top of the page?

C2_4_ProjectGasPercent Double What percentage of gas production from the project from Part A
listed at the top of the page is associated with wells for this PWMS?

C2_4_CBI Yes/No Is question C2

- 4 CBI?

C2_5_OwnerDesign Yes/No Was the PWMS designed with input from the surface owner?

C2_5_ContractorDesign Yes/No Was the PWMS designed by working with an outside contractor?

C2_5_OtherDesign Yes/No Was the PWMS designed in some other way?

C2_5_OthDesignDesc Text Description of the other design process

C2_5_Operator Yes/No Does the operator manage the day

- to

- day operations for the
produced water management?
C2_5_Landowner Yes/No Does the landowner manage the day

- to

- day operations for the
produced water management ?

C2_5_Contractor Yes/No Does a contractor or third party manage the day

- to

- day operations for the produced water management?

C2_5_ContractorCompany Text Contractor/third party company name

C2_5_ContractorCost Double 2008 annual operating and maintenance costs (dollars)

C2_5_ContractorCostQualifie

r Double Qualifier that may be associated with 2008 annual operating and maintenance costs (dollars)

C2_5_MinCBMWater Double Minimum quantity of CBM produced water required for contract (bbl)

C2_5_MinCBMWaterQualifie

r Double Qualifier that may be associatd with minimum quantity of CBM produced water required for contract (bbl)

C2_5_CBI Yes/No Is question C2

- 5 CBI?

C2_6_CapCostPWMS Long Integer Capital cost of the PWMS (dollars)

C2_6_CostYearPWMS Text Year cost incurred

C2_6_PurchasedPWMS Yes/No Did your company purchase this PWMS from another company so
that this capital cost information is unavailable?

C2_6_CBI Yes/No Is question C2

- 6 CBI?

C2_7_2008OMCostPWMS Long Integer 2008 operating and maintenance cost (dollars) for this PWMS

C2_7_Revenue Long Integer Annual revenue received from operating the PWMS

C2_7_CBI Yes/No Is question C2

- 7 CBI?

C2_8_VolPiped Long Integer Total 2008 volume of water generated from the CBM wells identified
in Part A that is piped to this PWMS
C2_8_VolPipedUnits Text Volume units

C2_8_CapCostPiped Long Integer Capital cost of the piped water gathering system between the CBM wells identified in Part A and this PWMS (dollars)B

- 6 PWMSystemGeneral (Part C, Section s 2 and 3)

FieldName FieldType FieldDescription

C2_8_CostYearPi ped Text Year cost incurred

C2_8_PurchasedPiped Yes/No Did your company purchase this piped produced water gathering system from another company so that this capital cost information is

unavailable?
C2_8_2008OMCostPiped Long Integer 2008 operating and maintenance cost of the piped water gathering
system between the CBM wells identified in Part A and this PWMS (dollars)
C2_8_VolTrucked Long Integer Total volume of produced water trucked to this PWMS in 2008

C2_8_VolTruckedUnits Text Volume units

C2_8_TruckCapacity Long Integer Average volume capacity of truck used

C2_8_TruckCapacityUnits Text Truck capacity units

C2_8_MilesTraveled Long Integer Total vehicle miles traveled for the truck transport of produced water

to this PWMS in 2008
C2_8_DaysTraveled Long Integer Total number of days used to truck this produced water to this PWMS

in 2008
C2_8_TruckCosts Long Integer Total 2008 costs incurred to truck produced water to this PWMS

C2_8_CBI Yes/No Is question C2

- 8 CBI?

C2_9_CBI Yes/No Is question C2

- 9 CBI?

C2_9_ProjectArea Double Total project land area (Part A Project)

C2_9_ProjectAreaUnits Text Units of total project land area

C2_9_PWMSArea Double Total PWMS land area

C2_9_PWMSAreaUnits Text Units of total PWMS land area

C2_9_UndevelopedArea Double Total underdeveloped land area

C2_9_UndevelopedAreaUnits Text Units of total underdeveloped land area

C2_9_Suitable Yes/No Is the undeveloped area suitable for construction of new or additional
wastewater treatment systems?

C2_9_Explanation Memo Explanation of suitability of undeveloped area

C2_10_OtherPWMS Yes/No Have you ever operated or considered operating a PWMS other than
what is described in this section for the project?

C2_10_CBI Yes/No Is question C2

- 10 CBI?
C2_11_PWMSConsidered Memo Type of management system considered

C2_11_CBI Yes/No Is question C2

- 11 CBI?

C2_12_CBINoPWMSReasons Memo Reasons for not implementing or for stopping the operation of the

management system

C2_12_CBI Yes/No Is question C2

- 12 CBI?
C2_13_Studies Yes/No Have any monitoring or other studies been conducted to assess the
potential impacts of produced water for this PWMS?

C2_13_CBI Yes/No Is question C2

- 13 CBI?

C2_14_CBI Yes/No Is question C2

- 14 CBI? (See PWMS Systems table for details on each study)B

- 7 PWMSystemGeneral (Part C, Section s 2 and 3)

FieldName FieldType FieldDescription

The remaining fields on this table are flags added to indicate whether there is information on the detailed tables in Part C,

Section 3.

C3_4_NoData Yes/No Yes indicates that survey contained no data for this question

C3_5_NoData Yes/No Yes indicates that survey contained no data for this question

C3_6_NoData Yes/No Yes indicates that survey contained no data for this question

C3_7_Treat Yes/No Do you treat produced water to remove pollutants prior to discharge to surface water or POTW/third party?

C3_7_CBI Yes/No Is question C3

- 7 CBI?

C3_8_NoData Yes/No Yes indicates that survey contained no data for this question

C3_9_NoData Yes/No Yes indicates that survey contained no data for this question

C3_10_NoData Yes/No Yes indicates that survey contained no data for this question

C3_11_NoData Yes/No Yes indicates that survey contained no data for this question

C3_12_NoData Yes/No Yes indicates that survey contained no data for this question

C3_13_NoData Yes/No Yes indicates that survey contained no data for this question

PWMSystemStudies (Part C, C2

- 14)

FieldName FieldType FieldDescription

ProjPWMSystemID Long Integer Unique ID for Proj + system combination

PWMSystemStudyID AutoNumber Unique identifier for study

C2_14_Title Memo Title of the study

C2_14_Date Text Date of the study

L_DestinationCode (linking table defining destination codes and descriptions for C3

- 1)

FieldName FieldType FieldDescription

Destination code Text Destination code

Desc Text Destination descriptionB

- 8 PWMSystemDestination (Part C, C3

- 1 Destination and C3

- 2 Cost Information)

FieldName FieldType FieldDescription

ProjPWMSystemID Long Integer Unique ID for Proj + system combination

C3_1_Destination Text Code associated with selected destination

C3_1_OtherDesc Text Description of other (if applicable)

C3_1_CBI Yes/No Is question C3

- 1 CBI?

