Quality Assurance Project Plan 

for the Coalbed Methane Detailed Study 

Questionnaire 

(Element A.1) 

Prepared for: 

U.S. Environmental Protection Agency 

Office of Science and Technology 

Engineering and Analysis Division 

1200 Pennsylvania Avenue, NW 

Washington, DC 20460 

Prepared by:

PG Environmental, LLC 

570 Herndon Parkway, Suite 500 

Herndon, VA 20170 

and 

Eastern Research Group, Inc. 

14555 Avion Parkway, Suite 200 

Chantilly, VA 20151-1102 

EPA Contract No: EP-C-07-029 

Work Assignment No. 2-01 

January 27, 2010 

Revision 1
Jim ParkerWork Assignment Manager'

PG F,nvir<lnmental, LLC

Date Date

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Date

Jan McGoldrickQuality Assurance OfficerPG Environmcntal, LLC

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Prq ect Quality Assr¡runcc Ot¡or<linatorEastenl Rcscarclt Group, Inc.

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Birute Vanatta

Task Order Manager

Bastel'n Re,soarch Gloup, Inc.

Date

Date Marion Kelly

Quality Assurance CoordinatorU.S. Environrnental Prolcction Agency

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U,S. Environmental Profection Agertcy

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Damon Highstnith

Technical Projecf Offi cel

JanetTechnology istics Branch Chief

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 January 27, 2010

PG QAPP–CBM Detailed Study Questionnaire Page i of iii 

Contents (Element A.2) 

Contents ........................................................................................................................... i

Tables .............................................................................................................................. i

Figures ............................................................................................................................ ii

Appendices ..................................................................................................................... ii

Distribution (Element A.3) ............................................................................................... iii

1.0 Introduction and Background .................................................................................. 1

2.0 Project Management Elements ............................................................................... 2

2.1 Project/Task Organization (Element A.4) ................................................................ 2

2.1.1 Project Management and Technical Staff ............................................... 2

2.1.2 Quality Assurance Staff .......................................................................... 4

2.2 Problem Definition and Background (Element A.5) ................................................. 4

2.3 Project/Task Description (Element A.6) ................................................................... 5

2.3.1 Finalizing Detailed Questionnaire ........................................................... 6

2.3.2 Preparing Electronic Version of Detailed Questionnaire ......................... 6

2.3.3 Mailing and Tracking Questionnaires ..................................................... 6

2.3.4 Developing a Survey Database and Data Dictionary ............................. 6

2.3.5 Providing Survey Assistance .................................................................. 6

2.3.6 Following Up on Incomplete Surveys ..................................................... 7

2.3.7 Coding and Entering Respondent Data into Survey Database ............... 7

2.3.8 Tabulating Data ...................................................................................... 7

2.4 Quality Objectives and Criteria (Element A.7) ......................................................... 7

2.4.1 Completeness ........................................................................................ 8

2.4.2 Accuracy ................................................................................................ 8

2.4.3 Reasonableness .................................................................................... 8

2.5 Special Training Requirements / Certification (Element A.8) ................................... 8

2.6 Documentation and Records (Element A.9) ............................................................ 9

3.0 Data Generation and Acquisition Elements ........................................................... 10

3.1 Sampling Process Design (Element B.1) .............................................................. 10

3.2 Sampling Methods (Element B.2) .......................................................................... 10

3.2.1 Completeness ...................................................................................... 10

3.2.2 Accuracy .............................................................................................. 11

3.3 Data Handling and Custody (Element B.3) ............................................................ 11

3.4 Data Management (Element B.10) ........................................................................ 12

3.4.1 Questionnaire Non-Response Follow Up ............................................. 12

3.4.2 Questionnaire Response Review and Follow Up ................................. 13

3.4.2 Questionnaire Response Coding and Data Entry ................................. 15

4.0 Assessment and Oversight Elements.................................................................... 16

4.1 Assessments and Response Actions (Element C.1) ............................................. 16

4.2 Reports to Management (Element C.2) ................................................................. 16

5.0 Reconciliation with User Requirements ................................................................. 18

6.0 References ............................................................................................................ 19

Tables 

Table 1. QAPP Distribution ..................................................................................................... iii
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PG QAPP–CBM Detailed Study Questionnaire Page ii of iii 

Figures 

Figure 1. Project Organization ........................................................................................ 3 

Figure 2. CBM Detailed Questionnaire Contact Record ............................................... 14 

Appendices 

Appendix A – Final Detailed Questionnaire .................................................................. A-1 

Appendix B – ICR Supporting Statement ..................................................................... B-1
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PG QAPP–CBM Detailed Study Questionnaire Page iii of iii 

Distribution (Element A.3)

This Quality Assurance Project Plan (QAPP) was distributed to staff of the U.S. Environmental 

Protection Agency, PG Environmental, LLC, and Eastern Research Group, Inc. (Table 1). A 

copy of the document was provided to all PG and Eastern Research Group personnel involved in 

the project, including those who joined the project after publication of the QAPP. 

Table 1. QAPP Distribution 

Name 

Title Contact Information Mailing Address 

U.S. Environmental Protection Agency 

Damon Highsmith 

Technical Project Officer 

(202) 566-2504 (phone) 

highsmith.damon@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 

Carey Johnston 

Work Assignment Manager 

(202) 566-1014 (phone) 

johnston.carey@epa.gov 

Janet Goodwin 

Technology & Statistics Branch 

Chief 

(202) 566-1060 (phone) 

goodwin.janet@epa.gov

PG Environmental, LLC 

Jim Parker 

Work Assignment Manager 

(703) 707-8258 x100 (phone) 

jim.parker@pgenv.com PG Environmental, LLC 

570 Herndon Parkway, Suite 500 

Herndon, VA 20170 

(703) 707-8259 (fax) 

Jan McGoldrick 

Quality Assurance Officer 

(703) 707-8258 x108 (phone) 

jan.mcgoldrick@pgenv.com

Katie Bradshaw 

Environmental Scientist 

(703) 707-8258 x109 (phone) 

katie.bradshaw@pgenv.com 

Paul Hanson 

Senior Chemical Engineer 

(303) 279-1778 x104 (phone) 

paul.hanson@pgenv.com

PG Environmental, LLC 

607 10th Street, Suite 307 

Golden, CO 80401 

(303) 279-1793 (fax) 

Eastern Research Group, Inc. (subcontractor to PG Environmental) 

Birute Vanatta 

Task Order Manager 

(703) 633-1724 (phone) 

Birute.Vanatta@erg.com Eastern Research Group, Inc. 

14555 Avion Parkway 

Suite 200 

Chantilly, VA 20151-1102 

(703) 263-7280 (fax) 

Betsy Bicknell 

Project Quality Assurance Officer 

(703) 633-1612 (phone) 

Betsy.Bicknell@erg.com

Lori Weiss 

Senior Chemical Engineer 

(703) 633-1658 (phone) 

Lori.Weiss@erg.com

Anne Jones 

Senior Economist (781) 674-7328 (phone) 

Anne.Jones@erg.com

Eastern Research Group, Inc 

110 Hartwell Avenue 

Lexington, MA 02421-3136 

(781) 674-2851 (fax) 
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PG QAPP–CBM Detailed Study Questionnaire Page 1 of 19 

1.0 Introduction and Background 

The U.S. Environmental Protection Agency (EPA), acting through its Office of Science and 

Technology (OST), Engineering and Analysis Division (EAD), is studying whether it would be 

appropriate to revise the effluent guidelines for the Oil and Gas Point Source Category to control 

pollutant discharges from coalbed methane (CBM) produced waters. Discharges from CBM 

operations are not covered by existing effluent limitations, guidelines, and standards (ELGs) 

because at the time the ELGs were established, CBM extraction was not a standard practice. 

Such extraction, however, has increased in recent years, raising the question of whether specific 

discharge restrictions should be developed. 

EPA required more detailed information on the characteristics of CBM produced water and of 

the technologies available to treat such discharges. To obtain these data, EPA undertook a 

Detailed Study, including a screener questionnaire and a detailed industrial survey. EPA tasked 

PG Environmental, LLC, (PG) with supporting the Agency in its Detailed Study under Work 

Assignment 2-01 of Contract No. EP-C-07-029. Specifically, EPA tasked PG with finalizing the 

draft detailed questionnaires that had been developed under earlier work assignments (Work 

Assignments 0-01 and 1-01) of the same contract. 

The detailed questionnaire contained both technical (Parts A and C) and economic (Part B) 

sections. PG finalized the questionnaire with assistance from Eastern Research Group, Inc., 

(ERG) (Work Assignment 2-01, EPA Contract No. EP-C-07-029, Subcontract No. EAD/029-

001). ERG provided support for revising the economic portion (Part B) of the detailed 

questionnaire under a separate work assignment and contract (under EPA Contract No. 68-C02-

095). This document represents PG’s project-specific QAPP to finalize and implement the 

detailed questionnaire up to and including data entry of Part A and Part C questionnaire 

responses into a database. It covers the work of the entire PG Team (i.e., PG and its 

subcontractor ERG) in conducting these tasks (1). Subsequent revisions to this QAPP will 

address the technical analysis of questionnaire responses. Quality assurance procedures related 

to survey design and statistical analyses are provided in the QAPP prepared by Battelle under a 

separate contract (Quality Assurance Project Plan for WA 2-11: Statistical Support for Coalbed 

Methane Detailed Study; Contract No. EP-C-05-030) (2). Procedures for maintaining the CBM 

public record are provided in the 304(m) Project File Management Plan prepared by ERG under 

a separate contract (1). 

This QAPP is responsive to applicable elements in EPA Requirements for Quality Assurance 

Project Plans QA/R-5 (3). It is a project-specific supplement to PG’s corporate quality 

management protocols, which detail the responsibilities of PG’s Quality Assurance and Quality 

Control (QA/QC) personnel and project management team; it also describes the procedures these 

staff use to plan, implement, and assess project quality. 

PG has organized this document according to the elements outlined in the above-mentioned EPA 

guidance document. Group A elements are addressed from the title page through section 2.6 of 

the document, while applicable Group B elements are addressed in section 3.0. Group C 

elements are addressed in section 4.0, and applicable Group D elements are addressed in section 

5.0. References are provided in Section 6.0. 
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PG QAPP–CBM Detailed Study Questionnaire Page 2 of 19 

2.0 Project Management Elements 

In this section, PG discusses its project management approach for the assignment. The discussion 

is organized according to the nine elements EPA identified for inclusion in this section: 

A.1 Title and Approval Sheet 

A.2 Table of Contents 

A.3 Distribution List 

A.4 Project/Task Organization 

A.5 Problem Definition/Background 

A.6 Project/Task Description 

A.7 Quality Objectives and Criteria 

A.8 Special Training/Certification 

A.9 Documents and Records 

Elements A.1 to A.3 were provided earlier in this document. The remaining elements are 

discussed below. 

2.1 Project/Task Organization (Element A.4)

Figure 1 presents the organizational framework under which PG developed and implemented the 

detailed questionnaire. The chart depicts the staff with program management and technical 

responsibilities and those with QA/QC roles. It shows the relationship and lines of 

communication among all project participants, including those from EPA, as users of the data, 

and those from ERG, a subcontractor on the assignment. 

2.1.1 Project Management and Technical Staff 

Jim Parker, the PG Work Assignment Manager (WAM), was responsible for all management and 

administrative aspects of the technical work performed for the project and for ensuring that the 

quality of work, schedule, and budget met the requirements of the EPA/EAD effluent guidelines 

program. Mr. Parker was also responsible for ensuring that all contractual issues were 

addressed. He was the principal contact for the EPA WAM on project issues, deliverables, and 

schedule, and he provided direction to ERG under subcontract EAD/029-001. Mr. Parker kept 

Jan McGoldrick, the PG QA Officer (QAO), informed of any quality issues that arose. 

Under the assignment, the PG Team (1) revised and finalized the detailed questionnaire; (2) 

developed an electronic version of the detailed questionnaire; (3) mailed and tracked the detailed 

questionnaires; (4) developed a database and database dictionary to house questionnaire data; (5) 

assisted detailed questionnaire respondents through voicemail and email; (6) followed up on 

incomplete detailed questionnaires; (7) entered detailed questionnaire data into the survey 

database; and (8) tabulated questionnaire data. 
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PG QAPP–CBM Detailed Study Questionnaire Page 3 of 19 

OST/EAD 

Project Officer 

PG QA Officer 

Other PG QA/QC 

Staff 

Technical Reviewers 

OST/EAD QA 

Coordinator 

OST/EAD 

Work Assignment 

Manager

PG Program 

Manager 

ERG Work 

Assignment 

Manager 

and 

Technical Staff

PG Work 

Assignment 

Technical Staff 

PG Work 

Assignment 

Manager 

ERG Project QA 

Coordinator 

 Project Reporting and Authority 

 Lines of Communication 

Figure 1: Project Organization (Element A.4)
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PG QAPP–CBM Detailed Study Questionnaire Page 4 of 19 

Mr. Jim Parker led PG’s efforts, while Ms. Birute Vanatta led ERG’s efforts. Mr. Parker and 

Ms. Vanatta were supported by other PG and ERG project staff as needed. The staff adhered to 

the QA guidelines outlined in this QAPP when providing technical support under the work 

assignment. In addition, they maintained complete, legible, permanent, and defensible records 

documenting all work performed. 

2.1.2 Quality Assurance Staff 

Jan McGoldrick, PG’s QAO, was responsible for developing and maintaining PG’s QA program 

based on the firm’s quality management protocols. She provided direction and guidance to PG 

and subcontractor QA/QC staff and, through them, to the technical and administrative staff 

completing the work. On this work assignment, Ms. McGoldrick, following consultation with 

PG’s Program Manager (PM), had the authority to suspend the performance of any activities 

determined to be deviating from the established quality management procedures, work plan, or 

project-specific QAPP until appropriate corrective actions were instituted. 

Betsy Bicknell served as ERG’s QA Coordinator for this project and, as such, was responsible 

for developing and executing ERG’s QA activities under the assignment. The PG WAM 

reviewed ERG’s performance, including its QA/QC activities, on an ongoing basis. The PG 

QAO could at her discretion conduct an audit of ERG’s QA activities during the period of 

performance of the assignment. 

The PG QAO and PG WAM appointed Technical Reviewers as needed during the conduct of 

this assignment. The Technical Reviewers evaluated the quality of work products as they were 

being developed and once they were completed. The reviewers did not have any involvement in 

the products or processes for which they were assigned QA/QC responsibilities. The Technical 

Reviewers could be internal or external to the PG Team. They had science, engineering, or 

water policy backgrounds, as well as experience in survey design, administration, and analysis. 

The ERG Work Assignment Manager also assigned internal ERG Technical Reviewers for 

activities being conducted by ERG. (For further discussion on procedures, see section 4.1 of 

this QAPP.)

2.2 Problem Definition and Background (Element A.5)

EPA developed and administered the CBM screener and detailed questionnaires to collect 

information to determine whether it would be appropriate to revise the effluent guidelines for the 

Oil and Gas Point Source Category to control pollutant discharges from CBM produced water. 

The purpose of the questionnaires was to gather industry information that would enable EPA to: 

• Profile the CBM industry and its produced water management practices 

• Determine the scope of the industry and any subcategories 

• Determine whether technically and economically feasible control technologies or 

management strategies exist to reduce or eliminate the discharge of pollutants 

• Determine whether the current regulatory controls are adequate. 

To address the key questions and project outcome described below, EPA employed a two-phase 

sample design. In the first phase, EPA collected information about CBM projects from a census 
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PG QAPP–CBM Detailed Study Questionnaire Page 5 of 19 

of CBM projects with more than two wells. The responses to the screener questionnaire served 

as the basis for EPA to select a sample of CBM projects to receive the detailed questionnaire. 

(For further discussion on sample design, see section 3.1 of this QAPP.)

The detailed questionnaire was designed to answer the following key questions: 

• What pollutants are being discharged by CBM operations? 

• How do produced volumes of gas and water change over the life of CBM projects? 

• What are the existing technically feasible produced water management alternatives? 

• For what geology/geography is each management alternative feasible? 

• What are the operation and maintenance costs of the technically feasible control 

technologies? 

• For what produced water characteristic is each management alternative feasible? 

• What are the expected incremental pollutant removals attributable to each management 

alternative? 

• What is the economic affordability (e.g., production losses, firm failures, impacts on 

small business) of each management alternative? 

• What are the non-water-quality impacts of each management alternative: 

o Soil contamination, destruction, and erosion 

o Energy use 

o Treatment residuals and other solid waste 

o Other impacts? 

This QAPP specifically addresses implementation of the detailed questionnaire. As noted in 

section 1.0 of this QAPP, survey design and statistical analysis for EPA’s CBM survey effort was 

handled by Battelle under a separate contract (2).

2.3 Project/Task Description (Element A.6)

EPA received approval from the Office of Management and Budget (OMB) for an industrial 

survey (screener and detailed questionnaires) under the Paperwork Reduction Act on February 

29, 2009. EPA published two Federal Register Notices announcing the data collection efforts 

(73 FR 4556, January 25, 2008; 73 FR 40575, July 15, 2008). The PG Team aided EPA in (1) 

finalizing the hard-copy detailed questionnaire, (2) preparing an electronic detailed 

questionnaire, (3) mailing and tracking questionnaires, (4) developing a survey database and 

database dictionary, (5) assisting respondents by phone and email, (6) following up on 

incomplete surveys, (7) entering respondent data into the survey database, and (8) tabulating 

questionnaire response data. A brief description of these tasks is provided in the subsections that 

follow. The QA/QC activities associated with the tasks are discussed in section 3 of this QAPP. 
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PG QAPP–CBM Detailed Study Questionnaire Page 6 of 19 

2.3.1 Finalizing Detailed Questionnaire 

The PG Team assisted EPA in finalizing the detailed questionnaire. There were no significant 

changes to the detailed questionnaire––only edits to improve the look and ease of use. Questions 

for the detailed questionnaire were designed to elicit information in the following areas: 

• Company economic information 

• Quantity and quality of water produced during methane extraction 

• Produced water discharge or reuse location and method 

• Produced water treatment methods prior to disposal or reuse 

• Capital and operating costs and energy consumption of produced water treatment and 

disposal 

• Residuals (sludge, brine, air emissions) produced during water treatment––quantity, 

quality, and disposition 

• Names, locations, and production histories of CBM extraction projects (one or more 

wells) 

• Gas and produced water production rates over the life of each project 

• Information about current National Pollutant Discharge Elimination System (NPDES) 

and other operating permits. 

Appendix A of this QAPP is a copy of the final detailed questionnaire. Appendix B is a copy of 

the Information Collection Request supporting statement. 

2.3.2 Preparing Electronic Version of Detailed Questionnaire 

PG, with support from ERG, developed an electronic version of the detailed questionnaire. This 

version enabled CBM project operators to report their responses to the detailed questionnaire 

electronically to EPA. The electronic version of the detailed questionnaire was produced in 

Microsoft Word and was similar in appearance to the hard-copy version. 

2.3.3 Mailing and Tracking Questionnaires 

PG printed and mailed hard-copy versions of the final detailed questionnaire as directed by EPA. 

PG also accepted delivery of completed detailed questionnaires. The PG Team conducted some 

follow-up in terms of questionnaires not returned (e.g., follow-up phone calls, emails, or letters). 

2.3.4 Developing a Survey Database and Data Dictionary 

Under Work Assignment 2-01, the PG Team developed a database for entering questionnaire 

responses for Parts A and C of the questionnaire, as well as a data dictionary describing the data 

elements. In addition, the PG Team developed procedures it would use for performing QA/QC 

of the data and preparing and printing data tabulations. 

2.3.5 Providing Survey Assistance 

PG maintained a phone number and email address on behalf of EPA during the detailed 

questionnaire response period. Operators with inquiries about the questionnaires were able to 
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PG QAPP–CBM Detailed Study Questionnaire Page 7 of 19 

contact EPA through PG in this manner. PG logged and reviewed the messages daily and 

distributed the questions to appropriate responders using a tracking system. In general, the PG 

Team responded to questions pertaining to the technical portion of the questionnaires, while 

ERG, under a separate contract and work assignment, responded to questions pertaining to the 

economic section (1). PG forwarded policy-related questions to EPA OST/EAD for response. 

The PG Team prepared a Frequently Asked Questions (FAQs) document in anticipation of 

commonly asked administrative and technical questions. The PG Team and EPA continually 

discussed the nature of the questions received and the responses given to ensure consistency 

among responses and to minimize the introduction of bias into the survey process. As necessary, 

the FAQs were updated to reflect revised or additional questions and associated responses. 

2.3.6 Following Up on Incomplete Surveys 

As PG received the detailed questionnaires, they were reviewed for completeness (i.e., to ensure 

that responses to all questions were provided). Procedures for follow-up are identified in section 

3.4 of this QAPP. PG developed documentation for the public record that summarized how the 

questionnaires were implemented and tracked. 

2.3.7 Coding and Entering Respondent Data into Survey Database 

For the detailed questionnaire, the PG Team coded responses on the hard-copy questionnaires to 

ensure that the responses were in a form that could be easily entered into the detailed survey 

database. The Team then entered the detailed questionnaire responses into the survey database. 

More detail regarding this procedure is provided in Section 3.4.2.

CBM operators were able to identify responses containing confidential business information 

(CBI) on the questionnaires. The PG Team handled all CBI data in accordance with applicable 

EPA procedures (see also section 2.5). 

2.3.8 Tabulating Data 

Once all the questionnaires had been entered into the survey database, in accordance with the 

procedures in section 3.4, the PG Team conducted accuracy checks and followed up on any 

problems identified in reviewing the hard-copy questionnaires and data. The PG Team also 

identified whether the database contained any outliers and investigated them accordingly. 

2.4 Quality Objectives and Criteria (Element A.7)

The primary objective of this QAPP was to ensure that the data collected using the CBM detailed 

questionnaires would be of the quality necessary to support EPA in determining whether it would 

be appropriate to revise the effluent guidelines for the Oil and Gas Point Source Category to 

control pollutant discharges from CBM produced water. The tasks described earlier, in section 

2.3, involved the collection and use of data gathered using a detailed survey of selected CBM 

projects. Questionnaire data collected directly from industry personnel were considered primary 

data. The PG Team defined the acceptance criteria (i.e., data specifications) it used to evaluate 

whether the data collected under the technical portions of the screener and detailed 

questionnaires would be suitable for EPA’s study needs. The acceptance criteria were related to 

the completeness, accuracy, and reasonableness of questionnaire responses. 
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PG QAPP–CBM Detailed Study Questionnaire Page 8 of 19 

2.4.1 Completeness 

Completeness was defined as the number of valid responses received compared to the number of 

questionnaires distributed. As described in part B of the ICR Supporting Statement (Appendix 

B), EPA considered non-responses to specific questions and non-responses to the overall detailed 

questionnaires in developing the sampling design for the CBM industry. Therefore, acceptable 

completeness was determined in terms of EPA’s statistical sampling plan. The PG Team worked 

with EPA’s statisticians to determine the levels of completeness required. The specific methods 

the PG Team used to improve completeness are described in section 3.4 of this QAPP. 

2.4.2 Accuracy 

Questionnaire accuracy pertained to (1) whether the respondents provided correct answers to the 

questions asked; (2) whether the responses provided were interpreted correctly by the 

questionnaire sponsor; and (3) whether the responses entered into the questionnaire database 

were free from error. The PG Team was not tasked with developing and implementing tools, 

such as conducting on-site inspections and interviews, to measure elements 1 and 2. The 

methods the PG Team used to measure element 3, or to increase the accuracy of responses, are 

described in section 3.4 of this QAPP. The PG Team’s goal for data entry accuracy was 100 

percent error-free. 

2.4.3 Reasonableness 

To be suitable for use in EPA’s overall CBM Detailed Study, the data collected by the detailed 

questionnaires had to reasonably reflect physical possibilities and industry practices. For 

example, a produced water flow rate of 1 billion gallons per hour is not physically possible and 

therefore is not reasonable. The PG Team’s goal was for all responses to be reasonable. The 

methods the PG Team used to evaluate and improve the reasonableness of questionnaire 

responses are described in section 3.4 of this QAPP. 

2.5 Special Training Requirements / Certification (Element A.8)

As noted previously, the owners and operators of CBM industries could indicate that certain 

responses on their questionnaires contained CBI. PG’s Document Control Officer (DCO) for 

CBI worked in conjunction with EPA’s DCO to regulate access to all CBI received by PG under 

this assignment. Only authorized PG employees and subcontractors were allowed access to the 

CBI. Only the PG DCO or an authorized employee could release CBI material. 

Access to CBI by PG employees was based on an employee’s need-to-know status. Before 

access was authorized, an employee’s justification for access was documented and submitted to 

the PG DCO. This notice indicated the name of the employee, why access to CBI was necessary, 

and the Work Assignment number under which the employee used CBI. The PG DCO informed 

the employee of his or her responsibilities for the security of CBI. The employee was required to 

familiarize himself or herself with the appropriate procedures for handling CBI. 

PG required all subcontractors and consultants that had been determined by the PG DCO to have 

a demonstrated need to know under the work assignment to submit a CBI security plan before 

being awarded any tasks involving CBI. ERG, the subcontractor under this assignment, already 

had an approved CBI plan with EPA OST/EAD for effluent guidelines-related support. 
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PG QAPP–CBM Detailed Study Questionnaire Page 9 of 19 

2.6 Documentation and Records (Element A.9)

PG developed and instituted document control mechanisms for reviewing, revising, and 

distributing QAPPs. Each QAPP has a signed approval form, title page, table of contents, and 

EPA-approved document control format, which appears in the upper right corner of each page. 

(See header at the top of each page of this QAPP for a specific example.) During the course of 

the project, PG circulated any revisions to the QAPP to technical and QA/QC project staff at PG, 

ERG, and EPA. 

PG and ERG adhered to their respective standard practices for managing project-related data, 

documents, and records. In finalizing and implementing the detailed questionnaire, information 

and data collected included questionnaire responses, helpline questions and responses, 

questionnaire tracking documentation, and summary memoranda related to the survey effort. In 

addition, survey responses were entered into a database for subsequent analysis by EPA. All 

technical data collected, generated, and analyzed on the project were handled and stored in a 

centralized file in PG’s Herndon, Virginia, office. All documents collected or produced in the 

course of the project were stored in the centralized file. The ERG Task Order Manager 

designated an ERG project staff member to maintain all project files and ensured that appropriate 

files were submitted to PG at periodic intervals throughout the assignment. 

The PG Team describes how it managed data obtained from the CBM detailed questionnaires in 

section 3.4 of this QAPP under Element B.10, Data Management. Computer files were 

maintained by PG employees and on PG’s servers. All computer users were instructed on the 

importance of routinely archiving project data files from hard drives to the server and, as 

necessary, tape backup storage or diskettes. 

As described in Section 2.5 above, materials designated as CBI were maintained separately, 

under restricted access, and used only in accordance with PG’s policies and procedures for CBI 

by staff who had received CBI clearance, with oversight by the DCO. 

All quality system documents and records will be maintained for the life of the contract. Quality 

system records were filed according to guidance provided by the PG Program Manager and 

QAO. 

Disposition of quality system documents and records was determined in accordance with 

contract requirements. 
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PG QAPP–CBM Detailed Study Questionnaire Page 10 of 19 

3.0 Data Generation and Acquisition Elements 

The detailed questionnaire involved collecting and reviewing data obtained from the owners 

and/or operators of CBM extraction projects. Elements B.1 to B.3 and Element B.10 below were 

relevant to this task. The PG Team’s approach to each of these elements is described in the 

subsections that follow. 

• Element B.1, Sampling Process Design 

• Element B.2, Sampling Methods 

• Element B.3, Sample Handling and Custody 

• Element B.4, Analytical Methods 

• Element B.5, Quality Control 

• Element B.6, Instrument/Equipment Testing, Inspection, and Maintenance 

• Element B.7, Instrument/Equipment Calibration and Frequency 

• Element B.8, Inspection/Acceptance of Supplies and Consumables 

• Element B.9, Non-direct Measurements 

• Element B.10, Data Management 

3.1 Sampling Process Design (Element B.1) 

As discussed in sections 1.0 and 2.3 of this QAPP, EPA conducted a detailed survey of a 

sampling of CBM projects identified as part of the screener questionnaire. Using a sample frame 

of 773 projects (screener surveys), EPA, with support from Battelle, selected 203 CBM projects 

to receive detailed questionnaires. EPA selected the projects for sampling by basin, 

establishment size, and discharge method (i.e., direct or indirect discharge, and zero discharge). 

Within each sampled strata, EPA targeted 30 percent of the projects for sampling. Additional 

details on the sampling process design have been provided in a memorandum prepared by 

Battelle under a separate contract (EPA Contract No. EP-05-030, Work Assignment 4-11: 

Coalbed Methane (CBM) Study: Final Detailed Questionnaire Sample Design) (4). 

3.2 Sampling Methods (Element B.2) 

EPA distributed the detailed questionnaires under the authority of section 308 of the Clean Water 

Act (Federal Water Pollution Control Act, 33 U.S.C. § 1318). All CBM project operators that 

received a detailed questionnaire were required by law to respond to it. 

3.2.1 Completeness 

As it relates to the sampling method, completeness was defined as the number of valid responses 

received compared to the number of questionnaires distributed. EPA assumed a relatively high 

response rate for the survey effort. For the detailed questionnaire, EPA adjusted the estimated 

sample size assuming a non-response rate of 10 percent. This assumption of a 10 percent nonresponse rate was based on EPA’s experience with a typical effluent guidelines questionnaire. 

EPA adjusted the detailed sample weights for any non-response for the survey. 

When developing the initial drafts of the detailed questionnaire, EPA and the PG Team had 

worked closely (under other work assignments) with applicable industry trade associations. The 
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PG QAPP–CBM Detailed Study Questionnaire Page 11 of 19 

CBM industry was therefore generally well informed of the goals and objectives of EPA’s study 

effort and of EPA’s schedule for questionnaire distribution and receipt. 

Under a previous work assignment, ERG and EPA had developed contact names and mailing 

lists for CBM operators. An accurate mailing list reduced the number of undeliverable 

questionnaires and improved completeness. 

3.2.2 Accuracy 

For the questionnaires to result in accurate information concerning the CBM industry, 

respondents had to provide correct responses to the questions asked, and the PG Team and EPA 

had to interpret the responses correctly. Under an earlier work assignment, the PG Team and 

EPA had worked with industry representatives to determine the best terminology to use when 

developing questions. Industry representatives had also made suggestions regarding the types of 

questions that would be best. The PG Team and EPA then verified that draft questions would 

elicit the information needed to answer questions related to EPA’s overall CBM Detailed Study. 

The entities listed below were asked to provide comments on drafts of the detailed questionnaire 

and to provide specific comment on the terminology used, the definitions of key terms, and the 

availability of the data requested: 

• Internal ERG and PG environmental Technical Reviewers 

• EPA core workgroup members 

• EPA extended workgroup members 

• CBM industry and trade association personnel 

• General public, including tribes, environmental groups, and other stakeholders 

• The Office of Management and Budget (OMB). 

3.3 Data Handling and Custody (Element B.3) 

As noted previously, PG assigned a unique survey identifier to every potential respondent to the 

detailed questionnaire. PG also established hard-copy files for each respondent containing this 

information. Finally, PG printed the survey identifier on each page of the detailed questionnaire. 

PG established an electronic system to track each detailed questionnaire mailed. The system 

included the unique survey identifier and the dates the questionnaires were mailed and received 

by the applicable CBM owner/operator. As completed detailed questionnaires were received, PG 

date-stamped the first several pages of each major section and logged the dates into the 

electronic tracking system. 

As described in Section 2.3.2, an electronic detailed questionnaire was provided as an option for 

response. PG also logged the dates on which any CD-ROMs or DVDs of electronic detailed 

questionnaire responses were received. 

To document reviewer mark-ups, PG photocopied all returned detailed questionnaires. The PG 

Team used the photocopies of the questionnaire responses when conducting follow-up, data 

coding (where applicable), and data entry. These photocopies, along with the original 

questionnaires, were stored in PG’s CBI room in files arranged by the unique survey identifier 
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PG QAPP–CBM Detailed Study Questionnaire Page 12 of 19 

number and respondent name. Upon completion of the survey review task, PG provided EPA 

with the CD-ROM or DVD versions of the marked-up photocopies for the public record (minus 

any data identified as CBI). ERG, under a separate contract with EPA (1), maintained the public 

record for the CBM survey effort. 

The PG Team managed the data entry process for Parts A and C of the detailed questionnaire. 

PG provided ERG with PDF versions of each detailed questionnaire for its review and data entry 

for Part B (economic section). The PG Team reviewed, coded, and entered detailed 

questionnaire data. ERG’s activities related to review and data entry of the economic portions of 

the detailed questionnaire were performed under a separate work assignment (1). PG logged the 

date on which the PDF versions of the detailed questionnaires were transmitted to ERG into the 

electronic tracking system. PG and ERG adhered to EPA procedures for handling CBI when 

handling and transmitting questionnaires, as well as to their own standard protocols for handling 

other project-related data, documents, records, and memoranda. 

3.4 Data Management (Element B.10) 

The PG Team implemented the following QA activities to improve the completeness, accuracy, 

and reasonableness of responses to the detailed questionnaires received. 

3.4.1 Questionnaire Non-Response Follow Up 

The PG Team conducted some follow-up (e.g., follow-up phone calls) in terms of non-response 

to questionnaires. EPA determined the extent to which follow-up would be conducted before 

considering a questionnaire non-responsive. The PG Team determined, in conjunction with the 

EPA statisticians, what was an acceptable response rate for the questionnaires. EPA was ready 

to implement other means for collecting questionnaires, including, as necessary, follow-up phone 

calls and letters, criminal fines, civil penalties, and other sanctions, as provided by law. The PG 

Team operated a phone line and email address where CBM industry owners and operators could 

submit questions regarding the surveys. The PG Team and EPA responded to these inquiries in a 

consistent manner. These activities also helped to improve the completeness of responses on 

individual questionnaires (see section 3.4.2 below). 

As noted previously, EPA tasked PG with distributing the detailed questionnaires. The PG Team 

undertook numerous QC activities to improve the questionnaire responses. The QC activities 

included the following: 

• PG printed the questionnaires with a unique survey identifier on every page. The unique 

survey identifier was then included in the questionnaire database, hard-copy and 

electronic tracking forms, and hard-copy files. 

• PG reviewed the questionnaire cover letters, printed questionnaire forms, and mailing 

labels against the original mailing list provided by EPA to ensure that all the information 

matched and was consistent. 

• PG created an electronic tracking log. For the detailed questionnaires the log included 

such information as the unique survey identifier, targeted CBM operator and address, 
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PG QAPP–CBM Detailed Study Questionnaire Page 13 of 19 

date mailed, date received by recipient, date returned, follow-up conducted and results, 

and date data entered into survey database. 

• PG mailed a hard-copy form of the detailed questionnaire to a sample of CBM projects 

identified by EPA through a tracking service (i.e., U.S. Postal Service registered mail, or 

Federal Express). This enabled the PG Team to track each project’s receipt of the 

questionnaire. Respondents, however, also had the option of downloading an electronic 

version of the detailed questionnaire from EPA’s Web site so that they could complete it 

electronically rather than by hand. Respondents choosing this approach simply mailed 

EPA a CD-ROM or DVD of their questionnaire responses rather than sending a hardcopy version. The purpose of providing respondents with alternative forms of 

submission was to enhance EPA’s ability to collect detailed questionnaires. 

• Reminder postcards were sent midway through the survey time frame to operators that 

had not yet responded to the survey at that point in time. The purpose of this effort was 

to ensure that responses would be received. 

3.4.2 Questionnaire Response Review and Follow Up 

PG reviewed Parts A and C of each received detailed questionnaire for completeness and 

reasonableness. As necessary, PG called respondents when questionnaires were found to be 

incomplete. PG’s reviews specifically identified the following: 

• Missing or incomplete responses if not caught earlier during the questionnaire receipt and 

tracking phase 

• Inconsistent responses (e.g., questions completed when a response directed that they be 

skipped, responses that contradicted other questionnaire responses) 

• Unreasonable responses (out of the permissible range). 

If any of these issues were identified, PG called the respondent to obtain a complete, consistent 

response to each question. PG documented those communications and changed the original 

questionnaire response based on the follow-up communication. The communications were 

logged, and the communication record was stored in the survey file in PG’s CBI-secured room. 

After review and follow-up were completed, PG reported the number of valid responses provided 

for each question. PG worked with EPA statisticians to determine whether there were enough 

responses to make generalizations about the CBM project universe. 

To further improve the completeness and accuracy of questionnaire responses, PG developed an 

electronic version of the detailed questionnaire that aided in the preparation of responses to the 

questionnaire. Second, the PG Team and EPA provided assistance to questionnaire respondents 

by telephone and an email messaging system. For the detailed survey effort, the PG Team also 

offered support to respondents in completing the detailed questionnaire. 

Before mailing out the detailed questionnaires, the PG Team also developed FAQs that contained 

anticipated questions from questionnaire respondents and appropriate responses from the PG 

Team and EPA staff. The PG Team routinely discussed with EPA the nature of questions being 
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PG QAPP–CBM Detailed Study Questionnaire Page 14 of 19 

received and the answers being given to ensure that bias was not being introduced into the survey 

process. The PG Team updated the FAQs as necessary and distributed the updated FAQs to 

appropriate project team members. 

PG documented the following with respect to the detailed questionnaires: mail-out and receipt 

dates; specifics regarding follow-ups to helpline and email inquiries; findings from the review of 

completed questionnaires; notes from follow-up inquiries with respondents and related edits 

made to questionnaire responses; and transmission of questionnaires from PG to ERG. 

PG used a form (Figure 2) to document telephone conversations with respondents. PG stored the 

completed forms in the applicable questionnaire file in the CBI room for the study. PG provided 

copies of these records to EPA as requested. 

Project Name: CBM Detailed Study 

Project No: 

Facility ID: 

Facility Name: 

Contact Name: Contact Phone No: Contact Email Address: 

 

Date: PG Staff Name: 

Time: AM PM 

This document 

contains CBI: 

 _____ Yes 

 _____ No

Type of Contact: 

 Email Telephone 

General Subject(s) 

Discussed: 

CBI = 

Yes (Y)

Question 

No. Topics Discussed

 

 

 

Figure 2: CBM Detailed Questionnaire Contact Record 
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PG QAPP–CBM Detailed Study Questionnaire Page 15 of 19 

At the completion of the detailed questionnaire mail-out and receipt procedures, PG produced a 

memorandum for the public record that summarized the tracking procedures followed. The 

memorandum included such information as basic procedures followed, statistics regarding the 

number of questionnaires mailed and returned, significant dates, statistics regarding the number 

of complete and incomplete questionnaires, the number of helpline calls or email inquiries 

received and responded to while the questionnaires were in the field, and the number of followup calls the PG Team and EPA made to obtain complete questionnaires. 

3.4.2 Questionnaire Response Coding and Data Entry 

The PG Team developed a Microsoft Access database in which responses to the detailed 

questionnaires were entered. 

Before entering the data for Parts A and C of the detailed questionnaire, PG Team staff coded the 

completed detailed questionnaires to ensure that all responses were in the format required for 

data entry. (Questionnaire coding improves the accuracy of data entry.) A CBI-cleared ERG 

employee with prior experience related to questionnaire data entry keyed information from the 

hard-copy surveys into the database. To ensure that the database was accurate, a second CBIcleared PG team member independently reviewed 20 percent of the questionnaires for data entry 

accuracy. If data entry errors were identified, the PG Team coordinated with the EPA WAM to 

determine, based on the resources available, the extent of additional review (i.e., greater than 20 

percent) that should be performed on data entry. To further minimize the potential for keying or 

other errors, all data entry staff were experienced in the use of Microsoft Access. When errors in 

database entry were discovered during review, ERG corrected the data field for the CBM 

project(s). Separate ERG staff performed a 100 percent check to ensure that resolved errors were 

correctly re-entered into the Microsoft Access database. 

The completed database containing detailed questionnaire data was stored electronically on 

ERG’s secure CBI network. PG also stored a copy of the database on its secure CBI network to 

facilitate future data analysis. The PG Team prepared a data element dictionary to document the 

database structure and to serve as a guide for database users. The PG Team could query the 

system to determine whether any responses were missing for a given question for any 

questionnaire respondent. The PG Team followed up on any such discrepancies identified. 
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PG QAPP–CBM Detailed Study Questionnaire Page 16 of 19 

4.0 Assessment and Oversight Elements 

This section describes the methods the PG Team used to assess the quality of work conducted for 

the questionnaire data collection tasks. 

4.1 Assessments and Response Actions (Element C.1) 

The PG WAM and PG QAO appointed Technical Reviewers as needed during the conduct of the 

work assignment. The ERG Task Order Manager and QA Coordinator did the same. The 

products likely to receive a technical review included one or more of the following: 

• Revisions to the detailed questionnaire 

• Draft/final of electronic detailed questionnaire 

• Draft/final of survey database and database dictionary. 

In addition, a technical review of the documentation of follow-up work on incomplete 

questionnaires was performed. For the detailed survey, only a sample was reviewed. Technical 

reviews are critical evaluations of work performed. PG and ERG adhered to their respective 

standard procedures for conducting and documenting such reviews, as well as the responsibilities 

of reviewers. In general, technical reviews are conducted by professionals who are proficient in 

the work areas of interest, but who were not directly responsible for performance of the work. 

Technical reviewers document the results of their reviews. For this work assignment, the PG 

WAM was responsible for ensuring that technical reviews were conducted by the appropriate 

personnel and documented according to company policies. 

PG’s QAO and ERG’s Project QA Coordinator assessed the implementation of QA/QC 

procedures on this project as follows: 

• Reviewed this QAPP for completeness and applicability and signed the signature page of 

the QAPP following successful review(s). 

• Trained all project staff to ensure that all QC procedures in the QAPP were understood 

prior to initiation of technical support. 

• Audited project files to verify that project staff were (1) using the QC procedures 

identified in this QAPP, (2) using appropriate PG and ERG standard operating 

procedures, and (3) documenting the deliverable review process. If not, the PG QAO 

directed the PG WAM to implement corrective action and document that the action was 

taken. ERG followed a similar procedure between that firm’s Project QA Coordinator 

and Task Order Manager. Corrective action could include additional staff instruction or 

the development and use of additional measures to ensure the quality of data management 

and review. 

