jul

Quality Assurance Project Plan

for 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 25, 2011

EPA Contract No. 68-C-02-095

Work Assignment 8-37
This page is intentionally blank

History 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

Approval
Distribution

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) 566-1047 (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.com
i

CONTENTS

Page

1. INTRODUCTION .................................................................................................................... 1

2. PROJECT MANAGEMENT ...................................................................................................... 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 Project Status Reports for Management ................................................................. 7

3. PROJECT DESCRIPTION AND OBJECTIVES ............................................................................. 8

3.1 Problem Definition/Background............................................................................. 8

3.2 Project Description.................................................................................................. 9

4. DATA NEEDS, SOURCES, AND QUALITY CRITERIA ............................................................. 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. DATA ACQUISITION, REVIEW, QUALITY VERIFICATION, AND REPORTING......................... 15

5.1 Data Acquisition and Documentation................................................................... 16

5.2 Data Storage and Management ............................................................................. 17

5.3 Data Review.......................................................................................................... 18

5.4 Data Quality Verification...................................................................................... 18

5.5 Data Quality Reporting......................................................................................... 19

6. USE OF EXISTING DATA ..................................................................................................... 19

7. PROJECT REPORTS (DELIVERABLES).................................................................................. 20

8. REFERENCES ...................................................................................................................... 20

Appendix A: PROJECT FILE MANAGEMENT PLAN

Appendix B: EXAMPLE DATA NEEDS QUESTIONS 
ii

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 ................................................................................................................20
iii

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.................................................................................17
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1. INTRODUCTION

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 removal 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 owned 

treatment works (POTW) to surface water.

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

study. For 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 survey. 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 they plan to publish in December 2012. EPA will evaluate the

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

to control the pollutants discharged. Data sources include both primary and secondary data1

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 Guidelines (EPA, 2002b) for ensuring and maximizing the quality of 

information disseminated by EPA. EPA’s Information Quality Guidelines defines quality as:

(e.g., literature, 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, ERG has prepared this detailed Quality Assurance Project Plan (QAPP)

covering the existing data collection efforts. 

• Objectivity - information is accurate, reliable, and unbiased and its presentation 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 projects involving the collection 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).
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• Working with EPA to develop specifications for the 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, assumptions made, and calculations used in all 

project deliverables. These presentations 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 actions 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 approved 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 8-37, 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 information 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 

review checklist is provided with this plan to help reviewers understand how QA/R-5 elements 

are addressed. The organization of this plan is as follows:
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• 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. PROJECT MANAGEMENT

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 reports to management.

2.1

Project Organization is depicted in 

Project Organization and Responsibilities

Figure 2-1, listing the staff with program management 

and technical responsibilities and those with QA/QC roles. It shows the relationship and lines of 

communication among all project participants, including those from EPA.

Ms. Lori Weiss, the 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 direction 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 Corporate 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.
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Figure 2-1. Project-Level QA Organization for ERG’s Support for the CBM Rulemaking

ERG Corporate

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 Authority
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2.2

Project team members who collect existing data for the CBM Rulemaking will have read 

this QAPP and relevant background documents (e.g., CBM Detailed Study Report) to ensure that 

they have the necessary background 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 search 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 (CBI) 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. ERG’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 ERG’s CBI security plan (or 

successor 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 ERG’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 centralized 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.”
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At the conclusion of the rulemaking, all electronic project 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 responsible 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 an MS AccessTM database. This system is 

compatible with the needs of the Federal Docket Management System (FDMS). The ERG 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 review, 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 this 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) checks on 

calculations and data quality and (2) reviews 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 final product technical review of all deliverables prior 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 activities) 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 project. 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 staff have developed QC procedures and that these 

procedures are used; and
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— That project staff are documenting their use of these QC procedures by 

completing checklists, review spreadsheets, 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.

Any quality deficiencies (e.g., insufficient QC review, incomplete documentation)

detected by technical reviewers or the Project QA Coordinator will be communicated, in writing, 

to the ERG WAM. The ERG WAM is responsible for ensuring that appropriate corrective action 

is 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 stopped 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 

documents 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) activities. 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. 