C3_2_Volume Double 2008 volume of produced water from this PWMS to this destination

C3_2_VolumeUnits Text Units for volume

C3_2_MaxDayCap Double Maximum daily capacity of producted water from this PWMS capable
of going to this destination

C3_2_MaxDayCapUnits Text Units for maximum daily capacity

C3_2_CapCostPercent Double Percent of total capital cost for this destination

C3_2_LandAcq Yes/No Is land acquisition included in the capital costs?

C3_2_Piping Yes/No Are piping/hoses included in the capital costs?

C3_2_Outfall Yes/No Is outfall structure included in the capital costs?

C3_2_InjWell Yes/No Are injection wells included in the capital costs?

C3_2_Pond Yes/No Are ponds included in the capital costs?

C3_2_Pumps Yes/No Are pumps included in the capital costs?

C3_2_Liner Yes/No Are liners included in the capital costs?

C3_2_MonEquip Yes/No Is monitoring equipment included in the capital costs?

C3_2_AerEquip Yes/No Is aeration equipment included in the capital costs?

C3_2_TrtUnit Yes/No Are treatment units included in the capital costs?

C3_2_Tanks Yes/No Are tanks included in the capital cost s?

C3_2_LandApp Yes/No Is land applicatin equipment included in the capital costs?

C3_2_Other1 Yes/No Is another componenet included in the capital costs?

C3_2_Other1Desc Text Description of other1

C3_2_Other2Desc Text Description of other2

C3_2_OandMCostPercent Double Percent of total operation and maintenance cost

C3_2_Labor Yes/No Is labor included in the O and M costs?

C3_2_Materials Yes/No Are materials included in the O and M costs?

C3_2_EOil Yes/No Is oil energy included in the O an d M costs?

C3_2_EGas Yes/No Is gas energy included in the O and M costs?

C3_2_Chemicals Yes/No Are chemicals included in the O and M costs?

C3_2_EElec Yes/No Is electric energy included in the O and M costs?

C3_2_OtherOandM Yes/No Is another componen t included in the O and M costs?

C3_2_OtherOandMDesc Text Description of other O and M component

C3_2_CBI Yes/No Is question C3

- 2 CBI?B

- 9 PWMSystemResidual (Part C, C3

- 3 Residual)

FieldName FieldType FieldDescription

ProjPWMSystemID Long Integer Unique ID for Proj + system combination

ResidualID AutoNumber Sequential ID for residual mgmt info within a system

C3_3_ResidDesc Text Description of residual generated and its source

C3_3_ResidFreq Text Frequency of residuals removal from this PWMS in 2008

C3_3_ResidFreqUnits Text Units for frequency

C3_3_Volume Long Integer Volume of residual generated in 2008

C3_3_VolumeUnits Text Units for volume

C3_3_FinalDest Text Name of final destination for this residual

C3_3_DestDist Long Integer Distance from this PWMS to the final destiantion for this residual (miles)

C3_3_DispCost Long Integer Annual 2008 cost of disposal for this residual (dollars)

C3_3_Piped Yes/No Is transportation: piped included in the residual disposal cost?

C3_3_Trucked Yes/No Is transportation: trucked included in the residual disposal cost?

C3_3_Fees Yes/No Are disposal fees included in the residual disposal cost?

C3_3_Other1 Yes/No Is something else included in the residual disposal cost?

C3_3_Other1Des c Text Description of other1

C3_3_Other2 Yes/No Is something else included in the residual disposal cost?

C3_3_Other2Desc Text Description of other2

C3_3_CBI Yes/No Is question C3

- 3 CBI?

PWMSystemSurfaceWater (Part C, C3

- 4 Surface Water Information)

FieldName FieldType FieldDescription

ProjPWMSystemID Long Integer Unique ID for Proj + system combination

C3_4_NoData Yes/No Indicates whether or not data was submitted for this question

C3_4c_PermitAtt Yes/No Is a copy of the current surface water discharge NPDES permit

attached?

C3_4a_NPDES Text NPDES permit number

C3_4a_PermitType Text Permit Type (General or Individual)

C3_4a_ExpDate Date/Time Expiration Date (MM

- DD

- YYYY)

C3_4a_RevorMod Yes/No Is the permit currently being reviewed of modified?

C3_4a_EffluentMon Yes/No Is effluent monitoring required?

C3_4a_EffMonFreq Long Integer Frequency of effluent monitoring

C3_4a_EffMonFreqUnits Text Units for frequency

C3_4a_StreamMon Yes/No Is stream monitoring required?

C3_4a_StreamMonFreq Text Frequency of stream monitoring

C3_4a_StreamMonFreqUnit

s Text Units for frequency

C3_4_CBI Yes/No Is question C3

- 4 CBI?B

- 10 PWMSystemSurfaceWaterOutfall (C3

- 4, Permit Outfalls)

FieldName FieldType FieldDescription

ProjPWMSystemID Long Integer Unique ID for Proj + system combination

C3_4a_NPDES Text NPDES permit number

C3_4b_OutfallNumber Text Number given to outfall by operator

C3_4b_Treatment Text Code associated with selected treatment (None, RipRap, Atom, etc.)

C3_4b_Discharge Double Flowrate or volume discharged through outfall

C3_4b_DischargeUnits Text Flowrate or volume units

C3_4b_DischFreq Text Frequency of discharge (continuous, intermittent or emergency)

C3_4b_IntDays Long Integer Number of days of intermittent discharge in 2 008

C3_4b_EmerDays Long Integer Number of days of emergency discharge in 2008

PWMSystemPOTW (C3

- 5 POTW)

FieldName FieldType FieldDescription

ProjPWMSystemID Long Integer Unique ID for Proj + system combination

POTWID AutoNumber Sequential ID for POTW discharge within a system

C3_5a_FacName Text POTW/PrOTW/Facility Name

C3_5a_DischDest Text Third party destination of discharge water

C3_5a_PrimaryContact Text Primary contact name

C3_5a_Address Text Facility address

C3_5a_City Text Facility city

C3_5a_State Text Facility state

C3_5a_ZIP Text Facility ZIP

C3_5a_Phone Text Telephone number

C3_5b_AgreementAtt Yes/No Is a copy of the current permit or discharge agreement attached?

