MEMORANDUM

TO: Project Record

FROM: EPA

DATE: 02 April 2013

SUBJECT: Quality Assurance Activities During the Review of 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 

Sector

1

(Detailed Questionnaire) to 105 out of 251 CBM operators (U.S. EPA, 2009a). The

Detailed Questionnaire comprises the engineering portion (Parts A and C) and the economic 

portion (Part B). EPA received responses from 88 operators in hardcopy format, which EPA 

reviewed and compiled in several Detailed Questionnaire databases for subsequent industry

analyses. 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 Projects2Selected for Questionnaire and Certification 

Section 1 – Project 

Identification

Identifies the projects and wells associated with the operator and determines 

whether the operator responded to the Screener survey3. (U.S. EPA, 2009b)

Part B: Financial and Economic Information

Section 1 – Contact 

Information

Identifies a contact for the financial and economic portion of the 

questionnaire.

Section 2 – Firm-level 

Financial 

Includes firm-level financial information at the lowest corporate level (i.e., 

the immediate owner or operator). 

Section 3 – Project-level 

Questions

Includes project-specific financial information from the operator who 

manages the day-to-day operations of the project. 

Part C: Produced Water Management System (PWMS) Information

Section 1 – General 

Operator Information

Identifies a contact for the technical portion of the questionnaire. 

Section 2 – PWMS General Includes project-specific information on the components and costs of the 

produced water management system that is used for the project. 

 

1

EPA used the information collected from the CBM industry in the Screener Questionnaires to select a sample of 

operators and projects required to complete 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 

Includes project-specific information related to the discharge and treatment 

practices of the produced water management system. 

Section 4 – Produced Water 

Quality Data

Includes water quality data submitted by the operator, which 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 

questionnaires 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 REVIEW OF THE ENGINEERING PORTION OF THE DETAILED QUESTIONNAIRE (PARTS 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 of 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 the Economic Database. (U.S. EPA, 2013a)
Memorandum

April 2, 2013

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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 a7

 Partial or Non-Respondent b19

 Indicated No Produced Water Generated c3

 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 a31 36% c

Data Entry into Engineering Database 85 100%

Data Entry Review b63 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

ERG 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 contained the following 

fields:

 Operator ID (OID);

 Reviewer name;

 Date review completed;

 Second reviewer name;

 Date second review completed;

 Second review issues found;

 Indication of whether the questionnaire is ready for data entry;

 Data entry date;
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April 2, 2013

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 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 numbers;

o Permit and outfall information; and

o Pollutant data.

Section 2.0 discusses 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 by 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, ERG created review copies of the Detailed Questionnaires

and marked them according to the Instructions for Review and Coding of the CBM Detailed 

Questionnaire (Appendix A in the Questionnaire QAPP). The instructions provided questionspecific guidance on checking the reasonableness and completeness of the responses and 

correcting them as needed. During review, ERG made corrections so that responses were 

internally consistent within the questionnaire. For example, ERG corrected 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 copy, ERG

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, ERG calculated the percent different and noted on Form B where reported 

water volumes were more than 10 percent different. 

ERG conducted a second technical review of at least 25 percent of the Detailed 

Questionnaires. ERG targeted second reviews on questionnaires that operated produced water 

management systems (PWMSs) 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 issues from second review and noted any additional changes to 

the questionnaire on the review copy and Form B. 

ERG also coded the responses during review to ensure they could easily be entered into a 

database. Using the Instructions for Review and Coding of the CBM Detailed Questionnaire, 

ERG used the following codes: 

 

 Illegible response: -666
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April 2, 2013

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 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 constructed tables that followed the design of the Detailed 

Questionnaire. 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. EPA, 2013c). The database 

dictionary provides a description of the tables and data fields contained in the database (EPA, 

2013d). 

Because EPA received most of the responses to the Detailed Questionnaires in hardcopy, 

ERG manually entered all responses to the Detailed Questionnaires into the engineering 

database, including all corrections, coding, and documented changes noted in Form B. A data 

entry reviewer other than the data entry person checked the data entry. ERG performed a second 

review of at least 25 percent of the Detailed Questionnaires entered into the database by visually 

comparing all the information contained in the database to the review copy. ERG internally

tracked the data entry and data entry review in the Survey Review Tracking database. 

After ERG completed data entry of the Detailed Questionnaires, ERG performed 

database clean-up and standardization activities to facilitate subsequent data analyses. The 

following subsections describe these activities.

1.3.1 Database Field Updates

ERG compiled a crosswalk based on primary key fields in the database to identify the 

operator, project, and produced water management system. These primary key fields are 

automatically generated numbers in the tables, which are used to facilitate query development. 