4.2 Reports to Management (Element C.2) 

The PG WAM informed the EPA WAM of the progress of all work activities through the 

monthly progress reports required under Work Assignment 2-01 of EPA Contract No. EP-C-07-

029. 
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PG QAPP–CBM Detailed Study Questionnaire Page 17 of 19 

PG’s Technical Reviewers and the QAO communicated any quality deficiencies identified as a 

result of reviews or audits to the PG WAM in writing. ERG’s Technical Reviewers and Project 

QA Coordinator did the same, notifying ERG’s Task Order Manager, who, in turn, reported the 

information to the PG WAM. If quality objectives and criteria were not met, the PG WAM was 

responsible for ensuring that the appropriate corrective actions were taken and reported to PG’s 

QAO. An example of an appropriate corrective action would be additional data entry review if 

data entry errors were identified. 

As required by Work Assignment 2-01, PG also supplied quarterly QA status reports to the EPA 

WAM. During the active phase of the detailed survey, the QA status reports were provided 

monthly, and verbal reports were provided as part of the standing weekly work assignment status 

meeting. If urgent issues arose, verbal reports were provided to EPA immediately. 
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PG QAPP–CBM Detailed Study Questionnaire Page 18 of 19 

5.0 Reconciliation with User Requirements 

Completed detailed questionnaires are the primary data sources that EPA used to answer the key 

questions posed in section 2.2.1 of this QAPP. The questionnaire responses provided detailed 

descriptions of CBM extraction operations, industry finances, and produced water management 

practices. EPA used the questionnaire data, in combination with secondary data, to support its 

overall CBM Detailed Study. 

The PG Team thoroughly documented for the public record all primary and secondary source 

data used in any reports or memoranda developed under Work Assignment 2-01 of Contract No. 

EP-C-07-029. Subsequent analyses of questionnaire responses clearly described for the record 

any limitations of the quality of the questionnaire data or assumptions required for its use. 
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PG QAPP–CBM Detailed Study Questionnaire Page 19 of 19 

6.0 References 

(1) ERG finalized, reviewed, and analyzed the economic section (Part B) of the detailed 

questionnaire under a separate QAPP, work assignment, and contract (Contract No. 68-C02-

095). ERG also assisted PG as a subcontractor in finalizing, reviewing, and analyzing the 

detailed questionnaire under WA 2-01 of EPA Contract EP-C-07-029. This QAPP is for the 

latter activities (Parts A and C), although reference is often made to ERG’s activities with 

respect to the economic sections of the questionnaires. 

(2) Battelle (November 2, 2007). Quality Assurance Project Plan for WA 2-11: Statistical 

Support for Coalbed Methane Detailed Study; Contract No. EP-C-05-030. 

(3) U.S. Environmental Protection Agency (March 2001). EPA Requirements for Quality 

Assurance Project Plans, EPA QA/R-5. EPA, Office of Environmental Information, 

Washington, DC, EPA/240/B-01/003. 

(4) Battelle (October 19, 2009). EPA Contract No. EP-05-030, Work Assignment 4-11: Coalbed 

Methane (CBM) Study: Final Detailed Questionnaire Sample Design. 
 Rev. 1 

 January 27, 2010 

Appendix A, PG QAPP–CBM Detailed Study Questionnaires Page 1 of 116 

Appendix A 

Draft Detailed Questionnaire 
November 2009 

Attach Address Label

U.S. ENVIRONMENTAL PROTECTION AGENCY 

DRAFT QUESTIONNAIRE FOR THE COALBED METHANE 

EXTRACTION SECTOR 

Form Approved 

OMB Control No. 2040-0279 

Approval Expires 2/29/12 

 The public reporting and recordkeeping burden for this collection of information is estimated to average 

approximately 80 hours per response. Burden means the total time, effort, or financial resources expended by persons to 

generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to 

review instructions, develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, 

and verifying information, processing and maintaining information, and disclosing and providing information; adjust the 

existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond 

to a collection of information; search data sources; complete and review the collection of information; and transmit or 

otherwise disclose information. An agency may not conduct or sponsor, and a person is not required to respond to, a 

collection of information unless it displays a currently valid OMB control number. 

 To comment on the Agency’s need for this information, the accuracy of the provided burden estimates, and any 

suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has 

established a public docket for this ICR under Docket ID No. EPA-HQ-OW-2006-0771, which is available for public 

viewing at the Water Docket in the EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW, 

Washington, DC 20004. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday 

through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone 

number for the Water Docket is (202) 566-2426. An electronic version of the public docket is available through the federal 

data management system (FDMS) at http://www.regulations.gov. Use FDMS to submit or view public comments, access the 

index listing of the contents of the public docket, and to access those documents in the public docket that are available 

electronically. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID 

No. EPA-HQ-OW-2006-0771 and OMB control number (2040-0279) in any correspondence. 
General Instructions CBM Questionnaire

i

Operator ID: 

INTRODUCTION 

The U.S. Environmental Protection Agency (EPA) is conducting a survey of coalbed methane (CBM) 

extraction operations. EPA will use the responses collected in this detailed questionnaire to inform its 

decision on whether to initiate a rulemaking to potentially revise the effluent guidelines for the Oil and 

Gas Extraction Point Source Category (40 CFR 435) to include limits for pollutants discharged in CBM 

produced water. This questionnaire is not focused on conventional oil and gas extraction. Any regulatory 

decisions resulting from this survey will not affect conventional oil and gas operations. The technical 

data collected will be used to determine the characteristics of CBM produced water, potential 

environmental impacts, existing management, beneficial use, and disposal practices for CBM produced 

water, and the related costs for this industry sector. The financial and economic data collected will be 

used to characterize the economic status of the industry sector and to estimate the possible economic 

impacts of potential technology and beneficial use options for CBM produced water. EPA is conducting 

this survey as part of its annual review of existing effluent guidelines, which is required by the Clean 

Water Act (CWA) sections 301(d) and 304(b). You must respond to this questionnaire if you operated a 

CBM well in 2008. 

EPA is conducting this survey under the authority of Section 308 of the Clean Water Act (Federal Water 

Pollution Control Act, 33 U.S.C. Section 1318). You must respond to this questionnaire within 60 

days of receiving it unless EPA authorizes an extension (see page iii). Failure to respond, late filing, or 

failure to comply with the instructions may result in criminal fines, civil penalties, and other sanctions, 

as provided by law. 

OVERVIEW OF THE QUESTIONNAIRE 

The questionnaire is divided into three parts: Part A lists the projects operated by your company that 

have been selected for this questionnaire, Part B contains financial and economic Information, and part 

C contains produced water management information. The parts are divided into the following sections: 

PART A: CBM PROJECTS SELECTED FOR QUESTIONNAIRE AND CERTIFICATION

Part A of the questionnaire identifies the projects selected for this questionnaire. The questions in Parts 

B and C pertain only to the projects listed in Part A. You are required to provide information in Part B, 

Section 3, and Part C, Sections 2 through 4, for each of the projects identified in Part A. 

PART B: FINANCIAL AND ECONOMIC INFORMATION

INSTRUCTIONS FOR PART B 

SECTION 1: CONTACT INFORMATION 

SECTION 2: FIRM-LEVEL FINANCIAL QUESTIONS 

SECTION 3: PROJECT-LEVEL QUESTIONS 

The financial and economic data collected in Part B of this questionnaire will be used to characterize the 

economic status of the industry and to estimate the possible economic impacts of wastewater 

regulations. The questions in Part B pertain to calendar years 2006 through 2008. 

PART C: PRODUCED WATER MANAGEMENT INFORMATION

INSTRUCTIONS FOR PART C 

SECTION 1: GENERAL OPERATOR INFORMATION 

SECTION 2: PRODUCED WATER MANAGEMENT SYSTEM GENERAL QUESTIONS 
General Instructions CBM Questionnaire

ii

SECTION 3: DETAILED PRODUCED WATER MANAGEMENT AND TREATMENT 

QUESTIONS 

SECTION 4: PRODUCED WATER QUALITY DATA 

The information requested in Part C of this questionnaire will be used to analyze produced water 

production rates, produced water characteristics, and produced water management, treatment, and 

disposal practices. Part C requests information for calendar year 2008. 

PART D: SUPPORTING INFORMATION

LIST OF ACRONYMS 

DEFINITION OF KEY TERMS 
General Instructions CBM Questionnaire

iii

Operator ID: 

COMPLETION OF THE QUESTIONNAIRE 

Each section of the questionnaire should be completed by the person(s) most knowledgeable about the 

information requested. The corporate official or designee responsible for directing or supervising the 

response to the questionnaire must sign the Certification Statements on page A-6 to verify and validate 

the information provided. 

Keep a Copy of the Completed Questionnaire

Please keep a copy of the completed questionnaire, including attachments. EPA will review the 

information submitted and may request your cooperation in answering follow-up questions, if necessary, 

to complete analyses. 

QUESTIONNAIRE ASSISTANCE 

EPA Coalbed Methane Help Lines

Phone Line (Leave Voice Mail for a Response within One Business Day) ..................................................................... XXX-XXX-XXXX 

Internet Electronic Mailing Address (Response within One Business Day) ....................................................................... XXX@XXX.com

WHEN TO RETURN QUESTIONNAIRE 

You must respond to this questionnaire within 60 days of receiving it. 

If you wish to request an extension, you must do so in writing within 30 days of receipt of this 

questionnaire. Written requests may be e-mailed to Mr. Carey Johnston at johnston.carey@epa.gov with 

“CBM Survey Extension Request” in the e-mail subject line or may be mailed to: 

United States Postal Service One- or Two-Day Delivery (e.g., FedEx)

Mr. Carey Johnston Mr. Carey Johnston 

U.S. EPA, Office of Water U.S. EPA, Office of Water 

Mail Code: 4303T Room 6231G, EPA West 

1200 Pennsylvania Avenue, N.W. 1301 Constitution Avenue, NW 

Washington, DC 20460 Washington, DC 20004 

Extension requests will be evaluated on a case-by-case basis. Submittal of an extension request to EPA 

does not alter the due date of your questionnaire unless and until EPA agrees to the extension and 

establishes a new date. 

WHERE TO RETURN QUESTIONNAIRE 

After completing the questionnaire and certifying the information that it contains, please use the 

enclosed mailing label to mail the completed questionnaire to: 

U.S. Environmental Protection Agency 

CBM Industry Survey 

c/o PG Environmental, LLC 

447B Carlisle Drive 

Herndon, VA 20170 
General Instructions CBM Questionnaire

iv

Operator ID: 

REQUESTING AN ELECTRONIC VERSION OF THE QUESTIONNAIRE 

If you would like an electronic version of the questionnaire, it is available on the EPA Web site at: 

http://www.epa.gov/guide/cbm/. 

CONFIDENTIAL BUSINESS INFORMATION 

If no business confidentiality claim accompanies the information when it is received by EPA, EPA 

may make the information available to the public without further notice.

Regulations governing the confidentiality of business information are contained in the Code of Federal 

Regulations (CFR) at Title 40 Part 2, Subpart B. You may assert a business confidentiality claim 

covering part or all of the information you submit, other than effluent data and information or data that 

is otherwise publicly available, as described in 40 CFR 2.203(b): 

“(b) Method and time of asserting business confidentiality claim. A business which is submitting 

information to EPA may assert a business confidentiality claim covering the information by placing on (or 

attaching to) the information, at the time it is submitted to EPA, a cover sheet, stamped or typed legend, 

or other suitable form of notice complying language such as ‘trade secret,’ ‘proprietary,’ or ‘company 

confidential.’ Allegedly confidential portions of otherwise non-confidential documents should be clearly 

identified by the business, and may be submitted separately to facilitate identification and handling by 

EPA. If the business desires confidential treatment only until a certain date or until the occurrence of a 

certain event, the notice should so state.” 

You may claim as confidential all information included in the response to a question by checking the 

Confidential Business Information (CBI) box next to the question number. Alternatively, all questions 

marked with a CBI check box may be claimed confidential now by checking the box at the end of this 

paragraph. If you do not check this box, any individual response where “CBI” is NOT checked will be 

considered nonconfidential. Note that you may be required to justify any claim of confidentiality at a 

later time. Note also that facility effluent data are not eligible for confidential treatment, pursuant to 

Section 308(b) of the Clean Water Act, and thus will be treated as non-confidential even if the CBI box 

is checked. In addition, information that is publicly-available should not be claimed confidential. Note 

also that information claimed confidential cannot be accessed, verified, or used by the industry at a later 

date to evaluate data and analyses supporting the results of the CBM study. 

 Check Here to Claim All Eligible Data are CBI 

Information covered by a claim of confidentiality will be disclosed by EPA only to the extent of, and by 

means of, the procedures set forth in 40 CFR Part 2, Subpart B. In general, submitted information 

protected by a business confidentiality claim may be disclosed to other employees, officers, or 

authorized representatives of the United States concerned with implementing the Clean Water Act. 

Exemption 4 of the Freedom of Information Act (FOIA) protects from disclosure "trade secrets and 

commercial or financial information obtained from a person and privileged or confidential." See 5 

U.S.C. 552(b)(4). 

Information covered by a claim of confidentiality will be made available to EPA contractors under EPA 

Contract Numbers No. 68-C02-095, EP-C-07-029, and EP-C-05-030 to enable the contractors to 
General Instructions CBM Questionnaire

v

perform the work required by their contracts with EPA. All EPA contracts provide that contractor 

employees use the information only for the purpose of performing the work required by their contracts 

and will not disclose any CBI to anyone other than EPA without prior written approval from each 

affected business or from EPA’s legal office. EPA has approved written procedures for each contractor 

on how they will gather, safeguard, and secure CBI. Any comments you may wish to make on this issue 

must be submitted in writing along with your completed survey. 
Part A. CBM Projects Selected for Questionnaire CBM Questionnaire

A-1

Operator ID: 

PART A. CBM PROJECTS SELECTED FOR QUESTIONNAIRE AND 

CERTIFICATION 

A1-1. Did you respond to EPA’s screener questionnaire on CBM projects? 

 Yes. Continue with Question A1-2. 

 No. Skip to Question A1-3.

A1-2. You have been selected by EPA to respond to questions about projects you identified in EPA’s 

screener survey sent to you on XXX, 2009. EPA has selected the following projects in its 

representative sampling of CBM projects for this survey: 

[This table will be pre-populated based on information collected in the screener questionnaire.] 

Table A-1. Projects Selected for this Questionnaire 

Project Identifier 

Count of Wells Productive in 

2008 (from screener) 

 

For each of the projects listed in Table A-1, EPA requests that you provide identifying information 

on all wells that were actively producing either water or gas in 2008. The number of wells with 

identifying information submitted should match the number of wells listed in Table A-1 (reported in 

your screener survey). Reasons for any discrepancies should be reported in the Comments section in 

Question A1-4. You may use Table A-2 to fill in this information or you can submit your own printout 

or electronic form, whichever is more convenient. Make as many copies of the table as you need, 

ensuring that the relevant project identifier is written on the top right hand corner of the page. 

Please provide the API number for each well in the project unless the well is located in Kansas, 

Virginia, or Indiana. List the API number in Column A of Table A-2 if you choose to use this table. 

Please follow the instructions below for Kansas, Virginia, and Indiana and enter the information into 

Column B of Table A-2 if using this table. 

• Kansas -The well identifying information should be the lease/permit number that is in the form 

of a six-digit number, e.g., 221405. 

• Virginia -The well identifying information should be the permit number that is in the form of a 

2-letter and 4-digit number combination, e.g., BU-0390. 

• Indiana -The well identifying information should be the permit number that is in the form of a 

5-digit number, e.g., 50125. 

If you have projects listed in Table A-1, please skip Question A1-3. Remember to sign the 

Certification Statement on page A-6 after completing the rest of the questionnaire.
Part A. CBM Projects Selected for Questionnaire CBM Questionnaire

A-2

Operator ID: 

Project ID: 

A1-3. According to EPA’s information, you did not receive a screener questionnaire, but most likely you 

operated only one or two CBM projects in 2008. A CBM project comprises a well, group of wells, 

lease, group of leases, or recognized unit for which you operated as an economic unit when making 

production decisions in 2008. If you did not operate any CBM wells in 2008 or if you had another 

concern about whether your organization is the appropriate respondent for this questionnaire, please 

contact the EPA help line for further instructions. Otherwise, EPA requests that you provide 

identifying information on all CBM wells that were actively producing water or gas in 2008, by project. 

EPA recognizes that such groupings can change over time, so define your project(s) in a way that is 

best representative of your production decision grouping in 2008. 

Please provide an identifying name or number for your project in the top right-hand corner of Table 

A-2. Table A-2 must be completed for each CBM project you identify (you will need to copy the table 

if you have more than one project). You will need to use this project identifier in other sections of this 

survey questionnaire. 

Please provide the API number in Column A of Table A-2 for each well in the project unless the well 

is located in Kansas, Virginia, or Indiana. Please follow the instructions below for Kansas, Virginia, 

and Indiana and enter the information into Column B of Table A-2 if using this table. 

• Kansas – The well identifying information should be the lease/permit number that is in the 

form of a six-digit number, e.g., 221405. 

• Virginia – The well identifying information should be the permit number that is in the form of a 

2-letter and 4-digit number combination, e.g., BU-0390. 

• Indiana – The well identifying information should be the permit number that is in the form of a 

5-digit number, e.g., 50125. 

Remember to sign the Certification Statement on page A-6 after completing the rest of the 

questionnaire. 
Part A. CBM Projects Selected for Questionnaire CBM Questionnaire

A-3

Operator ID: 

Table A-2. Well Identifying Information for All Actively Producing Wells for Project ID ______ 

(Submit One Copy for Each Project Listed in Table A-1 or Requested in Question A3-1.) 

Column A 

API Number 

(Excluding Kansas, Virginia, Indiana)

Column B 

Permit Number 

(Kansas, Virginia, Indiana Only) 

 
Part A. CBM Projects Selected for Questionnaire CBM Questionnaire

A-4

Operator ID: 

Copy of 

A1-4. Comments on Part A. Please cross-reference your comments by question number. If you need 

additional space, please photocopy this page before writing on it, and number each copy in the 

space provided. 

Question 

Number Comment 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 
Part A. CBM Projects Selected for Questionnaire CBM Questionnaire

A-5
Part A. CBM Projects Selected for Questionnaire CBM Questionnaire

A-6

Operator ID: 

CERTIFICATION STATEMENT 

I certify under penalty of law that the attached questionnaire was prepared under my direction or 

supervision and that qualified personnel properly gathered and evaluated the information submitted. 

The information submitted is, to the best of my knowledge and belief, accurate and complete. In 

those cases where we did not possess the requested information for questions applicable to our 

operations, we provided best estimates. We have to the best of our ability indicated what we believe 

to be company confidential business information as defined under 40 CFR Part 2, Subpart B. We 

understand that we may be required at a later time to justify our claim in detail with respect to each 

item claimed confidential. I am aware that there are significant penalties for submitting false 

information, including the possibility of fines and imprisonment as explained in Section 308 of the 

Clean Water Act.

 

Signature of Certifying Official Date 

 ( ) 

Printed Name of Certifying Official Telephone Number of Certifying 

Official 

Title of Certifying Official 

Facility Name 

(Continue to Part B, Section 1 of the questionnaire, complete all sections, and return the 

questionnaire along with the signed Certification Statement to the address provided on page iii.)
Part B. Financial and Economic Information 

Section 1: Contact Information CBM Questionnaire 

B-1

Operator ID: 

PART B. FINANCIAL AND ECONOMIC INFORMATION 

SECTION 1: CONTACT INFORMATION 

GENERAL INSTRUCTIONS FOR SECTION 1 

This section of the questionnaire is designed to collect general operator information pertinent to Part 

B, including contact information. 

Indicate information that should be treated as confidential by checking the Confidential Business 

Information (CBI) box next to each question number with responses containing CBI. Any response 

where "CBI" is not checked will be considered non-confidential unless you have previously 

indicated that all eligible information should be considered confidential. Refer to the instructions 

given in the CONFIDENTIAL BUSINESS INFORMATION section on page iv for additional 

information regarding EPA's confidentiality procedures set forth in 40 CFR Part 2, Subpart B. 

B1-1. Provide the name, title, telephone and facsimile numbers, and e-mail address of the primary contact 

at your operation for information supplied in the firm-level financial and economic portions of the 

questionnaire (Part B, Section 2). 

 ( ) 

Primary Contact Name Telephone Number 

 ( ) 

Primary Contact Title Facsimile Number 

 Convenient time to call between: 

Email Address am / pm and 

 am / pm (Eastern 

Time) 

B1-2. Provide the name, title, telephone and facsimile numbers, and e-mail address of the primary contact 

at your operation for information supplied in the project-level economic and financial portions of this 

questionnaire (Part C), if different from the primary contact above. 

 ( ) 

Primary Contact Name Telephone Number 

 ( ) 

Primary Contact Title Facsimile Number 

 Convenient time to call between: 

Email Address am / pm and 

 am / pm (Eastern 

Time) 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 1: Contact Information CBM Questionnaire 

B-2

B1-3. If you know that other facilities in your firm have received this questionnaire and would like to 

reference the firm-level information provided by another respondent, please provide the operator ID 

(shown at the top of each page of the questionnaire) of the respondent who is submitting Part B 

Section 2 for your firm: 
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

B-3

Operator ID: 

SECTION 2: FIRM-LEVEL FINANCIAL QUESTIONS 

Instructions: Section 2 of this survey is focused primarily on collecting firm-level financial 

information at the lowest corporate level for which it is available or can be reasonably estimated. 

This level is considered the “immediate owner/operator.” Most respondents to this detailed 

questionnaire were identified using a screener survey. 

For those who were not asked to respond to a screener survey, the detailed questionnaire has been 

sent to the entity that is listed in state oil and gas commission (or similar agency) databases as the 

operator of one or more CBM wells within the state. Because the survey is focused on the lowest 

corporate level, the appropriate respondent should be the “immediate owner/operator,” who is the 

entity responsible for management and/or day-to-day operation of this project and makes the 

following types of decisions: 

• Whether well(s) should be shut-in, worked over or abandoned. 

• Whether additional or replacement wells should be drilled into a reservoir 

• Whether additional or different production equipment should be installed; and 

• Any other decision factor used by DOE in the General Instructions to Form EIA-23 (see also definition 

of management decisions in the Definitions of Key Terms section at the end of the questionnaire). 

If you are an owner who manages a contract operator to oversee the operation of the project or 

projects, you are still considered the immediate owner/operator for the purposes of this 

questionnaire. EPA is aware that you might need to consult with or send portions of this 

questionnaire to your contract operator for assistance in completing the survey. 

If you have any concerns that your organization is not the appropriate respondent for this survey, 

please contact the EPA help line. As an example, if you have a working interest in one or more CBM 

wells but do not operate or manage the well or wells yourself, nor do you oversee a contract operator 

for this work, you will need to contact the EPA help line. 

EPA would like at least some minimum information on three levels of corporate hierarchy, if 

applicable: immediate owner/operator, owner, and parent or ultimate parent. Some immediate 

owner/operators are independent (not owned by any other firm). Others have owner firms above 

them in the hierarchy. The owner firm, in turn, may be owned directly or through other intermediate 

parents by an ultimate parent, which is the highest level of the corporate hierarchy. In many cases, 

information requested from higher levels of the corporate hierarchy will include only the names of 

key corporate entities. 

Additionally, some immediate owner/operators are owned by more than one owner firm (e.g., joint 

ventures). EPA will be requesting only the corporate names of joint owners; financial information 

will be requested only from the firm created as the joint venture (e.g., a limited liability corporation). 
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

B-4

Operator ID: 

B2-1. Describe the position in the corporate hierarchy of the immediate owner/operator (as defined above). 

If the location to which this questionnaire was mailed is, for example, a field office and not considered 

a separate corporate entity for accounting purposes, you may need to confer with corporate staff to 

complete Part B, Section 2. In this case, check the box that applies to the lowest level in your 

corporate hierarchy where accounting statements (audited or unaudited) are recorded. This may be 

at the division level or at a higher firm level, depending on your circumstances. If you are not sure 

how to answer this question, please contact the EPA help line. 

(Choose only one of the following.) 

 Independent owner/operator. This firm is not owned or affiliated with any other firm. Skip to 

Question B2-4.

 Joint venture. This firm is owned by at least two other firms (not individuals). Continue with 

Question B2-2. 

 Division or profit center. This entity is owned by no more than one owner firm, although the 

owner firm, in turn, might be a subsidiary or a joint venture. Continue with Question B2-2. 

 Subsidiary firm. This firm is owned by no more than one owner firm (portions may 

be publicly held). The owner firm, in turn, might be a subsidiary or a joint venture, 

however. Continue with Question B2-2. 

B2-2. If the immediate owner/operator is, in turn, owned by an owner firm or firms (is not an independent 

owner/operator), what is the corporate name (or names, if a joint venture) of the owner(s)? 

B2-3. What is the name of the ultimate parent company (or companies, if a joint venture) for the immediate 

owner/operator? (If there is only one owner firm above the immediate owner/operator, it should be 

listed in Question B2-2. In this case, please respond “none”.) 

B2-4. In 2008, was your highest level of corporate ownership a small business under the Small Business 

Administration (SBA) definitions? If you responded to this question in EPA’s screener questionnaire, 

the response you provided at that time has been transferred to this questionnaire and you do not 

need to respond further to this question. Otherwise, please refer to page 12 for definitions that may 

assist in answering this question. If you need further assistance beyond that provided in Part D, 

please contact the EPA help line. [NOTE: Question will be prepopulated if they provided a screener 

answer.] 

 Yes 

 No 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

B-5

B2-5. What is the 6-digit NAICS code for the immediate owner/operator? Please refer to page 12 for 

definitions that may assist in answering this question. If you need any further assistance, please 

contact the EPA help line and EPA will help you make this determination. 

 
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

B-6

Operator ID: 

B2-6. Is the immediate owner/operator a contract operator only (owns no working interests in any CBM 

projects)? 

 Yes 

 No 

B2-7. What is the organization type of the immediate owner/operator? 

 C Corporation 

 S Corporation, Limited Liability Corporation, or Limited Liability Partnership 

 Division or Profit Center. Owner firm is a: 

 C Corporation 

 S Corporation, Limited Liability Corporation, or Limited Liability Partnership 

 Other: 

 Other: 

B2-8. Are you required to use the cost-depletion method (unit of production) in computing your depletion 

allowance for tax purposes? (That is, you, your owner firm, or your corporate parent is considered a 

vertically integrated firm under IRS rules.) 

 Yes 

 No 

B2-9. What was the 2008 employment at the immediate owner/operator? Please include any local contract 

labor, but do not allocate overhead employment from higher corporate levels. 

a. Total 2008 employment was 

b. 2008 employment attributable to CBM operations was (estimate if 

necessary). 

B2-10. In 2008, was all produced water from all CBM projects operated by the immediate owner/operator 

injected into a receiving formation in a Class II injection well under the UIC program? 

 Yes. You have completed Section B, Part 2. Continue with Section B, Part 3. 

 No. Continue with Question B2-14. 

Instructions: The following questions should be answered at the lowest level of firm organization at 

which substantial financial decisions are made on CBM operations (e.g., decisions on major capital 

investments or major production decisions for an individual project, such as converting from 

discharge of produced water to subsurface injection, or whether to develop a new or abandon an 

existing CBM project). This may be the operator or the operator’s owner firm, for example, or even 

higher in the corporate hierarchy, such as at a parent firm. Questions B2-11 through B2-14 ask for 

information critical to evaluating CBM project decisions and/or understanding the financial situation 

reflected in the information provided in this section. 

B2-11. Indicate the corporate level at which major investment decisions (such as those discussed above) are 

made: 

 Immediate Owner/Operator 

 Owner Firm(s) 

Other. Name

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

B-7

EPA intends to make assumptions about the method of capital investment analysis and cost of 

capital for projects you operate. You can agree to these assumptions if they seem to reflect your 

operation adequately, or you can provide alternative assumptions if you feel these assumptions are 

not appropriate to your operation. If this decision is made at a higher level and you do not know the 

answers to these questions, you have the option of indicating you do not know. If you leave the 

questions unanswered or you indicate that you do not know, EPA will use the assumptions 

outlined in the questions.
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

B-8

Operator ID: 

B2-12. EPA plans to use a net present value analysis to determine the extent to which costs of various 

produced water alternatives that are analyzed affect the profitability of the project, up to and including 

a finding that it is not economical to install and operate produced water management alternatives (i.e., 

a project with an estimated positive net present value is estimated to have a negative net present 

value if additional costs of produced water management are incurred). (Choose one answer.) 

 Agree or Don’t Know. We understand EPA will use the assumption discussed above. 

 Disagree. We would prefer EPA consider an analysis as described in the comments section 

on page B-45.

B2-13. EPA plans to use the average pre-tax cost of capital as recommended by OMB, which assumes an 

average investment risk. With no inflation considered, this rate is 7 percent. This rate corresponds 

roughly to a 10 percent interest rate, for example, if a 3 percent inflation rate is assumed throughout 

the time frame of the analysis. (Choose one answer). 

 Agree or Don’t Know. We understand EPA will use the assumption discussed above. 

 Disagree. We would prefer EPA to use the following figure to represent our pre-tax cost of 

capital. Provide the nominal rate (i.e., do not subtract an inflation rate from this figure). 

 % 

B2-14. EPA will also investigate the impact of alternative produced water management costs using a hurdle 

rate for future projects (the return required to undertake a project). EPA plans to use a hurdle rate 

(not including inflation) in sensitivity analyses ranging from 12% to 22%. This would be equivalent to a 

hurdle rate that includes a factor for inflation of roughly 15% to 25% (assuming a 3 percent factor). 

 Agree or Don’t Know. We understand EPA will use the assumption discussed above. 

 Disagree. We would prefer EPA to use the following figure (nominal, including inflation) to 

represent our hurdle rate: 

 % 

Instructions: The following questions (B2-15 through B2-25) ask for income statement (through net 

income) and balance sheet information. Information is requested at the lowest level in the 

corporate hierarchy at which such information is kept. 

B2-15. If you qualify as a small business under SBA definitions and answered YES to Question B2-4, you 

have the option of providing just your accounting reports or income tax returns (e.g., Schedule C) for 

the years 2006, 2007, 2008, showing income and balance sheet information. EPA will fill out most of 

the information needed using your accounting reports or returns. 

 Yes. We are a small business and are opting to have EPA prepare the answers to Questions 

B2-16 to B2-22 for us. We are providing an estimate of the percentage of our earnings (net 

revenues minus operating costs minus depreciation) attributable to CBM production in 2006, 

2007, and 2008: 

2006: % 

2007: % 

2008: %. Skip to Question B2-23.

 No. Continue with Question B2-16.

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

B-9

Operator ID: 

B2-16. Instructions: If you are a small business and have opted to have EPA prepare answers to Questions 

B2-16 to B2-22, please skip to Question B2-23. 

EPA understands that audited financial data may not be available at the immediate owner/operator 

level in the corporate hierarchy, but wishes to assess impacts on the most sensitive portion of the 

corporation and encourages good faith estimates or unaudited financial data if this is what is available 

at this level. If you are not comfortable with an estimate, you can opt to answer at a higher level, but 

please answer all income statement questions (Questions B2-16 through B2-19) at the same 

corporate level. You will be able to use either an estimate or “NA” to apply to some line items that 

might not be recorded at a division level, if this is the level at which you are responding. 

Income Statement Information: Questions B2-17 through B2-19 ask for revenues, costs and 

expenses, and earnings, interest, taxes and net income (loss). To the extent possible, provide this 

information at the immediate owner/operator level, whether a profit center or firm. EPA acknowledges 

that some items, such as depreciation, taxes, and interest might be kept only at a higher corporate 

level in some cases, although some or all of these may be routinely estimated for planning purposes. 

In this case, EPA would like these estimates. If you can provide all but depreciation, taxes, and 

interest at the immediate owner/operator level, please do so, using “NA” for depreciation, taxes and 

interest. Otherwise, information at the next higher level (owner firm) is acceptable. Please indicate the 

corporate level at which these income statement data are being provided. 

 Immediate Owner/Operator 

 Owner Firm (from Question B2-2) 

 Other (list corporate name): 

B2-17. What were your organization’s revenues for 2006-2008? Report in nearest thousands of dollars (i.e., 

if net sales were $1,253,779, please report as $1,254,000; zeroes have been provided already). If 

you would like EPA to know that you estimated any line item, you can indicate this by checking ( ) 

the estimate column (Est.). 

Est. Revenues 2006 2007 2008 

a. Net sales and other 

operating revenues (all 

operations, including nonoil and gas related revenues)

 ,

 ,000

 ,

 ,000

 ,

 ,000

b. Revenues attributable to all 

oil and gas operations 

(including CBM) 

 ,

 ,000

 ,

 ,000

 ,

 ,000

c. Revenues attributable to 

CBM operations only 

 ,

 ,000

 ,

 ,000

 ,

 ,000

d. Other income (Specify): ,

 ,000

 ,

 ,000

 ,

 ,000

e. Total revenues 

(a plus d) 

 ,

 ,000

 ,

 ,000

 ,

 ,000

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

B-10

Operator ID: 

B2-18. What were your organization’s operating expenses for 2006-2008? Report in nearest thousands of 

dollars (i.e., if operating costs were $1,253,779, please report as $1,254,000; zeroes have been 

provided already). If depreciation information is not recorded at the corporate level represented in the 

income statement information provided above, or is not usually estimated for your corporate level, 

please insert NA. If depreciation is routinely estimated or you opt to estimate depreciation, please 

provide the information. If you would like EPA to know that you estimated any line item, you can 

indicate this by checking ( ) the estimate column (Est.). 

Est. Costs and Expenses 2006 2007 2008 

a. Operating costs (all 

operations) 

 ,

 ,000

 ,

 ,000

 ,

 ,000

b. Operating costs attributable 

to all oil and gas operations 

(including CBM) 

 ,

 ,000

 ,

 ,000

 ,

 ,000

c. Operating costs attributable 

to CBM operations only 

 ,

 ,000

 ,

 ,000

 ,

 ,000

d. Selling, general, and 

administrative costs 

 ,

 ,000

 ,

 ,000

 ,

 ,000

e. Depreciation, depletion, and 

amortization 

 ,

 ,000

 ,

 ,000

 ,

 ,000

f. Royalty payments ,

 ,000

 ,

 ,000

 ,

 ,000

g. Severance tax payments ,

 ,000

 ,

 ,000

 ,

 ,000

h. Other costs (Specify): ,

 ,000

 ,

 ,000

 ,

 ,000

i. Total costs and expenses 

(a plus d through h) 

 ,

 ,000

 ,

 ,000

 ,

 ,000

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

B-11

B2-19. What were your organization’s earnings and net income for 2006-2008? Report in nearest thousands 

of dollars (i.e., if earnings were $1,253,779, please report as $1,254,000; zeroes have been provided 

already). If tax and/or interest information is not recorded at the corporate level represented in the 

income statement information provided above, or is not usually estimated for your corporate level, 

please insert NA. If these items are routinely estimated or you opt to estimate them, please provide 

the estimates. If you would like EPA to know that you estimated any line item, you can indicate this by 

checking ( ) the estimate column (Est.). 

Est. Earnings and Net Income 2006 2007 2008 

a. Earnings before interest and 

taxes (Question B2-17e 

minus Question B2-18i) 

 ,

 ,000

 ,

 ,000

 ,

 ,000

b. Interest expense ,

 ,000

 ,

 ,000

 ,

 ,000

c. Federal and state income tax ,

 ,000

 ,

 ,000

 ,

 ,000

d. Net income or net loss 

(a minus b minus c) 

 ,

 ,000

 ,

 ,000

 ,

 ,000
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

B-12

Operator ID: 

B2-20. Balance Sheet Questions: Questions B2-21 through B2-23 ask for assets, liabilities and equity 

information, as well as information on payments to principal. EPA acknowledges that balance sheets 

might be kept only at a higher corporate level than the income statement information provided, in 

some cases, although some or all of these may be routinely estimated for planning purposes. In this 

case, EPA would like these estimates. If you can provide estimates at the immediate owner/operator 

level, please do so. If not, information at the next higher level (owner firm) is preferred to information 

at higher levels of the corporation, even if at this level, the information is unaudited. Please indicate 

the level at which these balance sheet and other data are being provided: 

 Immediate Owner/Operator 

 Owner Firm (from Question B2-2) 

Other (list co

B2-21. What were your company’s assets in 2008? Report in nearest thousands of dollars (i.e., if assets 

were $1,253,779, please report as $1,254,000; zeroes have been provided already). If you would like 

EPA to know that you estimated any line item, you can indicate this by checking ( ) the estimate 

column (Est.). 

Est. Assets 2008 

a. Current assets , ,000

b. Property, plant, and equipment (net of depreciation) , ,000

c. Other assets (net of depreciation) , ,000

d. Total assets (sum of a through c) , ,000

B2-22. What were your company’s liabilities and equity in 2008? Report in nearest thousands of dollars (i.e., 

if total liabilities were $1,253,779, please report as $1,254,000; zeroes have been provided already). 

If you would like EPA know that you estimated any line item, you can indicate this by checking ( ) 

the estimate column (Est.). 

Est. Liabilities and Equity 2008 

a. Current liabilities (including accounts payable, accrued 

expenses and taxes, and the current portion of long-term 

debt) 

 , ,000

b. Long-term debt (including bonds, debentures, long-term 

leases, bank debt, and all other noncurrent liabilities such 

as deferred income taxes) 

 , ,000

c. Retained earnings , ,000

d. Other owner equity (not including retained earnings) , ,000

e. Sum of liabilities and owner equity (sum of a, b, c, and d) , ,000

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

B-13

Operator ID: 

B2-23. This question asks for payments to principal over 3 years. Payments to principal are cash outlays 

made to pay back long-term debt, excluding interest payments (similar to a mortgage payment, which 

can also be split between payments to principal and interest). These payments should relate to the 

long-term debts reported in Question B2-22 or those shown in the financial statements submitted in 

response to Question B2-15. Please provide these payments in: 

a. 2006? $ , ,000 This is an estimate: (optional check box) 

b. 2007? $ , ,000 This is an estimate: (optional check box) 

c. 2008? $ , ,000 This is an estimate: (optional check box) 

B2-24. The income statement and balance sheet information reflect a fiscal year starting in (month): 

 

IMPORTANT: If you have provided your financial information in Questions B2-16 through B2-22, 

submission of financial reports is optional and you may skip to Section 3, Part B. Please note that a 

benefit of submitting your financial reports in addition to completing Questions B2-16 through B2-

22 is that submission of these financial reports may reduce the need for EPA to contact you for 

clarifications on your answers to Questions B2-16 through B2-22. If, however, you opted to have 

EPA complete these questions for you as a small business as indicated in Question B2-15, the 

submission of financial reports or tax returns is not optional. 

B2-25. Please provide financial statements. 

Instructions: For those who choose to or must provide such information, please include copies of all 

2006-2008 financial statements that would be needed or were used to compile the answers to 

Questions B2-16 through B2-22 above with your completed questionnaire. These may be accountant 

reports, annual reports, Federal income tax returns (e.g., Schedule C), and/or 10-K reports. Include 

income statements, balance sheets, and associated notes for your organization to the extent 

possible, preferably at the lowest level in the corporation at which information is kept. If you have 

included such financial statements, please check the “attached” box. 

 Attached. 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 3: Project-Level Questions CBM Questionnaire 

B-14

Operator ID: 

SECTION 3: PROJECT-LEVEL QUESTIONS 

Instructions: This section asks for information from the operator of the project or projects identified 

in Part A, where operator is defined as the person responsible for the management and day-to-day 

operation of this project or projects as defined in Section 2 and in the definitions section of this 

questionnaire. If your project numbers have not been prepopulated in the tables that follow, 

please use the project identifiers you assigned the project in Table A-2.

If you own but do not operate the project in question, and you are not able to complete some or all of 

the information, please contact your contract operator to obtain answers to questions for Section 3. 

Alternatively, you may remove Section 2 of the questionnaire and provide the remaining portions of 

the questionnaire to your contract operator. You are responsible for obtaining the questionnaire from 

your contract operator, recompiling the questionnaire, signing the certification pages, and returning 

the entire questionnaire to EPA. 

If your project(s) operates in a reservoir that has been unitized, please include information 

only for that portion of the unit you operate, and provide the unit number or other group 

identifier in Question B3-9.

[Note: Additional copies will be provided if Part A contains more than 3 projects]. 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-15

Table B-1. General Project Information—Projects through Year End 2008 [project identifiers will be pre-popul

Question Project Project P

Project Identifier Information

CBI?

 Yes B3-1. Name or Identifier of Project. Prepopulated Prepopulated Pr

CBI?

 Yes B3-2. Name of Field(s). Indicate “unnamed” if no name has been assigned. 

CBI?

 Yes B3-3. Is this project considered a wildcat project? Yes No Yes No 

CBI?

 Yes B3-4. Does this project commingle CBM with conventional oil and gas or other unconventional 

production (e.g., tight shale)? 

 NOTE: unless otherwise specified, all 

further questions relating to gas production or water production in Part B pertain to total (conventional, other 

unconventional, and CBM) production. 

 Yes. Continue with 

Question B3-5. 

 No. Skip to Question 

B3-9.

 Yes. Continue with 

Question B3-5. 

 No. Skip to Question 

B3-9.

CBI?

 Yes

B3-5. If you commingle CBM with conventional oil 

and gas or other unconventional production, what percentage of the gas and water produced from this project was extracted from coalbeds in 2008 (%) (estimate if necessary)? 

a. Gas % 

b. Water % 

a. Gas %

b. Water %

a. 

b. 

CBI?

 Yes

B3-6. If you commingle CBM with 

conventional/other production, what was the oil production from this project in 2008 (bbls)? 

 bbls bbls 

CBI?

 Yes

B3-7. If you commingle CBM with 

conventional/other production, is the average royalty rate on this oil the same as that for gas? If no, please provide the royalty rate; if not applicable or the rate is the same as that for gas, please insert “NA.” 

