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# Data Analysis Addendum to the Quality Assurance Project Plan f or the Coalbed Methane Existing Data Collection

Prepared for:



## U.S. Environmental Protection Agency

Engineering and Analysis Division
Office of Water 1200 Pennsylvania Avenue, NW Washington, D.C. 20460

Prepared by:



## Eastern Research Group, Inc.

14555 Avion Parkway
Suite 200 Chantilly, VA 20151

- 1102

November 30 , 2011

EPA Contract No. 68 -C- 02

- 095 Work Assignment 9- 37i This page is intentionally blankii History of QAPP for the Coalbed Methane Existing Data Collection

Revision 0 Data Analysis Addendum

Delivery Date June 28, 2011 November 1, 2011

Work Assignment 8

- 37 9

- 37

Scope Coalbed Methane Existing Data Collection 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) November 18, 2011

Comments

Addressed June 28, 2011 August 25, 2011 November 30, 2011

Approval August 30, 2011iii Distribution

This data analysis addendum to the Quality Assurance Project Plan (QAPP) for the Coalbed Methane Existing Data Collection will be distributed to staff of the U.S. Environmental

Protection Agency and Eastern Research Group, Inc. ( Table A 1 ). The ERG WAM will provide a copy of the approved QAPP addendum 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 A 1

. QAPP Distribution

Name

Title Contact Information Mailing Address

U.S. Environmental Protection Agency

Meghan Hessenauer Technical Project Officer (202) 566

- 1040 (phone) hessenauer.meghan@epa.gov

U.S. Environmental Protection Agency Office of Science and Technology 1200 Pennsylvania Avenue, NW (4303T) Washington, DC 20460 (202) 566

- 1053 (fax) Marion Kelly Quality Assurance Coordinator (202) 566

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

Marla Smith Work Assignment Manager (202) 566

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

Ahmar Siddiqui EPA Project Engineer (202) 566

- 1044 siddiqui.ahmar@epa.gov

Janet K. Goodwin Technology & Statistics Branch Chief (202) 566

- 1060 (phone) goodwin.janet@epa.gov

Eastern Research Group, Inc

Deborah Bartram ERG Program Manager (703) 633

- 1669 deborah.bartram@erg.com

Eastern Research Group, Inc. 14555 Avion Parkway

Suite 200 Chantilly, VA 20151

- 1102 (703) 263

- 7280 (fax) Mary Willett ERG Quality Assurance Officer (703) 633

- 1615 mary.willett@erg.com

Lori Weiss Work Assignment Manager (703) 633

- 1658 lori.weiss@erg.com

Katie Connolly

Team Member (703) 633

- 16 41 katie.connolly@erg.com

Carissa Erickson

Team Member (703) 633

- 1688 carissa.erickson@erg.com

Sarah Hays

Team Member (703) 633

- 1661 sarah.hays@erg.com

Chris Krejci

Team Member (512) 407

- 1835 chris.krejci@erg.com

Dan

- Tam Nguyen

Team Member (703) 633

- 1617

dan

- tam.nguyen@erg.com

Steve Strackbein

Team Member (703)633

- 1656 steve.strackbein@erg.comiv CONTENTS

Page

A 1. I NTRODUCTION

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

A 2. P ROJECT M ANAGEMENT

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

A 3. P ROJE CT D ESCRIPTION AND O BJECTIVES

................................ ................................ ............. 2

A 4. D ATA N EEDS

, S OURCES

, AND Q UALITY C RITERIA

................................ ............................... 2

A 5. D ATA A CQUISITION AND R EVIEW

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

A 5. 1 Existing Data Tracking Database (Tracking Database) and Development

of Detailed Data Tables

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

A 5. 2 Development of Data Subsets

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

A 6. U SE OF E XISTING D ATA AND Q UALITY V ERIFICATION

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

A 6. 1 Develop Costs and Loads Methodology

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

A 6. 2 Calculate Costs and Loads

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

A 6. 3 Check Results of Costs and Loads Calculations

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

A 7. P ROJECT R EPORTS (D ELIVERABLES )