Using this crosswalk, ERG developed queries and modules to perform the database updates 

described below. ERG checked the resulting database tables to ensure the values were updated 

properly 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 ERG 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 the questionspecific CBI fields. For Detailed Questionnaires marked as allCBI, ERG used the 

allCBI indicator in the database to update the question-specific CBI fields 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 contained a variety of units for these responses (i.e., barrels, bbls, bbl, 

gallons, gal). ERG 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 barrels. 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. ERG removed records in the database table 

that indicated “None” or “Unknown.” ERG 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 

question. 

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. ERG transcribed all comments 

from the original Detailed Questionnaire into the Comments and Flags table in the engineering 

database. In addition to the respondents’ comments, ERG 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 Detailed 

Questionnaire. 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 fields 
Memorandum

April 2, 2013

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to distinguish between general questionnaire comments and documented changes of the 

questionnaire responses.

2.0 EPA REVIEW AND PROCESSING OF DETAILED QUESTIONNAIRE ATTACHMENTS

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.

ERG noted whether each questionnaire contained the attachments listed above using 

yes/no fields in the Questionnaire Review Tracking Database. Operators provided the 

supplemental information in various data formats. To minimize errors in transferring the data to 

the database, ERG used the following general procedures: 

 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 hardcopy attachments that ERG could not process through OminPage®, ERG 

typed the data into an Excel spreadsheet then visually checked 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 hardcopy questionnaire file. 
Memorandum

April 2, 2013

Page 8

Table 5. Data Processing Procedures for Detailed Questionnaire Attachments of 

Supplemental Information

Supplemental 

Information

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 saved 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. 

Supplemental pollutant data from non-dischargers were not 

imported.

ERG stored pollutant data in the CBI Pollutant Database (EPA, 

2013e). 

3.0 ADDITIONAL UPDATES TO THE DETAILED QUESTIONNAIRE RESPONSES

In addition to questionnaire responses, ERG incorporated additional information into the 

engineering and pollutant databases. This section discusses how ERG 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 System (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 system (ICIS- NPDES), 

which houses discharge monitoring report (DMR) data for primarily major dischargers. 

However, because most CBM operators are minor dischargers, ERG only identified DMR data 

for a few Detailed Questionnaire respondents. ERG extracted the DMR data from ICIS-NPDES 

and imported them as a separate table 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, ERG received DMR data from the Wyoming Department of Environmental 

Quality (WYDEQ) and from the Alabama Department of Environmental Management (ADEM), 

which includes discharges from CBM projects not included n ICIS-NPDES. ERG imported the 

DMR data from these two states into separate tables in the pollutant database. A second reviewer 
Memorandum

April 2, 2013

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checked that the data imported completely into the pollutant database by 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, 2013f).

3.1.2 Updating Discharge Destinations in the Engineering Database for Projects Reporting 

POTW or Third-Party Disposal

ERG evaluated the discharge destinations for projects indicating discharge to a POTW or 

third party in Question C3-1 to confirm the discharge status for these projects. EPA intended this 

response to include only 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 receiving their produced water and whether it was a 

POTW5, PrOTW 6, or other type of facility. Twenty-four responses indicated discharge to a 

POTW or third party.

ERG 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 CWT7, or 2) another CBM operator that uses 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 analyses. 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, only 

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 revised destination for these projects in the engineering database, which 

EPA used for subsequent industry analyses. 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 owned and operated by a private entity and used for 

storage, treatment, recycling, or reclamation of liquid industrial wastes.

7Centralized waste treatment facility - A facility that treats any hazardous 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

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Treatment and Disposal details ERG’s review of projects reporting POTW/third-party and the 

reassignment of discharge destinations for these projects (EPA, 2013g). 

Table 4. Summary of Projects in EPA’s Review of POTW and ThirdParty 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 projects 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 permits 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 

discharging 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 evaporation/infiltration 

ponds hold a Wyoming Pollution Discharge Elimination System (WYPDES) permit, the 

operator’s Detailed Questionnaire response may have categorized the project as a discharging 

project. ERG conducted an additional review of the CBM projects in Wyoming using the state 

DMR data to determine if the project discharged to surface water in 2008.

ERG received 2008 DMR data from Wyoming that included information on the type 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 discharged to surface water or to infiltration/evaporation 

ponds; and 

 Whether the discharge volume reported in the Detailed Questionnaire accurately 

reflects what is discharged to surface water.