C3_5_CBI Yes/No Is question C3

- 5 CBI?

PWMSystemLandApp (C3

- 6 Land Application)

FieldName FieldType FieldDescription

ProjPWMSystemID Long Integer Unique ID for Proj + system combination

LandAppID AutoNumber Sequential ID for each land applicatino within a system

C3_6a_LandAppArea Long Integer Area of land used for land application (acres)

C3_6b_Criteria Text Criteria on the produced water for this land application

C3_6c_AboveGround Yes/No Is the land application/irrigation above

- ground?

C3_6c_SDI Yes/No Is the land application/irrigation sub

- surface drip (SDI)?

C3_6c_Other Yes/No Is the land application/irrigation another type?

C3_6c_OtherDesc Text Description of other

C3_6d_Frequency Text Frequency of application

C3_6d_Months Text Months that the land application occurred in 2008

C3_6d_NumDays Text Number of days applied in 2008B

- 11 C3_6_CBI Yes/No Is question C3

- 6 CBI?

PWMSystemTreatment (C3

- 8 Treatment Information)

FieldName FieldType FieldDescription

ProjPWMSystemID Long Integer Unique ID for Proj + system combination

PWMSystemTreatmentID AutoNumber Code of treatment units for each destination within a system

C3_8_TreatType Text Treatment type

C3_8_OtherDesc Text Description of other

C3_8_QualData Yes/No Is water quality data for the produced water entering and/or leaving

this treatment unit?

C3_8_CBI Yes/No Is question C3

- 8 CBI?

SedimentationPond (C3

- 9)

FieldName FieldType FieldDescription

ProjPWMSystem Long Integer Unique ID for Proj + system combination

SedimentationPo AutoNumber Sequential ID for each pond within the system

C3_9_Design Double Design capacity (acre

- feet)

C3_9_Volume Double Volume of produced water into

C3_9_VolUnits Text Units of volume

C3_9_SurfaceAr Double Surface area (acres)

C3_9_Liner Yes/No Is a liner used?

C3_9_LinerType Text Type of liner

C3_9_Thickness Double Thickness of the liner

C3_9_Thickness Text Units of thickness

C3_9_Chemicals Text Chemicals added

C3_9_CapCost Double Capital cost of sedimentation pond (dollars)

C3_9_CapCostYe Text Year of capital costs

C3_9_InitialCost Double Initial bonding costs (dollars)

C3_9_InitialCost Text Year of initial costs

C3_9_2008 OandM Double 2008 Operating and maintenance cost of

SedimentationPondParameters (Water Quality Parameters for C3

- 9)

FieldName FieldType FieldDescription

ProjPWMSystem Long Integer Unique ID for Proj + system combination

SedimentationPo Long Integer Sequential ID for each pond within the system

C3_9_Parameter Text Parameter name

C3_9_RemEff Text Estimated removal efficiency

C3_9_Basis_Com Memo Basis/CommentsB

- 12 IonExchange (C3

- 10)

FieldName FieldType FieldDescription

ProjPWMSystem Long Integer Unique ID for Proj + system combination

IonExchangeID AutoNumber Sequential (unique ID) for each ion

C3_10_Design Long Integer Design capacity (acre

- feet)

C3_10_Volume Long Integer Volume of produced water into ion

C3_10_VolUnits Text Units of volume

C3_10_Resin Text Resin name/description

C3_10_RegenFreq Long Integer Average regeneration frequency

C3_10_RegenFre Text Units of average regeneration frequency

C3_10_AvgLife Long Integer Average resin life (years)

C3_10_Chemicals Text Chemicals added

C3_10_CapCost Long Integer Capital cost of ion exchange unit (dollars)

C3_10_2008Oan Long Integer 2008 Operating and maintenance cost

C3_10_PilotProj Yes/No Pilot project

C3_10_CBI Yes/No Is question C3

- 10 CBI?

IonExchangeParameters (Water Quality Parameters for C3

- 10)

FieldName FieldType FieldDescription

ProjPWMSystem Long Integer Unique ID for Proj + system combination

IonExchangeID Long Integer Discharge to land application question copy

C3_10_Paramet Text Parameter name

C3_10_RemEff Text Estimated removal efficiency

C3_10_Basis_Co Memo Basis/Comments

LowPressureFiltration (C3

- 11)

FieldName FieldType FieldDescription

C3_11_CleanFre Text Units of average cleaning frequency

ProjPWMSystem Long Integer Unique ID for Proj + system combination

LowPressureFilt AutoNumber Sequential ID for each filter within a system

C3_11_Design Double Design capacity (bbl/d)

C3_11_Volume Double Volume of produced water entering

C3_11_VolUnits Text Units of volume

C3_11_FilterType Text (fixed width) Type of filter

C3_11_OthFilter Text Description of other type of filter

C3_11_Vendor Text Vendor/Unit name

C3_11_Chemicals Text Chemicals added

C3_11_CleanFreq Double Average cleaning frequency

C3_11_CapCost Double Capital cost of filtration system (dollars)

C3_11_2008Oan Double 2008 Operating and maintenance cost ofB

- 13 C3_11_PilotProj Yes/No Pilot project

C3_11_CBI Yes/No Is question C3

- 11 CBI?

LowPressureFiltrationParameters (Water Quality Parameters for C3

- 11)

FieldName FieldType FieldDescription

ProjPWMSystem Long Integer Unique ID for Proj + system combination

LowPressureFilt Long Integer Sequential ID for each filter within a system

C3_11_Paramet Text Parameter name

C3_11_RemEff Text Estimated removal efficiency

C3_11_Basis_Co Memo Basis/Comments

HighPressureFiltration (C3

- 12)

FieldName FieldType FieldDescription

ProjPWMSystem Long Integer Unique ID for Proj + system combination

HighPressureFilt AutoNumber Sequential number for each filter within a system

C3_12_Design Double Design capacity (bbl/d)

C3_12_Volume Double Volume of produced water entering

C3_12_VolUnits Text Units of volume

C3_12_FilterType Text (fixed width) Type of filter

C3_12_OthFilter Text Description of other type of filter

C3_12_Vendor Text Vendor/Unit name

C3_12_CleanFre Text Units of average cleaning frequency

C3_12_MemLife Double Membrane life (years)

C3_12_CleanFreq Double Average cleaning frequency

C3_12_2008Oan Double 2008 Operating and maintenance cost of

C3_12_CapCost Double Capital cost of filtration system (dollars)

C3_12_PilotProj Yes/No Pilot project

C3_12_CBI Yes/No Is question C3

- 12 CBI?

