The time is now: The Biden administration must adopt strict CO2 emission standards for the power sector
The problem of climate pollution from the power sector is so great that it demands both pushes and pulls—that is, government incentives that help entice industry in a positive action in combination with regulation of dangerous and health-harming pollution pushing those who aren’t moving fast enough along. It is not often that an industry is subject to both a policy push and pull at the same time, but when it is, it can unleash significant potential for dramatic emissions reductions. That is currently the case for carbon scrubbers on fossil fuel-fired power plants.
The Inflation Reduction Act, passed this summer, provides incentives for the U.S. power sector to transition to clean energy. At the same time, the Biden administration has an obligation to issue strict carbon dioxide emission standards for the power sector under the Clean Air Act in light of West Virginia v. EPA.
The Act requires the Environmental Protection Agency (EPA) to survey all adequately demonstrated systems of pollution controls for the power sector; to choose the best of them, considering costs, energy, and environmental factors; and then to set emission standards based on that best system. The states and power companies must then meet the pollution limits through any means they choose.
For a technology to be adequately demonstrated, it need not be on every street corner. Indeed, in the absence of incentives and regulation, industry is unlikely to deploy pollution controls on its own. Instead, EPA must demonstrate that the system is available, and can make that demonstration by any number of means: vendor guarantees, literature review, pilot plants, test programs, or experience with the technology in other industries. Carbon capture and sequestration technology has these in spades. There are no technological barriers to deploying carbon capture in the power sector, there has only been a historical lack of incentives and regulation.
Industries have used carbon capture and storage for decades. Now that the Inflation Reduction Act is law, more power plant applications of carbon capture are under consideration as illustrated in the map below. Many of the carbon capture projects in the power sector under consideration are at natural gas-fired combined-cycle (NGCC) plants. The table below shows at least 14 carbon capture projects at NGCC plants are undertaking detailed engineering work called Front End Engineering Design (FEED) studies to thoroughly plan a project. These FEED studies demonstrate real interest and ability of industry to adopt carbon capture. These are no mere theoretical exercises: FEED studies use currently-available equipment and know-how to provide engineering plans and cost estimates for substantial investment decisions.
U.S. Carbon Capture Activity Project Map (Coal and Gas Projects)
Natural Gas Carbon Capture and Storage Projects
| Project | Size | Quantity | Notes |
|---|---|---|---|
| Panda Energy, TXi | 420 MW | 645,000-1 million tons per year depending on capacity factor | Existing NGCC, FEED complete |
| Quail Run Energy Center, TX | 550 MW | 1.5 million metric ton/year | Existing NGCC, FEED |
| Deer Creek Energy Center, TXii | 1,116 MW | 5 million metric ton/year | Existing NGCC, FEED |
| Baytown Energy Center, TX | |||
| Delta Energy Center, CAiii | 857 MW | 2.3 million metric tons/year | Existing NGCC, FEED |
| Plant Barry, ALiv | 525 MW | 1.5 million metric tons/year | Existing NGCC, FEED |
| Polk Power Station, FLv | ~280 MW | ~800,000 metric tons/year | Existing NGCC, FEED |
| LG&E | 700 MW | 1.7 million metric tons/year | Existing NGCC, FEED |
| Mustang Station, TXvi | 460 MW | 1.6 million metric tons/year | Existing NGCC, FEED |
| Chevron Kern River Eastridge, CA | 50 MW, steam | 300,000 metric tons/year | Existing Cogen, Pre-FEED |
| CalCapture, CA | 550 MW | Up to 1.4 million metric tons/year | Existing NGCC, FEED |
| Coyote Clean Power, CO | 280 MW | 850,000 metric tons/year | New Natural Gas, Allam Cycle, Pre-FEED |
| Broadwing Clean Energy, IL | 280 MW | 850,000 metric tons/year | New Natural Gas, Allam Cycle, Pre-FEED |
| Competitive Power Ventures , WV | 1800 MW | Not announced, but greater than 4 million metric tons/year | New NGCC-CCS, early development |
Another six coal-fired power plants are also doing FEED studies, as shown in the table below.
Coal Carbon Capture and Storage Projects
| Project | Size | Quantity | Notes |
|---|---|---|---|
| Project Tundra, ND | 455 MW | 3.3 million metric tons/year | FEED complete |
| Dry Fork, WY | 400 MW | 2.2 million metric ton/year | Pre-FEED |
| Dave Johnson, WY | 330 MW | 1.26 million metric ton/year | Pre-FEED |
| Gerald Gentleman, NE | 700 MW | 4.3 million metric tons/year | Pre-FEED |
| Madison Unit 3, LA | 600 MW | 3.6-5.0 million metric tons/year | NGCC, FEED |
| Prairie State, IL | 800 MW | 6.2-8.2 million metric tons/yr | FEED complete |
The magnitude of the CO2 capture from these plants is significant. Today, the U.S. captures and permanently sequesters about 16 million metric tons annually from industrial sources. If these U.S. gas and coal power CCS projects are all built, they will lead to nearly 50 million metric tons of carbon capture per year, more than double what the U.S. is currently capturing. These projects strongly indicate that carbon capture technology is adequately demonstrated, commercially available, and affordable enough to warrant serious consideration. If that were not the case, developers would focus on other areas.
