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# Quality Assurance Project Plan

f or the Coalbed Methane Existing Data Collection

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

- 1102

August 2 5 , 2011

EPA Contract No. 68 -C- 02

- 095 Work Assignment 8

- 37This page is intentionally blankHistory of QAPP for the Coalbed Methane Existing Data Collection

Revision 0

Delivery Date June, 28, 2011

Work Assignment 8

- 37

Scope Coalbed Methane Existing Data Collection

Comments Received June 14, 2011 (comments on April 22, 2011 draft) August 18, 2011 (comments on June 28, 2011 draft)

Comments Addressed June 28 , 2011 August 25, 2011

ApprovalDistribution

This Quality Assurance Project Plan (QAPP) will be distributed to staff of the U.S. Environmental Protection Agency and Eastern Research Group, Inc. ( Table 1

- 1 ). The ERG WAM will provide a copy of the approved QAPP to all Eastern Research Group, Inc. staff

involved in the data collection project, including those who join the project after approval 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 Coordinator (202) 566

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

Marla Smith Work Assignment Manager (202) 566

- 10 47 (phone) smith.marla@epa.gov

Ahmar Siddiqui EPA Project Engineer (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 Quality Assurance Officer (703) 633

- 1615 mary.willett@erg.com

Lori Weiss Work Assignment Manager (703) 633

- 1658 lori.weiss@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.comi CONTENTS

Page

1. I NTRODUCTION

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

2. P ROJECT M ANAGEMENT

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

2.1 Project Organization and Responsibilities

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

2.2 Special Training and Certificates

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

2.3 Project Records

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

2.4 Assessment of QAPP Implementation

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

2.5 Proj ect Status Reports for Management

................................ ................................ . 7

3. P ROJECT D ESCRIPTION AND O BJECTIVES

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

3.1 Problem Definition/Background

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

3.2 Project Description

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

4. D ATA N EEDS

, S OURCES

, AND Q UALITY C RITERIA

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

4.1 Data Needs

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

4.2 Data Sources

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

4.2.1 Literature Review Data Sources

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

4.2.2 Cost Data Sources

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

4.2.3 State and Federal Databases

................................ ................................ ...... 12

4.3 Data Quality Criteria and Specifications

................................ .............................. 12

5. D ATA A CQUISITION

, R EVIEW

, Q UALITY V ERIFICATION

, AND R EPORTING

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

5.1 Data Acquisition and Documentation

................................ ................................ ... 16

5.2 Data Storage and Management

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

5.3 Data Review

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

5.4 Data Quality V erification

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

5.5 Data Quality Reporting

................................ ................................ ......................... 19

6. U SE OF E XISTING D ATA

................................ ................................ ................................ ..... 19

7. P ROJECT R EPORTS (D ELIVERABLES )

................................ ................................ .................. 20

8. R EFERENCES

................................ ................................ ................................ ...................... 20

Appendix A: PROJECT FILE MANAGEMENT PLAN

Appendix B: EXAMPLE DATA NEEDS QUESTIONSii LIST OF TABLES

Page

Table 1

- 1. QAPP Distribution

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

Table 3

- 1. Key Products and Milestones

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

Table 4

- 1. Industry Profile Data Acceptance Criteria

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

Table 4

- 2. Produced Water Characterization Data Acceptance Criteria

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

Table 4

- 3. Treatment Technology Performance Data Acceptance Criteria

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

Table 4

- 4. Treatment Technology Cost Data Acceptance Criteria

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

Table 7

- 1. Key Products

................................ ................................ ................................ ................ 20iii LIST OF FIGURES

Page

Figure 2

- 1. Project

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

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

Figure 5

- 1. Telephone Contact Report Form

................................ ................................ ................. 17Revision No. 0 Date: June 28, 2011 Page 1 of 2 1

1. I NTRODUCTION

ERG is providing technical support to the U.S. EPA for development of effluent limitations guidelines and standards (effluent guidelines) for the coalbed methane ( 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 requires the remov al of groundwater to reduce the pressure in the coal seam, which allows CBM to flow to the surface through the well. This recovered groundwater, commonly referred to as produced water, may be permitted for discharge directly or indirectly via a publicly ow ned treatment works (POTW) to surface water.

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 the number 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 industry sur vey. Information on these data collection efforts is documented in Coalbed Methane Extraction: Detailed Study Report , dated December 2010.

EPA will continue to collect information and data on the CBM industry to support a proposed rulemaking which the y pl an 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. Data sources include both primary and secondary data 1

EPA’s Quality Guidelines

. In response to guidelines issued by the Office of Management and Budget (OMB, 2002) under Section 515 of the Treasury and General Government Appropriations Act for Fiscal Year 2001 (Public Law 106

- 554; H.R. 5658), EPA developed Information Quality Guidelin es (EPA, 2002 b ) for ensuring and maximizing the quality of

information disseminated by EPA. EPA’s Information Quality Guidelines defines quality as : (e.g., literatu re , publicly available sources of information and data) and primary data collection, including site visits and an industry survey which has already been distributed to the industry. As directed by EPA, E RG has prepared this detailed Quality Assurance Proje ct Plan (QAPP) covering the existing data collection efforts.

**•** Objectivity

- information is accurate, reliable

, and unbiased and its present ation is clear, complete

, and unbiased;

**•** Utility

- information is useful for the intended users; and

**•** Integrity

- information is not compromised through corruption or falsification

either by accident or by unauthorized access or revision ( from EPA, 2003 )

.

In executing project s involving the collecti on and use of existing data, ERG will support EPA in meeting these guidelines by :

**•** Understanding how EPA intends to use the collected data and collecting data appropriate for that use;

1 In this document, the terms “existing data” and “secondary data” are used interchangeably to describe existing data to be used for a secondary purpose (i.e. a purpose other than that for which the data were originally collected).Revision No. 0 Date: June 28, 2011 Page 2 of 2 1

**•** Working with EPA to develop specifications for th e required accuracy, reliability, and objectivity of the data

, evaluating collected data against those specifications

, and including the results of these evaluations in intermediate and final project

deliverables ; and

**•** Presenting the sources of data, assump tions made, and calculations used in all project deliverables. These present ations will be sufficiently detailed and transparent to ensure the reproducibility of the work by qualified third parties.