HighPressureFiltrationParameters (Water Quality Parameters for C3

- 12)

FieldName FieldType FieldDescription

ProjPWMSystem Long Integer Unique ID for Proj + system combination

C3_12_Basis_Co Memo Basis/Comments

C3_12_RemEff Text Estimated removal efficiency

HighPressureFilt Long Integer Sequential number for each filter within a

C3_12_Paramet Text Parameter nameB

- 14 TreatmentNotSpecified (C3

- 13)

FieldName FieldType FieldDescription

ProjPWMSystem Long Integer Unique ID for Proj + system combination

TreatNotSpecifie AutoNumber Sequential number for each filter

C3_13_Design Double Design capacity (bbl/d)

C3_13_Volume Double Volume of produced water entering

C3_13_VolUnits Text Units of volume

C3_13_TrtDesc Memo Description of treatment system

C3_13_Vendor Text Vendor/Unit name

C3_13_Chemicals Text Types of che micals used with this system

C3_13_ChemAm Text Amounts of chemicals used

C3_13_RegenFreq Double Average regeneration/cleaning frequency

C3_13_RegenFre Text Units of average regeneration/cleaning

C3_13_CapCost Double Capital cost of filtration system (dollars)

C3_13_2008Oan dM Double 2008 Op erating and maintenance cost

C3_13_PilotProj Yes/No Pilot project

C3_13_CBI Yes/No Is question C3

- 13 CBI?

TreatmentNotSpecifiedParameters (Water Quality Parameters for C3

- 13)

FieldName FieldType FieldDescription

ProjPWMSystem Long Integer Unique ID for Proj + system combination

TreatNotSpecifie Long Integer Sequential number for each filter within a

C3_13_Paramet Text Parameter name

C3_13_Removal Text Estimated removal efficiency

C3_13_Basis_Co Memo Basis/Comments

Analy t icalData (Part C, Section 4)

FieldName FieldType FieldDescription

ProjPWMSystem Long Integer Unique ID for Proj + system combination

C4_1_Pollutant Text Pollutant

C4_1_SampleTy Text Sample type (grab/composite)

C4_1_Location Text Location

C4_1_SamplingD Date/Time Sampling date

C4_1_Value Single Measured value (mg/L)

C4_1_Method Text Analytical method

C4_1_FlowRate Single Flow rate (gpm)

C4_1_PermitLimit Single Permit limit (mg/L)B

- 15 WaterQualityData (Part C, Section 4)

FieldName FieldType FieldDescription

ProjPWMSystem Long Integer Unique ID for Proj + system combination

C4_1DataSubmit Yes/No Was own data submitted as attachment ?

C4_1_CBI Yes/No Is question C4

- 1 CBI?

C4_2a_WET Yes/No Performed any whole effluent toxicity

C4_2b_WETInfo Memo Information on the WET testing conducted

C4_2c_ToxExcee Yes/No Has toxicity ever exceeded permit limits?

C4_2d_Study Yes/No Was a TIE, TRE or other study performed to

C4_2d_StudyCost Long Integer 2008 Annual Costs for TIE and TRI ($)

C4_2e_ToxAttac Yes/No Is a copy of the study attached?

C4_2e_ToxIssue Memo Description of the cause of the toxicity

C4_2_CBI Yes/No Is question C4

- 2 CBI?

Comments (Part C, C4

- 3)

FieldName FieldType FieldDescription

OperatorID Integer Operator Identification Number

ComCBI Yes/No Is this comment CBI?

Question Text Question Number

Comment Memo Comment

CommentID AutoNumber Sequential Comment Number

Flags (Added during survey review. See Appendix C for details)

FieldName FieldType FieldDescription

FieldName Text Name of field that stores the value

Issue Memo This field was added to align with Form B

Comment Memo This will hold range or actual value or other changes from the survey

QuestionInfo Text Question information

TableName Text Name of table that stores the value

OperatorID Long Integer Operator ID

ProjPWMSystem Long Integer Unique ID for Proj + system combination

FlagID AutoNumber Unique ID for flag record

FlagType Text Indicates the kind of flag or if a comment.

### APPENDIX C

I NSTRUCTIONS FOR REVIEW AND CODING OF THE

TECHNICAL PORTIONS OF THE CBM DETAILED QUESTIONNAIRE

Parts A and C

1. I NTRODUCTION

ERG ’s technical staff is responsible for the review, coding, and data entry for Part A (CBM Projects Selected for Questi onnaire) and Part C (Produced Water Management Information) , which are the technical portions of the CBM Detailed Questionnaire (DQ)

. These instructions do not include procedures for tracking non

- respondents. The DQ distribution and response receipt was c ompleted under a separate EPA contract.

This document describes the procedures that the ERG technical staff will use to complete

the review of the technical portions of the questionnaire an d code the responses to improve consistency and aid in questionna ire analysis

. Parts A and C information will be

entered into the technical questionnaire database developed by the ERG Team.

Also u nder this contract, ERG economic staff is responsible for reviewing, coding, and data entry for Part B (Project

- level Fina ncial Information). ERG economic staff will follow separate procedures for reviewing survey responses and develop ing a separate
database to house the economic information

.

T he ERG Team will handle all DQs as C onfidential B usiness I nformation (CBI) u ntil the CBI status of the DQ has been confirmed by the review process

.

2. G ENERAL S URVEY T RACKING AND D OCUMENTATION I NSTRUCTIONS

ERG will follow the steps listed below to track the survey review process:

1. Enter survey into ERG’s CBM record index database by following the procedures

in ERG’s CBM Project File Management Plan

. Each questionnaire will be assigned a unique DCN and any attachments received with the questionnaire will be noted with the suffix A# after the DCN (e.g. attachment 1 of DCN 004 will be DCN004.A1). ERG received a working copy of each survey (noted as DCNXXX.C2), which will be used to complete the survey review.

2. Review the survey following the procedures in Section 3 of this document. Survey reviewers will mark any changes on the surv ey review copy in RED INK

.

3. Document all changes to the survey on Form B (discussed in Section 2.1).4. Document the review of the survey in the CBM Survey Tracking system (discussed in Section 2.2).