% % 

CBI?

 Yes

B3-8. If you commingle CBM with 

conventional/other production, in what year did conventional/other gas and/or oil production begin? 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-16

Question Project Project P

CBI?

 Yes B3-9. Unit Number, or other group identifier (if relevant) Skip to Question B3-11 if not part of 

a formal unit.

CBI?

 Yes B3-10. Indicate the percentage of annual production on the unit in 2008 associated with your portion of 

the unit (%). 

% % 

Numbers of Wells in Project at Year End 2008

CBI?

 Yes B3-11. Total actively producing (water or gas) in 2008. (Note this should match number reported in 

Table A-2.). 

Vertical 

Horizontal 

Vertical 

Horizontal 

VeHo

CBI?

 Yes B3-12. Total approved drilling permits considered applicable to this project in 2008. Vertical Horizontal Vertical Horizontal Ve

Ho

CBI?

 Yes B3-13. Spudded, drilling, or completed (production pending) in 2008. Vertical Horizontal Vertical Horizontal Ve

Ho

CBI?

 Yes B3-14. Inactive (shut in, temporarily abandoned, or other non-productive status, e.g., permanently 

abandoned, during all of 2008). 

Vertical 

Horizontal 

Vertical 

Horizontal 

VeHo

Basic Historic Information

CBI?

 Yes B3-15. Did you initiate development for this project or did you acquire a project that another operator 

developed? If you initiated development, enter the year in which you acquired the first lease. If you acquired all or part of an existing project, enter the year in which you acquired the project. For the purpose of this questionnaire, any projects or portions of projects acquired from another operator after lease acquisition but before development are considered part of the lease acquisition process. However, if you acquired any projects or portions of projects after initiating development of the first lease to create a larger project, complete both the “first lease acquired” and “acquired project” dates. 

First Lease Acquired 

Acquired Project (if you answer here, please skip to Question B3-45). 

First Lease Acquired 

Acquired Project (if you answer here, please skip to Question B3-45). 

FiAcanto 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-17

Question Project Project P

CBI?

 Yes B3-16. Did you answer the “first lease acquired ” question with any answer that was earlier than 

2004 OR did you answer the “project acquired” 

question? 

 Yes. Skip to Question 

B3-45. 

 No. Continue with 

Question B3-17. 

 Yes. Skip to Question 

B3-45.

 No. Continue with 

Question B3-17. 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-18

STOP BEFORE PROCEEDING! 

Please review Part C of this questionnaire before beginning the 

Part B. Part C covers all costs of produced water management agas/water separation. Exclude all of these produced water manain Part B Section 3 of this questionnaire. 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-19

Table B-2 requests additional historic information on your projects. Note that good faith estimates are acceptable

typical values, where information is difficult to quantify. You may note if you have provided an estimate, where the far left shown as “Est.” Instructions: If you indicated this project began prior to 2004, or if you acquired any portion of the project after beyond just lease acquisition), skip to Question B3-45. Otherwise, provide information for Questions B3-17 thr

costs and timing for any project you initiated as of January 2004 or later that you have operated continuou

you did not acquire any portion of the project in any stage of development beyond lease acquisition). Report dollthousands of dollars where indicated (i.e., if lease development costs were $1,253,779, please report as $1,254,00

provided already). Note: if you have less than 100 percent working interest, provide the financial informatio

not just your share. Remember to exclude all produced water management costs covered in Part C from Table B-2. One term that EPA uses in this table is unusual expenditures. There might be two types of unusual expenditures—

(i.e., capitalized) and those that are expensed (i.e., generally considered a part of O&M but the expenditure does and is a relatively large percentage of O&M). For the purposes of this survey, an unusual expenditure is defined 

1) An expenditure that does not occur every year and that is more than 10 percent of O&M (e.g., major storm 

outlay for repairs); or 

2) A capitalized one-time or capital cost not considered a lease acquisition or development cost (e.g. construc

building not directly associated with production) and is not a cost covered in Part C. 

If you are uncertain of which cost category any of your expenditures belong, you can provide the expenditin the comments section, or you can contact the EPA help line.
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-20

Table B-2. Project History 

Question Project Project P

General Questions 

CBI?

 Yes 

 Est.? 

 Yes 

B3-17. Between January 1, 2004 and December 31, 

2008 (2004-2008), did you do any exploratory drilling for CBM in the basin in which this project is located (including for this project, if applicable)? 

 Yes. Continue with 

Question B3-18. 

 No. Skip to Question 

B3-20.

 Yes. Continue with 

Question B3-18. 

 No. Skip to Question 

B3-20.

CBI?

 Yes 

 Est.? 

 Yes

B3-18. In this basin, between 2004 and 2008, what 

was your average exploratory well success rate for CBM (% of exploratory wells that result in a project that produces or is expected to produce commercial gas)? (including for this project, if applicable)? (%) 

 % % 

CBI?

 Yes 

 Est.? 

 Yes

B3-19. Between 2004 and 2008, what was your 

average cost per well to drill exploratory wells in this basin (including for this project, if applicable)? 

$ , ,000 $ , ,000 $ 

Lease Acquisition Costs

CBI?

 Yes 

 Est.? 

 Yes

B3-20. Sum of lease acquisition amounts, 2004-2008. 

Include legal and administrative costs but exclude lump sum payments or cost of amenities provided to surface owners. ($000) 

$ , ,000 $ , ,000 $ 

CBI?

 Yes 

 Est.? 

 Yes

B3-21. Year(s) of lease(s) acquisition (e.g., 2004, 

2005). 

CBI?

 Yes 

 Est.? 

 Yes

B3-22. Total lump sum (2004-2008) payments 

associated with securing the leases other than those to mineral rights owners, such as those to surface owner(s) (all leases). Also include total costs incurred to provide surface owners with amenities in lieu of lump sum payments. Do not include royalties, rents, or other recurring payments. ($000) 

$ , ,000 $ , ,000 $ 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-21

Question Project Project P

Lease Development Costs

CBI?

 Yes 

 Est.? 

 Yes 

B3-23. Total one-time outlays on project development

through December 31, 2007 Include all planning, geological and geophysical costs, and any site development costs not included as drilling costs (see definition of well drilling costs in Appendix D). Exclude all permit costs, drilling costs (as defined in Appendix D), stimulations, recompletions, and any costs for water management systems included in Part C). Note: 2008 data is requested later. ($000). 

$ , ,000 $ , ,000 $ 

CBI?

 Yes 

 Est.? 

 Yes 

B3-24. Total costs of all well drilling through December 

31, 2007 (through tophole equipment, e.g., Christmas tree); see definition of drilling costs in Appendix D ($000). Do not include recompletions. Note: 2008 data is requested later. 

$ , ,000 $ , ,000 $ 

CBI?

 Yes 

 Est.? 

 Yes 

B3-25. Total costs of permit application fees and 

associated costs to prepare permit applications (e.g., one-time costs to perform permit-related studies, etc.) through end of 2007. (Do not include ongoing costs of monitoring, recordkeeping, and reporting or any costs related to produced water management permitting, e.g., NPDES or UIC permits, covered in Part C.) ($000) 

$ , ,000 $ , ,000 $ 

Project Development Schedule

CBI?

 Yes 

 Est.? 

 Yes 

B3-26. Year site preparation work began (e.g., 2004). 

CBI?

 Yes 

 Est.? 

 Yes 

B3-27. Year drilling began. 

CBI?

 Yes 

 Est.? 

 Yes 

B3-28. Year water production began. 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-22

Question Project Project P

CBI?

 Yes 

 Est.? 

 Yes 

B3-29. Year CBM gas production began (do not 

include conventional gas or oil or other unconventional production, if applicable). 

CBI?

 Yes 

 Est.? 

 Yes 

B3-30. Year of peak water production (NA if water 

production has not yet peaked). 

CBI?

 Yes 

 Est.? 

 Yes 

B3-31. Water produced in peak year (bbls) (NA if 

water production has not yet peaked). bbls bbls 

CBI?

 Yes 

 Est.? 

 Yes 

B3-32. Year of peak gas production (CBM and 

conventional oil and gas or other unconventional production, if applicable) (NA if gas production has not yet peaked). 

CBI?

 Yes 

 Est.? 

 Yes 

B3-33. Gas produced in peak year (MMBtu) (CBM and 

conventional/other production, if applicable) (NA if gas production has not yet peaked). 

 MMBtu MMBtu 

Operating and Maintenance Costs of Project

CBI?

 Yes 

 Est.? 

 Yes 

B3-34. In 2004 through 2007, what were your O&M 

costs for this project by year? Include any regularly recurring costs, such as labor and energy costs, lease rental costs, annual payments to surface owners, or recurring costs associated with permits (e.g., monitoring, recordkeeping and reporting or other such payments) that are not related to produced water management. Exclude all costs of produced water management covered in Part C. Also exclude any costs of workovers, stimulations, recompletions, or other activities if these are considered unusual expenditures and reported in Questions B3-35 or B3-44 (see definition of unusual expenditures in the 

instructions to Table B-2 or in the Part D, Definition of Key Terms). If your project was not active in a year shown, please indicate with NA. ($000) 

2004: $ , ,000

2005: $ , ,0002006: $ , ,0002007: $ , ,000

2004: $ , ,000

2005: $ , ,0002006: $ , ,0002007: $ , ,000

20

202020
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-23

Question Project Project P

Other Expenditures Associated with Project

CBI?

 Yes 

 Est.? 

 Yes 

B3-35. What was the total cost of workovers, 

stimulations, and recompletions through year end 2007 ($000)? If not incurred, indicate 0. If any of these activities is considered routine O&M and was included in Question B3-34, indicate NA: 

 Workovers  Stimulations  Recompletions 

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

$ $ $ 

CBI?

 Yes 

 Est.? 

 Yes 

B3-36. Total number of such activities through year 

end 2007. If not incurred indicate 0. If any of these activities is considered routine O&M and was included in Question B3-34, indicate NA: 

 Workovers  Stimulations  Recompletions 

CBI?

 Yes 

 Est.? 

 Yes 

B3-37. Were any one-time outlays on unusual 

expenditures for amortized items incurred as of year end 2007 on this project that were not included in development or drilling costs (Questions B2-23 and B2-24) or in B3-35 as stimulations and recompletions? (See definition of unusual expenditures above in instructions 

to Table B-2.) 

 Yes. Continue with 

Question B3-38. 

 No. Skip to Question 

B3-41.

 Yes. Continue with 

Question B3-38. 

 No. Skip to Question 

B3-41.

CBI?

 Yes 

 Est.? 

 Yes 

B3-38. If you incurred unusual expenditures that were 

amortized, what were they for? If more space is needed, please use the comments page at the end of this section. 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-24

Question Project Project P

CBI?

 Yes 

 Est.? 

 Yes

B3-39. When did these unusual expenditures that 

were amortized occur (Year, e.g., 2004)? If more space is needed, please use the comments page at the end of this section. 

CBI?

 Yes 

 Est.? 

 Yes 

B3-40. What was your one-time total outlay on these 

unusual expenditure amortized items? ($000) If more space is needed, please use the comments page at the end of this section. 

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

$ $ $ 

CBI?

 Yes 

 Est.? 

 Yes

B3-41. Were any other unusual expenditures for O&M 

incurred as of year end 2007 on this project that you excluded in Question B3-34 (O&M costs) but did not include in Question B3-35 (workovers, stimulations, recompletions)? Do not include produced water costs reported in Part C. See definition of unusual expenditures

in instructions to Table B-2. 

 Yes. Continue 

Question B3-42. 

 No. Skip to Question 

B3-45 (Table B-3).

 Yes. Continue 

Question B3-42. 

 No. Skip to Question 

B3-45 (Table B-3).

CBI?

 Yes 

 Est.? 

 Yes

B3-42. If you incurred unusual expenditures for O&M 

costs, what were they for? If more space is needed, please use the comments page at the end of this section. 

CBI?

 Yes 

 Est.? 

 Yes

B3-43. When did these unusual expenditures for O&M 

occur (Year, e.g., 2004)? If more space is needed, please use the comments page at the end of this section. 

CBI?

 Yes 

 Est.? 

 Yes 

B3-44. How much did these unusual expenditures for 

O&M cost? ($000) If more space is needed, please use the comments page at the end of this section. 

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

$ $ $ 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-25

Table B-3 requests information about your project in 2008. Note that good faith estimates, including averageinformation is difficult to quantify are acceptable. Please note if you have provided an estimate, where applicableshown as “Est.” Instructions: Respond to questions for all projects, regardless of when the project began development or when 

Report large dollar amounts in nearest thousands of dollars where indicated (i.e., if fixed operating costs were $1

$1,254,000; zeroes have been provided already). Note: if you have less than 100 percent working interest, pro

information for the entire project, not just your share. Remember to exclude all produced water management costs covered in Part C from Table B-3. One term that EPA uses in this table is unusual expenditures. There might be two types of unusual expenditures—

(i.e., capitalized) and those that are expensed (i.e., generally considered a part of O&M but the expenditure does 

and is a relatively large percentage of O&M). For the purposes of this survey, an unusual expenditure is defined 

1) An expenditure that does not occur every year and that is more than 10 percent of O&M (e.g., major storm 

outlay for repairs); or 

2) A capitalized one-time or capital cost not considered a lease acquisition or development cost (e.g., constru

a building not directly associated with production) and is not a cost covered in Part C. 

If you are uncertain of which cost category any of your expenditures belong, you can provide the expenditin the comments section, or you can contact the EPA help line.
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-26

Table B-3. Current (2008) Operations at Your Projects 

Question Project Project P

General Information 

CBI?

 Yes 

 Est.? 

 Yes 

B3-45. If this is a single lease project, indicate type of 

lease (fee, federal, state, tribal, other) and skip 

to Question B3-47. Otherwise indicate NA and answer B3-46. 

CBI?

 Yes 

 Est.? 

 Yes 

B3-46. If this is a unit or multi-lease project, list the 

number of each type of lease. 

 Fee  Federal  State  Tribal  Other 

 Fee  Federal  State  Tribal  Other 

2008 Drilling Expenditures 

CBI?

 Yes 

 Est.? 

 Yes 

B3-47. What was the total cost of all well drilling in this 

project in 2008 (excluding recompletions)? See definition of drilling cost in Appendix D. ($000) 

$ , ,000 $ , ,000 $ 

CBI?

 Yes 

 Est.? 

 Yes 

B3-48. What was the total number of all wells drilled in 

this project in 2008 (excluding recompletions)? 

2008 Project Development Costs 

CBI?

 Yes 

 Est.? 

 Yes 

B3-49. What was the total outlay on all activities 

related to project development in 2008? Exclude drilling costs, stimulation costs and any produced water management costs that are reported in Part C. Also exclude any lease acquisition costs if included in Table B-2. ($000) 

$ , ,000 $ , ,000 $ 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-27

Question Project Project P

2008 Operating and Maintenance Costs of Project 

CBI?

 Yes 

 Est.? 

 Yes 

B3-50. What were your 2008 total operating and 

maintenance costs of gas production? Include any regularly recurring costs, such as labor and energy costs, lease rental costs, annual payments to surface owners, or recurring costs associated with permits (e.g., monitoring, recordkeeping and reporting or other such payments) that are not related to produced water management. Exclude all costs of produced water management covered in Part C. Also exclude any costs of workovers, stimulations, recompletions, or other activities if these are considered unusual expenditures 

and reported in Questions B3-52 or B3-58 (see definition of unusual expenditures in the 

instructions to Table B-3 or in the Part D, Definition of Key Terms). ($000). 

$ , ,000 $ , ,000 $ 

CBI?

 Yes 

 Est.? 

 Yes 

B3-51. In 2008, please estimate the percentage of 

O&M costs that would have been incurred had the project been temporarily shut in throughout the year. This factor should account for any labor to check on equipment, any annual payments to surface owners, leasehold payments, permit costs not related to produced 

water management or other expenditures that might occur regardless of production. EPA will 

assume this percentage is 5 percent of total 2008 O&M unless you specify otherwise. 

 We estimate %  We accept the 5% 

estimate 

 We estimate % We accept the 5% 

estimate 

Other Expenditures Associated with Project 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-28

Question Project Project P

CBI?

 Yes 

 Est.? 

 Yes 

B3-52. What was the total cost of workovers, 

stimulations, and recompletions in 2008 ($000)? If not incurred, indicate 0. If any of these activities is considered routine O&M and was included in Question B3-50, indicate NA: 

 Workovers  Stimulations  Recompletions 

$ , ,000

$ , ,000$, , ,000

$ , ,000

$ , ,000$, , ,000

$ $ $, 

CBI?

 Yes 

 Est.? 

 Yes 

B3-53. Were any one-time outlays on unusual 

expenditures for amortized items incurred on this project in 2008 that were not included in development or drilling costs (Questions B3-47 or B3-49) or in Question B3-52 under stimulations or recompletions? (See definition of unusual expenditures in instructions to Table B-3.) Exclude any costs for produced water management that are included in Part C. 

 Yes. Continue with 

Question B3-54. 

 No. Skip to Question 

B3-56.

 Yes. Continue with 

Question B3-54. 

 No. Skip to Question 

B3-56.

CBI?

 Yes 

 Est.? 

 Yes 

B3-54. If you incurred unusual expenditures for 

amortized items, what were they for? If more space is needed, please use the comments page at the end of this section. 

CBI?

 Yes 

 Est.? 

 Yes 

B3-55. What was the total one-time outlay on these 

unusual expenditure amortized items? ($000) If 

more space is needed, please use the comments page at the end of this section. 

$ , ,000

$ , ,000$, , ,000

$ , ,000

$ , ,000$, , ,000

$ $ $, 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-29

Question Project Project P

CBI?

 Yes 

 Est.? 

 Yes 

B3-56. Were any other unusual expenditures for O&M 

incurred on this project as of year end 2008 on this project that you excluded in Question B3-50 (O&M costs) but did not include in Question B3-52 (workovers, stimulations, recompletions)? Do not include produced water costs reported in Part C. See definition of unusual expenditures in instructions to Table B-3. 

 Yes. Continue with 

Question B3-57. 

 No. Skip to Question 

B3-59.

 Yes. Continue with 

Question B3-57. 

 No. Skip to Question 

B3-59.

CBI?

 Yes 

 Est.? 

 Yes 

B3-57. If you incurred unusual expenditures for O&M, 

what were they for? If more space is needed, please use the comments page at the end of this section. 

CBI?

 Yes 

 Est.? 

 Yes 

B3-58. How much did these unusual expenditures for 

O&M cost? ($000) If more space is needed, please use the comments page at the end of this section. 

$ , ,000

$ , ,000$, , ,000

$ , ,000

$ , ,000$, , ,000

$ $ $, 

2008 Production, Royalties, and Taxes 

CBI?

 Yes 

 Est.? 

 Yes 

B3-59. What was the total gas production from this 

project in 2008? (MMBtu) MMBtu MMBtu 

CBI?

 Yes 

 Est.? 

 Yes 

B3-60. What was the total gas sold from this project in 

2008? (MMBtu) MMBtu MMBtu 

CBI?

 Yes 

 Est.? 

 Yes 

B3-61. What was the total gas used by this project in 

2008? (MMBtu) MMBtu MMBtu 

CBI?

 Yes 

 Est.? 

 Yes 

B3-62. What was the minimum, average, and 

maximum wellhead price received for sold gas for this project in 2008? ($.$$/MMBtu) 

$ min 

$ average 

$ max 

$ min 

$ average 

$ max 

$ 

$ 

$ 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-30

Question Project Project P

CBI?

 Yes 

 Est.? 

 Yes 

B3-63. What was this project’s total water production 

in 2008? (Provide estimate if this was not measured.) (bbls) 

 bbls bbls 

CBI?

 Yes 

 Est.? 

 Yes 

B3-64. What was your average working interest share 

for this project in 2008? (%) % % 

CBI?

 Yes 

 Est.? 

 Yes 

B3-65. What was the average gas royalty rate for this 

project in 2008 (among all parties over all leases, including surface owner if relevant)? (%) 

 % % 

CBI?

 Yes 

 Est.? 

 Yes 

B3-66. What were the total severance taxes from this 

project in 2008? (% or $000) % 

$ , ,000

 % 

$ , ,000

$ 

CBI?

 Yes 

 Est.? 

 Yes 

B3-67. Were there any other taxes such as ad 

valorem or production shares associated with this project? Provide dollar amount and/or percent and describe: 

 % 

$ , ,000

 % 

$ , ,000

$ 

Reserves Information 

CBI?

 Yes 

 Est.? 

 Yes 

B3-68. Do you report reserves information to SEC or 

to DOE using the EIA Form 23 survey? 

 Yes. Continue with 

Question B3-69. 

 No. Skip to Question 

B3-71.

 Yes. Continue with 

Question B3-69. 

 No. Skip to Question 

B3-71.

CBI?

 Yes 

 Est.? 

 Yes 

B3-69. What is the estimated remaining proved 

reserves associated with this project as of December 31, 2008? (Prorate field estimates to project, where necessary, and specify units used and estimation method.) 

 Specify units (e.g., MMcf):  Estimation Method: 

 SEC Definition of Proved Reserves  Other: 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-31

Question Project Project P

CBI?

 Yes 

 Est.? 

 Yes 

B3-70. What discount rate and wellhead price was 

used for this proved reserve estimate? 

$ 

at % 

$ 

at %

$ 

at 

CBI?

 Yes 

 Est.? 

 Yes 

B3-71. If available, what is the estimated remaining 

technically recoverable reserves (year end 2008)? (Prorate field estimates to project, where necessary, and specify units used, e.g. MMcf.) Indicate NA if you do not compute technically recoverable reserves. 

 Specify units (e.g., MMcf): 

CBI?

 Yes 

 Est.? 

 Yes 

B3-72. If available, what is the projected remaining 

productive life of this project in the technically recoverable reserves estimate? (years) 

 years years 

CBI?

 Yes 

 Est.? 

 Yes 

B3-73. What was the cumulative gas production at 

2008 year end for this project? 

 Specify units (e.g., MMBtu): 

CBI?

 Yes 

 Est.? 

 Yes 

B3-74. What was the cumulative water production at 

2008 year end for this project (estimate if not measured)? 

 Specify units (e.g., thousand bbls): 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions CBM Questionnaire 

B-32

Operator ID: 

Questions for Project 

[One copy will be provided for each project in Part A.]

FUTURE COSTS AND REVENUES 

Instructions: EPA will need to project costs and revenues of this project over the next 10 years. 

EPA acknowledges that projections beyond 5 years are very uncertain and will project information 

beyond the 5 year horizon, unless respondents prefer to provide those estimates themselves. You 

have several options for providing projection information: 

1) Provide your own estimate of costs and revenues at the project over the next 5 years or 

through the end of your planning horizon (at least 3 years, including 2009, 2010, and 2011) in 

Table B-4; 

2) Accept certain assumptions EPA would plan to make in lieu of using your projections; 

3) Provide your 5-year projection in Table B-4 plus an additional 5-year projection beyond the 

fifth year, which you can attach to the questionnaire separately; 

4) Use a combination of any of these. 

For respondents choosing not to do their own projections or choosing only to project certain 

information, EPA will rely on state information on production for the wells in your project to 

determine a production profile, where possible, information provided by other respondents to this 

questionnaire, and/or best professional judgment. For any item you feel that EPA’s assumptions will 

not work for your project, you can fill out those items in the 5-year projection table (or provide a 10-

year projection, if you choose) for any of Questions B3-87 to B3-102 in Table B-4. Please check 

which overall option you have chosen and follow the instructions associated with the options you 

have selected. 

B3-75. Please indicate how you would like to handle projections of project data requested in the remainder of 

this questionnaire. Check any that apply. 

 We request EPA make some or all of these projections based on the information provided 

below in Questions B3-76 through B3-86 for any items for which we have not provided a 

projection for in Table B-4. Instructions: Please complete Questions B3-76 through B3-86 

for this project. You do not have to complete Table B-4, which asks for up to 5 years of yearby-year projections, unless you have opted out of certain assumptions and have chosen to 

provide a projection for one or more line items. 

 We will be skipping Questions B3-76 through B3-86 and will provide year-by-year projection 

data for three to five years in Table B-4. Instructions: Please fill out Table B-4 for as many 

years as you have in your planning horizon. EPA is requesting your best judgment on these 

projections; the Agency is aware that projections are not certain. If the number of years 

requested exceeds your planning horizon, please indicate with NA in any remaining years. 

You may provide projections that include an assumption for inflation but provide that 

assumption in Question B3-102. 

 We have attached additional projections out to 10 years for some or all of the information 

shown in Table B-4 to this questionnaire. If your projections include an assumption for 

inflation, make sure to show that assumption explicitly in your attachments. 

CBI?

 Yes
Part B. Financial and Economic Information 

Section 3: Project-Level Questions CBM Questionnaire 

B-33

Operator ID: 

Instructions: EPA will make projections from 2008 or beyond your planning horizon (as shown in 

your responses to Table B-4) based on your answers to the following questions, your reported 2008 

data, and any information provided in Table B-4. Please provide information to the extent possible 

without considering the effects of inflation. If this is not possible, please note the inflation rate 

inherent in your answers in the Comments Section in Question B3-102. If you have provided some 

projections in Table B-4, EPA will assume further projections based on your answers to the 

following questions and/or either your last year’s reported values in Table B-4 or the patterns seen in 

the projections provided (assuming at least 3 years’ projections have been provided). For any of the 

Questions B3-76 through B3-86 that have not been answered and for which alternative information 

has not been provided in Table B-4 or attached to this questionnaire, EPA will assume you have 

agreed to EPA’s approach. 

For the few projects where conventional oil is also produced, EPA will make the oil production 

projections and price projections, unless you provide oil production curves and/or other information 

with your questionnaire. 

B3-76. Please provide the numbers of wells you plan to drill in this project over the next 5 years by year. If 

any years are beyond your planning horizon, please indicate with “NA.” 

2008 2011 

2009 2012 

2010 

B3-77. In what year do you estimate drilling will be completed for this project, based on your current plans 

(and barring any changes in regulations, changes in your assumptions about future gas prices, etc.) 

 

B3-78. EPA will use estimated costs of drilling based on data collected in this questionnaire of the CBM 

industry, publicly available information, and best engineering judgments as specific to your basin as 

possible to project drilling costs over 10 years. EPA will also assume drilling costs per well will not 

change by more than ordinary inflation (estimated as a function of the recent historic Producer Price 

Index for the oil and gas extraction industry) over the 10-year period (check any that apply): 

 We agree to this approach. 

 We would like EPA to use the following average cost per well for drilling: 

 $ per well ($2008) 

 We would prefer EPA to consider the following factor incremental to inflation to represent 

drilling cost increases greater than inflation over time at our project: 

 $ % per year 

B3-79. At this point in time, using your current assumptions about wellhead prices, how much longer would 

you expect this project to produce economically? 

 We shut in this project in 2008. 

 We shut in this project in 2009 or we plan to shut in this project in 2009. 

 From one to 3 years. 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 3: Project-Level Questions CBM Questionnaire 

B-34

 More than 3 years but less than or equal to 5 years. 

 More than 5 years but less than or equal to 8 years. 

 More than 8 years but less than or equal to 10 years. 

 More than 10 years. 

 Unknown. 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions CBM Questionnaire 

B-35

Operator ID: 

B3-80. EPA will use gas production data found in state reported production data to create gas production 

profiles for this project. Note that EPA has little to no historic gas production information from Indiana 

and Illinois and very dated information from Pennsylvania, so production curves from operators in 

these states would be especially appreciated. If historic gas production data for this project are not 

publicly available, or if your project is too new to provide much information to create a production 

profile, EPA will use information that might be generated by this questionnaire considered likely to be 

most representative of your project, general information on gas production profiles from the state or 

other published sources, and, if necessary, professional judgment or information from other, similar 

basins (if relevant) to create the gas production profile from this project. 

 We agree to this approach. 

 We have attached a gas production curve for this project. 

 We have attached a gas production curve for a typical well in this project. 

 We have projected our gas volumes for this project in Table B-4. 

 Other approach (provide information in comments section). 

B3-81. EPA will use water production data found in state reported production data to create produced water 

production profiles for this project. Note that EPA does not have any well-specific or lease-specific 

produced water production information from state agencies in the following states: Arkansas, Kansas, 

Illinois, Indiana, Ohio, Oklahoma, and West Virginia. Also, if water reporting is voluntary and you do 

not report water to your state agency, EPA will not have this information. Production curves, or any 

other production data, from operators in states where production data might be missing would be 

especially appreciated If historic water production data for this project are not publicly available, or if 

your project is too new to provide much information to create a production profile, EPA will use 

information that might be generated by this questionnaire considered likely to be most representative 

of your project, general information on water production profiles from the state or other published 

sources, and, if necessary, professional judgment or information from other states in the same or 

similar basins (if relevant) to create the water production profile from this project. 

 We agree to this approach. 

 We have attached a water production curve for this project. 

 We have attached a water production curve for a typical well in this project. 

 We have projected our water volumes for this project in Table B-4. 

 Other approach (provide information in comments section) 

B3-82. EPA will use frequency of workovers, stimulations, and recompletions based on data collected in this 

questionnaire of the CBM industry, publicly available information, and best engineering judgments as 

specific to your basin as possible to project such activities in EPA’s 10-year projection: 

 We agree to this approach. 

 We prefer to provide EPA with workover frequencies specific to our project. On average, a 

well in this project is worked over: 

 time(s) per 10-year period (note that fractions are acceptable). 

 We prefer to provide EPA with stimulation frequencies specific to our project. On 

average, a well in this project is stimulated: 

 time(s) per 10-year period (note that fractions are acceptable). 

 We prefer to provide EPA with recompletion frequencies specific to our project. On average, 

a well is recompleted: 

 time(s) per 10-year period (note that fractions are acceptable). 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 3: Project-Level Questions CBM Questionnaire 

B-36
Part B. Financial and Economic Information 

Section 3: Project-Level Questions CBM Questionnaire 

B-37

Operator ID: 

B3-83. EPA will use estimated costs of workovers, stimulations, and recompletions based on data collected 

in this questionnaire of the CBM industry, publicly available information, and best engineering 

judgments as specific to your basin as possible to project costs of such activities in EPA’s 10-year 

projection: 

 We agree to this approach. 

 We prefer to provide EPA with workover costs specific to our project. 

Average workover cost per well ($2008): $ 

 We prefer to provide EPA with stimulation costs specific to our project. 

Average stimulation cost per well ($2008): $ 

 We prefer to provide EPA with recompletion costs specific to our project. 

Average recompletion cost per well ($2008): $ 

B3-84. EPA will use the range and average well head prices reported for your project, along with similar 

information from other projects in the vicinity of your project, DOE projections of wellhead prices from 

the current EIA’s Annual Energy Outlook, historic gas prices at Henry Hub, and other publicly 

available information to project wellhead gas price over the next 10 years at your project. EPA will 

take into account basin-specific infrastructure projections, well drilling projections, and other 

information to identify trends in future basin differentials. Sensitivity analyses will also be run using 

low and high wellhead prices based on DOE’s low and high wellhead price projections. 

 We agree to this approach. 

 We have provided a projection of wellhead price in Table B-4. 

 We have provided additional information in comments that we think should be used in 

computing this project’s projected wellhead price. 

B3-85. Using the percentage provided in Question B3-51 to split 2008 O&M costs (excluding produced water 

management costs) between fixed and variable costs, EPA will assume your existing variable O&M 

costs for this project (estimated on a per MMBtu basis) and your existing fixed costs (estimated on a 

per-year basis) will not vary over the 10-year projection, assuming no inflation. 

 We agree to this approach. 

 We have provided a projection of O&M costs for this project (excluding produced water 

management) in Table B-4. 

 We have provided additional information in comments that we think should be used in 

computing this project’s projected O&M costs for this project. 

B3-86. Please use the space below to add any additional comments you think might be useful to EPA in 

understanding what issues might affect costs in the next few years, particularly changes to state 

regulations that may be pending, competition for drilling rigs, changes in infrastructure availability, 

changes to royalty rates or severance, etc. 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 3: Project-Level Questions CBM Questionnaire 

B-38
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-39

If you will not be continuing with Table B-4, please proceed to Part C of this questionnaire. Note: you do not nee

items in Table B-4 are estimates; EPA will assume all entries are estimates and acknowledges that such estimateReport large dollar amounts in nearest thousands of dollars where indicated (i.e., if additional capital expenditure$1,253,779, please report as $1,254,000; zeroes have been provided already). If you are providing information on 

produces conventional oil, and wish to provide projections of oil production and oil prices, please do so in an atta

comments section in Question B3-103. Remember to exclude all produced water management costs covered in Part C from Table B-3. One term that EPA uses in this table is unusual expenditures. There might be two types of unusual expenditures—

(i.e., capitalized) and those that are expensed (i.e., generally considered a part of O&M but the expenditure does 

and is a relatively large percentage of O&M). For the purposes of this survey, an unusual expenditure is defined 

 1) An expenditure that does not occur every year and that is more than 10 percent of O&M (e.g., maj

large outlay for repairs); or 

 2) A capitalized one-time or capital cost not considered a lease acquisition or development cost (e.g. 

system or a building not directly associated with production) and is not a cost covered in Part C. 

If you are uncertain of which cost category any of your expenditures belong, you can provide the expendit

in the comments section, or you can contact the EPA help line.
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-40

Table B-4. Projections of Costs and Production over 5 Years 

Question 2009 20010 2011 2012 

CBI?

 Yes B3-87. What do you estimate your total operating and 

maintenance costs of gas production will be in 2009-2013? Include any regularly recurring costs, such as labor and energy costs, lease rental costs, annual payments to surface owners, or recurring costs associated with permits (e.g., monitoring, recordkeeping and reporting or other such payments) that are not related to produced water management. Exclude all costs of produced water management covered in Part C. Also exclude any costs of workovers, stimulations, recompletions, or other activities if these are considered unusual expenditures and reported in Questions B3-91 or B3-96 (see definition of unusual expenditures in the instructions to Table B-4 or in the Part D, Definition of Key Terms). ($000).

$ , ,000 $ , ,000 $ , ,000 $ , 

Drilling Expenditure Schedule

CBI?

 Yes

B3-88. Estimated number of wells 

drilled annually (excluding recompletions). 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-41

Question 2009 20010 2011 2012 

CBI?

 Yes B3-89. Estimated total drilling costs incurred, excluding 

recompletions, by year. (See definition of drilling costs in Appendix D.) ($000). 

$ , ,000 $ , ,000 $ , ,000 $ , 

Additional Expenditures

CBI?

 Yes

B3-90. Estimated number of the 

following activities: (if not expected to occur indicate 0. If any of these activities is considered routine O&M and was included in Question B3-87 indicate “NA”): 

 Workovers  Stimulations  Recompletions 

CBI?

 Yes B3-91. Estimated total cost ($000) of the following activities in each 

year (if not expected to occur indicate 0. If any of these activities is considered routine O&M and was included in Question B3-87 indicate “NA”):

 Workovers  Stimulations  Recompletions 

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

$ , 

$ , $ , 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-42

Question 2009 20010 2011 2012 

CBI?

 Yes B3-92. Estimated additional project development expenditures 

incurred (excluding well drilling costs, costs reported in Question B3-91, and produced water gathering and management costs), by year ($000). 

$ , ,000 $ , ,000 $ , ,000 $ , 

CBI?

 Yes B3-93. Estimated new permit or permit renewal costs 

(excluding produced water management related permits, such as NPDES and UIC permits). 

$ , ,000 $ , ,000 $ , ,000 $ , 

CBI?

 Yes B3-94. Total one-time outlays on unusual expenditures for 

amortized items in each year that are not included as development or drilling costs in Questions B3-89 or B3-92 or included as stimulation or recompletion costs in Question B3-91. (See definition of unusual expenditures above in instructions to Table B-4). Exclude those costs that are associated with produced water management as covered in Part C. If more space is 

needed, please use the comments page at the end of this section. 

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

$ , 

$ , $ , 

CBI?

 Yes B3-95. Description of unusual expenditures on amortized 

items included in B3-94 above. If more space is needed, please use the comments page at the end of this section.
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-43

Question 2009 20010 2011 2012 

CBI?

 Yes B3-96. Other unusual expenditures for O&M not included in Question 

B3-87 (O&M costs) or in Question B3-91 (workovers, stimulations, recompletions) (See definition of unusual expenditures above in instructions to Table B-4). Exclude those costs that are associated with produced water management as covered in Part C. If more space is 

needed, please use the comments page at the end of this section. 

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

$ , 

$ , $ , 

CBI?

 Yes B3-97. Description of unusual expenditures included in B3-96 

above. If more space is needed, please use the comments page at the end of this section. 

Production Schedule

CBI?

 Yes B3-98. What is your projection of gas production at this project? 

(MMBtu/yr) 

$ MMBtu $ MMBtu $ MMBtu $ M

CBI?

 Yes B3-99. What is your projection of water production at this 

project? (bbls/yr) 

$ bbls $ bbls $ bbls $ 

CBI?

 Yes B3-100. What wellhead price of gas have you used to project gas 

production? ($.$$/MMBtu) 

$ MMBtu $ MMBtu $ MMBtu $ M

CBI?

 Yes B3-101. What is your projection of severance and other 

production taxes? ($000) 

$ , ,000 $ , ,000 $ , ,000 $ , 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-44

Question 2009 20010 2011 2012 

CBI?

 Yes B3-102. What inflation rate are you using in these projections 

(including expenditure projections)? If using more than one inflator for different cost items, use the comments section to specify (%). 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions CBM Questionnaire 

B-45

Operator ID: 

Copy of 

B3-103. Comments on Part B. Please cross-reference your comments by question number. If you need 

additional space, please photocopy this page before writing on it, and number each copy in the 

space provided. 

Question 

Number Comment 

CBI?

 Yes

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 
Part C. Produced Water Management Information 

Section 1: General Operator Information CBM Questionnaire 

C-1

Operator ID: 

PART C. PRODUCED WATER MANAGEMENT INFORMATION 

INSTRUCTIONS FOR PART C (Technical Portion of Questionnaire)

Read all question-specific instructions and definitions of key terms (Part D). 

Data may be submitted as clearly marked electronic attachments to this questionnaire.

Complete this part of the questionnaire for only the projects listed in Part A. 

You may need to make copies of some PAGES before responding. Some pages in Part C of the 

questionnaire will need to be photocopied before you respond. Indicate how many copies of the 

PAGE you are submitting by completing the entry “Copy ___ of ___” in the top right corner. 

Not all questions will be applicable to every operator. EPA prepared Part C of the questionnaire 

to be applicable to a variety of operators; therefore, not all of the questions will apply to every 

operator. Complete each relevant item in the questionnaire. 

Mark responses for each question. Fill in the appropriate response(s) to each question. Please use 

black ink or type in the spaces provided. Answer the questions in sequence unless you are directed 

to SKIP. Do not leave any entry blank. If the answer is zero, write “0" or “zero”. If a question is not 

applicable to your operations, write “NA.” EPA intends that responses to all questions be based 

upon available data and information. Please provide best estimates when exact data are not available. 

If you provide an estimate, note the methods that were used to make the estimate, along with the 

section and question number that the estimate refers, on the Comments page at the end of Part C. 

You are not required to provide a block flow diagram for each Produced Water Management 

System in Section 2. A narrative description of the Produced Water Management System is 

sufficient. Examples of acceptable block flow diagrams and narrative descriptions are provided in 

Section 2. 

You are not required to perform new or non-routine tests or measurements solely for the 

purpose of responding to this questionnaire. EPA intends that responses to all questions be based 

upon available data and information. In the event that exact data are not available, please provide 

best engineering estimates and note the methods that were used to make the estimates on the 

Comments page located at the end of each section. 

Include any clarifying attachments. If additional attachments are required to clarify a response, 

please place the associated question number and your operator identification number in the top right 

corner of each page of the attachments. The following list contains examples of items that may be 

included as attachments to this questionnaire: 

 – Operations brochure, pamphlet, general description; 

 – Produced water treatment flow diagrams; 

 – Hard copy or electronic water quality data collected from water monitoring locations; 

 – Produced water treatment operation and maintenance logs; and 

 – Pollution prevention or management practices policies or data. 
Part C. Produced Water Management Information 

Section 1: General Operator Information CBM Questionnaire 

C-2

Pay close attention to the measurement units requested (e.g., barrels per day, milligrams per 

liter). Report answers in the units that are specified, unless the question requires you to specify the 

units. 

Indicate information that should be treated as confidential. You may claim as confidential all 

information included in the response to a question by checking the Confidential Business 

Information (CBI) box next to the question number. Note that you may be required to justify any 

claim of confidentiality at a later time. See the CONFIDENTIAL BUSINESS INFORMATION 

section on page iv. 

Questions? If you have any questions regarding the completion of this questionnaire, see the 

QUESTIONNAIRE ASSISTANCE section on page iii. 
Part C. Produced Water Management Information 

Section 1: General Operator Information CBM Questionnaire 

C-3

Operator ID: 

SECTION 1: GENERAL OPERATOR INFORMATION 

GENERAL INSTRUCTIONS FOR SECTION 1 

This section of the questionnaire collects operator and company address and contact information. 

Indicate information that should be treated as confidential by checking the Confidential Business 

Information (CBI) box next to each question number with responses containing CBI. Any response 

where "CBI" is not checked will be considered non-confidential unless you have claimed all CBIeligible data as CBI at the beginning of the questionnaire. Refer to the instructions given in the 

CONFIDENTIAL BUSINESS INFORMATION section on page iv for additional information 

regarding EPA's confidentiality procedures set forth in 40 CFR Part 2, Subpart B. 

C1-1. Provide the name, title, telephone and facsimile numbers, and e-mail address of the primary contact 

at your operation for information supplied in Part C of this questionnaire. 

 ( ) 

Primary Contact Name Telephone Number 

 ( ) 

Primary Contact Title Facsimile Number 

 Convenient time to call between: 

Email Address am / pm and 

 am / pm (Eastern 

Time) 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-4

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

SECTION 2: PRODUCED WATER MANAGEMENT SYSTEM GENERAL QUESTIONS 

GENERAL INSTRUCTIONS FOR PART C SECTION 2 

The following questions request general information on the components and costs of the produced 

water gathering system(s) and the Produced Water Management System(s) used for the project(s) 

listed in Part A. These data will be used to evaluate the costs and benefits of various CBM water 

management arrangements. 

