TECHNICAL SUPPORT DOCUMENT
THE COAL SECTORS
PROPOSED RULE FOR MANDATORY REPORTING OF
GREENHOUSE GASES
Office of Air and Radiation
U.S. Environmental Protection Agency
January 28, 2009
-------
Table of Contents
1.0 I ntroduction 4
1.1 Purpose 4
1.2 Organization of this Report 4
2.0 Overview of the Coal Industry 5
2.1 The Role of Coal in the Economy 5
2.2 Emission Thresholds and the Coal Industry 6
2.3 Structure of the Coal Industry 9
3.0 Coal Sampling and Testing 20
3.1 ASTM Coal Testing Standards 21
3.2. Coal Sampling 22
3.3. Coal Weighing 27
3.4 National Coal Quality Inventory 27
4.0 Industry Federal Reporting Requirements 29
4.1 Coal Production 29
4.2 Coal Imports and Exports 31
4.3 Coal Distribution and Consumption 31
5.0 Data Gaps and Quality 35
5.1 Reporting Gaps in Industry Coverage 36
5.2 Quality Assurance and Control 36
APPENDIX 1 2007 U.S. COAL PRODUCTION BY COAL HOLDING COMPANIES 37
APPENDIX 2 Matrix of Federal Reporting Requirement on Coal 50
APPENDIX 3 Carbon Content at Given Level of Energy Content 52
-------
List of Exhibits
Exhibit 1. Coal Share of Primary Energy Consumption 5
Exhibit 2. Coal Consumption by End Use (Million Tons) 6
Exhibit 3. Threshold Analysis for Coal Mines 7
Exhibit 4. Flow of Coal Through the U.S. (Million Tons) 8
Exhibit 5. 2007 Coal Production by Coal-Producing Region 9
Exhibit 6. U.S. Coal Production by Coal Production Regions (Million Tons) 10
Exhibit 7. U.S. Coal Production by Type of Mining (Million Tons) 10
Exhibits. U.S. Coal Production by Coal Rank (Million Tons) 10
Exhibit 9. Summary Comparison of Major Coal Fields 11
Exhibit 10. Top 20 U.S. Coal Producers, 2007 12
Exhibit 11. Coal Production Distribution by Number of Holding Companies 12
Exhibit 12. Coal Production Distribution by Number of Holding Companies 13
Exhibit 13. 2007 Coal Mine Production 13
Exhibit 14. Coal Producers - WPRB 14
Exhibit 15. Top 20 CAPP Coal Producers, 2007 14
Exhibit 16. Production Distribution of CAPP Coal Producers, 2007 15
Exhibit 17. CAPP Production Distribution by Number of Holding Companies 15
Exhibit 18. All Waste Coal Producers, 2007 16
Exhibit 19. U.S. Coal Imports by Country of Origin (Million Tons) 17
Exhibit 20. U.S. Coal Imports by Electric Utilities (Million Tons) 17
Exhibit21. U.S. Coal Imports by Customs District (Million Tons) 18
Exhibit 22. U.S. Coke Imports by Country of Origin (Million Tons) 18
Exhibit 23. U.S. Coal Exports (Million tons) 19
Exhibit24. U.S. Coal Exports by Customs District (Million tons) 19
Exhibit 25. 2006 Exports of US Coal by Origin 19
Exhibit 26. List of U.S. Coal Exporters 20
Exhibit 27. Carbon Content vs. Energy Content 28
Exhibit 28. Carbon Content versus Energy Content - Individual State Samples 28
-------
1.0 Introduction
1.1 Purpose
This is one of three in a series of reports to identify the current federal reporting requirements of
the fuel suppliers, namely petroleum products, coal and natural gas with respect to the
production, imports and throughput of fuels. The analysis here is part of a larger effort to
develop guidelines for mandatory reporting requirements for greenhouse gases (GHGs). In
December 2007, Congress enacted an omnibus appropriations bill that directs EPA to develop
and publish a rule requiring measurement and reporting of GHG emissions above appropriate
thresholds in all sectors of the economy. The bill mandates that EPA publish a proposed rule
within nine months and a final rule within 18 months. Understanding what information about
volumes that fuel suppliers already generate and report is a first step in developing mandatory
GHG reporting requirements.
This report focuses on companies and facilities in the coal industry, particularly coal mines, coal
imports, coal exports and waste coal reclaimers. The emphasis is on: (1) Current levels of coal
production, imports, and exports, (2) Threshold analysis, (3) Correlation analysis between coal
higher heat value and carbon content, (4) Coal sampling, testing and weighing standards. The
report also addresses questions of granularity of data, facility definitions and boundaries,
frequency of reporting, validation of reported data, and how data gaps are managed. Finally,
the report develops conclusions about the coverage of the data that are reported, key gaps in
the data, and questions about data verification and quality assurance and control.
1.2 Organization of this Report
To provide context for the reporting requirements of the coal sectors, in section 2, we first
provide an overview of the coal industry. We begin that with a statistical summary of coal
production, imports, exports and consumption. We follow this with a discussion of the coal
industry participants, with brief discussions of each, focusing on the types of information
generated in both the natural course of business as well as information reported to federal
government agencies. We also identify the kinds of information typically reported to state
government agencies. Finally, we discuss the regulatory framework for the industry's
participants.
Section 3 is where we describe the current federal reporting requirements of the industry. It is
divided into three subsections addressing coal mines, imports, and exports.
In Section 4, we present our conclusions about overall gaps in the reporting requirements, as
well as other issues relevant to data coverage. We also present our findings on the quality
control and reliability of the data reported.
-------
2.0 Overview of the Coal Industry
2.1 The Role of Coal in the Economy
Coal consumption in the U.S. totaled 22.8 quadrillion Btu (1,129 million short tons) in 2007,
accounting for 22.4 percent of total energy consumption in the U.S. (see Exhibit 1). More coal
energy is used in the US than any other form except petroleum, though natural gas is a very
close second. Coal energy usage is especially large when one considers that coal is not used
for transportation, and very little is used in the residential and commercial sectors i.e. the non
industrial sectors.
The electric utility sector is the largest coal consuming sector by a very wide margin.
Approximately 93 percent of coal consumed domestically in 2007 or over 1 billion tons of coal
was by electric utilities (see Exhibit 2). Coal-fired electric generation accounted for 50 percent
of total power generation in the same year. Coal generation has actually modestly increased in
share of generation over time even as consumption of electricity has more the doubled.
Between 1971, and 2007, the share of coal generation from 45 percent to 50 percent, while the
oil share fell from 12 percent to less than 1 percent. Thus, even though over the past fifty to
hundred years, coal has been replaced in nearly all space heating and transportation
applications, total coal usage has greatly increased as a result of its leading role in the strongly
growing electric power sector.
Non-power coal users include coke plants and other industrial facilities which consumed 23
million tons and 56 million tons in 2007, respectively. Coke is used to produce steel.
Exhibit 1. Coal Share of Primary Energy Consumption
Nuclear
8.3%
Renewable
6.7%
Petroleum
39.2%
Natural Gas
23.3%
Source: Energy Information Administration (EIA), Annual Energy Review 2007
- U.S. Primary Energy Consumption by Source and Sector, 2007
-------
Exhibit 2. Coal Consumption by End Use (Million Tons)
Total Consumption
Electric Power
Coke Plants
Other Industrial
Residential and Commercial
2004
1,107.3
1,016.3
23.7
62.2
5.1
2005
1,126.0
1,037.5
23.4
60.3
4.7
2006 2007
1,112.3 1,128.8
1,026.6 1,046.4
23.0 22.7
59.5 56.4
3.2 3.2
Source: Energy Information Administration, Annual Coal Reports and 2007 Quarterly Coal Reports.
2.2 Emission Thresholds and the Coal Industry
The EPA is considering rules for monitoring requirements on facilities and companies in the coal
industry. One element of the rules will be establishing thresholds or minimum size requirements
for reporting entities tied to the annual emissions derived from the volume of the facilities and
companies. The thresholds being considered are 1,000, 10,000, 25,000 and 100,000 metric
tonnes per year of CO2. For coal suppliers, these thresholds would be applied to the CO2
emissions that would result from complete combustion or oxidation of the coal produced or
supplied into the U.S. economy, rather than the actual GHG emissions for the individual facilities
or companies. Converting these thresholds into the equivalent of coal tonnages1 yield the
following values:
1,000 metric tones = 532 short tons of coal
10,000 metric tonnes = 5,321 short tons of coal
25,000 metric tonnes = 13,303 short tons of coal
100,000 metric tones = 53,211 short tons of coal
These thresholds would not result in a significant reduction in the number of coal facilities and
companies that would be subject to monitoring, considering the following:
• According to the MSHA, there were 1,346 coal mines producing more than 532
tons in 2007. This covered 99 percent of U.S. active coal mines. There were
867 mines or 64 percent of all active mines producing at or above the 53,211
tons annual production level.
• Thus, we can expect that about 64 percent of all active coal mines would be
covered by a 100,000 metric tones threshold. At the lower threshold 99 percent
of all active coal mines would be covered by the rule. See Exhibit 3.
1 Carbon content is found using the weighted average of CO2 (Ibs/MMBtu) from EIA Table FE4 along with
the heat content (MMBtu/ton) and production (tons) from the 2007 MSHA database. The molecular mass
ratio of carbon to CO2 (12/44) is then used to find carbon content from the derived CO2 content (4,143
Ibs/short ton).
-------
Exhibit 3. Threshold Analysis for Coal Mines
Threshold
Level
mtCO2e/yr
1,000
10,000
25,000
100,000
Total 2007
National
Emissions
(million
mtCO2e/yr)1
2,153
2,153
2,153
2,153
Total 2007
Number of
Facilities in
the United
States
1,365
1,365
1,365
1,365
Emissions
Covered
Million
mtCO2e/
Yr2
2,146
2,146
2,144
2,130
Percent
99.7%
99.7%
99.6%
98.9%
Facilities
Covered
Number of
Facilitie3
1,346
1,237
1,117
867
Percent of
Facilities
99%
91%
82%
64%
Source: EIA Table FE4 and 2007 MSHA database.
Notes:
(1) 2007 National Emissions (mtCO2e) = 2007 Production x US Weighted Average CO2 content (4,143 Ibs/short ton) / (2204.6
Ibs/mt).
(2) Emissions covered (mtCO2e) = sum of coal CO2 emissions for all facilities with mtCO2e production greater than the
threshold.
(3) Facilities covered = total number of facilities with mtCO2e production greater than the threshold.
No threshold analysis is performed for coal exporters, importers and waste coal reclaimers
because we could not find facility-specific data on coal volumes. The number of facilities and
companies engaging in these activities is relatively small (see discussions in Section 2.0). In
2007, the 14 companies that reported coal exports in 2007 all owned coal mines that will be
required to report under the proposed rule. Furthermore, coal importers are typically electric
utilities, steel companies, and industrial plants that are also required to report under the rules for
Stationary Source. A total of 14 companies or 16 facilities reported the reclamation of coal in
2007.
Exhibit 4 presents the flow of coal through the U.S.
-------
Exhibit 4. Flow of Coal Through the U.S. (Million Tons)
Coal Million Tons, 2006
CensusIM145
EIA-920, EIA-5, EIA-3, EIA-6A
Colombia
Venezuela
Indonesia
Canada
Other
TOTAL
25.340
4.198
3.147
2.048
1.513
36.246
69.9%
11.6%
8.7%
5.7%
4.2%
EIA-6A, EIA-3, EIA-5
MSHA 7000-2
US Domestic Supply:
1,113.103
Appalachia
Interior
Western
Refuse
TOTAL
391.159
151.389
619.449
0.752
1162.75
33.6%
13.0%
53.3%
0.1%
Europe
Canada
S America
Asia
Africa
Other
TOTAL
Rail:
Truck:
Barge:
Conveyor:
Other:
799.463
122.538
103.314
77.983
19.307
71.2%
10.9%
9.2%
6.9%
1.7%
42.642
Net stock incrc
EIA-906/920, EIA-5, EIA-3, EIA-6A, Ell
TOTAL 1,122.605
Census EM 545 Note: Does not equal production total
20.804
19.890
4.925
2.008
1.380
0.640
49.647
41.9%
40.1%
9.9%
4.0%
2.8%
1.3%
-------
2.3 Structure of the Coal Industry
2.3.1 Coal Production
The U.S. is the world's second largest coal producing and consumption country, only next to
China. Several key features of this industry include:
• In 2006, U.S. coal mines produced about 1.2 billion tons of coal of which 49
percent was bituminous, 44 percent was sub-bituminous and the rest was lignite
and anthracite.