5. Upload or scan any supporting data included with the ques tionnaire. For example, ERG will scan or data enter any analytical data included with the questionnaire. Detailed procedures for this step are included in Instructions for Data Entry of the CBM Detailed Questionnaire.

2.1 Review Form B

The CBM Detailed Quest ionnaire Submission Review Form B 1 , or Form B, is provided

in Figure 2

- 1 . ERG will use Form B to document changes that are made on the questionnaire by the technical reviewer during the check for completeness, general survey coding, and question

- by

- questi on review (Section 3) . Upon completion, the technical reviewer will provide Form B with the marked questionnaire for data entry.

Form B: Coalbed Methane Detailed Questionnaire Submission Review Form

Operator Name: Operator ID #: This document contains CBI:

Yes

No

Part and Question Issue Resolution

Figure 2

- 1. Form B

1 Form A is the contact form which was used by EPA’s previous contractor, PG Environmental, to

document contact with th e operator. ERG will not contact any facility unless instructed by the EPA WAM. ERG will write an email or memorandum to EPA describing why contacting the operator is necessary and including a description of the items that were not provided, recommendation s for items to be discussed with the facility, and other data sources investigated to obtain the information. After receiving approval for the contact, ERG will use Form A to document all topics discussed with the operator.2.2 CBM Survey Review Tracking System

Figure 2

- 2 illustrates the form that will be used by ERG staff to document the review of the technical portions of the questionnaire. The form is part of ERG’s questionnaire review tracking database. The ERG reviewer will use the top section of the form to document the various stages of review (first review, second revi ew, data entry) and whether there is additional information contained in the survey that will need to be either scanned or uploaded during data entry. For example, if the operator provided an electronic spreadsheet listing all the wells, ERG will upload th e excel file to the database directly rather than hand entering all the well information. If the operator included a produced water management system diagram, ERG will scan the diagram so that it is available electronically during the technical questionnai re database analysis stage. The bottom section of the form documents that the reviewer completed the quality assurance

checks listed in Section 3.Figure 2

- 2. Technical Review Completion Checklist3. D ETAILED Q UESTIONNAIRE R EVIEW I NSTRUCTIONS

This section lists the specific steps the reviewer should complete for each questionnaire.

3.1 Review for Completeness

Table 2

- 1 lists general completeness checks to be performed for each survey. Unless specified in the table, these general changes do not need to be ad ded to Form B

.

For surveys previously completed by PG Environmental, ERG will ensure these checks have been conducted and the appropriate changes have been marked on the survey review hardcopy. Additionally, ERG will review the completed contact form

, Fo rm A

, and Form B provided by PG Environmental to ensure appropriate information has been translated onto the survey review hardcopy.

Table 3

- 1

. Completeness Review Checklist

Topic Explanation Code/Review Ma rking Operator ID Check that the Operator ID is on every page. Note that this field was pre

- populated and should be complete. However, we want to add the ID in case pages get lost or mixed between surveys. Add OID on every page.

Check each

page Check t hat each page of the survey is completed properly. Place an ‘X’ at the top of any page that does not have

information that needs to be data

entered.

CBI Check to see if the CBI box on Page iii is checked, indicating the entire survey is CBI. If the box is checked, circle or highlight to make indication obvious to data entry staff.
If the overall CBI box is not checked, check cover

letter and comments pages to determine if the respondent has claimed the entire survey or any particular section or questi ons CBI. Mark CBI boxes to match any

indications in cover letter. Circle or highlight individual CBI boxes that are checked yes. Mark changes to CBI boxes in Form B. Review CBI check boxes for individual questions. Circle or highlight individual CBI

boxe s that are checked yes.

Comments Respondents may add notes or comments throughout the survey rather than on the comments

pages. Circle any comments in the survey, add in the question number on the corresponding comment summary sheet (either question A1

- 4 or C4

- 3), and write

“DE

– Obtain comment from main question page.” The data entry staff will refer back to the question to obtain the comment

for the database. Check the comments tables (QA1

- 4 and QC4

- 3) to

make sure that each comment is associated with a specific q uestion number

. Add the question number to QA1

- 4 or QC4

- 3 as needed. You may enter ‘GEN’ for the question number for a general comment. Read through all respondent comments to see if they impact the answers provided for any of the Make changes in responses as

needed to reflect comments andTopic Explanation Code/Review Ma rking question s add the flags shown in Tables 2

- 2

and 2

- 3 as appropriate. Document changes on Form B.

3.2 Conduct General Coding for Responses

Tables 2

- 2 and 2

- 3 list standard coding procedures reviewers shoul d use for coding the

survey. Table 2

- 2 provides codes that will be used to mark specific responses in the DQ

. For these responses, strikeout the original response and enter the code on the survey

. Table 2

- 3 show s data flag codes that are used to code valu es that are provided in ranges

. M ark any required flags from Table 2

- 3 on Form B in addition to entering it on the survey using red ink.

Table 3

- 2. Completeness Review Codes

Topic Explanation Code/Review Marking Illegible

response Respondent has illeg ible response. Cross out and write in

- 666

Unknown

response Respondent has written in ‘unknown’. Cross out and w rite in

- 777

NA Respondent has written in ‘NA’. Cross out and w rite in

- 888

Blank Respondent has left required response blank. Cross out and write in

- 999

. Blank Response is not required. Leave blank.

Table 3

- 3 . Data Flag Codes

Topic Explanation Code/Review Marking

Estimates Respondents may indicate that the number is an approximation or estimation. Cross out approximation terms or

charac ters. Enter data flag ‘EST’

under the Form B Issue. Under Form B Resolution, enter the original response. Ranges Respondents may provide data in ranges. Cross out the range and enter the midpoint of the range. Enter the data flag ‘MID’ under the Form B

Is sue. Under Form B Resolution, enter the original

range Minimum or

maximum

values Respondents may enter minimum or maximum values using < and > for numeric entries. Circle the number and write > or < on Form B for that question. For example, if responden t enters <20,000, circle the 20,000 and

write < under the Form B Issue

and enter the Resolution3.3 Question

- by

- Question Review of Part A

The steps for reviewing Part A responses are listed in Table 3

- 4

. Mark changes on the

survey review hardcopy and document the changes on Form B. If the respondent has provided a long list of wells (typically more than 25) in hardcopy or has provided a list in electronic spreadsheet format, check the boxes on the survey tracking form to note that there is additional data for scanning or uploading.

Table 3

- 4 . Part A

Question Check Action I f Check Does Not Pass

A1

- 1. Yes or No is checked. Check if A1

- 2 is pre

- populated with information from the screener. If so,

check Yes.