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

A 8. R EFERENCES

................................ ................................ ................................ ...................... 10v LIST OF TABLES

Page

Table A 1. QAPP Distribution

................................ ................................ ................................ ....... iii

Table A 2. Data Analysis Addendum Relationships to Existing Data QAPP Sections

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

Table A 3. Cost E stimate Quality Specifications

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

Table A 4. Pollutant Loads Estimate Quality Specifications

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

Table A 5. Summary of Procedures and Results Quality Verification

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

Table A 6. Key Products

................................ ................................ ................................ .................. 9Data Analysis Addendum

Date: November 1 , 2011 Page 1 of 10

A 1. I NTRODUCTION

This is a data analysis addendum to the Quality Assurance Project Plan for the Coalbed

Methane Existing Data Collection (Existing Data QAPP) which was approved on August 30,

2011 . This addendum covers three new tasks (c ost estimation

, l oad estimation , and p rocedures

for creating data subsets ) that will be conducted as part of the Coalbed Methane ( CB M ) rulemaking. This addendum does not modify the quality assurance procedures discussed in the main document but incorporates additional discussion of the new tasks. Please refer back to

Section 1 of the Existing Data QAPP for a description of the CBM proj ect.

This QAPP addendum is organized into the following sections:

**•** Section A 2: Project Management

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

**•** Section A 4: Data Needs, Sources, and Quality Criteria

**•** Section A 5: Data Acquisition, Review, Quality Verificati on, and Reporting

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

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

**•** Section A 8: References

Table A 2 shows the information addressed in this Data Analysis Addendum and the relationships to the Existing Data QAPP.

Table A 2 . Data Analysis Addendum Relationships to Existing Data QAPP Sections

Existing Data QAPP Data Analysis

Addendum

Data Analysis Addendum Information Section

Number Section Heading Section Number

4.3 Data Quality Criteria and Specifications A 4

. ERG added quality specifications for the data

used in c ost and pollutant loads estimates

.

5.2 Data Storage and Management A 5.1 ERG described the e xisting data t racking database and the development of detailed

data tables.

5.0 Data Acquisition, Review, Quality Verification, and Reporting A 5.2 ERG explained the d evelopment and

documentation of data subsets.

6.0 Use of Existing Data A 6.1 ERG explained how we will develop the costs and loads methodology.

A 6.2 ERG explained how we will calculate the

costs and loads estimates.

A 6.3 ERG explained how we will check the results

of the costs and loads calculations.

A 2. P ROJECT M ANAGEMENT

ERG will conduct the work covered by this data analysis addendum using the
management organization and activities described in Section 2 of the Existi ng Data QAPP, approved on August 30 , 2011. The Existing Data QAPP explains how ERG will use a four

- step plan

- do

- check

- report cycle for the collection and use of existing data fo r the CBM extractionData Analysis Addendum

Date: November 1 , 2011 Page 2 of 10 industry. Please r efer t o Section 1 of the Existing Data QAPP for a detailed breakdown of the plan

- do

- check

- report process

.

A 3. P ROJECT D ESCRIPTION AND O BJECTIVES

Please r efer back to Section s 1 and 3 of the Existing Data QAPP for a description of the

CBM project. The purpose of this data analysis a ddendum is to describe how ERG will use the

data sources

, identified and reviewed according to Section 4 of the Existing Data QAPP

, to develop estimates of technology costs and pollutant reductions for CBM produced water treatment technology options

. In ad dition, this data analysis addendum describes how ERG will identify and extract data subsets from the regulatory database for economic, benefits, statistical, or environment assessment analyses, at the request of the EPA WAM.

ERG is supporting EPA in developing candidate treatment technology options for CBM produced water. ERG will use primary data collected from the detailed questionnaire according

to the Quality Assura nce Project Plan for the Review and Data Entry of the Engi neering Portions of the Coalbed Methane Questionnaire (Questionnaire QAPP) and existing data collected according to the Existing Data QAPP to identify pollutant control technologies,

estimate the costs of implementing these technologies, and estimate the p ollutants removed and

the non

- water quality impacts of these technologies.

