A­
1
APPENDIX
A
MERCURY
CONCENTRATIONS
IN
FUELS
This
appendix
provides
the
basis
of
the
assumptions
in
this
study
on
the
mercury
concentrations
of
fossil
and
non­
fossil
fuels.

FOSSIL
FUELS
This
section
describes
this
study's
assumptions
on
mercury
concentrations
for
coal,
oil,
and
natural
gas
and
explains
the
methodologies
used
to
arrive
at
them.

Coal
Mercury
concentrations
in
different
types
of
coal
in
different
regions
of
the
country
were
calculated
through
the
following
four
steps:

 
Collected
data
on
mercury
concentrations
in
different
types
of
coal
by
State.
The
three
coal
types
are
bituminous,
subbituminous,
and
lignite.

 
Made
adjustments
in
mercury
concentrations
for
coals
in
those
States,
where
companies
would
clean
them
and
EPA
had
data
on
their
mercury
concentrations
prior
to
cleaning.

 
Converted
data
on
mercury
concentrations
that
were
expressed
in
parts
per
million
weight
(
ppmw)
to
pounds
of
mercury
per
trillion
Btus
of
heat
content
of
each
coal
(
lbs
/
TBtus).

 
Conducted
cluster
analysis
to
group
the
same
types
of
coals
with
similar
mercury
concentrations
together
to
arrive
at
an
average
estimate
of
the
mercury
concentrations
in
that
set
of
coals.

These
steps
are
described
below
in
detail.

Compilation
of
State
Data
EPA
relied
primarily
on
the
EPA's
Report
to
Congress
on
hazardous
air
pollutant
(
HAP)
emissions
(
HAP
Study;
EPA,
1998a).
1
The
mercury
concentrations
in
coal
used
for
the
purposes
of
the
IPM
mercury
emissions
analyses
are
reported
in
Exhibit
A1.
For
bituminous
coals
from
Illinois
and
Colorado,
mercury
concentrations
pertain
to
as­
shipped
coals,
which
are
deemed
cleaned
prior
to
shipping.

1
EPA.
1998a.
Study
of
Hazardous
Air
Pollutant
Emissions
from
Electric
Utility
Steam
Generating
Units
 
Final
Report
to
Congress.
Volumes
I
and
II.
Office
of
Air
Quality
Planning
and
Standards.
U.
S.
Environmental
Protection
Agency.
EPA­
453/
R­
98­
004a
&
­
004b.
February
1998.
A­
2
Coal
Cleaning
Bituminous
coals
from
selected
States
are
cleaned
to
meet
customer
specifications
for
heating
value,
and
ash
and
sulfur
content.
EPA
estimates
that
the
average
mercury
reduction
due
to
coal
washing
is
21
percent
in
the
HAP
Study.
In
the
IPM
mercury
analyses,
the
Agency
assumed
a
21
percent
reduction
for
bituminous
coals
shipped
from
14
States
(
i.
e.,
Alabama,
Iowa,
Indiana,
Kansas,
Kentucky,
Maryland,
Missouri,
Ohio,
Oklahoma,
Pennsylvania,
Tennessee,
Utah,
Virginia,
and
West
Virginia).
Consistent
with
the
HAP
Study,
no
mercury
removal
factor
was
applied
to
lignite
and
subbituminous
coals,
nor
to
bituminous
coals
shipped
from
Arizona,
Montana,
New
Mexico,
and
Wyoming.

Mercury
Concentrations
in
IPM
Mercury
concentrations
of
coal
(
i.
e.,
amount
of
mercury
per
unit
of
heat
content,
which
is
expressed
as
"
lbs/
TBtu")
differs
by
type,
based
on
their
initial
mercury
concentrations
on
a
parts
per
million
weight
(
ppmw)
basis
and
heat
content.
2
EPA
estimated
the
mercury
concentrations
in
coals
for
use
in
IPM
using
the
following
formula:

Mercury
concentration
of
coal
in
ppmw
*
lbs
to
short
ton
conversion
factor
/
heat
content
of
coal
*
MMBtu
to
Trillion
Btu
conversion
factor.
3
The
mercury
concentrations
reported
in
column
5
of
Exhibit
A1
pertain
to
the
average
mercury
concentrations
of
coal.
4
There
can
be
substantial
variation
in
the
mercury
concentrations
of
coal
from
different
mines
in
a
State
and
in
different
coal
seams
at
the
same
mine.
However,
Exhibit
A1
shows
that
certain
types
of
coals
in
various
regions
of
the
country
do
have
average
concentrations
of
mercury
that
differ
markedly
from
the
average
concentrations
of
mercury
of
other
types
of
coal.
In
the
same
coal
class,
there
are
also
marked
differences
in
average
mercury
concentrations
between
States.

