This document was developed  for  the  Proposed  Mandatory GHG  Reporting Rule.
For the final document,  please visit  the  final Mandatory Reporting  of
Greenhouse  Gases Rule.
Suppliers  of Coal
                                                                                          United Slates
Proposed Rule: Mandatory Reporting of Greenhouse Gases                           Environmental Protection


Under the proposed Mandatory Reporting of Greenhouse Gases (GHGs) rule, all suppliers of coal (as
defined below) would report emissions associated with the complete combustion or oxidation of the coal
that they place into commerce. Coal suppliers would collect data on their products ; calculate the
potential GHG emissions associated with these products; and follow the specified procedures for
ensuring data quality, amending missing data, and meeting recordkeeping and reporting requirements.


Coal suppliers that operate coal mines should review the requirements of 40 CFR part 98,  subpart FF
(Underground Coal Mines) to determine if they would also report emissions from underground coal
mines.

How Is This Source Category Defined?

Under the proposal, suppliers of coal are defined as:

    •    Coal mines, including any coal mine that is categorized as active by the Mine Safety and Health
        Administration (MSHA) and produces coal within the United States during the reporting year, regardless of
        the rank of coal produced (e.g., bituminous, sub-bituminous, lignite, anthracite).
    •    Coal importers, including any U.S. coal mining company, wholesale coal dealer, retail coal dealer, or
        other organization that imports coal into the United States. An "importer" is the person primarily liable for
        the payment of any duties on the merchandise or an authorized agent acting on the importer's behalf.
    •    Coal exporters, including any U.S. coal mining company, wholesale coal dealer, retail coal dealer, or other
        organization that exports coal from the United States.
    •    Waste coal reclaimers, meaning any U.S. facility that reclaims or recovers waste coal from previous
        mining operations and sells or delivers the coal to an end-user.

What GHGs Would  Be Reported?

The proposal calls for suppliers to report the estimated carbon dioxide (CO2) emissions that would result from the
complete combustion or oxidation of coal supplied during the calendar year.

How Would GHG Emissions Be Calculated?

Under the proposal, CO2 emissions would be estimated based on measurements of the amount of coal produced and
a determination of the mass fraction of carbon in coal. Several different methods can be used to estimate mass
fraction depending on the size and nature of the operation:

    •    Coal mines producing more than 100,000 short tons of coal annually would calculate the annual weighted
        average mass fraction of carbon in the coal  with one of two methods: 1) daily measurements of carbon in
        the coal, or 2)  a statistical relationship between the carbon content of coal and the gross calorific value
        (GCV). The statistical relationship between carbon content and GCV (also known as higher heating value)
        must be established by each coal mine based on daily measurements of the gross GCV of the coal and a
        monthly measurement of carbon in the coal.
    •    Coal mines producing less than 100,000 short tons of coal annually would calculate the annual weighted
        average mass fraction of carbon in coal either by : 1) using the same methods used by coal mines producing
March 2009                                      1                               EPA-430-F-09-011

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This document  was  developed  for the Proposed  Mandatory GHG  Reporting Rule.
For the final  document,  please  visit the  final Mandatory Reporting  of
Greenhouse Gases  Rule.

        more than 100,000 short tons, or 2) calculating an annual weighted average of daily measurements of the
        GCV and correlating it to a carbon default value provided in the rule.
    •   Coal exporters, coal importers, and waste coal reclaimers would calculate the mass fraction of carbon in
        coal using any of the methods used by coal mines, based on per shipment measurements in place of daily
        measurements, if preferred.

What Information Would Be Reported?

In addition to the information required by the General Provisions at 40 CFR 98.3(c), the proposal calls for each coal
mine owner or operator to report the following information for each mine:

    •   The name and MSHA identification number of the mine, and the name of the operating company.
    •   The total annual tons of coal produced by rank.
    •   The annual weighted-average carbon content of the coal as calculated.
    •   The carbon content or GCV measured daily and the coal volume measured daily.
    •   Annual estimated CO2 emissions associated with the volume of produced coal.

Coal importers would report the following information at the corporate level:

    •   The total annual tons of coal imported into the United States by rank and country of origin.
    •   Annual CO2 emissions associated with the volume of imported coal.
    •   The annual weighted-average carbon content of the coal as calculated.
    •   The carbon content or GCV measured per shipment and the coal volume measured per shipment.

Coal exporters would report the following information at the corporate level:

    •   The total annual tons of coal exported from the United States by rank and by coal-producing company and
        mine.
    •   Annual CO2 emissions associated with the volume of exported coal.
    •   The annual weighted-average carbon content of the coal as calculated.
    •   The carbon content or GCV measured per shipment and the coal volume measured per shipment.

Waste coal reclaimers would report the following information for each reclamation site:

    •   By rank, the total annual tons of waste coal produced or owned by each waste coal-producing mine or
        waste coal pile owned by the waste coal producer.
    •   Mine and state of origin if waste coal is reclaimed from mines that are no longer operating.
    •   Annual CO2 emissions associated with the volume of reclaimed waste coal.
    •   The annual weighted-average carbon content of the coal as calculated.
    •   The carbon content or GCV measured per shipment and the coal volume measured per shipment.

Any type of reporter that calculates the annual weighted-average of the carbon content in the coal from a statistical
relationship between carbon content and GCV (higher heating value) would also report the following information:

    •   All of the data used to construct the carbon content vs. British thermal units/pound (Btu/lb) correlation
        graph.
    •   Slope of the correlation line.
    •   The R-square (R2) value of the correlation.

For More Information

This series of information sheets is intended to assist reporting facilities/owners in understanding key provisions of
the proposed rule. However, these information sheets are not intended to be a substitution for the rule. Visit EPA's
Web site (www.epa.gov/climatechange/emissions/ghgrulemaking.html') for more information, including the
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This  document was  developed  for the  Proposed Mandatory  GHG Reporting  Rule.
For  the final document,  please  visit the final Mandatory Reporting of
Greenhouse  Gases  Rule.

proposed preamble and rule and additional information sheets on specific industries, or go to
 to access the rulemaking docket (EPA-HQ OAR-2008-0508). For questions that cannot be
answered through the Web site or docket, call 1-877-GHG-l 188.
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