This QAPP describes how ERG will accomplish these actio ns by using the four

- step plan

- do

- check

- report cycle repeatedly until the project is completed , as summarized below. ERG will collect quality information as it conducts the project and report that information with the project deliverable(s ).

PLAN **•** Identify key questions/objectives

**•** Identify the type and quality of information required to answer the questions/meet the objectives
DO **•** Collect the required data

CHECK **•** Evaluate collected data against the quality specifications

REPORT **•** Report results of the data quality evaluation

PLAN **•** How to use the collected data

**•** Analysis and/or summary of collected data

**•** Required quality of the analysis results
DO **•** Conduct the planned analysis

CHECK **•** Evaluate analysis results against the quality specifications

REPORT **•** Report results of the quality evaluation of the analysis

QAPP Approval and Distribution. Each QAPP has a signed approval form, title page, table of contents, and EPA

- approved document control format (see header at the top of each page in this QAPP). During the course of the project, the ERG WAM will circulate any approved revision to the appro ved QAPP to all ERG and EPA project staff. ERG will document the circulation of the revised QAPP to project staff with a signature page for the revision.

History of this QAPP. As directed by Work Assignment 8

- 3 7 , ERG prepared a detailed QAPP addressing the support it will provide for EPA’s existing data collection under the CBM Rulemaking

. ERG delivered a draft QAPP to EPA on April 22, 2011; this version of the QAPP incorporates comments received from EPA and organizational changes to improve the layout of the information presented in the QAPP. In accordance with EPA’s standard procedures for QAPPs, the first approved version of this QAPP will be referred to as “Revision 0.” In addition to this QAPP, ERG has also prepared QAPPs for site visits and the inform ation collection request sent to facilities as part of the CBM Rulemaking.

QAPP Organization. This QAPP is organized according to the work flow ERG uses for projects involving the collection and use of existing data. Although its organization differs from that presented in EPA Requirements for Quality Assurance Project Plans QA/R

- 5 (EPA, 2001 ) , it is responsive to all applicable elements of QA/R

- 5

. To facilitate EPA review of this QAPP, a

revie w checklist is provided with this plan to help reviewers underst and how QA/R

- 5 elements

are addressed . The organization of this plan is as follows:Revision No. 0 Date: June 28, 2011 Page 3 of 2 1

**•** Section 2 : Project Management

**•** Section 3 : Project Description and Objectives

**•** Section 0 : Data Needs, Sources, and Quality Criteria

**•** Section 5 : Data Acquisition, Review, Quality Verification, and Reporting

**•** Section 6 : Use of Existing Data

**•** Section 7 : Project Reports (Deliverables)

**•** Section 8 : References

2. P ROJECT M ANAGEMENT

This section addresses project management, including:

**•** Project organization and responsibilities;

**•** Special training and certification;

**•** Project records;

**•** Assessment of the implementation of this QAPP; and

**•** Project status and quality activity r eports to management.

2.1

Project Organization is depicted in Project Organization and Responsibilities

Figure 2

- 1

, listing the staff with program m anagement and technical responsibilities and those with QA/QC roles. It shows the relationship and lines of communication among all project participants, including those from EPA

.

Ms. Lori Weiss, t he ERG Work Assignment Manager (WAM)

, will be the principal contact for the EPA WAM on project issues, deliverables, and schedule. Ms. Weiss will be responsible for:

**•** Ensuring that ERG’s quality of work, schedule, and budget meet the requirements of the EPA effluent guidelines program;

**•** Providing technical directi on to ERG staff and managing the daily activities on the project;

**•** Obtaining appropriate technical review of all ERG deliverables and ensuring deliverables conform to EPA’s technical review requirements; and

**•** Keeping the ERG Project QA Coordinator and the ERG Program 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. Ms. Willet also serves as ERG’s

overall Co rporate QA Manager and as such ensures that project

- specific QA/QC programs are commensurate with project objectives and with ERG’s quality system. Ms. Willett has no other role on the CBM project and is independent from the CBM project team.Revision No. 0 Date: June 28, 2011 Page 4 of 2 1

Figure 2

- 1 . Project

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

QA Manager

ERG Project QA Coordinator

ERG Technical

Reviewers To be assigned ERG Program Manager

ERG Work Assignment

Manager

ERG

Task Lead

ERG

Staff EPA Project Officer

EPA Work Assignment

Manager

EPA QA Officer

Lines of Communication Reporting and AuthorityRevision No. 0 Date: June 28, 2011 Page 5 of 2 1

2.2

Project team members who collect existing data for the CBM Rulemaking will have read this QAPP and relevant background documents (e.g., C BM Detailed Study Report) to ensure that they have the necessary ba ckground information to collect appropriate data. To supplement this basic level of training, the ERG WAM will meet regularly with the project team members involved in the existing data collection to ensure that the data collected are appropriate and that the project team members have all of the necessary information and training to searc h for and identify data for the CBM Rulemaking. Special Training and Certificates

Information and data collected during this project may be classified as Clean Water Act Confidential Business Information (C BI) by the owners of the information . Therefore, ERG will train project staff in CBI

- handling procedures as outlined in ERG’s CBI security plans. ERG will permit only staff demonstrating their understanding of CBI handling procedures by passing a written test to access CBI on this project. E RG’s CBI Security Officer, Ms. Laurie Morgan, will maintain a list of all personnel cleared to access Clean Water Act CBI. The ERG WAM will confirm that project personnel are included on this list before they are permitted to access CBI.

ERG will strictly adhere to all EPA procedures when handling industry CBI. ERG will manage all reports, documents, and other materials and all draft documents developed under this work assignment in accordance with the procedures set forth in E RG’s CBI security plan ( or

su ccessor approved plans ) : 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

.