2
The
different
sulfur
grades
of
coal
that
are
used
in
the
IPM
mercury
analyses
include
the
following
six
sulfur
grades
of
bituminous
coals,
three
sulfur
grades
of
subbituminous
coals,
and
two
sulfur
grades
of
lignite
coals:
Low
Sulfur
Eastern
Bituminous
(
BA),
Low
Sulfur
Western
Bituminous
(
BB),
Low
Medium
Sulfur
Bituminous
(
BD),
Medium
Sulfur
Bituminous
(
BE),
Medium
High
Sulfur
Bituminous
(
BF),
and
High
Sulfur
Bituminous
(
BG);
Low
Sulfur
Subbbituminous
(
SB),
Low
Medium
Sulfur
Subbituminous
(
SD),
and
Medium
Sulfur
Subbituminous
(
SE);
and
Low
Medium
Sulfur
Lignite
(
LD)
and
Medium
High
Sulfur
Lignite
(
LF).
3
The
details
of
this
calculation
are:
(
x
lbs
of
Hg
/
106
lbs
of
coal)
*
(
2,000
lbs
/
ton)
*
(
ton
/
y
MMBtu)
*
(
106
MMBtu/
TBtu)
where,
x
is
the
mercury
concentration
reported
in
the
HAP
Study
and
y
is
the
heat
content
of
coal,
derived
from
IPM.
4
The
average
mercury
concentration
of
coal
for
a
State
indicates
simple
average
mercury
concentration
of
various
sulfur
grades
of
a
particular
type
of
coal
shipped
from
that
State.
A­
3
Exhibit
A1
Average
Mercury
Concentrations
in
Coal
by
State
of
Origin
and
Coal
Type
State
of
Origin
Coal
Type
Original
Average
Mercury
Concentrations
(
ppmw)
1
Final
Average
Mercury
Concentrations
(
ppmw)
Final
Average
Mercury
Concentrations
(
lbs
of
Hg
per
Trillion
Btu)
Alabama
Bituminous
0.19
0.15
11.91
Arkansas2
Bituminous
0.17
0.13
21.84
Arizona2
Bituminous
0.07
0.07
6.45
Colorado
Bituminous
0.07
0.07
5.89
Iowa
Bituminous
0.19
0.15
14.70
Illinois
Bituminous
0.08
0.08
7.18
Indiana
Bituminous
0.11
0.09
7.96
Kansas
Bituminous
0.19
0.15
13.18
Kentucky
Bituminous
0.15
0.12
9.92
Maryland
Bituminous
0.42
0.33
26.58
Missouri
Bituminous
0.17
0.13
12.04
Montana
Bituminous
0.09
0.09
8.38
New
Mexico2
Bituminous
0.06
0.06
5.76
Ohio
Bituminous
0.22
0.17
14.94
Oklahoma
Bituminous
0.17
0.13
10.76
Pennsylvania
Bituminous
0.29
0.23
18.13
Tennessee2
Bituminous
0.15
0.12
9.63
Utah
Bituminous
0.04
0.03
2.87
Virginia
Bituminous
0.14
0.11
8.65
West
Virginia
Bituminous
0.16
0.13
10.11
Wyoming2
Bituminous
0.08
0.08
8.13
Alaska
Subbituminous
0.07
0.07
9.32
Montana
Subbituminous
0.09
0.09
9.97
New
Mexico
Subbituminous
0.06
0.06
7.06
Washington
Subbituminous
0.06
0.06
7.40
Wyoming
Subbituminous
0.08
0.08
9.35
Colorado2
Lignite
0.18
0.18
29.81
Louisiana
Lignite
0.19
0.19
28.04
Montana
Lignite
0.12
0.12
17.87
North
Dakota
Lignite
0.13
0.13
19.73
Texas
Lignite
0.19
0.19
31.51
Notes:
1
ppmw
=
parts
per
million
weight
=
lbs.
of
mercury
/
million
lbs.
of
coal.
2
For
Tennessee,
the
mercury
concentration
was
obtained
from
another
EPA
study
(
EPA,
1998b),
5
as
the
HAP
Study
does
not
report
this
information.
For
Arkansas,
the
mercury
concentration
of
bituminous
coal
was
assumed
to
be
the
same
as
that
for
bituminous
coal
from
Oklahoma.
Additionally,
for
Arizona,
New
Mexico,
and
Wyoming,
it
was
assumed
that
the
mercury
concentrations
of
bituminous
coal
were
the
same
as
the
mercury
concentrations
of
subbituminous
coal
from
those
states.
For
lignite
coal
from
Colorado,
the
average
mercury
concentration
of
all
lignite
coals,
as
reported
in
the
HAP
Study,
was
used.
Source:
EPA
5
EPA,
Analyzing
Electric
Power
Generation
under
the
CAAA,
March
1998.
A­
4
Cluster
Analysis
Mercury
concentrations
in
coal
vary
widely
across
different
types
in
different
States.
The
wide
range
of
mercury
concentrations
for
each
grade
of
coal
across
supply
regions
was
divided
into
similar
groups
using
"
clustering"
analysis
for
the
purposes
of
the
IPM
mercury
analyses.

