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Carbon dioxide emission tallies for 210 U.S.

coal-fired power plants: A comparison of two
accounting methods

Jeffrey C. Quick

To cite this article: Jeffrey C. Quick (2014) Carbon dioxide emission tallies for 210 U.S. coal-fired
power plants: A comparison of two accounting methods, Journal of the Air & Waste Management
Association, 64:1, 73-79, DOI: 10.1080/10962247.2013.833146

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TECHNICAL PAPER

Carbon dioxide emission tallies for 210 U.S. coal-fired power plants:
A comparison of two accounting methods
Jeffrey C. Quick⁄
Utah Geological Survey, Salt Lake City, Utah, USA
⁄Please address correspondence to: Jeffrey C. Quick, Utah Geological Survey, P.O. Box 146100, 1594 W. North Temple, Salt Lake City, UT 84114,
USA; e-mail: jeffreyquick@utah.gov

Annual CO2 emission tallies for 210 coal-fired power plants during 2009 were more accurately calculated from fuel consumption
records reported by the U.S. Energy Information Administration (EIA) than measurements from Continuous Emissions Monitoring
Systems (CEMS) reported by the U.S. Environmental Protection Agency. Results from these accounting methods for individual plants
vary by
10.8%. Although the differences systematically vary with the method used to certify flue-gas flow instruments in CEMS,
additional sources of CEMS measurement error remain to be identified. Limitations of the EIA fuel consumption data are also
discussed. Consideration of weighing, sample collection, laboratory analysis, emission factor, and stock adjustment errors showed
that the minimum error for CO2 emissions calculated from the fuel consumption data ranged from
1.3% to
7.2% with a plant
average of
1.6%. This error might be reduced by 50% if the carbon content of coal delivered to U.S. power plants were reported.

Implications: Potentially, this study might inform efforts to regulate CO2 emissions (such as CO2 performance standards or
taxes) and more immediately, the U.S. Greenhouse Gas Reporting Rule where large coal-fired power plants currently use CEMS to
measure CO2 emissions. Moreover, if, as suggested here, the flue-gas flow measurement limits the accuracy of CO2 emission
tallies from CEMS, then the accuracy of other emission tallies from CEMS (such as SO2, NOx, and Hg) would be similarly
affected. Consequently, improved flue gas flow measurements are needed to increase the reliability of emission measurements
from CEMS.

Introduction
Carbon dioxide emissions from coal-fired power plants can be
calculated from flue gas composition and volume measurements
made by Continuous Emission Monitoring Systems (CEMS) or
from fuel consumption and quality measurements using mass
balance calculations. Results from CEMS are included in the
U.S. Environmental Protection Agency (EPA) Clean Air
Markets Division (CAMD) database (U.S. Environmental
Protection Agency, 2012a) whereas fuel consumption and quality
measurements are included in the U.S. Energy Information
Administration (EIA) Form-923 database (U.S. Energy
Information Administration, 2012). Comparison of CO2 emission
tallies from these databases (Ackerman and Sundquist, 2008;
Borthwick et al., 2011; Huang and Gurney, 2011) shows similar
population totals, but significantly different results for individual
units and plants, which leads to several questions. Are CO2
emissions more accurately measured by CEMS, or calculated
from fuel consumption? Why do results from these accounting
methods differ? Definitive answers to these questions are needed
to inform discussion of CO2 emission trading programs, perfor-
mance standards, or taxes. Comparison of results from tests of
varied duration for units at unnamed plants has suggested that
CO2 emissions measured by CEMS are more accurate than those
calculated from fuel consumption (Evans et al., 2009) and, alter-
natively, that both methods are prone to error (Zimmerman,
2009). Accordingly, this study attempts to answer these questions
by using published data to compare CO2 emissions measured by
CEMS with CO2 emissions calculated from fuel consumption
measurements for 210 coal-fired power plants during 2009.
Method
Data
The year-2009 data used in this study are from the CAMD
website (U.S. Environmental Protection Agency, 2012a), EIA
spreadsheet files (U.S. Energy Information Administration,
2012), and summaries of these data (Emissions & Generation
Resource Integrated Database, 2012). Some additional data
(Bragg et al., 1998; Keystone, 2002; U.S. Energy Information
Administration, 2003; Illinois Geological Survey, 2007), which
have been described elsewhere (Quick, 2010), were used with
the EIA data to calculate CO2 emission factors. Methods used to
certify flue-gas flow at these plants were from the EPA Emissions
Collection and Monitoring Plan System (U.S. Environmental

