1 Frequently Asked Questions (FAQs) Regarding the EPA Coalbed Methane Screener Survey

1. General Questions

Do I have to fill out the survey?

Yes. The U.S. Environmental Protecti on Agency (EPA) is conducting this data

collection under the author ity of Section 308 of the Clean Water Act or CWA (Federal Water Pollution Control Act, 33 U.S.C. Section 1318). You must respond to this questionnaire within 30 days of receiving it. For more information, please see the instruction booklet provided with the questionnaire.

I received more than one screener survey , do I have to fill out all of them?

Yes, some establishments received more than one survey since according to our records, you operate in more than one basin and/or state. The cover letter that was included with your screener surveys will indicate the basins and states that our records show you oper ating in. If your establishment has expanded to additional basins or states please note t hat in Item F, Question 2 and if your establishment no longer operates in one of the basins or states named in the cover letter please note that in the Remarks section.

Why do I have to fill out the survey?

EPA is conducting this data collection under the authority of Section 308 of the CWA (Federal Water Pollution Cont rol Act, 33 U.S.C. Section 1318). You must respond to this questionnaire wit hin 30 days of receiving it. For more information, please see the instruction booklet provided with the questionnaire. EPA plans to use the “C oalbed Methane Extraction Sector Survey” to collect information on geograph ical and geologic differences in the characteristics of CBM produced wa ters, environmental data, current regulatory controls, and availability and a ffordability of treatment technology options.

I need more time to complete the screener

If you wish to request an ext ension, you must do so in writing within 30 days of receipt of this questionnaire. For more information, please see the instruction booklet provided with the questionnaire.

Where do I send the completed survey?

Keep a copy and mail the completed survey (electronic file on CD or hard copy) to:2 U.S. Environmental Protection Agency CBM Industry Screener c/o PG Environmental, LLC 570 Herndon Parkway

Suite 500 Herndon, VA 20170

How long do I have to complete the survey?

The due date is 30 days calculat ed from the date of receipt.

How long will it take to complete the survey?

EPA estimates an average of 5 hours per response to generate, maintain, retain, or provide information in the survey.

Do I have to answer all the questions?

Yes. You must complete all the questions as instructed. If the information for a question is not available or unknown , provide a comment in the Remarks section as the response to the question.

What if my response is larger than the space provided in the hard copy survey? (i.e., not enough rows or not enough space in a column)?

If you are using the hard copy survey , photocopy the question page(s) before writing on it and number the photocopi ed pages in the upper right hand corner. Insert copies in sequence behind the original.

Can I fill out a hard-copy survey rat her than the electronic screener survey?

Yes, however, EPA encourages you to us e the electronic format. The electronic format is designed to reduce the burden associated with completion of the survey – for example, changi ng one of your responses requires significantly less effort in the electronic version than in a hard copy form. The electronic survey also provides validati on options for you to assure that you are submitting a complete and accurate survey, which reduces the likelihood of follow-up communication by EPA to cl arify responses and/or correct errors.

If you would prefer to us e the hard copy you are fr ee to do so and you can just fill out the survey you received in the mail.3 How many sites have received this survey?

The screener survey will be sent to 290 owners and operators of CBM wells throughout the major producing basins in the U.S. These recipients have been identified in data collected by the st ates as the owner/operator of CBM

wells.

How will the screener survey results be used?

EPA will use the information collected in the survey to determine whether to initiate a rulemaking to potentially revise the ELGs for the Oil and Gas Extraction Point Source Category (40 CF R Part 435) to include limits for pollutants discharged in CBM produced wa ter. The screener collects only

information that EPA needs to select a r epresentative sample of the industry for the detailed survey.

What about submitting confidentia l business information (CBI)?

If you wish to protect the information from public disclosure, you may assert a claim of business confidentiality coveri ng all or part of the information you

submit. This should be done at the time the information is submitted.