The
clustering
analysis
places
objects
into
groups
or
clusters,
such
that
the
data
in
a
given
cluster
tend
to
be
similar
to
each
other,
and
that
they
are
dissimilar
to
the
data
in
other
clusters.
In
other
words,
the
clustering
analysis
minimizes
the
variance
(
i.
e.,
the
square
of
the
average
deviation
of
the
data
from
their
arithmetic
mean)
of
the
data
within
each
cluster.
6
The
clustering
analysis
was
performed
to
minimize
the
complexity
involved
in
incorporating
the
wide
range
of
mercury
concentrations
of
each
individual
sulfur
grade
and
type
of
coal
into
the
IPM
input
file.
The
clustering
analysis
was
performed
through
the
following
two
steps:

 
First,
the
number
of
clusters
of
mercury
concentrations
within
each
sulfur
grade
of
coal
was
determined
based
on
the
range
of
mercury
concentrations
for
that
sulfur
grade
of
coal
and
the
extent
of
its
supply.

 
Second,
the
SAS
clustering
analysis
program
was
used
to
group
the
mercury
concentrations
of
each
sulfur
grade
of
coal
across
various
supply
regions
into
a
specified
number
of
clusters,
such
that
the
variance
of
mercury
concentrations
within
each
coal
cluster
is
minimized.

For
example,
mercury
concentrations
of
Low
Sulfur
Western
Bituminous
(
BB)
coals
across
nine
supply
regions
are
in
the
range
of
2.61
to
8.12
lbs
of
Hg/
TBtu.
Based
on
the
amount
of
BB
coal
supplied
and
the
range
of
its
mercury
concentrations,
it
was
determined
that
BB
coal
would
be
divided
into
two
clusters.
Then,
using
the
SAS
clustering
analysis
program,
BB
coals
were
divided
into
a
BB1
cluster,
with
mercury
concentrations
not
exceeding
5.5
lbs
of
Hg/
TBtu,
and
into
a
BB2
cluster,
with
mercury
concentrations
exceeding
5.5
lbs
of
Hg/
TBtu.

Exhibit
A2
shows
the
clusters
of
various
sulfur
grades
of
coal
and
their
mercury
concentrations
that
were
developed
and
analyzed
in
this
effort.
EPA
assumed
in
IPM
that
the
coals
identified
in
the
first
column
had
the
average
mercury
concentrations
of
each
cluster
shown
in
the
columns
on
the
far
right
in
Exhibit
A2.
For
example,
the
mercury
concentration
of
BA
coals
from
Alabama
is
estimated
to
be
approximately
11.87
lbs
of
Hg/
TBtu.
Exhibit
A2
indicates
that
this
coal
falls
into
the
second
cluster
(
i.
e.,
BB2),
as
its
mercury
concentration
is
greater
than
10.5
lbs
of
Hg/
TBtu.
Therefore,
for
the
purposes
of
calculating
mercury
emissions
using
IPM,
the
average
mercury
concentration
of
the
BB2
cluster
(=
11.87
lbs
of
Hg/
TBtu)
was
used
for
all
BB2
coals.