Produced Water Management System (PWMS) - For the purposes of this questionnaire, Produced 

Water Management System is defined as a system that is managed by the operator as a single unit 

for produced water management. Produced water management may include different treatment, 

transfer to disposal locations, and/or reuse practices. The Produced Water Management System may 

treat water from a lease, field, project, or plan of development (POD). Water discharge permits, land 

application permits, and applications for permits to drill (APD) typically use one of these terms to 

define the well grouping. Note that the Produced Water Management System can have multiple 

disposal options but it is managed as a single unit. For example, an operator may use a combination 

of stock tanks, irrigation, and storage ponds on a single Produced Water Management System. Also 

note that the Produced Water Management System may serve the same or different wells from the 

CBM project defined in Part A. Finally, for the purposes of this questionnaire, the PWMS does not 

include the produced water gathering system (e.g., piping or trucking) that is used to transport the 

produced water between the CBM wellhead and a centralized location (e.g., treatment unit, land 

application site). For example, produced water gathering pipes are typically installed underground at 

the same time as the gas gathering pipes. 

The following diagrams are designed to help you determine the Produced Water Management 

Systems that should be addressed in this section of the questionnaire. Please complete a copy of this 

section for each Produced Water Management System used for the projects listed in Part A. Note 

that you are not required to provide a block flow diagram for each Produced Water Management 

System in response to Question C2-1. A narrative description of the Produced Water Management 

System is sufficient. Examples of acceptable block flow diagrams and narrative descriptions are 

provided on pages C-11 and C-12. 

In Example 1, the operator is using the same produced water management system for all wells in the 

CBM project listed in Part A. Therefore, there is a one-to-one match between the CBM economic 

project and Produced Water Management System. The operator should complete one copy of Part C 

Sections 2 and 3 for the Produced Water Management System. 
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-5

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

CBM Economic Project Matches Directly with the 

Produced Water Management System

X X X X X X X X X X

Economic Project

Produced Water Management System

X Well

Sedimentation

Pond

Discharge 

to River

Water Gathering 

System

Example 1. 

In Example 2, the operator is using the two Produced Water Management Systems for the wells 

included in the CBM economic project listed in Part A. The operator should complete two copies of 

Part C Section 2 and Part C Section 3, one for each produced water management scenario used as 

part of this economic project. 

PWMS #1

Settling pond

Land application

PWMS #2

Settling pond

Surface water

CBM Economic Project with 

Two Produced Water Management Systems

X X X X X X X X X X

Economic Project

Produced Water Management System

X Well

Water 

Gathering 

System
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-6

Example 2. 
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-7

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

In Example 3, the operator has two economic projects that share the same produced water 

management system. One of the economic projects, CBM Economic Project 1, was listed in Part A. 

The operator should have completed Part B, Section 3 for Economic Project 1. The operator did not 

need to provide information for Economic Project 2 because it was not listed in Part A. The operator 

should complete one copy of Part C for the combined produced water management system. In 

Example 3, the operator will identify the CBM wells and different produced water volumes managed 

by the PWMS from Project 1 and Project 2. 

Example 3.

For EACH Produced Water Management System you operated in 2008 to manage produced water 

from the wells listed in Part A, complete a copy of the entire Part C Section 2 and Section 3. You 

may need to make multiple copies of these sections. Please enter a Produced Water Management 

System number or name in the upper right-hand corner of this section. The number you choose could 

be one you use internally to refer to the project, but can be just a number such as 1, 2, 3, etc., if you 

use no formal identifier. This information will be used to check that the detailed information 

provided in this section is linked to the correct Produced Water Management System. 

Question C2-1 requests a block flow diagram or narrative description for each Produced Water 

Management System. EPA has provided examples to guide you in completing this question. 

Questions C2-2 through C2-14 request general information on the Produced Water Management 

System such as how the management system was selected and capital and operating costs. 

Questions C3-1 through C3-13 request discharge and treatment information for the Produced Water 

Management System. 
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-8

Question C4-3 requests water quality and whole effluent toxicity data. 

A comment page is included at the end of this section to clarify responses. 

Note that this section was designed to be applicable to a variety of operators. Many of the detailed 

questions are only applicable to discharge of produced water to surface waters, a POTW, or third 

party. Please follow the skip patterns noted throughout the section. 
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-9

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

EPA may contact you for additional detailed cost data for the information you provide in this section 

of the questionnaire. If you are unsure of how to complete any parts of this section, please refer to 

the QUESTIONNAIRE ASSISTANCE information on page iii. 

C2-1. For each Produced Water Management System (PWMS), please provide a block diagram (as in the 

following examples) that shows, or a narrative description that explains, how the produced water was 

managed from the CBM well field to the PWMS in 2008. Refer to this diagram or narrative as you 

answer questions throughout this section. Hand drawings are sufficient for this question. Please 

provide a Produced Water Management System identification number and name for each diagram. 

 Attached a block diagram. 

 Attached a narrative description. 

The following items should be included on your diagram or discussed in your narrative for each 

Produced Water Management System: 

 Name of the CBM Project in Part A that is connected to this PWMS. 

 Identify the water gathering system (e.g., underground pipes, trucking) that moves produced 

water from the CBM wellhead to the PWMS. 

 Name or identification number for this Produced Water Management System. This name or 

number should be noted in the upper right-hand corner of all pages in this section. 

 If more than one PWMS serves this project, number of producing wells (including those 

producing water only) associated with each PWMS. 

 Discharge, disposal, and reuse practices for this Produced Water Management System 

including the final destination of the produced water. 

 Individual treatment units prior to discharge, disposal, or reuse. Please show each individual 

unit on the diagram. For example, if you have two sedimentation ponds, please show each 

one on the diagram. 

 Points of chemical addition, along with the chemical name. 

 Descriptions of any waste streams resulting from CBM produced water treatment (e.g., 

concentrated brine, ion exchange regeneration wastewater, settled solids). 

 Destinations for all produced water. Please remember to include evaporation or infiltration. 

 The locations where routine water quality data are collected (you will be asked to provide 

some of this data in Part C Section 4). 

 Please note whether any produced water from conventional oil and gas extraction is 

commingled with produced water from this CBM project. Please indicate on the diagram or in 

your narrative description, the volumes or flow rates of the conventional oil and gas extraction 

produced water as well as the point at which these waters are commingled. 

 Please note whether any produced water from another CBM project (either yours or another 

operator’s) is commingled with produced water from this CBM project. If produced water from 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-10

another project operated by your company enters this management system, provide the 

name of the project as provided in your screener survey. Please indicate on the diagram or in 

your narrative description, the volumes or flow rates of the CBM produced waters that are not 

from this CBM project as well as the point at which these waters are commingled. 
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-11

Operator ID: 9999

Project ID from Part A: PRB1

Operator’s Name or ID for this Produced Water Management System: POD1

Example 4 illustrates a Produced Water Management System with only one management practice. In 

this example, you would complete one copy of this section for this Produced Water Management 

System. 

One Produced Water Management System for the CBM Project 

(Treatment and Discharge)

Concentrated Brine –

Contract Hauled

Outfall 001 

Discharge to River

Sedimentation/

Equalization Pond

8 Wells

2

Routine Sampling Point 1

Routine Sampling Point 2

6 Media Filters

2 RO Units

Blend Tank

1 Backwash

Economic Project: PRB 1

PWMS Name: POD1

Water Gathering System

Example 4. 

Example 5 is an example of a narrative description for a CBM project with only one PWMS. In this 

example, you would complete one copy of this section for this Produced Water Management 

System. 

Produced water from the eight CBM wells in the San Juan POD is piped 

underground to six storage tanks. Only water from the eight wells enters the 

storage tanks. The water is trucked from the storage tanks to one of two 

injection wells. The water is filtered and a biocide is added prior to reinjection. A sample of the water is tested prior to re-injection. 

Example 5. 
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-12

Operator ID: 9900

Project ID from Part A: Black Warrior 1

Operator’s Name or ID for this Produced Water Management System: Treatment System 1

Example 6 illustrates a Produced Water Management System with multiple produced water 

management practices that vary throughout the year. The dates during which each water 

management practice is in use are shown above that branch of the flow diagram. You should 

complete two copies of Part C Sections 2 and 3 for this scenario, one for the west side and one for 

the east side. 

50 Wells

(West side of CBM Project)

Storage Tanks

Land Application

280 bpd

280 bpd

35 Wells (April-September)

(East side of CBM Project)

85 Wells (October-May)

Sedimentation 

Pond 1

200 bpd

Sludgecontract 

hauled

14 bpd Evaporation 2 bpd

Note: October-May flow in italics

Economic Project: Black Warrior 1

PWMS Name: Treatment System

Temporal Changes in Produced Water Collection and Management Practices

Discharge to River

1

2

May-October Only

480 bpd

4 bpd 20 bpd

Sedimentation 

Pond 2

Sludgecontract 

hauled

13 bpd 1 bpd Evaporation 5 bpd 1 bpd

Alum, Antimicrobial

3 170 bpd

450 bpd Routine Sampling Points

50 Wells

(West side of CBM Project)

Storage Tanks

Land Application

280 bpd

280 bpd

35 Wells (April-September)

(East side of CBM Project)

85 Wells (October-May)

Sedimentation 

Pond 1

200 bpd

Sludgecontract 

hauled

14 bpd Evaporation 2 bpd

Note: October-May flow in italics

Economic Project: Black Warrior 1

PWMS Name: Treatment System

Temporal Changes in Produced Water Collection and Management Practices

Discharge to River

1

2

May-October Only

480 bpd

4 bpd 20 bpd

Sedimentation 

Pond 2

Sludgecontract 

hauled

13 bpd 1 bpd Evaporation 5 bpd 1 bpd

Alum, Antimicrobial

3 170 bpd

450 bpd Routine Sampling Points

Water Gathering System

Example 6. 
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-13

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

C2-2. In what year did this Produced Water Management System (PWMS) begin operating? 

Number of days in operation in 2008: 

 365 days; or 

 days 

C2-3. What was the average daily flowrate or total volume of water treated by this Produced Water 

Management System in 2008? Please check whether you are providing average daily flowrate or 

total volume and provide the flowrate or volume and units. 

d. Generated by the wells identified in Part A in 2008 

 Average Daily Flowrate 

 Total Volume 

 

Please specify the flowrate or volume units: 

e. Managed by this PWMS in 2008 

 Average Daily Flowrate 

 Total Volume 

 

Please specify the flowrate or volume units: 

C2-4. Please relate the water produced and gas production from the wells related to this Produced Water 

Management System with the wells from the project from Part A listed at the top of the page: 

f. What percentage of water treated by this Produced Water Management System is from the 

project from Part A listed at the top of the page: 

% 

g. What percentage of 2008 gas production from the project listed at the top of this page is 

associated with the wells served by this Produced Water Management System (estimate is 

acceptable).” 

% 

C2-5. Selection of Management Option

h. How was the Produced Water Management System designed? (Check all that apply.) 

 Input from the surface owner during development of the surface use plan 

 Work with outside contractor 

 Other: Please describe 

i. Who manages the day-to-day operations for the produced water management? 

 Operator (Skip to Question C2-6) 

 Landowner (Skip to Question C2-6) 

 Contractor/third party; please provide company name 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-14

j. Cost of hiring the contractor/third party for produced water management in 2008. Exclude the 

costs associated with the water gathering system from the CBM wells to the PWMS. 

2008 annual 

operating and maintenance cost $ 

Min

imum quantity of CBM produced water required for contract: bbl 

Skip to Question C2-8, unless you have costs in addition to contractor/third party 

management. 
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-15

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

C2-6. Produced Water Management System Capital Costs – Please provide the following capital cost 

information for this Produced Water Management System (e.g., treatment system, land application 

site). Exclude any costs associated with excavating surface impoundments if the impoundment was 

converted from other uses, such as drill pits, but do include the costs of conversion. Also exclude the 

costs associated with installing the water gathering system from the CBM wells to the PWMS. For 

example, you should exclude the costs of any trucking or installation of any pumps or pipes used to 

transport produced water from the CBM wells to the PWMS. 

k. Capital cost in dollars: $ 

 Check this box if your company purchased this PWMS from another 

company and you do not have this capital cost information. Skip to Question C2-6.

l. Year cost incurred: 

C2-7. Produced Water Management System Operating and Maintenance Costs – Please provide the 

costs for this Produced Water Management System (e.g., treatment system, land application site) for 

2008. Exclude the costs associated with maintaining the water gathering system from the CBM wells 

to the PWMS. For example, you should exclude the costs of any trucking or pump or pipe 

maintenance used for the transport of produced water from the CBM wells to the PWMS. You should 

include non-produced water transportation costs associated with the PWMS (e.g., contract hauling 

residuals from the PWMS, permit compliance monitoring). 

m. 2008 operating and maintenance cost in dollars: $ 

n. Please provide any annual revenue received from operating this Produced Water 

Management System (e.g., payments from water recipients, payment for treating produced 

water from another operator) $ 

C2-8. Produced Water Gathering and Transportation Questions. Please provide cost and design 

information for transporting the produced water from the CBM wells identified in Part A to this PWMS. 

The produced water gathering system (e.g., piping or trucking) is used to transport the produced 

water between the CBM wellhead and a centralized location (e.g., treatment unit, land application 

site). 

o. What is the total 2008 volume of water generated from the CBM wells identified in Part A that 

is piped to this PWMS? 

 

Please specify the volume units: 

NOTE: You should skip to Question C2-8.d if all of the produced water generated from the CBM 

wells identified in Part A is stored at the CBM wells and subsequently trucked off-site for final 

disposition (e.g., underground injection, treatment and disposal, land application). 

p. What is the capital cost in dollars of the piped water gathering system between the CBM 

wells identified in Part A and this PWMS? 

 $ Year cost incurred: 

 Check this box if your company purchased this piped produced water 

gathering system from another company and you do not have this capital cost 

information. Skip to Question C2-8.d.

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-16

q. What is the 2008 operating and maintenance cost in dollars of the piped water gathering 

system between the CBM wells identified in Part A and this PWMS? 

 $ 
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-17

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

r. Please answer the following questions if you truck produced water from the wells identified in 

Part A to this PWMS. Otherwise, skip to Question C2-9.

i. Total volume of produced water trucked to this PWMS in 2008: 

ii. Total vehicle miles traveled for the truck transport of 

produced water to this PWMS in 2008: 

iii. Total number of days used to truck produced water to this PWMS in 2008: 

iv. Average volume capacity of the tanker truck used in 

2008 (e.g., 2,000 gal./truck): 

v. Total 2008 costs incurred to truck produced water to this PWMS: $ 

C2-9. Please indicate the land area occupied by your operations. 

Location Area Units 

a. Total Project Area (Part A 

Project) 

 

b. Total PWMS Area 

c. Total Undeveloped Area 

d. Is the undeveloped area suitable for construction of new or additional wastewater treatment 

systems? 

 Yes 

 No: Provide explanation: 

C2-10. Have you ever operated or considered operating a produced water management system other than 

what is described in this section for the project? 

 Yes 

 No (Skip to Question C2-12) 

C2-11. What type of management system did you consider? 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-18
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-19

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

C2-12. What were the reasons for not implementing or for stopping the operation of the management 

system? 

C2-13. Have any monitoring or other studies been conducted to assess the potential impacts of produced 

water for this Produced Water Management System, such as impacts related to irrigation, 

impoundment, or surface water discharges? Produced water related impacts may include but are not 

limited to: changes in soil characteristics, changes in stream flows, changes in aquatic toxicity, and 

changes in aquatic and riparian species composition. 

 Yes 

 No (Skip to Part C Section 3) 

C2-14. Indicate the following information about the studies, if known. If there are additional studies, please 

provide the information in the Comments Section (Question C4-3). 

Title: 

Date: / / 

Title: 

Date: / / 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-20

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

SECTION 3: DETAILED PRODUCED WATER MANAGEMENT AND TREATMENT QUESTIONS 

GENERAL INSTRUCTIONS FOR SECTION 3 

Questions C3-1 through C3-13 request detailed information for the Produced Water Management 

System. Please see the following tables to identify the questions you should complete. 

C3-1. Produced Water Destination - This table provides information on the final destination of the 

produced water for this Produced Water Management System. Note that EPA will request information 

on any treatment technologies used prior to discharge in later questions. Check ( ) all that apply. 

Table C-1. Final Destination of CBM Produced Water 

Check ( ) 

All that 

Apply Destination 

Discharge to Surface Water, POTWs, and Third Parties

a. Discharge to surface water (requiring NPDES permit) 

b. Discharge to POTW or third party (e.g., discharge to another operator’s 

treatment system) 

Zero Discharge

c. Land Application (no crop production) 

d. Land Application (for crop production) 

e. Underground Injection 

f. Evaporation or infiltration pond (with no intended discharge to surface 

water) 

g. Livestock or Wildlife Watering 

h. Hauled off site 

i. Other (Specify):

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-21

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Copy of 

C3-2. Cost Information for Each Destination – Complete a copy of the following table for each produced 

water destination selected in Question C3-1. You should have one copy of this table for each box 

checked in Table C-1. 

Destination Option Selected in 

Question C3-1 

(Use this row to indicate which 

destination you are providing 

information on. You will make 

multiple copies of this table if 

you checked more than one 

destination in Question C3-1.)

 Discharge to Surface Water 

 Discharge to POTW or 

Third Party 

 Land Application (no crop 

production) 

 Land Application (for crop 

production) 

 Underground Injection 

 Evaporation or infiltration 

pond 

 Livestock or wildlife 

watering 

 Hauled off site 

 Other: 

2008 Volume of Produced 

Water From this PWMS to 

this Destination

Unit: 

Maximum Daily Capacity of 

Produced Water from this 

PWMS Capable of Going to 

this Destination: Unit: 

Capital Costs 

% of Total Capital Cost 

Provided in Response to 

Question C2-6 for this 

destination: 

 % 

(If only one box is checked in 

Table C-1 then enter 100% 

above.) 

Check ( ) the Components Below that are Included in the 

Capital Costs: 

 Tanks 

 Pumps 

 Piping/hoses 

 Outfall structure 

 Injection well 

 Pond 

 Treatment unit 

 Liner 

 Land acquisition 

 Monitoring equipment 

 Aeration equipment 

 Land application equipment

 Other: 

 Other: 

Operation and Maintenance 

Costs 

% of Total Operation and 

Maintenance Cost provided in 

Response to Question C2-7: 

 % 

Check ( )the Components Below that are Included in the 

Operation and Maintenance Costs: 

 Chemicals 

 Energy: electric 

 Energy: gas 

 Energy: oil 

 Materials 

 Labor 

 Other: 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-22

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Copy of 

C3-3. Residuals Management Information – Complete a copy of the following table for each type of 

residual generated by this PWMS. Make sure you indicate in your narrative description or block 

diagram (see Question C2-1) each type of residual waste generated by this PWMS and the ultimate 

disposal of the residual. 

Residuals Management and 

Costs 

List Type(s) of Residuals 

Generated (e.g., brine waste 

from ion exchange unit): 

(Note: If more than one 

residual is generated by this 

PWMS, please make one copy 

of this question for each type of 

residual generated.)

Description of Residual Generated and its Source (e.g., brine 

waste from ion exchange treatment system): 

Volume (and units) of Residual Generated in 2008: 

Frequency of Residuals Removal from this PWMS in 2008 (e.g., 

brine waste tank emptied once per week). 

Name of Final Destination for this Residual (e.g., ABC 

Underground Injection Well, Permit No. XYZ): 

Distance from this PWMS to the Final Destination for this 

Residual: 

 miles 

Annual 2008 Cost of Disposal for this Residual: 

$ 

Components of Residual Disposal Cost: 

 Transportation: Piped 

 Transportation: Trucked 

 Disposal Fees 

 Other (Specify): 
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-23

If you check “Discharge to Surface Water” in Table C-1, please also complete Question C3-4 and 

then skip to Question C3-7. 

If you check “Discharge to a POTW or Third Party” in Table C-1, please also complete Question 

C3-5 and then skip to Question C3-7. 

If you check “Land Application (No Crop Production)” or “Land Application (For Crop 

Production)” in Table C-1, please also complete Question C3-6 and then skip to Question C3-7. 

For all other destinations selected in Table C-1, skip to Question C3-7. 
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-24

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Surface Water Discharge Question Copy of 

C3-4. Surface Water Discharge. Complete Question C3-4 if you checked that this Produced Water 

Management System discharges to surface water in Table C-1. If this Produced Water Management 

System does not discharge to surface water, skip to Question C3-5. Complete one copy of this 

question for each surface water discharge permit used in this Produced Water Management System. 

s. General Information on Surface Water Discharge Permit – Please complete the following 

table of general information about the surface water discharge permit. 

NPDES Permit Number 

Permit Type General 

 Individual 

Expiration Date (MM-DD-YYYY) 

Stream Monitoring Required? Yes (Specify frequency: )

 No 

Effluent Monitoring Required? Yes (Specify frequency: )

 No 

Permit currently being reviewed or modified? Yes 

 No 

t. General Information on Outfalls Included in Permit – Please complete the following table 

of general information about the outfalls included in the permit listed in part (a) of this 

question. Make multiple copies if the permit covers more than three outfalls. 

i. Outfall Number – List each outfall included in the NPDES permit. 

ii. Aeration Equipment– Check ( ) any aeration equipment or other treatment 

equipment used at the outfall. 

iii. Flowrate or Volume Discharged Through Outfall – Please provide the total volume 

discharged through each outfall in 2008. 

iv. Frequency of Discharge – Indicate the frequency of discharge including number of 

days discharged in 2008. 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-25

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Surface Water Discharge Question Copy of 

Outfall Number Treatment at Outfall(s)

Flowrate or Volume 

Discharged Through 

Outfall (Specify units) Frequency of discharge 

 None 

 Rip Rap 

 Atomizer 

 Sprinkler head 

 Diffuser 

 Other 

Specify: 

 

Units: 

 Continuous 

 Intermittent 

Number of days of 

intermittent discharge in 

2008 

 Emergency discharge 

only 

Number of days of 

emergency discharge in 

2008 

 None 

 Rip Rap 

 Atomizer 

 Sprinkler head 

 Diffuser 

 Other 

Specify: 

 

Units: 

 Continuous 

 Intermittent 

Number of days of 

intermittent discharge in 

2008 

 Emergency discharge 

only 

Number of days of 

emergency discharge in 

2008 

 None 

 Rip Rap 

 Atomizer 

 Sprinkler head 

 Diffuser 

 Other 

Specify: 

 

Units: 

 Continuous 

 Intermittent 

Number of days of 

intermittent discharge in 

2008 

 Emergency discharge 

only 

Number of days of 

emergency discharge in 

2008 

u. Discharge Permit and Discharge Monitoring Reports. Please attach a copy of the current 

surface water discharge NPDES permit. If available, EPA prefers the NPDES permit be 

submitted in an electronic format (e.g., PDF format). Please report any discharge monitoring 
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-26

report (DMR) data for 2006 through 2008 in Part C Section 4. If available, EPA prefers this 

DMR data be submitted in an electronic format (e.g., PDF format). 

 Permit Attached. 
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-27

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

POTW/Third Party Discharge Question Copy of 

C3-5. Discharge to POTW or third party. Complete Question C3-5 if you checked that this Produced 

Water Management System discharges to a POTW or third party in Question C3-1. If this Produced 

Water Management System does not discharge to a POTW or third party, skip to Question C3-7. 

Complete one copy of this question for each POTW or third party used in this Produced Water 

Management System. 

 POTW. 

 PrOTW. 

 Other facility. 

v. Provide the POTW, PrOTW, or other facility name, address, primary contact, and phone 

number (if applicable). 

POTW/PrOTW/Other Facility Name 

Address 

 

City State Zip Code 

 ( ) 

Primary Contact Name Telephone Number 

b. Please attach a copy of the current permit or discharge agreement. Please report any 

monitoring data in Part C Section 4. If available, EPA prefers data be submitted in an 

electronic format. 

 Permit/Discharge Agreement Attached 

Continue to Question C3-7. 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-28

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Discharge to Land Application (with or without crop production) Question Copy of 

C3-6. Discharge to Land Application (with or without crop production) – Complete Question C3-6 if 

you checked that this Produced Water Management System discharges to land application in 

Question C3-1. If this Produced Water Management System does not discharge to a land application 

system, skip to Question C3-7. Complete one copy of this question for each land application system 

used at this Produced Water Management System. 

Land Application (Complete for Irrigation and Non-Irrigation Land Application) 

a. Area of Land Used for Land Application 

(acres) 

b. Describe any criteria on the Produced 

Water for this Land Application 

c. Type of Land Application/Irrigation Above-ground irrigation (e.g., center-pivot) 

 Sub-surface drip irrigation (SDI) 

 Other (Specify): 

d. Frequency of Application Continuous 

 Intermittent: 

 Number of days applied in 2008 

 Months that the land application occurred in 

2008 (e.g., February, March, May) 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-29

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Produced Water Treatment 

C3-7. Do you treat produced water to remove pollutants prior to discharge to surface water or POTW/third 

party? 

 Yes 

 No (Skip to Part C Section 4) 

C3-8. This table provides direction on how to provide information on the treatment of the produced water for 

this Produced Water Management System. Check ( ) all that apply. EPA will request more detailed 

information about treatment of the produced water in later questions. 

Table C-2. Treatment of CBM Produced Water 

Chec

k (:) All th

at

Apply 

Type of Treatment Unit 

Do you have water quality 

data for the produced 

water entering and/or 

leaving this treatment 

unit? If so, please provide 

in Section 4 (water quality 

section). 

Additional 

Information 

a. Sedimentation Pond (for 

equalization or suspended solids 

removal) 

 Yes 

 No 

Complete Question C3-9

for each pond. 

b. Ion exchange Yes 

 No 

Complete Question C3-

10 for each ion 

exchange unit. 

c. Low-Pressure Filtration (e.g., 

Hydro-cyclone, Multi-media 

filtration) 

 Yes 

 No 

Complete Question C3-

11 for each low-pressure 

filtration unit. 

d. High-Pressure Filtration (e.g., 

Reverse Osmosis, 

Nanofiltration) 

 Yes 

 No 

Complete Question C3-

12 for each highpressure filtration unit. 

e. Other (Specify): Yes 

 No 

Complete Question C3-

13 for any additional 

treatment units not listed 

elsewhere. 

Copy pages as needed to include information on all treatment units checked ( ) in the table above. 

Please be sure to enter the Produced Water Management System identification number or name so 

that EPA can link the information in this section to the correct Produced Water Management System. 

CBI?

 Yes

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-30

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Sedimentation Ponds Question Copy of 

C3-9. Sedimentation Ponds – Complete Question C3-9 if you checked that this Produced Water 

Management System uses sedimentation ponds in Table C-2. Also, please indicate the water quality 

parameters that are removed by this treatment unit and the estimated removal efficiency. If this 

Produced Water Management System does not use sedimentation ponds, skip to Question C3-10. 

Design Capacity (acre-feet) acre-feet 

Volume of Produced Water into 

Sedimentation Pond in 2008 bbl 

Surface Area acres 

Type of Liner and Thickness (if applicable) Yes – Liner used 

 Specify type and thickness: 

 No liner 

Chemicals Added (e.g., coagulants, biocides) 

Capital Cost of Sedimentation Pond and Year 

of Cost 

$ 

Year: 

Initial Bonding Costs and Year of Costs $ 

Year: 

2008 Operating and Maintenance Cost of 

Sedimentation Pond $ 

Targeted Water Quality Parameter 

Parameter Name 

Estimated Removal 

Efficiency Basis/Comments 

 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-31

 
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-32

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Ion Exchange Question Copy of 

C3-10. Ion Exchange - Complete Question C3-10 if you checked that this Produced Water Management 

System uses ion exchange in Table C-2. Also, please indicate the water quality parameters that are 

removed by this treatment unit and the estimated removal efficiency. If this Produced Water 

Management System does not use ion exchange, skip to Question C3-11. Remember to complete 

one copy of this question for each ion exchange unit used in this Produced Water Management 

System. Also make sure to complete Question C3-3 for any brine waste generated. 

Design Capacity of Ion Exchange System 

(bbl/d) bbl/d 

Volume of produced water into Ion Exchange 

in 2008 (bbl) bbl 

Vendor/Unit Name 

Resin Name/Type 

Average Regeneration Frequency (specify 

frequency; e.g., once/hour, once/4 hours, 

once/day) 

Average Resin Life (yrs) years 

Chemicals Added (e.g., regenerates, 

biocides) 

Capital Cost of Ion Exchange Unit and Year 

of Cost 

$ 

Year:

2008 Operating and Maintenance Cost of Ion 

Exchange Unit $ 

Pilot Project Yes 

 No 

Targeted Water Quality Parameter 

Parameter Name 

Estimated Removal 

Efficiency Basis/Comments 

 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-33

 

 
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-34

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Low-Pressure Filtration Question Copy of 

C3-11. Low-Pressure Filtration – Complete Question C3-11 if you checked that this Produced Water 

Management System uses low-pressure filtration in Table C-2. Also, please indicate the water quality 

parameters that are removed by this treatment unit and the estimated removal efficiency. If this 

Produced Water Management System does not use low-pressure filtration, skip to Question C3-12. 

Remember to complete one copy of this question for each low-pressure filtration unit used in this 

Produced Water Management System. Also make sure to complete Question C3-3 for any residuals 

generated. 

Design Capacity of Filtration System (bbl/d) bbl/d 

Volume of Produced Water Entering LowPressure Filtration Unit in 2008 (bbl) bbl 

Type Multimedia 

 Sand 

 Ultrafiltration 

 Other: 

Vendor/Unit Name 

Average Cleaning Frequency (specify 

frequency; e.g., once/hour, once/4 hours, 

once/day) 

Chemicals Added (e.g., coagulants, biocides) 

Capital Cost of Filtration System and Year of 

Cost 

$ 

Year:

2008 Operating and Maintenance Cost of 

Filtration System $ 

Pilot Project Yes 

 No 

Targeted Water Quality Parameter 

Parameter Name 

Estimated Removal 

Efficiency Basis/Comments 

 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-35

 

 
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-36

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

High-Pressure Filtration Question Copy of 

C3-12. High-Pressure Filtration – Complete Question C3-12 if you checked that this Produced Water 

Management System uses high-pressure filtration in Table C-2. Also, please indicate the water 

quality parameters that are removed by this treatment unit and the estimated removal efficiency. If 

this Produced Water Management System does not use high-pressure filtration, skip to Question 

C3-13. Remember to complete one copy of this question for each high-pressure filtration unit used in 

this Produced Water Management System. Also make sure to complete Question C3-3 for any 

residuals generated. 

Design Capacity of Filtration System (bbl/d) bbl/d 

Volume of Produced Water Entering HighPressure Filtration Unit in 2008 (bbl) bbl 

Type Reverse Osmosis 

 Nanofiltration 

 Other (Specify type): 

Vendor/Unit Name 

Average Cleaning Frequency (specify 

frequency; e.g., once/hour, once/4 hours, 

once/day) 

Membrane Life (years) years 

Chemicals Added (e.g., coagulants, biocides) 

Capital Cost of Filtration System and Year of 

Cost 

$ 

Year:

2008 Operating and Maintenance Cost of 

Filtration System $ 

Pilot Project Yes 

 No 

Targeted Water Quality Parameter 

Parameter Name 

Estimated Removal 

Efficiency Basis/Comments 

 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-37

 

 
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-38

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Treatment Not Specified Elsewhere Question Copy of 

C3-13. Treatment Not Specified Elsewhere – Complete Question C3-13 if you checked that this Produced 

Water Management System uses land application or treatment not specified elsewhere in Table C-2. 

Remember to complete one copy of this question for any additional treatment units used at this 

Produced Water Management System. Also make sure to complete Question C3-3 for any residuals 

generated. 

a. General Information – Please complete the following table of general information. Also, 

please indicate the water quality parameters that are removed by any treatment unit and the 

estimate removal efficiency. 

Design Capacity of This Treatment System 

(bbl/d) bbl/d 

Volume of Produce Water Entering 

Treatment Unit in 2008 (bbl) bbl 

Description of Treatment System 

Vendor/Unit Name 

Type and Amounts of Chemicals Used With 

This System in 2008 (e.g., coagulants, 

biocides, soil amendments) 

Average Regeneration/Cleaning Frequency 

Specify units (e.g., once/hour, once/4 hours, 

once/day): 

Capital Cost of System and Year of Cost $ 

Year:

2008 Operating and Maintenance Cost of 

System $ 

Pilot Project Yes 

 No 

Targeted Water Quality Parameter (Complete for Treatment Technology Not Specified 

Elsewhere) 

Name 

Estimated Removal 

Efficiency Basis/Comments 

 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

C-39

 

 
Part C. Produced Water Management Information 

Section 4: Produced Water Quality Data CBM Questionnaire 

C-40

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

SECTION 4: PRODUCED WATER QUALITY DATA 

To enable EPA to evaluate the ability of produced water management systems to remove potential 

pollutants of concern, water quality data is required. EPA will evaluate the performance of produced 

water management systems via analysis of effluent data, and as available, analysis of data that 

represents the influent to the produced water management system. EPA also requests information 

related to the measured values (e.g., analytical method information) to allow for examination of the 

quality of data provided. This section requests this water quality data for each Produced Water 

Management System. 

C4-1. Complete Table C-3 for locations related to treatment unit processes for which you have water quality 

data. All information collected will aid EPA in determining CBM produced water characteristics by 

basin; identifying pollutants; calculating baseline loadings; and estimating the effectiveness of 

treatment technologies. Note that if you already have water quality data in electronic or 

hardcopy format, you may submit these data using your own reporting method. If you need 

more space, make a copy of Table C-3. Locations may include: wellhead, influent to treatment; 

effluent from treatment; and discharge outfalls. Please include all paired influent and effluent data for 

any treatment units operated by your site. Provide all relevant data for 2008. If 2008 data is 

unavailable, please provide the most recent data. 

• The pollutant analyzed; 

• The measured value including units (if not detected, list the detection limit value preceded by 

a less than (<) symbol); 

• The analytical method used; 

• The date samples were collected; 

• Where the samples were collected (this should be a number from a label on your block flow 

diagram); 

• Whether the samples were collected as grabs or as composites; and 

• Provide flow rate only if flow rate data were recorded at the sampling point during the 

sampling period. 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 4: Produced Water Quality Data CBM Questionnaire 

C-41

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

C4-2. Whole Effluent Toxicity Information 

c. Have you performed any whole effluent toxicity (WET) testing for this Produced Water 

Management System? 

 Yes 

 No (Skip to Question C4-3) 

d. Please provide the information on the WET testing conducted, including the including the test 

organism, test type (e.g., acute or chronic), and the results. 

e. Has toxicity ever exceeded permit limits? 

 Yes 

 No (Skip to Question C4-3) 

f. Was a toxicity identification evaluation (TIE), toxicity reduction evaluation (TRE), or other 

study performed to determine the cause, treatability, or effective management of toxicity? 

 Yes 

 2008 Annual Costs ($) for TIE and TRE: ____________ 

 No (Skip to Question C4-3) 

g. Please describe the cause of the toxicity and the final resolution of the toxicity issue. 

 

 Attached 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 4: Produced Water Quality Data CBM Questionnaire 

C-42

Operator ID: 

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Analytical Data Question Copy of 

Table C-3. Analytical Data 

Note: If you already have water quality data in electronic or hardcopy format, you may submit 

these data using your own reporting method. EPA prefers water quality data be submitted in 

an electronic format (e.g., Microsoft© Access, Microsoft© Excel, non-scanned PDF). 

 Submitted own data as attachment to this questionnaire.

Pollutant 

Measure

d Value 

(mg/L) 

Analytic

al 

Method 

Permit 

Limit 

(mg/L)

Samplin

g Date Location

Sample 

Type 

(grab/ 

composite

) 

Flow 

Rate 

(gpm) 

Total 

Dissolved 

Solids 

1124 

EPA 

Method 

160.1 

 7/1/06 SP-1 Grab 130 

 
Part C. Produced Water Management Information 

Section 4: Produced Water Quality Data CBM Questionnaire 

C-43
Part C. Produced Water Management Information 

Section 4: Produced Water Quality Data CBM Questionnaire 

C-44

Operator ID: 

Copy of 

C4-3. Comments on Part C. Please cross-reference your comments by question number. If you need 

additional space, please photocopy this page before writing on it, and number each copy in the 

space provided. Please use this table to comment on any information you would like to share with 

EPA on how you manage CBM produced water. 

Question 

Number Comment 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 
Part D. Supporting Information 

Section 1: List of Acronyms and Abbreviations CBM Questionnaire 

D-1

PART D. SUPPORTING INFORMATION 

SECTION 1: LIST OF ACRONYMS AND ABBREVIATIONS

% Percent 

bbl Barrel (42 gallons) 

bbl/d Barrels per day 

bcf Billion cubic feet 

BPJ Best Professional Judgment 

BTU British thermal unit 

CBM Coal bed methane 

CFR Code of Federal Regulations 

CFS Cubic feet per second 

Cl- Chloride 

CWA Clean Water Act 

dpy Days per year 

EA Environmental Assessment 

EC Electrical Conductivity 

EDR Electrodialysis Reversal 

ELG Effluent limitations guideline 

EPA U.S. Environmental Protection Agency 

ft Foot 

ft2 Square foot 

ft3 Cubic foot 

gal Gallon 

gpd Gallons per day 

gpm Gallons per minute 

hrs/day Hours per day 

in Inch 

kWh Kilowatt-hour 

lb Pound 

lb/hr Pounds per hour 

mcf Thousand cubic feet 

MCL Maximum contaminant level 

mg/L Milligrams per liter 

MGD Million gallons per day 

MMBTU/hr Million BTUs per hour 

mmcf Million cubic feet 

MW Megawatt 

NA Not applicable 

POTW Publicly Owned Treatment Works 

ppm Parts per million 

PrOTW Privately Owned Treatment Works 

psi pounds per square inch 

RO Reverse osmosis 

s Second 

SAR Sodium Adsorption Ratio 

SIC Standard Industrial Classification 

tcf Trillion cubic feet 
Part D. Supporting Information 

Section 1: List of Acronyms and Abbreviations CBM Questionnaire 

D-2

TDS Total dissolved solids 

ton English ton, wet weight 

TMDL Total maximum daily load 

tpy Ton per year 

TSS Total suspended solids 

yr Year 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-3

SECTION 2: DEFINITION OF KEY TERMS 

Ad Valorem Taxes—A type of property taxes, usually levied as a percentage of production or value 

of production by local authorities, such as a county, a school district, city, or township. 

Aeration—Process that mixes air and water, normally by injecting air into water, spraying water 

into the air, or allowing water to pass over an irregular surface, to release compounds from the water 

through oxidation, precipitation, or evaporation. 

Arroyo—An intermittently dry creek. 

Balance Sheet—A quantitative summary of a company's financial condition at a specific point in 

time, including assets, liabilities and net worth. The first part of a balance sheet shows all the 

productive assets a company owns, and the second part shows all the financing methods (such as 

liabilities and shareholders' equity); also called statement of condition. 

Batch (Intermittent) Discharge or Application—A discreet volume or mass of liquid or solid that 

is collected and discharged periodically. 

Beneficial Use—The produced water is of good enough quality to be used for wildlife propagation 

or livestock watering or other agricultural uses and the produced water is actually put to such use 

during periods of discharge. 

Best Management Practices (BMP)—Methods that have been determined to be the most effective, 

practical means of preventing or reducing pollution from non-point sources. Activities, maintenance 

procedures, and other management practices to prevent or reduce the pollution. BMPs may include 

treatment requirements, operating procedures, and practices to control plant site runoff, spillage or 

leaks, sludge or waste disposal, or drainage from raw material storage. 

C Corporation—A business that is a completely separate entity from its owners, unlike a 

partnership. 

Capital Cost—The costs associated with the purchase, development or construction of fixed assets 

such as land, stations, buildings, and water treatment equipment. 

Capital Cost of Project Development—As defined for Question B3-13. this includes all capital and 

one-time costs of project development beyond the immediate tophole equipment (e.g., Christmas 

tree), including any exploratory costs, planning costs, geological and geophysical costs, site 

development costs, such as pads and roads or other land preparation activities, production pumps, 

gas/water separation equipment, other onsite gas gathering or treatment equipment, and gas pipelines 

to offsite location and/or point of sale. It does not include any capital costs of water management 

(see definition). 

Clarification—Separation and concentration of solids from liquid/solid mixtures that are mostly 

liquid. 

Clean Water Act—Federal legislation enacted by Congress to “restore and maintain the chemical, 

physical, and biological integrity of the Nation’s waters” (Federal Water Pollution Control Act of 

1972, as amended, 33 U.S.C. 1251 et seq.). 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-4

Coalbed Methane (CBM)—Natural gas found in coal seam reservoirs. 

Coalbed Methane (CBM) Project— A CBM project comprises a well, group of wells, lease, group 

of leases, or recognized unit which you operate as an economic unit when making production 

decisions. The well or wells may be associated with one or more water management practices (that 

is, the project should be defined on the basis of gas production economics, not necessarily on the 

basis of a water management system). If a project operates as a unit in which you are not the sole 

operator, please include information only for that portion of a unit for which you actively operate. 

EPA understands that the concept of a project is variable over time, so the well or wells included as a 

part of a project should be those that best defined the project as it existed in 2008. 

Coalbed Methane (CBM) Unit—A unit is a group of leases that are managed together with the 

intention of maximizing production (and/or minimizing costs), where operating these leases 

independently might result in more wells drilled, less production realized, or both. Units can be 

formal, legal entities that are written into lease agreements, pooling agreements, and/or state permits; 

or informal, particularly where minerals rights on several leases are owned by the same entity. 

Continuous Flow—A flow regime characterized by persistent flow, as opposed to intermittent flow 

or batch processes. 

Contract Haul—The removal of any waste stream (including produced water) from a facility by a 

company authorized to transport and dispose of the waste, excluding discharges to sewers or surface 

waters. 

Cost-Depletion Method—Recovery of the tax basis in a mineral deposit by deducting it 

proportionately over the productive life of the deposit. This is in contrast to the percentage depletion 

method, which permits a taxpayer with an economic interest in a mineral deposit to deduct a 

specified percentage of the gross income from the deposit instead of using the cost depletion method. 

