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FAQ - Coal Analyses (Part II)

3. What analyses are required and what must be reported or provided?

For facilities required to complete Part II, the total tonnage of coal received (i.e., all shipments) by a facility over the period of the information collection effort must be reported. No sample identification numbers need to be reported on question 3 of Part II for those shipments received for which no analyses are required.

For each coal sample analyzed to fulfill the requirements of the information collection effort (i.e., representing every sixth shipment, at least to start), the following analyses are required:

  • Total sulfur, percent
  • Heating value, Btu/lb
  • Ash, percent
  • Mercury, ppm
  • Chlorine, ppm
For purposes of consistency between shipments and facilities, reporting of all analyses (and tonnages) is being requested on a dry basis. Any other analyses obtained from this sample (e.g., arsenic, chromium) may also be provided on an entirely voluntary basis.

If it is the policy of the facility to obtain samples from other shipments (e.g., shipments 1 to 5), analyses (for whatever constituent) of these shipments do not need to be provided to the Agency. Similarly, any historical coal analyses in the possession of the facility do not need to be provided to the Agency.

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4. Do you have to submit hard-copy information to satisfy Part II, Questions 5-11, or will the Web site be set up to accept this type of data/information, too?

The Web site will be set up to handle all of Part II up to question 10. Part II, question 11 will require the submission of hard-copy information and should be submitted to the same address as Part I.

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5. How do you report "Amount received, dry basis, tons" for the sampling of stockpiled coal in the months when no shipments are received?

Example: Site receives seven shipments per year (by boat) from a single source and a single seam from May to November. They burn this stockpiled coal throughout the year. When they are sampling this stockpiled coal (every 10 days) in the months where they are not receiving shipments, how do they address the part of question 3 asking for "Amount received, dry basis, tons" for the sample?

Answer: When adding analysis data on this type of sample to the web page, enter an applicable statement (e.g., "coal pile sample-no coal received", "as-fired sample-no coal received) in that part of question 3 asking for "Amount received, dry basis, tons". That is, a minimum of three analyses are required for months where coal is burned, even if no coal shipments are received. However, a clear indication should be made of analyses of shipments received and of analyses that reflect coal burned when no shipments are received.

Similarly, tonnages are required to be reported for all coal shipments received; however, the sample identification needs only be reported for the analyzed shipment.

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6. In question 3 of Part II (Amount received, dry basis, tons), what moisture content should be used to convert tonnages to a dry basis?

Answer: EPA is not requiring companies to report analyses for all shipments, however, EPA believes that this can be handled in one of two ways:

  1. if the company routinely analyzes all shipments for proximate/ultimate (incl. moisture), they should use those analyses to determine dry tonnage.
  2. if the company doesn't routinely analyze all shipments for moisture, they should use some average moisture content taken from whatever analyses they do perform.

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7. In question 4 of Part II (Total amount of coal represented by sample, tons), what total is EPA referring to?

Answer: The tons represented by sample should be only for the shipment analyzed.

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OMB Control Number 2060-0396
Last Update: 10 March 1999
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