ERG will provide information on technologies capable of controlling pollutants of concern present in CBM produced water

, which EPA will use to develop technology options.

ERG wil l develop cost estimates for each option that consider elements such as equipment, installation, indirect costs (e.g., spare parts, engineering, construction, and contractor fees), contingency, and annual costs (e.g., labor, maintenance, chemicals, energy, disposal of residuals, monitoring). EPA will evaluate these options to determine which (if any) represent Best Available Technology Economi cally Achievable (BAT)

. EPA may also ask ERG to evaluate the

non

- water quality environmental impacts of the technol ogies, such as air pollution, solid waste, and energy use.

ERG will also support EPA in developing a methodology to estimate baseline pollutant loads and pollutant reductions achievable by each candidate technology option.

A 4. D ATA N EEDS , S OURCES , AND Q UA LITY C RITERIA

Section 4 of the Existing Data QAPP , approved August 30, 2011, describes how ERG will acquire, review, and document existing data

. Tables 4

- 1 through 4

- 4 of the Existing Data QAPP list the criteria that ERG will use to evaluate if an existing data source and/or questionnaire data are acceptable for use in analyses supporting the CBM rulemaking . ERG will provide information on the quality of data sources that may be used in analyses, and the EPA

WAM will make the final determination of whether the source is suitable for use. If ERG identifies limitations in the quality of the data from data sources that may impact decisions regarding the overall direction of further data collection efforts or the quality of deliverables,

ERG will communi cate these issues to the EPA WAM. After a data source is determined to be acceptable for use, ERG may use the data to complete the rulemaking analyses described in

Section 6 of this addendum.Data Analysis Addendum

Date: November 1 , 2011 Page 3 of 10 ERG will prepare a methodology memorandum that discusses potential costing approaches and series of technology memorandums that provide information on technologies to consider for regulatory options. The EPA WAM will approve these memorandums and select th e technology options for evaluation prior to ERG’s development of costs and loads estimates.

These memorandums are discussed in more detail in Section A 6. 2 of this addendum. Table A 3

and Table A 4 outlin e the quality specifications ERG will use to determine whether the cost and loads estimates, which were computed using the approved methodology, are appropriate.

Table A 3 . Cost Estimate Quality Specifications

Acceptance

Criterion: Cost

Estimates Specification

Meet requirements for economic analysis **•** Include one

- time costs for planning activities

.

**•** Include one

- time costs for equipment purchase and installation.

**•** Include on

- going operating, and maintenance costs (annual costs).

**•** Include periodic operating and maintenance costs, as appropriate. Appropriate for project

locations **•** Equipment costs, including transportation and installation, reflect the costs for supplies

and labor at the project locations.

**•** Operating costs (electricity, fuel, labor, chemicals, etc. ) reflect the costs at each project

l ocation and may represent state or regional averages

.

**•** Option costs reflect baseline conditions for produced water in each geographic location.

Unit costs are on specified, stan dard year basis **•** Costs are converted to a standard year using RS Means Construction Ind ex or other

standard cost index

.

Complete **•** Estimate costs for existing projects that currently discharge wastewater and are subject to new proposed requirements.

**•** Estimate costs for new projects , based on existing technology design elements

. Accurate **•** Calculations reflect the criteria outlined in the approved costing methodology

memorandum

.

**•** Unit conversions are correct.

Reasonable **•** Order

- of

- magnitude of costs is comparab le to costs reported for projects that already

have treatment option in place.

**•** Costs of treatment options are comparable to vendor estimates.

Table A 4 . Pollutant Loads Estimate Quality Specifications

Acceptance

Criterion:

Pollutant Loads Specification

Appropriate for project locations **•** Pollutants and pollutant concentrations are reported in reputable existing data sources and/or the detailed questionnaire

, based on project location. Values outside the range of expected values are included in the database, but flagged for review and possible exclusion. Complete **•** Include all potential pollutants

, reported in reputable existing data sources and/or the detailed questionnaire

, which may b e present in the produced water.