Percentage depletion is generally restricted to independent producers, royalty owners, and some 

other narrow categories of oil and gas owners. 

Cost of Capital—The opportunity cost of an investment; that is, the rate of return that a company

would otherwise be able to earn at the same risk level as the investment that has been selected. For 

example, when an investor purchases stock in a company, he/she expects to see a return on that 

investment. Since the individual expects to get back more than his/her initial investment, the cost of 

capital is equal to this return that the investor receives, or the money that the company misses out on 

by selling its stock. 

Creek—A small, natural stream that is often a shallow or intermittent tributary to a river. 

Cumulative Depreciation—The total charges against the fixed assets of a company for wear and 

tear, obsolescence, or the depletion of a natural resource—oil in the ground, for instance—as it is 

used up. 

Current Assets—Any asset that can reasonably be expected to be used up or converted to cash or 

sold within a year or less, e.g., cash, accounts receivable, prepaid expenses. 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-5

Current Liabilities—Debts that are payable within 1 year, including accounts payable, notes 

payable within one year, accrued expenses and taxes, and the portion of long-term debt that are paid 

this year. 

Depreciation, Depletion, and Amortization—The allocation of the cost of an asset over a period of 

time for accounting and tax purposes. Depletion, which reflects the declining value of a natural 

resource asset as it is produced, may be calculated either using the cost-depletion or percentage 

depletion method, depending on type of firm (see cost-depletion method). 

Design Capacity Flow Rate—Maximum flow rate a treatment unit is designed to handle. 

Direct Discharge—The discernible, confined, and discrete conveyance of pollutants to United 

States surface waters such as rivers, lakes, and oceans. See 40 CFR 122.2. 

Discharge—The discernible, confined, and discrete conveyance of pollutants to: (1) United States 

surface waters such as rivers, lakes, and oceans (“direct discharge”), or (2) a publicly owned, 

privately owned, federally owned, combined, or other treatment works (“indirect discharge”). See 40 

CFR 122.2. 

Disposal—Intentional placement of waste (including produced water) into or on any land where the 

material will remain after closure. Waste placed into water is defined as discharge, not disposal. 

Division—A business unit of a firm, often treated as a profit center (see profit center). 

Drilling Cost—Includes tangible and intangible costs of drilling and completing a well (if 

completed), as defined in API’s Joint Association Survey of Drilling Costs, which includes 

“expenditures for drilling dry holes and productive wells and equipping new productive wells 

through the Christmas tree” installation...these cost elements are the costs of labor, materials, 

supplies, water, fuels, power, and direct overhead (i.e., field, district, and regional), for such 

operations as site preparation, road building, erecting and dismantling derricks and drilling rigs, 

drilling hole, running and cementing casing, hauling materials, etc. Include the total cost of water, if 

purchased, or cost of water well, if drilled and chargeable to oil or gas well drilling operations. Well 

costs also include machinery and tool charges and rentals, and depreciation charges, where 

appropriate, for rigs and other equipment and facilities which will be used in drilling more than one 

well. Deduct the condition value of materials salvaged after use where appropriate. Do not report the 

cost of lease equipment such as artificial lift equipment and downhole lift equipment, flow lines, 

flow tans, separators, etc. that are required for production. Do not reduce the costs by test well, 

bottom hole, or dry hole contributions. 

Earnings Before Interest and Taxes (EBIT)—A measure of a company’s earning power from 

ongoing operations, equal to earnings before deduction of interest payments and income taxes; also 

called operating profit or operating income. 

Emergency Discharge—A volume or mass of liquid or solid residuals are discharged only during 

extenuating circumstances (i.e., a treatment process malfunction). 

Equalization—The process of storing produced water for later treatment or discharge. This process 

can also provide some removal of some suspended solids. 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-6

Evaporation—The process by which water or other liquid becomes a gas. Water from land areas, 

bodies of water, and all other moist surfaces is absorbed into the atmosphere as a vapor. 

Filtration—This treatment technology relies on the difference in size between the pore and the 

particle to be removed. Low-Pressure Filtration typical involves using can include direct media 

filtration using one or more layers of granular media such as sand and/or anthracite with coagulation. 

High-Pressure Filtration typically uses a driving force to transport wastewater through a membrane, 

which separates the wastewater into two flows: permeate and retentate (e.g., microfiltration, 

ultrafiltration, and reverse osmosis). 

Fiscal Year—A 12-month period over which a company budgets its spending. A fiscal year does not 

always begin in January and end in December; it may run over any period of 12 months. 

Groundwater—Water in a saturated zone or stratum beneath the surface of land or water. 

Hurdle Rate—The required rate of return in a discounted cash flow analysis, above which an 

investment makes sense and below which it does not. Often, this is based on the firm's cost of capital 

or weighted average cost of capital, plus or minus a risk premium to reflect the project's specific risk 

characteristics; also called required rate of return. 

Income Statement—An accounting report showing various categories of revenues, expenses, 

interest payments, taxes, and net income. 

Indirect Discharge—The discernible, confined, and discrete conveyance of pollutants to a publicly 

owned, privately owned, federally owned, combined, or other treatment works. 

Infiltration—The process by which water penetrates into soil from the ground surface

Injection Well (Deep or Shallow Well Injection) —Any bored, drilled, or driven shaft or a dug 

hole, improved sinkhole, or a subsurface fluid distribution system where the depth is greater than the 

largest surface dimension that is used to dispose of fluids underground. See underground injection. 

Interest Expense—An expense for interest on a loan. 

Intermittent Flow—A flow regime characterized by flows that occur sporadically, seasonally, or 

for only a portion of time during normal operations. 

Ion Exchange (IX) —Treatment process using a resin formulated to adsorb cationic or anionic 

species to remove pollutants from an influent stream. 

Lake—A body of freshwater or saltwater surrounded by land. 

Landfill—A natural or man-made formation in the earth into which solid waste, sludges, or other 

process residuals are placed for permanent disposal. 

Lease Bid—Amount (generally a lump sum at time of lease acquisition) paid to the mineral rights 

owner to hold the property for a period of time, whether or not the lease is developed. This does not 

include rental payments, which may be charged over time, nor does it include royalties, which are 

paid only once production begins. 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-7

Limited Liability Corporation or Company—A type of company, authorized only in certain 

states, whose owners and managers receive the limited liability and (usually) tax benefits of an S 

Corporation without having to conform to the S corporation restrictions. 

Limited Liability Partnership—See limited liability corporation. 

Long-term Debt—Liabilities that are paid off over periods greater than 1 year, including mortgages, 

notes, bonds, debentures, long-term leases, bank debt, and deferred income taxes. 

Maximum Daily Flow—The maximum flow in a 24-hour period. 

Membrane Filtration—Separation processes that use a membrane as the filter mechanism. 

Mineral Rights Owner—Party owning the rights to minerals beneath land that has been or will be 

used for the purposes of producing minerals or hydrocarbons. Party may or may not own the rights 

to the land surface. See surface owner. 

NAICS—NAICS is an economic classification system. Economic units that use like processes to 

produce goods or services are grouped together. These units are assigned a code for identification 

purposes. US Census Bureau (http://www.census.gov/epcd/www/naics.html). Common 6-digit 

NAICS in the CBM extraction industry include 211111, Crude Petroleum & Natural Gas Extraction; 

213111, Drilling Oil and Gas Wells; 213112, Support Activities for Oil and Gas; 212111, 

Bituminous Coal & Lignite Surface Mining; 212112, Bituminous Coal Underground Mining; 

221210, Natural Gas Distribution; 221112, Fossil Fuel Electric Power Generation; and 324110 

Petroleum Refineries. 

Nanofiltration—A method of water treatment that utilizes membranes to remove hardness, bacteria, 

viruses, and organic-related color. 

Net Income—Gross sales minus taxes, interest, depreciation, and other expenses. 

Net Sales—Gross sales minus returns, discounts, and allowances (investorwords.com). 

NPDES Permit Program—The National Pollutant Discharge Elimination System (NPDES) 

program authorized by Sections 307, 318, 402, and 405 of the Clean Water Act that applies to 

facilities that discharge wastewater directly to United States surface waters. For the CBM industry, 

operators are required to obtain NPDES permits for their direct discharges to surface waters. 

Operating and Maintenance Cost—The ongoing, repetitive costs of operating a water system; for 

example, employee wages and costs for treatment chemicals and periodic equipment maintenance. 

Operating Costs (income statement)—These are the recurring expenses which are related to the 

operation of a business. 

Operator—The person responsible for the management and day-to-day operation of one or more 

CBM wells. The operator is generally a working interest owner or a company under contract to the 

working interest owner(s). 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-8

Other Assets (net of depreciation)—Any non-current assets (assets that cannot be easily converted 

to cash) other than property, plant and equipment. 

Owner Firm—The next level up in the corporate hierarchy from the owner/operator. This firm 

owns the owner/operator firm or division, regardless of whether the owner/operator is a contract 

operator or a working interest operator. 

Owner/Operator—The entity (firm or division, if a profit center) responsible for the management 

and day-to-day operation of a well. The owner/operator is generally a working interest owner or a 

company under contract to the working interest owner(s). Management decisions might include 

whether well(s) should be shut-in, worked over or abandoned, whether additional or replacement 

wells should be drilled, whether additional or different production equipment should be installed, 

and any other decision factor used by DOE in the General Instructions to Form EIA-23. 

Payback Period—The amount of time taken to break even on an investment. Since this method 

ignores the time value of money and cash flows after the payback period, it can provide only a 

partial picture of whether the investment is worthwhile. 

Payments to Principal—Payments made on the principal portion of a loan or other borrowing 

mechanism classified as long-term debt (excludes the interest payments on these loans). 

Pollutant—Under the Clean Water Act, a dredged spoil, solid waste, incinerator residue, filter 

backwash, sewage sludge, munitions, chemical waste, biological material, certain radioactive 

material, heat, wrecked or discarded equipment, rock sand, cellar dirt, and industrial, municipal, and 

agricultural waste (40 CFR 122.2). 

Pollution Prevention—The use of materials, processes, or practices that reduce or eliminate the 

creation of pollutants or wastes. It includes practices that reduce the use of hazardous and nonhazardous materials, energy, water, or other resources, as well as those practices that protect natural 

resources through conservation or more efficient use. Pollution prevention includes but is not limited 

to source reduction, in-process recycle and reuse, and water conservation practices. 

Primary Collection Point—The first point in the Produced Water Management System where 

produced water from all wells flowing to one final destination are combined. In example 4, the 

sedimentation/equalization pond would be the primary collection point. 

Privately Owned or Held—A company whose shares are not traded on the open market. 

Privately Owned Treatment Works (PrOTW)—Any device or system owned and operated by a 

private entity and used for storage, treatment, recycling, or reclamation of liquid industrial wastes. 

Produced Water—Water drawn from any hydrologic unit for the purpose of producing 

hydrocarbons. 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-9

Produced Water Management System— For the purposes of this questionnaire, Produced Water 

Management System is defined as a system that is managed by the operator as a single unit for 

produced water management. Produced water management may include different treatment, transfer 

to disposal locations, and/or reuse practices. The Produced Water Management System may treat 

water from a lease, field, project, or plan of development (POD). Water discharge permits, land 

application permits, and applications for permits to drill (APD) typically use one of these terms to 

define the well grouping. Note that the Produced Water Management System can have multiple 

disposal options but it is managed as a single unit. For example, an operator may use a combination 

of stock tanks, irrigation, and storage ponds on a single Produced Water Management System. Also 

note that the Produced Water Management System may serve the same or different wells from the 

CBM project defined in Part A. Finally, for the purposes of this questionnaire, the PWMS does not 

include the produced water gathering system (e.g., piping or trucking) that is used to transport the 

produced water between the CBM wellhead and a centralized location (e.g., treatment unit, land 

application site). For example, produced water gathering pipes are typically installed underground at 

the same time as the gas gathering pipes. 

Produced Water Treatment or Treatment—The treatment of water with physical, chemical, 

biological, or other processes to remove specific pollutants from the water stream or to alter the 

physical or chemical state of specific pollutants in the water stream. Produced water treatment is 

performed to allow for discharge, disposal or beneficial use of the water. 

Profit Center—A business unit or department which is treated as a distinct entity enabling revenues

and expenses to be determined so that profitability can be measured. For the purposes of this 

questionnaire a profit center is defined as an entity that tracks finances at least through earnings 

before interest and taxes. 

Property, Plant and Equipment—A type of asset a company owns that is vital to business 

operations but cannot be easily liquidated. The value of property, plant and equipment is typically 

depreciated over the estimated life of the assets, because even the longest-term assets become 

obsolete or useless after a period of time. 

Publicly Owned or Held—A company which has issued securities through an offering, and which 

are now traded on the open market. 

Publicly Owned Treatment Works (POTW)—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. 

Receiving Waters—A stream, river, or other surface water body to which wastewater or other 

pollutants are discharged. 

Retained Earnings—Earnings not paid out as dividends but instead reinvested in the core business 

or used to pay off debt; also called earned surplus or accumulated earnings or unappropriated profit. 

Reverse Osmosis (RO)—A method of water treatment that involves the application of pressure to a 

concentrated solution which causes the passage of a liquid from the concentrated solution to a 

weaker solution across a semi-permeable membrane. The membrane allows the passage of the 

solvent (water) but not the dissolved solids (solutes). This water treatment method is typically used 

for desalinization and the removal of ions, radionuclides, bacteria, and viruses. 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-10

River—Water which flows in a channel from high ground to low ground and ultimately to a lake or 

sea. 

Royalty Payments—Payments made to the mineral rights owner. These payments may be based on 

a percentage of the gas produced or as a percentage of the revenues received. A royalty is not a 

working interest share (see working interest). 

S Corporation—A form of corporation, allowed by the IRS for most companies with 75 or fewer 

shareholders, which enables the company to enjoy the benefits of incorporation but be taxed as if it 

were a partnership. Also called Subchapter S Corporation. 

SEC Proved Reserves—Proved oil and gas reserves are the estimated quantities of crude oil, 

natural gas, and natural gas liquids which geological and engineering data demonstrate with 

reasonable certainty to be recoverable in future years from known reservoirs under existing 

economic and operating conditions, i.e., prices and costs as of the date the estimate is made. Prices 

include consideration of changes in existing prices provided only by contractual arrangements, but 

not on escalations based upon future conditions. See SEC SX Reg. 210.4-10 (November 18, 1981). 

Sedimentation Pond—An impoundment constructed at the produced water treatment site to remove 

suspended solids from the produced water. These impoundments can also provide equalization of the 

produced water prior to treatment or discharge. 

Selling, General and Administrative Costs—Income statement item which combines salaries, 

commissions, and travel expenses for executives and salespeople, advertising costs, and payroll

expenses. 

Severance Tax Payments—Payments made to a state for the right to remove a natural resource, 

usually applied to gas for use in another state. 

Sludge—The accumulated solids and solid residues separated from liquids by settling or treatment. 

Storage Pond—An impound for liquid wastes. 

Sum of Liabilities and Owner Equity—Current Liabilities + Long-Term Debt + Retained Earnings 

+ Other Owner Equity. 

Surface Owner—Party owning land that has been or will be used for the purposes of producing 

minerals or hydrocarbons. Party may or may not own mineral rights beneath that land. 

Surface Use Plan—Agreement between a landowner and a coalbed methane producer describing 

the conditions of land use for coalbed methane production including existing and proposed facilities 

(e.g. wells, roads, pipelines, and treatment systems), compensation for property damages, and 

considerations for land reclamation.

Surface Waters—Waters of the United States including, but not limited to, oceans and all interstate 

and intrastate lakes, rivers, streams, creeks, arroyos, mudflats, sand flats, wetlands, sloughs, wet 

meadows, playa lakes, and natural ponds (40 CFR 122.2). 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-11

Technically Recoverable Reserves—Reserves recoverable given current technologies and 

industry practices and assuming no limitations on production due to market conditions. 

Total Assets—Total Current Assets + Total Non-current Assets (including Property, Plant, and 

Equipment and Other Assets Net of Depreciation). 

Treatment Unit—A unit operation used to remove pollutants from produced water. Treatment units 

include, but are not limited to sedimentation ponds, ion exchange systems, and filters. 

Ultimate Parent—The firm at the highest level of the corporate hierarchy. If the owner firm is not 

owned by another firm, the owner firm is the ultimate parent. If the owner/operator is not owned by 

any other firm, there is no ultimate parent. 

Ultrafiltration (UF) —A method of water treatment that utilizes membranes in a pressure-driven 

process for concentrating solutions containing colloids and higher molecular weight materials. This 

water treatment method typically removes viruses, colloids, clays, bacteria, humic acids, and fulvic 

acids, but not ions or radionuclides. 

Underground Injection—The technology of placing fluids underground, in porous formations of 

rocks, through wells or other similar conveyance systems. See injection well. 

Unusual Expenditure—An expenditure that does not occur every year and that is more than 10 percent of 

O&M (e.g., major storm damage causes large outlay for repairs); or a capitalized one-time or capital cost not 

considered a lease acquisition or development cost (e.g., construction of a septic system or a building not 

directly associated with production) and is not a cost covered in Part C. 

Water Reuse—Beneficial use of coalbed methane produced water (e.g., livestock watering, 

irrigation, or dust control) in lieu of discharge/disposal. 

Wellhead Price of Gas—The price of gas at the wellhead, which is different from the price at 

natural gas hubs, reflecting the implicit cost to transport the gas to buyer, including the cost of 

gathering, compression, dehydration, etc. 

Working Interest—Percentage of ownership in an oil and gas lease granting its owner the right to 

explore, drill and produce oil and gas from a tract of property. Working interest owners are obligated 

to pay a corresponding percentage of the cost of leasing, drilling, producing and operating a well or 

unit. After royalties are paid, the working interest also entitles its owner to share in production

revenues with other working interest owners, based on the percentage of working interest owned. 

Working interest is not royalty; mineral rights owners who do not have working interests do not 

contribute to the costs of production. 

Workover, Stimulation, or Recompletion—Major, intermittent tasks. Workovers are major 

maintenance or remedial treatments on a well. Well stimulation includes fracturing, for example, 

either performed initially or later in the productive life of the well. Recompletion is a process 

undertaken to restore the productivity of a well, including to complete a well in a new stratum or 

strata. 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-12

Zero Discharge—Disposal of produced water other than by direct discharge to surface water or by 

indirect discharge to a POTW. Zero discharge does not allow for periodic or infrequent discharges 

attributed to activities such as maintenance, blowdown, or system purges. Examples include 

evaporation, underground injection, contract hauling, and/or water reuse. 
12

SECTION 3: SMALL BUSINESS DEFINITIONS AND NAICS IDENTIFICATION 

SBA allows small businesses to self-certify (subject to challenges, if they arise), which means 

that if you classify yourself as a small business, EPA will assume you have made this 

designation in good faith and will accept this designation. 

The Small Business Administration (SBA) defines small businesses in the following way: 

“The Small Business Act states that a small business concern is "one that is independently 

owned and operated and which is not dominant in its field of operation." The law also states that 

in determining what constitutes a small business, the definition will vary from industry to industry 

to reflect industry differences accurately. SBA's Small Business Size Regulations implement the 

Small Business Act's mandate to SBA. SBA has also established a table of size standards, 

matched to North American Industry Classification System (NAICS) industries.” 

The following table lists NAICS codes that are likely to be common among CBM operators. It 

also lists the current SBA definitions of small business for each of these likely NAICS codes. If, 

for any reason, you are not certain of your NAICS, the following website can be accessed using a 

key word search: http://www.census.gov/naics/2007/index.html; alternatively, you can use 

http://www.census.gov/naics/2007/NAICOD07.HTM, if you prefer to scroll through the 

definitions by type of industry. Note that clicking on the NAICS codes provides a definition of 

the industry in question. 

If you do not see an applicable NAICS in this table, you can refer to SBA’s Table of Size 

Standards, accessible at 

http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf. 

Alternatively, if you prefer, you can contact the EPA help line for assistance. 

NAICS Name of Industry SBA Small Business Size 

Standard 

211xxx Oil and Gas Extraction ≤500 employees 

21211x Coal Mining ≤500 employees 

213111 Drilling Oil and Gas Wells ≤500 employees 

213112 Support Activities for Oil and Gas Operations ≤$6.5 million annual revenues

213113 Support Activities for Coal Mining ≤$6.5 million annual revenues

22111x Electric Power Generation <4 million mW-hrs/year 

221112 Fossil Fuels Electric Power Generation <4 million mW-hrs/year 

22112x Electric Power, Transmission, Control and 

Distribution 

<4 million mW-hrs/year 

22121x Natural Gas Distribution ≤500 employees 

32411x Petroleum Refineries ≤1,500 employees 

486110 Pipeline Transportation of Crude Oil ≤1,500 employees 

486210 Pipeline Transportation of Natural Gas ≤$6.5 million annual revenues

The size standards are not the only standards that apply, however. SBA further defines small 

business in such a way that any business concern that is affiliated with a large business or, in 

many cases, a foreign firm cannot be considered a small business. SBA defines affiliation as: 
13

h. General Principles of Affiliation. 

i. Concerns and entities are affiliates of each other when one controls or has the 

power to control the other, or a third party or parties controls or has the power to 

control both. It does not matter whether control is exercised, so long as the 

power to control exists. 

ii. SBA considers factors such as ownership, management, previous relationships 

with or ties to another concern, and contractual relationships, in determining 

whether affiliation exists. 

iii. Control may be affirmative or negative. Negative control includes, but is not 

limited to, instances where a minority shareholder has the ability, under the 

concern's charter, by-laws, or shareholder's agreement, to prevent a quorum or 

otherwise block action by the board of directors or shareholders. 

iv. Affiliation may be found where an individual, concern, or entity exercises control 

indirectly through a third party. 

v. In determining whether affiliation exists, SBA will consider the totality of the 

circumstances, and may find affiliation even though no single factor is sufficient 

to constitute affiliation. 

Examples of affiliation would include a subsidiary of a large firm, a firm owned 50 percent or 

more by a large firm, and a joint venture by a small firm and a large firm. Even if the joint 

venture itself meets size standards, this affiliation would render the joint venture a large firm. 

However, if two small firms, each of which meets SBA size standards, join in a joint venture, the 

joint venture is also considered a small firm if it meets size standards. Another example of 

affiliation is a business concern that has as a corporate officer a person who is a corporate officer 

of a large firm. Small firms associated with large venture capital firms or investment firms 

through their investments in the small firm, however, are not considered affiliated. 
 Rev. 1 

 January 27, 2010 

Appendix A, PG QAPP–CBM Detailed Study Questionnaires Page 1 of 87 

Appendix A 

Final Detailed Questionnaire 
October 2009 

U.S. ENVIRONMENTAL PROTECTION AGENCY 

DETAILED QUESTIONNAIRE FOR THE 

COALBED METHANE EXTRACTION SECTOR 

Form Approved 

OMB Control No. 2040-0279 

Approval Expires 2/29/12 

 The public reporting and recordkeeping burden for this collection of information is estimated to average 

approximately 80 hours per response. Burden means the total time, effort, or financial resources expended by 

persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes 

the time needed to review instructions, develop, acquire, install, and utilize technology and systems for the 

purposes of collecting, validating, and verifying information, processing and maintaining information, and 

disclosing and providing information; adjust the existing ways to comply with any previously applicable 

instructions and requirements; train personnel to be able to respond to a collection of information; search data 

sources; complete and review the collection of information; and transmit or otherwise disclose information. An 

agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless 

it displays a currently valid OMB control number. 

 To comment on the Agency’s need for this information, the accuracy of the provided burden estimates, 

and any suggested methods for minimizing respondent burden, including the use of automated collection 

techniques, EPA has established a public docket for this ICR under Docket ID No. EPA-HQ-OW-2006-0771, 

which is available for public viewing at the Water Docket in the EPA Docket Center (EPA/DC), EPA West, Room 

B102, 1301 Constitution Ave., NW, Washington, DC 20004. The EPA Docket Center Public Reading Room is 

open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the 

Reading Room is (202) 566-1744, and the telephone number for the Water Docket is (202) 566-2426. An 

electronic version of the public docket is available through the federal data management system (FDMS) at 

http://www.regulations.gov. Use FDMS to submit or view public comments, access the index listing of the 

contents of the public docket, and to access those documents in the public docket that are available 

electronically. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of 

Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Officer for EPA. Please 

include the EPA Docket ID No. EPA-HQ-OW-2006-0771 and OMB control number (2040-0279) in any 

correspondence. 
General Instructions CBM Questionnaire 

i 

Operator ID: 

INTRODUCTION 

The U.S. Environmental Protection Agency (EPA) is conducting a survey of coalbed methane (CBM) extraction 

operations. EPA will use the responses collected in this detailed questionnaire to inform its decision on whether to 

initiate a rulemaking to potentially revise the effluent guidelines for the Oil and Gas Extraction Point Source 

Category (40 CFR 435) to include limits for pollutants discharged in CBM produced water. This questionnaire is 

not focused on conventional oil and gas extraction. Any regulatory decisions resulting from this survey will not 

affect conventional oil and gas operations. The technical data collected will be used to determine the 

characteristics of CBM produced water, potential environmental impacts, existing management, beneficial use, 

and disposal practices for CBM produced water, and the related costs for this industry sector. The financial and 

economic data collected will be used to characterize the economic status of the industry sector and to estimate 

the possible economic impacts of potential technology and beneficial use options for CBM produced water. EPA 

is conducting this survey as part of its annual review of existing effluent guidelines, which is required by the Clean 

Water Act (CWA) sections 301(d) and 304(b). You must respond to this questionnaire if you operated a CBM well 

in 2008. 

EPA is conducting this survey under the authority of Section 308 of the Clean Water Act (Federal Water Pollution 

Control Act, 33 U.S.C. Section 1318). You must respond to this questionnaire within 60 days of receiving it 

unless EPA authorizes an extension (see page ii). Failure to respond, late filing, or failure to comply with the 

instructions may result in criminal fines, civil penalties, and other sanctions, as provided by law. 

OVERVIEW OF THE QUESTIONNAIRE 

The questionnaire is divided into three parts: Part A lists the projects operated by your company that have been 

selected for this questionnaire, Part B contains financial and economic information, and Part C contains produced 

water management information. The parts are divided into the following sections: 

PART A: CBM PROJECTS SELECTED FOR QUESTIONNAIRE AND CERTIFICATION

Part A of the questionnaire identifies the projects selected for this questionnaire. The questions in Parts B and C 

pertain only to the projects listed in Part A. You are required to provide information in Part B, Section 3, and 

Part C, Sections 2 through 4, for each of the projects identified in Part A. 

PART B: FINANCIAL AND ECONOMIC INFORMATION

INSTRUCTIONS FOR PART B 

SECTION 1: CONTACT INFORMATION 

SECTION 2: FIRM-LEVEL FINANCIAL QUESTIONS 

SECTION 3: PROJECT-LEVEL QUESTIONS 

The financial and economic data collected in Part B of this questionnaire will be used to characterize the 

economic status of the industry and to estimate the possible economic impacts of wastewater regulations. The 

questions in Part B pertain to calendar years 2006 through 2008. 

PART C: PRODUCED WATER MANAGEMENT INFORMATION

INSTRUCTIONS FOR PART C 

SECTION 1: GENERAL OPERATOR INFORMATION 

SECTION 2: PRODUCED WATER MANAGEMENT SYSTEM GENERAL QUESTIONS 

SECTION 3: DETAILED PRODUCED WATER MANAGEMENT AND TREATMENT QUESTIONS 

SECTION 4: PRODUCED WATER QUALITY DATA 

The information requested in Part C of this questionnaire will be used to analyze produced water production rates, 

produced water characteristics, and produced water management, treatment, and disposal practices. Part C 

requests information for calendar year 2008. 

PART D: SUPPORTING INFORMATION

SECTION 1: LIST OF ACRONYMS 

SECTION 2: DEFINITION OF KEY TERMS 

SECTION 3: SMALL BUSINESS DEFINITIONS AND NAICS IDENTIFICATION 
General Instructions CBM Questionnaire 

Operator ID: 

ii

COMPLETION OF THE QUESTIONNAIRE

Each section of the questionnaire should be completed by the person(s) most knowledgeable about the 

information requested. The corporate official or designee responsible for directing or supervising the response to 

the questionnaire must sign the Certification Statements on page A-2 to verify and validate the information 

provided. 

Keep a Copy of the Completed Questionnaire

Please keep a copy of the completed questionnaire, including attachments. EPA will review the information 

submitted and may request your cooperation in answering follow-up questions, if necessary, to complete 

analyses. 

QUESTIONNAIRE ASSISTANCE 

EPA Coalbed Methane Help Lines

Phone Line (Leave Voice Mail for a Response within One Business Day)........................................................1-800-864-9230 

Internet Electronic Mailing Address (Response within One Business Day)........................................ cbmdetailed@pgenv.com 

Please contact the help line if you would like to schedule an appointment for assistance with completing the questionnaire. 

WHEN TO RETURN QUESTIONNAIRE 

You must respond to this questionnaire within 60 days of receiving it. 

If you wish to request an extension, you must do so in writing within 30 days of receipt of this questionnaire. 

Written requests may be e-mailed to Mr. Carey Johnston at johnston.carey@epa.gov with “CBM Survey 

Extension Request” in the e-mail subject line or may be mailed to: 

United States Postal Service One- or Two-Day Delivery (e.g., FedEx)

Mr. Carey Johnston Mr. Carey Johnston 

U.S. EPA, Office of Water U.S. EPA, Office of Water 

Mail Code: 4303T Room 6231G, EPA West 

1200 Pennsylvania Avenue, NW 1301 Constitution Avenue, NW 

Washington, DC 20460 Washington, DC 20004 

Extension requests will be evaluated on a case-by-case basis. Submittal of an extension request to EPA does not

alter the due date of your questionnaire unless and until EPA agrees to the extension and establishes a new date. 

WHERE TO RETURN QUESTIONNAIRE 

After completing the questionnaire and certifying the information that it contains, please use the enclosed mailing 

label to mail the completed questionnaire to: 

U.S. Environmental Protection Agency 

CBM Industry Survey 

c/o PG Environmental, LLC 

570 Herndon Parkway, Suite 500 

Herndon, VA 20170 
General Instructions CBM Questionnaire 

Operator ID: 

iii

REQUESTING AN ELECTRONIC VERSION OF THE QUESTIONNAIRE 

If you would like an electronic version of the questionnaire, it is available on the EPA Web site at: 

http://www.epa.gov/guide/cbm/. 

CONFIDENTIAL BUSINESS INFORMATION 

If no business confidentiality claim accompanies the information when it is received by EPA, EPA may 

make the information available to the public without further notice.

Regulations governing the confidentiality of business information are contained in the Code of Federal 

Regulations (CFR) at Title 40 Part 2, Subpart B. You may assert a business confidentiality claim covering part or 

all of the information you submit, other than effluent data and information or data that is otherwise publicly 

available, as described in 40 CFR 2.203(b): 

“(b) Method and time of asserting business confidentiality claim. A business which is submitting 

information to EPA may assert a business confidentiality claim covering the information by placing on (or 

attaching to) the information, at the time it is submitted to EPA, a cover sheet, stamped or typed legend, 

or other suitable form of notice complying language such as ‘trade secret,’ ‘proprietary,’ or ‘company 

confidential.’ Allegedly confidential portions of otherwise non-confidential documents should be clearly 

identified by the business, and may be submitted separately to facilitate identification and handling by 

EPA. If the business desires confidential treatment only until a certain date or until the occurrence of a 

certain event, the notice should so state.” 

You may claim as confidential all information included in the response to a question by checking the Confidential 

Business Information (CBI) box next to the question number. Alternatively, all questions marked with a CBI check 

box may be claimed confidential now by checking the box at the end of this paragraph. If you do not check this 

box, any individual response where “CBI” is NOT checked will be considered nonconfidential. Note that you may 

be required to justify any claim of confidentiality at a later time. Note also that facility effluent data are not eligible 

for confidential treatment, pursuant to Section 308(b) of the Clean Water Act, and thus will be treated as nonconfidential even if the CBI box is checked. In addition, information that is publicly-available should not be claimed 

confidential. Note also that information claimed confidential cannot be accessed, verified, or used by the industry 

at a later date to evaluate data and analyses supporting the results of the CBM study. 

 Check Here to Claim All Eligible Data are CBI 

Information covered by a claim of confidentiality will be disclosed by EPA only to the extent of, and by means of, 

the procedures set forth in 40 CFR Part 2, Subpart B. In general, submitted information protected by a business 

confidentiality claim may be disclosed to other employees, officers, or authorized representatives of the United 

States concerned with implementing the Clean Water Act. Exemption 4 of the Freedom of Information Act (FOIA) 

protects from disclosure "trade secrets and commercial or financial information obtained from a person and 

privileged or confidential." See 5 U.S.C. 552(b)(4). 

Information covered by a claim of confidentiality will be made available to EPA contractors under EPA Contract 

Numbers No. 68-C02-095, EP-C-07-029, and EP-C-05-030 to enable the contractors to perform the work required 

by their contracts with EPA. All EPA contracts provide that contractor employees use the information only for the 

purpose of performing the work required by their contracts and will not disclose any CBI to anyone other than 

EPA without prior written approval from each affected business or from EPA’s legal office. EPA has approved 

written procedures for each contractor on how they will gather, safeguard, and secure CBI. Any comments you 

may wish to make on this issue must be submitted in writing along with your completed survey. 
Part A. CBM Projects Selected for Questionnaire and Certification CBM Questionnaire 

Operator ID: 

A-1

PART A. CBM PROJECTS SELECTED FOR QUESTIONNAIRE AND 

CERTIFICATION 

A1-1. Did you respond to EPA’s screener questionnaire on CBM projects? 

 Yes. Continue with Question A1-2. 

 No. Skip to Question A1-3.

A1-2. You have been selected by EPA to respond to questions about projects you identified in EPA’s 

screener survey sent to you on February 27, 2009. EPA has selected the following projects in its 

representative sampling of CBM projects for this survey (Note: if no projects are listed in Table A-1 

below, please contact the EPA Coalbed Methane Help Line): 

[This table will be pre-populated based on information collected in the screener questionnaire.] 

Table A-1. Projects Selected for this Questionnaire 

Project Identifier 

Count of Wells Productive in 

2008 (from screener) 

 

For each of the projects listed in Table A-1, EPA requests that you provide identifying information 

on all wells that were actively producing either water or gas in 2008. The number of wells with 

identifying information submitted should match the number of wells listed in Table A-1 (reported in 

your screener survey). Reasons for any discrepancies should be reported in the Comments section in 

Question A1-4. You may use Table A-2 to fill in this information or you can submit your own printout 

or electronic form, whichever is more convenient. Make as many copies of the table as you need, 

ensuring that the relevant project identifier is written on the top right hand corner of the page. 

Please provide the API number for each well in the project unless the well is located in Kansas, 

Virginia, or Indiana. List the API number in Column A of Table A-2 if you choose to use this table. 

Please follow the instructions below for Kansas, Virginia, and Indiana and enter the information into 

Column B of Table A-2 if using this table. 

• Kansas -The well identifying information should be the lease/permit number that is in the form 

of a six-digit number, e.g., 221405. 

• Virginia -The well identifying information should be the permit number that is in the form of a 

2-letter and 4-digit number combination, e.g., BU-0390. 

• Indiana -The well identifying information should be the permit number that is in the form of a 

5-digit number, e.g., 50125. 

If you have projects listed in Table A-1, please skip Question A1-3. Remember to sign the Certification 

Statement on page A-2 after completing the rest of the questionnaire.
Part A. CBM Projects Selected for Questionnaire and Certification CBM Questionnaire 

Operator ID: 

A-2

A1-3. According to EPA’s information, you did not receive a screener questionnaire, but most likely you 

operated only one or two CBM projects in 2008. A CBM project comprises a well, group of wells, 

lease, group of leases, or recognized unit for which you operated as an economic unit when making 

production decisions in 2008. If you did not operate any CBM wells in 2008 or if you had another 

concern about whether your organization is the appropriate respondent for this questionnaire, please 

contact the EPA help line for further instructions. Otherwise, EPA requests that you provide 

identifying information on all CBM wells that were actively producing water or gas in 2008, by project. 

EPA recognizes that such groupings can change over time, so define your project(s) in a way that is 

best representative of your production decision grouping in 2008. 

Please provide an identifying name or number for your project (Project ID) in the top right-hand corner 

of Table A-2 which must be completed for each CBM project you identify (you will need to copy the 

table if you have more than one project). You will need to use this project identifier in other sections of 

this survey questionnaire. 

Please provide the API number in Column A for each well in the project unless the well is located in 

Kansas, Virginia, or Indiana. Please follow the instructions below for Kansas, Virginia, and Indiana 

and enter the information into Column B of Table A-2 if using this table. 

• Kansas – The well identifying information should be the lease/permit number that is in the 

form of a six-digit number, e.g., 221405. 

• Virginia – The well identifying information should be the permit number that is in the form of a 

2-letter and 4-digit number combination, e.g., BU-0390. 

• Indiana – The well identifying information should be the permit number that is in the form of a 

5-digit number, e.g., 50125. 

Remember to sign the Certification Statement on page A-2 after completing the rest of the 

questionnaire. 
Part A. CBM Projects Selected for Questionnaire and Certification CBM Questionnaire 

Operator ID: 

A-3

Table A-2. Well Identifying Information for All Actively Producing Wells for Project ID ______ 

(Submit One Copy for Each Project Listed in Table A-1 or Requested in Question A1-3.) 

Column A 

API Number 

(Excluding Kansas, Virginia, Indiana) 

Column B 

Permit Number 

(Kansas, Virginia, Indiana Only) 

 
Part A. CBM Projects Selected for Questionnaire and Certification CBM Questionnaire 

Operator ID: 

A-4

Copy of 

A1-4. Comments on Part A. Please cross-reference your comments by question number. If you need 

additional space, please photocopy this page before writing on it, and number each copy in the 

space provided. 

Question 

Number Comment 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 
Part A. CBM Projects Selected for Questionnaire and Certification CBM Questionnaire 

Operator ID: 

A-5

CERTIFICATION STATEMENT 

I certify under penalty of law that the attached questionnaire was prepared under my direction or supervision 

and that qualified personnel properly gathered and evaluated the information submitted. The information 

submitted is, to the best of my knowledge and belief, accurate and complete. In those cases where we did not 

possess the requested information for questions applicable to our operations, we provided best estimates. We 

have to the best of our ability indicated what we believe to be company confidential business information as 

defined under 40 CFR Part 2, Subpart B. We understand that we may be required at a later time to justify our 

claim in detail with respect to each item claimed confidential. I am aware that there are significant penalties 

for submitting false information, including the possibility of fines and imprisonment as explained in Section 

308 of the Clean Water Act.

 

Signature of Certifying Official Date 

 ( ) - 

Printed Name of Certifying Official Telephone Number of Certifying Official 

 

Title of Certifying Official 

 

Facility Name 

(Continue to Part B, Section 1 of the questionnaire, complete all sections, and return the questionnaire along 

with the signed Certification Statement to the address provided on page ii.)
Part B. Financial and Economic Information 

Section 1: Contact Information CBM Questionnaire 

Operator ID: 

B-1

PART B. FINANCIAL AND ECONOMIC INFORMATION 

SECTION 1: CONTACT INFORMATION 

GENERAL INSTRUCTIONS FOR SECTION 1 

This section of the questionnaire is designed to collect general operator information pertinent to Part B, 

including contact information. 

Indicate information that should be treated as confidential by checking the Confidential Business Information 

(CBI) box next to each question number with responses containing CBI. Any response where "CBI" is not 

checked will be considered non-confidential unless you have previously indicated that all eligible information 

should be considered confidential. Refer to the instructions given in the CONFIDENTIAL BUSINESS 

INFORMATION section on page ii for additional information regarding EPA's confidentiality procedures set 

forth in 40 CFR Part 2, Subpart B. 

B1-1. Provide the name, title, telephone and facsimile numbers, and e-mail address of the primary contact 

at your operation for information supplied in the firm-level financial and economic portions of the 

questionnaire (Part B, Section 3). 

 ( ) - 

Primary Contact Name Telephone Number 

 ( ) - 

Primary Contact Title Facsimile Number 

 Convenient time to call between: 

Email Address am / pm and 

 am / pm (Eastern Time) 

B1-2. Provide the name, title, telephone and facsimile numbers, and e-mail address of the primary contact 

at your operation for information supplied in the project-level economic and financial portions of this 

questionnaire (Part B, Section 2), if different from the primary contact above. 

 ( ) - 

Primary Contact Name Telephone Number 

 ( ) - 

Primary Contact Title Facsimile Number 

 Convenient time to call between: 

Email Address am / pm and 

 am / pm (Eastern Time) 

B1-3. If you know that other facilities in your firm have received this questionnaire and would like to 

reference the firm-level information provided by another respondent, please provide the operator ID 

(shown at the top of each page of the questionnaire) of the respondent who is submitting Part B 

Section 2 for your firm: 

 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

Operator ID: 

B-2

SECTION 2: FIRM-LEVEL FINANCIAL QUESTIONS 

Instructions: Section 2 of this survey is focused primarily on collecting firm-level financial information at the 

lowest corporate level for which it is available or can be reasonably estimated. This level is considered the 

“immediate owner/operator.” Most respondents to this detailed questionnaire were identified using a screener 

survey. 

For those who were not asked to respond to a screener survey, the detailed questionnaire has been sent to 

the entity that is listed in state oil and gas commission (or similar agency) databases as the operator of one or 

more CBM wells within the state. Because the survey is focused on the lowest corporate level, the 

appropriate respondent should be the “immediate owner/operator,” who is the entity responsible for 

management and/or day-to-day operation of this project and makes the following types of decisions: 

• Whether well(s) should be shut-in, worked over or abandoned. 

• Whether additional or replacement wells should be drilled into a reservoir 

• Whether additional or different production equipment should be installed; and 

• Any other decision factor used by DOE in the General Instructions to Form EIA-23 (see also definition 

of management decisions in the Definitions of Key Terms section at the end of the questionnaire). 