Other nations are also considering carbon capture at natural gas plants. Because these nations lack the incentives the U.S. offers, they have fewer proposed projects, as shown in the table below. Still, this indicates that capture technology is available and adequately demonstrated.
International Carbon Capture and Storage Projects
| Project | Size | Quantity | Notes |
|---|---|---|---|
| Genesee 1 and 2, Alberta Canadavii | 1,360 MW | 3 million metric tons/year | Repower coal plant with NGCC-CCS |
| Peterhead, UK | 910 MW | 1.5-2 million metric ton/year | New NGCC, FEED |
| Keady, UK | 910 MW | 1.5 million metric ton/year | New NGCC, FEED |
| Net-Zero Teeside, UK | 860 MW | Up to 2 million metric tons/year | New NGCC, FEED |
| Staythrope, UK | 1,700 MW | Not announced | NGCC, FEED |
A long history of experience supports capture technology on power plants. In past decades, capture from natural gas helped demonstrate carbon capture on coal. For example, twelve years ago MHI used their experience with capture on natural gas-fired boilers to demonstrate capture on coal at Southern Company’s Plant Barry in Alabama on a 25 MW slipstream. Success at Plant Barry enabled Petra Nova to apply carbon capture at a much larger scale. Likewise, Fluor developed a carbon capture project at the Bellingham NGCC plant in Massachusetts from 1991 to 2005 capturing 85-95% of CO2 from a 40 MW slipstream. They used this experience to design a coal-fired power plant capture pilot in Wilhelmshaven, Germany, that operated in 2012. These coal power plant experiences can be transferred back to natural gas-fired combined cycle plants. They often use the same family of solvents to capture carbon dioxide with minor changes to account for differences in flue gas composition. These solvents have undergone years of testing. Since 2012, many leading carbon capture solvent providers (including Aker, Cansolv, Fluor, ION, Carbon Clean Solutions, MHI) have carried out major test campaigns at Technology Centre Mongstad (Norway), which can capture 80 metric tons per day of combined cycle flue gas. Recent test campaigns have included demonstrations of CO2 capture with flexible plant operation.
Finally, it’s important to recognize the importance of strong technology-based standards to advance our climate goals—we simply can’t get close to our goals without them. For these carbon pollution controls to work on coal-fired power plants requires the application of state-of-the-art air pollution controls, and on NGCCs, state-of-the-art controls also must be used. It’s a win-win, for the climate, and for communities.
i See also, W.R. Elliot, Front-End Engineering Design (FEED) Study for a Carbon Capture Plant Retrofit to a Natural Gas-Fired Gas Turbine Combined Cycle Power Plant (2022), https://www.osti.gov/servlets/purl/1836563.
ii See also, Deer Park Energy Center, Calpine, https://www.calpine.com/deer-park-energy-center (last visited Feb. 6, 2023).
iii See also, Andrew Awtry, ION Clean Energy, “Project Delta” Front-End Engineering and Design for a CO2 Capture System at Calpine’s Delta Energy Center (2022), https://netl.doe.gov/sites/default/files/netl-file/22CM_PSC17_Awtry_0.pdf (presented at National Energy Technology Laboratory Carbon Management Project Review Meeting, Aug. 15 – 19, 2022).
iv See also, Landon Lunsford, Southern Company Services, Inc., Front End Engineering Design of Linde-BASF Advanced Post-Combustion CO2 Capture Technology at a Southern Company Natural Gas-Fired Power Plant (2022), https://www.osti.gov/servlets/purl/1890156.
v The Department of Energy’s Categorical Exclusion Designation Form for the FEED Study suggests that only Unit 2 is the subject of the FEED study. Therefore, the amount of CO2 subject to the FEED is revised downward from the DOE announcement. Dep’t of Energy, NETL, Categorical Exclusion (CX) Designation Form for Project No. DE-FOA-0002515 (2022), https://www.energy.gov/sites/default/files/2022-11/CX-026914.pdf.
vi See also, Gary Rochelle et al., Cost Details from Front-End Engineering Design of Piperazine with Advanced Stripper (2022), https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4281548.
vii See also, Burns & McDonnell Delivers on Capital Power’s Genesee Repowering Project, Burns & McDonnell (Sept. 29, 2021), https://www.burnsmcd.com/news/capital-power-genesee-repowering-project.
