### MEMORANDUM

**TO:** Project Record **FROM:** EPA **DATE:** 02 April 2013 **SUBJECT :**  **Quality Assurance**  **Activities During the Review o**  **f the**  **Engineering Portion**

**of the Detailed Questionnaire for the**  **Coalbed Methane (CBM) Extraction**  **Sector and the Development of the**  **Detailed Questionnaire Databases** EPA distributed the Detailed Questionnaire for the Coalbed Methane (CBM) Extraction Secto r 1 (Detailed Questionnaire) to 10 5 out of 251 CBM operators (U.S. EPA, 2009a) . The Detailed Questionnaire comprises the engineering portion (Parts A and C) and the eco nomic portion (Part B) . EPA received responses from 88 operators in hardcop y format, which EPA reviewed and compiled in several Detailed Questionnaire databases for subsequent industry anal ys es. Table 1 summarizes the information requested in the Detailed Questionnaire. **Table 1**  **. Summary of Information Requested in the Detailed Questionnaire for the**  **CBM Extraction Sector Part A: CBM Projects**  **2 Selected for Questionnaire and Certification**  Section 1

– Project Identification I dentifies the projects and wells associated with the operator and determines whether the operator responded to the S creener survey 3 . (U.S. EPA, 2009b) **Part B: Financial and Economic Information** Section 1

– Contact Information I dentifies a contact for the financial and economic portion of the questionnaire. Section 2

– Firm - level Financial I ncludes firm - level financial information at the lowest corporate level (i.e., the immediate owner or operator). Section 3

– Project - level Questions I ncludes project - specific financial information from the operator w ho manages the day - to - day

operations of the project. **Part C: Produced Water Managem ent**  **Syste m**  **(PWMS) Inform**  **ation** Section 1

– General Operator Information I dentifies a contact for the technical portion of the questionnaire. Section 2

– PWMS General I ncludes project - specific information on the components and costs of the produced water management system that is used for the project.

1 E PA used the information collected from the CBM industry in the Screener Questionnaires to select a sample of operators and projects required to comple te the Detailed Questionnaire. The statistical sampling plan is located in the CBI docket . (Batelle, 2009) 2 EPA identified the primary unit of analysis for the CBM industry as a “project,” defined as a well, group of wells, lease, group of leases, or recognized unit that is operated as an economic unit when making production decisions. 3 The Screener requested operators to verify small business status; CBM operations in 2008; and number of projects operated. For each project, the Screener requested for calendar year 2008 the number of wells, gas production, and produced water management methods.Memorandum

April 2 , 2013 Page 2 **Table 1**  **. Summary of Information Requested in the Detailed Questionnaire for the**  **CBM Extraction Sector** Section 3

– Detailed PWMS and Treatment I ncludes project - specific information related to the discharge and treatment practices of the produced water management system. Section 4

– Produced Water Quality Data I ncludes water quality data submitted by the operator, w hich may include data for untreated produced water, treated produced water , and outfall discharges. This memorandum describes the review and database development activities for the engineering portion of the Detailed Questionnaire (Parts A and C) 4 . ERG, EPA’s contractor for the engineering portions of the CBM rulemaking, conducted the questionnaire review and database development according to the Quality Assurance Project Plan for the Review and Data Entry of the Engineering Portions of the Coalbed Methane Questionnaire (Questionnaire QAPP) approved on July

13, 2011 (U.S. EPA, 2011) . ERG received hardcopies of the Detailed Questionnaire from EPA in May 2011. EPA had completed some initial follow - up with operators upon receipt of the questionnaires ; however, upon EPA direction, ERG did not contact operators during the questionnaire review . This memorandum discusses the steps ERG took to review the qu estionnaires and develop a database. Section 1 discusses the questionnaire review procedures, Section 2 discusses the development of the engineering database, Section 3 discusses additional updates to the data and Section 4 discusses the data quality of the Detailed Questionnaire responses and database . **1.0 R** **EVIEW OF THE E**  **NGINEERING P**  **ORTION OF THE D**  **ETAILED Q**  **UESTIONNAIRE (P** **ARTS A**  **AND C)**  Table 2 summarizes EPA’s distribution and receipt of the Detailed Questionnaire responses. Attachment 1 includes the full list of operators that received the Detailed Questionnaires. Table 3 summarizes the quality control (QC) activities ERG performed during the review . The following subsections describe ERG’s procedures for ensuring quality during review o f the engineering portion of the Detailed Questionnaire.