If you are an owner who manages a contract operator to oversee the operation of the project or projects, you 

are still considered the immediate owner/operator for the purposes of this questionnaire. EPA is aware that 

you might need to consult with or send portions of this questionnaire to your contract operator for assistance 

in completing the survey. 

If you have any concerns that your organization is not the appropriate respondent for this survey, please 

contact the EPA help line. As an example, if you have a working interest in one or more CBM wells but do not 

operate or manage the well or wells yourself, nor do you oversee a contract operator for this work, you will 

need to contact the EPA help line. 

EPA would like at least some minimum information on three levels of corporate hierarchy, if applicable: 

immediate owner/operator, owner, and parent or ultimate parent. Some immediate owner/operators are 

independent (not owned by any other firm). Others have owner firms above them in the hierarchy. The owner 

firm, in turn, may be owned directly or through other intermediate parents by an ultimate parent, which is the 

highest level of the corporate hierarchy. In many cases, information requested from higher levels of the 

corporate hierarchy will include only the names of key corporate entities. 

Additionally, some immediate owner/operators are owned by more than one owner firm (e.g., joint ventures). 

EPA will be requesting only the corporate names of joint owners; financial information will be requested only 

from the firm created as the joint venture (e.g., a limited liability corporation). 
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

Operator ID: 

B-3

B2-1. Describe the position in the corporate hierarchy of the immediate owner/operator (as defined above). 

If the location to which this questionnaire was mailed is, for example, a field office and not considered 

a separate corporate entity for accounting purposes, you may need to confer with corporate staff to 

complete Part B, Section 2. In this case, check the box that applies to the lowest level in your 

corporate hierarchy where accounting statements (audited or unaudited) are recorded. This may be 

at the division level or at a higher firm level, depending on your circumstances. If you are not sure 

how to answer this question, please contact the EPA help line. 

(Choose only one of the following.) 

 Independent owner/operator. This firm is not owned or affiliated with any other firm. Skip to 

Question B2-4.

 Joint venture. This firm is owned by at least two other firms (not individuals). Continue with 

Question B2-2. 

 Division or profit center. This entity is owned by no more than one owner firm, although the 

owner firm, in turn, might be a subsidiary or a joint venture. Continue with Question B2-2. 

 Subsidiary firm. This firm is owned by no more than one owner firm (portions may be publicly 

held). The owner firm, in turn, might be a subsidiary or a joint venture, however. Continue 

with Question B2-2. 

B2-2. If the immediate owner/operator is, in turn, owned by an owner firm or firms (is not an independent 

owner/operator), what is the corporate name (or names, if a joint venture) of the owner(s)? 

 

 

 

B2-3. What is the name of the ultimate parent company (or companies, if a joint venture) for the immediate 

owner/operator? (If there is only one owner firm above the immediate owner/operator, it should be 

listed in Question B2-2. In this case, please respond “none”.) 

 

 

 

B2-4. In 2008, was your highest level of corporate ownership a small business under the Small Business 

Administration (SBA) definitions? If you responded to this question in EPA’s screener questionnaire, 

the response you provided at that time has been transferred to this questionnaire and you do not 

need to respond further to this question. Otherwise, please refer to page D-2 for definitions that may 

assist in answering this question. If you need further assistance beyond that provided in Part D, 

please contact the EPA help line. [NOTE: Question will be prepopulated if you provided a screener 

answer.] 

 Yes 

 No 

B2-5. What is the 6-digit NAICS code for the immediate owner/operator? Please refer to page D-2 for 

definitions that may assist in answering this question. If you need any further assistance, please 

contact the EPA help line and EPA will help you make this determination. 

 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

Operator ID: 

B-4

B2-6. Is the immediate owner/operator a contract operator only (owns no working interests in any CBM 

projects)? 

 Yes 

 No 

B2-7. What is the organization type of the immediate owner/operator? 

 C Corporation 

 S Corporation, Limited Liability Corporation, or Limited Liability Partnership 

 Division or Profit Center. Owner firm is a: 

 C Corporation 

 S Corporation, Limited Liability Corporation, or Limited Liability Partnership 

 Other: 

 Other: 

B2-8. Are you required to use the cost-depletion method (unit of production) in computing your depletion 

allowance for tax purposes? (That is, you, your owner firm, or your corporate parent is considered a 

vertically integrated firm under IRS rules.) 

 Yes 

 No 

B2-9. What was the 2008 employment at the immediate owner/operator? Please include any local contract 

labor, but do not allocate overhead employment from higher corporate levels. 

a. Total 2008 employment was 

b. 2008 employment attributable to CBM operations was (estimate if 

necessary). 

B2-10. In 2008, was all produced water from all CBM projects operated by the immediate owner/operator 

injected into a receiving formation in a Class II injection well under the UIC program? 

 Yes. You have completed Part B, Section 2. Continue with Part B, Section 3 on page B-2. 

 No. Continue with Question B2-14. 

Instructions: The following questions should be answered at the lowest level of firm organization at which 

substantial financial decisions are made on CBM operations (e.g., decisions on major capital investments or 

major production decisions for an individual project, such as converting from discharge of produced water to 

subsurface injection, or whether to develop a new or abandon an existing CBM project). This may be the 

operator or the operator’s owner firm, for example, or even higher in the corporate hierarchy, such as at a 

parent firm. Questions B2-11 through B2-14 ask for information critical to evaluating CBM project decisions 

and/or understanding the financial situation reflected in the information provided in this section. 

B2-11. Indicate the corporate level at which major investment decisions (such as those discussed above) are 

made: 

 Immediate Owner/Operator 

 Owner Firm(s) 

 Other. Name of entity: 

EPA intends to make assumptions about the method of capital investment analysis and cost of capital for 

projects you operate. You can agree to these assumptions if they seem to reflect your operation adequately, 

or you can provide alternative assumptions if you feel these assumptions are not appropriate to your 

operation. If this decision is made at a higher level and you do not know the answers to these questions, you 

have the option of indicating you do not know. If you leave the questions unanswered or you indicate that 

you do not know, EPA will use the assumptions outlined in the questions.

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

Operator ID: 

B-5

B2-12. EPA plans to use a net present value analysis to determine the extent to which costs of various 

produced water alternatives that are analyzed affect the profitability of the project, up to and including 

a finding that it is not economical to install and operate produced water management alternatives (i.e., 

a project with an estimated positive net present value is estimated to have a negative net present 

value if additional costs of produced water management are incurred). (Choose one answer.) 

 Agree or Don’t Know. We understand EPA will use the assumption discussed above. 

 Disagree. We would prefer EPA consider an analysis as described in the comments section 

on page B-2.

B2-13. EPA plans to use the average pre-tax cost of capital as recommended by OMB, which assumes an 

average investment risk. With no inflation considered, this rate is 7 percent. This rate corresponds 

roughly to a 10 percent interest rate, for example, if a 3 percent inflation rate is assumed throughout 

the time frame of the analysis. (Choose one answer). 

 Agree or Don’t Know. We understand EPA will use the assumption discussed above. 

 Disagree. We would prefer EPA to use the following figure to represent our pre-tax cost of 

capital. Provide the nominal rate (i.e., do not subtract an inflation rate from this figure). 

 % 

B2-14. EPA will also investigate the impact of alternative produced water management costs using a hurdle 

rate for future projects (the return required to undertake a project). EPA plans to use a hurdle rate 

(not including inflation) in sensitivity analyses ranging from 12% to 22%. This would be equivalent to a 

hurdle rate that includes a factor for inflation of roughly 15% to 25% (assuming a 3 percent factor). 

 Agree or Don’t Know. We understand EPA will use the assumption discussed above. 

 Disagree. We would prefer EPA to use the following figure (nominal, including inflation) to 

represent our hurdle rate: 

 % 

Instructions: The following questions (B2-15 through B2-25) ask for income statement (through net income) 

and balance sheet information. Information is requested at the lowest level in the corporate hierarchy at 

which such information is kept. 

B2-15. If you qualify as a small business under SBA definitions and answered YES to Question B2-4, you 

have the option of providing just your accounting reports or income tax returns (e.g., Schedule C) for 

the years 2006, 2007, 2008, showing income and balance sheet information. EPA will fill out most of 

the information needed using your accounting reports or returns. 

 Yes. We are a small business and are opting to have EPA prepare the answers to Questions 

B2-16 to B2-22 for us. We are providing an estimate of the percentage of our earnings (net 

revenues minus operating costs minus depreciation) attributable to CBM production in 2006, 

2007, and 2008: 

2006: % 

2007: % 

2008: %. Skip to Question B2-23.

 No. Continue with Question B2-16.

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

Operator ID: 

B-6

B2-16. Instructions: If you are a small business and have opted to have EPA prepare answers to Questions 

B2-16 to B2-22, please skip to Question B2-23. 

EPA understands that audited financial data may not be available at the immediate owner/operator 

level in the corporate hierarchy, but wishes to assess impacts on the most sensitive portion of the 

corporation and encourages good faith estimates or unaudited financial data if this is what is available 

at this level. If you are not comfortable with an estimate, you can opt to answer at a higher level, but 

please answer all income statement questions (Questions B2-16 through B2-19) at the same 

corporate level. You will be able to use either an estimate or “NA” to apply to some line items that 

might not be recorded at a division level, if this is the level at which you are responding. 

Income Statement Information: Questions B2-17 through B2-19 ask for revenues, costs and 

expenses, and earnings, interest, taxes and net income (loss). To the extent possible, provide this 

information at the immediate owner/operator level, whether a profit center or firm. EPA acknowledges 

that some items, such as depreciation, taxes, and interest might be kept only at a higher corporate 

level in some cases, although some or all of these may be routinely estimated for planning purposes. 

In this case, EPA would like these estimates. If you can provide all but depreciation, taxes, and 

interest at the immediate owner/operator level, please do so, using “NA” for depreciation, taxes and 

interest. Otherwise, information at the next higher level (owner firm) is acceptable. Please indicate the 

corporate level at which these income statement data are being provided. 

 Immediate Owner/Operator 

 Owner Firm (from Question B2-2) 

 Other (list corporate name): 

B2-17. What were your organization’s revenues for 2006-2008? Report in nearest thousands of dollars (i.e., 

if net sales were $1,253,779, please report as $1,254,000; zeroes have been provided already). If 

you would like EPA to know that you estimated any line item, you can indicate this by checking ( ) 

the estimate column (Est.). 

Est. Revenues 2006 2007 2008 

a. Net sales and other operating 

revenues (all operations, 

including non-oil and gas 

related revenues) 

 , ,000 , ,000 , ,000

b. Revenues attributable to all oil 

and gas operations (including 

CBM) 

 , ,000 , ,000 , ,000

c. Revenues attributable to CBM 

operations only , ,000 , ,000 , ,000

d. Other income (Specify): 

 , ,000 , ,000 , ,000

e. Total revenues 

(a plus d) , ,000 , ,000 , ,000

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

Operator ID: 

B-7

B2-18. What were your organization’s operating expenses for 2006-2008? Report in nearest thousands of 

dollars (i.e., if operating costs were $1,253,779, please report as $1,254,000; zeroes have been 

provided already). If depreciation information is not recorded at the corporate level represented in the 

income statement information provided above, or is not usually estimated for your corporate level, 

please insert NA. If depreciation is routinely estimated or you opt to estimate depreciation, please 

provide the information. If you would like EPA to know that you estimated any line item, you can 

indicate this by checking ( ) the estimate column (Est.). 

Est. Costs and Expenses 2006 2007 2008 

a. Operating costs (all 

operations) , ,000 , ,000 , ,000

b. Operating costs attributable to 

all oil and gas operations 

(including CBM) 

 , ,000 , ,000 , ,000

c. Operating costs attributable to 

CBM operations only , ,000 , ,000 , ,000

d. Selling, general, and 

administrative costs , ,000 , ,000 , ,000

e. Depreciation, depletion, and 

amortization , ,000 , ,000 , ,000

f. Royalty payments , ,000 , ,000 , ,000

g. Severance tax payments , ,000 , ,000 , ,000

h. Other costs (Specify): 

 , ,000 , ,000 , ,000

i. Total costs and expenses 

(a plus d through h) , ,000 , ,000 , ,000

B2-19. What were your organization’s earnings and net income for 2006-2008? Report in nearest thousands 

of dollars (i.e., if earnings were $1,253,779, please report as $1,254,000; zeroes have been provided 

already). If tax and/or interest information is not recorded at the corporate level represented in the 

income statement information provided above, or is not usually estimated for your corporate level, 

please insert NA. If these items are routinely estimated or you opt to estimate them, please provide 

the estimates. If you would like EPA to know that you estimated any line item, you can indicate this by 

checking ( ) the estimate column (Est.). 

Est. Earnings and Net Income 2006 2007 2008 

a. Earnings before interest and 

taxes (Question B2-17e minus 

Question B2-18i) 

 , ,000 , ,000 , ,000

b. Interest expense , ,000 , ,000 , ,000

c. Federal and state income tax , ,000 , ,000 , ,000

d. Net income or net loss 

(a minus b minus c) , ,000 , ,000 , ,000

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

Operator ID: 

B-8

B2-20. Balance Sheet Questions: Questions B2-21 through B2-23 ask for assets, liabilities and equity 

information, as well as information on payments to principal. EPA acknowledges that balance sheets 

might be kept only at a higher corporate level than the income statement information provided, in 

some cases, although some or all of these may be routinely estimated for planning purposes. In this 

case, EPA would like these estimates. If you can provide estimates at the immediate owner/operator 

level, please do so. If not, information at the next higher level (owner firm) is preferred to information 

at higher levels of the corporation, even if at this level, the information is unaudited. Please indicate 

the level at which these balance sheet and other data are being provided: 

 Immediate Owner/Operator 

 Owner Firm (from Question B2-2) 

 Other (list corporate name): 

B2-21. What were your company’s assets in 2008? Report in nearest thousands of dollars (i.e., if assets 

were $1,253,779, please report as $1,254,000; zeroes have been provided already). If you would like 

EPA to know that you estimated any line item, you can indicate this by checking ( ) the estimate 

column (Est.). 

Est. Assets 2008 

a. Current assets , ,000

b. Property, plant, and equipment (net of depreciation) , ,000

c. Other assets (net of depreciation) , ,000

d. Total assets (sum of a through c) , ,000

B2-22. What were your company’s liabilities and equity in 2008? Report in nearest thousands of dollars (i.e., 

if total liabilities were $1,253,779, please report as $1,254,000; zeroes have been provided already). 

If you would like EPA know that you estimated any line item, you can indicate this by checking ( ) 

the estimate column (Est.). 

Est. Liabilities and Equity 2008 

a. Current liabilities (including accounts payable, accrued 

expenses and taxes, and the current portion of long-term debt) , ,000

b. Long-term debt (including bonds, debentures, long-term leases, 

bank debt, and all other noncurrent liabilities such as deferred 

income taxes) 

 , ,000

c. Retained earnings , ,000

d. Other owner equity (not including retained earnings) , ,000

e. Sum of liabilities and owner equity (sum of a, b, c, and d) , ,000

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 2: Firm-Level Financial Questions CBM Questionnaire 

Operator ID: 

B-9

B2-23. This question asks for payments to principal over 3 years. Payments to principal are cash outlays 

made to pay back long-term debt, excluding interest payments (similar to a mortgage payment, which 

can also be split between payments to principal and interest). These payments should relate to the 

long-term debts reported in Question B2-22 or those shown in the financial statements submitted in 

response to Question B2-15. Please provide these payments in: 

a. 2006? $ , ,000 This is an estimate: (optional check box) 

b. 2007? $ , ,000 This is an estimate: (optional check box) 

c. 2008? $ , ,000 This is an estimate: (optional check box) 

B2-24. The income statement and balance sheet information reflect a fiscal year starting in (month): 

 

IMPORTANT: If you have provided your financial information in Questions B2-16 through B2-22, submission 

of financial reports is optional and you may skip to Section 3, Part B. Please note that a benefit of 

submitting your financial reports in addition to completing Questions B2-16 through B2-22 is that submission 

of these financial reports may reduce the need for EPA to contact you for clarifications on your answers to 

Questions B2-16 through B2-22. If, however, you opted to have EPA complete these questions for you as a 

small business as indicated in Question B2-15, the submission of financial reports or tax returns is not 

optional. 

B2-25. Please provide financial statements. 

Instructions: For those who choose to or must provide such information, please include copies of all 

2006-2008 financial statements that would be needed or were used to compile the answers to 

Questions B2-16 through B2-22 above with your completed questionnaire. These may be accountant 

reports, annual reports, Federal income tax returns (e.g., Schedule C), and/or 10-K reports. Include 

income statements, balance sheets, and associated notes for your organization to the extent 

possible, preferably at the lowest level in the corporation at which information is kept. If you have 

included such financial statements, please check the “attached” box. 

 Attached. 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 3: Project-Level Questions CBM Questionnaire 

Operator ID: 

B-10

SECTION 3: PROJECT-LEVEL QUESTIONS 

Instructions: This section asks for information from the operator of the project or projects identified in Part A, 

where operator is defined as the person responsible for the management and day-to-day operation of this 

project or projects as defined in Section 2 and in the definitions section of this questionnaire. If your project 

numbers have not been prepopulated in the tables that follow, please use the project identifiers you 

assigned the project in Table A-2.

If you own but do not operate the project in question, and you are not able to complete some or all of the 

information, please contact your contract operator to obtain answers to questions for Section 3. Alternatively, 

you may remove Section 2 of the questionnaire and provide the remaining portions of the questionnaire to 

your contract operator. You are responsible for obtaining the questionnaire from your contract operator, 

recompiling the questionnaire, signing the certification pages, and returning the entire questionnaire to EPA. 

If your project(s) operates in a reservoir that has been unitized, please include information only for 

that portion of the unit you operate, and provide the unit number or other group identifier in Question 

B3-9.

[Note: Please make additional copies of Table B-1 through Table B-3 if Part A contains more than 3 

projects]. 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-11

Table B-1. General Project Information—Projects through Year End 2008 [Please enter the project name from Pa

Question Project Project P

Project Identifier Information

CBI?

 Yes B3-1. Name or Identifier of Project. 

CBI?

 Yes B3-2. Name of Field(s). Indicate “unnamed” if no name has been assigned. 

CBI?

 Yes B3-3. Is this project considered a wildcat project? Yes No Yes No 

CBI?

 Yes B3-4. Does this project commingle CBM with conventional oil and gas or other unconventional 

production (e.g., tight shale)? 

 NOTE: unless otherwise specified, all further 

questions relating to gas production or water 

production in Part B pertain to total (conventional, other unconventional, and 

CBM) production. 

 Yes. Continue with 

Question B3-5. 

 No. Skip to Question 

B3-9.

 Yes. Continue with 

Question B3-5. 

 No. Skip to Question 

B3-9.

CBI?

 Yes

B3-5. If you commingle CBM with conventional oil 

and gas or other unconventional production, what percentage of the gas and water produced from this project was extracted from coalbeds in 2008 (%) (estimate if necessary)? 

a. Gas % 

b. Water % 

a. Gas %

b. Water %

a. 

b. 

CBI?

 Yes

B3-6. If you commingle CBM with 

conventional/other production, what was the oil production from this project in 2008 (bbls)? 

 bbls bbls 

CBI?

 Yes

B3-7. If you commingle CBM with conventional/

other production, is the average royalty rate on this oil the same as that for gas? If no, please provide the royalty rate; if not applicable or the rate is the same as that for gas, please insert “NA.” 

% % 

CBI?

 Yes

B3-8. If you commingle CBM with 

conventional/other production, in what year did conventional/other gas and/or oil production begin? 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-12

Question Project Project P

CBI?

 Yes B3-9. Unit Number, or other group identifier (if relevant) Skip to Question B3-11 if not part of 

a formal unit.

CBI?

 Yes B3-10. Indicate the percentage of annual production on the unit in 2008 associated with your portion of 

the unit (%). 

% % 

Numbers of Wells in Project at Year End 2008

CBI?

 Yes B3-11. Total actively producing (water or gas) in 2008. (Note this should match number reported in 

Table A-2.). 

Vertical 

Horizontal 

Vertical 

Horizontal 

VeHo

CBI?

 Yes B3-12. Total approved drilling permits considered applicable to this project in 2008. Vertical Horizontal Vertical Horizontal Ve

Ho

CBI?

 Yes B3-13. Spudded, drilling, or completed (production pending) in 2008. Vertical Horizontal Vertical Horizontal Ve

Ho

CBI?

 Yes B3-14. Inactive (shut in, temporarily abandoned, or other non-productive status, e.g., permanently 

abandoned, during all of 2008). 

Vertical 

Horizontal 

Vertical 

Horizontal 

VeHo

Basic Historic Information

CBI?

 Yes B3-15. Did you initiate development for this project or did you acquire a project that another operator 

developed? If you initiated development, enter the year in which you acquired the first lease. If you acquired all or part of an existing project, enter the year in which you acquired the project. For the purpose of this questionnaire, any projects or portions of projects acquired from another operator after lease acquisition but before development are considered part of the lease acquisition process. However, if you acquired any projects or portions of projects after initiating development of the first lease to create a larger project, complete both the “first lease acquired” and “acquired project” dates. 

First Lease Acquired 

Acquired Project (if you answer here, skip to Page B-2). 

First Lease Acquired 

Acquired Project (if you answer here, skip to Page B-2). 

FirAcanB-

CBI?

 Yes B3-16. Did you answer the “first lease acquired ” question with any answer that was earlier than 

2004 OR did you answer the “project acquired” question? 

 Yes. Skip to Page B-2.  No. Continue with 

Question B3-17. 

 Yes. Skip to Page B-2. No. Continue with 

Question B3-17. 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-13

STOP BEFORE PROCEEDING! 

Please review Part C of this questionnaire before beginniremainder of Part B. Part C covers all costs of produced wmanagement after final gas/water separation. Exclude all produced water management costs in Part B Section 3 of questionnaire. 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-14

Table B-2 requests additional historic information on your projects. Note that good faith estimates are acceptable, including where information is difficult to quantify. You may note if you have provided an estimate, where applicable, in the box to the 

Instructions: If you indicated this project began prior to 2004, or if you acquired any portion of the project after developmelease acquisition), skip to Page B-2. Otherwise, provide information for Questions B3-17 through B3-44 on project costs a

you initiated as of January 2004 or later that you have operated continuously since that time (i.e., you did not acquirin any stage of development beyond lease acquisition). Report dollar amounts in nearest thousands of dollars where indicadevelopment costs were $1,253,779, please report as $1,254,000; zeroes have been provided already). Note: if you have 

working interest, provide the financial information for the entire project, not just your share. Remember to exclude all produced water management costs covered in Part C from Table B-2. One term that EPA uses in this table is unusual expenditures. There might be two types of unusual expenditures—those th

capitalized) and those that are expensed (i.e., generally considered a part of O&M but the expenditure does not occur in ev

large percentage of O&M). For the purposes of this survey, an unusual expenditure is defined as: 

1) An expenditure that does not occur every year and that is more than 10 percent of O&M (e.g., major storm 

outlay for repairs); or 

2) A capitalized one-time or capital cost not considered a lease acquisition or development cost (e.g. construc

building not directly associated with production) and is not a cost covered in Part C. 

If you are uncertain of which cost category any of your expenditures belong, you can provide the expenditure(s) wcomments section, or you can contact the EPA help line.[Note: Please make additional copies of Table B-2 if Part A contains more than 3 projects]. 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-15

Table B-2. Project History [Please enter the project name from Part A in the first table row

Question Project Project P

General Questions 

CBI?

 Yes 

 Est.? 

 Yes 

B3-17. Between January 1, 2004 and December 31, 

2008 (2004-2008), did you do any exploratory 

drilling for CBM in the basin in which this project is located (including for this project, if applicable)? 

 Yes. Continue with 

Question B3-18. 

 No. Skip to Question 

B3-20.

 Yes. Continue with 

Question B3-18. 

 No. Skip to Question 

B3-20.

CBI?

 Yes 

 Est.? 

 Yes

B3-18. In this basin, between 2004 and 2008, what 

was your average exploratory well success rate for CBM (% of exploratory wells that result in a project that produces or is expected to produce commercial gas)? (including for this project, if applicable)? (%) 

 % % 

CBI?

 Yes 

 Est.? 

 Yes

B3-19. Between 2004 and 2008, what was your 

average cost per well to drill exploratory wells in this basin (including for this project, if applicable)? 

$ , ,000 $ , ,000 

Lease Acquisition Costs

CBI?

 Yes 

 Est.? 

 Yes

B3-20. Sum of lease acquisition amounts, 2004-2008. 

Include legal and administrative costs but exclude lump sum payments or cost of amenities provided to surface owners. ($000) 

$ , ,000 $ , ,000 

CBI?

 Yes 

 Est.? 

 Yes

B3-21. Year(s) of lease(s) acquisition (e.g., 2004, 

2005). 

CBI?

 Yes 

 Est.? 

 Yes

B3-22. Total lump sum (2004-2008) payments 

associated with securing the leases other than those to mineral rights owners, such as those to surface owner(s) (all leases). Also include total costs incurred to provide surface owners with amenities in lieu of lump sum payments. Do not include royalties, rents, or other recurring payments. ($000) 

$ , ,000 $ , ,000 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-16

Question Project Project P

Lease Development Costs

CBI?

 Yes 

 Est.? 

 Yes 

B3-23. Total one-time outlays on project development

through December 31, 2007 Include all planning, geological and geophysical costs, and any site development costs not included as drilling costs (see definition of well drilling costs in Appendix D). Exclude all permit costs, drilling costs (as defined in Appendix D), stimulations, recompletions, and any costs for water management systems included in Part C). Note: 2008 data is requested later. ($000). 

$ , ,000 $ , ,000 

CBI?

 Yes 

 Est.? 

 Yes 

B3-24. Total costs of all well drilling through December 

31, 2007 (through tophole equipment, e.g., Christmas tree); see definition of drilling costs in Appendix D ($000). Do not include recompletions. Note: 2008 data is requested later. 

$ , ,000 $ , ,000 

CBI?

 Yes 

 Est.? 

 Yes 

B3-25. Total costs of permit application fees and 

associated costs to prepare permit applications (e.g., one-time costs to perform permit-related studies, etc.) through end of 2007. (Do not include ongoing costs of monitoring, recordkeeping, and reporting or any costs related to produced water management permitting, e.g., NPDES or UIC permits, covered in Part C.) ($000) 

$ , ,000 $ , ,000 

Project Development Schedule

CBI?

 Yes 

 Est.? 

 Yes 

B3-26. Year site preparation work began (e.g., 2004). 

CBI?

 Yes 

 Est.? 

 Yes 

B3-27. Year drilling began. 

CBI?

 Yes 

 Est.? 

 Yes 

B3-28. Year water production began. 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-17

Question Project Project P

CBI?

 Yes 

 Est.? 

 Yes 

B3-29. Year CBM gas production began (do not 

include conventional gas or oil or other unconventional production, if applicable). 

CBI?

 Yes 

 Est.? 

 Yes 

B3-30. Year of peak water production (NA if water 

production has not yet peaked). 

CBI?

 Yes 

 Est.? 

 Yes 

B3-31. Water produced in peak year (bbls) (NA if 

water production has not yet peaked). bbls bbls 

CBI?

 Yes 

 Est.? 

 Yes 

B3-32. Year of peak gas production (CBM and 

conventional oil and gas or other unconventional production, if applicable) (NA if gas production has not yet peaked). 

CBI?

 Yes 

 Est.? 

 Yes 

B3-33. Gas produced in peak year (MMBtu) (CBM and 

conventional/other production, if applicable) (NA if gas production has not yet peaked). 

 MMBtu MMBtu 

Operating and Maintenance Costs of Project

CBI?

 Yes 

 Est.? 

 Yes 

B3-34. In 2004 through 2007, what were your O&M 

costs for this project by year? Include any regularly recurring costs, such as labor and energy costs, lease rental costs, annual 

payments to surface owners, or recurring costs associated with permits (e.g., monitoring, recordkeeping and reporting or other such payments) that are not related to produced water management. Exclude all costs of produced water management covered in Part C. Also exclude any costs of workovers, stimulations, recompletions, or other activities if these are considered unusual expenditures and reported in Questions B3-35 or B3-44 (see definition of unusual expenditures in the 

instructions to Table B-2 or in the Part D, Definition of Key Terms). If your project was not active in a year shown, please indicate with NA. ($000) 

2004: $ , ,000

2005: $ , ,0002006: $ , ,0002007: $ , ,000

2004: $ , ,000

2005: $ , ,0002006: $ , ,0002007: $ , ,000

20

202020
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-18

Question Project Project P

Other Expenditures Associated with Project

CBI?

 Yes 

 Est.? 

 Yes 

B3-35. What was the total cost of workovers, 

stimulations, and recompletions through year end 2007 ($000)? If not incurred, indicate 0. If any of these activities is considered routine O&M and was included in Question B3-34, indicate NA: 

 Workovers  Stimulations  Recompletions 

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

CBI?

 Yes 

 Est.? 

 Yes 

B3-36. Total number of such activities through year 

end 2007. If not incurred indicate 0. If any of these activities is considered routine O&M and was included in Question B3-34, indicate NA: 

 Workovers  Stimulations  Recompletions 

CBI?

 Yes 

 Est.? 

 Yes 

B3-37. Were any one-time outlays on unusual 

expenditures for amortized items incurred as of 

year end 2007 on this project that were not included in development or drilling costs (Questions B2-23 and B2-24) or in B3-35 as stimulations and recompletions? (See definition of unusual expenditures above in instructions 

to Table B-2.) 

 Yes. Continue with 

Question B3-38. 

 No. Skip to Question 

B3-41.

 Yes. Continue with 

Question B3-38. 

 No. Skip to Question 

B3-41.

CBI?

 Yes 

 Est.? 

 Yes 

B3-38. If you incurred unusual expenditures that were 

amortized, what were they for? If more space is needed, please use the comments page at the end of this section. 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-19

Question Project Project P

CBI?

 Yes 

 Est.? 

 Yes

B3-39. When did these unusual expenditures that 

were amortized occur (Year, e.g., 2004)? If more space is needed, please use the comments page at the end of this section. 

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

CBI?

 Yes 

 Est.? 

 Yes 

B3-40. What was your one-time total outlay on these 

unusual expenditure amortized items? ($000) If 

more space is needed, please use the comments page at the end of this section. 

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

CBI?

 Yes 

 Est.? 

 Yes

B3-41. Were any other unusual expenditures for O&M 

incurred as of year end 2007 on this project that you excluded in Question B3-34 (O&M costs) but did not include in Question B3-35 (workovers, stimulations, recompletions)? Do not include produced water costs reported in Part C. See definition of unusual expenditures

in instructions to Table B-2. 

 Yes. Continue with 

Question B3-42. 

 No. Skip to Page B-2.

 Yes. Continue with 

Question B3-42. 

 No. Skip to Page B-2.

CBI?

 Yes 

 Est.? 

 Yes

B3-42. If you incurred unusual expenditures for O&M 

costs, what were they for? If more space is needed, please use the comments page at the end of this section. 

CBI?

 Yes 

 Est.? 

 Yes

B3-43. When did these unusual expenditures for O&M 

occur (Year, e.g., 2004)? If more space is needed, please use the comments page at the end of this section. 

CBI?

 Yes 

 Est.? 

 Yes 

B3-44. How much did these unusual expenditures for 

O&M cost? ($000) If more space is needed, please use the comments page at the end of this section. 

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-20

Table B-3 requests information about your project in 2008. Note that good faith estimates, including averages or typicais difficult to quantify are acceptable. Please note if you have provided an estimate, where applicable, in the box to the far l

Instructions: Respond to questions for all projects, regardless of when the project began development or when you acqu

large dollar amounts in nearest thousands of dollars where indicated (i.e., if fixed operating costs were $1,253,779, please 

zeroes have been provided already). Note: if you have less than 100 percent working interest, provide the financial in

project, not just your share. Remember to exclude all produced water management costs covered in Part C from Table B-3. One term that EPA uses in this table is unusual expenditures. There might be two types of unusual expenditures—those th

capitalized) and those that are expensed (i.e., generally considered a part of O&M but the expenditure does not occur in evlarge percentage of O&M). For the purposes of this survey, an unusual expenditure is defined as: 

1) An expenditure that does not occur every year and that is more than 10 percent of O&M (e.g., major storm 

outlay for repairs); or 

2) A capitalized one-time or capital cost not considered a lease acquisition or development cost (e.g., constru

a building not directly associated with production) and is not a cost covered in Part C. 

If you are uncertain of which cost category any of your expenditures belong, you can provide the expenditure(s) wcomments section, or you can contact the EPA help line.[Note: Please make additional copies of Table B-3 if Part A contains more than 3 projects]. 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-21

Table B-3. Current (2008) Operations at Your Projects [Please enter the project name from Part A in the 

Question Project Project P

General Information 

CBI?

 Yes 

 Est.? 

 Yes 

B3-45. If this is a single lease project, indicate type of 

lease (fee, federal, state, tribal, other) and skip 

to Question B3-47. Otherwise indicate NA and answer B3-46. 

CBI?

 Yes 

 Est.? 

 Yes 

B3-46. If this is a unit or multi-lease project, list the 

number of each type of lease. 

 Fee  Federal  State  Tribal  Other 

 Fee  Federal  State  Tribal  Other 

2008 Drilling Expenditures 

CBI?

 Yes 

 Est.? 

 Yes 

B3-47. What was the total cost of all well drilling in this 

project in 2008 (excluding recompletions)? See definition of drilling cost in Appendix D. ($000) 

$ , ,000 $ , ,000 

CBI?

 Yes 

 Est.? 

 Yes 

B3-48. What was the total number of all wells drilled in 

this project in 2008 (excluding recompletions)? 

2008 Project Development Costs 

CBI?

 Yes 

 Est.? 

 Yes 

B3-49. What was the total outlay on all activities 

related to project development in 2008? Exclude drilling costs, stimulation costs and any produced water management costs that are reported in Part C. Also exclude any lease acquisition costs if included in Table B-2. ($000) 

$ , ,000 $ , ,000 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-22

Question Project Project P

2008 Operating and Maintenance Costs of Project 

CBI?

 Yes 

 Est.? 

 Yes 

B3-50. What were your 2008 total operating and 

maintenance costs of gas production? Include any regularly recurring costs, such as labor and energy costs, lease rental costs, annual payments to surface owners, or recurring costs associated with permits (e.g., monitoring, recordkeeping and reporting or other such payments) that are not related to produced water management. Exclude all costs of produced water management covered in Part C. Also exclude any costs of workovers, stimulations, recompletions, or other activities if these are considered unusual expenditures and reported in Questions B3-52 or B3-58 (see definition of unusual expenditures in the 

instructions to Table B-3 or in the Part D, Definition of Key Terms). ($000). 

$ , ,000 $ , ,000 

CBI?

 Yes 

 Est.? 

 Yes 

B3-51. In 2008, please estimate the percentage of 

O&M costs that would have been incurred had the project been temporarily shut in throughout the year. This factor should account for any labor to check on equipment, any annual payments to surface owners, leasehold payments, permit costs not related to produced water management or other expenditures that might occur regardless of production. EPA will 

assume this percentage is 5 percent of total 2008 O&M unless you specify otherwise. 

 We estimate %  We accept the 5% 

estimate 

 We estimate % We accept the 5% 

estimate 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-23

Question Project Project P

Other Expenditures Associated with Project 

CBI?

 Yes 

 Est.? 

 Yes 

B3-52. What was the total cost of workovers, 

stimulations, and recompletions in 2008 ($000)? If not incurred, indicate 0. If any of these activities is considered routine O&M and was included in Question B3-50, indicate NA: 

 Workovers  Stimulations  Recompletions 

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

CBI?

 Yes 

 Est.? 

 Yes 

B3-53. Were any one-time outlays on unusual 

expenditures for amortized items incurred on this project in 2008 that were not included in development or drilling costs (Questions B3-47 or B3-49) or in Question B3-52 under stimulations or recompletions? (See definition of unusual expenditures in instructions to Table B-3.) Exclude any costs for produced water management that are included in Part C. 

 Yes. Continue with 

Question B3-54. 

 No. Skip to Question 

B3-56.

 Yes. Continue with 

Question B3-54. 

 No. Skip to Question 

B3-56.

CBI?

 Yes 

 Est.? 

 Yes 

B3-54. If you incurred unusual expenditures for 

amortized items, what were they for? If more space is needed, please use the comments page at the end of this section. 

CBI?

 Yes 

 Est.? 

 Yes 

B3-55. What was the total one-time outlay on these 

unusual expenditure amortized items? ($000) If more space is needed, please use the comments page at the end of this section. 

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-24

Question Project Project P

CBI?

 Yes 

 Est.? 

 Yes 

B3-56. Were any other unusual expenditures for O&M 

incurred on this project as of year end 2008 on this project that you excluded in Question B3-50 (O&M costs) but did not include in Question B3-52 (workovers, stimulations, recompletions)? Do not include produced water costs reported in Part C. See definition of unusual expenditures in instructions to Table B-3. 

 Yes. Continue with 

Question B3-57. 

 No. Skip to Question 

B3-59.

 Yes. Continue with 

Question B3-57. 

 No. Skip to Question 

B3-59.

CBI?

 Yes 

 Est.? 

 Yes 

B3-57. If you incurred unusual expenditures for O&M, 

what were they for? If more space is needed, please use the comments page at the end of this section. 

CBI?

 Yes 

 Est.? 

 Yes 

B3-58. How much did these unusual expenditures for 

O&M cost? ($000) If more space is needed, please use the comments page at the end of this section. 

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

2008 Production, Royalties, and Taxes 

CBI?

 Yes 

 Est.? 

 Yes 

B3-59. What was the total gas production from this 

project in 2008? (MMBtu) MMBtu MMBtu 

CBI?

 Yes 

 Est.? 

 Yes 

B3-60. What was the total gas sold from this project in 

2008? (MMBtu) MMBtu MMBtu 

CBI?

 Yes 

 Est.? 

 Yes 

B3-61. What was the total gas used by this project in 

2008? (MMBtu) MMBtu MMBtu 

CBI?

 Yes 

 Est.? 

 Yes 

B3-62. What was the minimum, average, and 

maximum wellhead price received for sold gas for this project in 2008? ($.$$/MMBtu) 

$ min 

$ average 

$ max 

$ min 

$ average 

$ max 

$ 

$ 

$ 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-25

Question Project Project P

CBI?

 Yes 

 Est.? 

 Yes 

B3-63. What was this project’s total water production 

in 2008? (Provide estimate if this was not measured.) (bbls) 

 bbls bbls 

CBI?

 Yes 

 Est.? 

 Yes 

B3-64. What was your average working interest share 

for this project in 2008? (%) % % 

CBI?

 Yes 

 Est.? 

 Yes 

B3-65. What was the average gas royalty rate for this 

project in 2008 (among all parties over all leases, including surface owner if relevant)? (%) 

 % % 

CBI?

 Yes 

 Est.? 

 Yes 

B3-66. What were the total severance taxes from this 

project in 2008? (% or $000) % 

$ , ,000

 % 

$ , ,000

CBI?

 Yes 

 Est.? 

 Yes 

B3-67. Were there any other taxes such as ad 

valorem or production shares associated with this project? Provide dollar amount and/or percent and describe: 

 % 

$ , ,000

 % 

$ , ,000

Reserves Information 

CBI?

 Yes 

 Est.? 

 Yes 

B3-68. Do you report reserves information to SEC or 

to DOE using the EIA Form 23 survey? 

 Yes. Continue with 

Question B3-69. 

 No. Skip to Question 

B3-71.

 Yes. Continue with 

Question B3-69. 

 No. Skip to Question 

B3-71.

CBI?

 Yes 

 Est.? 

 Yes 

B3-69. What is the estimated remaining proved 

reserves associated with this project as of December 31, 2008? (Prorate field estimates to project, where necessary, and specify units used and estimation method.) 

 Specify units (e.g., MMcf):  Estimation Method: 

 SEC Definition of Proved Reserves  Other: 

CBI?

 Yes 

 Est.? 

 Yes 

B3-70. What discount rate and wellhead price was 

used for this proved reserve estimate? 

$ 

at % 

$ 

at %

$ 

at 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-26

Question Project Project P

CBI?

 Yes 

 Est.? 

 Yes 

B3-71. If available, what is the estimated remaining 

technically recoverable reserves (year end 2008)? (Prorate field estimates to project, where necessary, and specify units used, e.g. MMcf.) Indicate NA if you do not compute technically recoverable reserves. 

 Specify units (e.g., MMcf): 

CBI?

 Yes 

 Est.? 

 Yes 

B3-72. If available, what is the projected remaining 

productive life of this project in the technically recoverable reserves estimate? (years) 

 years years 

CBI?

 Yes 

 Est.? 

 Yes 

B3-73. What was the cumulative gas production at 

2008 year end for this project? 

 Specify units (e.g., MMBtu): 

CBI?

 Yes 

 Est.? 

 Yes 

B3-74. What was the cumulative water production at 

2008 year end for this project (estimate if not measured)? 

 Specify units (e.g., thousand bbls): 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions CBM Questionnaire 

Operator ID: 

B-27

Questions for Project ID [Please provide a copy of Questions B3-75 through B3-102 for each project listed in Part A.] 

FUTURE COSTS AND REVENUES 

Instructions: EPA will need to project costs and revenues of this project over the next 10 years. EPA 

acknowledges that projections beyond 5 years are very uncertain and will project information beyond the 5 

year horizon, unless respondents prefer to provide those estimates themselves. You have several options for 

providing projection information: 

1) Provide your own estimate of costs and revenues at the project over the next 5 years or 

through the end of your planning horizon (at least 3 years, including 2009, 2010, and 2011) in 

Table B-4; 

2) Accept certain assumptions EPA would plan to make in lieu of using your projections; 

3) Provide your 5-year projection in Table B-4 plus an additional 5-year projection beyond the 

fifth year, which you can attach to the questionnaire separately; 

4) Use a combination of any of these. 

For respondents choosing not to do their own projections or choosing only to project certain information, EPA 

will rely on state information on production for the wells in your project to determine a production profile, 

where possible, information provided by other respondents to this questionnaire, and/or best professional 

judgment. For any item you feel that EPA’s assumptions will not work for your project, you can fill out those 

items in the 5-year projection table (or provide a 10-year projection, if you choose) for any of Questions B3-87 

to B3-102 in Table B-4. Please check which overall option you have chosen and follow the instructions 

associated with the options you have selected. 

