Clear Vitality Group (CEG), alongside a number of of our associate organizations, not too long ago submitted feedback in response to the EPA’s proposed guidelines for fossil fuel-fired energy vegetation. The feedback handle a number of points with the proposed guidelines, one of many largest being the inclusion of carbon seize and storage (CCS) and hydrogen mixing as Finest Techniques of Emissions Discount (BSER) pathways for brand spanking new energy vegetation in addition to present bigger capability vegetation.
What’s a BSER?
Per Part 111(d) of the Clear Air Act, as soon as the EPA identifies a supply class that emits dangerous air pollution (on this case, energy vegetation emitting greenhouse gasoline emissions), it should then decide the very best applied sciences for energy vegetation to cut back these pollution, aka a BSER. For a know-how to be thought-about a BSER, it should be “adequately demonstrated,” considering value, non-air high quality well being and environmental impacts, and vitality necessities (supply). “Ample demonstration” has been outlined as know-how “which has been proven to be moderately dependable, moderately environment friendly, and which may be moderately be anticipated to serve the pursuits of air pollution management with out changing into exorbitantly expensive in an financial or environmental method” (supply). Primarily based on this definition, neither CCS nor hydrogen meets the necessities to be thought-about a BSER. Their inclusion within the proposed guidelines depends on a number of misconceptions about every know-how.
CARBON CAPTURE AND STORAGE (CCS)
CCS Will Not Really Cut back Greenhouse Gasoline Emissions
The primary BSER pathway outlined by the EPA would require all new and reconstructed in addition to present massive, steadily used vegetation to put in CCS know-how with a 90 p.c carbon dioxide (CO2) emissions seize price by 2035. The latter class refers to electrical producing items (EGUs) which can be above 300 megawatts, with a capability issue of fifty p.c or extra. It must be famous that lots of the largest, most polluting energy vegetation are made up of a number of EGUs, which individually could not meet the 300-megawatt threshold. This loophole implies that many vegetation could not want to put in CCS in any respect, even when they’re heavy emitters.
We’ve very restricted information on how efficient carbon seize and storage is on energy vegetation. Per the EPA’s personal admission, most demonstrations of CCS have been for purposes apart from combustion generators. One of the outstanding examples, the Bellingham Vitality Heart in Massachusetts, operated from 1991 to 2005 and didn’t maintain a 90 p.c seize price (supply). The Boundary Dam plant operated by SaskPower in Saskatchewan, Canada, one of many solely at the moment working CCS vegetation on the earth, has additionally by no means sustained a steady price of 90 p.c seize (supply). Assuming CCS know-how advances sufficient by 2035 to make a sustained 90 p.c seize price doable, energy vegetation are nonetheless not required to run the know-how at startup or shut down, two essentially the most emissions heavy durations at most vegetation.
Past CCS’s restricted efficacy at energy vegetation, increasing its use has troubling implications for greenhouse gasoline (GHG) emissions system-wide. Most CCS tasks solely pencil out financially by way of the utilization of the captured carbon. The most typical utilization of captured carbon is in a course of referred to as enhanced oil restoration (EOR), by which high-pressure CO2 is injected into oil fields to stimulate extra oil manufacturing. The method doesn’t retailer all injected CO2 — some stays within the oil reservoir, whereas some returns to the floor with the oil. Critically, the emissions launched from the burning of oil produced with EOR are considerably better than the CO2 saved within the course of, undermining any potential local weather profit from storing the carbon. The Inflation Discount Act (IRA) elevated incentives for capturing and storing CO2, together with an incentive of $60/metric ton of CO2 captured and utilized along side EOR. Most CCS tasks on the earth at present are EOR tasks (supply). The proposed guidelines don’t handle the secondary marketplace for the saved carbon that may outcome from the CCS put in on vegetation, nor the potential GHG impression of a minimum of a few of this saved carbon getting used for EOR.
Carbon Pipelines Are an Environmental Justice Catastrophe
Captured carbon, no matter whether or not it’s destined for EOR operations or geologic sequestration in an underground basin, must be transported from the purpose of seize. Rolling out CCS on the size these proposed guidelines would require would precipitate a large buildout of CO2 pipelines. It’s estimated that to seize 1 / 4 of present CO2 emissions by 2050, the trade would want to handle practically two-and-a-half instances extra CO2 than the whole quantity of present US oil manufacturing, and assemble over 60,000 miles of pipelines (supply). Some CO2 pipelines are already being constructed, many close to communities have already been impacted by environmental and public well being ramifications from gasoline pipeline buildout. In 2020, the city of Satartia, Mississippi confronted mass poisoning from a CO2 pipeline explosion. Current pipeline rules will not be designed for CO2 pipelines, and neither are pipeline security protocols. As seen within the city of Satartia, emergency response groups had been hampered by the CO2 cloud itself, as a result of their automobiles didn’t have the mandatory oxygen to function. Residents additionally confronted long-term well being impacts following the incident (supply).
CCS Will increase Different Air Pollution
Including CCS to an influence plant requires factoring in extra demand for vitality to run the know-how. Due to the extra gasoline wanted to energy the CCS gear itself, electrical energy technology paired with CCS requires as much as 44 p.c extra gasoline than standalone energy technology. CCS doesn’t seize any poisonous native air pollution, comparable to advantageous particulates (PM2.5) or nitrogen oxides (NOx); the extra gasoline burned to energy the know-how can subsequently improve particulates and NOx emissions by wherever from 5 p.c to 60 p.c (supply). Even when the facility vegetation set up extra pollutions controls comparable to choose catalytic discount (SCR), these vegetation can be polluting on the similar price as present newer pure gasoline vegetation. Environmental justice communities are already seeing documented well being impacts from emissions at these ranges. Even when the plant just isn’t situated close to a group, the pollution it emits have been proven to have an effect on metropolitan areas many miles away (supply). It also needs to be famous that pollutant controls like SCR don’t function throughout the startup or shutdown of combustion generators, leading to uninhibited NOx emissions throughout that point (supply).