73
Journal of the Air & Waste Management Association, 64(1):73–79, 2014. Copyright © 2014 A&WMA. ISSN: 1096-2247 print
DOI: 10.1080/10962247.2013.833146 Submitted June 3, 2013; final version submitted July 20, 2013; accepted August 5, 2013.
74 Quick / Journal of the Air & Waste Management Association 64 (2014) 73–79
Protection Agency, 2012b). Finally, an unpublished data set that
includes the C content of commercial coal shipments was used to
estimate the error resulting from the use of the calculated CO2
emission factors.
Plant selection
This study narrowly compares CO2 emissions measured by
CEMS (CAMD data) with CO2 emissions calculated from fuel
consumption (EIA data) for 210 coal-fired power plants during
2009. Note that this comparison is made at the plant level rather
than the individual unit (boiler) level. Aggregation of emissions
data at the plant level avoids complications due to differences in
how individual units within a plant are identified and accounted
for in the CAMD and EIA data collection efforts, as well as
variation where unit fuel consumption reported to the EIA was
estimated rather than measured. Plant selection criteria include:
 The plants are listed in both the CAMD and EIA databases.
 The CAMD CO2 emission data are from CEMS.
 The CAMD data included gross electric generation.
 More than 99% of the fuel burned during 2009 was coal.
 Combined heat and power plants were ignored.
 The plant capacity factor was greater than 0.10.
The selected power plants represented about one-third of
U.S. coal-fired power plants, but were responsible for more
than two-thirds of the electricity generated from coal, and nearly
18% of the 7.3 billion tons (CO2 equivalent) of U.S. greenhouse
gas emissions during 2009 (U.S. Environmental Protection
Agency, 2013). Notably, the selected plants exclude large gas-
fired units (where CEMS are rarely used) and combined heat and
power plants (where the data sets differ in the allocation of heat
input for electricity). Limiting the comparison to coal-fired
power plants excludes plants that burn biomass (where biogenic
CO2 is inconsistently counted). Finally, data were excluded for
two plants (ORIS [plant identification] codes 1382 and 6052)
where the apparent parasitic energy consumption (gross genera-
tion minus net generation) exceeded 30%, and another two
plants (ORIS codes 1832 and 2712) where the apparent parasitic
energy consumption was a negative value.
Calculated CO2 emissions
Annual plant-level CO2 emissions were calculated from the
EIA data (U.S. Energy Information Administration, 2012) in
several steps. First, the average heating value of the delivered
coal was multiplied by the tons of coal consumed to determine
the annual coal heat input (British thermal units [Btu]) for each
plant. Next, plant-specific CO2 emission factors (lb CO2/million
Btu) for 2009 were calculated according to the geographic origin,
quality, and tons of delivered coal, as described elsewhere (Quick,
2010). The annual heat input from coal was multiplied by the
plant-specific CO2 emission factor to calculate the CO2 emissions
from coal burned at each plant. Carbon dioxide from noncoal fuel
consumption was calculated by multiplying the heat input from
auxiliary fuels listed with the EIA Generation and Fuel data
(natural gas, jet fuel, distillate petroleum, residual fuel oil, tire-
derived fuel, and petroleum coke) by their nominal CO2 emission
factors (117, 160, 161, 174, 190, and 225 lb CO2 /million Btu,
respectively) (U.S. Energy Information Administration, 2011).
Finally, the amounts of CO2 from the coal and the auxiliary
fuels were added together to obtain the total CO2 emissions for
each power plant. The auxiliary fuels contributed less than 0.7%
of the total CO2 emissions from any of the plants in this study.
Measured CO2 emissions
Nearly all of the CAMD CO2 emission results for the 210
plants originate from flue-gas volume and CO2 concentration
measurements from CEMS. Monthly plant CO2 emission tallies
were downloaded from the CAMD website (U.S. Environmental
Protection Agency, 2012a) and combined to obtain the annual
plant totals for 2009. Note that many plants had multiple CEMS,
generally corresponding to the number of combustion units at
the plant. In these instances the monthly data represent the sum
of emissions from multiple units. Besides the CO2 emissions, the
gross electric generation and the SO2 emissions were also down-
loaded from the CAMD website.
Results and Discussion
Figure 1 shows the difference between annual CO2 emissions
measured by CEMS and annual CO2 emissions calculated from
fuel consumption for 210 coal-fired U.S. power plants during
2009. Note that the differences shown in Figure 1 are normally
distributed about a mean value near zero (–0.7%). Consequently,
both the CAMD and the EIA emission tallies should provide
about the same total emissions for the U.S. coal-fired electric
generating fleet. However, consistent with previous work
(Ackerman and Sundquist, 2008; Borthwick et al., 2011;
Huang and Gurney, 2011), Figure 1 also shows that these meth-
ods indicate significantly different CO2 emission tallies for
individual plants. Indeed, Figure 1 shows that these differences
vary by
10.8% (two times the standard deviation) for indivi-
