Summary	of	Interagency	Working	Comments	on	Draft	Language	under	

EO12866/13563	Interagency	Review.		Subject	to	Further	Policy	Review.

Page 1 of 4

TSD: Achievability of New Steam

PRIORITY COMMENTS

Page 1.

“The EPA finds the final standard of 1,400 lb CO2/MWh-g to be achievable over a wide range of variable 

conditions that are reasonably likely to occur when the system is properly designed and operated.”

Reviewer notes that a higher capture rate under periods of steady-state operation could be required to 

accommodate start-up, shut-down, and part-load events in order to achieve the target over a 12 

operating month average – the value will depend on the number of such events, and operational 

procedures and characteristics during the events. Although a unit will be designed to run at 85% 

capacity factor, recent trends in natural gas prices have decreased the CF of existing plants below this 

level, thus this is possible that a unit facing these conditions may meet the standard on a 12 month 

rolling basis.

For clarity, reviewer recommends either adding a footnote to the sentence on page 1 above that refers 

the reader to the caveat included on page 4 of the TSD, which reads: 

“The DOE/NETL stated that ... ‘Actual average annual emissions from operating plants are likely to be 

higher than the design emissions rates shown due to start-up, shutdown, part-load operation, and 

performance degradation through maintenance cycles. Lower design emissions rates to ensure 

adequate margins may be required for compliance with future regulations; however, given that the 

slope of the variation of [L]COE with CO2 emission levels is not steep for either SC PC or IGCC plants 

(except at low capture rates), designing for this margin does not have major cost implications.’”

EPA Response: This suggested footnote has been added.

Page 5.

“The highest 12-operating-month averages for the Longview Power plant is about 11% higher than the 

NETL design – but the Longview Power plant does not utilize the ultra-supercritical steam conditions 

that NETL assumes in the cost and performance report” uses different steam 

Reviewer recommends rephrasing as follows: ““The highest 12-operating-month averages for the 

Longview Power plant is about 11% higher than the NETL design – but the Longview Power plant does 

not utilize the ultra-supercritical utilizes different steam conditions than that NETL assumes in the cost 

and performance report”

EPA Response: This edit has been made.

TECHNICAL COMMENTS
DELIBERATIVE DRAFT – NOT FOR DISTRIBUTION – NOT A STATEMENT OF ADMINISTRATION POLICY

Page 2 of 4

Page 1.

“– for such a unit utilizing bituminous coal that would be approximately 16 percent “

Reviewer recommends rewording this sentence for clarity:

“A SCPC unit utilizing bituminous coal could achieve the BSER with partial capture of approximately 16 

percent.”

EPA Response: This edit has been made.

Page 3, Table 1.

Reviewer notes that a data point is missing – the Bituminous emission rate at 23% capture. Reviewer 

suggests either clarifying why this was not included or including the data point in the table.

EPA Response: The DOE/NETL report did not provide that data point ... however, from Figure 1, I have 

estimated 1,280 lb/MWh-g. In any case, it will be very similar to the 22% capture listed above.

Page 3.

“As shown in Table 8 in the rule’s final preamble”

Reviewer recommends including Table 8 in this TSD to minimize reader confusion and cross referencing.

EPA Response: The Table has been added.

TSD: Geographic Availability

PRIORITY COMMENTS

Page 5.

Comment is in regards to the paragraph that discusses the evaluation of storage resources in states:

Reviewer notes that the paragraph and the section implies that NETL did not assess storage potential in 

specific areas. Reviewer notes that the Regional Carbon Sequestration partnerships (RCSPs) are 

voluntary organizations and storage potential was not assessed in particular states due to a variety of 

factors. 

Thus reviewer suggests adding the following text to the TSD: “However, the Regional Carbon 

Sequestration partnerships (RCSPs) are voluntary organizations and storage potential was not assessed 

in particular states due to a variety of factors: some states did not participate because they do not have 

adequate storage resources; other states did not assess storage as little oil and gas development has 

been done in the state due to low resource availability; other states did not submit storage assessments 

as they did not have the expertise nor the data to participate.”
DELIBERATIVE DRAFT – NOT FOR DISTRIBUTION – NOT A STATEMENT OF ADMINISTRATION POLICY

Page 3 of 4

EPA Response: Done

Page 10, Summary of Findings.

Reviewer recommends noting that this is the technical maximum potential of storage.

As such, reviewer suggests adding the following paragraph to page 10:

“These resource estimates represent the technical maximum potential, although other considerations 

such as pore space availability and ownership, economics, and legal constraints will factor in to which 

fields are developed within each geographic basin.”

EPA Response: Done

TECHNICAL COMMENTS

Page 2. 

“Figure 2 shows the location of high voltage electrical transmission lines (greater than 230 

volts)”

Reviewer recommends correcting text to read “Kilovolts” instead of “volts.”

EPA Response: Done

Pages 19-20.

“To partly make up for retiring coal and nuclear, northeastern utilities and Hydro-Quebec have proposed 

constructing several transmission lines, including the 1,200-MW Northern Pass, to increase the 

transmission of electricity from Canada.”

Reviewer suggests using an alternative project example such as the New England Clean Power Link 

project in Vermont (for more info, see http://energy.gov/oe/downloads/application-presidentialpermit-oe-docket-no-pp-400-tdi-ne-new-england-clean-power-link). If EPA wants to continue using the 

Northern Pass Project, suggest revising the text to reflect that the entity that has proposed the Northern 

Pass project is Northern Pass Transmission, LLC, which is a partnership of Eversource (new name as of a 

couple months ago) and Hydro-Qeubec. Further, the "purpose" of these projects is to increase access to 

Canadian hydro, not necessarily to increase transmission from Canada; each project has its own more 

specific purpose which is provided in its application, available through the DOE website for Presidential 

permit dockets/pending dockets.

EPA Response: Done - Deleted old sentence and added new language: Additionally, entities are 

also proposing to build transmission between the United States and Canada to increase access 

to Canadian hydropower. For example, Champlain VT, LLC (doing business as TDI-New England), 

applied in 2014 for a Presidential Permit to build the New England Clean Power Link which it 
DELIBERATIVE DRAFT – NOT FOR DISTRIBUTION – NOT A STATEMENT OF ADMINISTRATION POLICY

Page 4 of 4

stated would bring “clean, affordable hydropower to Vermont and the New England 

marketplace.”[FN: Champlain VT, LLC Application for Presidential Permit (May 20, 2014), available at

http://energy.gov/sites/prod/files/2014/07/f17/PP-400%20TDINew%20England%20Application%20with%20Appendices_0.pdf.]

TSD: IRP Review

Reviewer recommends that EPA include some context specific to the 111(b) rule in the intro text (e.g., 

explain why this information is provided in the docket).

EPA Response: Done