B3-75. Please indicate how you would like to handle projections of project data requested in the remainder of 

this questionnaire. Check any that apply. 

 We request EPA make some or all of these projections based on the information provided 

below in Questions B3-76 through B3-86 for any items for which we have not provided a 

projection for in Table B-4. Instructions: Please complete Questions B3-76 through B3-86 

for this project. You do not have to complete Table B-4, which asks for up to 5 years of yearby-year projections, unless you have opted out of certain assumptions and have chosen to 

provide a projection for one or more line items. 

 We will be skipping Questions B3-76 through B3-86 and will provide year-by-year projection 

data for three to five years in Table B-4. Instructions: Please fill out Table B-4 for as many 

years as you have in your planning horizon. EPA is requesting your best judgment on these 

projections; the Agency is aware that projections are not certain. If the number of years 

requested exceeds your planning horizon, please indicate with NA in any remaining years. 

You may provide projections that include an assumption for inflation but provide that 

assumption in Question B3-102. 

 We have attached additional projections out to 10 years for some or all of the information 

shown in Table B-4 to this questionnaire. If your projections include an assumption for 

inflation, make sure to show that assumption explicitly in your attachments. 

CBI?

 Yes
Part B. Financial and Economic Information 

Section 3: Project-Level Questions CBM Questionnaire 

Operator ID: 

Project ID: 

B-28

Instructions: EPA will make projections from 2008 or beyond your planning horizon (as shown in your 

responses to Table B-4) based on your answers to the following questions, your reported 2008 data, and any 

information provided in Table B-4. Please provide information to the extent possible without considering the 

effects of inflation. If this is not possible, please note the inflation rate inherent in your answers in Question 

B3-102. If you have provided some projections in Table B-4, EPA will assume further projections based on 

your answers to the following questions and/or either your last year’s reported values in Table B-4 or the 

patterns seen in the projections provided (assuming at least 3 years’ projections have been provided). For 

any of the Questions B3-76 through B3-86 that have not been answered and for which alternative information 

has not been provided in Table B-4 or attached to this questionnaire, EPA will assume you have agreed to 

EPA’s approach. 

For the few projects where conventional oil is also produced, EPA will make the oil production projections and 

price projections, unless you provide oil production curves and/or other information with your questionnaire. 

B3-76. Please provide the numbers of wells you plan to drill in this project over the next 5 years by year. If 

any years are beyond your planning horizon, please indicate with “NA.” 

2008 2011 

2009 2012 

2010 

B3-77. In what year do you estimate drilling will be completed for this project, based on your current plans 

(and barring any changes in regulations, changes in your assumptions about future gas prices, etc.) 

 

B3-78. EPA will use estimated costs of drilling based on data collected in this questionnaire of the CBM 

industry, publicly available information, and best engineering judgments as specific to your basin as 

possible to project drilling costs over 10 years. EPA will also assume drilling costs per well will not 

change by more than ordinary inflation (estimated as a function of the recent historic Producer Price 

Index for the oil and gas extraction industry) over the 10-year period (check any that apply): 

 We agree to this approach. 

 We would like EPA to use the following average cost per well for drilling: 

 $ per well ($2008) 

 We would prefer EPA to consider the following factor incremental to inflation to represent 

drilling cost increases greater than inflation over time at our project: 

 $ % per year 

B3-79. At this point in time, using your current assumptions about wellhead prices, how much longer would 

you expect this project to produce economically? 

 We shut in this project in 2008. 

 We shut in this project in 2009 or we plan to shut in this project in 2009. 

 From one to 3 years. 

 More than 3 years but less than or equal to 5 years. 

 More than 5 years but less than or equal to 8 years. 

 More than 8 years but less than or equal to 10 years. 

 More than 10 years. 

 Unknown. 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 3: Project-Level Questions CBM Questionnaire 

Operator ID: 

Project ID: 

B-29

B3-80. EPA will use gas production data found in state reported production data to create gas production 

profiles for this project. Note that EPA has little to no historic gas production information from Indiana 

and Illinois and very dated information from Pennsylvania, so production curves from operators in 

these states would be especially appreciated. If historic gas production data for this project are not 

publicly available, or if your project is too new to provide much information to create a production 

profile, EPA will use information that might be generated by this questionnaire considered likely to be 

most representative of your project, general information on gas production profiles from the state or 

other published sources, and, if necessary, professional judgment or information from other, similar 

basins (if relevant) to create the gas production profile from this project. 

 We agree to this approach. 

 We have attached a gas production curve for this project. 

 We have attached a gas production curve for a typical well in this project. 

 We have projected our gas volumes for this project in Table B-4. 

 Other approach (provide information in comments section). 

B3-81. EPA will use water production data found in state reported production data to create produced water 

production profiles for this project. Note that EPA does not have any well-specific or lease-specific 

produced water production information from state agencies in the following states: Arkansas, Kansas, 

Illinois, Indiana, Ohio, Oklahoma, and West Virginia. Also, if water reporting is voluntary and you do 

not report water to your state agency, EPA will not have this information. Production curves, or any 

other production data, from operators in states where production data might be missing would be 

especially appreciated If historic water production data for this project are not publicly available, or if 

your project is too new to provide much information to create a production profile, EPA will use 

information that might be generated by this questionnaire considered likely to be most representative 

of your project, general information on water production profiles from the state or other published 

sources, and, if necessary, professional judgment or information from other states in the same or 

similar basins (if relevant) to create the water production profile from this project. 

 We agree to this approach. 

 We have attached a water production curve for this project. 

 We have attached a water production curve for a typical well in this project. 

 We have projected our water volumes for this project in Table B-4. 

 Other approach (provide information in comments section). 

B3-82. EPA will use frequency of workovers, stimulations, and recompletions based on data collected in this 

questionnaire of the CBM industry, publicly available information, and best engineering judgments as 

specific to your basin as possible to project such activities in EPA’s 10-year projection: 

 We agree to this approach. 

 We prefer to provide EPA with workover frequencies specific to our project. On average, a 

well in this project is worked over: 

 time(s) per 10-year period (note that fractions are acceptable). 

 We prefer to provide EPA with stimulation frequencies specific to our project. On average, a 

well in this project is stimulated: 

 time(s) per 10-year period (note that fractions are acceptable). 

 We prefer to provide EPA with recompletion frequencies specific to our project. On average, 

a well is recompleted: 

 time(s) per 10-year period (note that fractions are acceptable). 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 3: Project-Level Questions CBM Questionnaire 

Operator ID: 

Project ID: 

B-30

B3-83. EPA will use estimated costs of workovers, stimulations, and recompletions based on data collected 

in this questionnaire of the CBM industry, publicly available information, and best engineering 

judgments as specific to your basin as possible to project costs of such activities in EPA’s 10-year 

projection: 

 We agree to this approach. 

 We prefer to provide EPA with workover costs specific to our project. 

Average workover cost per well ($2008): $ 

 We prefer to provide EPA with stimulation costs specific to our project. 

Average stimulation cost per well ($2008): $ 

 We prefer to provide EPA with recompletion costs specific to our project. 

Average recompletion cost per well ($2008): $ 

B3-84. EPA will use the range and average well head prices reported for your project, along with similar 

information from other projects in the vicinity of your project, DOE projections of wellhead prices from 

the current EIA’s Annual Energy Outlook, historic gas prices at Henry Hub, and other publicly 

available information to project wellhead gas price over the next 10 years at your project. EPA will 

take into account basin-specific infrastructure projections, well drilling projections, and other 

information to identify trends in future basin differentials. Sensitivity analyses will also be run using 

low and high wellhead prices based on DOE’s low and high wellhead price projections. 

 We agree to this approach. 

 We have provided a projection of wellhead price in Table B-4. 

 We have provided additional information in comments that we think should be used in 

computing this project’s projected wellhead price. 

B3-85. Using the percentage provided in Question B3-51 to split 2008 O&M costs (excluding produced water 

management costs) between fixed and variable costs, EPA will assume your existing variable O&M 

costs for this project (estimated on a per MMBtu basis) and your existing fixed costs (estimated on a 

per-year basis) will not vary over the 10-year projection, assuming no inflation. 

 We agree to this approach. 

 We have provided a projection of O&M costs for this project (excluding produced water 

management) in Table B-4. 

 We have provided additional information in comments that we think should be used in 

computing this project’s projected O&M costs for this project. 

B3-86. Please use the space below to add any additional comments you think might be useful to EPA in 

understanding what issues might affect costs in the next few years, particularly changes to state 

regulations that may be pending, competition for drilling rigs, changes in infrastructure availability, 

changes to royalty rates or severance, etc. 

 

 

 

 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-31

If you will not be continuing with Table B-4, please proceed to Part C of this questionnaire. Note: you do not need to indicatTable B-4 are estimates; EPA will assume all entries are estimates and acknowledges that such estimates are speculative. 

Report large dollar amounts in nearest thousands of dollars where indicated (i.e., if additional capital expenditures are expe

please report as $1,254,000; zeroes have been provided already). If you are providing information on a project that also pr

wish to provide projections of oil production and oil prices, please do so in an attachment or in the comments section in Qu

Remember to exclude all produced water management costs covered in Part C from Table B-4. One term that EPA uses in this table is unusual expenditures. There might be two types of unusual expenditures—those th

capitalized) and those that are expensed (i.e., generally considered a part of O&M but the expenditure does not occur in evlarge percentage of O&M). For the purposes of this survey, an unusual expenditure is defined as:  1) An expenditure that does not occur every year and that is more than 10 percent of O&M (e.g., major storm 

outlay for repairs); or 

 2) A capitalized one-time or capital cost not considered a lease acquisition or development cost (e.g. construc

building not directly associated with production) and is not a cost covered in Part C. 

If you are uncertain of which cost category any of your expenditures belong, you can provide the expenditure(s) w

comments section, or you can contact the EPA help line.
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-32

Table B-4. Projections of Costs and Production over 5 Years 

Question 2009 20010 2011 2012 

CBI?

 Yes B3-87. What do you estimate your total operating and 

maintenance costs of gas production will be in 2009-2013? Include any regularly recurring costs, such as labor and energy costs, lease rental costs, annual payments to surface owners, or recurring costs associated with permits (e.g., monitoring, recordkeeping and reporting or other such payments) that are not related to produced water management. Exclude all costs of produced water management covered in Part C. Also exclude any costs of workovers, stimulations, recompletions, or other activities if these are considered unusual expenditures and reported in 

Questions B3-91 or B3-96 (see definition of unusual expenditures in the instructions 

to Table B-4 or in the Part D, Definition of Key Terms). ($000).

$ , ,000 $ , ,000 $ , ,000 $ , 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-33

Question 2009 20010 2011 2012 

Drilling Expenditure Schedule

CBI?

 Yes

B3-88. Estimated number of wells 

drilled annually (excluding recompletions). 

CBI?

 Yes B3-89. Estimated total drilling costs incurred, excluding 

recompletions, by year. (See definition of drilling costs in Appendix D.) ($000). 

$ , ,000 $ , ,000 $ , ,000 $ , 

Additional Expenditures

CBI?

 Yes

B3-90. Estimated number of the 

following activities: (if not expected to occur indicate 0. If any of these activities is considered routine O&M and was included in Question B3-87 indicate “NA”): 

 Workovers  Stimulations  Recompletions 

CBI?

 Yes B3-91. Estimated total cost ($000) of the following activities in each 

year (if not expected to occur indicate 0. If any of these activities is considered routine O&M and was included in Question B3-87 indicate “NA”):

 Workovers  Stimulations  Recompletions 

$ , ,000

$ , ,000$ , ,000

$ , ,000$ , ,000$ , ,000

$ , ,000$ , ,000$ , ,000

$ , $ , $ , 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-34

Question 2009 20010 2011 2012 

CBI?

 Yes B3-92. Estimated additional project development expenditures 

incurred (excluding well drilling costs, costs reported in Question B3-91, and produced water gathering and management costs), by year ($000). 

$ , ,000 $ , ,000 $ , ,000 $ , 

CBI?

 Yes B3-93. Estimated new permit or permit renewal costs 

(excluding produced water management related permits, such as NPDES and UIC permits). 

$ , ,000 $ , ,000 $ , ,000 $ , 

CBI?

 Yes B3-94. Total one-time outlays on unusual expenditures for 

amortized items in each year that are not included as development or drilling costs in Questions B3-89 or B3-92 or included as stimulation or recompletion costs in Question B3-91. (See definition of unusual expenditures above in instructions to Table B-4). Exclude those costs that are associated with produced water management as covered in Part C. If more space is 

needed, please use the comments page at the end of this section. 

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

$ , 

$ , $ , 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-35

Question 2009 20010 2011 2012 

CBI?

 Yes B3-95. Description of unusual expenditures on amortized 

items included in B3-94 above. If more space is needed, please use the comments page at the end of this section.

CBI?

 Yes B3-96. Other unusual expenditures for O&M not included in Question 

B3-87 (O&M costs) or in Question B3-91 (workovers, stimulations, recompletions) (See definition of unusual expenditures above in instructions to Table B-4). Exclude those costs that are associated with produced water management as covered in Part C. If more space is 

needed, please use the comments page at the end of this section. 

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

$ , ,000

$ , ,000$ , ,000

$ , 

$ , $ , 

CBI?

 Yes B3-97. Description of unusual expenditures included in B3-96 

above. If more space is needed, please use the comments page at the end of this section. 

Production Schedule

CBI?

 Yes B3-98. What is your projection of gas production at this project? 

(MMBtu/yr) 

$ MMBtu $ MMBtu $ MMBtu $ 

CBI?

 Yes B3-99. What is your projection of water production at this 

project? (bbls/yr) 

$ bbls $ bbls $ bbls $ 
Part B. Financial and Economic Information 

Section 3: Project-Level Questions 

B-36

Question 2009 20010 2011 2012 

CBI?

 Yes B3-100. What wellhead price of gas have you used to project gas 

production? ($.$$/MMBtu) 

$ MMBtu $ MMBtu $ MMBtu $ 

CBI?

 Yes B3-101. What is your projection of severance and other 

production taxes? ($000) 

$ , ,000 $ , ,000 $ , ,000 $ , 

CBI?

 Yes B3-102. What inflation rate are you using in these projections 

(including expenditure projections)? If using more than one inflator for different cost items, use the comments section to specify (%). 
Part B. Financial and Economic Information CBM Questionnaire 

Operator ID: 

B-37

Copy of 

B3-103. Comments on Part B. Please cross-reference your comments by question number. If you need 

additional space, please photocopy this page before writing on it, and number each copy in the 

space provided. 

Question 

Number Comment 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 

CBI?

 Yes 
Part C. Produced Water Management Information CBM Questionnaire 

Operator ID: 

C-1

PART C. PRODUCED WATER MANAGEMENT INFORMATION 

INSTRUCTIONS FOR PART C (Technical Portion of Questionnaire)

Read all question-specific instructions and definitions of key terms (Part D). 

Data may be submitted as clearly marked electronic attachments to this questionnaire.

Complete this part of the questionnaire for only the projects listed in Part A. 

You may need to make copies of some PAGES before responding. Some pages in Part C of the 

questionnaire will need to be photocopied before you respond. Indicate how many copies of the PAGE you 

are submitting by completing the entry “Copy ___ of ___” in the top right corner. 

Not all questions will be applicable to every operator. EPA prepared Part C of the questionnaire to be 

applicable to a variety of operators; therefore, not all of the questions will apply to every operator. Complete 

each relevant item in the questionnaire. 

Mark responses for each question. Fill in the appropriate response(s) to each question. Please use black 

ink or type in the spaces provided. Answer the questions in sequence unless you are directed to SKIP. Do 

not leave any entry blank. If the answer is zero, write “0" or “zero”. If a question is not applicable to your 

operations, write “NA.” EPA intends that responses to all questions be based upon available data and 

information. Please provide best estimates when exact data are not available. If you provide an estimate, note 

the methods that were used to make the estimate, along with the section and question number that the 

estimate refers, on the Comments page at the end of Part C. 

You are not required to provide a block flow diagram for each Produced Water Management System in 

Section 2. A narrative description of the Produced Water Management System is sufficient. Examples of 

acceptable block flow diagrams and narrative descriptions are provided in Section 2. 

You are not required to perform new or non-routine tests or measurements solely for the purpose of 

responding to this questionnaire. EPA intends that responses to all questions be based upon available 

data and information. In the event that exact data are not available, please provide best engineering 

estimates and note the methods that were used to make the estimates on the Comments page located at the 

end of each section. 

Include any clarifying attachments. If additional attachments are required to clarify a response, please 

place the associated question number and your operator identification number in the top right corner of each 

page of the attachments. The following list contains examples of items that may be included as attachments 

to this questionnaire: 

 – Operations brochure, pamphlet, general description; 

 – Produced water treatment flow diagrams; 

 – Hard copy or electronic water quality data collected from water monitoring locations; 

 – Produced water treatment operation and maintenance logs; and 

 – Pollution prevention or management practices policies or data. 

Pay close attention to the measurement units requested (e.g., barrels per day, milligrams per liter). 

Report answers in the units that are specified, unless the question requires you to specify the units. 

Indicate information that should be treated as confidential. You may claim as confidential all information 

included in the response to a question by checking the Confidential Business Information (CBI) box next to 

the question number. Note that you may be required to justify any claim of confidentiality at a later time. See 

the CONFIDENTIAL BUSINESS INFORMATION section on page ii. 

Questions? If you have any questions regarding the completion of this questionnaire, see the 

QUESTIONNAIRE ASSISTANCE section on page ii. 
Part C. Produced Water Management Information 

Section 1: General Operator Information CBM Questionnaire 

Operator ID: 

C-2

SECTION 1: GENERAL OPERATOR INFORMATION 

GENERAL INSTRUCTIONS FOR SECTION 1 

This section of the questionnaire collects operator and company address and contact information. 

Indicate information that should be treated as confidential by checking the Confidential Business Information 

(CBI) box next to each question number with responses containing CBI. Any response where "CBI" is not 

checked will be considered non-confidential unless you have claimed all CBI-eligible data as CBI at the 

beginning of the questionnaire. Refer to the instructions given in the CONFIDENTIAL BUSINESS 

INFORMATION section on page ii for additional information regarding EPA's confidentiality procedures set 

forth in 40 CFR Part 2, Subpart B. 

C1-1. Provide the name, title, telephone and facsimile numbers, and e-mail address of the primary contact 

at your operation for information supplied in Part C of this questionnaire. 

 ( ) - 

Primary Contact Name Telephone Number 

 ( ) - 

Primary Contact Title Facsimile Number 

 Convenient time to call between: 

Email Address am / pm and 

 am / pm (Eastern Time) 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

Operator ID: 

C-3

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

SECTION 2: PRODUCED WATER MANAGEMENT SYSTEM GENERAL QUESTIONS 

GENERAL INSTRUCTIONS FOR PART C SECTION 2 

The following questions request general information on the components and costs of the produced water 

gathering system(s) and the Produced Water Management System(s) used for the project(s) listed in Part A. 

These data will be used to evaluate the costs and benefits of various CBM water management arrangements. 

Produced Water Management System (PWMS) - For the purposes of this questionnaire, Produced 

Water Management System is defined as a system that is managed by the operator as a single unit 

for produced water management. Produced water management may include different treatment, 

transfer to disposal locations, and/or reuse practices. The Produced Water Management System may 

treat water from a lease, field, project, or plan of development (POD). Water discharge permits, land 

application permits, and applications for permits to drill (APD) typically use one of these terms to 

define the well grouping. Note that the Produced Water Management System can have multiple 

disposal options but it is managed as a single unit. For example, an operator may use a combination 

of stock tanks, irrigation, and storage ponds on a single Produced Water Management System. Also 

note that the Produced Water Management System may serve the same or different wells from the 

CBM project defined in Part A. Finally, for the purposes of this questionnaire, the PWMS does not 

include the produced water gathering system (e.g., piping or trucking) that is used to transport the 

produced water between the CBM wellhead and a centralized location (e.g., treatment unit, land 

application site). For example, produced water gathering pipes are typically installed underground at 

the same time as the gas gathering pipes. 

The following diagrams are designed to help you determine the Produced Water Management Systems that 

should be addressed in this section of the questionnaire. Please complete a copy of this section for each 

Produced Water Management System used for the projects listed in Part A. Note that you are not required to 

provide a block flow diagram for each Produced Water Management System in response to Question C2-1. A 

narrative description of the Produced Water Management System is sufficient. Examples of acceptable block 

flow diagrams and narrative descriptions are provided on pages C-2 and C-2. 

In Example 1, the operator is using the same produced water management system for all wells in the CBM 

project listed in Part A. Therefore, there is a one-to-one match between the CBM economic project and 

Produced Water Management System. The operator should complete one copy of Part C Sections 2 and 3 for 

the Produced Water Management System. 
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

Operator ID: 

C-4

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

CBM Economic Project Matches Directly with the 

Produced Water Management System

X X X X X X X X X X

Economic Project

Produced Water Management System

X Well

Sedimentation

Pond

Discharge 

to River

Water Gathering 

System

Example 1. 

In Example 2, the operator is using the two Produced Water Management Systems for the wells included in 

the CBM economic project listed in Part A. The operator should complete two copies of Part C Section 2 and 

Part C Section 3, one for each produced water management system used as part of this economic project. 

PWMS #1

Settling pond

Land application

PWMS #2

Settling pond

Surface water

CBM Economic Project with 

Two Produced Water Management Systems

X X X X X X X X X X

Economic Project

Produced Water Management System

X Well

Water 

Gathering 

System

Example 2. 
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

Operator ID: 

C-5

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

In Example 3, the operator has two economic projects that share the same produced water management 

system. One of the economic projects, CBM Economic Project 1, was listed in Part A. The operator should 

have completed Part B, Section 3 for Economic Project 1. The operator did not need to provide information for 

Economic Project 2 because it was not listed in Part A. The operator should complete one copy of Part C for 

the combined produced water management system. In Example 3, the operator will identify the CBM wells 

and different produced water volumes managed by the PWMS from Project 1 and Project 2. 

Example 3.

For EACH Produced Water Management System you operated in 2008 to manage produced water from the 

wells listed in Part A, complete a copy of the entire Part C Section 2 and Section 3. You may need to make 

multiple copies of these sections. Please enter a Produced Water Management System number or name 

in the upper right-hand corner of this section. The number you choose could be one you use internally to 

refer to the project, but can be just a number such as 1, 2, 3, etc., if you use no formal identifier. This 

information will be used to check that the detailed information provided in this section is linked to the correct 

Produced Water Management System. 

Question C2-1 requests a block flow diagram or narrative description for each Produced Water Management 

System. EPA has provided examples to guide you in completing this question. 

Questions C2-2 through C2-14 request general information on the Produced Water Management System 

such as how the management system was selected and capital and operating costs. 

Questions C3-1 through C3-13 request discharge and treatment information for the Produced Water 

Management System. 

Question C4-3 requests water quality and whole effluent toxicity data. 

A comment page is included at the end of this section to clarify responses. 

Note that this section was designed to be applicable to a variety of operators. Many of the detailed questions 

are only applicable to discharge of produced water to surface waters, a POTW, or third party. Please follow 

the skip patterns noted throughout the section. 
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

Operator ID: 

C-6

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

EPA may contact you for additional detailed cost data for the information you provide in this section of the 

questionnaire. If you are unsure of how to complete any parts of this section, please refer to the 

QUESTIONNAIRE ASSISTANCE information on page ii. 

C2-1. For each Produced Water Management System (PWMS), please provide a block diagram (as in the 

following examples) that shows, or a narrative description that explains, how the produced water was 

managed from the CBM well field to the PWMS in 2008. Refer to this diagram or narrative as you 

answer questions throughout this section. Hand drawings are sufficient for this question. Please 

provide a Produced Water Management System identification number and name for each diagram. 

 Attached a block diagram. 

 Attached a narrative description. 

The following items should be included on your diagram or discussed in your narrative for each 

Produced Water Management System: 

 Name of the CBM Project in Part A that is connected to this PWMS. 

 Identify the water gathering system (e.g., underground pipes, trucking) that moves produced 

water from the CBM wellhead to the PWMS. 

 Name or identification number for this Produced Water Management System. This name or 

number should be noted in the upper right-hand corner of all pages in this section. 

 If more than one PWMS serves this project, number of producing wells (including those 

producing water only) associated with each PWMS. 

 Discharge, disposal, and reuse practices for this Produced Water Management System 

including the final destination of the produced water. 

 Individual treatment units prior to discharge, disposal, or reuse. Please show each individual 

unit on the diagram. For example, if you have two sedimentation ponds, please show each 

one on the diagram. 

 Points of chemical addition, along with the chemical name. 

 Descriptions of any waste streams resulting from CBM produced water treatment (e.g., 

concentrated brine, ion exchange regeneration wastewater, settled solids). 

 Destinations for all produced water. Please remember to include evaporation or infiltration. 

 The locations where routine water quality data are collected (you will be asked to provide 

some of this data in Part C Section 4). 

 Please note whether any produced water from conventional oil and gas extraction is 

commingled with produced water from this CBM project. Please indicate on the diagram or in 

your narrative description, the volumes or flow rates of the conventional oil and gas extraction 

produced water as well as the point at which these waters are commingled. 

 Please note whether any produced water from another CBM project (either yours or another 

operator’s) is commingled with produced water from this CBM project. If produced water from 

another project operated by your company enters this PWMS, provide the name of the 

project as provided in your screener survey. Please indicate on the diagram or in your 

narrative description, the volumes or flow rates of the CBM produced waters that are not from 

this CBM project as well as the point at which these waters are commingled. 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-7

Operator ID: 9999

Project ID from Part A: PRB1

Operator’s Name or ID for this Produced Water Management System: POD1

Example 4 illustrates a Produced Water Management System with only one management practice. In 

this example, you would complete one copy of this section for this Produced Water Management 

System. 

One Produced Water Management System for the CBM Project 

(Treatment and Discharge)

Concentrated Brine –

Contract Hauled

Outfall 001 

Discharge to River

Sedimentation/

Equalization Pond

8 Wells

2

Routine Sampling Point 1

Routine Sampling Point 2

6 Media Filters

2 RO Units

Blend Tank

1 Backwash

Economic Project: PRB 1

PWMS Name: POD1

Water Gathering System

Example 4. 

Example 5 is an example of a narrative description for a CBM project with only one PWMS. In this example, 

you would complete one copy of this section for this Produced Water Management System. 

Produced water from the eight CBM wells in the San Juan POD is piped underground 

to six storage tanks. Only water from the eight wells enters the storage tanks. The 

water is trucked from the storage tanks to one of two injection wells. The water is 

filtered and a biocide is added prior to re-injection. A sample of the water is tested 

prior to re-injection. 

Example 5. 
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

C-8

Operator ID: 9900

Project ID from Part A: Black Warrior 1

Operator’s Name or ID for this Produced Water Management System: Treatment System 1

Example 6 illustrates a Produced Water Management System with multiple produced water management 

practices that vary throughout the year. The dates during which each water management practice is in use 

are shown above that branch of the flow diagram. You should complete two copies of Part C Sections 2 and 3 

for this scenario, one for the west side and one for the east side. 

50 Wells

(West side of CBM Project)

Storage Tanks

Land Application

280 bpd

280 bpd

35 Wells (April-September)

(East side of CBM Project)

85 Wells (October-May)

Sedimentation 

Pond 1

200 bpd

Sludgecontract 

hauled

14 bpd Evaporation 2 bpd

Note: October-May flow in italics

Economic Project: Black Warrior 1

PWMS Name: Treatment System

Temporal Changes in Produced Water Collection and Management Practices

Discharge to River

1

2

May-October Only

480 bpd

4 bpd 20 bpd

Sedimentation 

Pond 2

Sludgecontract 

hauled

13 bpd 1 bpd Evaporation 5 bpd 1 bpd

Alum, Antimicrobial

3 170 bpd

450 bpd Routine Sampling Points

50 Wells

(West side of CBM Project)

Storage Tanks

Land Application

280 bpd

280 bpd

35 Wells (April-September)

(East side of CBM Project)

85 Wells (October-May)

Sedimentation 

Pond 1

200 bpd

Sludgecontract 

hauled

14 bpd Evaporation 2 bpd

Note: October-May flow in italics

Economic Project: Black Warrior 1

PWMS Name: Treatment System

Temporal Changes in Produced Water Collection and Management Practices

Discharge to River

1

2

May-October Only

480 bpd

4 bpd 20 bpd

Sedimentation 

Pond 2

Sludgecontract 

hauled

13 bpd 1 bpd Evaporation 5 bpd 1 bpd

Alum, Antimicrobial

3 170 bpd

450 bpd Routine Sampling Points

Water Gathering System

Example 6. 
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

Operator ID: 

C-9

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

C2-2. In what year did this Produced Water Management System (PWMS) begin operating? 

Number of days in operation in 2008: 

 365 days; or 

 days 

C2-3. What was the average daily flowrate or total volume of water treated by this Produced Water 

Management System in 2008? Please check whether you are providing average daily flowrate or 

total volume and provide the flowrate or volume and units. 

a. Generated by the wells identified in Part A in 2008 

 Average Daily Flowrate 

 Total Volume 

 Please specify the flowrate or volume units: 

b. Managed by this PWMS in 2008 

 Average Daily Flowrate 

 Total Volume 

 Please specify the flowrate or volume units: 

C2-4. Please relate the water produced and gas production from the wells related to this Produced Water 

Management System with the wells from the project from Part A listed at the top of the page: 

a. What percentage of water treated by this Produced Water Management System is from the 

project from Part A listed at the top of the page: 

 % 

b. What percentage of 2008 gas production from the project listed at the top of this page is 

associated with the wells served by this Produced Water Management System (estimate is 

acceptable).” 

 % 

C2-5. Selection of Management Option

a. How was the Produced Water Management System designed? (Check all that apply.) 

 Input from the surface owner during development of the surface use plan 

 Work with outside contractor 

 Other: Please describe 

b. Who manages the day-to-day operations for the produced water management? 

 Operator (Skip to Question C2-6) 

 Landowner (Skip to Question C2-6) 

 Contractor/third party; please provide company name 

c. Cost of hiring the contractor/third party for produced water management in 2008. Exclude the 

costs associated with the water gathering system from the CBM wells to the PWMS. 

 2008 annual operating and maintenance cost $ 

 Minimum quantity of CBM produced water required for contract: bbl 

Skip to Question C2-8, unless you have costs in addition to contractor/third party 

management. 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

Operator ID: 

C-10

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

C2-6. Produced Water Management System Capital Costs – Please provide the following capital cost 

information for this Produced Water Management System (e.g., treatment system, land application 

site). Exclude any costs associated with excavating surface impoundments if the impoundment was 

converted from other uses, such as drill pits, but do include the costs of conversion. Also exclude the 

costs associated with installing the water gathering system from the CBM wells to the PWMS. For 

example, you should exclude the costs of any trucking or installation of any pumps or pipes used to 

transport produced water from the CBM wells to the PWMS. 

a. Capital cost in dollars: $ 

 Check this box if your company purchased this PWMS from another company and 

you do not have this capital cost information. Skip to Question C2-7.

b. Year cost incurred: 

C2-7. Produced Water Management System Operating and Maintenance Costs – Please provide the 

costs for this Produced Water Management System (e.g., treatment system, land application site) for 

2008. Exclude the costs associated with maintaining the water gathering system from the CBM wells 

to the PWMS. For example, you should exclude the costs of any trucking or pump or pipe 

maintenance used for the transport of produced water from the CBM wells to the PWMS. You should 

include non-produced water transportation costs associated with the PWMS (e.g., contract hauling 

residuals from the PWMS, permit compliance monitoring). 

a. 2008 operating and maintenance cost in dollars: $ 

b. Please provide any annual revenue received from operating this Produced Water 

Management System (e.g., payments from water recipients, payment for treating produced 

water from another operator) $ 

C2-8. Produced Water Gathering and Transportation Questions. Please provide cost and design 

information for transporting the produced water from the CBM wells identified in Part A to this PWMS. 

The produced water gathering system (e.g., piping or trucking) is used to transport the produced 

water between the CBM wellhead and a centralized location (e.g., treatment unit, land application 

site). 

a. What is the total 2008 volume of water generated from the CBM wells identified in Part A that 

is piped to this PWMS? 

 Please specify the volume units: 

NOTE: You should skip to Question C2-8.d if all of the produced water generated from the CBM wells 

identified in Part A is stored at the CBM wells and subsequently trucked off-site for final disposition (e.g., 

underground injection, treatment and disposal, land application). 

b. What is the capital cost in dollars of the piped water gathering system between the CBM 

wells identified in Part A and this PWMS? 

 $ Year cost incurred: 

 Check this box if your company purchased this piped produced water gathering 

system from another company and you do not have this capital cost information. Skip 

to Question C2-8.d.

c. What is the 2008 operating and maintenance cost in dollars of the piped water gathering 

system between the CBM wells identified in Part A and this PWMS? 

 $ 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

Operator ID: 

C-11

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

d. Please answer the following questions if you truck produced water from the wells identified in 

Part A to this PWMS. Otherwise, skip to Question C2-9.

i. Total volume of produced water trucked to this PWMS in 2008: 

ii. Total vehicle miles traveled for the truck transport of 

produced water to this PWMS in 2008: 

iii. Total number of days used to truck produced water to this PWMS in 2008: 

iv. Average volume capacity of the tanker truck used in 

2008 (e.g., 2,000 gal./truck): 

v. Total 2008 costs incurred to truck produced water to this PWMS: $ 

C2-9. Please indicate the land area occupied by your operations. 

Location Area Units 

a. Total Project Area (Part A Project) 

b. Total PWMS Area 

c. Total Undeveloped Area 

d. Is the undeveloped area suitable for construction of new or additional wastewater treatment 

systems? 

 Yes 

 No: Provide explanation: 

 

 

C2-10. Have you ever operated or considered operating a produced water management system other than 

what is described in this section for the project? 

 Yes 

 No (Skip to Question C2-12) 

C2-11. What type of management system did you consider? 

 

 

 

 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part C. Produced Water Management Information 

Section 2: Produced Water Management System General Questions CBM Questionnaire 

Operator ID: 

C-12

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

C2-12. What were the reasons for not implementing or for stopping the operation of the management 

system? 

 

 

 

 

C2-13. Have any monitoring or other studies been conducted to assess the potential impacts of produced 

water for this Produced Water Management System, such as impacts related to irrigation, 

impoundment, or surface water discharges? Produced water related impacts may include but are not 

limited to: changes in soil characteristics, changes in stream flows, changes in aquatic toxicity, and 

changes in aquatic and riparian species composition. 

 Yes 

 No (Skip to Part C Section 3) 

C2-14. Indicate the following information about the studies, if known. If there are additional studies, please 

provide the information in the Comments Section (Question C4-3). 

Title: 

Date: / / 

Title: 

Date: / / 

CBI?

 Yes

CBI?

 Yes

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

Operator ID: 

C-13

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

SECTION 3: DETAILED PRODUCED WATER MANAGEMENT AND TREATMENT QUESTIONS 

GENERAL INSTRUCTIONS FOR SECTION 3 

Questions C3-1 through C3-13 request detailed information for the Produced Water Management System. 

Please see the following tables to identify the questions you should complete. 

C3-1. Produced Water Destination - This table provides information on the final destination of the 

produced water for this Produced Water Management System. Note that EPA will request information 

on any treatment technologies used prior to discharge in later questions. Check ( ) all that apply. 

Table C-1. Final Destination of CBM Produced Water 

Check ( ) All 

that Apply Destination 

Discharge to Surface Water, POTWs, and Third Parties

a. Discharge to surface water (requiring NPDES permit) 

b. Discharge to POTW or third party (e.g., discharge to another operator’s 

treatment system) 

Zero Discharge

c. Land Application (no crop production) 

d. Land Application (for crop production) 

e. Underground Injection 

f. Evaporation or infiltration pond (with no intended discharge to surface water) 

g. Livestock or Wildlife Watering 

h. Hauled off site 

i. Other (Specify): 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

Operator ID: 

C-14

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Copy of 

C3-2. Cost Information for Each Destination – Complete a copy of the following table for each produced 

water destination selected in Question C3-1. You should have one copy of this table for each box 

checked in Table C-1. 

Destination Option Selected in 

Question C3-1 

(Use this row to indicate which 

destination you are providing 

information on. You will make 

multiple copies of this table if you 

checked more than one destination 

in Question C3-1.)

 Discharge to Surface Water 

 Discharge to POTW or Third 

Party 

 Land Application (no crop 

production) 

 Land Application (for crop 

production) 

 Underground Injection 

 Evaporation or infiltration pond

 Livestock or wildlife watering 

 Hauled off site 

 Other: 

2008 Volume of Produced Water 

From this PWMS to this 

Destination

 

Unit: 

Maximum Daily Capacity of 

Produced Water from this PWMS 

Capable of Going to this 

Destination:

 

Unit: 

Check ( ) the Components Below that are Included in the Capital 

Costs: 

Capital Costs 

% of Total Capital Cost Provided in 

Response to Question C2-6 for this 

destination: 

 % 

(If only one box is checked in Table 

C-1 then enter 100% above.) 

 Tanks 

 Pumps 

 Piping/hoses 

 Outfall structure 

 Injection well 

 Pond 

 Treatment unit 

 Liner 

 Land acquisition 

 Monitoring equipment 

 Aeration equipment 

 Land application equipment 

 Other: 

 Other: 

Check ( )the Components Below that are Included in the Operation 

and Maintenance Costs: 

Operation and Maintenance 

Costs 

% of Total Operation and 

Maintenance Cost provided in 

Response to Question C2-7: 

 % 

 Chemicals 

 Energy: electric 

 Energy: gas 

 Energy: oil 

 Materials 

 Labor 

 Other: 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

Operator ID: 

C-15

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Copy of 

C3-3. Residuals Management Information – Complete a copy of the following table for each type of 

residual generated by this PWMS. Make sure you indicate in your narrative description or block 

diagram (see Question C2-1) each type of residual waste generated by this PWMS and the ultimate 

disposal of the residual. 

Residuals Management and 

Costs 

List Type(s) of Residuals 

Generated (e.g., brine waste 

from ion exchange unit): 

(Note: If more than one residual 

is generated by this PWMS, 

please make one copy of this 

question for each type of 

residual generated.)

Description of Residual Generated and its Source (e.g., brine waste 

from ion exchange treatment system): 

 

Volume (and units) of Residual Generated in 2008: 

 

Frequency of Residuals Removal from this PWMS in 2008 (e.g., brine 

waste tank emptied once per week). 

 

Name of Final Destination for this Residual (e.g., ABC Underground 

Injection Well, Permit No. XYZ): 

 

Distance from this PWMS to the Final Destination for this Residual: 

 miles 

Annual 2008 Cost of Disposal for this Residual: 

$ 

Components of Residual Disposal Cost: 

 Transportation: Piped 

 Transportation: Trucked 

 Disposal Fees 

 Other (Specify): 

If you check “Discharge to Surface Water” in Table C-1, please also complete Question C3-4 and then skip 

to Question C3-7. 

If you check “Discharge to a POTW or Third Party” in Table C-1, please also complete Question C3-5 and 

then skip to Question C3-7. 

If you check “Land Application (No Crop Production)” or “Land Application (For Crop Production)” in Table 

C-1, please also complete Question C3-6 and then skip to Question C3-7. 

For all other destinations selected in Table C-1, skip to Question C3-7. 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

Operator ID: 

C-16

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Surface Water Discharge Question Copy of 

C3-4. Surface Water Discharge. Complete Question C3-4 if you checked that this Produced Water 

Management System discharges to surface water in Table C-1. If this Produced Water Management 

System does not discharge to surface water, skip to Question C3-5. Complete one copy of this 

question for each surface water discharge permit used in this Produced Water Management System. 

a. General Information on Surface Water Discharge Permit – Please complete the following 

table of general information about the surface water discharge permit. 

NPDES Permit Number 

Permit Type General 

 Individual 

Expiration Date (MM-DD-YYYY) 

Stream Monitoring Required? Yes (Specify frequency: )

 No 

Effluent Monitoring Required? Yes (Specify frequency: )

 No 

Permit currently being reviewed or modified? Yes 

 No 

b. General Information on Outfalls Included in Permit – Please complete the following table 

of general information about the outfalls included in the permit listed in part (a) of this 

question. Make multiple copies if the permit covers more than three outfalls. 

i. Outfall Number – List each outfall included in the NPDES permit. 

ii. Aeration Equipment– Check ( ) any aeration equipment or other treatment 

equipment used at the outfall. 

iii. Flowrate or Volume Discharged Through Outfall – Please provide the total volume 

discharged through each outfall in 2008. 

iv. Frequency of Discharge – Indicate the frequency of discharge including number of 

days discharged in 2008. 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

Operator ID: 

C-17

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Surface Water Discharge Question Copy of 

Outfall Number Treatment at Outfall(s) 

Flowrate or Volume 

Discharged Through 

Outfall (Specify units) Frequency of discharge 

 

 None 

 Rip Rap 

 Atomizer 

 Sprinkler head 

 Diffuser 

 Other 

Specify: 

 

 

Units: 

 Continuous 

 Intermittent 

Number of days of 

intermittent discharge in 

2008 

 Emergency discharge only 

Number of days of 

emergency discharge in 

2008 

 

 None 

 Rip Rap 

 Atomizer 

 Sprinkler head 

 Diffuser 

 Other 

Specify: 

 

 

Units: 

 Continuous 

 Intermittent 

Number of days of 

intermittent discharge in 

2008 

 Emergency discharge only 

Number of days of 

emergency discharge in 

2008 

 

 None 

 Rip Rap 

 Atomizer 

 Sprinkler head 

 Diffuser 

 Other 

Specify: 

 

 

Units: 

 Continuous 

 Intermittent 

Number of days of 

intermittent discharge in 

2008 

 Emergency discharge only 

Number of days of 

emergency discharge in 

2008 

c. Discharge Permit and Discharge Monitoring Reports. Please attach a copy of the current 

surface water discharge NPDES permit. If available, EPA prefers the NPDES permit be 

submitted in an electronic format (e.g., PDF format). Please report any discharge monitoring 

report (DMR) data for 2006 through 2008 in Part C Section 4. If available, EPA prefers this 

DMR data be submitted in an electronic format (e.g., PDF format). 