You may claim as confidential all information included in the response to a question by stating so in the “Remarks” section of the screener survey. If a response is not marked as confidential, EPA assumes that the response is not confidential. Regulations governing the confidentiality of business

information are contained in 40 CFR Part 2, Subpart B.

What assurances do I have that CBI will be protected?

Regulations governing the handling of confidential business information are contained in 40 CFR Part 2, Subpart B. Please refer to the survey Instruction Guide (Part IV) for a summary of these regulations.

2. Electronic Screener Questions

What is the electronic screener?

The electronic screener is a version of the screener survey you received in the mail that was created using Micros oft Excel 2003. The electronic screener is compatible with Microsoft Excel 2003 and all newer versions of Microsoft

Excel.4 How is the electronic screener set up?

The electronic screener contains nine work sheets that are labeled by tabs at the bottom of the page. The electronic screener contains the instruction guide, the cover page, two user gui des for the worksheets, and five worksheets that contain the survey questions.

What should I do if nothing happens when I click on the electronic screener Excel navigation arrows?

If nothing happens when you click the arrows in the electronic screener you

will need to enable macros. If the security box appe ars upon opening the file, then you should click “enable macros.” If the security box does not appear upon opening the file, you wil l need to change your security settings to allow you to enable macros.

How to enable macros if you are using Excel 2003 :

If you have opened the electronic survey and the "Security Warning" box did not appear then you must change the secu rity setting by doing the following:

1. Select from the Excel menu Tools --> Macro --> Security 2. In the Security box select "Medium Security" and press Ok 3. Close the survey and then open it again 4. The "Security Warning" box should now appear and click "Enable

Macros"

How to enable macros if you are using Excel 2007 :

If upon opening the file and clicking on an arrow a macro error box appears, then you must do the following:

1. Select “Office” button --> “Excel Options” button (bottom of menu) -->

“Trust Center” link in left column --> “Trust Center Settings” button --> “Macro Settings” link in left column

2. Select radio button beside “Enab le all macros” and click “Ok”

3. Close the file 4. A message will prompt you to save the file 5. Save the file and then reopen the file

If you are still having problems with the macros buttons, use the labeled

worksheet tabs at the bottom of the su rvey to move from one worksheet to

another.5 How do I navigate from one worksheet to another and how do I navigate within

the worksheet?

This electronic survey uses macros butt ons in the form of arrows to move

from one worksheet to another . It is important to not e that these arrows only take you to another worksheet. Within that worksheet you will have to move to the appropriate cell that corresponds to the question you are referring to. If you are having difficulty enabling macros on your computer, you can use the

labeled worksheet tabs at the bottom of the surv ey to move from one

worksheet to another. Within a workshee t, you can move to the neighboring cell to the right by hitting the Tab key. Some cells in this survey are locked and therefore cannot be changed or manipulated by the user.

How many projects can I put on the electronic screener?

Each electronic survey has enough spaces for 25 projects. If you have more than 25 projects please download and subm it an additional electronic survey.

What if my response is larger than the space provided in t he electronic screener (i.e., not enough rows or not enough space in a column)?

The electronic screener survey will allow you to generate 25 project response fields. If you need more than 25 projec t response fields, then make another electronic copy of the e- survey and label it “Copy # of # .”

I’m having problems with the worksheet containing Item A-C

Worksheet Section Description

Item A The hardcopy of the screener surv ey that you received in the mail contained an establishment name in the mailing address label. You

should have also filled in this inform ation in the Address Label box on the Cover Page worksheet. This section asks you to confirm if the

establishment name on the address label was correct. The cell to the right of the question is a dropdown menu, so when you click on the box an arrow will appear to the right of t he box. If you click on the arrow a list will come up with the choices "Yes" or "No". If you select "Yes" the cell to the right will highlight blue meaning that you do not need to type in the establishment name. If you select "N o" the cell to the right will not highlight and you should type in the correct establishment name.