6
In
other
words,
it
is
a
measure
of
dispersion
of
the
data
from
their
arithmetic
mean.
A­
5
Exhibit
A2
Coal
Clusters
and
Average
Mercury
Concentrations
(
Lbs
of
Hg
per
Trillion
Btu)
Range
of
mercury
concentration
within
each
coal
cluster
Average
mercury
concentration
within
each
cluster
Coal
Type
by
Sulfur
Grade
No.
of
clusters
Cluster
#
1
Cluster
#
2
Cluster
#
3
Cluster
#
1
Cluster
#
2
Cluster
#
3
Low
Sulfur
Eastern
Bituminous
(
BA)
2
 
10.5
>
10.5
­­
9.62
11.87
­­

Low
Sulfur
Western
Bituminous
(
BB)
2
 
5.5
>
5.5
­­
2.79
6.14
­­

Low
Medium
Sulfur
Bituminous
(
BD)
3
 
7.0
>
7.0
to
 
14.0
>
14.0
5.22
9.64
17.89
Medium
Sulfur
Bituminous
(
BE)
3
 
9.0
>
9.0
to
 
13.0
>
13.0
7.98
10.01
17.83
Medium
High
Sulfur
Bituminous
(
BF)
3
 
13.0
>
13.0
to
 
20.0
>
20.0
9.55
18.10
26.58
High
Sulfur
Bituminous
(
BG)
3
 
8.0
>
8.0
to
 
14.0
>
14.0
7.43
10.38
15.91
Low
Sulfur
Subbituminous
(
SB)
1
 
0
­­
­­
9.46
­­
­­

Low
Medium
Sulfur
Subbituminous
(
SD)
1
 
0
­­
­­
8.84
­­
­­

Medium
Sulfur
Subbituminous
(
SE)
1
 
0
­­
­­
9.37
­­
­­

Low
Medium
Sulfur
Lignite
(
LD)
1
 
0
­­
­­
23.80
­­
­­

Medium
High
Sulfur
Lignite
(
LF)
2
 
25.0
>
25.0
­­
19.73
31.31
­­

Notes:
­­
=
not
applicable.
A­
6
Oil
and
Natural
Gas
EPA
used
data
from
the
HAP
study
to
develop
average
mercury
concentrations
of
oil
and
natural
gas
(
see
Exhibit
A3).
The
Agency
estimated
mercury
concentrations
in
oil
and
natural
gas
for
use
in
the
IPM
analysis
in
the
following
manner:

 
Oil
­
The
mercury
concentration
of
0.0092
ppmw
was
converted
to
a
mercury
concentration
in
pounds
per
TBtu
using
the
following
formula:
Mercury
concentration
*
lbs
to
gallon
conversion
factor
/
heat
content
*
Btu
to
Trillion
Btu
conversion
factor
=
(
0.0092
lbs
/
106
lbs)
*
(
7.88
lbs
/
gal)
*
(
gal
/
150,000
Btu)
*
(
1012
Btu
/
TBtu)
=
0.483
lbs/
TBtu.

 
Natural
gas
­
The
mercury
concentration
of
0.0000024
mg/
cm
was
converted
to
a
mercury
concentration
in
pounds
per
TBtu
using
the
following
formula:
Mercury
concentration
*
cubic
meter
(
cm)
to
cubic
feet
(
cft)
conversion
factor
/
heat
content
*
Btu
to
Trillion
Btu
conversion
factor
*
mg
to
kg
conversion
factor
*
kg
to
lbs
conversion
factor
=
(
2.4
*
10­
6
mg/
cm)
*
(
0.027
cm/
cft)
*
(
cft/
1,035
Btu)
*
(
1012
Btu/
TBtu)
*
(
kg/
106
mg)
*
(
2.21
lbs/
kg)
=
0.000138
lbs/
TBtu.