• Of the total coal produced, 69 percent was mined from surface mines and the
remaining 31 percent from underground mines.
• Although 90 percent of the U.S. coal reserves are concentrated in 10 states, coal
is mined in 27 states. Nearly 60 percent of the total coal produced in the U.S.
came from west of the Mississippi (See Exhibits 5 through 8). Specifically, one-
third of the total production came from the Appalachian region (primarily Eastern
Kentucky, West Virginia and Southern Appalachian coals, but also from northern
Appalachia), over one-half of the production came from the Western region
(nearly three-fourths of which was exclusively from Wyoming), and the remaining
13 percent came from the Interior region (primarily from Texas, Indiana, Illinois
and Western Kentucky).
• On state-by-state basis, Wyoming is the single largest coal producer and
accounted for nearly 40 percent of the U.S. total coal production in 2007.
Exhibit 5.
2007 Coal Production by Coal-Producing Region
U.S. Total: 1,145.6 Million Short Tons
Source: Energy Information Administration
-------
Exhibit 6. U.S. Coal Production by Coal Production Regions (Million Tons)
Year
2002
2003
2004
2005
2006
2007
U.S. Coal
Production1
1,094.3
1,071.8
1,112.1
1,131.5
1,162.7
1,145.6
Appalachia
396.2
376.1
389.9
396.7
391.2
377.1
Interior
146.6
146.0
146.0
149.2
151.4
146.6
Western
550.4
548.7
575.2
585.0
619.4
621.0
Refuse
Recovery
1.0
1.0
1.0
0.7
0.8
0.8
Source: Energy Information Administration, Annual Coal Reports.
Exhibit 7. U.S. Coal Production by Type of Mining (Million Tons)
Year
2002
2003
2004
2005
2006
2007
U.S. Coal1
Production
1,094.3
1,071.8
1,112.1
1,131.5
1,162.7
1,145.6
Underground Mining
357.4
352.8
367.6
368.6
359.0
351.8
Surface Mining1
736.9
719.0
743.6
762.1
803.0
793.7
Includes a small amount of refuse coal recovery.
Source: Energy Information Administration, Annual Coal Reports.
Exhibit 8. U.S. Coal Production by Coal Rank (Million Tons)
Year
2002
2003
2004
2005
2006
2007
U.S. Coal
Production1
1,094.3
1,071.8
1,112.1
1,131.5
1,162.7
1,145.6
Bituminous1
571.3
540.9
561.5
571.2
561.6
542.8
Sub-
bituminous
438.4
442.6
465.4
474.7
515.3
523.7
Lignite
82.5
86.4
83.5
83.9
84.2
78.6
Anthracite
1.2
1.2
1.7
1.7
1.5
1.6
Includes a small amount of refuse coal recovery.
Source: Energy Information Administration, Annual Coal Reports
Major coal fields include Central Appalachia (CAPP), Northern Appalachia (NAPP), Illinois Basin
(ILB) and Powder River Basin (PRB). The great majority of coal production from PRB is from
Wyoming mines (WPRB).
Coal quality varies among major coal regions. For example, the energy content for CAPP is
between 12,000 Btu/Lb and 12,500 Btu/lb while WPRB's energy content is lower at between
8,400 Btu/Lb and 8,800 Btu/Lb. The sulfur content of WPRB coal is lower at 0.35% than 0.6%-
1.0% for CAPP. WPRB coal also has a very high moisture content of 30% compared to about
10% for CAPP coal. Exhibit 9 presents a summary comparison of major coal fields.
WPRB coal mining began in the 1970's when coal-fired power plants were required to meet
increasingly stringent air quality standards. This has caused the coal production pattern to shift
from the eastern coal fields to the west during the past 30 years.
10
-------
Exhibit 9. Summary Comparison of Major Coal Fields
Coal Fields
Coal Rank
Type of Mining
Number of Mines
Operating
2006 Production
(MM Tons)
Productivity
(Tons per Hour)
Coal Qualify:
Btu/Lb
% Sulfur
Ash
Moisture
WPRB
Sub-bituminous
Surface
13
431 .31
36.24
8,400-8,800
0.35%
10%
30%
CAPP
Bituminous
Surface and
Underground
807
236.1
2.89
12,000-12,500
0.6%- 1%
8%
10%
ILB
Bituminous
Surface and
Underground
76
95.1
4.07
10,500-11,500
1.5% -3. 5%
8%
10%
Source: Gillette News Record, Casper Star Tribune, and State Mine Inspector of Wyoming
2.3.2 Coal Producers
According to the Mine Safety and Health Administration (MSHA), a total of 1,365 coal mines are
producing in the U.S. in 2007. Of which 1,049 mines are located in Appalachia. Surface mines
account for 57% of the number of mines operating. However, some of these mines are huge.
There are only a total of 13 surface mines operating in WPRB with annual production of 436.5
million tons. The two largest mines in WPRB, Black Thunder (Arch Coal) and North
Antelope/Rochelle (Peabody Coal) produce about 90 million tons each annually. The annual
WPRB coal production per mine averages about 33 million tons or more than 100 times the
average annual production at Appalachian coal mines of 300,000 tons.
Although the cost of transporting PRB coal is high because of long distance to its targeted utility
customers, the mining cost is extremely low compared to mines in the East. Productivity at PRB
mines averaged 36.24 tons per man-hour in 2006 as compared to an average of 3.13 per man-
hour in Appalachia mines. The ability to compete economically has allowed PRB coal to
penetrate into markets as far as the state of Georgia where traditionally CAPP coal has been
consumed at electric utilities.
According to EIA, 2007 coal production shows a slight decrease to 1.145 billion tons from 1.16
billion produced in 2006. There is some discrepancy between coal production data reported by
EIA and that by MSHA (Mine Safety and Health Administration). For example, 2007 U.S. coal
production reported by MSHA is 1.142 billion tons or 3.42 million tons less than EIA.
According to coal production reports submitted to MSHA, the top 20 coal holding companies
produced a total of 897.6 million tons in 2007 or nearly 80 percent of the U.S. coal production.
Peabody Coal Company is the largest coal producer in the U.S. with nearly 200 million tons
production or 17.4 percent of the U.S. total in 2007 (see Exhibit 10). A complete list of
2007 coal production by holding company is provided in Appendix 1. This list is compiled based
on the mine ownership list available from MSHA production reports.
11
-------
Exhibit 10. Top 20 U.S. Coal Producers, 2007
Company
Peabody Energy
Rio Tinto
Arch Coal Inc
Foundation Coal Corporation
CONSOL
AT. Massey Coal
North American Coal
Peter Kiewit Sons
Westmoreland Coal
Robert E Murray
Alliance Coal
TXU
Alpha Natural Resources
International Coal Group
BMP Billiton
Magnum Coal
Chevron
James River Coal
Ashland
Jeffery A Hoops
Total Top 20
U.S Total Production
Production (Million Tons)
198.7
134.4
116.6
71.8
61.3
38.3
34.1
30.8
30.4
27.6
23.9
23.9
19.9
18.7
15.4
13.7
12.0
10.8
10.5
8.4
897.6
1,142.2
% of Total U.S. Production
17.4%
1 1 .8%
10.2%
6.3%
5.4%
3.4%
3.0%
2.7%
2.7%
2.4%
2.1%
2.1%
1 .7%
1 .6%
1 .4%
1 .2%
1 .0%
0.9%
0.9%
0.7%
79%
100.0%
Source: MSHA
A total of 611 holding companies reported coal production to MSHA in 2007. The average 2007
coal production per holding company is 1.87 million tons while the median is only about 61,000
tons. This is because 46 percent of the total number of companies reported production less
than 50,000 tons. Most of these small companies are located in Appalachia. Exhibits 11 and 12
present a distribution of number of holding companies by production range.
Exhibit 11. Coal Production Distribution by Number of Holding Companies
8 250
'c
200
150
£
8
•5
j> 100
i so
JZL
,
<$>
2007 Production (tons)
12
-------
Exhibit 12. Coal Production Distribution by Number of Holding Companies
Annual Tonnage
> 50 Million
30 to 50 Million
20 to 30 Million
10 to 20 Million
5 to 10 Million
1 to 5 Million
500 Thousand to 1 Million
250 to 500 Thousand
100 to 250 Thousand
50 to 100 Thousand
< 50 Thousand
Total
Number of Companies
5
3
4
7
12
52
26
55
94
70
283
611
Number of Companies as a
Percentage of the Total
0.8%
0.5%
0.7%
1.1%
2.0%
8.5%
4.3%
9.0%
15.4%
1 1 .5%
46.3%
Source: MSHA
According to 2007 MSHA data, a total of 1,333 mines or 98 percent of all active coal mines
produced more than 1,000 tons per year. The combined total coal production from these mines
accounted for 99.7 percent of all U.S. coal production. More than half of all U.S. coal mines
produced more than 100,000 tons in 2007, accounting for 97.9 percent of all U.S. production.
These mines are designated as large mines in the rule. It is assumed that coal resources in
large mines may come from multiple coal seams and that quality of these coals may vary.
Furthermore, It is assumed that coal sampling and testing are performed on a daily basis at
large mines, sometimes at a laboratory on site. Therefore, we require in the rule daily coal
sampling and testing. On the other hand, it is assumed that smaller mines with annual
production of less than 100,000 tons have limited resources to conduct coal sampling and
testing on a daily basis. Therefore, we provide a testing and sampling alternative to smaller
mines.
Exhibit 13. 2007 Coal Mine Production
Tons/year
1,000
10,000
25,000
100,000
Total U.S.
Production (OOO's
Short Tons)
1,145,567
1,145,567
1,145,567
1,145,567
Total
Number of
U.S. Mines
1,365
1,365
1,365
1,365
Production
Thousands of
Short Tons
1,142,135
1,141,230
1,138,677
1,121,552
percent
99.7%
99.6%
99.4%
97.9%
Mines
Number
of Mines
1333
1156
1004
706
Percent of
Total US
98%
85%
74%
52%
Source: EIA, MSHA.
On a regional basis, the coal industry also exhibits a similar concentration pattern. There is a
greater number of mines operating in Appalachia and Interior regions than in PRB and the mine
size is also much smaller on average than PRB mines. There are only 13 mines operating in
WPRB and therefore, the concentration is greater. Wyoming Powder River Basin 2007 mine
production available from MSHA shows the level of concentration. As shown in Exhibit 14, the
top 4 companies produced approximately 400 million tons in WPRB, accounting for more than
90% of the region's total production in 2007. WPRB production was 38.2 percent of the 2007
U.S. coal production.
13
-------
Exhibit 14. Coal Producers - WPRB
Company
Peabody Energy
RTZ-CRA Group
Arch Coal Inc
Foundation Coal Corporation
Kiewit Petersons' Inc
Western Fuels Association
Black Hills Corp
Total WPRB Production
2007 Production (Million
Tons)
139.8
113.0
96.4
51.6
25.3
5.3
5.0
436.5
% of Total U.S. Production
32%
26%
22%
12%
6%
1%
1%
100%
Source: MSHA
CAPP produced a total of 217.4 million tons in 2007 or 19 percent of total U.S. production. The
top 20 companies accounted for 70 percent of this region's total production (see Exhibit 15).
Many of the top 20 companies are also major coal producers of other coal regions.