A1

- 2. I f ‘YES’ is checked for A1

- 1, A1

- 2 is

pre

- populated with information from

the screener

. Otherwise, Blank. None.

A ll projects on Table A

- 1 have a corresponding Table A

- 2. Add reviewer comment on Form B on inconsistency.

Project IDs listed at the top of each

Table A

- 2 match the Table A

- 1 IDs. Reconcile the Project IDs between the tables. Add comment if Project IDs

cannot be reconciled.

N umber of wells on Table A

- 2 = N umber of wells on Table A

- 1. Add reviewer comment on Form B on inconsistency.

A1

- 3. If ‘NO’ is checked for A1

- 1, A1

- 3

contains list of wells in Table A

- 2. These respondents need to create a unique Project ID. If list of wells is not provided, add

reviewer comment. If Project ID is missing, generate a unique ID for each project (e.g., EPAProject_1...) Check the tracking form if there is a list

of wells that should be scanned or uploaded.

A1

- 4. See Section 3 .1, Table 3

- 1 Comments,

above.

Certification

Statement C ertificat ion statement is completed, signed and dated

. Make a note in Form B.

3.4 Question

- by

- Question Review of Par t C

The steps for reviewing Part C are in the following subsections.

3.4.1 Part C Section 1

Section C 1 should contain a contact and contact information for the person responsible for the engineering section.

If there is no contact information, but a contact is provided for Part B, enter ‘Part B’ for the contact name. If there is no Part B contact information, enter ‘Mailing List Contact

. ’3.4.2 Part C Section 2

This section contains the PWMS general information. During the review of this Section,

ERG staff will co mplete the checks listed in Table 3

- 5

.

Table 3

- 5

. Part C Section 2 Review Checks

Question Check Action If Check Does Not Pass

C2

- 1 Check that all information requested

in C2

- 1 is shown on diagram or

described in the narrative. Add reviewer comments on Fo rm B identifying inconsistency. Check the tracking form if there is a diagram that

should be scanned for reference.

C2

- 2 Check that all information is complete. Use Table 3

- 2 completeness codes.

C2

- 3 Check that a flow from the wells was provided. This should be for wells from project listed at top of page. If provided on diagram, input data from diagram. If not provided, Use

Table 3

- 2 completeness codes. Check that the units and type of flow (average daily or total) agree

. C hange the type of flow checked to

ag ree with units. For example, gallons per day should have average daily

flow rate checked; gallons or barrels

should have total volume checked.

C2

- 4 Check that all information is complete. Use Table 3

- 2 completeness codes. For multiple projects entering one PWMS, check that the sum of percentages in C2

- 4a from each project using this PWMS is less than or equal to 100%. The percent in C2

- 4a should a percentage of the volume reported in C2

- 3b. 100% means the

PWMS is dedicated to the project

identified at the top of the page. Note that a PWMS may serve more than

one projects for this operator or may treat water from a third party (<100%). Add reviewer comments on Form B identifying inconsistency.

C2

- 5 Check that all information is complete. Use Table 3

- 2 completeness codes.

C2

- 6 Check that the year cost incurred is complete if a cost is provided. Use Table 3

- 2 completeness codes.

C2

- 7 Check that all information is complete. Use Table 3

- 2 completeness codes.

C2

- 8 Check the volume of water reported in

C2

- 8a plus C2

- 8 d is less than or equal

to the volume reported in C2

- 3a. Add reviewer comments on Form B identifying inconsistency.

Check that the year cost incurred is complete if a cost is provided. Use Table 3

- 2 completeness codes.

Check that units are provided fo r d.i

and d.iv. Use Table 3

- 2 completeness codes.

C2

- 9 Check that units are provided for all

entries. Use Table 3

- 2 completeness codes.

Check that the difference of C2

- 9a and

C2

- 9b is approximate to the total undeveloped area (C2

- 9c). Add reviewer comment s on Form B identifying inconsistency.

C2

- 10 Yes or No is checked. If responses provided to C2

- 11 and

and C2

- 12, check Yes. Otherwise,

check No.Question Check Action If Check Does Not Pass

C2

- 11 Check that there is a response if C2

- 10 is marked yes. Use Table 3

- 2 completeness codes.

C2

- 12 Check that there is a response if C2

- 10 is marked yes. Use Table 3

- 2 completeness codes.

C2

- 13 Yes or No is checked. If response provided for C2

- 14, check Yes. Otherwise, check No.

C2

- 14 Check if any additional studies were added to comments and if so, write in information on p.C

- 12 or write note to

include studies from comments section

and mark the studies in the comments section so data entry staff can easily

find. None.3.4.3 Part C Section 3

This section contains the detailed Produced Water Management System ( PWMS )

information. E RG staff will perform the checks listed in Table

.

Table 2

- 6 . Part C Section 3 Review Checks

Question Check Action If Check Does Not Pass

Part C

- Sections 2, 3,

and 4 Check that the Operator ID, Project ID,

and PWMS identifi er are on every

page. If Operator ID or Project ID is blank, fill in IDs based on Part A Project IDs.

If the PWMS identifier is blank, the reviewer may assign PWMS ID(s) (PWMS_EPA1, PWMS_EPA2...).

C3

- 1 Check that at least one destination is

checked in the fir st row. Add reviewer comments on Form B identifying inconsistency.

Check that C3

- 4, C3

- 5 and C3

- 6 are completed if discharge to surface water, POTW, or land application are

checked. Use Table 3

- 2 completeness codes.

C3

- 2 Check that a copy of C3

- 2 was

submit ted for each destination checked

in C3

- 1

. Add reviewer comments on Form B identifying inconsistency.

Check that the number of copies listed at the top matches the number of copies

submitted

. Add reviewer comments on Form B identifying inconsistency.

Ch eck that units were provided for the water volume and maximum capacity. Use Table 3

- 2 completeness codes.

Check that the sum of % in Capital

Costs and sum of % in O&M Costs for

all destinations for this PWMS equals

100%. Add reviewer comments on Form B identifying inconsistency.

C3

- 3 Check that the number of copies listed at the top matches the number of copies

submitted. Add reviewer comments on Form B identifying inconsistency.

Check that units were provided for the water volume and frequency of

remova l. Use Table 3

- 2 completeness codes.

C3

- 4 Check that the number of copies listed at the top matches the number of copies submitted (check this for both p.C

- 16

and C

- 17) Add reviewer comments on Form B identifying inconsistency.