Exhibit
A3
Average
Mercury
Concentrations
in
Oil
and
Natural
Gas
Fuel
Type
Unit
for
Mercury
Concentration
in
the
HAP
Study
Mercury
Concentration
in
the
HAP
Study
Mercury
Concentration
In
IPM
(
lbs
of
Hg/
TBtu)
Oil
Ppmw
0.0092
0.483
Natural
Gas
mg/
cm
0.0000024
0.00014
Notes:
ppmw
=
parts
per
million
weight
=
lbs.
of
mercury
/
million
lbs.
of
oil.
Source:
EPA
NON­
FOSSIL
FUELS
The
non­
fossil
fuels
covered
in
this
study
are
wood
waste,
municipal
solid
waste,
and
geothermal
resources.
The
source
of
data
on
the
mercury
concentrations
in
these
fuels
is
EPA's
Mercury
Study
Report
to
Congress.
Volume
II:
An
Inventory
of
Anthropogenic
Mercury
Emissions
in
the
United
States,
December
1997
(
Mercury
Study).
7
Exhibit
A4
reports
the
assumptions
on
the
mercury
concentrations
of
non­
fossil
fuels
that
EPA
uses
in
the
IPM
analysis.
Details
on
how
EPA
prepared
these
estimates
are
provided
below.

7
EPA.
1997.
Mercury
Study
Report
to
Congress.
Volume
II:
An
Inventory
of
Anthropogenic
Mercury
missions
in
the
United
States.
Office
of
Air
Quality
Planning
and
Standards
and
Office
of
Research
and
Development.
U.
S.
Environmental
Protection
Agency.
EPA­
452/
R­
97­
004.
December
1997.
A­
7
Exhibit
A4
Average
Mercury
Concentrations
of
Non­
Fossil
Fuels
(
lbs
of
Hg
per
TBtu)
Fuel
Type
Average
Mercury
Concentration
in
IPM
Wood
Waste
0.57
Municipal
Solid
Waste
71.85
Geothermal
Resource
4.08
Wood
Waste
Consistent
with
the
Mercury
Study,
the
mercury
concentration
of
wood
waste
is
assumed
to
be
0.0000052
lbs
per
ton.
Also,
based
on
the
same
study,
the
heat
content
of
wood
waste
has
been
assumed
to
be
4,560
Btu/
lb.
Based
on
these
estimates,
the
mercury
concentration
in
wood
waste
was
calculated
for
use
in
the
IPM
analysis
as
follows:
=
(
5.2*
10­
6
lbs/
ton)
*
(
lbs/
4,560
Btu)
*
(
ton/
2,000
lbs)
*
(
1012
Btu/
TBtu)
=
0.57
lbs/
TBtu.

Municipal
Solid
Waste
Municipal
Waste
Combustors
(
MWCs)
are
subject
to
the
New
Source
Performance
Standards
for
MWCs,
which
require
MWCs
to
reduce
mercury
emissions
by
about
90
percent.
For
the
purposes
of
the
IPM
mercury
analyses,
EPA
assumed
that
MWCs
would
achieve
this
reduction
by
the
year
2005
and
mercury
concentrations
in
the
MSW
are
assumed
to
be
0.08
mg/
dscm.
Based
on
this
estimate,
the
mercury
concentration
of
municipal
waste
was
calculated
for
use
in
the
IPM
analysis
as
follows:
=
(
20.9/
13.9)
*
(
0.08
mg/
dscm)
*
(
9,570
cft/
MMBtu)
*
(
cm/
35.31
cft)
*
(
106
MMBtu/
TBtu)
*
(
Metric
Ton/
109
mg)
*
(
1.102
tons/
Metric
ton)
*
(
2,000
lbs/
ton)
=
71.85
lb/
TBtu.

Geothermal
EPA
estimates
that
the
average
mercury
emissions
factor
for
geothermal
plants
is
estimated
to
be
0.00012
lbs/
MWh.
Assuming
a
heat
rate
of
29,425
Btu/
KWh,
the
mercury
concentration
of
a
geothermal
resource
was
calculated
for
use
in
the
IPM
analysis
in
the
following
way:
=
(
0.00012
lbs/
MWh)
*
(
MW/
1,000KW)
*
(
KWh/
29,425
Btu)
*
(
1012
Btu/
TBtu)
=
4.078
lbs/
TBtu
