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vi: 5. :~ _ _ -.' - - - ...-.. VnIC.!n• ni•! OL uJ b\1L <br />- Adobe Mining ~o. <br />254 South Jefferson Street <br />January 5, 1943 Kltt>.nningt PA id201 <br />(412) 543-2592 <br />Mr. Jerome A. Farnella <br />OSM: Audit Appeals Officer <br />Division of Compliance Nanayement <br />Ten Parkway Center <br />Pittsburgh, PA 15220 <br />SUe,7ECT: EQIIIIIBRIUM MOISTURE <br />Gear Mr. Farnella: <br />ae AoflneA in OSTM IA17.A0_ "StanAa rrl To tt methnA for Fr~„iTihri,m, Mn1rt„re of foal •* <br />96 to 97 percent relative humidity and 30'C," "This test method affords a means of estimating <br />the bed moisture of either coal that 1s wet and shows visible surface moisture, or coal that <br />may have lost soma moisture. !t may be used for estimating the surface, or extraneous moisture <br />of wet coal, sucA moisture being the difference between the total moisture as determined by test <br />method 0 3302 and the Equilibrium Moisture". The test provides a means to estimate bed moisture. <br />ASTH D 1412-H9 1s used when coals show rlslbte signs of excess moisture or moisture loss. Our <br />samples are collected daily and sampled within a 24 hour period. The samples do not Show <br />excessive moisture unless very wet conditions exist outside nor does the sample have excess <br />moisture Toss because samples are bagged to plastic begs and processed quickly. <br />The total aalsture test that we have performed on our coal using ASTM D 2961 er AS1M 0 3173 essen- <br />tially provides results of what the moisture is of our coals as we produce the coal or collect samples 1n <br />our exploration process. The samples are collected under oaring conditions sent to the labs and <br />analyzed far total moisture. Based on 110 core samples from the McCoytown Plant area in the Brookville. <br />Lower Kittanning and Clarion seams, the totai'moisture was 3.535. The average moisture on raw coals <br />from the Dutch Run Plant areas, Upper Freeport. Middle Kittanning and Lower Kittanning coals 1s <br />3.395. <br />These moistures represent total moistures of coals that have been randomly collected. <br />By no means have these samples achieved Equilibrivm as defined in ASTM D 3302-89a, "Equi11br1wrt- <br />conditlon reached in air drying where change in weight of the sample. under conditions Of ambient <br />temperature and humidity is no more than 0.15/hr or 0.055/k11r°. Assuming that these samples have not <br />been allowed to air dry "ASTM D 3302-89a, Air Drying - a process of Dertlal drying of a coal sample to <br />Bring 1t to near Equilibrium with the atmosphere in the roam in which further reduction/division of the <br />sample is t0 take place", then the moistures in the samples we caTlect on a dally basis ere in excess <br />of the Equilibrium Moisture. The arbitrary allocation of an Equilibrium Moisture in excess of what the <br />total moisture is on our raw coals is un~ustifled. <br />i once egsin asked that OSM re-audit all the infonnatien we have concerning inherent moisture So <br />that we can put this issue to rest. <br />Sincerely, <br />~. <br />Eric Urbanowicz <br />EU/db <br />