Check that this question has been completed if surface water discharge

was checked in C3

- 1. Add reviewer comments on Form B identifying inconsistency..

Check that units are provided for all flows or frequencies provided. Use Table 3

- 2 completeness codes.

Check whether the operator checked that a permit was attached. If a permit was attached, mark the tracking database so the permit is

scanned for future use.

C3

- 5 Check that a copy of C3

- 5 was completed if discharge to POTW was

checked in C3

- 1. Add reviewer comments on Form B identifyi ng inconsistency.Question Check Action If Check Does Not Pass Check that the number of copies listed at the top matches the number of copies

submitted and that all information is complete. Add reviewer comments on Form B identifying inconsistency.

C3

- 6 Check that this question has been completed if d ischarge to land application was checked in C3

- 1. Add reviewer comments on Form B identifying inconsistency.

Check that the number of copies listed at the top matches the number of copies

submitted and that all information is complete. Add reviewer comme nts on Form B identifying inconsistency.

C3

- 7 If yes is checked, verify that respondent provided information on

treatment in C3

- 8

. None.

C3

- 8 Check that there is a corresponding detailed question completed for any

treatment units checked. Add reviewer comments o n Form B identifying inconsistency.

C3

- 9 Check that the number of copies listed at the top matches the number of copies

submitted and that all information is complete. Check that units are supplied for any frequencies requested. Add reviewer comments on Form B identifying inconsistency.

Use Table 3

- 2 completeness codes. C3

- 10

C3

- 11

C3

- 12

C3

- 13 Check that the number of copies listed at the top matches the number of copies

submitted and that all information is complete. Add reviewer comments on Form B identifying incons istency.

Check that units are supplied for any frequencies requested. Use Table 3

- 2 completeness codes.

Read description to see if this unit can

be classified under one of the other

treatment types. Make changes as appropriate. None.

3.4.4 Part C Sectio n 4

This section contains the water quality data. ERG staff perform the checks listed in

Table

.

Table 2

- 7 . Part C Section 3 Review Checks

Question Check Action If Check Does Not Pass

C4

- 1 Check that the number of copies listed at the top of Table C

- 3 matches the number of copies submitted. Add reviewer comments on Form B identifying inconsistency.

C4

- 2 Check that all information is complete. Use Table 3

- 2 completeness codes.
Analytical

Data Check whether the operator indicated

tha t they attached analytical data was

attached. Mark the tracking database to note that analytical data needs to be scanned or uploaded.

### APPENDIX D

INSTRUCTIONS FOR DATA ENTRY OF THE CBM DETAILED QUESTIONNAIRE

Parts A and C

1. I NTRODUCTION

ERG ’s technical staff is responsible for the review, coding, and data entry for Part A (CBM Projects Selected for Questionnaire ) and Part C (Produced Wat er Management Information) of the CB M Detailed Questionnaire (DQ). Reviewed copies of Parts A and C of the DQ will be data entered into the engineering database . This document describes the procedures that the ERG data entry (DE) staff will use to complete data entry of Parts A and C of the DQ. To facilitate data entry, all markings and coding will be completed by the technical survey reviewer prior to data entry. Procedures for review and coding of the DQ are laid out in Instructions for Review and Codin g of the CBM Detailed Questionnaire. The database structure is described in the database dictionary.

The ERG Team will handle all DQs as Confidential Business Information (CBI) until the CBI status of the DQ has been confirmed by the review process.

2. G ENER AL D ATA E NTRY I NSTRUCTIONS

Data entry staff will receive a questionnaire package from the technical reviewer containing the following:

1) Hardcopy questionnaire that has been marked in red ink by the reviewer ; and 2) Separate page(s) containing reviewer comm ents and changes (Form B)

Questionnaire r esponses and reviewer comments from Form B will be data entered into the engineering database. The engineering database was developed with a series of forms that will be used to ease data entry . The forms follow t he logic of the DQ.

The main operators form contains the operator identification information. The DE staff will navigate to other parts of the questionnaire using the main Operators form to ensure that the Operator ID, Project ID, and PWMS ID are linked together properly. The identification numbers are used to aid data entry by:

**•** Filtering the form's records so that only projects and systems associated with the operator are available; and

**•** Pre

- populating the identification numbers on each part of the

ques tionnaire.DE staff will use the following steps to enter the questionnaire information into the

database:

1. Open engineering database and view the main switchboard.

2. Click the menu item that o pen s the Operators Form and complete part A general Operator i nformation and question C 1

- 1 Contact information

a. Enter comments provided by the operator in the response by selecting the Survey Comments button at the bottom of the form.

b. If survey respondent checks “universal CBI claim " (page iii), check the

appr opriate universal CBI checkbox, but do not check individual CBI checkboxes for each subsequent question . This will be done during data

verification.

3. Click Go to Projects to enter project info rmation from Part A.

a. From the Projects form, c lick Go to Project Wells w hich will open up a

table to enter well info rmation (Table A

- 2). Enter the well data.

b. If the number of project wells is significant and can be imported by other means, mark the survey review tracking database to indicate there is well information to upload (if not already done so by the reviewer) . Do not
manual ly enter the well information. For example, the respondent may have provided an electronic excel file which can be directly uploaded to

the database.

4. Click Go To Systems . From the main Systems Form, select the appropriate Project/PWMS scenario or identify new scenarios. After selecting the appropriate scenario, sele ct the relevant question button, which are identified by question number, to enter information from each question in Part C. Based on an operator’s CBM operations, not all questions on Part C of the DQ may apply . The reviewer will have coded all applicable answers.

a. If multiple Project/PWMS scenarios exist, close out of the question forms and select a new scenario from the main Systems Form . Ensure the proper IDs have been pre

- populated on subsequent question forms.

b. Use the navigation buttons at the bottom of the questio n forms to enter a

new record. For example, if multiple NPDES permits were provided for surface water discharge, use the n avigation buttons to add all the NPDES permit information.

5. Enter Form B comments using the Reviewer Comments/Flags button at the bottom of the main Systems Form.

6. Once the survey is completed, close out all forms and begin from the Operators

Form to enter information for the next survey.

7. Update the survey tracking database with the date data entry was completed. If a DE reviewer is identified, notify the DE reviewer that the survey is ready for

review.3. D ATA E NTRY R EVIEW I NSTRUCTIONS

ERG will review the entered data for 25 percent of the operators. An ERG technical staff member will use the same steps as above to navigate through the data entry forms and check each value entered against the hardcopy. The staff member will also check that all operator comm ents on the comment pages in the questionnaire and the

reviewer comments on Form B have been entered into the database.