Item B Item B asks you to fill in a contact person in case we have any questions about your responses. Please fill in the Name, Street Address, City, State, Zip, Phone, and E-mail in the appropriate sections. Item A-C

Item C Item C asks if your establishment owned or operated any coalbed methane wells in 2008 only. The cell to the right of the question is a dropdown menu, so when you click on the box an arrow will appear to the right of the box. If you click on t he arrow a list will come up with the

choices "Yes" or "No". Please follow t he instructions to the right of the dropdown menu cell when you have selected the appropriate response.6 I’m having problems with the worksheet containing Item D-E

I’m having problems with the worksheet containing Item F: Project Information

Worksheet Column Description

Project Name

or Identifier The name and/or number of the coalbe d methane project. This name or identifier is automatically carried over into the Contact Information and Remarks worksheets. Edits to the “Project Name or Identifier” must be made in the Project Information worksheet.

Project

Location This column includes 2 cells, "Basin (e.g., Powder River)" and "State (2- letter abbreviation)." Please put the bas in that the specific project is located in and the state 2-letter abbreviation in their respective cells.

Please indicate a basin name that you use and other operators would recognize.

Did you buy or sell this project during 2008? This column consists of 2 cells, "Yes or No" and "If Yes, what month?". The first cell, "Yes or No" is a dr opdown menu. When you click on the cell, an arrow will appear to the right of the cell and when you click on the arrow the choices "Yes" and "No" will appear. When you select "Yes" the cell to the right will turn from blue to white indicating that you should answer the question "If Yes, what month? ". If you select "No" the cell to the right will remain blue indicating that you do not need to fill in the neighboring cell.

Number of

wells for this project in 2008 This should be the number of wells in the specific projec t identified in the “Project Name or Identifier” column for 2008 alone.

Combined gas

production

from wells in

2008 This should be the number of the comb ined (total) gas production from the wells for the specific project identifie d in the “Project Name or Identifier”

column for 2008 alone.

Units These cells are referring to the units used in the neighboring cell for the “Combined gas production from wells in 2008.” This column is made up of two cells, “Thousands of Cubic Feet (Mcf) or Other” and “If Other, enter reporting units.” The first cell, “Thousands of Cubic Feet or Other,” is a drop-down menu. When you click on the cell an arrow appears to the right of the cell. By clicking on the arrow you can select “Thousands of Cubic

Feet” or “Other.” The default unit is Thousands of Cubic Feet (Mcf) and automatically appears in all the cells in the column. If you are reporting your “Combined gas production from wells in 2008” in other units, please select "Other" and put the units you are using in the “If Other, enter reporting units” cell. Worksheet Section Description

Item D Item D includes two questions. The first question asks if the highest level of corporate ownership in 2008 was a small business. There is a table to the right with the common size standar ds that you should use to help you answer the question. The cell to the right of the question is a dropdown menu, so when you click on the box an arrow to the right of the box will appear. If you click on the arrow a list will come up with the choices "Yes" or "No" and you should then select the appropriate response. The second question below, asks you to give an approximate date for the availability of your 2008 fiscal year fi nancial data. Please be as specific as possible. Item D-E

Item E Item E asks you how many projects your establishment owned or operated. You will be asked to list these projects and provide more specific information on these projects in Item F.7 Worksheet Column Description

How did you

manage your

process water? This column consists of 8 cells, including “Discharge to surface water," ” Discharge to POTW,” “Land applicat ion,” “Underground injection,” “Evaporation/infiltration pond,” "Livestock/wildlife watering," "Trucked/transported off-site to a 3rd party", and "No water produced." The option "Discharge to POTW" is referring to any discharges to a publicly owned treatment works. The option "Land application" is referring to any discharges applied to land with or without crop production. Each cell is a drop-down menu. When you click on the cell, an arrow will appear to the right of the cell and when you click on the arrow an "X" will appear. Place an "X" under every method that you used to manage your process water. If you accidentally select an "X" from the drop-down menu, you must hit the Delete key (not the Backspace key) to clear the cell.