dual plants. Less clear is whether these differences originate
from erroneous EIA measurements, CAMD measurements, or
both.
Origin of the CO2 emission measurement error
To identify the origin of the measurement error indicated by
Figure 1, the CAMD and EIA CO2 emission tallies for each plant
were divided by the plant’s annual gross electric generation
(MWh); the reason for this data transformation is explained in
the supplemental material. The resulting CAMD and EIA CO2
emission rates (lb CO2/MWh) are compared in Figure 2. The
comparison shows both data sets have similar average CO2
emission rates (less than 1% difference), but the CAMD emis-
sion rates show a 30% greater range of variation compared to the
EIA emission rates. The CAMD and EIA CO2 emission rates are
directly compared in Figure 3. Note the larger standard error in
Figure 3a (where the CAMD rates are the dependent variable)
compared to Figure 3b. Measurement error in the dependent
variable inflates the standard error (Hutcheon et al., 2010).
Also note the diminished slope of the best-fit line in Figure 3b
(0.60) where the CAMD rates are the independent variable
compared to the slope for the best-fit line in Figure 3a (1.01).
 Quick / Journal of the Air & Waste Management Association 64 (2014) 73–79
Figure 1. Annual CO2 emissions measured by CEMS (CAMD data) vary by
10.8% (two times the standard deviation) from CO2 emissions calculated from fuel
consumption (EIA data) for 210 U.S. coal-fired power plants during 2009. The percent difference was calculated according to: 100  (CAMD – EIA)/[(CAMD þ
EIA)/2].
Figure 2. Annual CO2 emission rates calculated from CAMD and EIA data for
210 U.S. power plants during 2009 show similar mean values (2,062 and 2,074 lb
CO2/MWh, respectively), but more variable CAMD emission rates compared to
EIA emission rates (standard deviations of 178 and 137 lb CO2/MWh,
respectively).
The diminished slope is called attenuation bias, and results from
measurement error in the independent variable (Hutcheon et al.,
2010). These observations show that the difference between the
CAMD and EIA CO2 emission tallies shown in Figure 1 is
largely due to CAMD measurement error. Thus, for individual
plants the annual CAMD CO2 emission tallies are less accurate
than those calculated from EIA fuel consumption data.
Cause of the CAMD CO2 measurement error
Consideration of the measurement frequency as well as cali-
bration and certification protocols helps to explain the cause of
the CAMD measurement error shown in Figure 3. The annual
emission totals for these power plants are based on hourly flue-
gas volume and CO2 concentration measurements. EPA rules
(U.S. Environmental Protection Agency, 2009) require daily
calibration of instruments in CEMS that measure the flue-gas
CO2 concentration to within 1.0% CO2 (by volume); this
75
corresponds to a relative precision between
7 and
12% for
typical flue gas CO2 concentrations (between 8 and 14% CO2 by
volume). Importantly, the calibration is accomplished using
cylinder gas standards, which minimizes the possibility of sig-
nificant CO2 concentration measurement bias. Moreover, the
frequent (daily) calibration requirement substantially reduces
the influence of the limited measurement precision. For example,
during 2009 each power plant reported between 3,486 and
76,658 hourly CO2 measurements (average ¼ 17,442).
Assuming daily calibration with a precision of
10%, the CO2
concentration measurement errors would cancel during the year
p would cause a
0.8% error in the annual emission
and at most
total (10/ (3,468/24) ¼ 0.8). Although leaks in the sample gas
collection system can reduce the measured CO2 concentration,
this potential bias is readily identified during mandatory annual
or semi-annual audits (Boze, 2010).
The possibility of significant and persistent flue-gas flow
measurement error is more difficult to dismiss. Unlike the CO2
concentration measurement, the flue-gas flow measurement is
not challenged with a calibration standard. Indeed, a huge known
volume of flue gas would be required to directly calibrate the
flue-gas flow measurement system at a power plant; such stan-
dards do not exist. Consequently, the accuracy of the flue-gas
flow measurement cannot be assured. Although the flue-gas flow
measurement system is not directly calibrated, it must be peri-
odically certified during annual or semi-annual audits to comply
with EPA rules. Certification is accomplished by comparing
flue-gas flow measurements from the installed equipment with
independent flue-gas flow measurements obtained using a
EPA-approved method (Table 1) (U.S. Environmental
Protection Agency, 2012c). Method 2 was initially developed
to certify the performance of CEMS used to measure SO2 emis-
sions. Unrealistically high SO2 emission tallies at some power
plants were subsequently attributed to a high flue-gas flow bias
due to the inability of method 2 to account for velocity decay
near the stack wall, as well as nonlaminar, inclined, or swirling
flow within the stack (Placet et al., 2000). Accordingly, the EPA
modified method 2 for these situations, and special provisional
methods were approved for rectangular ducts.
76 Quick / Journal of the Air & Waste Management Association 64 (2014) 73–79