2.3

ERG’s standard controls for project

- related data, documents, and records are presented in

the Coalbed Methane Project File Management Plan ( Appendix A )

. Standard controls for project

- related data, documents, and records are also presented in Section 5 of E RG’s 2002 QMP ( ERG, 2002 ). ERG will enter all secondary data that is used for the CBM rulemaking into the CBM project file. Project Records

ERG will handle and store all information collected, generated, and analyzed during this project in a centralized record. This centr alized record contains all data collected or accessed from other sources and documents analyses of data collected (e.g., literature reviews and database analyses). During the period of performance, all project files, including interim or working files and final project deliverables, will be located and maintained on a server at ERG’s facilities and will be backed up daily

. Any files that contain CBI will be maintained on ERG’s

secure CBI server.

The ERG WAM is responsible for establishing and ensuring that version control is used

for all project documents. Under this work assignment, project team members will identify the version of interim and working documents in the document and in the electronic file name using a sequential numbering or dating scheme. Historical files will be kept and maintained in the project file. Final versions of documents will be identified in the electronic filename as

“FINAL.”Revision No. 0 Date: June 28, 2011 Page 6 of 2 1

At the conclusion of the rulemaking , all electronic pro ject files will be copied to a DVD

disk and provided to the EPA WAM

. ERG will remove the files from the ERG server but retain a copy of project electronic files in the ERG archive and will return paper materials to the EPA

WAM as directed.

ERG’s WAM is res ponsible for designating an individual to maintain all project files, known as the index keeper. She is also responsible for ensuring that project team members

document all data sources used

. ERG is using a project file management plan for this project

adapted from similar plans prepared for other work assignments on Contract No. 68

- C

- 02

- 095. The contents of the record will be indexed using a n MS AccessTM database. This system is compatible with the needs of the Federal Docket Management System (FDMS). The E RG WAM has assigned the “index keeper” the responsibility of maintaining the file index and filing documents in the electronic project file.

2.4

ERG will conduct several stages of review during the planning and execution of this project to assess that the procedures outlined in this QAPP are followed. All tasks conducted and products generated receive (1) a conceptual review, (2) a developmental re view, and (3) a final product review. Assessment of QAPP Implementation

A conceptual review is performed during the initial stages of work development and ensures that the final product and associated documentation will address the needs set forth by

the EPA WAM

, the work assignment , and t his QAPP . Conceptual review will be provided by the program manager as well as senior engineers knowledgeable in the development of effluent limitations guidelines, but not directly involved in the work assignment.

The quality of intermediate deliverables and final products is also evaluated as these work products evolve. This developmental review includes , for example, (1) check s on calculations and data quality and (2) review s of draft documents to ensure that the direction of work is consistent with the conceptual review outline. The ERG WAM and project team members will provide this level of review.

The ERG WAM will conduct f inal product technical review of all deliverables p rior to delivery to EPA. Technical review is a documented critical review of work that has been performed within the “state of the art.” In addition, reports and memoranda to the record will be reviewed by a senior

- level engineer (for engineering activitie s) not directly involved with the product . All deliverables will subsequently be reviewed by the EPA WAM. ERG will document all reviews of project deliverables in the project QA database

.

Mary Willett will serve as the Project QA Coordinator for this proje ct. Ms. Willett or her designee will assess the implementation of QA/QC procedures on this project as follows:

**•** Review the QAPP (this document) for completeness and applicability; and

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

— That project s taff have developed QC procedures and that these procedures are used; andRevision No. 0 Date: June 28, 2011 Page 7 of 2 1

— That project staff are documenting their use of these QC procedures by completing checklists, review spreadsheet s , and other project

- specific

forms.

Mary Willett also serves as the Corporate QA Manager. At any time or at the end of the project or work assignment, Ms. Willett, or her designee, may inspect the project QA files.

A ny quality deficiencies (e.g., insufficient QC review, incomplete documentation ) detected by technical revie wers 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 taken and reported to the Project QA Coordinator

, who also is the ERG Corporate QA Manager

. Upon notification, the ERG Project/ Corporate QA Manager will conduct a project review. If she concurs that the work is deficient, the Project /Corporate QA Coordinator will recommend to the ERG Program Manager that work related to these deficiencies be stop ped until

remedied

. The ERG Program Manager will take necessary steps to resolve the issues and

, if appropriate

, will notify the EPA PO and/or WAM of actions taken

.

ERG will include any reports of corrective actions in the project QA files. At any time or at the end of the project or work assignment, the Project/ Corporate QA Manager or her designee may inspect the project QA files.

2.5

ERG will electronically submit to the EPA WAM and PO a monthly progress report that

docu ments the costs incurred and work performed during the previous accounting period and work planned for the current accounting period. Project Status Reports for Management

Additionally, the ERG WAM will provide the EPA WAM with monthly reports on the status of quality assurance (QA) activitie s. These reports will be incorporated into our monthly technical progress reports which will be supplemented to include the following:

**•** 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.

E RG will describe QA activities conducted for majo r deliverables, such as summary

memo randa , when such documents are delivered to EPA. These descriptions may be included in the document or in the transmittal email, as directed by EPA.

ERG will provide copies of the c ompleted existing data and QA database s upon request by the EPA WAM. If data do not meet all the quality specifications but are needed for rulemaking analysis, ERG will obtain approval to use the data from EPA and include the approval in the QA documentation

.Revision No. 0 Date: June 28, 2011 Page 8 of 2 1

3. P ROJECT D ESCRIPTION AND O BJECTIVES

This section provides a management

- level overview of the project and its objectives. That is, this section focuses on the purpose of the project. Planned execution of the project is detailed in the following sections:

**•** Section 0 describes the data needed to answer the questions presented in Section

3 ;

**•** Section 5 describes how ERG will obtain, check, and store collected data;

**•** Section 6 describes h ow ERG will use the data by developing data summaries or engineering analyses; and

**•** Section 7 describes the project deliverables.

3.1

B ased on the results of EPA’s CBM Detailed Study, EPA is developing effluent guidelines for the CBM industry . The following are examples of the types of information that

EPA will use in its engineering analyses to support the rulemaking : Problem Definition/Background

**•** Produced water volumes and characteristics ;

**•** Availability, cost, and effectiveness of

— M anagement practice s for produced water ; and

— Produced water treatment technologies

.

