## Summary	of	Interagency Working	Comments	on	Draft	Language	under

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

Page **1** of **3** 

## 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 a dding 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 - u p, 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]C OE with CO2 emission levels is not steep for either SC PC or IGCC plants (except at low capture rates), designing for this margin does no t have major cost implications.’” **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 an d performance report” 

### TECHNICAL COMMENTS **Page 1.**

“– for such a unit utilizing bituminous coal that would be approximately 16 percent “DELIBERATIVE DRAFT – NOT FOR DISTRIBUTION – NOT A STATEMENT OF ADMINISTRATION POLICY

Page **2** of **3** Reviewer recommends rewording this sentence for clarity:

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

## TSD: Geographic Availability **PRIORITY COMMENTS Page 5.**  Comment is in regards to the p aragraph that discusses the evaluation of storage resources in states: Reviewer notes that t he paragraph and the section implies that NETL did not assess storage potential in specific areas. Reviewer notes that t he 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 Sequestrat ion 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. ” **Page 10 , Summary of Findings**  **.** Reviewer recommends noting th at this is the technic al maximum potential of storage. As such, reviewer s uggest s adding the following paragraph to page 10: “These resource estimates represent the technical maximum potential, although other considerations such as p ore space availability and ownership, economics, and legal constraints will factor in to which fields are developed within each geographic basin.”DELIBERATIVE DRAFT – NOT FOR DISTRIBUTION – NOT A STATEMENT OF ADMINISTRATION POLICY

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### TECHNICAL COMMENTS **Page 2.**



### “ Figure 2 shows the location of high voltage electrical transmission lines (gr eater than 230 **volts** )” Reviewer recommends correcting text to read “Kilovolts” instead of “volts.” **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 transmiss ion 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 - presidential permit - 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 proje ct 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 fr om 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. 

## 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).