ERG will describe QA activities conducted for major deliverables, such as summary 

memoranda, 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 completed existing data and QA databases 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.
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3. PROJECT DESCRIPTION AND OBJECTIVES

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 how ERG will use the data by developing data summaries or 

engineering analyses; and 

• Section 7 describes the project deliverables. 

3.1

Based 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 

— Management practices for produced water; and

— Produced water treatment technologies.

During the Detailed Study, EPA collected 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, EPA-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) Produced 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 water. (This work is 

partially funded by the U.S. Department of Energy and industry partners.) ERG will explore the

304(m) dockets, the NAS report, and CSM information and computerized modules (e.g., 

Beneficial Use Economic Module (BEM) at

http://aqwatec.mines.edu/produced_water/tools/modules/buecon/index.htm).

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

matrix” to identify 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 identify areas that have incomplete and or out-dated information 

(“data gaps”). After receiving EPA concurrence that additional information is required, ERG 

will support EPA in searching for and collecting additional data.
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3.2

Depending on EPA’s identification of data gaps, ERG’s supplementary 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 

(both 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 available data with additional existing data collected during the 

CBM rulemaking to support estimates 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 environment. This will be an iterative process driven by the evaluation of existing data and 

this 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 database Spring 2012

Data analyses documents TBD

Final report, including descriptions of data sources, summary of 

technical reviews, and summary of all QC activities performed to 

date

Fall 2012

TBD: To be determined as data analyses are requested by EPA.
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4. DATA NEEDS, SOURCES, AND QUALITY CRITERIA

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 matrix:

Data Needs

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

• Survey questionnaire data;

• Reports from industry, academia, peer-reviewed journals, 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;

• Information 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 technologies 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 include 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 geographic 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 technical reports. ERG will obtain the cost information needed for 

this project from contacts with equipment vendors and vendor websites, as well as from data 
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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, government 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.

• Find 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 

literature, 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 of state

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:

• Obtain current (e.g., 2001 - 2011) cost information from process and equipment 

vendors that serve areas where CBM operations occur; 

• Consult the Energy Information Administration (EIA)2

• Consult RSMeans® for labor and construction costs; and

website for information 

about the cost of electricity, gasoline, and diesel fuel; 

• Attempt to obtain project costs from CBM operators for similar projects 

completed for CBM 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. 
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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 other 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 published 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 

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

4.3

This QAPP is intended to ensure that the existing data collected for the CBM rulemaking 

are of known quality such that EPA can decide if they are of the quality necessary to support 

effluent guidelines development. 

Data Quality Criteria and Specifications

This section presents how ERG plans to evaluate the existing data collected for this 

project and the criteria used to evaluate the quality of these data. Acceptance criteria 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;

• Characterization of produced water treatment system performance/efficiency; and 

• Estimation of cost of treatment.

ERG will use the criteria in Tables 4-1 through 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, 

EPA 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.
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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 2001 or after. 

• Because CBM is a relatively new industry, ERG may 

use information from sources prior to 2001 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 

direction on how to incorporate or exclude the data in 

analyses.

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 of 

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, questionnaire data) to confirm 

the information is reasonable based on documented 

CBM practices. This comparison will be presented in 

the QA sections of major deliverables.
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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).

• Source 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 information 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 

(“characterization 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.
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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.

• Costs per year basis is reported. ERG will convert all 

costs to a standard year basis using RS Means®

Construction Index or other standard cost index

approved by EPA.

Representativeness Appropriate for actual CBM 

locations

• Reflect the costs for equipment, including 

transportation and installation, supplies, operating 

costs (e.g. electricity, fuel, labor, chemicals), 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 operations.

• Cost trends follow the design basis trends (e.g., costs 

for large produced water volumes are greater than the 

costs for small volumes).

5. DATA ACQUISITION, REVIEW, QUALITY VERIFICATION, AND REPORTING

This section describes how ERG will acquire the existing data needed to answer the key 

questions listed in Section 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 uses of 

these data sources are discussed in Section 6. 
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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 will use the following procedures 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. ERG 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 bibliographic information for the source as well as information 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 rulemaking 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 explained 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. Following 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 following procedures to document data collected via telephone and 

email contact.