4 The review

of the economic portion of the Detailed Questionnaire is described in a separate memorandum, Quality Assurance Activities During the Review of the Economic Portion of the Detailed Questionnaire for the Coalbed Methane (CBM) Extraction Sector and the Development of th e Economic Database . (U.S. EPA, 2013a)Memorandum

April 2 , 2013 Page 3 **Table 2. Summary**  **of Responses to the**  **Engineering Portion of the**  **Detailed Questionnaire Number of**  **Detailed Questionnaires**  Distributed to Industry 114 Indicated Out of Scope

– No CBM wells a 7 Partial or Non - Respondent b 19 Indicated No Produced Water Generated c 3 Engineering Portion (Parts A and C) Reviewed 85 a – The count of out - of

- scope questionnaires only includes those questionnaires that indicated that they do not operate any CBM projects. b

– The count of partial or non - respondent questionnaires only includes those questionnaires that did not respond or only responded partially to all projects for which EPA requested information. Partial questionnaires were not reviewed. c – ERG did not review the Detailed Questionnaires for Part C information for these questionnaires because no produced water was generated in 2008 from any of the operator’s projects. **Table 3. QC Statistics for Review and Data Entry of the Detailed Questionnaire Responses**  **Number of Detailed Questionnaires**  **Percent Reviewed** Initial Technical Review 85 100% Second Technical Review a 31 36% c Data Entry

into Engineering Database 85 100% Data Entry Review b 63 74% c a – Second technical review of the Detailed Questionnaire was conducted by a senior staff member familiar with the CBM Detailed Questionnaire, the CBM industry, and the issues operators had completing the questionnaire. b

– Data entry review was conducted by a technical staff member familiar with the technical review (either as initial reviewer or second reviewer). c – Meets Questionnaire QAPP criteria for review of at least 25% of the detailed questionnaire. **1.1 Log**  **- in**  **and Tracking Procedures**  E RG developed a tracking database ( Questionnaire Review Tracking database) to document the receipt, review , data entry , and data processing activities of the engineering portions of the Detailed Questionnaire . The tracking database table contain ed the following fields:

 Operator ID (O ID) ;  Reviewer name;  Date review completed;  S econd reviewer name;  Date second review completed;  Second review issues found;  Indication of whether the questionnaire is ready for data entry;  Data entry

date;Memorandum

April 2 , 2013 Page 4

 Data entry reviewer name;  Data entry

issues found;  Date data entry

review complete ;  Indication of whether additional data processing is needed for attachments that included: o Diagram; o Well identification number s ; o Permit and outfall information ; and o Pollutant data. Section 2 .0 di scusses the attachment data processing in greater detail . EPA gave respondents the option to claim answers to specific questions as CBI by marking question - specific indicators in the Detailed Questionnaire or to claim all eligible data CBI b y marking the “ allCBI” box at the beginning of the Detailed Questionnaire. During the review of the Detailed Questionnaire, ERG handled all questionnaires as CBI, as specified in the Questionnaire QAPP. **1.2 Review**  **and Coding of Survey Responses** ERG reviewed the responses to the engineering portion of the Detailed Questionnaires. To preserve the submitted versions, E RG created review copies of the Detailed Questionnaires and marked them according to the I nstructions for R eview and C oding of the CBM Detailed Questionnaire (Appendix A in the Questionnaire QAPP) . The instructions provided question specific guidance on checking the reasonableness and completeness of the responses and correcting them as needed. During review, E RG made corrections so that responses were internally consistent within the questionnaire. For example, E RG c orrected water volumes for a project to match the block diagram or to match the total and individual project flows reported elsewhere in the questionnaire. In addition to noting the change on the working cop y, E RG documented all issues found with the questionnaire and any technical changes made to the questionnaire on the Coalbed Methane Review Form (Form B). Where the water volumes reported in the Detailed Questionnaire were not consistent across general, destination, and treatment questions , E RG calculated the percent different and noted on Form B where reported water volumes were more than 10 percent different. E RG conducted a second technical review of at least 25 percent of the D etailed Q ue stionnaire s. E RG targeted second reviews on questionnaires that operated produced water management sy stems (PWMS s ) that discharged to surface water . ERG documented the issues found during second review in the Questionnaire Review Tracking Database. The initial technical reviewer resolved any i ssues from second review and noted any additional changes to the questionnaire on the review cop y and Form B. ERG also coded the responses during review to ensure the y could easily be entered into a database. Us ing the Instructions for R eview and C oding of the CBM Detailed Questionnaire , ERG used the following codes:

 Illegible response: - 666Memorandum

April 2 , 2013 Page 5

 Unknown (respondent wrote in unknown): - 777  Not applicable: - 888  Respondent left a required response blank: - 999 **1.3 Data**  **Entry and Database Development** The CBM engineering survey database is a confidential database that is located on EPA’s CBI docket (U.S. EPA, 2013b) . ERG developed the engineering database to house the questionnaire responses and construct ed tables that f ollowed the design of the Detailed Q uestionnaire. ERG also developed data entry forms to facilitate data entry and ensure all data for an operator was linked together properly across multiple tables. The memorandum, Summary of Confidential Business Information Claims in Industry Responses to EPA’s CBM Screener Surveys and Detailed Questionnaires and Industry Data Available in the EPA Docket, describes EPA’s decision to maintain this database in the CBI docket (U.S. EP A, 2013c ). The database dictionary provides a description of the tab les and data fields contained in the database ( EPA, 2013 d).Because EPA received most of the responses to the D etailed Q uestionnaire s in hardcop y , ERG manually