During the Detailed Study, EPA c ollected much of the necessary information to support the rulemaking. This information includes a survey with two questionnaires. The screener questionnaire collected basic information about every operator and well in the nation. The detailed questionnaire obtained more specific information from a subset of operators and projects, most of which discharge water. In addition, EPA collected information that is provided in the Dockets for the 304(m) Effluent Guidelines Plans (2006, 2008, and 2010). The docket

includes the Detailed Study Report (December 2010, EP A

- 820

- R

- 10

- 022)

. Subsequently, EPA received a pre

- publication version of a detailed National Academy of Science (NAS) report “Management and Effects of Coalbed Methane Produced Water in the Western United States.”

The Colorado School of Mines ’ (CSM) Produc ed Water Treatment and Beneficial Use

Information Center ( http://aqwatec.mines.edu/produced_water/index.htm ) also released extensive information about treatment and management of produced wate r

. ( This work is partially funded by the U.S. Department of Energy and industry partners. ) ERG will explore the 304(m) dockets, the N AS report, and CSM information and computerized mod ules (e.g., Beneficial Use Economic Module (BEM) at http://aqwatec.mines.edu/produced_water/tools/modules/buecon/index.htm ).

A s it evaluates the data and sources described above , ERG will construct a “ data needs

matrix ” to i dentify the major components of the analyses and appropriate data sources. Appendix

B provides examples of the types of questions that the data needs matrix will address. EPA and

ERG will use the matrix to i dentify areas that have incomplete and or out

- dat ed information (“data gaps”). After receiving EPA concurrence that additional information is required

, ERG will support EPA in searching for and collecting additional data.Revision No. 0 Date: June 28, 2011 Page 9 of 2 1

3.2

Depending on EPA’s identification of data gaps, ERG ’s suppleme ntary collection of existing data may include the following: Project Description

**•** Collecting data on the pollutants present in produced water from CBM operations;

**•** Gathering information on CBM produced water management and treatment

, including:

— Differences in water management between each of the CBM production basins;

— Geographic and temporal differences in produced water volumes and characteristics;

— Current best practices employed in the management of produced

water;

— Impacts from CBM production and produced water management (b oth water

- quality and non

- water

- quality impacts);

— Costs of produced water management;

**•** Collecting information on the use of hydraulic fracturing in CBM extraction ; and

**•** Collecting information on basins with emerging CBM development.

ERG will combine the a vailable data with additional existing data collected during the CBM rulemaking to support estimate s of the costs for treatment of CBM produced water using the best available technology and the impacts of produced water treatment to the economy and

the env ironment. This will be an iterative process driven by the evaluation of existing data and

t his QAPP addresses tasks required to ensure the existing data sources used in the CBM rulemaking produce reliable data that can be used to meet the project's overall objectives and goals.

The key products ERG will produce and key milestones are listed in Table 3

- 1.

Table 3

- 1. Key Products and Milestones

Key products and milestones Date Regulatory database outline July 2011

Draft data needs matrix September 2011 Existing data tracking d atabase Spring 2012 Data analyses documents TBD

Final r eport , including descriptions of data sources, summary of technical reviews, and summary of all QC activities performed to

date Fall 201 2

TBD: To be determined as data analys es are requested by EPA.Revision No. 0 Date: June 28, 2011 Page 10 of 2 1

4. D ATA N EEDS , S OURCES , AND Q UALITY C RITERIA

This section discusses the existing data needed to answer the questions listed in the data

needs matrix and describes the sources that ERG will review to identify these data. As described in Section 5.4, ERG may use data that do not meet the specifications if, for example, there are no

other available data.

4.1

The following list provides examples of the type of data that ERG will review in developing the data needs m atrix : Data Needs

**•** 304(m) docket with the CBM Detailed Study record materials ;

**•** Survey questionnaire data ;

**•** Reports from industry , academia, peer

- reviewed journal s , and government organizations containing profiles of the CBM industry ;

**•** Data on produced water volumes per well and per basin ;

**•** Data on pollutant concentrations in CBM produced water;

**•** Information on current produced water management practices and treatment;

**•** Information on state and local regulations that may impact the selected management practice;

**•** Informat ion on geographic and geologic characteristics that may impact the selected management practice (e.g., availability of formation for reinjection, availability of agricultural land for irrigation);

**•** Technology performance and cost data for treatment technolo gies that may be included as regulatory options ; and

**•** Information on basins with emerging development and their produced water volumes, characteristics, and management practices

.

In general, these data should be collected in the past 10 years (because the industry has experienced most of its growth during that time), be presented in English, and they should represent the CBM industry in the U .S

. Section 4.3 discusses specific quality requirements for

these data.

4.2

Existing data sources may incl ude monitoring data from state and federal agency databases, journal articles and technical papers, technical references, industry/vendor telephone queries, and vendor websites. Ideally, these data will be from the past ten years and they will
represent ge ographic areas where CBM operations are located and have surface water and/or beneficial use discharges . Additionally, the cumulative treatment technology and produced water management data should cover options generally available to CBM operations. Tables 4

- 1 through 4

- 4 contain detailed specifications for the type of data that ERG plans to collect. Data Sources

ERG will obtain the technology reports and case studies needed for this project from published literature and final technic al reports . ERG will obtain the cost information needed for this project from contacts with equipment vendors and vendor websites , as well as from dataRevision No. 0 Date: June 28, 2011 Page 11 of 2 1

collected under the CBM questionnaire and technical references used for general cost data (see

Section 4 .2.2)

.

