The U.S. Environmental Protection Agency’s proposed CO2 rule for new coal-fired power plants, which was published on Jan. 8 and requires partial carbon capture and storage systems (CCS) on these plants, would actually freeze development of CCS technologies.
“[T]his regulation will essentially stop the development of CCS,” said Alstom official Robert Hilton in March 12 testimony to Congress. “Without new coal plants, it is unlikely technology developers will continue to invest in CCS development. Since the proposed regulation provides a significantly lower cost alternative (NGCC without controls) to the application of CCS to coal, there is unlikely to be a market for at least 10 years, and most R&D cannot be sustained for that period. Industry bases R&D on market potential and return on investment. With no market in sight, investment will stop. One only need to look at slowing pace of private and public investment world-wide in CCS projects as shown in the annual survey of the Global Carbon Capture and Storage Institute (GCCSI), which results from economic conditions and lack of progress on climate change negotiations as proof that EPA’s assumption are unrealistic.”
The House Science committee’s subcommittees on Environment and Energy on March 12 held a joint hearing to explore the basis for the EPA’s conclusion that CCS systems are adequately demonstrated as a technology for controlling CO2 emissions in full-scale commercial power plants under the New Source Performance Standards (NSPS).
Environment Subcommittee Chairman David Schweikert, R-Ariz., said in a statement issued after the hearing: “My colleagues and I received testimony from a variety of professionals in the energy field on the EPA’s NSPS proposal, which revealed an immature mandate request for utility companies, based on flimsy scientific data, and oversight without legitimate, existing infrastructure for our energy production. These requirements of CCS storage for power plants are so expensive and unavailable, witness David Hawkins, the Director of Climate Programs for the Natural Resources Defense Council, admitted they would not be adopted without regulation. Until these technologies are proven to be commercially available for our utilities companies without risks of harm to the storage location of carbon dioxide, our cities’ power suppliers will be left with very little options for compliance and freedom to grow their businesses.”
Energy Subcommittee Chairman Cynthia Lummis, R-Wyo., added: “The EPA is ignoring the consequences of their rulemaking to instead set a legal precedent for mandating unproven technologies. This is a policy of picking winners and losers through environmental regulations. New natural gas fired units, boilers and heaters and existing plant standards are next. We need to see an all-of-the-above energy policy, not one based purely on politics.”
At Alstom, commercial deployment of CCS systems is not there yet
Hilton, the Vice President, Power Technologies for Government Affairs for Alstom, noted that Alstom has taken each of its carbon capture-related technologies from the bench level to small and then larger pilots, followed by validation scale demonstrations with the aim to finally reach commercial scale demonstration. To date, none of these technologies have been deployed at commercial scale.
It is critical to be at commercial scale to define the risk of offering the technology, Hilton added. “This cannot be defined until the technology can be shown to work at full scale. This is the first opportunity that we have to work with the exact equipment in the exact operating conditions that will become the subject of contractual conditions when the technology is declared commercial and is offered under standard commercial terms including performance and other contractual guarantees. This also becomes the first opportunity to optimize the process and equipment to effect best performance and, very importantly, seek cost reduction. These too are required to define commercial contractual conditions. Finally, our customers would be reluctant to invest in Carbon Capture technologies that have not been demonstrated to full commercial scale.”
Based on these criteria, Alstom does not currently deem its technologies for carbon capture to be commercial and, to Hilton’s knowledge, there are no other technology suppliers globally that can meet this criteria or are willing to make a normal commercial contract for CCS at commercial scale. “I emphasize however that the technologies being developed by Alstom and others work successfully,” he added.
EPA in its proposal said there are commercial CCS projects. But Hilton said that is not so much the case.
- The Kemper County IGCC project with carbon capture in Mississippi is not even operating yet.
- SaskPower’s project in Canada is under construction and not demonstrated and has delayed start-up until July 2014.
- The Texas Clean Energy Project IGCC is not financed and hasn’t started construction, which is also the case for the HECA IGCC project in California.
- NRG Energy’s Parish coal plant CCS project in Texas is has yet to start construction.
- American Electric Power’s demonstration on the Mountaineer coal plant in West Virginia was only 2.3% of the plant gas stream and therefore should not qualify, Hilton noted.
- Basin Electric Power Cooperative’s Dakota Gasification plant in North Dakota is a producer of synthetic natural gas and a fertilizer plant – not a power plant.
“Alstom suggests this summary demonstrates the EPA referenced projects fail to meet the ‘technically feasible’ criteria,” he said. “These technologies are not operating at significant scale at any site as of the rule publication. We do not support mandating technology based on proposed projects (many of which may never be built). These facts lead to the conclusion that the technology is not ‘adequately demonstrated’ to be feasible at full scale.”
EPRI witness says CO2 storage still needs a lot of work yet
Robert Trautz, a Senior Technical Leader in the Generation Sector at the Electric Power Research Institute, said in his March 12 testimony that there is still a lot of work to be done yet on evaluating deep geological storage sites for the captured CO2.