Figure 3. Attenuation bias due to CAMD measurement error is shown by comparison of best-fit lines where (a) EIA CO2 emission rates are used to predict CAMD
rates, and (b) CAMD CO2 emission rates are used to predict EIA rates (data are for 210 U.S. coal-fired power plants during 2009). Although both lines share the same
significance and correlation (P < 0.001, R2 ¼ 0.61), note the larger standard error for (a) and that the slope for (b) is closer to zero.

Table 1. EPA methods used to measure and certify flue-gas flow. Results from the installed measurement system must agree with results from one or more of these
methods

Method Description
2 Assumes laminar flow, no wall effects adjustment
D2H Assumes laminar flow, default wall effects adjustment
M2H Assumes laminar flow, measured wall effects adjustment
2G Assumes inclined flow, no wall effects adjustment
2GH Assumes inclined flow, measured or default wall effects adjustment
2F Assumes swirling flow, no wall effects adjustment
2FH Assumes swirling flow, measured or default wall effects adjustment
2J Rectangular ducts, assumes laminar flow, measured or default wall effects adjustment
2GJ Rectangular ducts, assumes inclined flow, measured or default wall effects adjustment
2FJ Rectangular ducts, assumes swirling flow, measured or default wall effects adjustment

About half of the 210 plants included in this study used more
than one of the methods listed in Table 1 to certify their CEMS
during 2009. For plants that used only one method, Table 2
shows that those that used method 2 reported significantly higher
CO2 emissions than indicated by plant fuel consumption. As
noted earlier, method 2 has long been known to potentially
overestimate flue-gas flow (Placet et al., 2000) and, conse-
quently, CO2 emissions. Apparently, this positive bias persists.
Table 2 also shows that plants with CEMS that were certified
using methods 2GH and M2H reported significantly lower CO2
emissions than indicated by fuel consumption, which is consis-
tent with negative bias due to underestimated flue-gas flow.
Together, these observations support the idea that the CAMD
measurement error is at least partly due to biased flue-gas flow
measurements, which systematically vary with the flue-gas flow
certification method. However, the flue-gas flow measurement
bias accounts for less than half of the larger range of variation of
CAMD CO2 emission rates compared to EIA CO2 emission rates
shown in Figure 2. Consequently, an additional source of CAMD
measurement error remains to be identified. Given the limited
frequency of CEMS certification (once or twice a year), the
precision of the flue gas flow measurements during certification
could contribute to this remaining, albeit unidentified, measure-
ment error.
Improving the accuracy of CAMD CO2 emission
tallies
The EIA data are reported by month and obviously lack the
temporal resolution provided by CEMS. Indeed, the CAMD data
are reported every hour and can be summed by varied time
interval (day, night, week, month, and so forth). This temporal
 Quick / Journal of the Air & Waste Management Association 64 (2014) 73–79
Table 2. The difference between CAMD and EIA CO2 emissions varied with the method used to certify the CAMD flue-gas flow measurement at 112 power plants
during 2009
Method na CO2 % differenceb
2 32 þ3.0
2F 9 þ1.6
D2H 13 0.2
2FH 12 0.8
M2H 17 3.1
2GH 29 3.0
Number of plants. bAverage percent difference between CAMD and EIA CO2 emissions, calculated as: 100  (CAMD – EIA)/[(CAMD þ EIA)/2]. cStandard
a
deviation of the percent difference. dTwo-sample, ntotal ¼210, assuming equal variances. e Significance, two-tailed distribution. f Method significantly different at
95% confidence. g Method significantly different at 90% confidence.
resolution is useful for carbon-cycle studies (Gurney et al., 2009)
and potentially, calibration of orbital CO2 emission verification
tools (Velazco et al., 2011). However, the excellent temporal
resolution provided by CEMS is diminished by their limited
accuracy, which is at least partly due to flue-gas flow measure-
ment bias. Where accuracy is important and temporal resolution
useful, it should be possible to proportionally adjust the CEMS
CO2 measurements to comport with the annual CO2 emissions
calculated from EIA fuel consumption measurements. This
adjustment would improve the accuracy of the CAMD CO2
emission measurements and retain the temporal resolution pro-
vided by CEMS.
Limitations of EIA fuel consumption data