 Permit Attached. 
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

Operator ID: 

C-18

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

POTW/Third Party Discharge Question Copy of 

C3-5. Discharge to POTW or third party. Complete Question C3-5 if you checked that this Produced 

Water Management System discharges to a POTW or third party in Question C3-1. If this Produced 

Water Management System does not discharge to a POTW or third party, skip to Question C3-7. 

Complete one copy of this question for each POTW or third party used in this Produced Water 

Management System. 

 POTW. 

 PrOTW. 

 Other facility. 

a. Provide the POTW, PrOTW, or other facility name, address, primary contact, and phone 

number (if applicable). 

 

POTW/PrOTW/Other Facility Name 

 

Address 

 

City State Zip Code 

 ( ) - 

Primary Contact Name Telephone Number 

b. Please attach a copy of the current permit or discharge agreement. Please report any 

monitoring data in Part C Section 4. If available, EPA prefers data be submitted in an 

electronic format. 

 Permit/Discharge Agreement Attached 

Continue to Question C3-7. 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

Operator ID: 

C-19

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Discharge to Land Application (with or without crop production) Question Copy of 

C3-6. Discharge to Land Application (with or without crop production) – Complete Question C3-6 if 

you checked that this Produced Water Management System discharges to land application in 

Question C3-1. If this Produced Water Management System does not discharge to a land application 

system, skip to Question C3-7. Complete one copy of this question for each land application system 

used at this Produced Water Management System. 

Land Application (Complete for Irrigation and Non-Irrigation Land Application) 

a. Area of Land Used for Land Application 

(acres) 

 

b. Describe any criteria on the Produced Water 

for this Land Application 

 

c. Type of Land Application/Irrigation Above-ground irrigation (e.g., center-pivot) 

 Sub-surface drip irrigation (SDI) 

 Other (Specify): 

d. Frequency of Application Continuous 

 Intermittent: 

 Number of days applied in 2008 

 Months that the land application occurred in 2008 

(e.g., February, March, May) 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

Operator ID: 

C-20

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Produced Water Treatment 

C3-7. Do you treat produced water to remove pollutants prior to discharge to surface water or POTW/third 

party? 

 Yes 

 No (Skip to Part C Section 4) 

C3-8. This table provides direction on how to provide information on the treatment of the produced water for 

this Produced Water Management System. Check ( ) all that apply. EPA will request more detailed 

information about treatment of the produced water in later questions. 

Table C-2. Treatment of CBM Produced Water 

Check (:) All that Apply 

Type of Treatment Unit 

Do you have water quality 

data for the produced water 

entering and/or leaving this 

treatment unit? If so, please 

provide in Section 4 (water 

quality section). Additional Information 

a. Sedimentation Pond (for 

equalization or suspended solids 

removal) 

 Yes 

 No 

Complete Question C3-9 

for each pond. 

b. Ion exchange Yes 

 No 

Complete Question C3-10 

for each ion exchange unit.

c. Low-Pressure Filtration (e.g., 

Hydro-cyclone, Multi-media 

filtration) 

 Yes 

 No 

Complete Question C3-11 

for each low-pressure 

filtration unit. 

d. High-Pressure Filtration (e.g., 

Reverse Osmosis, Nanofiltration) 

 Yes 

 No 

Complete Question C3-12 

for each high-pressure 

filtration unit. 

e. Other (Specify): 

 

 Yes 

 No 

Complete Question C3-13 

for any additional 

treatment units not listed 

elsewhere. 

Copy pages as needed to include information on all treatment units checked ( ) in the table above. 

Please be sure to enter the Produced Water Management System identification number or name so that EPA 

can link the information in this section to the correct Produced Water Management System. 

CBI?

 Yes

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

Operator ID: 

C-21

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Sedimentation Ponds Question Copy of 

C3-9. Sedimentation Ponds – Complete Question C3-9 if you checked that this Produced Water 

Management System uses sedimentation ponds in Table C-2. Also, please indicate the water quality 

parameters that are removed by this treatment unit and the estimated removal efficiency. If this 

Produced Water Management System does not use sedimentation ponds, skip to Question C3-10. 

Design Capacity (acre-feet) acre-feet 

Volume of Produced Water into Sedimentation 

Pond in 2008 bbl 

Surface Area acres 

Type of Liner and Thickness (if applicable) Yes – Liner used 

 Specify type and thickness: 

 No liner 

Chemicals Added (e.g., coagulants, biocides) 

Capital Cost of Sedimentation Pond and Year of 

Cost 

$ 

Year: 

Initial Bonding Costs and Year of Costs $ 

Year: 

2008 Operating and Maintenance Cost of 

Sedimentation Pond $ 

Targeted Water Quality Parameter 

Parameter Name 

Estimated Removal 

Efficiency Basis/Comments 

 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

Operator ID: 

C-22

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Ion Exchange Question Copy of 

C3-10. Ion Exchange - Complete Question C3-10 if you checked that this Produced Water Management 

System uses ion exchange in Table C-2. Also, please indicate the water quality parameters that are 

removed by this treatment unit and the estimated removal efficiency. If this Produced Water 

Management System does not use ion exchange, skip to Question C3-11. Remember to complete 

one copy of this question for each ion exchange unit used in this Produced Water Management 

System. Also make sure to complete Question C3-3 for any brine waste generated. 

Design Capacity of Ion Exchange System (bbl/d) bbl/d 

Volume of Produced Water into Ion Exchange in 

2008 (bbl) bbl 

Vendor/Unit Name 

Resin Name/Type 

Average Regeneration Frequency (specify 

frequency; e.g., once/hour, once/4 hours, 

once/day) 

 

Average Resin Life (yrs) years 

Chemicals Added (e.g., regenerates, biocides) 

Capital Cost of Ion Exchange Unit and Year of 

Cost 

$ 

Year: 

2008 Operating and Maintenance Cost of Ion 

Exchange Unit $ 

Pilot Project Yes 

 No 

Targeted Water Quality Parameter 

Parameter Name 

Estimated Removal 

Efficiency Basis/Comments 

 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

Operator ID: 

C-23

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Low-Pressure Filtration Question Copy of 

C3-11. Low-Pressure Filtration – Complete Question C3-11 if you checked that this Produced Water 

Management System uses low-pressure filtration in Table C-2. Also, please indicate the water quality 

parameters that are removed by this treatment unit and the estimated removal efficiency. If this 

Produced Water Management System does not use low-pressure filtration, skip to Question C3-12. 

Remember to complete one copy of this question for each low-pressure filtration unit used in this 

Produced Water Management System. Also make sure to complete Question C3-3 for any residuals 

generated. 

Design Capacity of Filtration System (bbl/d) bbl/d 

Volume of Produced Water Entering LowPressure Filtration Unit in 2008 (bbl) bbl 

Type Multimedia 

 Sand 

 Ultrafiltration 

 Other: 

Vendor/Unit Name 

Average Cleaning Frequency (specify frequency; 

e.g., once/hour, once/4 hours, once/day) 

Chemicals Added (e.g., coagulants, biocides) 

Capital Cost of Filtration System and Year of Cost $ 

Year: 

2008 Operating and Maintenance Cost of 

Filtration System $ 

Pilot Project Yes 

 No 

Targeted Water Quality Parameter 

Parameter Name 

Estimated Removal 

Efficiency Basis/Comments 

 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

Operator ID: 

C-24

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

High-Pressure Filtration Question Copy of 

C3-12. High-Pressure Filtration – Complete Question C3-12 if you checked that this Produced Water 

Management System uses high-pressure filtration in Table C-2. Also, please indicate the water 

quality parameters that are removed by this treatment unit and the estimated removal efficiency. If 

this Produced Water Management System does not use high-pressure filtration, skip to Question 

C3-13. Remember to complete one copy of this question for each high-pressure filtration unit used in 

this Produced Water Management System. Also make sure to complete Question C3-3 for any 

residuals generated. 

Design Capacity of Filtration System (bbl/d) bbl/d 

Volume of Produced Water Entering HighPressure Filtration Unit in 2008 (bbl) bbl 

Type Reverse Osmosis 

 Nanofiltration 

 Other (Specify type): 

Vendor/Unit Name 

Average Cleaning Frequency (specify frequency; 

e.g., once/hour, once/4 hours, once/day) 

Membrane Life (years) years 

Chemicals Added (e.g., coagulants, biocides) 

Capital Cost of Filtration System and Year of Cost $ 

Year: 

2008 Operating and Maintenance Cost of 

Filtration System $ 

Pilot Project Yes 

 No 

Targeted Water Quality Parameter 

Parameter Name 

Estimated Removal 

Efficiency Basis/Comments 

 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 3: Detailed Produced Water Management and Treatment Questions CBM Questionnaire 

Operator ID: 

C-25

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Treatment Not Specified Elsewhere Question Copy of 

C3-13. Treatment Not Specified Elsewhere – Complete Question C3-13 if you checked that this Produced 

Water Management System uses land application or treatment not specified elsewhere in Table C-2. 

Remember to complete one copy of this question for any additional treatment units used at this 

Produced Water Management System. Also make sure to complete Question C3-3 for any residuals 

generated. 

a. General Information – Please complete the following table of general information. Also, 

please indicate the water quality parameters that are removed by any treatment unit and the 

estimate removal efficiency. 

Design Capacity of This Treatment System (bbl/d) bbl/d 

Volume of Produce Water Entering Treatment 

Unit in 2008 (bbl) bbl 

Description of Treatment System 

Vendor/Unit Name 

Type and Amounts of Chemicals Used With This 

System in 2008 (e.g., coagulants, biocides, soil 

amendments) 

 

Average Regeneration/Cleaning Frequency 

Specify units (e.g., once/hour, once/4 hours, 

once/day): 

 

Capital Cost of System and Year of Cost $ 

Year: 

2008 Operating and Maintenance Cost of System $ 

Pilot Project Yes 

 No 

Targeted Water Quality Parameter (Complete for Treatment Technology Not Specified Elsewhere) 

Name 

Estimated Removal 

Efficiency Basis/Comments 

 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 4: Produced Water Quality Data CBM Questionnaire 

Operator ID: 

C-26

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

SECTION 4: PRODUCED WATER QUALITY DATA 

To enable EPA to evaluate the ability of produced water management systems to remove potential pollutants 

of concern, water quality data is required. EPA will evaluate the performance of produced water management 

systems via analysis of effluent data, and as available, analysis of data that represents the influent to the 

produced water management system. EPA also requests information related to the measured values (e.g., 

analytical method information) to allow for examination of the quality of data provided. This section requests 

this water quality data for each Produced Water Management System. 

C4-1. Complete Table C-3 for locations related to treatment unit processes for which you have water quality 

data. All information collected will aid EPA in determining CBM produced water characteristics by 

basin; identifying pollutants; calculating baseline loadings; and estimating the effectiveness of 

treatment technologies. Note that if you already have water quality data in electronic or 

hardcopy format, you may submit these data using your own reporting method. If you need 

more space, make a copy of Table C-3. Locations may include: wellhead, influent to treatment; 

effluent from treatment; and discharge outfalls. Please include all paired influent and effluent data for 

any treatment units operated by your site. Provide all relevant data for 2008. If 2008 data is 

unavailable, please provide the most recent data. 

• The pollutant analyzed; 

• The measured value including units (if not detected, list the detection limit value preceded by 

a less than (<) symbol); 

• The analytical method used; 

• The date samples were collected; 

• Where the samples were collected (this should be a number from a label on your block flow 

diagram); 

• Whether the samples were collected as grabs or as composites; and 

• Provide flow rate only if flow rate data were recorded at the sampling point during the 

sampling period. 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 4: Produced Water Quality Data CBM Questionnaire 

Operator ID: 

C-27

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

C4-2. Whole Effluent Toxicity Information 

a. Have you performed any whole effluent toxicity (WET) testing for this Produced Water 

Management System? 

 Yes 

 No (Skip to Question C4-3) 

b. Please provide the information on the WET testing conducted, including the including the test 

organism, test type (e.g., acute or chronic), and the results. 

 

 

 

 

 

c. Has toxicity ever exceeded permit limits? 

 Yes 

 No (Skip to Question C4-3) 

d. Was a toxicity identification evaluation (TIE), toxicity reduction evaluation (TRE), or other 

study performed to determine the cause, treatability, or effective management of toxicity? 

 Yes 

2008 Annual Costs ($) for TIE and TRE: 

 No (Skip to Question C4-3) 

e. Please describe the cause of the toxicity and the final resolution of the toxicity issue. 

 

 Attached 

CBI?

 Yes
Part C. Produced Water Management Information 

Section 4: Produced Water Quality Data CBM Questionnaire 

Operator ID: 

C-28

Project ID from Part A: 

Operator’s Name or ID for this Produced Water Management System: 

Analytical Data Question Copy of 

Table C-3. Analytical Data 

Note: If you already have water quality data in electronic or hardcopy format, you may submit 

these data using your own reporting method. EPA prefers water quality data be submitted in 

an electronic format (e.g., Microsoft© Access, Microsoft© Excel, non-scanned PDF). 

 Submitted own data as attachment to this questionnaire.

Pollutant 

Measured 

Value 

(mg/L) 

Analytical 

Method 

Permit 

Limit 

(mg/L) 

Sampling 

Date Location 

Sample 

Type (grab/ 

composite)

Flow Rate 

(gpm) 

Total Dissolved 

Solids 1124 EPA Method 160.1 7/1/06 SP-1 Grab 130 

 
Part C. Produced Water Management Information CBM Questionnaire 

Operator ID: 

C-29

Copy of 

C4-3. Comments on Part C. Please cross-reference your comments by question number. If you need 

additional space, please photocopy this page before writing on it, and number each copy in the 

space provided. Please use this table to comment on any information you would like to share with 

EPA on how you manage CBM produced water. 

Question 

Number Comment 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 

CBI?

 Yes

 
Part D. Supporting Information 

Section 1: List of Acronyms and Abbreviations CBM Questionnaire 

D-1

PART D. SUPPORTING INFORMATION 

SECTION 1: LIST OF ACRONYMS AND ABBREVIATIONS

% Percent 

API American Petroleum Institute 

bbl Barrel (42 gallons) 

bbl/d Barrels per day 

bcf Billion cubic feet 

BPJ Best Professional Judgment 

BTU British thermal unit 

CBM Coal bed methane 

CFR Code of Federal Regulations 

CFS Cubic feet per second 

Cl- Chloride 

CWA Clean Water Act 

DOE U.S. Department of Energy 

dpy Days per year 

EA Environmental Assessment 

EC Electrical Conductivity 

EDR Electrodialysis Reversal 

ELG Effluent limitations guideline 

EPA U.S. Environmental Protection Agency 

ft Foot 

ft2 Square foot 

ft3 Cubic foot 

gal Gallon 

gpd Gallons per day 

gpm Gallons per minute 

hrs/day Hours per day 

in Inch 

kWh Kilowatt-hour 

lb Pound 

lb/hr Pounds per hour 

mcf Thousand cubic feet 

MCL Maximum contaminant level 

mg/L Milligrams per liter 

MGD Million gallons per day 

MMBTU/hr Million BTUs per hour 

mmcf Million cubic feet 

MW Megawatt 

NA Not applicable 

NPDES National Pollutant Discharge Elimination System 

POTW Publicly Owned Treatment Works 

ppm Parts per million 

PrOTW Privately Owned Treatment Works 

psi pounds per square inch 

RO Reverse osmosis 

s Second 

SAR Sodium Adsorption Ratio 

SIC Standard Industrial Classification 

tcf Trillion cubic feet 

TDS Total dissolved solids 

ton English ton, wet weight 

TMDL Total maximum daily load 

tpy Ton per year 

TSS Total suspended solids 

yr Year 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-2

SECTION 2: DEFINITION OF KEY TERMS 

Ad Valorem Taxes—A type of property taxes, usually levied as a percentage of production or value of 

production by local authorities, such as a county, a school district, city, or township. 

Aeration—Process that mixes air and water, normally by injecting air into water, spraying water into the air, 

or allowing water to pass over an irregular surface, to release compounds from the water through oxidation, 

precipitation, or evaporation. 

Arroyo—An intermittently dry creek. 

Balance Sheet—A quantitative summary of a company's financial condition at a specific point in time, 

including assets, liabilities and net worth. The first part of a balance sheet shows all the productive assets a 

company owns, and the second part shows all the financing methods (such as liabilities and shareholders' 

equity); also called statement of condition. 

Batch (Intermittent) Discharge or Application—A discreet volume or mass of liquid or solid that is collected 

and discharged periodically. 

Beneficial Use—The produced water is of good enough quality to be used for wildlife propagation or 

livestock watering or other agricultural uses and the produced water is actually put to such use during periods 

of discharge. 

Best Management Practices (BMP)—Methods that have been determined to be the most effective, practical 

means of preventing or reducing pollution from non-point sources. Activities, maintenance procedures, and 

other management practices to prevent or reduce the pollution. BMPs may include treatment requirements, 

operating procedures, and practices to control plant site runoff, spillage or leaks, sludge or waste disposal, or 

drainage from raw material storage. 

C Corporation—A business that is a completely separate entity from its owners, unlike a partnership. 

Capital Cost—The costs associated with the purchase, development or construction of fixed assets such as 

land, stations, buildings, and water treatment equipment. 

Capital Cost of Project Development—As defined for Question B3-13. this includes all capital and one-time 

costs of project development beyond the immediate tophole equipment (e.g., Christmas tree), including any 

exploratory costs, planning costs, geological and geophysical costs, site development costs, such as pads 

and roads or other land preparation activities, production pumps, gas/water separation equipment, other 

onsite gas gathering or treatment equipment, and gas pipelines to offsite location and/or point of sale. It does 

not include any capital costs of water management (see definition). 

Clarification—Separation and concentration of solids from liquid/solid mixtures that are mostly liquid. 

Clean Water Act—Federal legislation enacted by Congress to “restore and maintain the chemical, physical, 

and biological integrity of the Nation’s waters” (Federal Water Pollution Control Act of 1972, as amended, 33 

U.S.C. 1251 et seq.). 

Coalbed Methane (CBM)—Natural gas found in coal seam reservoirs. 

Coalbed Methane (CBM) Project— A CBM project comprises a well, group of wells, lease, group of leases, 

or recognized unit which you operate as an economic unit when making production decisions. The well or 

wells may be associated with one or more water management practices (that is, the project should be defined 

on the basis of gas production economics, not necessarily on the basis of a water management system). If a 

project operates as a unit in which you are not the sole operator, please include information only for that 

portion of a unit for which you actively operate. EPA understands that the concept of a project is variable over 

time, so the well or wells included as a part of a project should be those that best defined the project as it 

existed in 2008. 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-3

Coalbed Methane (CBM) Unit—A unit is a group of leases that are managed together with the intention of 

maximizing production (and/or minimizing costs), where operating these leases independently might result in 

more wells drilled, less production realized, or both. Units can be formal, legal entities that are written into 

lease agreements, pooling agreements, and/or state permits; or informal, particularly where minerals rights on 

several leases are owned by the same entity. 

Continuous Flow—A flow regime characterized by persistent flow, as opposed to intermittent flow or batch

processes. 

Contract Haul—The removal of any waste stream (including produced water) from a facility by a company 

authorized to transport and dispose of the waste, excluding discharges to sewers or surface waters. 

Cost-Depletion Method—Recovery of the tax basis in a mineral deposit by deducting it proportionately over 

the productive life of the deposit. This is in contrast to the percentage depletion method, which permits a 

taxpayer with an economic interest in a mineral deposit to deduct a specified percentage of the gross income 

from the deposit instead of using the cost depletion method. Percentage depletion is generally restricted to 

independent producers, royalty owners, and some other narrow categories of oil and gas owners. 

Cost of Capital—The opportunity cost of an investment; that is, the rate of return that a company would 

otherwise be able to earn at the same risk level as the investment that has been selected. For example, when 

an investor purchases stock in a company, he/she expects to see a return on that investment. Since the 

individual expects to get back more than his/her initial investment, the cost of capital is equal to this return 

that the investor receives, or the money that the company misses out on by selling its stock. 

Creek—A small, natural stream that is often a shallow or intermittent tributary to a river. 

Cumulative Depreciation—The total charges against the fixed assets of a company for wear and tear, 

obsolescence, or the depletion of a natural resource—oil in the ground, for instance—as it is used up. 

Current Assets—Any asset that can reasonably be expected to be used up or converted to cash or sold 

within a year or less, e.g., cash, accounts receivable, prepaid expenses. 

Current Liabilities—Debts that are payable within 1 year, including accounts payable, notes payable within 

one year, accrued expenses and taxes, and the portion of long-term debt that are paid this year. 

Depreciation, Depletion, and Amortization—The allocation of the cost of an asset over a period of time for 

accounting and tax purposes. Depletion, which reflects the declining value of a natural resource asset as it is 

produced, may be calculated either using the cost-depletion or percentage depletion method, depending on 

type of firm (see cost-depletion method). 

Design Capacity Flow Rate—Maximum flow rate a treatment unit is designed to handle. 

Direct Discharge—The discernible, confined, and discrete conveyance of pollutants to United States surface 

waters such as rivers, lakes, and oceans. See 40 CFR 122.2. 

Discharge—The discernible, confined, and discrete conveyance of pollutants to: (1) United States surface 

waters such as rivers, lakes, and oceans (“direct discharge”), or (2) a publicly owned, privately owned, 

federally owned, combined, or other treatment works (“indirect discharge”). See 40 CFR 122.2. 

Disposal—Intentional placement of waste (including produced water) into or on any land where the material 

will remain after closure. Waste placed into water is defined as discharge, not disposal. 

Division—A business unit of a firm, often treated as a profit center (see profit center). 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-4

Drilling Cost—Includes tangible and intangible costs of drilling and completing a well (if completed), as 

defined in API’s Joint Association Survey of Drilling Costs, which includes “expenditures for drilling dry holes 

and productive wells and equipping new productive wells through the Christmas tree” installation...these cost 

elements are the costs of labor, materials, supplies, water, fuels, power, and direct overhead (i.e., field, 

district, and regional), for such operations as site preparation, road building, erecting and dismantling derricks 

and drilling rigs, drilling hole, running and cementing casing, hauling materials, etc. Include the total cost of 

water, if purchased, or cost of water well, if drilled and chargeable to oil or gas well drilling operations. Well 

costs also include machinery and tool charges and rentals, and depreciation charges, where appropriate, for 

rigs and other equipment and facilities which will be used in drilling more than one well. Deduct the condition 

value of materials salvaged after use where appropriate. Do not report the cost of lease equipment such as 

artificial lift equipment and downhole lift equipment, flow lines, flow tans, separators, etc. that are required for 

production. Do not reduce the costs by test well, bottom hole, or dry hole contributions. 

Earnings Before Interest and Taxes (EBIT)—A measure of a company’s earning power from ongoing 

operations, equal to earnings before deduction of interest payments and income taxes; also called operating 

profit or operating income. 

Emergency Discharge—A volume or mass of liquid or solid residuals are discharged only during extenuating 

circumstances (i.e., a treatment process malfunction). 

Equalization—The process of storing produced water for later treatment or discharge. This process can also 

provide some removal of some suspended solids. 

Evaporation—The process by which water or other liquid becomes a gas. Water from land areas, bodies of 

water, and all other moist surfaces is absorbed into the atmosphere as a vapor. 

Filtration—This treatment technology relies on the difference in size between the pore and the particle to be 

removed. Low-Pressure Filtration typical involves using low pressure and can include direct media filtration 

using one or more layers of granular media such as sand and/or anthracite with coagulation. High-Pressure 

Filtration typically uses a driving force to transport wastewater through a membrane, which separates the 

wastewater into two flows: permeate and retentate (e.g., nanofiltration and reverse osmosis). 

Fiscal Year—A 12-month period over which a company budgets its spending. A fiscal year does not always 

begin in January and end in December; it may run over any period of 12 months. 

Groundwater—Water in a saturated zone or stratum beneath the surface of land or water. 

Hurdle Rate—The required rate of return in a discounted cash flow analysis, above which an investment 

makes sense and below which it does not. Often, this is based on the firm's cost of capital or weighted 

average cost of capital, plus or minus a risk premium to reflect the project's specific risk characteristics; also 

called required rate of return. 

Income Statement—An accounting report showing various categories of revenues, expenses, interest 

payments, taxes, and net income. 

Indirect Discharge—The discernible, confined, and discrete conveyance of pollutants to a publicly owned, 

privately owned, federally owned, combined, or other treatment works. 

Infiltration—The process by which water penetrates into soil from the ground surface

Injection Well (Deep or Shallow Well Injection) —Any bored, drilled, or driven shaft or a dug hole, 

improved sinkhole, or a subsurface fluid distribution system where the depth is greater than the largest 

surface dimension that is used to dispose of fluids underground. See underground injection. 

Interest Expense—An expense for interest on a loan. 

Intermittent Flow—A flow regime characterized by flows that occur sporadically, seasonally, or for only a 

portion of time during normal operations. 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-5

Ion Exchange (IX) —Treatment process using a resin formulated to adsorb cationic or anionic species to 

remove pollutants from an influent stream. 

Lake—A body of freshwater or saltwater surrounded by land. 

Landfill—A natural or man-made formation in the earth into which solid waste, sludges, or other process 

residuals are placed for permanent disposal. 

Lease Bid—Amount (generally a lump sum at time of lease acquisition) paid to the mineral rights owner to 

hold the property for a period of time, whether or not the lease is developed. This does not include rental 

payments, which may be charged over time, nor does it include royalties, which are paid only once production 

begins. 

Limited Liability Corporation or Company—A type of company, authorized only in certain states, whose 

owners and managers receive the limited liability and (usually) tax benefits of an S Corporation without having 

to conform to the S corporation restrictions. 

Limited Liability Partnership—See limited liability corporation. 

Long-term Debt—Liabilities that are paid off over periods greater than 1 year, including mortgages, notes, 

bonds, debentures, long-term leases, bank debt, and deferred income taxes. 

Maximum Daily Flow—The maximum flow in a 24-hour period. 

Membrane Filtration—Separation processes that use a membrane as the filter mechanism. 

Mineral Rights Owner—Party owning the rights to minerals beneath land that has been or will be used for 

the purposes of producing minerals or hydrocarbons. Party may or may not own the rights to the land surface. 

See surface owner. 

NAICS—NAICS is an economic classification system. Economic units that use like processes to produce 

goods or services are grouped together. These units are assigned a code for identification purposes. US 

Census Bureau (http://www.census.gov/epcd/www/naics.html). Common 6-digit NAICS in the CBM extraction 

industry include 211111, Crude Petroleum & Natural Gas Extraction; 213111, Drilling Oil and Gas Wells; 

213112, Support Activities for Oil and Gas; 212111, Bituminous Coal & Lignite Surface Mining; 212112, 

Bituminous Coal Underground Mining; 221210, Natural Gas Distribution; 221112, Fossil Fuel Electric Power 

Generation; and 324110 Petroleum Refineries. 

Nanofiltration—A method of water treatment that utilizes membranes to remove hardness, bacteria, viruses, 

and organic-related color. 

Net Income—Gross sales minus taxes, interest, depreciation, and other expenses. 

Net Sales—Gross sales minus returns, discounts, and allowances (investorwords.com). 

NPDES Permit Program—The National Pollutant Discharge Elimination System (NPDES) program 

authorized by Sections 307, 318, 402, and 405 of the Clean Water Act that applies to facilities that discharge 

wastewater directly to United States surface waters. For the CBM industry, operators are required to obtain 

NPDES permits for their direct discharges to surface waters. 

Operating and Maintenance Cost—The ongoing, repetitive costs of operating a water system; for example, 

employee wages and costs for treatment chemicals and periodic equipment maintenance. 

Operating Costs (income statement)—These are the recurring expenses which are related to the operation 

of a business. 

Operator—The person responsible for the management and day-to-day operation of one or more CBM wells. 

The operator is generally a working interest owner or a company under contract to the working interest 

owner(s). 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-6

Other Assets (net of depreciation)—Any non-current assets (assets that cannot be easily converted to 

cash) other than property, plant and equipment. 

Owner Firm—The next level up in the corporate hierarchy from the owner/operator. This firm owns the 

owner/operator firm or division, regardless of whether the owner/operator is a contract operator or a working 

interest operator. 

Owner/Operator—The entity (firm or division, if a profit center) responsible for the management and day-today operation of a well. The owner/operator is generally a working interest owner or a company under 

contract to the working interest owner(s). Management decisions might include whether well(s) should be 

shut-in, worked over or abandoned, whether additional or replacement wells should be drilled, whether 

additional or different production equipment should be installed, and any other decision factor used by DOE in 

the General Instructions to Form EIA-23. 

Payback Period—The amount of time taken to break even on an investment. Since this method ignores the 

time value of money and cash flows after the payback period, it can provide only a partial picture of whether 

the investment is worthwhile. 

Payments to Principal—Payments made on the principal portion of a loan or other borrowing mechanism 

classified as long-term debt (excludes the interest payments on these loans). 

Pollutant—Under the Clean Water Act, a dredged spoil, solid waste, incinerator residue, filter backwash, 

sewage sludge, munitions, chemical waste, biological material, certain radioactive material, heat, wrecked or 

discarded equipment, rock sand, cellar dirt, and industrial, municipal, and agricultural waste (40 CFR 122.2). 

Pollution Prevention—The use of materials, processes, or practices that reduce or eliminate the creation of 

pollutants or wastes. It includes practices that reduce the use of hazardous and non-hazardous materials, 

energy, water, or other resources, as well as those practices that protect natural resources through 

conservation or more efficient use. Pollution prevention includes but is not limited to source reduction, inprocess recycle and reuse, and water conservation practices. 

Primary Collection Point—The first point in the Produced Water Management System where produced 

water from all wells flowing to one final destination are combined. In example 4, the 

sedimentation/equalization pond would be the primary collection point. 

Privately Owned or Held—A company whose shares are not traded on the open market. 

Privately Owned Treatment Works (PrOTW)—Any device or system owned and operated by a private entity 

and used for storage, treatment, recycling, or reclamation of liquid industrial wastes. 

Produced Water—Water drawn from any hydrologic unit for the purpose of producing hydrocarbons. 

Produced Water Management System— For the purposes of this questionnaire, Produced Water 

Management System is defined as a system that is managed by the operator as a single unit for produced 

water management. Produced water management may include different treatment, transfer to disposal 

locations, and/or reuse practices. The Produced Water Management System may treat water from a lease, 

field, project, or plan of development (POD). Water discharge permits, land application permits, and 

applications for permits to drill (APD) typically use one of these terms to define the well grouping. Note that 

the Produced Water Management System can have multiple disposal options but it is managed as a single 

unit. For example, an operator may use a combination of stock tanks, irrigation, and storage ponds on a 

single Produced Water Management System. Also note that the Produced Water Management System may 

serve the same or different wells from the CBM project defined in Part A. Finally, for the purposes of this 

questionnaire, the PWMS does not include the produced water gathering system (e.g., piping or trucking) that 

is used to transport the produced water between the CBM wellhead and a centralized location (e.g., treatment 

unit, land application site). For example, produced water gathering pipes are typically installed underground at 

the same time as the gas gathering pipes. 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-7

Produced Water Treatment or Treatment—The treatment of water with physical, chemical, biological, or 

other processes to remove specific pollutants from the water stream or to alter the physical or chemical state 

of specific pollutants in the water stream. Produced water treatment is performed to allow for discharge, 

disposal or beneficial use of the water. 

Profit Center—A business unit or department which is treated as a distinct entity enabling revenues and 

expenses to be determined so that profitability can be measured. For the purposes of this questionnaire a 

profit center is defined as an entity that tracks finances at least through earnings before interest and taxes. 

Property, Plant and Equipment—A type of asset a company owns that is vital to business operations but 

cannot be easily liquidated. The value of property, plant and equipment is typically depreciated over the 

estimated life of the assets, because even the longest-term assets become obsolete or useless after a period 

of time. 

Publicly Owned or Held—A company which has issued securities through an offering, and which are now 

traded on the open market. 

Publicly Owned Treatment Works (POTW)—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. 

Receiving Waters—A stream, river, or other surface water body to which wastewater or other pollutants are 

discharged. 

Retained Earnings—Earnings not paid out as dividends but instead reinvested in the core business or used 

to pay off debt; also called earned surplus or accumulated earnings or unappropriated profit. 

Reverse Osmosis (RO)—A method of water treatment that involves the application of pressure to a 

concentrated solution which causes the passage of a liquid from the concentrated solution to a weaker 

solution across a semi-permeable membrane. The membrane allows the passage of the solvent (water) but 

not the dissolved solids (solutes). This water treatment method is typically used for desalinization and the 

removal of ions, radionuclides, bacteria, and viruses. 

River—Water which flows in a channel from high ground to low ground and ultimately to a lake or sea. 

Royalty Payments—Payments made to the mineral rights owner. These payments may be based on a 

percentage of the gas produced or as a percentage of the revenues received. A royalty is not a working 

interest share (see working interest). 

S Corporation—A form of corporation, allowed by the IRS for most companies with 75 or fewer shareholders, 

which enables the company to enjoy the benefits of incorporation but be taxed as if it were a partnership. Also 

called Subchapter S Corporation. 

SEC Proved Reserves—Proved oil and gas reserves are the estimated quantities of crude oil, natural gas, 

and natural gas liquids which geological and engineering data demonstrate with reasonable certainty to be 

recoverable in future years from known reservoirs under existing economic and operating conditions, i.e., 

prices and costs as of the date the estimate is made. Prices include consideration of changes in existing 

prices provided only by contractual arrangements, but not on escalations based upon future conditions. See 

SEC SX Reg. 210.4-10 (November 18, 1981). 

Sedimentation Pond—An impoundment constructed at the produced water treatment site to remove 

suspended solids from the produced water. These impoundments can also provide equalization of the 

produced water prior to treatment or discharge. 

Selling, General and Administrative Costs—Income statement item which combines salaries, 

commissions, and travel expenses for executives and salespeople, advertising costs, and payroll expenses. 

Severance Tax Payments—Payments made to a state for the right to remove a natural resource, usually 

applied to gas for use in another state. 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-8

Sludge—The accumulated solids and solid residues separated from liquids by settling or treatment. 

Storage Pond—An impound for liquid wastes. 

Sum of Liabilities and Owner Equity—Current Liabilities + Long-Term Debt + Retained Earnings + Other 

Owner Equity. 

Surface Owner—Party owning land that has been or will be used for the purposes of producing minerals or 

hydrocarbons. Party may or may not own mineral rights beneath that land. 

Surface Use Plan—Agreement between a landowner and a coalbed methane producer describing the 

conditions of land use for coalbed methane production including existing and proposed facilities (e.g. wells, 

roads, pipelines, and treatment systems), compensation for property damages, and considerations for land 

reclamation.

Surface Waters—Waters of the United States including, but not limited to, oceans and all interstate and 

intrastate lakes, rivers, streams, creeks, arroyos, mudflats, sand flats, wetlands, sloughs, wet meadows, playa 

lakes, and natural ponds (40 CFR 122.2). 

Technically Recoverable Reserves—Reserves recoverable given current technologies and industry 

practices and assuming no limitations on production due to market conditions. 

Total Assets—Total Current Assets + Total Non-current Assets (including Property, Plant, and Equipment 

and Other Assets Net of Depreciation). 

Treatment Unit—A unit operation used to remove pollutants from produced water. Treatment units include, 

but are not limited to sedimentation ponds, ion exchange systems, and filters. 

Ultimate Parent—The firm at the highest level of the corporate hierarchy. If the owner firm is not owned by 

another firm, the owner firm is the ultimate parent. If the owner/operator is not owned by any other firm, there 

is no ultimate parent. 

Ultrafiltration (UF) —A method of water treatment that utilizes membranes in a pressure-driven process for 

concentrating solutions containing colloids and higher molecular weight materials. This water treatment 

method typically removes viruses, colloids, clays, bacteria, humic acids, and fulvic acids, but not ions or 

radionuclides. 

Underground Injection—The technology of placing fluids underground, in porous formations of rocks, 

through wells or other similar conveyance systems. See injection well. 

Unusual Expenditure—An expenditure that does not occur every year and that is more than 10 percent of 

O&M (e.g., major storm damage causes large outlay for repairs); or a capitalized one-time or capital cost not 

considered a lease acquisition or development cost (e.g., construction of a septic system or a building not 

directly associated with production) and is not a cost covered in Part C. 

Water Reuse—Beneficial use of coalbed methane produced water (e.g., livestock watering, irrigation, or dust 

control) in lieu of discharge/disposal. 

Wellhead Price of Gas—The price of gas at the wellhead, which is different from the price at natural gas 

hubs, reflecting the implicit cost to transport the gas to buyer, including the cost of gathering, compression, 

dehydration, etc. 

Working Interest—Percentage of ownership in an oil and gas lease granting its owner the right to explore, 

drill and produce oil and gas from a tract of property. Working interest owners are obligated to pay a 

corresponding percentage of the cost of leasing, drilling, producing and operating a well or unit. After royalties 

are paid, the working interest also entitles its owner to share in production revenues with other working 

interest owners, based on the percentage of working interest owned. Working interest is not royalty; mineral 

rights owners who do not have working interests do not contribute to the costs of production. 
Part D. Supporting Information 

Section 2: Definition of Key Terms CBM Questionnaire 

D-9

Workover, Stimulation, or Recompletion—Major, intermittent tasks. Workovers are major maintenance or 

remedial treatments on a well. Well stimulation includes fracturing, for example, either performed initially or 

later in the productive life of the well. Recompletion is a process undertaken to restore the productivity of a 

well, including to complete a well in a new stratum or strata. 

Zero Discharge—Disposal of produced water other than by direct discharge to surface water or by indirect 

discharge to a POTW. Zero discharge does not allow for periodic or infrequent discharges attributed to 

activities such as maintenance, blowdown, or system purges. Examples include evaporation, underground 

injection, contract hauling, and/or water reuse. 
Part D. Supporting Information 

Section 3: Small Business Definitions and NAICS Identification CBM Questionnaire 

D-10

SECTION 3: SMALL BUSINESS DEFINITIONS AND NAICS IDENTIFICATION 

SBA allows small businesses to self-certify (subject to challenges, if they arise), which means that if you 

classify yourself as a small business, EPA will assume you have made this designation in good faith and will 

accept this designation. 

The Small Business Administration (SBA) defines small businesses in the following way: 

“The Small Business Act states that a small business concern is "one that is independently owned 

and operated and which is not dominant in its field of operation." The law also states that in 

determining what constitutes a small business, the definition will vary from industry to industry to 

reflect industry differences accurately. SBA's Small Business Size Regulations implement the Small 

Business Act's mandate to SBA. SBA has also established a table of size standards, matched to 

North American Industry Classification System (NAICS) industries.” 

The following table lists NAICS codes that are likely to be common among CBM operators. It also lists the 

current SBA definitions of small business for each of these likely NAICS codes. If, for any reason, you are not 

certain of your NAICS, the following website can be accessed using a key word search: 

http://www.census.gov/naics/2007/index.html; alternatively, you can use 

http://www.census.gov/naics/2007/NAICOD07.HTM, if you prefer to scroll through the definitions by type of 

industry. Note that clicking on the NAICS codes provides a definition of the industry in question. 

If you do not see an applicable NAICS in this table, you can refer to SBA’s Table of Size Standards, 

accessible at http://www.sba.gov/idc/groups/public/documents/sba_homepage/serv_sstd_tablepdf.pdf. 

Alternatively, if you prefer, you can contact the EPA help line for assistance. 

NAICS Name of Industry SBA Small Business Size 

Standard 

211xxx Oil and Gas Extraction ≤500 employees 

21211x Coal Mining ≤500 employees 

213111 Drilling Oil and Gas Wells ≤500 employees 

213112 Support Activities for Oil and Gas Operations ≤$6.5 million annual revenues 

213113 Support Activities for Coal Mining ≤$6.5 million annual revenues 

22111x Electric Power Generation <4 million mW-hrs/year 

221112 Fossil Fuels Electric Power Generation <4 million mW-hrs/year 

22112x Electric Power, Transmission, Control and Distribution <4 million mW-hrs/year 

22121x Natural Gas Distribution ≤500 employees 

32411x Petroleum Refineries ≤1,500 employees 

486110 Pipeline Transportation of Crude Oil ≤1,500 employees 

486210 Pipeline Transportation of Natural Gas ≤$6.5 million annual revenues 

The size standards are not the only standards that apply, however. SBA further defines small business in 

such a way that any business concern that is affiliated with a large business or, in many cases, a foreign firm 

cannot be considered a small business. SBA defines affiliation as: 

a. General Principles of Affiliation. 

i. Concerns and entities are affiliates of each other when one controls or has the power 

to control the other, or a third party or parties controls or has the power to control 

both. It does not matter whether control is exercised, so long as the power to control 

exists. 
Part D. Supporting Information 

Section 3: Small Business Definitions and NAICS Identification CBM Questionnaire 

D-11

ii. SBA considers factors such as ownership, management, previous relationships with 

or ties to another concern, and contractual relationships, in determining whether 

affiliation exists. 

iii. Control may be affirmative or negative. Negative control includes, but is not limited to, 

instances where a minority shareholder has the ability, under the concern's charter, 

by-laws, or shareholder's agreement, to prevent a quorum or otherwise block action 

by the board of directors or shareholders. 

iv. Affiliation may be found where an individual, concern, or entity exercises control 

indirectly through a third party. 

v. In determining whether affiliation exists, SBA will consider the totality of the 

circumstances, and may find affiliation even though no single factor is sufficient to 

constitute affiliation. 

Examples of affiliation would include a subsidiary of a large firm, a firm owned 50 percent or more by a large 

firm, and a joint venture by a small firm and a large firm. Even if the joint venture itself meets size standards, 

this affiliation would render the joint venture a large firm. However, if two small firms, each of which meets 

SBA size standards, join in a joint venture, the joint venture is also considered a small firm if it meets size 

standards. Another example of affiliation is a business concern that has as a corporate officer a person who is 

a corporate officer of a large firm. Small firms associated with large venture capital firms or investment firms 

through their investments in the small firm, however, are not considered affiliated.