Dear Mr. Storm,
Not sure if I showed you this before, but wanted you to review and comment on this presentation on Carbon Dioxide Measurement at our NWSA website. Paul Wolff and I studied correlations of coal type and carbon / BTU correlations from USGS data, and found high correlations of Carbon and Btu with coal type. This means that one can accurately predict CO2 emissions from coal type, more accurately than CEMS or coal sampling. Todays carbon monitoring legislation (Carbon mass balance, I.e. coal sampling, and CEMS continuous emission monitors) is based on possibly the two LEAST accurate methods of measurement of the four available types. The conclusion is that accurate heat rate monitoring systems and use of a constant for carbon in the fuel based on coal rank (based on linear relationships from the USGS database) is the best way to measure carbon dioxide emissions and avoid “Gaming” the system for carbon reporting being mandated by EPA. This would also give clear incentives to power plant owners to act to reduce heat rate and increase efficiency whenever possible. As you know, efficiency improvement is the only true way to reduce emissions in real time, with sequestration being the only other alternative. With the EPA’s ruling it is likely that “Gaming” the system will prevail. And all engineers know, efficiency just makes sense. This parallels your thesis of revitalizing America’s coal plants with newer, modern materials to get more power from the same coal consumption.