**•** Estimate baseline and all regulatory option loads.

**•** Evaluate if projects currently discharging wastewater are in compliance with the regulatory option.

Accurate **•** Pollutants and pollutant concentrations are comparable to those reported in reputable existing data sources and/or the detailed questionnaire

.

**•** Calculations reflect the criteria outlined in the approved costing methodology memorandum.

**•** Option discharge loads reflect removals achieved from each regulatory option app lied.

**•** Unit conversions are correct.Data Analysis Addendum

Date: November 1 , 2011 Page 4 of 10

Acceptance

Criterion:

Pollutant Loads Specification

Reasonable **•** Order

- of

- magnitude of influent and effluent pollutant concentrations from treatment technologies are comparable to those reported for projects in reputable existing data sources and/or the detailed questionnaire. Depending on the observed data ranges and expected variability of the technology, several orders of magnitude may still indicate reasonable data. Values outside the range check are flagged for review and possible exclusion.

A 5. D ATA A CQUISITION AND R EVIEW

As discussed in Section 5.2 of the Existing Data QAPP , approved August 30, 2011

, ERG

will store existing and questionnaire data collected for the CBM project in the CBM r egulatory

database

. The regulatory database comprises the engineering questionnaire database, the economics questionnaire database , and the existing data tracking database (tracking database)

. The tracking database houses the e xisting data c itation and review information, but does not store any actual data.

ERG will evaluate existing data sources listed in the tracking database . ERG will also

discuss the procedures for pulling a data subset , which will include any portion of dat a from the regulatory database that the EPA WAM requests, for use in project analyses

.

A 5. 1

ERG will store citation and review information for existing data sources in the tracking

database

. For each source, t he tracking database will identif y t opics covered, citation

informa tion , and any additional source s

. Most of the fields in the tracking database are simpl e checkbox or yes/no fields that indicate the type of information included in the source. T he tracking database does not store actual data, but rather identifies whether or not the source

discusses particular topics . ERG wil l use the fields in the tr acking database to identify potential

sources that may have useful data to contribute to the rulemaking analysis. The tracking database will indicate the location of any data copied into spreadsheets or other data formats. Other existing data sources may not inc lude operator and project level data , but they will contain information on specific basins or treatment technologies that can be used to supplement the primary data collected in the detailed questionnaire

. ER G will evaluate the existing sources using

the c riteria specified in Section 4 of the Existing Data QAPP and provide information on the quality of sources to the EPA WAM . The EPA WAM will determine whether the source is suitable for use in the rulemaking analysis. Existing Data Tracking Database (Tracking Database) and Development of Detailed

Data Tables

Using the tracking database, ERG will identify data sources that may be used during the rulemaking analysis. These sources may have information relating to treatment efficiencies, costs, and pollutant reductions achieved using various treatment options. ER G will enter th e data

into detailed data tables in a format appropriate for use in analyses , such as Microsoft Excel or

Access

. The detailed data tables will contain fields that can link to the tracking database for

citation information. ERG will also be a ble link the detailed data tables to the detailed questionnaire engineering database through data fields such as basin or state. T o review the accuracy of the compilation of the detailed data tables, the ERG WAM will assign a project team member to compare 20 percent of the entries in the detailed data tables to the original data

sources. If the project team member finds errors, an ERG project team member will documentData Analysis Addendum

Date: November 1 , 2011 Page 5 of 10
the errors and conduct additional checks of the data (the extent will depend on the sever ity of the original errors and the outcomes of the additional checks)

.