Exhibit 15. Top 20 CAPP Coal Producers, 2007
Company
A. T. Massey
Magnum Coal
Alpha Natural Resources
Jeffery A Hoops
International Coal Group
CONSOL
James River Coal
Arch Coal
Foundation Coal
Richard Gilliam
James H. Booth
TECO Energy
Clearwater Natural Resources
Wexford Capital
United Company
Ashland
Energy Coal Resources
James C. Justice
James O. Bunn
Alliance Resources partners
Total Top 20
CAPP Total Production
Production (Million Tons)
34.6
13.7
13.7
8.4
7.8
7.6
7.5
7.0
6.9
6.8
5.1
5.1
4.2
4.0
3.7
3.6
3.5
3.4
3.4
3.2
152.9
217.4
% of Total U.S. Production
15.9%
6.3%
6.3%
3.8%
3.6%
3.5%
3.4%
3.2%
3.2%
3.1%
2.4%
2.3%
1 .9%
1 .9%
1 .7%
1 .6%
1 .6%
1 .6%
1 .5%
1 .5%
70.3%
100.0%
Source: MSHA
The average company size in CAPP is small compared to the WPRB average. CAPP coal
companies produced an average of 768,300 tons in 2007 versus 62.4 million tons in WPRB.
More than 38 percent of the companies or 108 coal holding companies in CAPP produced less
than 50,000 tons in 2007 (see Exhibits 16-17). A. T. Massey alone produced more than 30
million tons and Magnum Coal and Alpha Natural Resources each produced more than 10
million tons in 2007.
14
-------
Exhibit 16. Production Distribution of CAPP Coal Producers, 2007
120 -,
ft 100
| 80
O 60
•5
fe 40
1 20
, , | |
x ^ ^
V^ IvP ^
\ <4
| |
«^ ^— ^— ^— J—
N &>
10 Million
5 to 10 Million
1 to 5 Million
500 Thousand to 1 Million
250 to 500 Thousand
100 to 250 Thousand
50 to 100 Thousand
< 50 Thousand
Total
Number of Companies
3
9
26
13
29
54
41
108
283
Number of Companies as a
Percentage of the Total
1.1%
3.2%
9.2%
4.6%
10.2%
19.1%
14.5%
38.2%
100.0%
Source: MSHA
2.3.3 Waste Coal Production
Waste coal is a byproduct of previous coal processing operations. It is usually composed of
mixed coal, soil, and rock (mine waste). Waste coal piles are located near mines that have
been abandoned for years. Some waste coal piles may have been accumulated since as early
as 1900. Examples of waste coal include fine coal, coal obtained from a refuse bank or slurry
dam, anthracite culm, bituminous gob, and lignite waste.
Waste coal can be burned for power generation, either as-is in unconventional fluidized-bed
combustors or partially cleaned by removing some extraneous noncombustible constituents.
Waste coal has very low energy content averaging only about half as much as newly produced
coal. Therefore, waste coal is generally consumed at power plants located in close vicinity of
15
-------
the waste coal facility so that transportation cost is kept at a minimum. High transportation cost
from long distance travel would render waste coal uneconomic. Most waste coal is transported
to end users by truck. It is assumed that sampling of coal is performed for each truck shipment.
According to EIA, waste coal production made up only 0.1% of total coal production in the U.S.
in 2007. However there has been increased interest in the use of waste coal for power
generation projects. Waste coal production has increased by 17% from 2004 to 2007, and the
total for the first three quarters of 2008 has already surpassed the total from 2007.
In 2007 more than half (60%) of waste coal is produced in Appalachia, specifically Pennsylvania,
East Kentucky, Alabama, Virginia, and Ohio. Two facilities in Missouri owned by James O Bunn
et al make up another 36% of all waste coal produced. EIA reported a total of 14 entities or 16
facilities engaging in waste coal reclamation in 2007 (see Exhibit 18).
Exhibit 18. All Waste Coal Producers, 2007
Company
James O Bunn et al
TECO Energy Inc
Alpha Natural Resources LLC
John P Matey
Five J's LLC et al
Drummond Company Inc
Phoenix Coal Corporation
Headwaters Inc
Beard Company
John A Kosky
Jeff Kinser
Richard M Oley
Eugene F Morton
Jim Hall et al
Total
Production
(Million Tons)
0.41
0.19
0.12
0.10
0.08
0.06
0.06
0.05
0.04
0.04
0.01
1
1
1
1.16
% of Total U.S. Waste
Coal Production
35.6%
16.3%
10.0%
8.7%
6.7%
5.3%
4.8%
4.7%
3.7%
3.1%
0.5%
0.4%
0.2%
0.0%
100.0%
Source: MSHA, EIA
1Lessthan 10,000 tons.
2.3.4 Coal Imports
Coal imports into the U.S. have increased 33% in 2006 over 2004, but the level of imports
remains low. The U.S. imported 36.3 million tons of coal in 2006. The great majority of this
imported coal or 82 percent came from South America. Colombia alone supplied 70 percent of
the coal imported into the U.S. in 2006 (see Exhibit 19). It followed by Venezuela, Indonesia
and Canada.
16
-------
Exhibit 19. U.S. Coal Imports by Country of Origin (Million Tons)
Country of Origin
Colombia
Venezuela
Indonesia
Canada
Russia
Australia
South Africa
Other
Total
2004
16.7
4.4
2.2
2.9
0.3
0.3
0.03
0.2
27.3
2005
21.2
3.7
2.5
2.0
0.4
0.2
0.1
0.4
30.5
2006
25.3
4.2
3.1
2.0
0.9
0.2
0.1
0.5
36.3
2007
26.9
3.4
3.7
2.0
0.1
0.07
-
0.2
36.3
Source: Energy Information Administration, Quarterly Coal Reports
Imports of coal from Colombia come from the country's largest mining operation, El Cerrejon
which is jointly owned by the Colombian state enterprise, Carbocol and Intercor, a subsidiary of
Exxon/Mobil Corp. The mine capacity since 2006 is 28 million metric tons per year with plans to
expand to 32 million metric tons by 2008. Coal is mined by surface mining method. More than
90 percent of El Cerrejon mine production is under long term contracts. Coal is transported via a
dedicated rail line to the Puerto Bolivar terminal for exports. The port is capable of handling
vessels up to 150,000 dwt (dead weight tons). El Cerrejon coal is marketed through a third
party company.
Most of the U.S. coal imports are steam coals for power generation. In 2007, electric utilities
reported coal imports of 30.7 million tons. Southern Company alone accounted for 44 percent
of the total (Note: Southern Company is the holding company for five operating companies:
Alabama Power, Georgia Power, Gulf Power, Mississippi Power and Savannah Electric &
Power.). As shown in Exhibit 20, eight investors-owned utilities (lOUs) and independent power
producers (IPPs) used a combined total of almost 27 million tons or 88 percent of the total
imported coal by electric utilities in 2007. Only the Independent Power Producers (IPPs)
reported the country of origin to EIA while the Investor Owned Utilities (lOUs) did not report this
information. According to EIA data, thirty seven entities reported imports of coal for the
generation of electricity.
Exhibit 20. U.S. Coal Imports by Electric Utilities (Million Tons)
Utility Name
Southern Company
Dominion Energy
Jacksonville Electric Authority
Progress Energy
PSEG
Virginia Electric and Power
Dynegy
Public Service Co of New Hampshire
Sub-Total
Other
Total Utility Imports
2007 Imports
13.4
3.3
3.1
2.4
1.6
1.3
1.0
0.8
26.9
3.8
30.7
% of Total Utility Imports
43.7%
10.6%
10.0%
7.9%
5.3%
4.2%
3.2%
3.0%
88%
12%
100%
Source: FERC Form 423, EIA Form 423, and EIA 906
17
-------
About a third of the total coal imports are moved through the Mobile port. In 2007, coal imports
were reported from 23 customs districts (see Exhibit 21). Eight customs districts reported coal
imports in volume greater than 1 million tons each.
In addition, the U.S. also imported 2.5 million tons of coke in 2007.
supplier of coke imports (see Exhibit 22).
China was the largest
Similar to domestic coal sales, international coal sales transactions are executed according to a
coal supply contract between the seller and the purchaser. In addition to contract terms and
coal prices, the contract specifies source of coal supply (specific mine of origin), coal quantity,
coal specification requirement (i.e., heat content, sulfur, ash, moisture, ash fusion temperature,
etc.), loading and unloading points, coal weighing, sampling and testing procedures. It also
spells out premiums and penalties when coal quality delivered is above or below coal
specification requirements. Coal is shipped by ocean vessels, and coal weighing and sampling
are performed at port of discharge for each shipment. In general, each coal sample is divided
into three parts and put into sealed containers with part one to the seller for testing. Part two of
the sample will go to the purchaser for testing by an independent laboratory and part three or
the referee sample would be retained for 90 days in case there is a disagreement between the
purchaser and seller testing results.
Exhibit 21. U.S. Coal Imports by Customs District (Million Tons)
Customs District
Mobile
Boston
Tampa
New Orleans
San Juan, PR
Charleston
New York
Pembina, ND
Portland, ME
Savannah
Philadelphia
Baltimore
Other
Total
2004
8.5
4.4
2.5
1.3
1.6
0.7
1.1
1.4
0.8
0.5
0.5
0.7
3.2
27.1
2005
10.0
4.9
2.3
1.0
1.7
1.4
1.1
1.4
1.1
0.9
0.8
0.7
3.2
30.5
2006
12.3
5.3
2.7
2.3
1.9
1.9
1.5
1.2
1.1
1.1
1.0
0.9
3.1
36.3
2007
12.6
5.3
3.6
2.3
1.9
1.4
1.1
1.1
0.9
0.6
0.7
0.1
4.6
36.3
Source: Energy Information Administration, Quarterly Coal Reports
Exhibit 22. U.S. Coke Imports by Country of Origin (Million Tons)
Country of Origin
China
Japan
Colombia
Canada
Porland
Ukraine
Other
Total
2004
4.1
0.9
0.1
0.1
0.6
0.6
0.4
6.9
2005
1.7
0.7
0.1
0.3
0.3
0.3
0.2
3.5
2006
2.7
0.8
0.1
0.1
0.4
0.0
0.1
4.1
2007
1.1
0.8
0.2
0.2
-
-
0.2
2.5
Source: Energy Information Administration, Quarterly Coal Reports
18
-------
2.3.5 Coal Exports
The U.S. also exported 59 million tons of coal to overseas destinations in 2007 (see Exhibit 23).
Of the total, 46 percent was steam coal and 54 percent metallurgical - i.e., used to produce
coke. Canada is the largest coal importer of U.S. coal, accounting for 31 percent of the total
U.S. exports. More than a third of U.S. coal exports were shipped through Norfolk terminals in
2007 (Exhibit 24).
Exhibit 23. U.S. Coal Exports (Million tons)
Destination
North America
South America
Europe
Asia
Oceania
Africa
Total
2004
18.8
4.8
15.2
7.5
0.0
1.7
48.0
2005
20.6
4.6
18.8
5.1
0.0
0.9
49.9
2006
20.5
4.9
20.8
2.0
0.0
1.4
49.6
2007
19.1
7.2
27.1
1.2
0.0
4.5
59.2
Source: Energy Information Administration, Quarterly Coal Reports
Exhibit 24. U.S. Coal Exports by Customs District (Million tons)
Customs District
Norfolk
Detroit
Mobile
Baltimore
Cleveland
New Orleans
Buffalo
Other
Total
2004
14.4
6.3
6.5
4.7
3.4
3.0
1.9
7.7
48.0
2005
15.1
8.6
7.3
5.0
3.2
1.9
2.1
6.7
49.9
2006
15.0
13.7
7.4
5.9
3.2
2.2
1.4
3.4
49.6
2007
21.6
13.2
7.4
7.9
2.3
3.9
1.4
1.5
59.2
Source: Energy Information Administration, Quarterly Coal Reports
As we can see in Exhibit 25, the Appalachian region produces about 83% of US exports, the
bulk of that being from the Central Appalachian region. Coal exports from the western region
are primarily from Wyoming. A total of 14 companies has been engaging in coal exporting
business in 2007 (Exhibit 26). When the list of coal exporters is compared with the top 20
producers in the Central Appalachian (CAPP) region (Exhibit 15) 9 out of those top 20 CAPP
producers are also coal exporters.
Exhibit 25. 2006 Exports of US Coal by Origin
Region
Northern Appalachia
Central Appalachia
Southern Appalachia
West
Other
Total U.S.
Tons
(OOO's)
10,597
22,201
6,024
7,356
568
46,746
%of
Total
U.S.