4.2.1 Literature Review Data Sources

After identifying the data gaps, ERG will support EPA in conducting a targeted literature search of publicly available databases to identify published literature, including peer reviewed journals, newspapers, governme nt reports, permitting documents, industry and nonprofit reports,

and court cases that discuss the characteristics and management of CBM produced water to fill the gaps . ERG may use the following search engines to conduct the literature review:

**•** Scirus (www .scirus.com)

- Scirus is a comprehensive science

- specific search engine on the internet. Scirus filters out nonscientific web sites in web page searches and provides access to the world’s largest database of scientific, technical, and medical journals.

**•** Fin d Articles (www.findarticles.com)

- Find Articles provides access to articles from leading academic, industry and general interest publications.

**•** IngentaConnect (www.ingentaconnect.com)

- IngentaConnect searches a comprehensive collection of academic and professional publications.

**•** Google (www.google.com)

- Google searches for information readily available on

the Internet.

**•** Google Scholar (www.scholar.google.com)

- Google Scholar searches scholarly

literat ure, including peer

- reviewed papers, theses, books, abstracts and articles from academic publishers, professional societies, preprint repositories, and universities and other scholarly organizations.

In addition to the search engines mentioned above, ERG will perform a search o f s tate regulatory agency websites for states producing CBM , as well as websites for federal/national organizations involved with CBM production (e.g., U.S. Bureau of Land Management). At EPA’s direction, ERG may contact state and local agency representatives to obtain information on the locations, quantities, and characteristics of CBM discharges.

4.2.2 Cost Data Sources

After EPA concurs on data gaps related to costing information

, ERG will collect

information about the costs for CBM operators to install and operate wastewater pollution control technologies of interest to EPA

. Depending on the required information, ERG may :

**•** O btain current (e.g., 200 1

- 2011) cost information from process and equipmen t
vendors that serve are as where CBM operations occur ;

**•** C onsult the Energy Information Administration (EIA) 2

**•** C onsult RSMeans® for labor and construction costs ; and website for information about the cost of electricity, gasoline, and diesel fuel;

**•** A ttempt to obtain project costs from CBM operators for similar projects completed for C BM discharges via telephone, e

- mail, and or letter requests.

2 The EIA is an organization within the Department of Energy that compiles and reviews energy information to assist the government in developing policies that benefit the economy and the environment.Revision No. 0 Date: June 28, 2011 Page 12 of 2 1

4.2.3 State and Federal Databases

After EPA concurs on data gaps related to state and federal requirements, ERG may collect information from EPA databases (e.g., PCS, TRI, ICIS

- NPDES) or other databases provided by federal or state agencies (e.g., USGS, EIA) or trade organizations. ERG will not review the quality of existing data contained in EPA databases or ot her databases provided by federal or state agencies or trade organizations but will describe known limitations of the data and any limitations of using the data for the CBM rulemaking. If ERG identifies limitations in the quality of the data from publishe d literature or federal/state generated databases that may impact decisions regarding the overall direction of further data collection efforts or the quality of deliverables, ERG will communicate these issues to the EPA WAM. Data limitation discussions

wil l identify where data gaps exist and a description of data reporting requirements.

4.3

T his QAPP is intended to ensure that the existing data collected for the CBM r ulemaking

are of known quality such that EPA can deci de if they are of the quality necessary to support effluent guidelines development

. Data Quality Criteria and Specifications

This section pres ents how ERG plans to evaluate the existing data collected for this project and the criteria used to evaluate the quality of these data. Acceptance crite r ia and required quality depend on use. Existing data may be used for the following purposes:

**•** Industry profile;

**•** Characterization of produced water (estimates of baseline pollutant discharges);

**•** Identification of technology treatment alternatives ;

**•** Characteri zation of produced water treatment system performance/efficiency; and

**•** Estimation of cost of treatment.

ERG will use the criteria in Tables 4

- 1 t hrough 4

- 4 to evaluate the quality and relevance

of data collected from these sources for the purpose of developing regulations for the CBM industry. The criteria also will be applied to verify that information collected for the purpose of conducting the Detailed Study also are appropriate (or not) to support the regulation

. Ultimately,

EP A will use ERG’s evaluation to determine whether the data collected are useable. Note that

ERG may refine these tables as EPA determines how they will use the data that are collected and will update this QAPP and document the changes in a revision history to be attached after the QAPP signature page

. ERG will develop quality specifications for analyses of existing data (e.g., baseline loads and costs analysis, pollutant reduction models) after the methodology for developing these analyses has been finalized

.

Table 4

- 1 lists criteria for industry profile information obtained through a literature

review. Tables 4

- 2 through 4

- 4 contain additional acceptance criteria for data which may be used for produced water quality characterization, treatment technology performance, or treatment

costs , respectively

.Revision No. 0 Date: June 28, 2011 Page 13 of 2 1

Table 4

- 1

. Industry Profile Data Acceptance Criteria

Acceptance Criterion:

Literature

Review/Profile

Information Description/Definition Specification

Currency (up to date) Does the information reflect

current conditions? **•** Sources were published or presented in 200 1 or after.

**•** Because CBM is a relatively new industry, ERG may

use information from sources prior to 200 1 if it represents practices currently in place. ERG will

document all data collected in the CBM project file ( Appendix A ) . The EPA WAM will provide further

directio n on how to incorporate or exclude the data in analys e s

. Accuracy/Reliability Is the information true? ERG assumes that the underlying data and information contained in the following sources are accurate:

**•** Government publications (state and federal reports);

**•** Peer

- reviewed journal articles;

**•** Presentations at professional technical conferences;

and

**•** Publications from recognized industry experts or organizations. The EPA WAM will determine recognized experts.

ERG assumes that data from these sources are o f sufficient quality to evaluate for use in CBM rulemaking

activities.

For other sources, ERG will determine , case

- by

- case if

the source contains information that appears to be

accurate.

Regardless of the source , ERG will provide EPA with the following information and EPA will provide further direction on how to incorporate or exclude the data in the analysis:

**•** Source citation information;

**•** Analysis methodology and assumptions (when applicable) ; and

**•** Data limitations or analysis uncertainty.

Scope Is the information reported from CBM operations ? **•** Information pertains to CBM operations and not conventional oil and gas or shale gas.