Although they allow for more accurate annual CO2 emission
tallies, limitations of the EIA data should also be considered.
Both random and systematic measurement errors are likely.
Random error (precision) can be evaluated by considering the
instrumental precision of the coal consumption and quality mea-
surements, and is reduced with repeated measurements.
Systematic error (bias) is more difficult to identify, but is mini-
mized where the measurement instruments are calibrated using
standards having a known mass or composition.
One way EIA verifies the tons of coal consumed is by com-
parison with the amount of delivered coal and the change in coal
stocks. Ideally, the tons of coal consumed must equal the tons of
delivered coal minus any change in the amount of coal in the
plant stockpile. The amount of delivered coal is measured using
calibrated scales, which for commercial purposes are calibrated
using standard weights to within
0.25% (National Institute of
Standards and Technology, 2012). Stock changes are calculated
from annual or more frequent stockpile surveys. The stockpile
survey error is thought to be about
5% (DeSollar, 2011), which
corresponds to a
7.1% error for the stock change (ending
stockpile measurement minus beginning stockpile measure-
ment) according to eq 1:
pffiffiffiffiffiffiffiffiffiffiffiffiffiffiffi
52 þ 52 ¼ 7:1
Results from stockpile surveys are reported to the EIA, but are
not published. Accordingly, an apparent stock adjustment was
77
s
%diff.
c
t-Statisticd Pe
5.4 4.5 0.00f
5.8 1.3 0.19
5.0 0.4 0.70
4.9 0.0 0.96
4.2 þ1.9 0.06g
4.8 þ2.5 0.01f
estimated for each plant to equal the absolute difference between
the delivered tons and the consumed tons during 2009. The
apparent stock adjustment varied widely (see supplemental
material), but typically was about 5% of a plant’s annual coal
consumption.
Carbon dioxide emissions were calculated using CO2
emission factors (lb CO2/million Btu). The plant-specific
emission factors used in this study introduce a
1.3%
error, which is significantly less than the
2.3% error
expected for emission factors specified by coal rank (see
supplemental material). The error introduced by emission
factors is systematic (Frey and Tran, 1999) and cannot be
reduced by repeated measurement. However, because the
emission factor error may have either positive or negative
expressions, its influence can be reasonably considered by
simple error propagation methods.
The precision of the heating value measurement can also be
considered. In the laboratory, the heating value is measured
using a bomb calorimeter to within
140 Btu/lbdry for lignite
and subbituminous coal, and
107 Btu/lbdry for higher rank coal
(ASTM, 2000a). The calorimeter is calibrated using a compound
with a known heat of combustion so measurement bias is negli-
gible. The precision of the heating value measurement corre-
sponds to an average
1.0% relative error for the 210 plants in
this study, which varied between
0.8% and
1.7% depending
on the rank, heating value, and estimated moisture content of the
delivered coal.
Finally, error due to the collection and preparation of the
analysis sample can be estimated. General-purpose sampling
procedures specified in ASTM (2000b) method D-2234 are
intended to provide an analysis sample with a composition
within
10% of the dry ash yield of the shipment. Although
modern sampling systems can achieve better precision (Rose
and Byer, 2012), a
10% error is assumed here. This corre-
sponds to an average
1.0% relative error due to
sample collection, with results for individual plants ranging
from
0.6% to
1.4% depending on the ash yield and
estimated moisture content of the delivered coal. Assuming
(1) a
1.0% relative error for the heating value determination,
a
1.0% relative error due to sample collection, and that
5% of the consumed coal is accounted for by stock adjust-
ments, eq 2:
78 Quick / Journal of the Air & Waste Management Association 64 (2014) 73–79
qffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffi
ð0:95 0:25Þ2 þ ð0:05 7:1Þ2 þ 1:32 þ 1:02 þ 1:02 ¼ 2:0
shows that CO2 emissions calculated from mass and quality
measurements associated with a typical shipment should vary
by about
2.0%. Note that most of the power plants received 10
to several hundred coal shipments during 2009. Consequently,
random errors attributed to the coal shipment decline as the
number
p of shipment
p measurements
p (n) increases, according to
0.25/ n, 1.0/ n, and 1.0/ n for the delivered tons, sample