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 researchers will ensure that telephone contact reports and email records are 

added to the CBM Project File.
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Figure 5-1. Telephone Contact Report Form

ERG staff will use the existing data tracking database to generate 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 document 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. The 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 AccessTM 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 publications 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 Name: 

Phone No.: 

Name: 

GENERAL SUBJECT : 

TOPICS DISCUSSED AND ACTION TAKEN
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the publication file to the CBM 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 regulatory database per direction from the EPA WAM. 

If ERG is tasked with adding 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 primary 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-house 

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 file will be checked as described in the Project File 

Management Plan, which include 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 part 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 spreadsheet 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 ERG will determine if collected existing data meet the data acceptance criteria 

specified in Section

Data Quality Verification

4.3 ERG will document data quality by completing the existing data tracking 
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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 evaluated the quality of the collected existing data. To evaluate comparability, ERG will 

compare any existing data used in analyses 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 other 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 describe 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 need to use data that did not meet quality 

acceptance specifications, in major deliverables that rely on such data.

6. USE OF EXISTING DATA

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

the information contained in the source. Based on direction from EPA, ERG may use the existing 

data collected under this QAPP to 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 ensure that 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.
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ERG will document the use of existing data for project analyses in memoranda that 

include:

• Purpose of analysis;

• Description of analysis methodology;

• Data sources used;

• Criteria used to select the data sources;

• Exceptions to the criteria and rationale for exceptions; and

• Documentation of assumptions and equation.

7. PROJECT REPORTS (DELIVERABLES)

Table 7-1 lists the 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 describe the information 

each database contains and how the three databases are linked.

Existing data tracking database • List of all sources obtained from the existing data collection, including

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 • Description 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. REFERENCES

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, 2002a. U.S. Environmental Protection Agency. Guidance for Quality Assurance 

Project Plans QA/G-5. EPA/240/R-02/009. Office of Environmental Information. March 

2001. 

5. EPA, 2002b. U.S. Environmental Protection Agency. Guidelines for Ensuring and 

Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated 

by the Environmental Protection Agency. EPA/260R-02-008. October 2002. 
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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/B03/001. 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).
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Appendix A

PROJECT FILE MANAGEMENT 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 8-37

i

TABLE OF CONTENTS

Page

1.0 INTRODUCTION AND DEFINITIONS.........................................................................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 File..............................................................................1-3

1.6 Contract File.............................................................................................1-3

1.7 Personal Files...........................................................................................1-4

1.8 Project File 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 GENERAL PROCEDURES ........................................................................................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 QUALITY CONTROL PROCEDURES.........................................................................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 DOCKET ASSEMBLY..............................................................................................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 FIELDS
1-1

1.0 INTRODUCTION AND DEFINITIONS

This document is a plan for the preparation 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 accordance 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 Background

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 appropriate 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.

EPA 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 industrial survey. 

EPA tasked PG Environmental, LLC, (PG) with supporting the Agency in its Detailed Study 

under Work Assignment 2-01 of Contract No. 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 database, 

estimating pollutant discharges, and assessing the costs and benefits of regulatory alternatives.

1.2 Coalbed MethaneProject File

The Coalbed Methane project file will contain items that are collected or 

developed during the development of the Coalbed Methane 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 potentially 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 briefing packages and project plans;

• “Deliberative” items, including memoranda from ERG to EPA that present 

regulatory alternatives;

• Drafts of Site Visit Reports and Sampling Episode 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 materials;

• 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 plans, 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 purposes. 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 Docket

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 notices, any public 
1-3

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 Federal 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 publicly 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 server.

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 review 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

Personal 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 of 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. See 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 information 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 Business 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 available 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 locked 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 document 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 containing 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, documents 

containing CBI-deducible information will be sanitized prior to their placement in the public 
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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 version. The EPA WAM will approve ERG’s sanitization 

plan prior to ERG performing the sanitization steps. ERG will deliver the final sanitized 

document as a CBI document. The EPA WAM will review the document to confirm all CBI has 

been removed and approve the release of the document into the nonCBI public docket. The 

original non-sanitized version of the document will be maintained as a CBI document.
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2.0 GENERAL PROCEDURES

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 physically placed in the Coalbed Methane archive 

filed by record section. Within each 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 the 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 steps 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 project file, 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 Submitting 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 

PDF. If the document is hard copy, either scan the document in as a pdf or 

request assistance from ERG docket staff for scanning support.
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2. Complete an electronic project file log-in form (see Attachment 2) using 

the instructions below.

