MEMORANDUM

TO: Public Docket

FROM: EPA

DATE: March 20, 2013

SUBJECT: Methodology for the Development of the Non-CBI CBM Pollutant Database

This memorandum describes EPA’s methodology for extracting non-CBI effluent data 

from the CBI CBM Pollutant database (“CBI pollutant database”) 1to generate the CBM Effluent 

Pollutant database (“effluent pollutant database”)2for the EPA Docket (EPA-HQ-OW-2010-

0824). The effluent pollutant database accompanies this memorandum (CBM Effluent 

Pollutant.mdb). 

The CBI pollutant database contains data EPA collected from industry as part of the 

Detailed Questionnaire for the Coalbed Methane (CBM) Extraction Sector3. EPA requested 

2008 discharge monitoring report (DMR) data in Question C3-4 and 2008 pre- and posttreatment data (including well data) in Question C4-1 of the Detailed Questionnaire. The CBI

pollutant database also contains 2008 data from state discharge monitoring reports from

Alabama, Illinois, Montana, and Wyoming, which EPA collected to supplement the information 

submitted with the questionnaires

The rest of this memorandum discusses each of the data sets and the procedures EPA 

used to prepare the effluent pollutant database. 

Alabama and Wyoming DMR 

The Alabama Department of Environmental Management (ADEM) provided DMR data 

for all CBM operations in the Black Warrior and Cahaba basins and the Wyoming Department of 

Environmental Quality (WYDEQ) provided DMR data for all CBM operators in the Green River 

and Powder River (WY) basins. ADEM provided the individual monthly reports in Microsoft 

Excel and EPA imported the monthly average concentrations from the Excel files directly into 

the CBI pollutant database as the “Alabama 2008 DMR” table. The WYDEQ provided tabulated 

results in Microsoft Excel, which WYDEQ pulled from their state DMR database. EPA directly 

imported the Wyoming 2008 DMR data as a separate table in the CBI pollutant database. 

Because the DMR data are from publicly available sources, EPA did not need to process 

the data to remove CBI data prior to importing the data tables into the effluent pollutant 

database. 

 

1 The CBI CBM Pollutant database is located in the CBI portion of the EPA docket (EPA-HQ-OW-2010-0824, 

DCN: CBM00668).

2 The non-CBI CBM Effluent Pollutant database is located in the non-CBI portion of the EPA docket (EPA-HQOW-2010-0824, DCN: CBM00689). 

3 A blank version of the Detailed Questionnaire for the Coalbed Methane (CBM) Extraction Sector can be found in 

the EPA docket (EPA-HQ-OW-2006-0771, DCN: 10072).
Memorandum

March 20, 2013

Page 2

Montana and Indiana DMR

EPA extracted Montana and Indiana DMR data from the EPA DMR Pollutant Loading 

Tool (http://cfpub.epa.gov/dmr/), which contains permit and DMR data from EPA’s Permit 

Compliance System (PCS) and Integrated Compliance Information System for the National 

Pollutant Discharge Elimination System (ICIS-NPDES). EPA used the NPDES permit numbers 

reported in Question C3-4 of the Detailed Questionnaire to extract data from the DMR Pollutant 

Loading Tool. States are required to report DMR data for major facilities (primarily based on the 

volume discharged from the facility) to PCS/ICIS-NPDES. Most CBM projects are minor 

dischargers who are not obligated to report through PCS/ICIS-NPDES. Reporting is optional for 

these projects. 

Because states are not required to report DMR data for most CBM projects, EPA did not 

obtain DMR data for all CBM projects through this tool. However, EPA successfully identified 

all reported CBM permits for Montana (Powder River Basin) and Indiana (Illinois Basin) using 

this tool and pulled DMR data from the on-line search tool for the CBM permits reported in 

Montana and Illinois. EPA imported the results as a separate table in the CBI pollutant database. 

Because the “Montana_Indiana 2008 DMR” table contains data from a publicly available data 

source and only contains discharge data, EPA did not need to process the table to remove CBI 

data prior to importing the data table into the non-CBI pollutant database. 

Discharge Data Submitted with Detailed Questionnaires

As discussed in the previous two sections of this memorandum, EPA obtained complete 

DMR data for the Black Warrior, Cahaba, Green River, Illinois, and Powder River basins using 

publicly available sources. Therefore, EPA did not use the discharge data submitted in the 

Detailed Questionnaire for these basins.

The CBI pollutant database contains the DMR data as well as other well and treatment 

data submitted with the Detailed Questionnaire. To develop the effluent pollutant database, EPA

extracted the discharge data for the Appalachian and Raton basins from the “Analytical Data” 

table into a separate table “DQ 2008 DMR_Appalachian and Raton_Non-CBI.” 

EPA reviewed the submitted data for the Appalachian and Raton basins before including 

the data in the effluent pollutant database as non-confidential data. Operators submitted 

discharge data in Question C3-4, as well as wellhead and pre- and post-treatment data in 

Question C4-1. EPA processed the data according to the activities detailed in the 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 Databases4. 

As part of the pollutant database development, EPA determined whether the sample was 

collected at the well, at pre- or post- treatment points, or at the discharge outfall. EPA identified 

key words in the sample description to make this determination: 

 

4 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 can be 

found in the EPA docket (EPA-HQ-OW-2010-0824, DCN: CBM00663).
Memorandum

March 20, 2013

Page 3

 Pre-treatment – Contains “raw”, “pre-”, “inflow”, or “influent”.

 Post-treatment – Contains “post-”, “effluent”, or identifies name of treatment. 

 Discharge –Sample description contains outfall and NPDES permit numbers and does not 

contain any key words that would classify them as post-treatment point.

 Well Data – Contains “wellhead” or “well” or does not contain key words that would 

classify them in the other categories. 

To create the effluent pollutant database, EPA extracted data for samples indicated as 

“discharge data.” EPA did not include pollutant data for sample points at the well or at pre- and 

post-treatment points because it was not relevant to EPA’s analysis of the industry’s effluent 

discharges to surface water. 

Table 1 lists the sample points in the Appalachian and Raton basins that EPA identified 

as discharge points, and thus, included in the effluent pollutant database. In the Appalachian 

Basin, the sample points are at defined effluent outfall locations. In the Raton Basin, the 

produced water discharges are regulated by a general state discharge permit, which identifies 

outfall locations that EPA considered as effluent outfall locations. 

Table 1. Effluent Discharge Sample Points Submitted with 

Detailed Questionnaires for Appalachian and Raton Basins

Basin Sample Description

Appalachian PA0219312 - 001

Appalachian PA0253588 - 001

Appalachian WV0116343 - 003/ Outfall

Raton COG 900004 - 005A

Raton COG 900004 - 010A

Raton COG 900004 - 022A

Raton COG 900004 - 027A

Raton COG 900004 - 059A

Raton COG 900004 - 071A

Raton COG 900004 - 073A

Raton COG 900004 - 075A

Raton COG 900004 - 076A

Raton COG 900004 - COMB

Raton COG 900006 - 020A

Raton COG 900006 - 042A

Raton COG 900006 - 054A

Raton COG 900006 - 116A

Raton COG 900006 - COMB