entered all responses to the Detailed Questionnaire s into the engineering database , including all corrections, coding, and documented changes noted in Form B. A data entry reviewer other than the data entry p erson checked the data entry . E RG performed a second review of at least 25 percent of the Detailed Questionnaires entered into the database by visuall y comparing all the information contained in the database to the review cop y . E RG internally tracked the data entry

and data entry

review in the Survey

Review Tracking database. After E RG completed data entry of the Detailed Questionnaire s , E RG performed database clean - up and standardization activities to facili tate subsequent data anal ys es. The following subsections describe these activities. **1.3.1 Database Field Updates**  E RG compil ed a crosswalk based on primary key fields in the database to identify the operator, project, and pro duced water management sy stem. These primary key fields are automatically

generated numbers in the tables, which are used to facilitate query development. Using this crosswalk, E RG developed queries and modules to perform the datab ase updates described below. ERG checked the resulting database tables to ensure the values were updated properl y and documented the review in a QA documentation table located in the database. 1. CBI indicators

– The database contained question - specific CBI fields and the allCBI field, which E RG transcribed from the hardcopy responses to the Detailed Questionnaire. Respondents that indicated that all data were CBI (marked allCBI in Detailed Questionnaire) may or may not have checked CBI for th e question specific CBI fields. For Detailed Questionnaires marked as allCBI, E RG used the allCBI indicator in the database to update the question - specific C BIfields for the questionnaire.Memorandum

April 2 , 2013 Page 6 2. Standard units

– Many of the questionnaire fields allowed respondents to enter their own value for the units for flow, volume, and frequency . Therefore, the database contain ed a variety of units for these responses (i.e., barrels, bbls, bbl, gallons, gal). E RG created two new data fields for each numeric entry with a free response unit and updated the value and the units to standard units. For example, if a respondent reported a value in gallons, a new field was added to show the response in units of barrel s. Table 4 shows the standard units used in the database. **Table 4**  **. List of Standard Units in**  **the Engineering Database**

**Standard Units Description**  Acres Acres acre - ft Acre - feet Bbl Barrel bbl/d Barrel per day bbl/truck Barrel per truck bbl/yr Barrel per year ft3/yr Cubic feet per year ft3 Cubic feet Mil 0.001 inch Tons Tons Yr Year 3. Residuals Table - The residuals table contains responses to Question C3 - 3 of the Detailed Questionnaire, which asks for information related to solids generation during produced water management. E RG r emoved records in the database table that indicate d “None” or “Unknown.” E RG originally replaced these records using the completeness code - 888 indicating the response in not applicable . However, ERG found that some projects that reported “None” or “Unknown” did not have treatment units that would generate a residual. For those projects, ERG removed records from this table because they do not require a response for this questi on. **1.3.2 Comments and Flag Table**  Each section of the questionnaire had a comments section (Questions A1 - 4, C4 - 3) that allowed operators to enter information to clarify their responses. E RG transcribed all comments from the original Detailed Questionnaire into the Comments and Flags table in the engineering database. In addition to the respondents’ comments, E RG also transcribed changes and issues recorded on Form B during survey review . The information stored in the Comments and Flags table includes general comments on operations and costs; qualifiers to the data reported (i.e., less than (<), greater than (>), minimum (MIN) or maximum (MAX) value) ; rationale for the discrepancies in the values reported; and data related to specific questions in the D etaile d Q uestionnaire . To organize the information in the Comments and Flags table, ERG added categorical fields including fields to link to the operator, project, or question number and fieldsMemorandum

April 2 , 2013 Page 7 to distinguish between general questionnaire comments and documented changes of the questionnaire responses. **2.0 EPA**  **R EVIEW AND**  **P ROCESSING OF**  **D ETAILED**  **Q UESTIONNAIRE**  **A TTACHMENTS**  CBM operators may

have included the following supplemental information in attachments to their Detailed Questionnaires :

 Lists of wells included in each project (for operators with large numbers of wells);  Narrative descriptions or block diagrams of projects and PWMSs;  Permit files and outfall information; and  Produced water pollutant data. E RG noted whether each questionnaire contained the attachm ents listed above using ye s/no fields in the Questionnaire Review Tracking Database. Operators provided the supplemental inform ation in various data formats. To minimize errors in transferring the data to the database, ERG used the following general proced ures:

 For supplemental information that operators provided in electronic format, such as Excel files , ERG formatted the information and imported this information directly into the database.  For PDF attachments, ERG used text recognition software OmniPage® to copy and paste the information into Excel, format the tables, and then import the table(s) into the database.  For hardcop y attachments that ERG could not process through OminPage®, ERG ty ped the data into an Excel spreadsheet then visually c hecked the hardcopy

and the electronic data for transcription errors. After this check, EPA imported the table(s) into the database. ERG processed supplemental information from the Detailed Questionnaires, as summarized in Table 5. ERG checked that the data imported correctly by checking the record counts and number of fields imported. All original copies of the Detailed Questionnaire will remain in the operator’s hardcop y questionnaire file.Memorandum