A 5. 2

ERG will extract d ata subsets from the regulatory database at the request of the EPA WAM. The EPA WAM will request specific data for economic

, benefits, statistical, or environment assessment analyses a nd ERG will create database quer ies to pull the specific

information requested. Development of Data Subsets

ERG will verify that the data housed in the regulatory database has been reviewed according to the procedures outl ined in Section 4 of the Existing Data QAPP and Section 3 of the Questionnaire QAPP

. ERG will provide a description and purpose of the data subset as well as

documentation of the data subset . ERG will document the data subset by adding a description to

all field names within the data subset and by providing a database dictionary to accompany the

data subset

. ERG will also document the query development and QC procedures used to create

the data subset . All of this documentation will be included in a separate table within the regulatory database, which will include the following fields:

**•** Query name (for data subset pull) ;

**•** Name of ERG staff who created query;

**•** Date query was created;

**•** Name of ERG staff who completed QC check;

**•** Date QC check was completed; and

**•** Additional notes.

Because the primary data are CBI, data subsets are CBI materials and ERG will manage

the ir creation and distribution as specified in ERG’s 2008 Security Plan for Handling Confidential Business Information under the Clean Water Act

.

A 6. U SE OF E XISTING D ATA AND Q UALITY V ERIFICATION

ERG will use collected data to estimate costs for CBM operators to manage, treat, and dispose of CBM produced water using the candidate technology options selected by EPA

. ERG

will also estimate the pollutant reduc tions resulting from implementing the regulatory options. ERG will document the use of existing data for project analyses in memoranda that include:

**•** Purpose of analysis;

**•** Description of analysis methodology;

**•** D ata sources used;

**•** Criteria used to select the da ta sources;

**•** Exceptions to the criteria and rationale for exceptions; and

**•** Documentation of assumptions and equation s

.

ERG will check the accuracy of the analyses using the procedures outlined in Section A 6. 3 of

this addendum

, which discuss es the verification and validation methods.Data Analysis Addendum

Date: November 1 , 2011 Page 6 of 10

A 6. 1

ERG will implement the four

- stage plan

- do

- check

- report cycle to develop costs and loads

estimates. T he first stage in the four

- part cycle to develop the costs and loads methodology is to

“ plan

. ” ERG will develop methodologies for computing option costs

, ba seline pollutant loads

, and pollutant reductions. The EPA WAM will review and approve ERG’s methodologies

. After the EPA WAM approves the methodolog ies , ERG will develop a memorandum that describes, in detail, the assumptions, data inputs, equations, algo rithms, outputs, outliers, and testing procedures that will be used to estimat e costs and loads. ERG will compute costs and loads by following the procedures approved by EPA. Develop Cost s and Loads Methodology

ERG will plan how to use data from the detailed questionnaire and the existing d ata

, which will be housed in the regulatory database, to compute produced water management costs

and loads. Both the questionnaire and existing data sources have been reviewed according to the Questionnaire QAPP and Existing Data QAPP. ERG will work with EPA to determine the extent
to which data that do not meet the specified data acceptance criteria may be used to support EPA’s CBM rulemaking

.

A 6. 2

The second stage in the four

- part cycle to develop the costs and lo ads calculations is to

“ do

. ” ERG is supporting EPA ’s development of candidate technology options. ERG will identify technology options capable of controlling discharges of pollutants of concern in CBM produced

water

. EPA will evaluate these options to dete rmine which (if any) represent Best Available Technology Economically Achievable (BAT) or best demonstrated technology. ERG will estimate the costs, pollutant reductions, and non

- water quality environmental impacts ( such as air pollution, solid waste, and energy use ) that are associated with each candidate technology option. ERG will consider elements such as equipment, installation, indirect costs (e.g., spare parts, engineering, construction, and contractor fees), contingency, and annual costs (e.g., labo r, maintenance, chemicals, energy, disposal of residuals, monitoring) when developing the cost

estimates. In conducting this task, ERG will use existing data sources, including data from other EPA program offices (e.g., Office of Air, Coal Mine Methane Out reach) , industry groups, universities (e.g., Colorado School of Mines), treatment equipment vendors, and other sources identified through literature and internet searches. Before performing the literature searches, ERG will provide a summary of the search parameters and internet search engines for EPA

review. ERG will also use primary data collected through the detailed questionnaire. Calculate Costs and Loads

ERG will develop a memorandum that discusses potential approaches for costing including: facility

- specific basis; model facility basis; incorporation of cost models developed by the Colorado School of Mines; and any other relevant approaches. The memorandu m will discuss the pros and cons of each of these approaches and recommend one approach. ERG will discuss in this memorandum any outstanding issues that need to be discussed and resolved with

EPA and t he EPA WAM will review and approve this memorandum befo re ERG begins costs

and loads estimates calculations.