I’m having problems with the worksheet containing Item F: Contact Information

Worksheet Column Description

Project Name

or Identifier The project name or identifier is aut omatically filled in based on what was identified as the project name or identifier in the Project Information worksheet. This column is locked, so in order to edit the project name or identifier you must return to the project information worksheet and make

the edit there.

If this project

is selected

where should

we send the

second questionnaire? The cells in this column appear as drop-down menus. When you click on the cell an arrow will appear to the right of the cell. By clicking on the arrow you can select one of the thr ee choices. The choices are “To the same contact person identified in Ite m B,” “To the same person identified in the previous project,” and “Other (Please identify contact person).” If you select “Other (Please identify c ontact person),” the neighboring cell in the “Contact Information required?” column will appear highlighted with “Yes” in the cell. The neighboring cells in the “Name,” "Employer," “Street Address,” “City, State, Zip,” “P hone,” and “Email” columns will change from royal blue to white, allowing you to enter the contact person information for that project in those cells.

Contact

Information required? This cell is automatically filled in with “Yes” highlighted yellow, or “No” depending on your response to the question “If this project is selected where should we send the second questionnaire?” in the neighboring cell. Contact

Information

Name, Employer,

Street Address, City,

State, Zip, Phone, Email This information is required if the cell appears white. This information is not required if the cell appears royal blue.

I’m having problems with the works heet containing the Remarks section

Worksheet Column Description

Remarks Remarks This section should be used to clarify any survey responses in the Project Information and Contact Information worksheets, including identifying any confidential business information. Please identify the column and row you are referring to in your remarks.8 3. Item Specific Questions

3.1 Item C: Operating Status in 2008

I’m not sure whether we should be cons idered to own or operate CBM wells; we sold/acquired wells so we have only a few weeks/months of data

Even if you only owned or operated well s briefly in 2008, the answer should

be “Yes.”

I’m not sure we are the owner or operator. What does this mean?

The survey defines “owner or operator” as the owner or operator listed with state oil and gas commissions, e.g., in we ll drilling or production databases.

I operate wells where a portion of the gas from these wells is considered conventional (or another unconventional gas), not CBM. Do I answer “yes” to the question of owning or operating CBM wells?

If any of the wells are producing gas and/or water from coalbed strata, please answer “yes” to owning or operating CB M wells and continue with completing the survey.

In 2008, wells in my project(s) produced only water and no CBM. Do I answer “yes” to owning or operating CBM wells?

If these wells are dewatering a coalbed st ratum for the ultimate purpose of producing CBM, check “yes” to owning or operating CBM wells and continue with completing the survey.

In 2008, the wells in my projects were drilled but were not ye t producing either CBM or water. Do I answer “yes’ to owning or operating CBM wells?

If these wells are expected to pro duce CBM gas, please check “yes” to owning or operating CBM wells and c ontinue with completing the survey.

I only have a working interest in CBM wells. Should I answer yes to owning or operating CBM wells?

If you are the listed owner/operator of these wells in the state oil and gas commission databases, please answer “yes.” If you think a detailed questionnaire should go to another firm or firms, however, you can indicate this in Part F, Question 7. If you are (1) not sure of your status as the listed owner/operator, or (2) not the listed operator and/or you cannot answer the project-specific questions, please cont act the EPA helpline (1-800-764-4414 or cbmscreener@pgenv.com).9 I am a contract operator of CBM wells, and I do not own a working interest in any such wells. Should I answer yes to owning or operating CBM wells?

If you are the listed operator of those we lls, you should answer Yes, but if you if you have any concerns with answering the questions that follow, you can contact the EPA helpline (1-800-764-4414 or cbmscreener@pgenv.com) for

further assistance and instructions.