April 2 , 2013 Page 8 **Table 5. Data Processing Procedures for Detailed Questionnai re Attachments of**  **Supplemental Information Supplemental**  **Inform ation**  **Detailed Questionnaire**  **Response Data Processing Procedures**  Wells Question A1 - 3 Used general procedures to add information to the engineering database for all projects. Narratives Question C2 - 1 Used general procedures to add information to the engineering database for projects submitting narratives. Operators had the option to include a narrative or process diagram. Process Diagrams Question C2 - 1 Scanned diagrams into PDF and save d in supplemental folder on ERG’s network. Operators had the option to include a narrative or process diagram. Permits and Outfalls Question C3 - 4 Used general procedures to add information to the engineering database for all discharging projects. Non - discharging projects do not discharge to surface water and thus, no discharge permit, Pollutant Data Questions C3 - 4c and C4 - 1 Used general procedures to add information to the pollutant

database for operators that have discharging projects. Suppleme ntal pollutant data from non - dischargers were not im ported. ERG stored pollutant data in the CB I Pollutant D atabase ( EPA , 2013 e ). **3.0 A** **DDITIONAL U**  **PDATES TO THE D**  **ETAILED Q**  **UESTIONNAIRE R** **ESPONSES** In addition to questionnaire responses , E RG incorporated additional information into the engineering and pollutant databases. This section discusses how E RG obtained this information and added it to Detailed Questionnaire responses contained in these databases. **3.1.1 Obtaining**  **Discharge Monitoring Data to Supplement**  **Pollutant Data Submitted with the Detailed Questionnaires**  ERG extracted the list of National Pollutant Discharge Elimination Sy stem (NPDES) permits reported in Question C3 - 4a of the Detailed Questionnaire and checked the list of permits against available discharge data through EPA’s permit compliance s ys tem ( IC IS - NPDES ), which houses discharge monitoring report (DMR) data for primaril y major dischargers . However, because most CBM operators are minor dischargers, E RG onl y identified DMR data for a few Detailed Questionnaire respondents . E RG extracted the DMR data from ICIS -NPDES and imported them as a separate ta ble in the pollutant database. A second reviewer checked that the data imported completely into the database by

checking the number of records and fields imported into the table . Additionally , E RG received DMR data from the Wyoming Department of Environmental Quality (WYDEQ) and from the Alabama Department of Environmental Management (ADEM) , which include s discharges from CBM projects not included n I CI S -NPDES . ERG imported the DMR data from these two states into separate tables in the pollutant data base. A second reviewerMemorandum

April 2 , 2013 Page 9 checked that the data imported completel y into the pollutant database b y checking the number of records and fields imported into each table. The database dictionary for the pollutant database provides a description of the tables and fields included in the database (EPA, 2013 f ). **3.1.2 Updating Discharge Destinations**  **in the Engineering Database for Projects Reporting**  **POTW or Third** 

**- Party**  **Disposal** E RG evaluated the discharge destinations for projects indicating discharge to a POTW or third party

in Question C3 - 1 to confirm the discharge status for the se projects. EPA intended this response to include onl y indirect discharging projects; however, during the course of its review, ERG determined a need to further investigate the treatment facilities that operators reported to receive their produced water. Some operators may have used this response to reflect the transfer of water between projects or may have reported third - party facilities that may not discharge to surface water. Operators reporting discharge to POTW or third party completed Question C3 - 5, which asked for the name of the facility receiv ing their produced water and whether it was a POTW 5 , PrOTW 6 , or other ty pe of facility . Twenty - four responses indicated discharg e to a POTW or third party . E RG reviewed publicly

available information on the facilities reported in Question C3 - 5 to confirm discharge practices at the facility and to distinguish projects that conveyed the produced water to 1) a POTW , PrOTW, or CWT 7 , or 2) another CBM operator that us es surface discharge for final disposal , or 3) a third - party that does not discharge to surface water . This information was needed for EPA’s rulemaking analy ses. Table 4 summarizes the number of projects originally

reporting “POTW/third party” responses in the Detailed Questionnaire and ERG’s reassignment of discharge destinations for these projects . Based on ERG’s review, onl y four projects discharge to a POTW, PrOTW, or CWT; seven projects discharged produced water through another CBM project; and eleven projects sent their produced water to facilities that were classified as zero discharge facilities. ERG could not confirm discharges practices for two projects. ERG assigned a revise d destination for these projects in the engineering database , which EP A used for subsequent industry analy ses. The CBI attachment EPA Review of Produced Water

5 Publicly Owned Treatment Works - Any device or system owned by a state or municipality that is used to recycle, reclaim, or treat liquid municipal sewage and/or liquid industrial wastes 6 Privately Owned Treatment Works - Any device or system ow ned and operated by a private entity and used for storage, treatment, recycling, or reclamation of liquid industrial wastes. 7 Centralized waste treatment facility - A facility that treats any hazard ous or non - hazardous industrial wastes, hazardous or non - hazardous industrial wastewater, and/or used material received from off - site. The definition of centralized waste treatment facility includes both facilities that treat waste received exclusively from off - site and facilities that treat wastes generated on - site in combination with waste received from off - site - note that the CWT guidelines do NOT apply to operations at facilities which are subject to existing national effluent limitations guidelines and standards and which receive wastes from off - site for treatment or recovery that are subject to the same national effluent limitations guidelines and standards as the on - site generated wastes.Memorandum

April 2 , 2013 Page 10 Treatment and Disposal details ERG’s review of projects reporting POTW/third - party and the reassignment of discharge destinations for these projects (EPA, 2013 g).