23%
47%
13%
16%
1%
100%
Source: 2006 EIA Coal Distribution Report
Note: Total exports from this source did not match other EIA sources.
19
-------
Ex
hibit 26. List of U.S. Coal Exporters
Alliance Resource Partners, L.P.
Alpha Natural Resources
Arch Coal
Chevron Corporation
CONSOL Energy
Foundation Coal
International Coal Group Inc (ICG)
Jim Walter Resources Inc
Kinder Morgan
Massey Energy
Patriot Coal
Peabody
Rio Tinto
TECO Coal
2.3.6. Coal Industry Regulation
Coal mining industry is regulated by federal, state and local authorities with respect to matters
such as permitting and licensing requirements, air quality standards, water pollution, the
reclamation and restoration of mining properties after mining has been completed, the discharge
of materials into the environment, surface subsidence from underground mining, the effects of
mining on groundwater quality and availability, plant and wildlife protection, and employee
health and safety. A list of federal regulations applicable to the coal industry and with reporting
requirements is provided below.
Coal Mine Health and Safety Act of 1969
Energy Policy Act of 2005
Federal Mine Safety and Health Act of 1977
Mine Improvement and New Emergency Response Act of 2006 (The Miner Act)
Mining and Minerals Policy Act of 1970
Surface Mining Control and Reclamation Act of 1977 (SMCRA)
Tax Relief and Health Care Act of 2006
3.0 Coal Sampling and Testing
ASTM standards are the most widely used test methods and are accepted both nationally and
internationally. ASTM International (American Society for Testing and Materials) is one of the
largest voluntary standards development organizations in the world. Developed in 1898, ASTM
was created by a group of engineers and scientist in order to improve railroad safety for the
public by addressing frequent rail breaks through the creation of standardization on the steel
used in rail construction. With the quick advancement of industrialization new standardization
requirements evolved and were immediately addressed by ASTM through the creation of
consensus standards.
The term, volume and coal quality of coal requirements are specified in the coal
supply/purchase agreements. Coal quality is tested and certified by third party independent
laboratories. ASTM (American Society for Testing and Materials) standards are the industry-
20
-------
wide acceptable standards for coal testing. The test results are provided on a dry basis
(moisture free). General coal analysis and testing include the following:
1. Proximate analysis: moisture content, ash content, volatile matter, fixed carbon
2. Ultimate analysis: Carbon, Hydrogen, Oxygen, Nitrogen, sulfur
3. Ash analysis - SiO2, AI2O3, Fe2O3, MgO, CaO, Na2O, Mn2O3, TiO2, P2O5, SO3
4. Calorific value or specific energy
In addition, special coal analysis may also be performed on trace element, coal hardness, ash
fusion temperature, chlorine, fluorine, boron, arsenic, mercury, selenium, phosphorus, size
analysis, washability testing/float and zinc test.
Chemical analyses are generally done off-site in a lab. Coal quality/content testing is performed
for both the buyer and the seller; whoever is requesting the analysis. Analysis reports are
provided to the party paying for the service and any other party that the paying client instructs.
Quality assurance/quality control measures are considered necessary by most reputable labs
who participate in a program such as the Round Robin program for Coal, Met Coke and Coal
Ash.
3.1 ASTM Coal Testing Standards
There are three ASTM certified testing methods that are frequently used by coal producers and
coal consumers in the determination of coal quality:
• Proximate Analysis:
o ASTM D3172 - A Standard Practice for Proximate Analysis of Coal and
Coke - This practice covers the determination of moisture, volatile matter,
and ash and the calculation of fixed carbon on coals and cokes sampled
and prepared by prescribed methods and analyzed according to ASTM
established procedures.
o ASTM D5142 - Test Methods for Proximate Analysis of the Analysis
Sample of Coal and Coke by Instrumental Procedures - Proximate
analysis is most frequently used as an analysis for characterizing coals in
connection with their utilization because it separates the products
obtained when heated into four groups: (1) moisture, (2) volatile matter,
(3) fixed carbon, and (4) ash. The amount of carbon residue remaining
after the volatile matter test is measured by subtracting the sum of
percentages of the remaining three products (moisture, volatile matter,
and ash) from 100. This value represents fixed carbon. The fixed carbon
value is used in determining the efficiency of coal burning equipment and
as an indication of the yield of coke in a coking process. It does not take
into account the amount of carbon that is lost in hydrocarbons with the
volatiles during pyrolysis and therefore may not give an accurate
measurement of the carbon content in coal. Fixed carbon can also
contain appreciable amounts of sulfur, hydrogen, nitrogen and oxygen.
• Ultimate Analysis:
21
-------
o ASTM D3176 - A Standard Practice for Ultimate Analysis of Coal and
Coke - Involves the determination of carbon and hydrogen content as
found in the gaseous products of the complete combustion of the coal,
the determination of total sulfur, nitrogen, and ash content in the material
as a whole, and the estimation of oxygen content by difference. These
five elements comprise the organic fraction of coal. The ultimate analysis
of coal and coke represents the elemental composition of these organic
materials in coal in terms of carbon, hydrogen, nitrogen, sulfur and
oxygen as weighted percentages. The carbon determination includes
that which is present in the organic coal substance and any originally
present as mineral carbonate.
o ASTM D5373 - Test Methods for Instrumental Determination of Carbon
Hydrogen and Nitrogen in Laboratory Samples of Coal and Coke - This
test method was created to simultaneously determine the amount of
carbon, hydrogen and nitrogen in coal using computer controlled
instrumentation. These instruments must provide for complete conversion
of carbon to carbon dioxide, hydrogen to water vapor and nitrogen to
elemental nitrogen in a coal sample. This test must then provide a
quantitative determination of these gases in an appropriate gas stream.
Depending upon the detection scheme employed by each instrument,
there can be up to three configurations available for use.
• Testing the heat content of coal and coke:
o ASTM D5865 - A Standard Test Method for Gross Calorific Value of Coal
and Coke - Utilized to determine the amount of heat produced by
complete combustion of a substance at constant volume with all water
formed condensed to a liquid.
The test most frequently performed is the Proximate Analysis (ASTM D5142) which, for quality
purposes, analyzes the characteristics of coal: (1) moisture, (2) volatile matter, (3) fixed carbon
and (4) ash. For total carbon content evaluation of a coal sample, ASTM D5373 is utilized. As
of June 2007 ASTM D3178 Standard Test Methods for Carbon and Hydrogen in the Analysis
Sample of Coal and Coke was withdrawn and replaced by ASTM D5373. Of the three ASTM
standards listed, ASTM D5373 is the recommended method to use for determining the carbon
content of a coal sample.
ASTM D5373 may not be as readily used as ASTM D5142 (Proximate Analysis). Depending on
sampling procedures, requiring the use of ASTM D5373 may involve an entirely new collection
of coal samples to be taken separate from the samples used for Proximate Analysis. On the
other hand, if no new samples/sampling techniques are required by ASTM, then it may be
possible to develop a correlation between the Proximate Analysis and ASTM D5373 in order to
avoid disruption to mining operations and standard testing practices.
3.2. Coal Sampling
The purpose of collecting and preparing a sample of coal is to provide a test sample which,
when analyzed, will provide test results representative of the lot sampled. This helps ensure an
accurate characterization of the coal from which it is taken.
22
-------
Samples are extracted from the coal throughout the whole coal mining/handling process: from
exploration to shipment for sale. How samples are gathered is dependent on the aspect of
mining and the purpose for which the coal is being tested. Samples may be required for
technical evaluation, process control, quality control, and/or for commercial transactions.
Generally, most coal is sampled for quality assurance and is drawn from in-situ coal seams as
rectangular blocks or pillars cut from full seam height, from seam channels or from borehole
cores.
The sampling procedure will depend mainly on the nature of sample collection, i.e., by
mechanical or manual means, from moving belt or from stationary lots like wagons, stockpiles,
etc. These different sampling techniques commonly follow a relevant national or international
standard. At times, upon mutual agreement, modifications are made in the method of sampling
due to technical, cost and time constraints. Statistically, 80% of the total variances involved at
the different stages of sample collection, preparation and analysis comes from errors during its
collection.
For commercial transactions, several samples are taken to ensure accuracy and to mitigate any
discrepancies that may occur. In general, samples are taken and distributed to the purchaser
and the seller with one kept in the storage. Should any inconsistencies arise in the testing
results between the seller's and purchaser's samples the storage samples can be used to verify
any differences.
It is a general practice for coal samples to be taken and tested throughout the whole mining
process. During the washing procedure samples are gathered every hour on the hour as coal
composition will change. These tests are performed on site at the mines. Not all mines contain
a preparation plant and not all coal undergoes a washing treatment; however, it is common
practice for all coal to be tested prior to loading onto carriers.
Coal washing takes place in the preparation plant. Not all mines have a preparation plant. Coal
is washed to lessen impurities and enhance the quality of its composition. Washing reduces the
ash and sulfur content thereby increasing the relative carbon content and calorific value. It is
not certain if there are any significant changes in the moisture content of coal during the
washing procedure or from transport, but should be considered in sampling, preparing and
storing samples.
For purposes of EPA rulemaking it is recommended the sampling of coal be taken when coal is
loaded onto railcars, trucks or barges. This is to minimize the potential distortion of moisture
and other chemical components of coal after coal is processed at the preparation plant. For
mines that do not have coal preparation plants samples are recommended to be taken from the
conveyor belts.
3.2.1 General Principles of Sampling
The fundamental requirements of sampling include:
• All particles of coal in the lot to be sampled are accessible to the sampling equipment
and each individual particle shall have an equal probability of being selected and
included in the sample.
• The dimension of the sampling device used should be sufficient to allow the largest
particle to pass freely into it.
23
-------
The first stage of sampling known as primary increments is the collection of an
adequate number of coal portions from positions distributed over the entire lot to take
care of the variability of the coal. The primary increments are then combined into a
sample, as taken or after reducing the mass of the sample to a manageable size.
From this gross sample, the required number and types of test samples are prepared
by a series of processes jointly known as sample preparation.
The minimum mass of the gross sample should be sufficient to enable particles to be
present in the same proportions as in the lot of coal from which it is taken.
3.2.2. General Procedure for Establishing a Sampling Scheme
1. Decide for what purpose the samples are taken, e.g., plant performance evaluation,
process control, commercial transactions, etc.
2. Identify the quality parameters to be determined, i.e., general analysis, total moisture,
size analysis, carbon content
3. Define the lot
4. Define the precision required
5. Decided whether continuous or intermittent sampling is required
6. Determine the number of sub-lots and the number of increments per sub-lot to achieve
the required precision
7. Determine or estimate the nominal top size of the coal
8. Determine the minimum mass per increment and the minimum mass of the total sample
9. Decide on the method of combining the different increments to produce the gross
sample
10. Decide on drawing common or separate samples for general analysis and moisture
3.2.3. Moisture
Moisture is an important property of coal, as all coals are mined wet. Groundwater and other
extraneous moisture are known as adventitious moisture and are readily evaporated. Moisture
held within the coal itself is known as inherent moisture and is analyzed. Moisture may occur in
four possible forms within coal:
• Surface moisture: water held on the surface of coal particles
• Hydroscopic moisture: water held by capillary action within the microfractures of
the coal
• Decomposition moisture: water held within the coal's decomposed organic
compounds
• Mineral moisture: water which comprises part of the crystal structure of hydrous
silicates such as clays
Total moisture is analyzed by loss of mass between an untreated sample and the sample once
analyzed. This is achieved by any of the following methods:
24
-------
1. Heating the coal with toluene
2. Drying in a minimum free-space oven at 150 °C (300 °F) within a nitrogen atmosphere
3. Drying in air at 100 to 105 °C (210 to 220 °F) and relative loss of mass determined
Methods 1 and 2 are suitable with low-rank coals but method 3 is only suitable for high-rank
coals as free air drying low-rank coals may promote oxidation. Inherent moisture is analyzed
similarly, though it may be done in a vacuum.