ERG will also prepare a series of six memorand ums that provide information on technologies for EPA to consider in developing regulatory options. The first memorandum will provide basic details about s everal general technology types, and each subsequent memorandumData Analysis Addendum

Date: November 1 , 2011 Page 7 of 10 will provide additional details about potential candidate technologies. These memorandums will provide details on costs and pollutant removals, and information on pre

- and post

- treatment

requ ired for each technology. The EPA WAM will review th ese memorandum s and select technology options before ERG begins costs and loads estimates calculations.

As part of the costs and loads evaluation, ERG will evaluate the current treatment in place at ope rating projects to determine the amount and cost of additional treatment necessary for each operator in the CBM industry. ERG will use this information in developing the option costs.

In developing costs , ERG will use existing data sources, which are house d in the regulatory database, and primary data from the detailed questionnaire. The criteria that ERG will use to determine if the estimated costs are of the quality needed to support EPA’s rulemaking are

summarized in Table A 3

. ERG anticipates that operators will claim their financial and cost information to be CBI and therefore all calculations, including estimated costs, will be managed as CBI according to ERG’s Security Plan for Handling Confidential Business Information under

the Clean Water Act

.

ERG will characterize sources of wastewater in terms of flow, the types and amounts of pollutant constituents, and the total baseline pollutant discharge load. ERG will use this

information to estimate baseline pollutant loads and use technology performance information to calculate options loads

. ERG will use data collected from the questionnaire and existing data, which is housed in the regulatory database, to c alcu late baseline and option pollutant loads. The criteria that ERG will use to determine if the estimated loads are of the quality needed to support EPA’s rulemaking are summarized in Table A 4

.

ERG may use Microsoft Excel or Access to develop a calculation tool capable of computing costs and pollutant reductions for the CBM produced water treatment options. ERG

will record the following elements in a costs and loads calcu lation document :

**•** Electronic tool description;

**•** Flow charts (if necessary);

**•** Data sources;

**•** Documentation of assumptions;

**•** Discussion of any boundary or limiting conditions;

**•** Documentation of default parameter values and their sources; and

**•** Documentation of all equations (and sources, if applicable) used to
generate output.

A 6. 3

The third stage in the four

- part cycle to develop the costs and loads calculations is to

“ check

. ” ERG will perform a QC check of the Excel or Access tool created for estimating the costs and pollutant loadings for the technology options. The QC check will verify the appropriateness of the technical approach and verify that original data are correctly i nput. The QC check also will verify that the tool implements the documented approach. A CBM project

team member not involved in the calculations will review any constants used for appropriateness, will check that units are converted properly, and will docu ment and check the equations used against the documentation and the references

. To the extent possible, the team member will independently verify 20 percent of the calculations using hand calculations or separate Check Results of Costs and Loads CalculationsData Analysis Addendum

Date: November 1 , 2011 Page 8 of 10 spreadsheets for three representative CBM p rojects . If the checks fail, then the spreadsheet will

be revised and retested. The ERG WAM and ERG senior reviewer will review the results of the calculations to evaluate whether the results make sense (e.g., are on the proper scale, follow expected trend s, are comparable to data reported by industry) and provide EPA with information appropriate for use in rulemaking decisions.

ERG will document the electronic tool development in database tables or spreadsheets

that include :

**•** A list of any data changes in cluding a description, the purpose, and the process used to change the data;

**•** T he name of the ERG sta ff member who performed the QC and the date completed; and

**•** A list of any errors found during QC and the subse quent resolution (s)

.

When change s are made to the electronic tool , ERG will:

**•** Assign a unique name and number to the revised version of the tool (in either Excel or Access) ;

**•** Maintain a historical file of the changes ; and

**•** In a QA spreadsheet , log the changes made to the different versions and explain what was revised, the date the revision was made, and by whom.