**Table 4**  **. Summary of Projects in**  **EPA ’s Review of POTW and Third**  **** **Party Dischargers Reported**  **POTW or Third**  **- Party**  **Discharge Discharged**  **to**

**CWT or PrOTW/POTW**  **Transferred to**

**a Third -**  **Party that**  **Does Not Discharge**  **Transferred to** 

**another CBM Project**  **that Discharges to**  **Surface Water Discharge** 

**Unknown** 24 4 11 7 2 **3.1.3 Updating**  **Surface Water Destinations for Wyoming CBM Projects**  Generally , CBM projects that hold a discharge permit are allowed to discharge to surface water and would 1) indicate in the Detailed Questionnaire that they discharge to surface water in Question C3 - 1 and 2) list the discharge permits held by the project (C3 - 4a) . EPA used this information to identify

projec ts that discharged CBM produced water to surface water. Wyoming CBM discharges are permitted differently than most other states. Based on discussions with the Wyoming Department of Environmental Quality (WYDEQ), Wyoming issues several types of discharge p ermits to CBM projects depending on the final destination of the produced water (U.S. EPA, 2012) . CBM projects may discharge via permitted outfalls to surface water or to ponds that are designed to hold the capacity of the produced water without dischargin g to surface water. EPA considered the permitted discharge to self - contained ponds as discharge to infiltration/evaporation ponds, a zero discharge water management method, because there is no discharge to surface water. Because operators using these evapo ration/infiltration ponds hold a Wyoming Pollution Discharge Elimination Sy stem (WYPDES) permit, the operator’s Detailed Questionnaire response may have categorized the project as a discharging project. E RG conducted an additional review of the CBM project s in Wyoming using the state DMR data to determine if the project discharged to surface water in 2008. E RG received 2008 DMR data from Wyoming that included information on the ty pe of permitted outfalls (e.g., direct discharge, discharge to pond) and the discharge volumes from each outfall. EPA included the data in the CBM pollutant database (U.S. EPA, 2013e) and used this information to confirm the following:
 Whether the CBM project discharge d to surface water or to infiltration/evaporation ponds; and
 Wh ether the discharge volume reported in the Detailed Questionnaire accuratel y reflects what is discharged to surface water. E RG summarized these findings in the CBI attachment, EPA Review ofProduced Water Treatment and Disposal

, located in EPA’s CBI docket (EPA, 2013g). Based on these findings,Memorandum

April 2 , 2013 Page 11 E RG updated the responses to C3 - 1 and C3 - 2 in the engineering database. E RG documented these updates to the responses in the Comments and Flags table in the engineering database. **4.0 D**  **ATA Q**  **UALITY OF THE D**  **ETAILED Q**  **UESTIONNAIRES AND E**  **NGINEERING D**  **ATABASE** Table 5 documents the quality acceptance criteria for questionnaire review listed in the Questionnaire QAPP and the results of ERG’s data quality evaluation of the detailed questionnaire responses and the engineering database that houses the se responses . As directed b y EPA, ERG did not conduct follow - up activities during its review of the Detailed Questionnaire responses to improve the completeness or reasonableness of the responses . Subsequent industry anal ys es included the data available from the complete responses.Memorandum

April 2 , 2013 Page 12 **Table 5. Data Quality of Detailed Questionnaire Responses and Engineering Database** 

**Data Elem**  **ent Acceptance Criteria**  **Data Quality Evaluation** Operator - level

– Com

pleteness  Operator is generating produced water and provided the

produced water volumes for their projects.  Operators accounted for all the produced water volume in reporting volumes through their produce water management systems. ERG reviewed questionnaires from operators with projects that generated produced water during CBM extraction. ERG did not review 3 questionnaires because they contained only projects that did not generate pro duced water (no Part C information). ERG reviewed the engineering portion of the Detailed Questionnaires for 85 out of 88 (97%) questionnaires received. All operators reported produced water volumes for their projects. Operator - level

– Reasonableness  Operator responses are consistent throughout the questionnaire. For questionnaires that ERG reviewed, ERG performed question - specific consistency checks on the volumes and costs reported. See Data Quality Evaluation s for Individual Questionnaire Response s. Individual Questionnaire Responses