Coal is susceptible to oxidation at room temperature. Like moisture changes, such oxidation has
to be considered in sampling, preparing, and storing samples. Comparison of moisture and ash-
free (MAP) Btu values is often useful for evaluating suspected oxidation problems. All these
operations should be done rapidly and in as few steps as possible to minimize oxidation of the
coal. The sample containers used should have airtight lids to minimize moisture loss and
exposure of the coal to air. Containers should be selected that will hold only the required
amount of sample and leave a minimum of air space. Even when such precautions are taken,
the samples change very quickly, so the analysis of a sample should be carried out as soon as
possible after it is received.
3.2.4 ASTM Coal Collection Standards
It seems that in order to provide unbiased, representative coal samples for lab analysis either
the mining company or the buyer unloading the coal from a barge, railcar or truck will use some
sort of bulk sampling and/or mechanical sampling. There are ASTM sampling practices that
specify how the samples are to be collected and the QA/QC measures that should be taken
when collecting samples.
The two following practices are intended to provide a representative coal sample of the source
that they are collected from. In addition the samples from both procedures are to be crushed
and prepared for further analysis by Method D2013 so that the samples may be analyzed for a
variety of different parameters. These parameters may define the lot's value, its ability to meet
specifications, its environmental impact, as well as other properties.
ASTM D2234/2234M Standard Practice for Collection of a Gross Sample of Coal
This practice provides procedures for the collection of a sample under various sampling
conditions. Practice D2234/D2234 M allows for one division of the gross sample before
crushing. The mass and top size of the gross or divided sample collected by using these guides
and practices are usually too large for chemical or physical testing. This procedure explains
how to divide large samples before they are crushed and prepared for further analysis according
to Method D2013.
ASTM D7430-08 Standard Practice for Mechanical Sampling of Coal
This practice provides the guidelines for sample separation and crushing before it is followed by
Method D2013. For easier use the ASTM D7430-08 is the compilation of 4 previous standards
D7256/D 7256M, D4916, D4702, and D6518 that govern the mechanical sampling of coal.
There are four main parts of the practice. Part A: Mechanical Collection and Within-System
Preparation of a Gross Sample of Coal from Moving Streams. This section covers procedures
for the mechanical collection of a sample under Classification l-B-1 and l-B-2 (Practice
25
-------
D2234/D2234M) and the within-system preparation (reduction and division) of gross samples
utilizing various components of the mechanical sampling system.
Part B: Mechanical Auger Sampling describes procedures for the collection of an increment,
partial sample, or gross sample of material using mechanical augers. Reduction and division of
the material by mechanical equipment at the auger is also covered.
Part C: Quality Management of Mechanical Coal Sampling Systems is applicable to the quality
management of cross-belt, falling stream, and auger sampling systems. Part C also includes
the Spacing of Increments for Cross-Belt and Falling Stream Samplers. This section covers the
cross-belt and falling stream type mechanical sampling systems that take increments during a
fixed time strata either randomly or at fixed time intervals.
Part D: Bias Testing of a Mechanical Coal Sampling System presents sample collection and
statistical evaluation procedures for testing mechanical sampling systems, subsystems, and
individual system components for bias. It is the responsibility of the user of this practice to select
the appropriate procedure for a specific sampling situation.
ASTM 2013
The ASTM 2013 practice would follow the two previous ASTM methods and provides
instructions for reducing and dividing the gross or divided sample, by on-line or off-line
processes, or both, to a top size and mass suitable to the performance of testing.
Division and reduction of a sample may occur at more than one location. Most often, the sample
is collected, reduced, and divided (one or more times) by use of a mechanical sampling system.
The remaining sample may be further divided on-site to facilitate transporting it to the laboratory
where further reduction and division likely occurs before analysis. In places, this practice
requires air drying the sample before subsequent reduction. Procedures for air drying and air-
dry loss determination are provided in Test Method D3302.
This practice specifies how to prepare composite samples, if required. This practice divides the
procedures for the reduction and division for two groups of coal. Group A consists of cleaned
coals of all sizes and Group B consists of all other unknown coals.
This practice also covers procedures for checking precision of sample preparation and analysis
of the various stages. The data obtained from tests using consistent sample preparation and
analysis methods are used to estimate the random errors in the various stages of sample
division and analysis.
3.2.5 ISO Standards
ASTM standards are more frequently used in the U.S. whereas ISO standards are sometimes
used for international trade. ISO standards comparable to ASTM testing standards are:
ISO 17246:2005 Coal Proximate Analysis
ISO 17247:2005 Coal Ultimate Analysis
26
-------
3.3. Coal Weighing
Typically, coal is weighed using automated systems on the conveyor belt or at the loadout
facility. In general, the weighing and sampling of coal at coal mines are conducted at about the
same time to ensure consistency between quantity and quality of coal. This is because coal is
sold based on the unit of weight and within certain quality specifications. There are many types
of weighing devices and methods used in the coal industry including belt scales, rail and track
scales, and barge drafting. Each of these methods has a varying degree of accuracy and
different methods of calibration and certification. The NIST Handbook 44 published by the
Weights and Measures Division, National Institute of Standards and Technology is generally
used as the industry standard practice for coal weighing. In considering rules for coal weighing
requirements on facilities and companies in the coal industry, EPA will adopt the NIST
Handbook 44 as the standard for weighing coal.
3.4 National Coal Quality Inventory
In 1999, the U.S. Geological Survey (USGS) initiated the National Coal Quality Inventory
(NaCQIO) project to create a comprehensive database on the quality of U.S. coals. The project
was a cooperative effort between the USGS, various state geological surveys, universities, coal-
fired utilities and the coal industry with funding coming from USGS, Electric Power Research
Institute and the U.S. Department of Energy. Through this effort, a total of 729 samples were
collected. ASTM test standards of proximate and ultimate analyses were formed by
independent testing labs. The information is collected on moisture, ash, mercury, selenium, total
sulfur, chlorine, and major-minor trace elements.
Based on the USGS National Coal Quality Inventory database, a correlation was found between
the energy content and the carbon content of coal sampled throughout the United States.
Exhibit 27 shows both the raw data points as well as the representation of the linear regression
of the two variables. The data points are from 526 coal samples. A regression/correlation
analysis performed on the sample data shows a high correlation between the two with an R-
square (R2) of 0.99. The resulting regression equation is as follows:
Carbon Content (%) = 0.000057 * Coal Energy Content (Btu/lb)
27
-------
Exhibit 27.
Carbon Content vs. Energy Content
2000 4000 6000 8000 10000 12000 14000 16000 18000
btu/lb
• Carbon Content Linear (Carbon Content)
For an illustrative example of carbon content at various levels of coal energy content see
Appendix 3. Similar analysis also performed for each of the coal producing state that sample
data points are available from USGS. The results are summarized in the table below (Exhibit
28).
Exhibit 28.
Carbon Content versus Energy Content - Individual State Samples
State
ANUS
CO
IL
ND
PA
TN
TX
UT
WV
WY
R2
0.99
0.98
0.97
0.85
0.99
0.99
0.96
0.98
0.97
0.98
beta
0.000057
0.000057
0.000056
0.000060
0.000058
0.000057
0.000058
0.000056
0.000056
0.000058
Reports associated with the National Coal Quality Inventory can be found in the following URL:
httD://Dubs.usas.aov/of/2007/1116/
htto://oubs. usas. aov/of/2006/1162/ttfour
http://pubs. usas. aov/fs/fs-0120-99/fs-0120-99.pdf
htto://pubs.usas.gov/DD/Dl625b/ReDorts/ChaDters/ChaDter G.pdf
28
-------
http://pubs. usas. QOV/DD/D 1625a/Chapters/WQ.pdf
http://pubs. usas. QOV/DD/D 1625a/Chapters/PQ.pdf
http://pubs. usas. QOV/DD/D 1625a/Chapters/HQ. pdf
http://pubs. USQS. QOV/DD/D 1625a/Chapters/GQ.pdf
http://pubs. usas. aov/of/199 7/of9 7-1347
4.0 Industry Federal Reporting Requirements
In this section we focus on the three sectors identified as points of monitoring of coal: coal
mines, coal imports and coal exports. The following discussion is based on the information
gathered on current reporting requirements and presents an interpretive narrative of the
reporting matrix spreadsheets compiled for EPA. We focus our discussion on the reporting
requirements most relevant to the determination of an accurate accounting of coal flow through
the coal system.
For each sector, we discuss the key reporting obligations by agency and reporting form. We
then address the key questions EPA has identified for evaluating the suitability of the reporting
requirement as a basis for EPA's mandatory monitoring system. These questions include:
• What is reported? e.g., coal received, coal delivered, etc.
• Is the reporting tied to a facility or entity at a facility?
• What is the threshold for reporting?
• What is the frequency of reporting?
• How is the data developed?
• What are the verification/certification, QA/QC methods?
• How public is the information?
• Where are the gaps in sector coverage that would lead to un-accounted for
volumes?
The matrices on federal reporting requirements on coal are included in Appendix 2.
4.1 Coal Production
Energy Information Administration
EIA Form 7A is a comprehensive report of the operating characteristics of all US mines with
capacity over 10,000 short tons and stand-alone facilities that record over 5,000 hours of labor.
Mine level data is kept confidential, however EIA publishes data aggregated by state and
economic sector.
29
-------
Coal Production Report; Form EIA-7A
What is reported
Who is reporting
What is the threshold for reporting
What is the reporting frequency
How are the reported data developed
Are reports mandatory or voluntary
What is the facility level of the reporting
What are the verification/certification & QA/QC
methods
Is the data public or restricted
Where are the gaps in the data reported
Coal production operations, locations,
productive capacities, coal beds mined,
reserves, and disposition (volumes and
revenues received).
Mine operators (1 ,542 respondents)
Greater than 10,000 short tons
Annual
Mail, facsimile, or internet submission to EIA.
Mandatory
Mine
Sanctions against incorrect submission
Most data remains confidential, but EIA
aggregates for state or regional reporting
Currently no tracking of carbon. Tracks coal
quantity and rank.
Mining Safety and Health Administration
MSHA's data collection is primarily focused on accidents and injuries, but it does also collect
production, employee numbers and employee hours for its 7000-2 report. This report must be
filed for all mining operations that have at least one hour of work performed in them, effectively
including all operations. No data on coal quality is collected.
Quarterly Mine Employment and Coal Production Report; MSHA 7000-2
What is reported
Who is reporting
What is the threshold for reporting
What is the reporting frequency
How are the reported data developed
Are reports mandatory or voluntary
What is the facility level of the reporting
What are the verification/certification & QA/QC
methods
Is the data public or restricted
Where are the gaps in the data reported
Employees, work hours, coal production.
Mine operators
All
Quarter
Mandatory
Mine level
MSHA may request verification of data. Fines
and possible jail time for non-compliance.
Public
Data is limited to only production and
employee data.
Summary
These reports give a complete picture of the production and operating characteristics of the US
coal industry, however neither report gathers data on coal quality other than rank.
30
-------
4.2 Coal Imports and Exports
Census Bureau Form EM545
What is reported
Who is reporting
What is the threshold for reporting
What is the reporting frequency
How are the reported data developed
Are reports mandatory or voluntary
What is the facility level of the reporting
What are the verification/certification & QA/QC
methods
Is the data public or restricted
Where are the gaps in the data reported
Commodity type, country destination, customs
district origin, quantity (tons), and value
(dollars)
Coal exporters
All coal exports
Monthly
Not known
Mandatory
N/A
Not known
Public
Fuel characteristics not tracked
Census Bureau Form IM145
What is reported
Who is reporting
What is the threshold for reporting
What is the reporting frequency
How are the reported data developed
Are reports mandatory or voluntary
What is the facility level of the reporting
What are the verification/certification & QA/QC
methods
Is the data public or restricted
Where are the gaps in the data reported
Commodity type, country origin, customs
district destination, quantity (tons), and value
(dollars)
Coal importers
All coal imports
Monthly
Not known
Mandatory
N/A
Not known
Public
Fuel characteristics not tracked
Summary
Data collected on imports and exports in these forms cover 100% of the shipments, however no
descriptive data is available on the shipments other than quantity shipped.