**•** Source represents a geographic area in which CBM operations are active or emerging

. Reasonableness Is the information consistent with EPA’s understanding of CBM operations? **•** ERG will compare information collected from secondary data sources to primary sources (e.g., CBM Detailed Study Report, q uestionnaire data) to confirm

the information is reasonable based on documented

CBM practices. This comparison will be presented in the QA sections of major deliverables.Revision No. 0 Date: June 28, 2011 Page 14 of 2 1

Table 4

- 2 . Produced Water Characterization Data Acceptance Criteria

Acceptance Criterion:

Characterization Data Description/Definition Specification

Currency (up to date) Does the information reflect

current systems ? **•** Data reflect current practices.

Scope / Representativeness Is the information reported from CBM operations ? **•** Source represents CBM operations (the information does not include conventional oil and gas or shale gas operations).

**•** So urce represents a geographic area in which CBM operations are active or emerging

. Accuracy/Reliability Reported concentrations or other measurements represent produced water

concentrations Accuracy cannot be measured directly because we are looking at existing data ; however ERG will evaluate

whether:

**•** Measurements identify the analytical method used.

This in formation can then be used to evaluate whether

the results met the method performance specifications.

**•** Measurements contain data quality flags that suggest that data are of poor quality (e.g., analyte detected at high levels in field or lab blank)

.

**•** Results appear reliable based on case narratives, and anecdotal descriptions (where available)

.

**•** Report provides measurements for multiple samples.

Comparability Are the data comparable to

data from other sources that meet these acceptance

criteria? **•** Pollutant data for untreated produced water (“c haracterization data ) are consistent with data from other sources (e.g., samples were collected from the same point in the treatment process).

Completeness Were all other pieces of relevant information provided

with the data? **•** Data source identifies the location of the sample, analytes, concentrations, units, analytical method, and

detection limit. If available, QA/QC for sampling and/or laboratory results also will be evaluated.

Table 4

- 3 . Treatment Technology Performance Data Acceptance Criteria

Acceptance Criterion:

Cost Data Description/Definition Specification

Currency (up to date) Does the information reflect current systems? **•** Data reflect current practices

.

Representativeness Does the information reported reflect a technology relevant to the study? **•** Performance data are for systems that treat produced

water.

Scope Is the information reported from CBM operations, or operations with similar discharges ? **•** Source represents CBM operations and /or oil and gas operations when they treat produced water similar to CBM produced water).

**•** Source represents a geographic area similar to those in which CBM operations are active or emerging

.

**•** Source must describe a full

- scale operation or a pilot study

.Revision No. 0 Date: June 28, 2011 Page 15 of 2 1

Table 4

- 3 . Treatment Technology Performance Data Acceptance Criteria

Acceptance Criterion:

Cost Data Description/Definition Specification

Accuracy/Reliability (Accuracy of

measurements should be evaluated using Table

4

- 2 ) Is the information reported

true? **•** Data are obtained directly from the CBM operator, a vendor who does business with CBM operators

, and/or government entities collecting data from CBM
operators

.

Comparability Is the performance data

consistent with information provided from other sources? **•** Technology performance data are consistent with vendor specifications and primary data from CBM Questionnaire.

Table 4

- 4 . Treatment Technology Cost Data Acceptance Criteria

Acceptance Criterion:

Cost Estimates Description/Definition Specification

Complete Does the source contain all information required for the economic analysis? **•** Includes costs for any of the elements necessary to implement the technology option:

o One

- time costs for equipment purchase and

installation;

o On

- going operating and maintenance costs (annual

costs) ; and

o Periodic operating and maintenance costs, as

appropriate.

**•** C osts per year basis is reported. ERG will convert all costs to a standard year basis using RS Means ®

Construction Inde x or other standard cost index approved by EPA

. Representativeness Appropriate for actual CBM

locations **•** R eflect the costs for e quipment, including transportation and installation, supplies

, o perating costs ( e.g. electricity, fuel, labor, chemic als )

, and labor

at CBM locations.

Accuracy/Reliability Is the information reported

true? **•** Data are obtained directly from the CBM operator, a vendor who does business with CBM operators and/or government entities collecting data from CBM
operators

. . Comparability Is the data comparable to costs provided by sources that meet these acceptance

criteria? **•** Order

- of

- magnitude of costs is comparable to costs for similar installations at similar operat ion s.

**•** Cost trends follow the design basis trends ( e

. g ., cos ts for large produced water volumes are greater than the costs for small volumes).

5. D ATA A CQUISITION , R EVIEW , Q UALITY V ERIFICATION , AND R EPORTING

This section descr ibes how ERG will acquire the existing data needed to answer the key questions listed in Se ction 3.1 , describes how ERG will determine if the data meet the specifications listed in Section 0 , and how this determination will be documented. The use s of

these data sources are discussed in Section 6

.Revision No. 0 Date: June 28, 2011 Page 16 of 2 1

5.1

ERG project team members will obtain existing data from sources such as government publications, scientific literature, and vendor quotes. In addition to published information, ERG

may collect pollution control technology cost information by contacting vendors by telephone

and/or email. Data Acquisition and Documentation

ERG staff wi ll use the following procedu res when collecting published existing data:

1. ERG researchers will collect full content and bibliographic information on all newly collected publications, including “date accessed” for information collected

from the Internet. ER G researchers will save web pages as PDF files, so that the data source can be added to the electronic project file.

2. ERG will complete the existing data tracking Microsoft® Access database to document bibliogra phic information for the source as well as inf ormation on the

source content. The source will be added to the project file following the procedures described in the project file management plan (Appendix A). The project file management plan describes the bibliographic information required for

the rule making docket. The other fields in the existing data tracking system categorize the source information by topic (e.g., water characterization data, technology performance data). The existing data tracking database will be described in a project report as e xplained in Section 7.0

.
3. ERG researchers will submit the publications and meta data to the project file index keeper. The index keeper will add meta data describing the publications from the existing data tracking database to the CBM Project File. Followin g the procedures detailed in the project file management plan, the index keeper will add the publication file to the CBM Electronic Project File (Appendix A )

.
ERG staff will use the followin g procedures to document data collected via telephone and

email co ntact.