ERG will determine whether the cost and loads estimates meet the specifications presented in Table A 3 and Table A 4 by comparing the estimates to primary data from the questionnaires and existing data. ERG will verify and validate the estimated costs and loads by comparing them to actual costs and loads for similar projects. ERG will present any uncertainties

about the estimates to the EPA WAM, who will make the final determination about whether they

are ap propriate for use in the rulemaking analysis.

Table A 5 provides a summary of the procedures ERG will use to determine that data used and results generated on this project meet quality specifications.

Table A 5

. Summary o f Procedures and Results Quality Verification

Action Task QA Actions

PLAN Develop methodology Before delivery to EPA, an ERG senior engineer will provide conceptual review of methodology and assumptions. The EPA WAM will approve the final methodology

. Develop calculation approach

DO Calculate baseline

loads A CBM team member who did not do the calculation will check constants, unit conversions, and equations against the documentation and references

. To the extent possible, the team member will independently verify 20 percent of the calculations using hand calculations or separate spreadsheets for three representative CBM projects . If the checks fail, then the spreadsheet will be

revised and retested. ERG WAM and an ERG senior reviewer will revie w estimates to evaluate whether they are appropriate for the CBM industry. Estimate treatment in place

Calculate treatment performance and discharge volumes

Calculate pollutant

removalsData Analysis Addendum

Date: November 1 , 2011 Page 9 of 10

Action Task QA Actions

Calculate option costs

CHECK Methodology and assumptions The ERG WAM and a CBM team member who did not do the initial calculations

will review the creation and use of the electronic tool. An ERG senior r eviewer

will review calculation results to evaluate whether they are appropriate for the CBM industry. Spreadsheet and/or

database uses the methodology and assumptions

Cost equations and

d ata are properly

loaded

Results make sense (on both project and overall level)

Results are similar to existing projects and

other sources

REPORT Develop project reports (see Section A7) The ERG WAM and an ERG senior reviewer will review all project reports and evaluate whether they are appropriate for the CBM industry

. ERG will include the results of the costs and loads analyses, the QA procedures, and the result s of the quality review in the project reports

.

A 7. P ROJECT R EPORTS (D ELIVERABLES )

The fourth stage in the four

- part cycle that ERG will use to develop the costs and loads

calculations is to “ report

. ” Table A 6 lists the key products ERG will produce and how data quality will be reported in each.

ERG will include an evaluation of data quality in all project deliverables. ERG will also identify the sources of data, assumptions made, and calculations used in their development in all project deliverables. These identifications will be sufficiently detailed and transparent to ensure the reproducibility of the work by qualified third parties. All project deliverables will meet EPA’s standards of transparency, objectivity, integrity, and utility as specified in EPA’s Information Quality Guidelines ( U.S. EPA, 2002).

Table A 6 . Key Products

Key products Content
Regulatory database **•** Complete regulatory database that comprises the engineering questionnaire database, the economic questionnaire database, and the tracking database.

Data subsets **•** Relevant subsets of the regulatory database for use by other parties in analyses

out side of thi s work assignment.

Costs and loads methodology **•** Explains computing option costs and baseline pollutant loads and reductions

.

Costs and loads detailed assumptions **•** Assumptions, equations, inputs, algorithms, outputs, testing procedures, etc. used to
estimate costs and loads.

Costs and loads estimates **•** E stimates of costs and pollutant reductions for various technologies capable of treating CBM wastewater.Data Analysis Addendum

Date: November 1 , 2011 Page 10 of 10

A 8. R EFERENCES

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

2. Eastern Research Group, Inc. Quality Assurance Project Plan for the Review and Data Entry of the Engineering Portions of the Coalbed Methane Questio nnaire . July 14, 2011.

3. Eastern Research Group, Inc. 2011. Quality Assurance Project Plan for the Coalbed Methane Existing Data Collection . August 30, 2011.

4. U.S. Environmental Protection Agency (U.S. EPA). 2002 . Guidelines for Ensuring and Maximizing the Qu ality, Objectivity, Utility, and Integrity of Information Disseminated by the Environmental Protection Agency. EPA/260R

- 02

- 008. October 2002.