– Com pleteness  Responses were provided for the question, unless respondent followed a skip pattern that indicated they were not required to answer the question.  Units are defined with the response.  Responses are legible.  Second review of 25% of the questionnaires by ERG WAM or task lead. ERG used Instructions for Review and Coding of the CBM Detailed Questionnaire (Appendix C of the Questionnaire QAPP), w hich provided question specific checks for completeness and rea sonableness. EPA did not pursue additional follow - up calls to industry ; therefore, ERG used available information throughout the questionnaire to review individual responses . Table 6 summarizes ERG’s check on completeness for questions that were used in EPA’s industry analyses, including responses to water production/management volumes and cost questions. Responses that were illegible, unknown or NA, or left blank (but required) were coded according to the instructions and not used in any subsequent EPA analyses. ERG performed a second technical revie w of 31outMemorandum

April 2 , 2013 Page 13 **Table 5. Data Quality of Detailed Questionnaire Responses and Engineering Database** 

**Data Elem**  **ent Acceptance Criteria**  **Data Quality Evaluation** of 85 questionnaires (36%), which meets the QAPP criteria for second review of at least 25% of the questionnaires. ERG tracked initial and second reviews in the Survey Review Tracking Database. Individual Questionnaire Response

– Reasonableness  Responses are within the expected range of results for that response.  Responses are consistent with data reported in other parts of th e questionnaire. ERG used Instructions for Review and Coding of the CBM Detailed Questionnaire (Appendix C of the Questionnaire QAPP), w hich provided question specific checks for completeness and reasonableness. Using the instructions, ERG performed co nsistency checks on the volumes and costs reported in the questionnaire to check that all produced water volumes and costs were included . ERG conducted these reasonableness checks using the engineering database. Table 7 summarizes the results of the consi stency checks . Database

– Com

pleteness and Accuracy  Database contains all questionnaires passing the operator level completeness criteria.  Second review of 25% of the questionnaires by ERG engineering team member. ERG data entered responses from 85 out of 85 questionnaires (100%) into the engineering database (CBM_Engineering.mdb ) . ERG used database entry forms following the Instructions for Data Entry of the CBM Detailed Questionnaire (Appendix D of the Questionnaire QAPP). ERG performed a second re view of the data entry for 63 out of 85 questionnaires that were data entered (74%), which meets the QAPP criteria for at least 25% of the questionnaires. ERG tracked data entry and review in the Survey Review Tracking Database. Database - Reasonableness  Database results are consistent with expected results for questionnaire responses. ERG performed reasonableness checks in the database (summarized in Table 7).Memorandum

April 2 , 2013 Page 14 **Table 6. Completeness of Cost and Volume Questions in the Detailed Questionnaire Question**  **Number Question Description**  **Number of Complete**  **Responses Number of** 

**Expected Responses**  **Percent**

**Complete** C2 - 3a Project - specific produced water v olume 172 172 100% C2 - 3b Project - specific produced water v olume managed

by PWMS 230 231 99% C2 - 4a Percent of total PWMS volume treated that is the

project - specific volume in C2 - 3b 231 231 100% C2 - 4b Percent gas production attributed by wells in this

PWMS 230 231 99% C2 - 5c Cost of contractor/third party operator 43 52 83 % C2 - 6a PWMS cap ital cost 210 231 9 1 % C2 - 7a O peration and M aintenance (O&M) costs 197 231 85% C2 - 7b Annual r evenues from PWMS operations 1 79 231 7 8 % C2 - 8a Total piped v olume 226 231 98% C2 - 8b Piped c ap ital c ost 173 190 91% C2 - 8c Piped O & M cost 171 190 9 0 % C2 - 8d.i Trucked volume 220 231 95% C2 - 8d.v Trucked OM cost 226 231 9 8 % C3 - 1 Destination 321 321 100% C3 - 2 Destination - specific volume 311 321 9 7 % C3 - 2 Destination - specific %PWMS cap ital cost 312 321 97% C3 - 2 Destination - specific %PWMS O & M cost 306 321 95% C3 - 3 Volume of

residuals generated 36 48 75 % C3 - 3 Residuals disposal c ost 32 48 67% C3 - 8 Indicate type of treatment technology 220 231 95% C3 - 9 - C3 - 13 Treatment t echnology volume and cost

information (aggregated to protect CBI) 343 477 72 %Memorandum

April 2 , 2013 Page 15 **Table 7. Consistency Checks of Detailed Questionnaire Responses to PWMS Volumes and Costs**  **Reasonableness Check Number of**  **Complete R** **esponses Number of**  **Expected Responses Percent**  **Complete** All produced water generated by a project is included in the volumes to all the PWMSs for that project . 163 172 95% All the produced water entering a PWMS is included in the discharge/disposal volumes for that PWMS. 2 10 231 9 1 % All the produced water entering a PWMS is included in the volumes piped and trucked to the PWMS . 219 231 95% The percentage of capital costs reported by all discharge/disposal practices for a PWMS totals 100%. 222 231 96% The percentage of operating costs reported by all discharge/disposal practices for a PWMS totals 100%. 190 231 82%Memorandum