collection, and heating value, respectively. Substituting these
values into eq 2 allows calculation of the minimum error of the
annual CO2 emission tally calculated from the EIA fuel con-
sumption data for each plant according to eq 3:
sffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffiffi
   2  2ffi
X  0:25 2 Z W
pffiffiffi þ ðY  7:1Þ2 þ 1:32 þ pffiffiffi þ pffiffiffi
n n
where n is the number of shipments received by the plant during
2009, Y is the percent of the consumed coal accounted for by the
apparent stock adjustment (expressed as a decimal fraction), X ¼
1–Y, Z is the plant-specific heating value measurement error, and
W is the plant-specific sample collection error. Figure 4 shows
results from eq 3 for the 210 plants included in this study.
Results shown in Figure 4 are considered minimum values due to
unrecognized systematic measurement error (bias) associated with
stockpile measurements, sample collection protocols, and other
sources. Bias in stockpile surveys may have multiple causes, such
as the difference between the survey datum and the true elevation of
the ground surface under the stockpile. Like flue-gas flow monitor-
ing systems, coal sample collection systems are not directly cali-
brated. Instead, these systems are certified by comparison with
results from an independent sample collection method (ASTM,
2010), where the frequency of certification is specified by commer-
cial contracts, rather than government regulations. Other sources of
bias not considered in this study include additional CO2 from acid-
gas sorbents and avoided CO2 where unburned C is found in ash.
Figure 4. The minimum error of the annual CO2 emission tally calculated from
the EIA fuel consumption data varies between
1.3% and
7.2% for 210
U.S. coal-fired power plants during 2009.
However, as discussed in the supplemental material, ignoring CO2
from acid-gas sorbents introduces a small negative bias (0 to –3.2%
(2) range, average –0.4%) that is trivial compared to the
10.8%
variation shown in Figure 1. The amount of CO2 lost to unburned
C introduces a positive bias, but this error is also too small (esti-
mated þ0.3% to þ4.4% range) to account for this variation.
Improving the accuracy of EIA CO2 emission tallies
The EIA data collection (U.S. Energy Information
Administration, 2012) was not designed to measure CO2 emis-
sions from combustion. Not surprisingly, there are limitations
where these data are used for this purpose, as well as opportunities
for improvement. For example, additional data collection might be
undertaken to account for measurement bias due to CO2 emissions
from acid gas sorbents as well as unburned C in ash. Likewise,
consistent reporting of coal distributions to U.S. power plants from
terminals and transfer stations would reduce the stock adjustment
(3)
n error for plants that receive these distributions. Perhaps the most
significant limitation of the EIA data is the lack of C assays for
coal shipments. This requires the use of an emission factor to
calculate CO2 emissions. If the C content of each shipment were
measured, then the terms in eq 3 related to the p emission factor
(1.32) and the heating value measurement ([Z/ n]2) could be
replaced with a single term based on the
2.5% C dry random
error (ASTM, 2000c) associated with the C assay. As a result, the
average measurement error of the EIA CO2 emission tallies for
individual plants shown in Figure 4 would decrease from
1.6%
to
1.0%, which represents a potential 50% improvement in
accuracy. Moreover, the C assay could be made on coal samples
already collected for the heating value analyses. Assuming a C
analysis and reporting cost of $200 for each of the ~23,300 coal
shipments listed with the year-2009 EIA data, this improved
accuracy would have cost about $4.7 million, which is relatively
inexpensive (Sanchez et al., 2012).
Conclusion
The attenuation bias and inflated standard error shown in
Figure 3 indicate that the annual CO2 emission tallies for 210
coal-fired power plants calculated from EIA fuel consumption
data are more accurate than those measured by CEMS. The
limited accuracy of emission tallies based on CEMS measure-
ments is at least partly due to biased flue-gas flow measurements,
which systematically vary with the flue-gas flow certification
method. Although the EIA data allow for more accurate CO2
emission tallies, propagation of weighing, sample collection,
stock adjustment, emission factor, and laboratory errors showed
that the cumulative minimum error for these tallies ranged from