HYDROGEN
Hydrogen Does Not Cut back GHG Emissions – It Will increase Them
The second BSER pathway the proposed guidelines record for all new and reconstructed baseload or intermediate vegetation in addition to present massive, steadily used vegetation, if they don’t go the route of putting in CCS with 90 p.c seize, is to start co-firing a mix of 30 p.c low-GHG hydrogen by 2032, transferring as much as 96 p.c by 2038. The foundations outline low-GHG hydrogen as hydrogen produced with a GHG emissions price of 0.45 kilograms of CO2 equal per kilogram of hydrogen. Critically, this definition doesn’t present a mannequin for a way these GHG emissions can be accounted for. Many of the hydrogen falling beneath this definition will have to be produced through electrolysis, a course of by which an electrical present is run by way of water, separating the particles to provide hydrogen. Electrolysis is an vitality intensive course of – about 60 p.c of the vitality put in is misplaced throughout manufacturing (supply). Whereas electrolyzers may be paired instantly with a renewable vitality asset like a wind turbine or photo voltaic array, they can be instantly related to the grid. This second avenue of manufacturing can result in an enormous spike in demand that, if not matched with hourly renewable vitality manufacturing, can result in this so-called “low-GHG” hydrogen having increased emissions than hydrogen produced from pure gasoline (supply).
No matter how the hydrogen is produced, it will probably even have a worldwide warming impression as soon as it leaks into the ambiance. Hydrogen extends the lifetime of methane, a strong short-term greenhouse gasoline, within the ambiance. Due to this, it’s estimated to have a worldwide warming potential practically 12 instances that of CO2 over 100 years after launch. Within the first 20 years of its atmospheric lifetime, hydrogen has a worldwide warming potential 35 instances that of CO2 (supply).
The worldwide warming potential of hydrogen is much more alarming as a result of this can be very susceptible to leakage. The molecule is smaller than different parts generally present in pure gasoline, and gear delicate sufficient to detect leaks previous to an explosive occasion doesn’t at the moment exist (supply). Hydrogen also can crack metal pipelines by way of a course of known as embrittlement, so storing or transporting it may be extraordinarily harmful (supply). In a high-risk state of affairs by which a lot of the relevant energy vegetation beneath the EPA’s pointers start mixing and combusting hydrogen, we will anticipate leakage charges of as much as 5.6 p.c (supply). Assuming that every one the hydrogen in use is zero-GHG hydrogen, aka hydrogen produced with none related emissions, leakage charges should be stored beneath 9 p.c for hydrogen use to assist mitigate atmospheric methane, versus contributing to it. If even a few of that hydrogen is produced utilizing fossil fuels or is produced through grid related electrolysis, the mixed world warming impacts can be even better, and leaks should be minimized to beneath 1 p.c (supply).
Combusting Hydrogen Spikes Native Air Air pollution
The EPA’s justification for co-firing hydrogen as a BSER for energy vegetation facilities on the truth that hydrogen doesn’t produce CO2 when combusted. Whereas that’s true, hydrogen does produce about six instances as a lot NOx as methane when its combusted (supply). We will see the firsthand impacts of NOx in frontline communities situated close to present closely polluting energy vegetation that produce excessive quantities of NOx. These communities see increased charges of bronchial asthma, coronary heart assaults and strokes, lung most cancers, and untimely dying than different areas (supply). These well being impacts are seen even when the vegetation are assembly present requirements for NOx emissions and holding emissions inside permitted ranges (supply).
The NOx emissions controls at the moment in place at most energy vegetation, comparable to utilizing a catalytic response, diluting the gasoline combine with water or steam, or utilizing newer low-NOx know-how comparable to a dry low NOx (DLN) combustion system, will not be geared up to deal with increased blends of hydrogen and pure gasoline. Even combusting a 30 p.c mix of hydrogen, which is what the principles would have vegetation begin out with, has not been examined on a bigger scale. In a single pilot demonstration, NOx emissions elevated as a lot as 24 p.c because the fraction of hydrogen elevated. To maintain NOx emissions inside permitted limits – which once more, nonetheless trigger severe well being impacts – the plant needed to considerably improve its water consumption throughout blended hydrogen combustion (supply).
The Backside Line
By definition, a Finest System of Emissions Discount should “serve the pursuits of air pollution management with out changing into exorbitantly expensive in an financial or environmental method.” Each CCS and hydrogen have up to now confirmed to be ineffective at controlling greenhouse gasoline emissions. In reality, each applied sciences run the chance of accelerating the very pollution these guidelines are geared toward limiting. By way of environmental value, each applied sciences will improve NOx air pollution, and delay the lifetime of polluting fossil gasoline belongings which have been harming communities for many years. It’s irresponsible of the EPA to designate hydrogen or CCS as viable BSER pathways. We will solely hope that the Company will take heed to feedback like those CEG, our companions, and plenty of different organizations have submitted, and that the finalized guidelines mirror the acute limitations and potential hurt of those applied sciences.