April 2 , 2013 Page 16 **5.0 R** **EFERENCES** 1. Batelle, 2009 . Coalbed Methane Study: Comparison of Original to Final Detailed Questionnaire Sample Design. Batelle Memorial Institute. May 27, 2010. EPA - HQ - OW 2010 - 0824, DCN CBM00635. 2. U.S. EPA, 2009a . Detailed Questionnaire for the Coalbed Methane (CBM) Extraction Secto r . U.S. Environmental Protection Agency . October 2009. EPA - HQ - OW - 2006 - 0771, DCN 10072 . 3. U.S. EPA, 2009b . Co albed Methane Industry Screener. U.S. Environmental Protection Agency . 2009. EPA - HQ - OW - 2006 - 0771, DCN 10068 . 4. U.S. EPA, 201 1 . Quality Assurance Project Plan for the Review a nd Data Entry of the Engineering Portion of the Coalbed Methane Questionnaire . U.S. Environmental Protection Agency . July

13 , 201 1 . EPA - HQ - OW - 2010 - 0824, DCN CBM00 691 . 5. U.S. EPA, 2012. Coalbed Methane State Phone Calls. Various Dates an d Contacts. EPA HQ - OW - 2010 - 0824. DCN CBM00678. 6. U.S. EPA, 2013a. Quality Assurance Activities During the Review of the Economic Portion of the Detailed Questionnaire for the Coalbed Methane (CBM) Extraction Sector and the Development of the Economic Database. U.S. Environmental Protection Agency . February 2013. EPA - HQ - OW - 2010 - 0824, DCN CBM 00701 . 7. U.S. EP A, 2013 b . CBM Engineering Survey D atabase (Microsoft Access 2003 database) . U.S. Environmental Protection Agency . February 2013. E PA - HQ - OW - 2010 - 0824, DCN CBM00654 . 8. U.S. EPA, 2013c. Summary of Confidential Business Information Claims in Industry Responses to EPA’s CBM Screener Surveys and Detailed . U.S. Environmental Protection Agency . February

2013. EPA - HQ - OW - 2010 - 0824, DCN CBM00661. 9. U.S. EPA, 2013d . CBM Engineering Survey Database Dictionary . U.S. Environmental Protection Agency . February 2013. EPA - HQ - OW - 2010 - 0824, DCN CBM 00655 . 10. U.S. EPA, 2013 e . CBM Pollutant Data D atabase (Microsoft Access 2003 database) . U.S. Environmental Protection Agency . February 2013. EPA - HQ - OW - 2010 - 0824, DCN CBM00 668 . 11. U.S. EPA, 2013f. CBM Pollutant Data Database Dictionary . U.S. Environmental Protection Agency . February 2013. EPA - HQ - OW - 2010 - 0824, DCN CBM00 702 . 12. U.S. EPA, 2013g . CBI Attachment
- EPA Review ofProduced Water Treatment and Disposal. U.S. Environmental Protection Agency. February 2013. EPA - HQ - OW - 2010 - 0824, DCN CBM00687.Memorandum

April 2 , 2013 Page 17 **Attachment 1**

**Table A -**  **1 . List of Operators Receiving Detailed Questionnaires**  **Basin Operator nam**  **e** Appalachian APPALACHIAN ENERGY Appalachian CNX Gas Company LLC Appalachian COAL GAS RECOVERY LLC Appalachian COAL GAS TRANSPORTATION, LLC Appalachian Dominion Exploration & Production Inc. Appalachian Enervest Operating Co. Appalachian EQT Production Appalachian GEOMET, INC. Appalachian JESMAR ENERGY Appalachian NORTHPORT PRODUCTION COMPANY Appalachian Penn Virginia Oil & Gas Corporation Appalachian RANGE RESOURCES - APPALACHIA, LLC Appalachian RANGE RESOURCES - PINE MOUNTAIN INC. Appalachian RIDGEVIEW GAS COMPANY Appalachian Vitruvian Exploration Arkla CHC ENERGY, LLC Arkla SOUTHWESTERN ENERGY PROD. CO. Black Warrior BLACK WARRIOR METHANE CORP. Black Warrior CHEVRON U.S.A. Black Warrior EL PASO E&P COMPANY, L.P. Black Warrior Energen Resources Corp. Black Warrior HighMount Black Warrior Basin LLC Black Warrior KAVANAUGH ENERGY SERVICES INC Black Warrior ROBINSON'S BEND OPERATING II, LLC Black Warrior SAGA PETROLEUM CORP. LLC Cahaba GEOMET, INC. Cahaba PetroNova, LLC Cahaba Vitruvian Exploration Green River Anadarko Petroleum Corporation Green River DOUBLE EAGLE PETROLEUM CO Green River HUDSON GROUP LLC Green River Merit Energy Company Green River PIONEER NATURAL RESOURCES USA, INC. Green River REDWINE RESOURCES INC Green River Warren E&P IncMemorandum

April 2 , 2013 Page 18 **Table A -**  **1 . List of Operators Receiving Detailed Questionnaires** 