4.3 Coal Distribution and Consumption
Energy Information Administration
EIA Form 3 tracks coal receipts at manufacturing plants in the US that consume greater than
10,000 tons per year. This total also includes synfuel plants that use coal as a feedstock and
facilities using coal for gasification or liquefaction. In addition to tracking the quantity of coal
consumed and current stock levels, this form also tracks the origin of the coal, the predominant
transportation mode used, the coal rank, the heat content, the sulfur content, and the ash
content. Form 3 segregates synfuel in a separate schedule.
31
-------
Quarterly Coal Consumption and Quality Report Manufacturing Plants; Form EIA-3
What is reported
Who is reporting
What is the threshold for reporting
What is the reporting frequency
How are the reported data developed
Are reports mandatory or voluntary
What is the facility level of the reporting
What are the verification/certification & QA/QC
methods
Is the data public or restricted
Where are the gaps in the data reported
Origin, quantity, primary transportation mode,
quality (i.e., Btu, sulfur, and ash contents), and
cost; short tons
Manufacturing Plants
Greater than 1000 short tons
Quarter
Mail/electronic submission
Mandatory
Plant level
Not known
Parts are public others confidential
Tracks quantity, heat content, sulfur and ash
but not carbon
EIA form 5 is nearly identical to Form 3 except that it focuses on coal received at coke plants.
One exception is that Form 5 does not request data on the heat content of the coal; instead, it
requests the volatile matter percentage, a trait more relevant to the coking industry.
Quarterly Coal Consumption and Quality Report Coke Plants; Form EIA-5
What is reported
Who is reporting
What is the threshold for reporting
What is the reporting frequency
How are the reported data developed
Are reports mandatory or voluntary
What is the facility level of the reporting
What are the verification/certification & QA/QC
methods
Is the data public or restricted
Where are the gaps in the data reported
Coal receipts, costs, carbonization, and stocks,
as well as coke and breeze production,
distribution, and stocks at all U.S. coke plants;
short tons
All operating coke plants
All coke plants
Quarter
Mail/electronic submission
Mandatory
Plant level
Not known
Parts are public others confidential
Tracks quantity, volatile matter, sulfur and ash
but not carbon
EIA form 6A collects coal distribution data from US coal mining companies and wholesale and
retail coal dealers, including brokers. Companies that owned, purchased, or distributed 50,000
tons of coal during the reporting year must fill out this form. Companies that only distribute, but
never own, coal are exempt from this requirement. The coal distribution report tracks coal
shipments from US producers to US consumers. No data on coal quality is collected in this
form.
Coal Distribution Report; Form EIA-6A
What is reported
Who is reporting
Coal production, purchases, distribution by
consumer type, and stocks; short tons
Coal mining companies, wholesale coal
dealers (including brokers), and retail coal
dealers
32
-------
What is the threshold for reporting
What is the reporting frequency
How are the reported data developed
Are reports mandatory or voluntary
What is the facility level of the reporting
What are the verification/certification & QA/QC
methods
Is the data public or restricted
Where are the gaps in the data reported
Greater than 50,000 short tons
Annual
Mail/electronic submission
Mandatory
Company
Data consistency check performed by
EIA
Parts are public others confidential
Only tracks quantity of coal distributed
characteristics tracked.
, no
EIA Form 906 collects fuel receipts and generation data from US generators with capacity of 1
MW or more. Approximately 4,400 plants are required to fill out this form. Form 906 only tracks
the quantity, rank, and heat content of coal receipts. Due to a consolidation of forms planned
for 2008, Form 906 will be discontinued and replaced by EIA Form 923.
Power Plant Report; Form EIA-906
What is reported
Who is reporting
What is the threshold for reporting
What is the reporting frequency
How are the reported data developed
Are reports mandatory or voluntary
What is the facility level of the reporting
What are the verification/certification & QA/QC
methods
Is the data public or restricted
Where are the gaps in the data reported
Fuel consumption, heat content, electric
generation, and fuel stocks
Power plants
Plants greater than 1 MW capacity
Month/annual
Mail/electronic submission
Mandatory
Plant level
Not known
Public, but "Stocks at End of Reporting Period"
will be confidential
Discontinued in 2008
EIA Form 920 is similar to Form 906 in the data collected, but is required only for CHP plants.
Form 920 also tracks the use of electricity generated at the plants and sales. Like Form 906,
Form 920 will be discontinued in 2008 and replaced by EIA Form 923.
Combined Heat and Power Plant; Form EIA-920
What is reported
Who is reporting
What is the threshold for reporting
What is the reporting frequency
How are the reported data developed
Are reports mandatory or voluntary
What is the facility level of the reporting
What are the verification/certification & QA/QC
methods
Is the data public or restricted
Where are the gaps in the data reported
Fuel consumption, heat content, electric
generation, and fuel stocks
CHP plants
Plants greater than 1 MW capacity
Month/annual
Mail/electronic submission
Mandatory
Plant level
Not known
Public, but "Stocks at End of Reporting Period"
will be confidential
Discontinued in 2008
33
-------
EIA Form 423 reports fuel receipts at non-utility electric generating plants in the US of capacity
50MW or greater. In addition to tracking quantity, Form 423 tracks heat content, sulfur content,
ash content, cost, and specifically for coal, the origin of the fuel. Cost information is kept
confidential. Form 423 will be discontinued in 2008 and replaced by EIA Form 923.
Monthly Cost and Quality of Fuels for Electricity Plants; Form EIA-423
What is reported
Who is reporting
What is the threshold for reporting
What is the reporting frequency
How are the reported data developed
Are reports mandatory or voluntary
What is the facility level of the reporting
What are the verification/certification & QA/QC
methods
Is the data public or restricted
Where are the gaps in the data reported
Fuel quantity received, quality (Btu, sulfur, and
ash content), purchase type, cost, contract
expiration date, tolling agreements, and
supplier of fossil fuels delivered for the
generation of electric power. In addition, for
coal only, data will include type of mine and the
State and county where the mine is located.
Non-utility power plants
Non-utility plants greater than 50 MW capacity
Month/annual
Mail/electronic submission
Mandatory
Plant level
Cross-checked with fuel consumption reported
on EIA 906 and 920 forms
Public, but "fuel cost data" will be confidential
Discontinued in 2008
Federal Energy Regulatory Commission
FERC Form 423 is virtually identical to EIA Form 423, with the exceptions that the FERC form
covers all utility power plants and it reports delivered cost information. Form 423 will be
discontinued this year and replaced by EIA Form 923.
Cost and Quality of Fuels for Electric Plants; FERC Form-423
What is reported
Who is reporting
What is the threshold for reporting
What is the reporting frequency
How are the reported data developed
Are reports mandatory or voluntary
What is the facility level of the reporting
What are the verification/certification & QA/QC
methods
Is the data public or restricted
Where are the gaps in the data reported
Fuel quantity received, quality (Btu, sulfur, and
ash content), purchase type, cost, contract
expiration date, tolling agreements, and
supplier of fossil fuels delivered for the
generation of electric power. In addition, for
coal only, data will include type of mine and the
State and county where the mine is located.
Utility Power plants
All utility plants
Month/annual
Mail/electronic submission
Mandatory
Plant level
Not known
Public
Discontinued in 2008
34
-------
Energy Information Administration (Not vet released)
EIA Form 923 was designed to replace EIA forms 906, 920, 423, and FERC form 423. It
includes all relevant data elements present on the obsolete forms and also adds data on
commodity cost, mercury content of coal, additional detail on transportation modes, and it links
coal shipments to specific mines as indicated by the MSHA ID number. Additionally, a coal
balancing check was added that requires the reported change in fuel stocks to reconcile with the
fuel receipts and fuel consumption reported.
Power Plant Operations Report; Form EIA-923
What is reported
Who is reporting
What is the threshold for reporting
What is the reporting frequency
How are the reported data developed
Are reports mandatory or voluntary
What is the facility level of the reporting
What are the verification/certification & QA/QC
methods
Is the data public or restricted
Where are the gaps in the data reported
Electric power generation, fuel consumption,
fossil fuel stocks, and delivered fossil fuel cost
and quality
All electric power plants and CHP plants over 1
MW
All plants 1 MW or greater that have the ability
to draw power from the grid or deliver power to
the grid.
Month/annual
Mail/electronic submission
Mandatory
Plant level
Requires that changes in reported fuel stocks
must reconcile with fuel receipts and fuel
consumption reported.
Public, but non-utility cost data is confidential
Carbon not reported, but quantity and source
of coal reported as well as other fuel
characteristics
Summary
Coal quality data is almost exclusively found in these distribution and consumption reports,
however carbon is currently not reported in any of them. It will also not be included in the new
EIA Form 923. Coverage is fairly comprehensive, especially under the new form where only
units under 1 MW are not required to report.
5.0 Data Gaps and Quality
In this section we discuss the observed gaps in the reporting requirements and suggest
alternatives for acquiring missing data. Similarly, we discuss quality control of the accuracy of
the data that are reported.
In its current form, data collection on the coal industry is redundant, sometimes contradictory,
and not consistently checked for errors. Some of these issues are expected to be resolved with
the introduction of EIA form 923 in late 2008 / early 2009.
35
-------
5.1 Reporting Gaps in Industry Coverage
Both EIA and MSHA collect data on production, however MSHA requires reports from all mines
while EIA has a reporting threshold. This results in different totals reported from the two forms.
EIA collects more descriptive data of mines compared to MSHA, which focuses more on
accident reporting than operating characteristics. Neither MSHA nor EIA collect data on coal
quality at the producer; instead, that data is located in the various EIA and FERC forms that
monitor distribution and consumption.
The distribution and consumption forms are also duplicative in their reporting. EIA forms 906
and 920 collect data on fuel consumed and the heat content of fuel, but contain no other
descriptive data. Additionally, the 920 data only applies to CHP units 50MW and above, which
would seem to leave a considerable number of CHP units with no reporting requirement. The
423 forms, of which EIA and FERC both report, contain additional descriptive data on fuel use,
especially coal in which the source is identified. Fuel use reported for a particular plant does not
always match when comparing between the 906/920 forms and the 423 forms. Form 923, when
implemented, should resolve the disparities of fuel consumption reporting for the electric power
sector. Other sector reporting seems to be accurately covered by EIA forms 3, 5, and 6.
Import and export data, reported by the Census Bureau, covers all imports and exports but does
not contain any characteristics of the fuel shipments.
5.2 Quality Assurance and Control
EIA performs some cross-checking between its forms for accuracy, and contacts filers for
additional information if discrepancies exist. It is not known what kind of quality control was
performed by FERC for the 423 data. While using the data for internal use, ICF has noticed that
some of the FERC data is likely off by an order of magnitude (tons reported rather than
thousand tons). One of the problems in enforcing quality control with these forms is that the
penalties seem to only target missing data, rather than missing and/or incorrect data. The
introduction of the 923 form will likely reduce some of these errors as it incorporates automatic
balancing calculations which require fuel reporting to equilibrate.
36
-------
APPENDIX 1
2007 U.S. COAL PRODUCTION BY COAL HOLDING COMPANIES
Source: MSHA
Controller
Peabody Energy
RTZ-CRA Group
Arch Coal Inc
Foundation Coal Corporation
CONSOL Energy Inc
Massey Energy Company
NACCO Industries Inc
Westmoreland Coal Company
Robert E Murray
Kiewit Petersons' Inc
Alliance Resource Partners LP
TXU
Alpha Natural Resources LLC
International Coal Group Inc (ICG)
BMP Billiton
Magnum Coal Company
Chevron Corporation
James River Coal Company
Ashland Inc et al
Jeffery A Hoops
Level III Communications et al
Richard Gilliam et al
Pacific Minerals Inc et al
James O Bunn et al
Wexford Capital LLC
John C Smith Jr
Western Fuels Association
James H Booth et al
J Clifford Forrest III
TECO Energy Inc
Black Hills Corp
Black Beauty Resources Inc & United Minerals
Oxbow Carbon & Minerals Inc
Walter Industries Inc
Charles Ungurean
Clearwater Natural Resources LP
United Company
Allete Inc
Pacificorp
Kiewit Peter Sons' Inc et al
Energy Coal Resources Inc
James C Justice II
Felson Bowman
2007 Production
(tons)
198,674,509
134,352,528
116,564,889
71,827,904
61,320,542
38,302,078
34,068,714
30,392,392
27,566,697
27,171,022
23,872,215
23,852,935
19,886,012
18,705,641
15,427,995
13,702,575
11,990,796
10,820,915
10,453,806
8,351,542
6,984,546
6,798,473
6,473,810
6,116,390
5,530,387
5,480,569
5,303,516
5,112,618
5,104,054
5,090,818
5,049,231
4,966,840
4,823,662
4,530,690
4,248,029
4,175,806
4,123,999
3,894,230
3,685,476
3,655,146
3,496,083
3,390,202
3,121,532
2007 Production as a
Percentage of U.S.
