jul

Data Analysis Addendum to the

Quality Assurance Project Plan for the

Coalbed Methane Existing Data Collection

Prepared for:

U.S. Environmental Protection Agency 

Engineering and Analysis Division

Office of Water

1200 Pennsylvania Avenue, NW

Washington, D.C. 20460

Prepared by:

Eastern Research Group, Inc. 

14555 Avion Parkway

Suite 200

Chantilly, VA 20151-1102

November 30, 2011

EPA Contract No. 68-C-02-095

Work Assignment 9-37
i

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ii

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, 2011
iii

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) 566-1047 (phone)

smith.marla@epa.gov

Ahmar Siddiqui

EPA Project Engineer

(202) 566-1044

siddiqui.ahmar@epa.gov

Janet K. Goodwin

Technology & Statistics Branch Chief

(202) 566-1060 (phone)

goodwin.janet@epa.gov

Eastern Research Group, Inc

Deborah Bartram

ERG Program Manager

(703) 633-1669

deborah.bartram@erg.com

Eastern Research Group, Inc.

14555 Avion Parkway 

Suite 200

Chantilly, VA 20151-1102

(703) 263-7280 (fax)

Mary Willett

ERG Quality Assurance Officer

(703) 633-1615

mary.willett@erg.com

Lori Weiss

Work Assignment Manager

(703) 633-1658

lori.weiss@erg.com

Katie Connolly

Team Member

(703) 633-1641

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.com
iv

CONTENTS

Page

A 1. INTRODUCTION .................................................................................................................... 1

A 2. PROJECT MANAGEMENT ...................................................................................................... 1

A 3. PROJECT DESCRIPTION AND OBJECTIVES ............................................................................. 2

A 4. DATA NEEDS, SOURCES, AND QUALITY CRITERIA ............................................................... 2

A 5. DATA ACQUISITION AND REVIEW ........................................................................................ 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. USE OF EXISTING DATA AND QUALITY VERIFICATION ........................................................ 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. PROJECT REPORTS (DELIVERABLES).................................................................................... 9

A 8. REFERENCES ...................................................................................................................... 10
v

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

Date: November 1, 2011

Page 1 of 10

A 1. INTRODUCTION

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 (cost estimation, load estimation, and procedures 

for creating data subsets) that will be conducted as part of the Coalbed Methane (CBM)

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 project. 

This QAPP addendum is organized into the following sections:

• Section A2: Project Management

• Section A3: Project Description and Objectives

• Section A4: Data Needs, Sources, and Quality Criteria

• Section A5: Data Acquisition, Review, Quality Verification, and Reporting

• Section A6: Use of Existing Data

• Section A7: Project Reports (Deliverables)

• Section A8: 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 cost and pollutant loads estimates.

5.2 Data Storage and Management A 5.1

ERG described the existing data tracking 

database and the development of detailed 

data tables.

5.0

Data Acquisition, Review, 

Quality Verification, and 

Reporting A 5.2

ERG explained the development 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. PROJECT MANAGEMENT

ERG will conduct the work covered by this data analysis addendum using the 

management organization and activities described in Section 2 of the Existing 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 for the CBM extraction 
Data Analysis Addendum

Date: November 1, 2011

Page 2 of 10

industry. Please refer to Section 1 of the Existing Data QAPP for a detailed breakdown of the 

plan-do-check-report process.

A 3. PROJECT DESCRIPTION AND OBJECTIVES

Please refer back to Sections 1 and 3 of the Existing Data QAPP for a description of the 

CBM project. The purpose of this data analysis addendum 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 addition, 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 Assurance Project Plan for the Review and Data Entry of the Engineering 

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 pollutants 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 will 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 Economically Achievable (BAT). EPA may also ask ERG to evaluate the 

non-water quality environmental impacts of the technologies, 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. DATA NEEDS, SOURCES, AND QUALITY CRITERIA

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 communicate 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 the 

technology options for evaluation prior to ERG’s development of costs and loads estimates. 

These memorandums are discussed in more detail in Section A6. 2 of this addendum. Table A3

and Table A4 outline the quality specifications ERG will use to determine whether the cost and 

loads estimates, which were computed using the approved methodology, are appropriate.