1.3% to
7.2% with a plant average of
1.6%. This error
might be reduced by 50% if the carbon content of coal delivered
to U.S. power plants were reported.
This study has implications for the U.S. Greenhouse Gas
Reporting Program where large coal-fired power plants currently
report annual CO2 emissions measured using CEMS. The results
presented here indicate that more accurate emission tallies can be
calculated from data reported to the EIA-923 power plant opera-
tions survey. Moreover, efforts to improve the accuracy of CO2
 Quick / Journal of the Air & Waste Management Association 64 (2014) 73–79
emission tallies from CEMS are warranted if these tallies are
used to design and implement regulations intended to reduce
greenhouse gas emissions.
Acknowledgment
Art Diem (EPA) reviewed an early draft of the paper and
generously provided some of the data used in this study.
Correspondence with Kevin Gurney (Arizona State University)
and Richard Winschel (CONSOL Energy, Inc.) as well as
Channele Wirman and Rebecca Peterson (EIA) informed this
work. Reviews by David Tabet (Utah Geological Survey) improved
the paper. Finally, the thoughtful comments and suggestions from
my anonymous reviewers are acknowledged and appreciated.
Supplemental Material
Supplemental data for this article can be accessed on the pub-
lisher’s website http://dx.doi.org/10.1080/10962247.2013.833146.
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About the Author
Jeffrey C. Quick is a geologist who works in the Energy and Minerals section of
the Utah Geological Survey.