Comments On The Insanity Of EPA's New Power Plant Rule

August 11, 2023/ Francis Menton

Comments On The Insanity Of EPA's New Power Plant Rule

August 11, 2023/ Francis Menton

On May 23, EPA put out its long-expected proposed Rule designed to eliminate, or nearly so, all so-called “greenhouse gas” emissions from the electricity-generation sector of the economy.  The proposal came with the very long title: “New Source Performance Standards for GHG Emissions from New and Reconstructed EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean Energy Rule.”  The full document is 672 pages long.   

Various not-very-far-off deadlines are set, ranging from as early as 2030 for some changes to coal plants, to at the latest 2038 for the last changes to natural gas plants.  But how exactly is this emissions elimination thing to be accomplished?  Today a substantial majority of U.S. electricity (about 60%) comes from one or the other of those fuels; and it is inherent in the burning of hydrocarbons that you get CO2 as a product.  In all those 672 pages, EPA has only two ideas for how to eliminate the carbon emissions from combustion power plants: carbon capture and storage (CCS), and “green” hydrogen.  Either you must implement one of those two ideas to meet EPA’s standards by the deadline, or you must close your power plant.  But here’s the problem: both of those ideas are, frankly, absurd.   

The deadline for commenting on the proposed Rule was August 8, although comments have continued to pile in after that date.  Many hundreds of them have been received.  If you have nothing else to do for the next month or two, you can review the comments at this link. 

I have by no means made the effort to read all the comments, but I have gone looking for some of the more significant ones.  Two that I can highly recommend are this one by a group of 21 red state AGs led by West Virginia, and this one by an overlapping group of 18 red state AGs led by Ohio.  Both of those comments do an excellent job of dismantling the concept that either CCS or “green” hydrogen could ever work as a significant part of our electricity generation system.  Of the two, the West Virginia comment is the much longer (54 pages) and goes into far more technical detail.  But the Ohio comment, at 21 pages, has its share of good zingers as well.

The Ohio and West Virginia comments label the idea of CCS at the high rate demanded by EPA (90%) as either “infeasible” or not “viable,” and include recitations of the history of failed attempts to implement this frankly useless technology.  From the Ohio comment (page 4):

A study of 263 carbon-capture-and-sequestration projects undertaken between 1995 and 2018 found that the majority failed and 78% of the largest projects were cancelled or put on hold.  After the study was published in May 2021, the only other coal plant with a carbon-capture-and-sequestration attachment in the world, Petra Nova, shuttered after facing 367 outages in its three years of operation.

With the closure of Petra Nova, there remains in the entire world exactly one operating commercial CCS facility at a coal power station, the SaskPower Boundary Dam Unit 3 in Saskatchewan, Canada.  That one is supposed to achieve the 90% capture rate that EPA demands, but with constant operating issues it has fallen way, way short:

[T]his [SaskPower] facility is the world’s only operating commercial carbon capture facility at a coal-fired power plant.   And it has never achieved its maximum capacity.  It also battled significant technical issues throughout 2021—to the point that the plant idled the equipment for weeks at a time.  As a result, the plant achieved less than 37% carbon capture that year despite having an official target of 90% . . . . 

The West Virginia comment provides lots more technical detail on the failures of CCS. Why can’t a CCS system just easily suck up all the CO2 out of a power plant’s emissions stream? Because the effort to suck up the emissions takes energy from the output of the plant, and the higher the percentage of carbon emissions you seek to capture, the more of the energy output of the plant you consume. (I have previously described CCS efforts as a “war against the second law of thermodynamics.”). In the limiting case, you can use up all the power output of the plant on the CCS system and still not capture 100% of the CO2. From the West Virginia comment, page 24-25:

Take efficiency to start. CCS units run on power, too. An owner can get that power from the plant itself. But this approach makes the plant less efficient by increasing its “parasitic load”—and CCS more than triples combustion turbines’ normal parasitic load. . . . This is the cause the Wyoming study analyzed that showed installing CCS technology would devastate plants’ heat rates and lower net plant efficiency by 36%.

And that percentage relates to a system that captures well less than 100% of the plant’s carbon emissions. And these are only the start of the technical issues to be faced. For example, once you have captured all this CO2, where do you put it? Do you build an entire new national network of pipelines (at a cost of hundreds of billions of dollars) to transport it to some underground caverns somewhere? And then, are there environmental issues with the chemicals used to snag the CO2 out of the power plant’s emissions stream? From the West Virginia comment, page 27:

The Proposed Rule would force utilities to adopt and communities to accept all aspects of CCS technology without fully understanding the ramifications. For example, the environmental and health effects of CANSOLV—the leading amine-based and EPA-recommended CCS solvent, 88 Fed. Reg. at 33,291—appear unknown; leading CANSOLV studies over the past decade don’t discuss its impact.

And then, if you have to increase the power output of the plant by 50% or so to power the CCS facility, doesn’t that then increase the emissions of nitrous oxides and particulates by a comparable amount? From the West Virginia comment, page 27:

Nearly a decade ago, the European Union’s European Environmental Agency released a study finding that CCS would increase “direct emissions of NOx and PM” by nearly a half and a third, respectively, because of additional fuel burned, and increase “direct NH3 emissions” “significantly” because of “the assumed degradation of the amine-based solvent.”

It goes on and on from there. And then there’s the idea of “co-firing” the power plants with “green” hydrogen, produced by using wind or solar power or something else magical to electrolyze water. EPA’s proposed Rule would impose such a requirement on existing natural gas plants to take them up to 96% hydrogen by 2038. A few insights from the West Virginia comment, page 35:

Most combustion turbines on the market today cannot handle anything more than a 5-10% blend [of hydrogen]; 20% is generally accepted as the absolute technological ceiling. . . . Even in the best scenarios, a hydrogen volume fraction of 20% is usually the most technology currently can do.

And how about the problem (and cost) of producing the amounts of hydrogen that would be required. From the West Virginia comment, page 37:

America currently produces just .5% of the clean hydrogen we need under the Proposed Rule. The industry would have to close a 99.5% supply gap in just 15 years. EPA has offered no evidence showing that this gap will close.

There is much, much more on issues like transporting and handling the hydrogen, cost of production, and so forth.

The conclusion is obvious and impossible to escape: These proposed methods to allow combustion power plants to continue to exist are not real and can never work. EPA intends to force the closure of all such electricity generation facilities. Will we have an electricity system that can still function at that point? They neither know nor care. After all, we have a planet to save here.

Somehow, in the weighing of the costs and benefits here, the bureaucrats appear to have completely lost track of the enormous benefits that reliable access to electricity has brought to the people. They will destroy that without giving the subject a second thought.