EPRI is working closely with the U.S. Department of Energy and the Southern States Energy Board (SSEB) under the Southeast Regional Carbon Sequestration (SECARB) partnership program to assess CO2 storage opportunities in the southeastern United States. It is with the support of the SSEB and SECARB partnership that he testified.
“At the heart of the proposed EPA rule is a mandatory reduction in CO2 emissions intensity using carbon capture and storage (CCS) technology that will require EGUs that use solid fossil fuels like coal to reduce CO2 emissions to less than 1,100 lb/MW-hr gross,” Trautz noted. “To place this emission limit in perspective, the amount of CO2 that will need to be captured and stored to meet the 1,100 lb/MW-hr gross emission limit is approximately 40% of the CO2 output from a supercritical pulverized coal fired EGU. A relatively modest size 1,000 MW EGU will produce approximately 7.8 million metric tons of CO2 per year, requiring that about 3.1 million metric tons of CO2 be captured and stored per annum. For this example, the total CO2 tonnage to be stored over a 40 year EGU life span will exceed 120 million metric tons.”
Given the fact that the NSPS is clearly focused on reducing emissions from fossil fuel-fired EGUs, continued DOE investment in future research involving capture and saline demonstration projects that are fully integrated with advanced power generating systems is needed and would be invaluable to the power industry, he added.
“Only two of the demonstration projects in DOE’s research portfolio fielded to date have involved slip stream capture of a relatively small amount of CO2 from two power stations with corresponding injection into saline reservoirs of 37,000 and 100,000 metric tons,” Trautz said. “These include the injection projects performed at American Electric Power’s Mountaineer power station in West Virginia and the Alabama Power Company’s Plant Barry power plant in Alabama supported by EPRI. The FutureGen2 project located near Meredosia Illinois is a commercial scale oxy-combustion power system that will produce 1.1 million tons of CO2 emissions each year. Currently in the planning stages, if the DOE-supported FutureGen2 project progresses, it will be the first full-scale EGU involving CO2 saline injection in the United States.”
The CCS research community recognizes that the power industry will likely turn to saline reservoirs for large-scale, long-term CO2 storage needs because of their widespread distribution and large storage capacity. The potential use of depleted oil and gas reservoirs for CO2 storage could be adversely affected by potential regulatory requirements associated with CO2 storage and could have the unintended consequence of accelerating the move to saline storage. “Given that more is known about oil and natural gas reservoirs because of their commercial value, future government storage research and funding may need to focus disproportionately on characterization of saline storage reservoirs to help close the knowledge gap,” Trautz said. “This would help facilitate deployment and hasten the transition to saline storage.”
Scott Miller, General Manager and Chief Executive Officer of City Utilities of Springfield, and also a member of the Board of Directors of the American Public Power Association (APPA), testifying on behalf of his utility and APPA, said: “In justifying the use of CCS, EPA modified its definition of the [best system of emissions reduction] BSER in a manner that promotes newly emerging technologies, such as CCS. The agency asserts that BSER can be technology forcing and consider ‘the impact a standard will have on further technology development.’ While the re-proposal acknowledges that there are no commercially operating coal-fired power plants using CCS, the re-proposal asserts that four demonstration projects under development in the U.S. and Canada adequately demonstrate CCS at commercial scale. EPA never addresses the fact that there is no commercial demonstration of sequestration in non-oil and gas recovery locations. Nor does the agency address the myriad of regulatory hurdles impeding the sequestration of CO2 in the U.S.”
NRDC, EPA say that carbon limits are urgently needed
On the other side of the debate, David Hawkins of the NRDC said: “To date, the power sector has not used CCS broadly; but not because of any technical shortcomings. Rather, the sector has not applied CCS to full exhaust streams because of a policy failure. Up to now, there has been no national requirement to limit carbon pollution from power plants. CCS systems, like SO2 scrubbers, mercury controls, fine particulate controls, and nitrogen oxide controls, are not free. With rare exceptions, none of these other systems were used before there were regulatory requirements to control these pollutants.
“Congress wisely decided to give EPA the authority to impose clean air requirements to protect our health and welfare and this has resulted in trillions of dollars in benefits—exceeding compliance costs by a factor of 40 to 1,” Hawkins added. “Likewise, in the absence of any requirement to limit CO2 pollution from new or existing power plants, there has been simply no reason for owners and builders of power plants to install CCS systems.”
Janet McCabe, Acting Assistant Administrator, Office of Air and Radiation at EPA, didn’t delve into the technology issues in her prepared testimony, simply stating: “These proposed standards reflect the demonstrated performance of efficient, lower carbon technologies that are currently being used today. They set the stage for continued public and private investment in technologies like efficient natural gas and carbon capture and storage. The proposal was published in the Federal Register on January 8, and the formal public comment period is now open. We recently extended the comment period, to May 9, to ensure we get as much public input as practicable. We look forward to robust engagement on the proposal and will carefully consider the comments we receive as a final rule is developed.”