3.2 Item D: Business Size a nd Financial Data Availability

My firm is owned (in part or in whole) by another firm. Can my firm qualify as a

small business?

The firm might be able to qualify as a sm all business, but only if the firm has no affiliation with a large firm. If the owner firm is a large busi ness (even if it is a minority owner in some cases), the firm is considered affiliated with a large

firm and cannot claim to be a small busine ss. If you are not certain about your affiliation status, please contact the EPA helpline (1-800-764-4414 or cbmscreener@pgenv.com).

My firm is foreign-owned. If we meet the size standards, are we classified as a

small business?

Only in rare instances can a forei gn-owned firm meet the conditions for being a small business, since that firm must meet the size standards and also provide a significant contribution to the U.S. economy. If t he firm is foreignowned, you should be directed to check the box marked “no.”

3.3 Item E: Number of CBM Projects

I don’t understand what you mean by project.

A project in this survey is defined as a well, group of wells, lease, group of leases, or some other recognized unit t hat your establishment operates as an economic unit when making production decisions. If you still need assistance in defining project, please contac t the EPA helpline (1-800-764-4414 or cbmscreener@pgenv.com).

I commingle CBM with conventional gas in one or more of my projects. Do I include such projects in the count of projects?

Yes, and respond to the project-specific questions for any such projects.10 My project did not produce CBM gas in 2008 or produced only water in 2008. Do I include such projects in the count of projects?

Yes, and respond to the project-specific questions for any such projects.

3.4 Item F: CBM Project Information

What is the name or identifier that you use for this project?

The identifier for the project is a name or number that is familiar to the operator. If no identifie r exists, you should assign the identifiers A, B, C, etc.

I don’t know what basin my project is in or my project is not in a designated

basin.

If you are not certain how to designate a basin for your project, please contact the EPA helpline (1-800-764-4414 or cbmscreener@pgenv.com) and the helpline staff will assist you in identifying the region or basin name. Some key basin names include the Appalachian Basin, Illinois Basin, Black Warrior Basin, Cahaba Basin, Arkla Basin, Arkhoma Basin, An adarko Basin, Cherokee/Forest City Basin, San Juan Basin, Raton Basin, Uintah-Piceance Basin, Green River Basin, Wind River Basin, and Powder River Basin.

When you ask about the maximum number of CBM wells producing water or gas that were in a project, does this mean I should exclude any wells in the project that were producing conventional gas onl y? What about thos e that commingle CBM and conventional gas in the same wellbore?

Please exclude conventional gas-only wells, but do include all wells that commingle CBM and conventional gas within the same wellbore.

My project did not produce CBM gas dur ing 2008. How do I answer the questions on numbers of wells and production?

If the wells in your CBM project were dr illed but not yet in pr oduction (water or gas) in 2008, you can insert “0” in the box for the count of producing wells and mark 0 for your production. If the wells in your project were producing only water, put the count of t hose wells producing water in the box requesting the count of producing wells, and ma rk “0” for your production.11 I sold or acquired a project or part of a project during 2008. How do I answer the production question?

Indicate what month in 2008 the project or part of the project was sold and include all production in 2008 up to the date the project or part of the project

was sold.

I initiated or shut-in production on a project midway through 2008. How do I answer the production question?

You should not modify your response , include all production in 2008 on a project up to the shut-in or stop in production.

When you ask about the combined gas production, do I include conventional gas and CBM if the project produces both?

Do not include any conventional gas from conventional gas-only wells (estimates are acceptable) , but do include all gas fr om wells that commingle CBM and conventional gas within the same wellbore.

What do you mean by other reporting units?

If you have a very large project and wish to provide numbers on a million cubic feet (MMcf) or billion cubic feet (Bcf) basis, for example, simply report

the number and note that it is in MMcf or Bcf. Alter natively, if you wish to report in millions of British thermal unit BTUs (MMBtus), you are free to choose this unit for reporting.