• DCN: Leave this entry 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 document. 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 Department, 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:
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 CBI_Document Title;

For Placeholder submittals, use the format:

 PLACHOLDER: Document Title.

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

the 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 sheets, 

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. Choose 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 figures 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 data 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 

announcements 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 example, if a document file is not included because it is CBI or a duplicate of another document).
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Sub-Type Description

Interagency Review Draft materials 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 both 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 reviewed 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 others 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.

Report 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 function.

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 company/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 methodology. 

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: Name of the individual who authored, edited, 

compiled or wrote the memorandum, report, study, article, or book.

Author Name is limited to 25 characters. For documents with 

multiple authors, use the format: Bartram, Deborah, et. al.
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• Author Affiliation: The affiliation of the author. For documents 

written by ERG staff, use the format: Eastern Research 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 month. 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, include 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 to 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 volume 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 in above format is longer than 150 characters, just 

put the website. If the copyrighted document is a journal article, 

use the format:

 Journal Article: Nature 393(2002):639-40; or
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 Article in Electronic Journal: JAMA. 287, no. 5 (2001), 

http:/jama.ama-assn.org/issues/v287n5/rfull/joc10108.html 

(accessed January 7, 2002).

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 at the beginning of the title. If the entire document is nonconfidential 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 metadata 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, refer 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 included 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 items 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 

document 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:
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• A non-CBI electronic file, email the file and the log-in form to the

index keeper. 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 index 

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 the 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 biweekly 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 also 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.
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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 save 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 project-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 index keeper to make. The project file section lead will 
2-9

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 will 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 audits 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 file 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 official 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 an 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 electronic 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 keeper 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, SE00066.pdf will be the electronic 

version of document SE00066. If a DCN is comprised of multiple documents, a folder will be 
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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 main document that will keep the DCN as the 

filename. In addition, the attachments to the main document 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 additional documents will

be SE00066A01.pdf, SE00066A02.pdf, and SE00066A03.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 log-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 file 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 transmittal 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 not 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 files on compact disk (CD) or digital 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 the ERG Coalbed Methane archive, similar to hard 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 Coalbed Methane archive in pouches/envelopes attached to the project file item file 

folder.

Internet website material. 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. The 
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index keeper will convert any html files to pdf and add the electronic version to the electronic 

project file.

E-mail correspondence. 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 protected material. 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 copy of the 

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

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

be available in the docket office for public review. For ERG’s project files, copyright protected 

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

Hard-copy items. Items that are only available in hard copy format must be 

converted to an electronic file, typically 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 NPDES 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

 Abstract 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 EPA WAM to assign to materials 

received or generated at EAD. Each DCN will consist of CBM, five digits, and extensions (e.g., 

CBMXXXXX).

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 parent 
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document with an extension added to designate the appendix. For example, CBM05011A01 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 document 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 unique 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_00661.pdf).

2.3 Project File Index

The project file index will list all project file items. The index will be maintained 

using Microsoft Access® 2007 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. 

These 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 keeper as described below. An asterisk (*) 

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

• *Author 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

• Confidential Business Information (Y or N)

• Keyword 1 and Keyword 2

• Electronic Copy File 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 character 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 

Methane 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 assigning DCNs:

 DCN CBMXXXXX;

 Attachments to the DCN will be DCN CBMXXXXXA01, DCN 

CBMXXXXXA02, 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 field.
3-1

3.0 QUALITY CONTROL PROCEDURES

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.

Review 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 

documentation (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 submitting 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) will 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 ERG 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 

section 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 once 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 missing fields, duplicate DCNs, duplicate 

entries, and typos.

• 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 copyright 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 example, 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 protected.