Total
17.4%
1 1 .8%
10.2%
6.3%
5.4%
3.4%
3.0%
2.7%
2.4%
2.4%
2.1%
2.1%
1 .7%
1 .6%
1 .4%
1 .2%
1 .0%
0.9%
0.9%
0.7%
0.6%
0.6%
0.6%
0.5%
0.5%
0.5%
0.5%
0.4%
0.4%
0.4%
0.4%
0.4%
0.4%
0.4%
0.4%
0.4%
0.4%
0.3%
0.3%
0.3%
0.3%
0.3%
0.3%
37
-------
Jerry W Wharton
Thomas R Hamilton et al
Chester M Thomas
Patriot Coal Corporation
Donald Blankenberger
American Electric Power Company Inc
Tri-State Generation & Transmsn Assoc et al
Edward L demons Estate
John M Potter et al
Alcoa Inc
Exxon Mobil Corp
Citicorp Venture Capital Ltd
Phoenix Coal Corporation
Amvest Corporation
Vigo Coal Company Incorporated
Douglas M Epling
Timothy Elliott
David A Duff
Benjamin M Statler et al
James L Laurita Jr et al
James H Booth
General Dynamics Corp
Brody Trust
Deseret Generation & Transmission Co-operative
William D Humphreys et al
John M Stilley
Everett (Gordon) Justice
Drummond Company Inc
Joseph E Usibelli
Andrew B Jordan
Long Branch Energy Corporation
James F Graham
Harold E Akers et al
Cleveland-Cliffs Inc
Steven W Haynes et al
Five J's LLC et al
Thomas J Smith
Coalfield Transport Inc
John P Garcia et al
Ronald E Laswell et al
National Coal Corporation
Robert J Reed Sr
Gary Asher
Brian J Veldhuizen et al
Sun Company Inc
Dan Chambers et al
International Industries Inc
Joseph T Bennett et al
Robert R Jeran
Anthony P Cline
3,091,562
2,890,976
2,819,284
2,779,232
2,623,781
2,558,017
2,477,549
2,281,917
2,176,315
2,138,829
2,133,879
2,130,063
2,051,913
1,994,956
1,988,490
1,979,495
1,792,172
1,742,928
1,637,380
1,598,542
1,588,993
1,531,465
1,514,717
1,424,019
1,420,034
1,377,470
1,367,111
1,331,831
1,323,560
1,282,011
1,257,001
1,233,398
1,182,450
1,174,985
1,155,735
1,137,871
1,118,706
1,075,762
1,058,761
1,039,232
979,575
946,198
875,523
823,143
818,273
769,286
764,822
755,144
739,555
738,804
0.3%
0.3%
0.2%
0.2%
0.2%
0.2%
0.2%
0.2%
0.2%
0.2%
0.2%
0.2%
0.2%
0.2%
0.2%
0.2%
0.2%
0.2%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
38
-------
David Wells
Frank C Mann
Ben Bennett et al
W Thomas Mackall et al
Cambrian Mining PLC
David D Bundy
A J Taft
William G Skewes
Joseph A Owens
William J Cooper
International Resources LLC
Bill W Stoddard et al
Douglas M Epling et al
Alan Arthur et al
Aubra P Dean et al
Robert A Lewis et al
Bobby G Meadows Jr
Otis R Robison Jr
John W Smith
GCC of America
Anthony Frederick et al
John B Preece
Gary E Peyton
Robert L Worley
Douglas L Banner et al
Carl L Baker Jr
Evergreen Energy Inc
Robert 1 Hartley et al
David Maynard
Jerry Skeens et al
Ervin Stiltner
Tri-State Generation & Transmission Assn Inc et al
Forest Coal Company
Geraldine P Turner
Mary J Brown
Carl Kirk et al
Gary L Barker et al
Roger W Perry
Pat A Jones
George R Beener
William P Moore III et al
Randel L Richmond
Donald R Hoffman
Franklin S Schall
Rhonda Marcum
Charles D Lilly
Jerry M Gaines
Theodore L Darlington
Stanley R Ditty
F D Justice II et al
733,221
725,236
712,475
671,117
668,807
667,357
639,096
625,868
610,705
607,755
595,712
587,784
537,931
515,827
515,305
500,013
491,843
488,537
477,195
470,099
468,747
463,708
463,007
462,021
458,788
458,281
450,822
437,921
426,034
425,703
410,414
405,864
405,433
404,973
402,462
401,013
397,321
387,559
383,752
377,595
375,970
375,554
375,004
364,438
364,198
363,800
361,929
348,956
342,762
342,211
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
0.1%
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
'1
1
1
1
39
-------
C Ray Peters et al
Chris Patton et al
Progress Energy Inc
Edward A Asbury
Randy Gilkerson et al
Keith B Kimble
James Brakefield et al
Michael R Burns
James A Sigmon
Thomas Scholl
Roger L Kirk et al
Paul C Combs et al
Charles H Snyder Jr
Daris Stump
Martha A Bender
Wolford Jeffrey
Rowland Goble et al
David Cline
Bill C Smith
Willis Ring
Kenneth F Smith
Richard H Abraham et al
John A Blaschak
Scarlett Biliter
Donn A Chickering
William Ridley Elkins Jr
Jeffrey A Goldizen
Melvin Bailey
Cecil Ann Walker
Bronco Energy Fund Inc
Anthony V Lanham
Jem-Coal LLC et al
(Harold) Lynn Keene et al
Broe Companies Inc
Richard (Barry) Hale
Wesley D. Burke et al
Robert L Clear
Keith D Dyke
Edward Tincher
James Cox et al
David Forcey et al
Ronnie D Jackson
Sean D Taylor
Joseph L Waroquier et al
Gregory Jessee et al
James H Hurley
Clarence L Moss III
Thomas King Evans
INR-I Holdings LLC
Henry Chaney Jr
326,697
318,298
315,811
315,350
311,983
298,391
298,221
296,952
281,428
278,459
276,867
274,811
273,321
272,519
267,488
267,413
265,721
263,040
261,674
256,832
254,979
249,886
247,787
246,161
236,737
236,169
234,102
233,667
233,105
232,881
231,739
228,058
227,326
227,232
225,170
223,904
222,136
221,457
220,494
220,038
215,402
210,739
210,245
209,650
206,856
205,282
203,351
201,320
197,914
194,378
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
'i
i
i
i
40
-------
David Powers
Donald Newsome
Terry C Marshall et al
Clyde H McComas et al
Harry J Hanchar
Freddie A Taylor
Darrell G Spencer et al
Headwaters Inc
Johnny H Parton
Randall E Crawford et al
Paul M Hogg
Howard Russell Morris
John Lewis
G B Hendrickson
Prushnok Coal Company Inc
Ray Slone Jr
Jackie (Mitch) Fannin Et Al
John H Wellford
Jon K Ingle
George Cowfer Jr
James L Bevins
United American Energy Et Al
Alice Hall
Anthony K Dotson et al
H. Garrison Hill
Rodney Bentley et al
William F Haley
Timothy Schwinabart et al
Laird T Orr
Ralph L Wingrove
Gary Bowen II
Susie A Smith et al
James Taylor et al
Ron D Bowling
Michael T McCullough
Andrew J Hewitson
Michael Puskarich et al
Hank K Matney et al
John W Rich Sr et al
Mark Bowles
Greg Damron et al
Daniel A Fescemyer
Woodman Three Mining Inc
Anthony Blaschak et al
Ervin Stiltner et al
Terry Hovatter
Fredrick J Murell
Robert D Me Fall
Joseph L Waroquier Jr Et Al
Robert L Rosencrans et al
192,056
188,787
186,364
185,916
183,435
182,592
182,505
182,369
180,926
180,312
179,056
178,795
175,444
170,565
170,482
168,788
168,315
161,409
159,886
155,868
154,682
153,885
151,805
151,676
147,478
145,853
145,782
143,796
143,541
143,363
143,301
141,461
140,080
139,329
139,307
138,547
138,013
137,251
135,241
133,103
129,418
129,239
124,267
122,849
120,793
119,606
119,036
118,093
117,619
116,255
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
'i
i
i
i
41
-------
Scott E Fieg et al
Robert Swisher et al
Christopher J Evans
Jerry Tackett
Lester Sherman et al
Jody L Ritchie
Linda S Coleman
Robert L Johnson
Charles B Hall et al
Ronald S Bryant et al
John A Decker et al
Dick J Plaster
John P Matey
Terry L. Hall
Robert M Keen
David C Neiswonger
Mark E Strishock et al
Danny Justice
Coal International PLC et al
Jimmie R Ryan et al
Kenneth L Farley et al
Kenneth R Galloway
Charles T Clise Jr
Josh Osborne
Timothy R Dye
James M Davidson Jr
Jack H Ealy et al
Larry D Baumgardner
Marvin Shafer et al
Benjamin T Elkin
Minerva (Ruth) Mead
City Trust Of Philadelphia
John D North et al
Robert George Koval
R. Alex Johnson et al
Eddie Hurley
David D Osikowicz Jr
David Stevenson
Robert O Roan
Howard Covington et al
Nancy A Cybulla-Johnson
Neil 1 Atwell
Pagnotti Enterprises Inc
Joseph Aloe et al
Hufford V Williams
Noah L Vandyke
Barbara Evans et al
John M Lee
Robin M Lambert et al
Pen Garb Incorporated
115,498
113,976
112,537
109,645
109,170
108,829
107,721
105,113
104,455
102,152
101,814
101,677
101,041
101,022
100,404
99,848
99,478
98,298
96,568
95,336
95,079
93,891
93,147
91,340
90,314
90,028
88,717
86,799
86,190
85,247
83,481
82,503
82,106
80,603
80,280
80,144
79,616
79,603
79,167
79,058
78,888
78,635
75,705
74,825
74,315
73,660
73,451
73,404
73,081
72,407
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
'i
i
i
i
42
-------
Joseph Kuperavage et al
Jim Clark
John Harris
Robert Caylor
James Wayne Estep
Clinton L Ramey
Curtis Laws
Gary Dotson et al
William F Adams
Elmer Kincaid Jr
William R Ward et al
Bobby R Elswich et al
Consolidated Energy Inc
Edward Helfrich et al
Billy Wright
Kevin Wash burn
Jerry C Whitt et al
Ernest E Varney et al
Randall G Vance
James Larry Jamieson
William D Barnette et al
Francis H McCullough et al
D Kent Glover
William J Paulisick et al
Paul D Corbin et al
James V Filiaggi Jr
Dennis Greg Yonts
Clyde Meenach et al
Charles J Douglas
Leonard Swisher
Kevin Hall
Barry Runyon et al
John R Kellar
Mike Newsome
Gerald Peacock et al
Gerald D Thomas
Frank H Ikerd III
William E Nesselrotte
Perry Allen Whited
Robert E Elkin
David E Godin
John G Rocovich Jr et al
Alvin J Roman
RayECollett et al
William Haskins et al
James G Shank
Edsel H Preece et al
Beard Company
Charles T Norman
Larry Vance
72,187
71,701
69,671
69,630
67,827
67,787
66,259
66,137
65,079
64,023
63,586
63,377
60,532
60,150
59,587
59,281
58,266
58,165
58,140
57,833
56,722
56,569
56,530
56,405
56,224
55,432
55,117
54,771
54,232
52,716
52,034
51,603
51,546
50,906
50,148
49,630
49,050
48,711
48,548
48,427
47,541
47,024
46,722
46,085
45,525
44,350
43,470
42,693
42,594
42,404
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
'i
i
i
i
43
-------
Vhonda Dotson
Greg Fleenor
Connie Bryant
Elijah J Helton
Randall Wagers et al
Elster Me Clanahan et al
James R Gibbs et al
Leonard Hendrickson
Scott B Kimmel
Joseph Teodori et al
Michael D Poskas
Fred McGlothlin et al
Brian K Reichard
Harold Sturgill
John R Demuth et al
Jeremy Lynn Stewart
George Begley et al
(Charles) Ralph Sutton et al
Bernard J Kuperavage Jr et al
John A Kosky
Bull Mountain Coal Properties Inc
Dennis Daniels