1. ERG researchers will document all telephone contacts, questions asked, and responses using a Telephone Contact Report, such as the one depicted in Figure

5

- 1

.
2. ERG researchers will save email contacts as PDF files following the instructions in the Project File Management Plan , so that they can be added to the electronic project file.

3. ERG researche rs will ensure that telephone contact reports and email records are added to the CBM Project File.Revision No. 0 Date: June 28, 2011 Page 17 of 21

Figure 5-1. Telephone Contact Report Form

ERG staff will use the existing data tracking database to genera te QA reports for EPA’s evaluation. For example, ERG can pull all sources from the database that are marked as containing treatment cost data for CBM produced water. ERG can then generate a report that contains the source bibliographic information, the type of cost information included (e.g., capital, operating), the location of the technology, and the vendor name for use in evaluating the Table 4- 4 acceptance criteria. The database and database reports will be retained in the project file to

document that ERG evaluated the quality of the collected existing data.

ERG will plan and document the review of any materials developed using existing data. Documents using existing data will include the QA report generated from the database as an

attachment. The docu ment will also discuss data comparability as specified in Tables 4 -1 through

4- 4. For example, materials developed using existing data will note how the existing data compares to primary data sources such as the detailed questionnaire, where applicable. Th e ERG WAM (or other reviewer) will verify that the data sources meet quality specifications by reviewing the associated data quality check lists as discussed in Section 5.4 below. The review

will be documented in a Microsoft Access TM database.

5.2

ERG researchers will submit publications and meta data to the project file index keeper. The index keeper will add meta data describing the publica tions to the CBM Project File Index. Following the procedures detailed in the project file management plan, the index keeper will add Data Storage and Management Project No.: DISTRIBUTION

Page 1 of 1

Project Name:

TELEPHONE CALL

RECORD

Outgoing Call Date: Time:

Company Name: Contact Nam e:

Phone No.:

Name:

GENERAL SUBJECT :

TOPICS DISCUSSED AND ACTION TAKENRevision No. 0 Date: June 28, 2011 Page 18 of 2 1

the publication file to the C BM Electronic Project File. The index and electronic project file will be reviewed and checked for consistency and accuracy as discussed in Section 5.3

.

ERG may add existing data to the regul atory database per direction from the EPA WAM.

I f ERG is tasked with add ing existing data to the regulatory database , ERG will first develop a plan describing how it will be entered into the database such that it can be used in conjunction

with other prima ry data

. Section 7 describes the project reports for the existing data collection and database development. The regulatory database will be entered into the project file.

5.3

According to EPA’s Guidance for QAPPs (QA/G

- 5), data review is “the in

- ho use examination to ensure that the data have been recorded transmitted, and processed correctly. That includes, for example, checking for data entry, transcription, calculation, and reduction errors...It is a completeness check to determine if there are any deficiencies, such as data missing.... ” Data Review

Publications and Data. After acquiring publications and data, ERG will ensure that the meta data describing these data sources has been correctly entered into the project file index. Information added to the project f ile will be checked as described in the Project File Managem ent Plan, which inclu de periodic project file review, and project file reviews conducted during docket assembly. These checks will be performed by the ERG WAM or a project team member who was not directly involved in gathering and entering the data.

Databases. If ERG acquires existing data obtained from a database , ERG will check the

database for errors, such as missing data and registry errors. ERG also may reformat existing data into a database or spreadsheet for use in analysis. For data only available in (hardcopy) publications, ERG staff will key

- enter data into spreadsheets to store the data and use them for

calculations. ERG will not perform data calculations or data manipulations as part of the existing data collection. ERG will develop an addendum to this QAPP to discuss the data calculations and manipulations which will be performed as pa rt of the cost and loads analysis.

To review the accuracy of data entered from publications into electronic format, the ERG

WAM will assign a project team member to independently visually compare the publication data

with the data in the database or spread sheet for 100 percent of the entries. For data that have

been reformatted ( copied and pasted ) from electronic format, the ERG WAM will assign a project team member to independently compare 10 percent of the entries to the original data

source. If more than one quarter of those data contain errors (e.g., transcription, calculation, reduction, missing), an ERG project team member will document and correct the errors, and

additional checks of the data will be performed.

5.4

According to EPA’s Guidance for QAPPs (QA/G

- 5), data verification is “the process of evaluating the completeness, correctness, and conformance of a specific data set against the method, procedural or contractual specifications.” For this project, data verification means the process in which E RG will determine if collected existing data meet the data acceptanc e criteria specified in Section Data Quality Verification

4.3 ERG will document data quality by completing the existing data trackingRevision No. 0 Date: June 28, 2011 Page 19 of 2 1

database, which will contain the information required to evaluate the acceptance criteria in

Tables 4

- 1 through 4

- 4.

ERG will provide reports from the database to EPA with any deliverables prepared from

the data. The existing data tracking database will be retained in the project file to document that

ERG evaluate d the quality of the collected existing data. To evaluate comparability, ERG will compare any existing data used in a nalyses to primary data sources, such as the site visit reports or detailed questionnaire, and report the results of the comparison as part of the deliverable.

ERG may use data that do not meet the specifications (Section 4) if, for example, there

are no o ther available data. ERG will discuss such data quality issues with the EPA WAM and

obtain her written approval before using these data in subsequent analyses. This approval will be added to the project quality file. In its final project report, ERG will d escribe data quality and

data limitations , including any need to use data that did not meet quality acceptance specifications.

5.5

The ERG WAM will report the outcome of data quality verification (that is, our findings on the quality of data collected ) to the EPA WAM to enable her to determine whether the existing data are of sufficient quality for use in the CBM rulemaking. Data Quality Reporting

As discussed in Section 2.5

, the ERG WAM will provide the EPA WAM with a monthly report of the status of QA activities. In addition, ERG will include information on the data quality with any deliverables prepared from the data.

