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Year One at Boundary Dam 3

November 25, 2015

Year One at Boundary Dam 3 —  Or, You Can Catch Some of the Carbon Most of the Time or Most of the Carbon Some of the Time and Still Do Better than EPA’s New Source Performance Standards for New Coal-Fired Units.

On November 9th, Senator Joe Manchin of West Virginia again questioned EPA’s Clean Power Plan (“CPP”) and carbon dioxide standards for new coal-fired power plants, this time based on the first year of operation at the Boundary Dam carbon capture and sequestration (“CCS”) unit operating in Saskatchewan (Boundary Dam 3). His letter confuses the circumstances at the Boundary Dam plant and also miscomprehends EPA’s new pollution standards. In fact, far from undermining the standards, if anything Boundary Dam’s experience demonstrates that EPA’s standard for new coal-fired power plants in fact is conservative, providing further support for the standards finalized in the CPP as well.

On August 3rd of this year, EPA finalized carbon pollution standards for new coal-fired power plants. In accordance with the Clean Air Act, EPA determined that CCS is the best system of emission reduction for new coal-fired power plants and set an emission rate of 1,400 lb CO2/MWh. Depending on the type of coal burned at the power plant, the standard essentially requires the plant to capture 16-23 percent of the carbon dioxide emitted from its smokestack and sequester it underground. EPA determined that CCS is adequately demonstrated based on many projects including Boundary Dam.

Boundary Dam 3 is a 45-year-old coal-fired unit at an existing power plant that SaskPower retrofitted with CCS. Essentially the company added a chemical scrubber to remove 90 percent of the carbon dioxide emitted by the 110 MW unit. The captured carbon dioxide is sent via pipeline to an oil field where is it sequestered during enhanced oil recovery. The Boundary Dam 3 began operating with CCS in the fall of 2014, and reports from the company suggest that while it has been capturing 90 percent of the carbon dioxide emitted when the CCS equipment is operating, the unit has only been operating 40 percent of the time.

Boundary Dam has had some teething problems in its first year that are not uncommon for start-ups at large industrial plants. It captured 400,000 tons of carbon dioxide – rather than the anticipated 1 million tons – but this in no way undermines EPA’s determination that CCS is adequately demonstrated, as Senator Manchin suggests. Indeed, even with these first-year growing pains, Boundary Dam is capturing about 13 percent more carbon dioxide annually than U.S. EPA’s standard requires of a new unit of the same type and size.

Moreover, Boundary Dam also exceeds expectations under EPA’s Clean Power Plan, which sets state emissions goals and guidelines based in part on an emission performance rate for existing coal plants of 1,305 lb CO2/MWh. Assuming an uncontrolled emissions rate from an existing 45-year-old lignite coal-burning unit like Boundary Dam 3 is on the order of 2,000 lb CO2/MWh, the 36 percent emissions reductions at Boundary Dam in the first year translate to an annual emissions rate of 1,280 lb CO2/MWh. Even underperforming as it has, if Boundary Dam 3 were located in the United States, it could arguably generate emissions reductions credits for sale, and use by others, for the incremental reductions it is achieving below EPA’s standard.

So what is Senator Manchin’s beef? EPA provided a hypothetical alternative compliance option in the preamble to the new source standards. They explained that capturing 90 percent of the carbon dioxide emitted from a unit the size of Boundary Dam 3 shows that a larger unit could capture 90 percent of its carbon dioxide emissions from a portion of the exhaust from the unit and leave the remainder uncontrolled and still meet EPA’s standard. Indeed, at the NRG 610 MW WA Parish Plant in Texas, that is the plan.  At that unit, NRG will capture and sequester 90 percent of the carbon dioxide from a 240 MW equivalent “slip stream” of exhaust. That translates to about a 25 percent carbon dioxide emissions reduction from uncontrolled levels, leaving headroom beyond what EPA’s standard requires.  Nothing about Boundary Dam 3’s performance in this first year suggests that there is anything wrong with either EPA’s hypothetical or NRG’s plan for WA Parish.

So, what does the first year of operations at Boundary Dam tell us?  It tells us that EPA’s expectation that a new coal fired generating unit can be designed to capture 16-23 percent of its carbon dioxide is eminently reasonable and even conservative.

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