Thomas H Loughry et al
Ricky Blair
Robin Belcher
David L Huffman
Hung Q Nguyen
Billy R Daugherty
Kelly K Felts
Kres B VanDyke
David E Hess et al
Douglas K Tackett et al
David C Gummere
Russell Stacy
Albert Carapellotti et al
Brian K Short et al
Johnny Goley et al
Randy F Stout
John Asher et al
Stuart Renfro
David D Svonavec et al
David L Patterson Jr
Carl Ferguson
Citore Coal Co Inc et al
Jennifer N Szakacs
Charles R Sheesley Sr
Robert Helton
Cliff Bartley
Ronald J Kuperavage
Thomas Kraynak et al
42,401
42,321
42,119
41,371
41,251
41,104
40,276
40,129
39,878
39,308
38,987
38,621
38,600
38,000
37,729
36,965
36,852
36,569
36,473
36,019
35,111
35,005
34,700
34,116
34,112
33,560
33,560
33,002
32,996
32,923
32,337
31,355
31,177
31,025
30,131
29,452
29,266
28,475
28,459
28,389
28,184
27,796
27,608
27,250
26,721
26,450
25,894
25,452
25,274
25,186
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
'i
i
i
i
44
-------
Timothy R Mowry
Shad B Spencer
Judith Smith et al
Richard Maynard
Waste Management Inc
Gary N Boyd
Randy Hensley
Joe L Cusick et al
Donald Simpson
AES Corp
Thomas S Hynoski et al
Dennis B Hagerman
Kenneth M Pollock et al
Donald E Kahle Jret al
Rocky Hill
Wally T Fetterolf
Alon Ballenger
Justin L Curry
David M. Raynard
Harold P Leasure et al
Albert F Stiffler
Perry Queener et al
James W Cooper
Andrew J Freno
Charlie Sorokach et al
Debbie S. Rose
Ronald G Goff
Rob Mears et al
Cory Lee Shawver
Jody Puckett
Ricky D Kirk et al
Warren C Hartman
Paul A Cooney et al
Benjamin Wurts et al
Randy C Rothermel et al
Barry C Brocious et al
Roger L Miller
Jeffrey K Justus et al
Donald Miller et al
Mark Houser et al
Morris G Thompson
Mark E Daugherty
Daniel J Patterson
Kurt E Kerry
Noah White Jr
Kern Brashear
Hugh Slatery et al
Ronald L Gray
Emanuel A. Paris
Leonard Hendrickson et al
25,073
24,856
24,419
24,180
24,160
23,843
23,578
23,270
23,195
22,445
22,378
22,377
22,300
21,997
21,980
21,786
21,450
21,413
20,788
20,187
19,911
19,868
19,758
19,280
19,166
19,073
19,045
18,906
18,875
18,662
18,631
18,108
17,985
17,876
17,418
17,304
17,069
17,006
16,590
16,412
15,868
15,752
15,644
15,515
15,460
15,283
15,165
15,019
14,909
14,897
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
'i
i
i
i
45
-------
David A Betscher Et Al
Edward Fiala
Glen D Pope
Joseph W Zaprazny
Mark Popple et al
David L Cordill
William E Konya et al
Walter R Lindenmuth
Harvey Bumbarger
Jimmie D Lester
Jeffery S Sisler
Alan Larson et al
Troy Soberdash et al
Lloyd Cole et al
Alan D Clark et al
Eugene Byrum et al
Joseph Balazick et al
John Melochick
Donald C Bender et al
Kevin Gamblin
Gary Gioia
Timothy A Keck
Stephen N Peles
Donald Thompson
Donald E Stash Jr
Matthew J Polenik
Michael R Shelton
Frank Parks
Vincent Kassa
Gary R Cruey et al
Terry G Loving
Paul M Whatley
Jerry Volk et al
David L Hansen
Mark Morton et al
Steve Singleton et al
Gilbert L Barnes et al
Jimmy Wright
Jerry M Grant
ElmerS Campbell et al
Joe B Test
John R Yenzi Jr
Julian T Hammond
Oscar Hatten et al
David S Himmelberger
Dennis Kasubick et al
Arthur (David) Montgomery
Anthony J Ripepi
Michael L Horn et al
Robert W Titus
14,782
14,395
14,302
14,203
14,200
13,810
13,659
13,545
13,498
13,475
13,310
13,248
13,204
13,089
12,978
12,919
12,651
12,573
12,390
12,383
12,201
11,876
1 1 ,654
11,386
11,357
11,307
11,158
11,080
10,798
10,765
10,749
10,745
10,701
10,543
10,009
9,912
9,708
9,688
9,663
9,657
9,589
9,520
9,439
9,399
9,231
9,179
8,926
8,894
8,874
8,859
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
'i
i
i
i
46
-------
Ralph T Smith
Albert Michael Capps
Joseph A Robinson
Troy Lee Girdner
Charles C Swenglish
Rickey E Hause
George K Walker
Roger Bressler
Harold Craft
David Job Suender
Daniel J Joy et al
Frank M Neumeister
Steve J Patterson
Steve A Rife
Mark D Bevan
Warren Weaver et al
Kenneth S Bowling et al
Harry E Freed
Jesse L Stephens
Michael S Garcia
Eugene T Sosko
Larry Jordan
Brian Edmonds
William C Vought
David Rayner et al
Mike Fredrick et al
Jay Wallace
Douglas Vaughn
Daniel P Maksimik Jr
Bradley B Hopkins
Eddie Rowe
Chris E Kerstetter et al
Roger A Thomas et al
Rodney A Robinson et al
Jeff Kinser
Gary Berkley
Melvin Schaney
Robert R Stremick et al
Thomas L Hill
Patrick H Cunningham et al
Larry M Fahr
Roger Ohler
Richard M Oley
Clyde D Fields
Paul Ferlitch
Philip Reese
James M Allen
Amy J Johnson
Gabriel J Stewart
Ash English et al
8,798
8,695
8,616
8,535
8,370
8,331
8,318
8,246
8,223
8,217
8,179
8,154
7,914
7,878
7,775
7,680
7,670
7,611
7,451
7,346
7,180
7,106
7,000
6,997
6,643
6,486
6,448
6,268
6,262
6,193
6,093
5,983
5,524
5,384
5,222
5,212
5,097
5,036
4,784
4,651
4,547
4,533
4,495
4,412
4,404
4,203
4,175
4,056
3,944
3,596
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
'i
i
i
i
47
-------
John E Ling
Alfred J Brown
Mike Ritchie
Ricky G Derek et al
James Hood et al
Darryl Koperna
C Dan Burton
Kerry Harris
Frank A Muscara
Vogel Disposal Service Inc
Joseph Patrick Fremer Jr
Everett Shepherd II
Paul Hitchcock
Robert Cuomo
Dave Finney
Darryl W Lucas Sr
Darwin Rowe et al
Philip M Koury
Roy E Collins
Pat L Martin et al
Henry Comer
Chris Davis
Darryl M Jacobs
Eugene F Morton
Amanda Halcomb
Gregg Barrett
George L Rusnak et al
Larry Weaver
Jefferson Martin et al
Brian J Black
Paul Beilchick
Joseph P Cromyak
Richard Piccolomini
D L (Jack) Bowling
Rick H Varney
Thomas J Lynott
Gregory S Showers et al
Donald F Mauthe
Kenneth K Rishel
Lawrence Bender et al
Matthew S Postupack et al
Steve Bentley et al
W Ruskin Dressier
Vulcan Coal Partners LP
Harold J Rehe
Matt Short
Michael Supko et al
Michael S. Carsia et al
Alan Churchill
Todd Morchesky
3,543
3,452
3,451
3,414
3,274
3,085
3,000
3,000
2,955
2,769
2,740
2,690
2,619
2,597
2,589
2,577
2,490
2,460
2,454
2,421
2,397
2,368
2,208
2,164
2,017
1,998
1,980
1,899
1,880
1,869
1,844
1,838
1,800
1,785
1,580
1,573
1,529
1,468
1,438
1,385
1,360
1,155
1,141
1,104
1,099
1,074
1,051
939
693
657
1
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
i
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
48
-------
Jim Fahr et al
Thomas Klinger et al
Michael A Botner et al
Jerry W Lucas Jr
William Reiner et al
Jim Kummerfeld
Greg Schenck
Paul F Becker
Michael Rothermel et al
Regina A Constantica et al
William A Long et al
Barry Karnes
Jim Hall et al
Robert Bowers et al
Joseph E Shingara
Marvin Hays
Kevin E Thompson
Calvin Hepler
643
625
490
477
449
443
419
403
384
377
333
297
236
183
120
86
55
48
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Notes: (1) Production is less than 0.05% of U.S. total.
49
-------
APPENDIX 2
Matrix of Federal Reporting Requirement on Coal
Coal Production
Is the information What are the
Reporting Form Full Who must file the does the report capture? (i.e., what is Report (facility name What is Reported (product and throughput treated in the i.e., minimum level of throughput frequency of collect the data information without the available? Any certification Agency's QA/QC report for gaining an accurate
Coal Imports and Exports
Is the information What are the
Reporting Form Full Who must file the does the report capture? (i.e., what is Report (facility name What is Reported (product and throughput treated in the i.e., minimum level of throughput frequency of collect the data information without the available? Any certification Agency's QA/QC report for gaining an accurate
50
-------
Coal Distribution and Consumption
What percent of facilities and How is ownership of What is the threshold for
fuel flow does the report Facility Level of the fuel throughput reporting, i.e., minimum level What is the
Reporting Form Who must file capture? (i.e., what is the Report (facility What is Reported (product treated in the report of throughput or facility frequency of
Agency Full Official Title the report?
Energy Quarterly Coal I-
Admimstratio Quality Report
Plants, Form EIA-3
Energy Quarterly Coal All operating
Admimstratio Quality Report Coke
n Plants, Form EIA-5
rage of the industry?)
1 and o'
for
specif
Reporting?
Quarter
How does the
facility collect the
data reported?
Mail/electronic
Would the facility need
this information without
the reporting
requirement?
What are the
verification or
What are the
Agency's
QA/QC
requirements?
Not known
Summary Comments: How good
accurate accounting of fuel and
1400 plants file monthly, 3000 Plant
Information Quality of Fuels for plants
Admimstratio Electricity Plants,
n Form EIA-423
tility plants greater than Month/
Public, but "Stocks Not knov
Period" will be
Public, but "Stocks Not knov
Period" will be
confidential
51
-------
APPENDIX 3
Carbon Content at Given Level of Energy Content
Btu/lb
2,000
2,250
2,500
2,750
3,000
3,250
3,500
3,750
4,000
4,250
4,500
4,750
5,000
5,250
5,500
5,750
6,000
6,250
6,500
6,750
7,000
7,250
7,500
7,750
8,000
8,250
8,500
8,750
9,000
9,250
9,500
9,750
10,000
10,250
10,500
10,750
11,000
11,250
11,500
11,750
12,000
12,250
12,500
12,750
13,000
13,250
Carbon %
11.40
12.83
14.25
15.68
17.10
18.53
19.95
21.38
22.80
24.23
25.65
27.08
28.50
29.93
31.35
32.78
34.20
35.63
37.05
38.48
39.90
41.33
42.75
44.18
45.60
47.03
48.45
49.88
51.30
52.73
54.15
55.58
57.00
58.43
59.85
61.28
62.70
64.13
65.55
66.98
68.40
69.83
71.25
72.68
74.10
75.53
52
-------
13,500
13,750
14,000
14,250
14,500
14,750
15,000
15,250
15,500
76.95
78.38
79.80
81.23
82.65
84.08
85.50
86.93
88.35
53
------- |