**Basin Operator nam**  **e** Green River Yates Petroleum Corporation Illinois BARGER ENGINEERING Illinois BPI ENERGY, INC. Illinois Pulse Energy Systems Permian/Ft. Worth DIAMONDBACK OPERATING, LP Powder River (MT) FIDELITY EXPLORATION & PRODUCTION CO Powder River (MT) PINNACLE GAS RESOURCES INC Powder River (MT) ST.MARY LAND AND EXPLORATION Powder River (WY) Anadarko Petroleum Corporation Powder River (WY) BILL BARRETT CORPORATION Powder River (WY) BLACK DIAMOND ENERGY INC. Powder River (WY) BLACKSTONE OPERATING INC Powder River (WY) Citation Oil & Gas Corp. Powder River (WY) COLEMAN OIL & GAS INC Powder River (WY) Comet Energy Services LLC Powder River (WY) Continental Production Company, LLC Powder River (WY) Continental Production Company, LLC Powder River (WY) Cosner CBM LLC Powder River (WY) Devon Energy Production Company, LP Powder River (WY) DNR OIL & GAS INC Powder River (WY) DUNCAN OIL INC Powder River (WY) EMERALD OPERATING COMPANY Powder River (WY) FIDELITY EXPLORATION & PRODUCTION CO Powder River (WY) HIGH ENERGY INC. Powder River (WY) HILCORP ENERGY COMPANY Powder River (WY) J.M. Huber Corporation Powder River (WY) JIM'S WATER SERVICE OF CO, INC. Powder River (WY) L & J OPERATING INC Powder River (WY) LORAL OPERATING LLC Powder River (WY) MCCARTNEY ENGINEERING LCC Powder River (WY) Merit Energy Company Powder River (WY) Mountain Hawk Energy Powder River (WY) MTG OPERATING COMPANY Powder River (WY) NORTH FINN LLC Powder River (WY) OPES PRODUCTION INC Powder River (WY) Patriot Energy Resources, Inc.Memorandum

April 2 , 2013 Page 19 **Table A -**  **1 . List of Operators Receiving Detailed Questionnaires** 

**Basin Operator nam**  **e** Powder River (WY) Peabody Natural Gas LLC Powder River (WY) Pennaco Energy Incorporated Powder River (WY) Petro - Canada Resources (USA) Inc. Powder River (WY) PETROX RESOURCES INC Powder River (WY) PINNACLE GAS RESOURCES INC Powder River (WY) PURE PETROLEUM LLC Powder River (WY) REDSTONE RESOURCES INC. Powder River (WY) RESOLUTE WYOMING, INC Powder River (WY) RIM OPERATING INC Powder River (WY) SANDS OIL COMPANY INC Powder River (WY) ST.MARY LAND AND EXPLORATION Powder River (WY) STORM CAT ENERGY (USA) OPERATING CORP Powder River (WY) SUNCOR ENERGY (NATURAL GAS) AMERICA INC Powder River (WY) TREND EXPLORATION I LLC Powder River (WY) Williams Production RMT Company Powder River (WY) WINDSOR GAS DRAW, LLC Powder River (WY) WINDSOR JEPSON, LLC Powder River (WY) XTO Energy Inc. Powder River (WY) Yates Petroleum Corporation Raton EL PASO E&P COMPANY, L.P. Raton PIONEER NATURAL RESOURCES USA, INC. Raton PRESCO Raton Red River Ranch Holdings, LLC Raton XTO Energy Inc. San Juan BENSON - MONTIN - GREER DRILLING CORP San Juan BP AMERICA PRODUCTION COMPANY San Juan CHEVRON U.S.A. San Juan Dugan Production Corp San Juan Gosney & Sons Inc. San Juan HOLCOMB OIL & GAS INC. San Juan Koch Exploration Company, LLC San Juan MANANA GAS, INC San Juan Merrion Oil & Gas Corp San Juan N M & O OPERATING CO San Juan RC RESOURCES CORP San Juan RICHARDSON OPERATINGMemorandum

April 2 , 2013 Page 20 **Table A -**  **1 . List of Operators Receiving Detailed Questionnaires** 

**Basin Operator nam**  **e** San Juan Robert L Bayless Producer, LLC San Juan ROCANVILLE CORP San Juan ROSETTA RESOURCES OPERATING LLC San Juan XTO Energy Inc. San Juan XTO Energy Inc. Uinta - Piceance Anadarko Petroleum Corporation Uinta - Piceance CONOCO PHILLIPS COMPNAY Uinta - Piceance Laramie Energy II, LLC Uinta - Piceance MARALEX RESOURCES, INC. Uinta - Piceance Marathon Oil Company Uinta - Piceance MARION ENRGY, INC. Uinta - Piceance NATIONAL FUEL CORPORATION Uinta - Piceance PIONEER NATURAL RESOURCES USA, INC. Uinta - Piceance SG INTERESTS I LTD Uinta - Piceance WHITMAR EXPLORATION COMPANY Uinta - Piceance Williams Production RMT Company Uinta - Piceance XTO Energy Inc. Wind River Devon Energy Production Company, LP