Table A3. 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 

location and may represent state or regional averages.

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

Unit costs are on 

specified, standard 

year basis

• Costs are converted to a standard year using RS Means Construction Index 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 comparable to costs reported for projects that already 

have treatment option in place.

• Costs of treatment options are comparable to vendor estimates.

Table A4. 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 be 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 applied.

• 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. DATA ACQUISITION AND REVIEW

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 regulatory 

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 existing data citation 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 data 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, the tracking database will identify topics covered, citation 

information, and any additional sources. Most of the fields in the tracking database are simple 

checkbox or yes/no fields that indicate the type of information included in the source. The 

tracking database does not store actual data, but rather identifies whether or not the source 

discusses particular topics. ERG will use the fields in the tracking 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 include 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. ERG will evaluate the existing sources using 

the criteria 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. ERG will enter the 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 able link the detailed data tables to the detailed 

questionnaire engineering database through data fields such as basin or state. To 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 document 
Data 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 severity of the 

original errors and the outcomes of the additional checks). 

A 5. 2

ERG will extract data 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 and ERG will create database queries 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 outlined 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 

their creation and distribution as specified in ERG’s 2008 Security Plan for Handling 

Confidential Business Information under the Clean Water Act.

A 6. USE OF EXISTING DATA AND QUALITY VERIFICATION

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 reductions 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;

• Data sources used;

• Criteria used to select the data sources;

• Exceptions to the criteria and rationale for exceptions; and

• Documentation of assumptions and equations.

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

this addendum, which discusses 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. The 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, baseline pollutant loads,

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

the EPA WAM approves the methodologies, ERG will develop a memorandum that describes, in 

detail, the assumptions, data inputs, equations, algorithms, outputs, outliers, and testing 

procedures that will be used to estimate costs and loads. ERG will compute costs and loads by 

following the procedures approved by EPA. 

Develop Costs and Loads Methodology 

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

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 loads 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 determine 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., labor, 

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 Outreach), 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 memorandum 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 the EPA WAM will review and approve this memorandum before ERG begins costs 

and loads estimates calculations.

ERG will also prepare a series of six memorandums that provide information on 

technologies for EPA to consider in developing regulatory options. The first memorandum will 

provide basic details about several general technology types, and each subsequent memorandum 
Data 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 

required for each technology. The EPA WAM will review these memorandums 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 operating 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 housed 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 A3. 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 calculate 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 A4.

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 calculation 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 input. 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 document 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 Calculations 
Data Analysis Addendum

Date: November 1, 2011

Page 8 of 10

spreadsheets for three representative CBM projects. 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 trends, 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 including a description, the purpose, and the 

process used to change the data;

• The name of the ERG staff member who performed the QC and the date 

completed; and

• A list of any errors found during QC and the subsequent resolution(s).

When changes 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 A4 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 appropriate for use in the rulemaking analysis.

Table A5 provides a summary of the procedures ERG will use to determine that data used 

and results generated on this project meet quality specifications.

Table A5. Summary of 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 review 

estimates to evaluate whether they are appropriate for the CBM industry.

Estimate treatment in 

place

Calculate treatment 

performance and 

discharge volumes

Calculate pollutant 

removals 
Data 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 reviewer 

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 

data 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 results of 

the quality review in the project reports.

A 7. PROJECT REPORTS (DELIVERABLES)

The fourth stage in the four-part cycle that ERG will use to develop the costs and loads 

calculations is to “report.” Table A6 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 A6. 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 

outside of this 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 • Estimates 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. REFERENCES

1. Eastern Research Group, Inc. Security Plan for Handling Confidential Business 

Information under the Clean Water Act. September 25, 2008.

2. Eastern Research Group, Inc. Quality Assurance Project Plan for the Review and Data 

Entry of the Engineering Portions of the Coalbed Methane Questionnaire. 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 Quality, Objectivity, Utility, and Integrity of Information Disseminated 

by the Environmental Protection Agency. EPA/260R-02-008. October 2002.