The Great Green Lie: CCS Today Is Not Like Scrubbers in the 1970s (Part II)
By William Yeatman -- December 6, 2013As noted in Part I, EPA’s 1971 sulfur dioxide standard was based on the application of wet scrubber technology. However, most utilities found it was cheaper to meet the standard by switching to low sulfur coal, rather than install expensive wet scrubbers.
Consequently, during the 1970s, demand for low sulfur coal skyrocketed. Western states, primarily Wyoming and Utah, benefitted; eastern coal producing States in Appalachia and the Ohio River valley suffered.
In Congress, lawmakers from eastern coal producing states sought to redress the economic harm resulting from fuel switching precipitated by EPA’s sulfur standards. Their solution was to require scrubbers at all new coal-fired power plants.
If utilities had to install sulfur controls, these lawmakers reasoned, there would be no incentive to switch to low-sulfur coal. (Of course, this is an absurd waste: From an environmental standpoint, there’s no benefit if a utility installs wet scrubbers and also switches to higher sulfur coal. But that’s a different story of legislative sausage-making. See, generally, Bruce Ackerman & William Hassler, Clean Coal Dirty Air, 1981)
EPA executed this scrubber mandate on June 11, 1979, when it published revised sulfur dioxide emissions standards for new coal-fired power plants in the Federal Register (44 FR 33580). For this determination, there was no question whether wet scrubbers were commercially viable. There was, however, a question as to the commercial viability of “dry” scrubbers, a less water-intensive flue gas desulfurization system developed in the mid 1970s.
At the time, there were zero commercial dry scrubbers in operation at power plants, and utilities had closed financing and commenced construction on dry scrubbers at three power plants representing 1,350 megawatts (44 FR 33594). Notably, none of these projects received federal subsidies.
Despite the considerable evidence that dry scrubbers were an emerging technology in 1979, EPA did not find that the technology met the commercial viability threshold as required by the Clean Air Act. In its review of the regulation, the D.C. Circuit Court of Appeals affirmed that dry scrubbers were not “adequately demonstrated,” and, therefore, could not be the basis of New Source Performance Standards to control sulfur dioxide from power plants.
How the Great Green Lie Backfires on Proponents of the Carbon Pollution Standard
In the table below, I’ve summarized the information presented above, comparing EPA’s Carbon Pollution Standard with the agency’s prior sulfur dioxide standards for new coal-fired power plants.
Clearly, the contemporary status of CCS technology is a poor parallel to the development of wet scrubber technology in 1971, at which time the latter technology was market mature. However, CCS does compare well with the status of dry scrubber technology in 1979. Currently, CCS has been installed on zero power plants, although it isbeing installed at a 540 MW power plant in Mississippi. Dry scrubbers, by comparison, in 1979 were being installed at three power plants (representing 1350 megawatts).
Let’s elaborate on this CCS-dry-scrubber analogy, which is indeed apt. According to a February, 1980 survey by EPA, dry scrubbers were being readily embraced by the market, without subsidies. The agency noted:
“With regard to process development, there does not appear to be a need for EPA to fund programs aimed at the development of sprayer-dryer based technology since a significant amount of commercial interest currently exists in these systems…[N]umerous vendors of dry processes are devoting large research budgets to the development of sprayer dryer-based FGD systems, and it appears that this technology will be developed regardless of EPA involvement.”
For CCS, the opposite is true: The technology is so nascent and expensive that no utility would undertake it absent generous government subsidies. In fact, the only CCS project in the U.S. to close the necessary financing was aided by $270 million in Energy Department direct grants, and another $170 million in tax credits from the I.R.S. Without these taxpayer handouts, the project would never have broken ground.
The evidence indicates that dry scrubber technology was much further developed in 1979 than is CCS today. For starters, there were more dry scrubbers being installed then relative to CCS now. More importantly, the market actors were adopting dry scrubber technology of their own volition, whereas this cannot be said for CCS.
With this in mind, it is telling that EPA considered dry scrubber technology extensively in its 1979 sulfur dioxide standards for new power plants, yet the agency declined to determine that the technology was “adequately demonstrated” (i.e., commercially viable). The D.C. Circuit Court of Appeals was more explicit in a 1981 decision (Sierra Club v. Costle, 657 F. 2d 298 (D.C. Cir. 1981)) reviewing the sulfur dioxide standard, in which it found:
We feel compelled to state, so that there is no suggestion that the standard has been relaxed, that we do not hold that dry scrubbing is adequately demonstrated technology. Indeed, the record in this case would indicate the contrary.
Because dry scrubbers were not commercially viable in June 1979, they were an impermissible basis for a NSPS for new coal-fired power plants. In light of the evidence presented in this post that dry scrubbing more advanced in 1979 than CCS is today, the Court’s reasoning is an ominous precedent for proponents of the Carbon Pollution Standard.
Thus, the great green lie actually undermines the argument of those that speak it.
William, do you have data on the total installed cost (estimate) for the CCS project: “For CCS, the opposite is true: The technology is so nascent and expensive that no utility would undertake it absent generous government subsidies. In fact, the only CCS project in the U.S. to close the necessary financing was aided by $270 million in Energy Department direct grants, and another $170 million in tax credits from the I.R.S. Without these taxpayer handouts, the project would never have broken ground.” In other words, what percent of total is the $440 million subsidy; deminimus, 10%, 50%?