ERG summarized these findings in the CBI attachment, EPA Review of Produced Water 

Treatment and Disposal, located in EPA’s CBI docket (EPA, 2013g). Based on these findings, 
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April 2, 2013

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ERG updated the responses to C3-1 and C3-2 in the engineering database. ERG documented 

these updates to the responses in the Comments and Flags table in the engineering database. 

4.0 DATA QUALITY OF THE DETAILED QUESTIONNAIRES AND ENGINEERING DATABASE

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 these responses. As directed by 

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

analyses included the data available from the complete responses.
Memorandum

April 2, 2013

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Table 5. Data Quality of Detailed Questionnaire Responses and Engineering Database

Data Element Acceptance Criteria Data Quality Evaluation

Operator-level – Completeness  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 produced 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 

Evaluations for Individual Questionnaire 

Responses.

Individual Questionnaire Responses 

– Completeness 

 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), which provided questionspecific checks for completeness and 

reasonableness. 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 review of 31out 
Memorandum

April 2, 2013

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Table 5. Data Quality of Detailed Questionnaire Responses and Engineering Database

Data Element 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 the questionnaire. 

ERG used Instructions for Review and Coding of 

the CBM Detailed Questionnaire (Appendix C of 

the Questionnaire QAPP), which provided questionspecific checks for completeness and 

reasonableness. 

Using the instructions, ERG performed consistency 

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 

consistency checks. 

Database – Completeness and 

Accuracy

 Database contains all questionnaires passing the operatorlevel 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 review 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

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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 volume 172 172 100%

C2-3b

Project-specific produced water volume 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 capital cost 210 231 91%

C2-7a Operation and Maintenance (O&M) costs 197 231 85%

C2-7b Annual revenues from PWMS operations 179 231 78%

C2-8a Total piped volume 226 231 98%

C2-8b Piped capital cost 173 190 91%

C2-8c Piped O&M cost 171 190 90%

C2-8d.i Trucked volume 220 231 95%

C2-8d.v Trucked OM cost 226 231 98%

C3-1 Destination 321 321 100%

C3-2 Destination-specific volume 311 321 97%

C3-2 Destination-specific %PWMS capital 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 cost 32 48 67%

C3-8 Indicate type of treatment technology 220 231 95%

C3-9 -

C3-13

Treatment technology volume and cost 

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

April 2, 2013

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Table 7. Consistency Checks of Detailed Questionnaire Responses to PWMS Volumes and 

Costs

Reasonableness Check

Number of 

Complete Responses

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. 210 231 91%

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

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5.0 REFERENCES 

1. Batelle, 2009. Coalbed Methane Study: Comparison of Original to Final Detailed 

Questionnaire Sample Design. Batelle Memorial Institute. May 27, 2010. EPA-HQ-OW2010-0824, DCN CBM00635.

2. U.S. EPA, 2009a. Detailed Questionnaire for the Coalbed Methane (CBM) Extraction 

Sector. U.S. Environmental Protection Agency. October 2009. EPA-HQ-OW-2006-0771, 

DCN 10072.

3. U.S. EPA, 2009b. Coalbed Methane Industry Screener. U.S. Environmental Protection 

Agency. 2009. EPA-HQ-OW-2006-0771, DCN 10068.

4. U.S. EPA, 2011. Quality Assurance Project Plan for the Review and Data Entry of the 

Engineering Portion of the Coalbed Methane Questionnaire. U.S. Environmental 

Protection Agency. July 13, 2011. EPA-HQ-OW-2010-0824, DCN CBM00691.

5. U.S. EPA, 2012. Coalbed Methane State Phone Calls. Various Dates and Contacts. EPAHQ-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 CBM00701.

7. U.S. EPA, 2013b. CBM Engineering Survey Database (Microsoft Access 2003 

database). U.S. Environmental Protection Agency. February 2013. EPA-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 CBM00655.

10. U.S. EPA, 2013e. CBM Pollutant Data Database (Microsoft Access 2003 database).

U.S. Environmental Protection Agency. February 2013. EPA-HQ-OW-2010-0824, DCN 

CBM00668.

11. U.S. EPA, 2013f. CBM Pollutant Data Database Dictionary. U.S. Environmental 

Protection Agency. February 2013. EPA-HQ-OW-2010-0824, DCN CBM00702.

12. U.S. EPA, 2013g. CBI Attachment - EPA Review of Produced 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 name

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 Inc
Memorandum

April 2, 2013

Page 18

Table A-1. List of Operators Receiving Detailed Questionnaires

Basin Operator name

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 name

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 OPERATING
Memorandum

April 2, 2013

Page 20

Table A-1. List of Operators Receiving Detailed Questionnaires

Basin Operator name

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