ERG will describe data quality, including any ne ed to use data that did not meet quality acceptance specifications, in major deliverables that rely on such data

.

6. U SE OF E XISTING D ATA

ERG will develop an existing data tracking database to summarize sources reviewed and

the information contained in the so urce. Based on direction from EPA, ERG may use the existing data collected under this QAPP t o perform various analyses in support of the CBM rulemaking

. Some examples of the types of analyses that would employ the collected data include an industry profile , a summary of CBM produced water characteristics, and costs and loads analyses for treatment of produced water discharges. Prior to performing any of these analyses, ERG will revise this QAPP to include quality assurance criteria , including steps to ensur e th at the equations are correctly programmed and match the approaches that have been reviewed and approved by EPA

.

In general, EPA plans to use the data collected under this QAPP to answer the questions

listed in the data needs matrix

. ERG will use formats specified by EPA to prepare reports of

collected data and the results of engineering analyses of the collected data . Formats could

include annotated spreadsheets or technical memoranda, including tables of findings and bibliographic citations.Revision No. 0 Date: June 28, 2011 Page 20 of 2 1

ERG will document the use of existing data for project analyses in memoranda that

include:

**•** Purpose of analysis;

**•** Description of analysis m ethodology;

**•** D ata sources used ;

**•** Criteria used to select the data sources;

**•** Exceptions to the criteria and rationale for e xceptions; and

**•** Documentation of assumptions and equation.

7. P ROJECT R EPORTS (D ELIVERABLES )

Table 7

- 1 lists t he key products ERG will produce and how data quality will be reported

in each

.

Table 7

- 1

. Key Products

Key products Content
Regulatory database outline **•** Description of the regulatory database which comprises the engineering questionnaire database, the economic questionnaire database, and the existing data tracking database. The outline will descr ibe the information

each database contains and how the three databases are linked

. Existing data tracking d atabase **•** List of all sources obtained from the existing data collection

, includ ing bibliographic information and information on the content of the source. Data analyses documents **•** Project deliverables that may use or contain existing data

.

**•** ERG will revise this QAPP to include quality assurance criteria for any such analyses prior to beginning them

. Final project report **•** D escription of all data sources used, a summary of technical reviews provided, and a summary of all QA/QC activities performed in the development of the work product

8. R EFERENCES

1. Eastern Research Group, Inc. Security Plan for Handling Confidential Business Information Under the Clean Water Act. September 25, 2008.

2. Eastern Research Group, Inc. 2002. Quality Management Plan for Technical Support for the Strategy for National Clean Water Industrial Regulations, June 2002.

3. EPA, 2001. U.S. Environmental Protection Agency. EPA Requirements for Quality Assurance Project Plans QA/R

- 5 . EPA/240/B

- 01/003. Office of Environmental

Information. March 2001.

4. EPA, 200 2 a . U.S. Environmental Protection Agency. Guidance for Quality Assura nce Project Plans QA/ G

- 5 . EPA/240/R

- 02 /00 9 . Office of Environmental Information. March

2001.

5. EPA, 2002 b . U.S. Environmental Protection Agency . Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Dissemina ted by the Environmental Protection Agency. EPA/260R

- 02

- 008. October 2002.Revision No. 0 Date: June 28, 2011 Page 21 of 2 1

6. EPA, 2003 U.S. Environmental Protection Agency

. A Summary of General Assessment Factors for Evaluating the Quality of Scientific and Technical Information , EPA 100/B

03/001 . June, 2003.

7. OMB, 2002. U.S. Office of Management and Budget. Guidelines for Ensuring and Maximizing the Quality, Objectivity , Utility, and Integrity of Information Disseminated by Federal Agencies (67 FR 8452 ).Revision No. 0 Date: June 28, 2011

Appendix A

PROJECT FILE MANAGEM ENT PLAN

# 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]Revision No. 0 Date: June 28, 2011

Appendix B

EXAMPLE CBM DATA NEE DS QUESTIONSRevision No. 0 Date: June 28, 2011 Appendix B

1. How do CBM produced water management practices vary over the different basins in the

U.S.?

2. How do the volumes and characteristics of gas and water change over the life of the well and the project?

3. How do the volumes and characteristics of the produced water differ across various co al

basins and coal formations?

4. What pollutants are being discharged by CBM operations and at what concentrations are they being discharged ? How do water volume and pollutant concentrations dictate the management practices used for produced water?

5. What are the existing technologies used to treat the produced water prior to discharge or reuse? What pollutants are removed by the technology and what is the removal efficiency? What are the capital and operating costs of the treatment technology?

6. How is the prod uced water managed, reused, treated, and discharged? How do the pollutant concentrations in discharges differ between these practices? What are the costs to install a produced water management system and to annually operate the system ? How do the geologic characteristics of the coal basin (e.g., availability of underground aquifers) influence the selection of the management alternative ? For produced water that is discharged, what are the receiving water bodies for the produced water? How will discharge prac tices for produced water change if pollutants are regulated?

7. What is the prevalence of hydraulic fracturing (i.e., practice of fracturing rocks in a drilled wellbore to improve energy extraction) in CBM extraction and how do hydraulic fracturing practices differ across coal basins? What are the available management practices for chemicals used in hydraulic fracturing? If hydraulic fracturing occurs, what characteristics of the coal basin dictate the practices used for CBM extraction (e.g., drill depth and r adius, type of chemicals used)?

8. Are there basins or areas with emerging CBM development? How do the management practices for emerging basins compare to basins with mature CBM development?

9. What are the non

- water quality impacts from CBM production and produ ced water management (e.g., soil contamination, destruction, and erosion; energy use; and or treatment residuals and other solid waste)?

10. Are there practices in other industries that would be applicable/similar to CBM wastes? Can technologies be transferred from categories/subcategories (e.g., coastal oil and gas) for which EPA has promulgated regulations? What are the similarities and differences

between their wastes and CBM?