One other thing not mentioned but critical to the CCS issue is what do you do with the collected CO2. Technology and a permitting path existed for both wet and dry scrubbers at the time. CO2 disposal techniques and permitting on the scale necessary for the electricity generating sector is a major issue
Hi Tom, You bet. MIT runs a great database of current CCS projects. It’s available: http://sequestration.mit.edu/tools/projects/kemper.html
They update it regularly. According to the site, the Kemper project was supposed to cost $2.4 billion, but now it’s estimated to cost $4.5 billion. This is about 5-7 times the capital cost of a comparably sized coal-fired power plant. YIKES!
On a weight basis co2 is approximately 8/11 oxygen and 3/11 carbon. Sequestering co2 means that your sequestering mostly oxygen on a weight basis. If co2 is sequestered then it is not available for the release of free oxygen.
Why is NO ONE explaining that CSS is economically impossible? From my readings the cheapest methods involve pumping the CO2 into a void in the earth. That means that even if the CO2 is pumped and pressurized enough to convert it to a solid (dry-ice) then the space will be more than TWICE as large as the same volume of the earth that the Natural gas, or coal was removed from. Think about that for a minute. I live near a 600 Mw coal fired station. at least two train loads of the best Wyoming coal are delivered and burnt (turned from almost pure Carbon to CO2. One pound of pure carbon, when burnt will make more than TWO pounds of CO2. That means that four and probably 5 trainloads of Dry-Ice would have to be hauled from there, and even more if in the liquid state. They would need a gas line with about twice the capacity if a NG plant! Even if they drilled down and somehow created a void large enough the volume of that void required staggers the imagination. Then I hear ideas of making carbon compounds. Those would face even larger volume problems. I can not believe it is possible, What am I missing?
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In addition to the MIT database, there’s an interactive CCUS database made by DOE/NETL.
http://www.netl.doe.gov/technologies/carbon_seq/global/database/index.html
Note that the “U” stands for utilization…i.e. using the CO2 for enhanced oil&gas recovery.
Separating CO2 from exhaust gas or from natural gas is not a new technology. Using CO2 for enhanced oil recovery is not new either. The separation process (using sorbent, solvents, or membranes) is expensive because there’s a lot of CO2 that needs to be captured, but all of the technology is commercial and has already been demonstrated at large-scale.
If your issue is that you don’t think that the benefits of capture outweigh the costs, that’s a fair debate; and I think that we should be discussing what is the damage/benefit of CO2 emissions. This is still a wide open question because there have only been a few researchers (such as R. Tol and W. Nordhaus) who have put all of the individual estimates of costs/benefits into a single calculation.
But it’s a stretch to say that CO2 separation technologies are not commercial. There are three major companies (Praxair, Air Liquide, or Air Products& Chemicals) who do large scale CO2 separation from air, and there are a number of oil&gas companies who do CO2 separation from natural gas. There’s no significant difference between these processes and the processes used at the DOE-funded demo-sites (listed in the website above.)
If your concern is that CCUS could make electricity more expansive, this is a completely valid concern, but that concern has to be weighed against the competing concern of (a) higher average global temperatures, (b) lower ocean pH, and (c) higher sea levels.
Let’s try to keep the debate focused on the actual problem: Calculating the gross and net damage/benefits of CO2 emissions. This will help us determine what price to put on CO2 emission, and that will ultimately tell utilities whether it makes economic sense to install CO2 capture on power plants.
Eddie:
A couple of things.
First, CO2 capture has its best economics if the CO2 goes to enhanced oil recovery.
Second, you state: “Calculating the gross and net damage/benefits of CO2 emissions. This will help us determine what price to put on CO2 emission, and that will ultimately tell utilities whether it makes economic sense to install CO2 capture on power plants.”
Love your first sentence. You are saying that CO2 might, indeed, have net benefits for the economy and for the ecosphere. So sentence two might not only be “NO”–but that we should pay utilities NOT to capture but release so even if it might be economic for them to do the former (at least hypothetically).
Us libertarians are neutral: government failure is enough to leave market failure–in either direction–alone on the CO2 front.
Hi Eddie, RE: “But it’s a stretch to say that CO2 separation technologies are not commercial.”
This is different from what I say. Rather, I say that CCS on a power plant isn’t commercial.
In fact, EPA makes the same argument that you do: i.e., each component (“capture”, “transport”, and “injection/sequestration”) has been demonstrated, ergo, CCS is “adequately demonstrated.”
The court of review has found that EPA can rely on the existence of the same technology in a different industry to determine that it’s “adequately demonstrated.” (The court did so when it upheld selective catalytic reduction systems as NSPS for industrial boilers, even though few/none were in existence. The court bought EPA”s reasoning that the technology already worked on utility boilers).
However, the court has never weighed whether EPA can rely on the existence of COMPONENT parts of the technology that is the basis of NSPS. Perhaps it will, if EPA ever publishes a proposal in the Federal Register. It’s been three months!
[…] has never enacted a bill to regulate greenhouse gases from stationary sources, and it’s far from certain courts will uphold the EPA’s proposed “carbon pollution rule” to regulate just […]
[…] Standard to pass judicial review, CCS technology must be “commercially viable.” As I’ve written repeatedly, legal precedent together with market realities strongly indicate that CCS has […]
[…] EPA issued a pre-publication version of the Carbon Pollution Standard. The regulation requires that all new coal-fired power plants install carbon capture and sequestration technology to control […]