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# Coalbed Methane Industry Detailed Questionnaire

INSTRUCTION GUIDE

Instructions for Completing the Questionnaire

Please read all instructions.

Contents:

• Part I – EPA’s Purpose for Collecting the Data

• Part II – Duty to Respond Within 60 Days

• Part III – Filing for An Extension

• Part IV – Claiming Business Information to be Confi dential

• Part V – Contacting Us

• Part VI – Returning the Detailed Questionnaire2



### Part I – EPA’s Purpose for Collecting the Data

The U.S. Environmental Protection Agency (EPA) is c onducting this survey as part of its annual review of existing effluent guidelines, which is re quired by the Clean Water Act (CWA) sections 301(d) and 304(b). As part of this review, EPA is c ollecting information about coalbed methane (CBM) extraction operations as part of its effort t o determine whether to initiate a rulemaking to potentially revise the effluent guidelines for the Oil and Gas Extraction Point Source Category (40 CFR Part 435) to include limits for pollutants disc harged in CBM produced water. A screener survey was used to ensure EPA had the appropriate c ontact information and to provide sufficient information to stratify and select a sample of oper ators and “projects” (defined as a well, group of wells, lease, group of leases, or some other recogn ized unit that is operated as an economic unit when making production decisions) for the detailed questionnaire. The screener survey was completed in July 2009. The detailed questionnaire requests both technical and financial and

economic data. The technical data collected will be used to determine the characteristics of CBM produced water, potential environmental impacts, ex isting management practices, 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 econom ic impacts of potential technology and beneficial use options for CBM produced water. This instructi on guide is designed to provide guidance for completion of the detailed questionnaire only.



### Part II – Duty to Respond Within 60 Days

EPA is conducting this data collection under the au thority of Section 308 of the CWA (Federal Water Pollution Control Act, 33 U.S.C. Section 1318 ). You must respond to this questionnaire within 60 days of receiving it. Failure to respond, late filing, or failure to comply with the instructions may result in criminal fines, civil pe nalties, and other sanctions, as provided by law.

The public reporting and recordkeeping burden for t his collection of information is estimated to average 80 hours per response. Burden means the tot al time, effort, or financial resources expended by persons and the Federal Agency to generate, main tain, retain, or disclose or provide information.

This includes the time needed to review instruction s, develop, acquire, install, and utilize technology and systems for the purposes of collecti ng, validating, and verifying information, processing and maintaining information, and disclos ing and providing information; adjust the existing ways to comply with any previously applica ble 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 req uired to respond to, a collection of information unless it displays a currently valid OMB control nu mber.

To comment on the Agency’s need for this informatio n, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has establishe d a public docket for this ICR under Docket ID No. EPA-HQ-OW-2006-0771, which is available for pub lic viewing at the Water Docket in the EPA Docket Center (EPA/DC), EPA West, Room B102, 13 01 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.,3

Monday through Friday, excluding legal holidays. Th e telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Wa ter Docket is (202) 566-2426. An electronic version of the public docket is available through t he federal data management system (FDMS) at http://www.regulations.gov. Use FDMS to submit or v iew 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 commen ts 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 correspon dence.



### Part III – Filing for an Extension

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 Questionnaire 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 Wa ter 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-c ase basis. Submittal of an extension request to

EPA does not

alter the due date of your questionnaire unless an d until EPA agrees to the extension

and establishes a new date.



### Part IV – Claiming Business Information to be Confi dential

If no business confidentiality claim accompanies th e information when it is received by EPA, EPA may make the information available to the publi c without further notice.

Regulations governing the confidentiality of busine ss information are contained in the Code of Federal Regulations (CFR) at Title 40 Part 2, Subpa rt B. You may assert a business confidentiality claim covering part or all of the information you s ubmit, other than effluent data and information or data that is otherwise publicly available, as descr ibed in 40 CFR 2.203(b):

“(b) Method and time of asserting business confidentiali ty claim. A business which is submitting information to EPA may assert a business confidentiality claim covering the information by placing on (or attachin g to) the information, at the time it is submitted to EPA, a cover sheet, stamped or typed legend, or other suit able form of notice complying language such as ‘trade secret, ’ ‘proprietary,’ or ‘company confidential.’ Alleged ly confidential portions of otherwise non-confidential documents should be clearly identified by the busi ness, and may be submitted separately to facilitate identific ation and handling by EPA. If the business desires confidential treatment only until a certain date or until the occurrence of a certain event, the notic e should so

state.”

You may claim as confidential all information inclu ded in the response to a question by checking the Confidential Business Information (CBI) box nex t to the question number. Alternatively, all4

questions marked with a CBI check box may be claime d confidential by checking the box on page iii of the detailed questionnaire . If you do not check this box, any individual resp onse where

“CBI” is NOT checked will be considered nonconfidential. Note t hat you may be required to justify any claim of confidentiality at a later time. Note also that facility effluent data are not eligible f or 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 publiclyavailable 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 supportin g the results of the CBM study.

Information covered by a claim of confidentiality w ill 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 Unit ed States concerned with implementing the CWA. 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 w ill be made available to the following EPA contractors and subcontractors to enable them to pe rform the work required by their contracts with

EPA.

EPA Contract No. Contractor Name(s)

68-C-02-095 Eastern Research Group, Inc.
EP-C-07-029 PG Environmental, LLC, Eastern Research Group, Inc.

EP-C-05-030 Battelle
GS-10F-0209P Advanced Resources International, Inc.

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 affect ed 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 issu e must be submitted in writing along with your completed survey.



### Part V – Contacting Us

Frequently asked questions regarding the detailed q uestionnaire can be found on the EPA Website

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

.

If you would like an electronic version of the deta iled questionnaire, it is available on the EPA

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

.

EPA has contracted with two private firms, PG Envir onmental and Eastern Research Group (ERG), to operate a telephone and electronic mail helpline to assist respondents with any questions or concerns about the detailed questionnaire. You will receive a reply within 1 business day of contacting the helpline. Appointments for scheduled support can also be requested over the helpline.5

A conference call with ERG economic staff and PG en gineering staff will be scheduled to obtain assistance answering questions on all parts of the survey. Requests for appointments will be handled within 1 week of contacting the helpline:

CBM Helpline: 1-800-864-9230

Internet Electronic Mailing Address: cbmdetailed@pgenv.com



### Part VI – Returning the Detailed Questionnaire

After you have completed the detailed questionnaire , please return it to:

U.S. Environmental Protection Agency CBM Industry Questionnaire c/o PG Environmental, LLC 570 Herndon Parkway

Suite 500 Herndon, VA 20170