If the reviewer finds any errors, she will correct the item in the database and document the change on the Data Entry Changes table in the database. The fields in the change table are shown below. The ERG WAM will monitor the da ta entry change table weekly and include updates on the changes required as part of the weekly questionnaire

status report.

Data Entry Changes

FieldName FieldTy pe FieldDescription

OID Text Operator Identification Number

Question Text The question number from the DQ

Change Date Date/Time Date the DE correction was made.

Description Memo Description of the changes made.

Reviewer Text Name of re viewerE

- 1 APPENDIX E

DATA QUALITY VERIFICATION

ERG will perform a data quality verification of the data entered into the engineering questionnaire database. The data quality verification will consist of several steps :

**•** Perform global updates to ensure consistency across the information for a single operator and across operators (e.g, update CBI indicators, standardize units) ;

**•** Obtain summary statistics for an individual questionnaire response and the

overall database to a ssess the reasonableness of the r esponse s ;

**•** Check the internal consistency of the responses to a ssess the reasonableness of the data provided from an operator ; and

**•** Check the completeness of the questionnaire at the operator level

.

The following sections provide information on the initial database queries that ERG will use to perform the data quality verification. ERG may add queries based on the results of the initial queries or by direction from the EPA WAM. A CBM technical team member will write each query in Microsoft ® Access and a seco nd team member will check that the query logic matches the intended purpose. The results of all queries will be delivered to EPA in a summary report along with the QA documentation. QA documentation will include the query developer name

and date of develo pment

, the purpose of the query, the query reviewer name and date of review,

and information on changes made to the original query based on review.

Global Updates

ERG will perform the global updates shown in Table E

- 1.

Table E

- 1 Global Database Updates

Query Type Database Fields Purpose and Steps Update CBI Indicators Ensure all CBI indicators are TRUE if the operator notes their whole questionnaire is CBI.

**•** If an operator checks that all information in the questionnaire is CBI (‘AllCBI’ = TRUE), then update all CBI fields in the database to TRUE. Update Free response unit fields (e.g,

operator can enter units of choice) Standardize units across operators.

**•** Create table listing all conversions. For example, operators may use the words barrel, barrels, bbl, or bbls to indicate barrels. These terms will be

standardized to bbl.

**•** Create new units field for each unit field in the dat abase to standardize the

units.

**•** Update the units field using the unit conversion table. NOTE: Be sure to only update units that match (e.g., do not update MGal to gallons).

**•** Create a new data field for each numeric entry with a free response unit.

**•** Update the new data field to the standard unit.E

- 2 Table E

- 1 Global Database Updates

Query Type Database Fields Purpose and Steps Update Numeric fields with free response

units Convert units to a standard set of units (e.g, gallons to barrels) using

conversion table

**•** Create conversion table.

**•** Create new data field with standard units in the title (e.g.C2

- 3WellsFlow

will have a related field C2

- 3WellsFlow_Bbl)

**•** Update new units fields with values convert ed to standard unit s.

Summary Statistics for Individual Questionnaire Response s and Overall Database

ERG will use queries to generate summary statistics for questions containing key pieces

of data as shown in Table E

- 2. ERG will use these queries to evaluate the reasonableness of the

responses by examining values that are close to the minimum and maximum values

. ERG will report these statistics to EPA and identify extreme values that appear to be inconsistent with

values reported by the majority of other respondents. For example, volumes reported in quantities that are orders of magnitude larger than others. (EPA is NOT requesting a statistical evaluation of outliers. Instead, this is a more informal technical review of th e data.) ERG will not eliminate responses from the database. The EPA WAM will determine the required follow

- up action.

Table E

- 2 Example Statistics to Check Reasonableness of Responses

Parameter Average Minimum Maximum Median Volume of produced water/number

of wells PWMS Capital Cost/Volume of produced water treated PWMS Operating Cost/Volume of produced water treated Capital Cost of Individual Component/Volume of produced

water treated Operating Cost of Individual Component/Volume of produced

water treated

PWMS

– Produced water management system

ERG will use queries to determine the discharge destination by CBM basin as shown in

Table E

- 3 . Basin information was not collected in the detailed questionnaire but is know n from the screener and statistical sampling plan. ERG will flag any operator IDs that are performing a discharge practice that is not standard practice for the basin and report these to EPA (e.g., surface discharge in San Juan basin). For these unu sual practices, ERG also will verify that the question responses match the schematics provided for question C2

- 1.

Table E

- 3 Basin/Discharge Practice Summary

Basin Number of Operators Using Practice

Surface Discharge POTW

or Third Land Application Underground Injection Evaporation

or Livestock Watering OtherE

- 3 Party Infiltration

Basin 1

Basin 2

ETC

Internal Consistency

ERG will check the items listed below to ensure consistency across responses provided by a single operator. Respondents were to complete one copy of Part C for each project/ produced water management system (PWMS) combination.

Water Balance Checks

1. For a given project, check:

a. Each copy of Section 2 for the project should contain the same flow r ate of volume of produced water from the wells;

b. The sum of the volume of water managed by the PWMS (from all copies of Section 2) should equal the volume of water produced by the wells for the project.

2. For a given PWMS

, the sum of the percentages of water from the project o each PWMS

should be 100.

3. For a given project/PWMS combination,

a. The sum of the pumped and piped water volumes should equal the amount of

water from the wells to the PWMS.

b. The sum of the volumes from each discharge option should equal th e volume entering the PWMS.

c. The sum of the volumes to each outfall for surface discharge should equal the total amount reported to surface discharge.

Cost Checks

1. For a given PWMS,

a. The sum of the percentages of capital cost for each discharge option should equal

100.

b. The sum of the percentages of operating cost for each discharge option should equal 100.

Completeness

During the survey review, ERG reviewers added the following codes to note

i n completeness:

**•** Required response is blank:

- 999

**•** Not kno wn, unknown response:

- 777

**•** I llegible responses :

- 666E

- 4 ERG will use these codes to determine the completeness of individual questions and an operator’s response. ERG will perform the following completeness checks:

1. The number projects listed in Part A equals the number of projects in Part C

.

2. Completeness of individual responses : For questions requesting produced water flow/volume or cost information, count the number of incomplete responses for the question number and the total number of expected resp onses.

3. Completeness for an operator : Count the number of incomplete responses and the total number of expected responses.