In fact, there’s nothing clean about the “ACE” proposal; the rule would instead disrupt a decade-long trend towards coal plant curtailment and retirement, enabling the fleet to continue to pump carbon dioxide into the atmosphere by merely requiring tune-ups as the “Best System of Emissions Reductions”, or BSER. But a well-known and demonstrated technology is missing from its BSER list—one that can permanently sequester CO2 into geologic formations thousands of feet below the surface—carbon capture and storage (CCS).
In hundreds of pages of formal comments filed by CATF and its partner NRDC on Halloween 2018, we have provided EPA with a large body of research, analysis and computational modeling that concludes that carbon capture and storage (CCS) is a proven, available and affordable technology—one that EPA failed to consider as a BSER—because of its ability to reduce CO2 emissions from fossil power plants by as much as 95% or even more.
My engineering colleagues tell me that the technology used to scrub CO2 out of smokestacks is based on simple high school chemistry. But what do we do with all of that captured carbon dioxide? The answer is almost as simple. And this is where the deep thinking comes in. As it turns out, over a billion tons of CO2 have been safely injected deep into oil fields for enhanced oil recovery for nearly a half-century. And while oil fields can accommodate tens or hundreds of billions of tons of CO2, much larger deep geologic resources exist across the country and offshore—enough to accommodate 500 years or more of US CO2 emissions according to the US Geological Survey.
Several varieties of sedimentary rocks, sandstones and carbonates, can soak up CO2 in large quantities—in deep, porous rocks that have contained geologic fluids and gases for millions of years. At carbon storage sites, the injection and storage zone must be vertically separated from the surface by thousands of feet of rock, and there must be intervening impermeable barriers to vertical migration. This geologic isolation, combined with modern well construction methods and required monitoring of the injected CO2, mean that captured CO2 will remain permanently sequestered from the atmosphere.
But we wanted to know just where these sponge-like rocks are, and how the CO2 might get to locations where it can be injected and permanently isolated from the atmosphere. So, we gave a list of the coal plants impacted by the proposal – nearly, if not all coal plants in the United States—to the University of Texas Gulf Coast Carbon Center in Austin Texas, world experts on geologic carbon dioxide storage, and asked them to run a GIS analysis to tell us how far CO2 would have to be transported by pipeline from each plant to a deep geologic storage basin identified in 2015 by the U.S. Department of Energy’s National Energy Technology Laboratory.
Peter Tutton, a geoscientist and recent master’s degree graduate undertook the analysis. What he found was that every single U.S. coal plant has access to a geologic basin with the ability to sequester a lifetime of CO2 from those plants. In fact, fully half of the plants only required only an eight-mile pipeline. Almost all — 95 percent – of the plants could pipeline CO2 to a geologic site 123 miles distant or less. This is entirely reasonable given that approximately 4,500 miles of CO2 pipeline exist today, with several that are 200 or 300 miles long or more. To give an idea of where these power plants and geologic basins are, we asked Peter to create a map (below) to illustrate each power plant source and a paired geologic “sink” connected by pipeline.
This map, combined with the known abilities and economics of carbon capture, demonstrates that EPA was totally arbitrary in its lack of consideration or even a technical analysis of carbon capture and storage as a BSER in the ACE proposal. We hope that our filed comments and analytical work will motivate EPA to put deeper [geologic!] thought into including CCS in its final rule as BSER to provide real and quantifiable reductions of CO2 from our coal power fleet.