• 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 Methane 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 information;

• 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 each 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.) have 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 identification 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 DOCKET ASSEMBLY

The Coalbed Methane project file supports revisions to the Coalbed Methane 

ELGs. EPA opens a new docket for each proposed rulemaking effort. The Federal Register (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 Federal Register 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 have 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 

access 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 documents as “Pending Post.” The documents 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. Once 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, metadata, and document) by moving it to an FDMS area called 

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. Because 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 documentation. 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 and uploading 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 the 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 

document 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 submitting 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 document” 

wizard for this process.

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

FDMS:

− CBI documents,

− Copyright protected publications,

− Databases and large spreadsheets, and 

− Other materials as directed by docket staff.

• Assign 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 ERG 
4-3

Work Assignment Manager 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. Assign 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 

keeper, who will obtain the correct PDF from the ERG WAM or project 

team member, as appropriate. The ERG Work Assignment Manager 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 electronic 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 metadata.

• Prepare hard copy material for docket submittal, if necessary. The index 

keeper will try to convert hard copy material into 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); and 

– 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 number;

– 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 folders. 

• 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, Washington, D.C. 20460. 
Attachment 1

COALBED METHANE PROJECT FILE OUTLINE
A1-1

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 (Description of treatment technologies of 

equipment, including vendor information.)

1.4 Other Literature (Pollutant descriptions, process chemistry, toxicology 

information, pollution and environmental concerns, and newspaper and 

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 (Long-term monitoring data submittals; does not

include data submittals with questionnaire.)

2.1.2 Treatment Data (Pilot- and bench-scale studies or treatment 

performance data submitted by operators or vendors)

2.1.3 Other Submissions (Other industry and industry trade association 

technical data submissions, discharge data, treatment data, and 

performance data specific to Coalbed Methane plants not included 

elsewhere.)

2.2 Questionnaire Data

2.2.1 Development Files (Draft and final questionnaires, ICR, FRN and 

comments, and FAQs.)

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

mailout instructions/tracking.)

2.2.3 Coalbed Methane Questionnaire Responses (Review/coding and 

helpline guidelines, original and review copy, and helpline/review 

telecons and emails.)

2.2.4 Electronic Questionnaire Databases (Database development, 

data entry program, data element dictionaries, and tables/queries.)
A1-2

2.3 Site Visits

2.3.1 General/Development Items (Development files for site visits, 

including plant selection.)

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

documentation, 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 (Development files for sampling, 

including plant selection, generic SAP, and SER templates.)

2.4.2 Methods (Methods optimization work and method SOPs.)

2.4.3 Analytical Database

(Each episode section will contain planning documentation, site-specific 

SAP, data collected from the site, the 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 for 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 includes 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 data interpretation tasks.

4.0 OPTIONS ANALYSIS

4.1 Engineering Costs 

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 Loads

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 documentation.)
A1-3

4.3 Non-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 (TO BE 

PROVIDED BY EPA'S ECONOMIC LEAD. INCLUDES 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 lead.)

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 FORMS
A2-1

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 Sheet
A2-2

COALBED METHANE ELECTRONIC PROJECT FILE 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_COUNT:

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 FIELDS
A3-1

Guidelines for Free 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 user 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 combinations. 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, capitalization, 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 writing 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 the 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 save 
A3-2

space and time, (3) to replace 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

Summary 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 affiliations, 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 terms 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 Company

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 should 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. coli
A3-3

Guidelines for Abbreviations

Titles 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. Howe, 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 

capitalization 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 

parentheses 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

Acronyms 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, USA

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 Shore
A3-4

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

Table 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 Processing

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 Dell 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 numbers 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 for 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 died.

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 1st of January, 2003 

Dates may be represented in figures when not 

in narrative format but 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 percent

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-03-12456
A3-5

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 following 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 ZIP 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 the 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 used 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.

the 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 parentheses.

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 before.

The Hazards of Benzene: An Inhalation Study

Colons introduce items in a series. Please reference the following dockets: OAR2002-0012, OAR-1999-0014, and OW-2001-

0142.
A3-6

Guidelines for Punctuation

Colons separate elements in set formulas such 

as ratios, time, volume and page references, 

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 an 

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 and 

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 showing 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 the 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 NEEDS QUESTIONS
Revision 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 coal 

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 produced 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 practices 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 radius, 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 produced 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?