I don’t think my produced water management method is reflected in the list of options. How should I respond?

If you do not think your management method is reflected, please use the remarks section at the end of the questi onnaire to describe your method in

detail.

4. Definitions of Selected Key Terms

Clean Water Act – Federal legislation enacted by Congress to “restore and maintain the chemical, physical, and biol ogical integrity of the Nation’s waters” (federal Water Pollution Control Act of 1972, as amended, 33 U.S.C. 1251 et seq.).
Coalbed Methane (CBM) – Natural gas found in coal seam reservoirs.
Coalbed Methane (CBM) Project – A CBM project comprises a well, group of wells, lease, group of leases, or recognized unit which you operate as an economic unit when making production decisions. The well or wells may be associated with one or more water managem ent practices (that is, the project12 should be defined on the bases of gas pr oduction economics, not necessarily on the basis of water management system). If a project operates as a unit in which you are not the sole operator, pl ease include information only for that portion of a unit for which you actively operate. EPA understands that the concept of a project is va riable over time, so the well or wells included as a part of a project should be those that bes t defined the project as it existed in

2008.
Discharge – The discernible, conf ined, and discrete conveyance of pollutants to : (1) United States surface waters such as rivers, lakes, and oceans (“direct discharge”), or (2) a publicly owned, privately owned, federally owned, combined, or other treatment works (“i ndirect discharge”). See 40 CFR 122.2.

Evaporation – The process by which water or other liquid becomes a gas. Water from land areas, bodies or water, and all other moist surfaces is absorbed into the atmosphere as a vapor.

Fiscal Year – A 12 month period over which a company budgets its spending. A fiscal year does not always begin in J anuary and end in December; it may run over any period of 12 months.

Infiltration – The process by which water penetrates into soil from the ground

surface.
Injection Well (Deep or Shallow Well Injection) – Any bored, drilled, or driven shaft or a dug hole, improved sinkhole, or a subsurface fluid distribution system where the depth is greater than t he largest surface dimension that is used to dispose of fluids under ground. See underground injection.

NAICS – NAICS is an economic classificati on system. Economic units that use like processes to produce goods or serv ices are grouped toget her. These units are assigned a code for identification purposes. US Census Bureau (http://www.census.gov /epcd/www/naics.html ). Common 6-digit NAICS in the CBM extraction industry include 211111, Crude Petroleum & Natural Gas Extraction; 213111, Drilling Oil and Ga s Wells; 213112 Support Activities for Oil and Gas; 212111, Bituminous Coal & Lignite Surface Mining; 212112, Bituminous Coal Underground Mining; 221210, Natural Gas Distribution; 221112, Fossil Fuel Electric Powe r Generation; and 324110 Petroleum

Refineries.
Privately Owned or Held – A company whose shares are not traded on the open

market.

Produced Water – Water drawn from any hydr ologic unit for the purpose of producing hydrocarbons.
Publicly Owned or Held – A company which has issued securities through an offering, and which are now traded on the open market.
Publicly Owned Treatment Works (POTW) – Any device or system owned by a state or municipality that is used to re cycle, reclaim, or tr eat liquid municipal sewage and/or liquid industrial wastes.

Receiving Waters – A stream, river, or other surface water body to which wastewater or other pollu tants are discharged.13 Surface waters - Waters of the United St ates. See 40 CFR 122.2.
http://ecfr.gpoaccess.gov/cgi/t/text/textidx?c=ecfr&sid=8a3bce0135f51c11befeff39ba51e4 26&rgn=div5&view=tex t&node=40:21.0.1.1.

12&idno=40#40:21.0.1.1.12.1.6.2. Underground Injection – The technology of placing fluids underground, in porous formations of rocks, through wells or other similar conveyance systems. See injection well.

Water Reuse – Beneficial use of coalbed methane produced water (e.g., livestock watering, irrigation, or dust c ontrol) in lieu of discharge/disposal.