DELIBERATIVE PRE - DECISIONAL DRAFT – NOT FOR DISTRIBUTION – NOT A STATEMENT OF ADMINISTRATION POLICY 

# Summary	of	Interagency	Working	Comments	on	Draft	Language	under	EO12866/13563	Interagency	Review.		Subject	to Further	Policy	Review.

Page **1** of **3 BACKGROUND ON COST AND PERFORMANCE OF**  **CARBON CAPTURE AND STORAGE ( CCS**  **) AND NUCLEAR**  Our best information for pulverized coal ( PC ) and integrated gasification combined cycle ( IGCC ) power plant s is shown in the table below for non - capture plants and for plants with design emissions rates of 1,100 and 1,400 lb CO 2

### /MWh - gross as well as several other potential standards on a net basis . The PC and IGCC data is from a forthcoming NETL report . 1 

### These estimates do not include revenue from enhanced oil recovery ( EOR ) , which w ould lower LCOEs for plants with CCS. 2 

### The estimates for nuclear power plants are from a variety of sources, including EIA, EPRI, and others. Ultra Super Critical PC / Super Critical PC IGCC 3 

### Nuclear Design full load emissions rate 4 lb CO 2/MWh gross 

### 1 , 6 18 1 , 400 1 , 300 1 , 200 1 , 100 1 , 430 1 , 100 900 0 lb CO 2/MWh net 

### 1 , 7 05 1 , 498 1 , 400 1 , 30 2 1 , 20 1 1 , 720 1 , 356 1 , 129 0 CO 2 

### Captur e (%) 0% 16% 22% 29% 35% 0% 22% 37 % N/A Incremental Capital Cost of Partial CO 2 

### Capture (%) 0% 21% 27% 3 2 % 37% 0% 1 0 % 15% N/A LCOE - 15% (2011$/MWh) 75 .8 * 90.7 94.6 98.3 101.9 93 .7 101.4 10 7.3 N/A LCOE 5 

### (2011$/MWh) 82 .3 * 97.8 101.4 104.8 108.1 102.6 109.3 114 .2 96; 93 - 102 6 

### 106 7 

### ; 74 - 140 8 

### LCOE +30% (2011$/MWh) 9 5.3 * 115.9 121 .0 125 .8 130.5 12 0.3 130 .8 13 8.1 N/A Estimate of % Natural Gas Co Firing to Meet Standard 9 

### 0% 30% 45% 60% 75% 0% 60% 80% -

1 Forthcoming 2015 NETL report titled “ Cost and Performance Baseline for Fossil Energy Plants Supplement: Sensitivity to CO 2 Capture Rate in Coal - Fired Power Plants . ” 2 Once captured, CO 2 can be either permanently sequestered in an underground geologic formation (such as a saline aquifer), or utilized for injection into an oil field for enhanced oil recovery (EOR), a technique for producing additional crude oil from oil fields depleted by conventional production techniques. For example, in the case where captured CO 2 is utilized for EOR, a PC power plant that captures 29% of its CO 2 emissions for sale for injection into an oil field for EOR at a price of $30 per ton CO 2 at the plant gate could realize a reduction in the plant LCOE of approximately $8 per MWh. How ever, CO 2 prices are likely to be sensitive to the price of oil. 3 The incremental cost of achieving a 1,400 lb CO 2/MWh -gross standard for an IGCC is not evaluated here due to data limitations; in addition, the non - capture IGCC would likely use efficiency improvement measures or natural gas co - firing measures to close the small gap to the standard. 4 Gross CO 2 emissions represent full - load design emissions. Slightly higher capture rates and associated higher costs would be required to meet a specific limit u pon accounting for the effects of start - up and shut - down. Additional analysis is required to quantify these requirements. 5 2011 year dollars except as noted; constant - dollar 30 - year levelized values. Uncertainty ranges represent the capital cost accuracy range only ( - 15%+ 30%) and do not take into account variability due to site - specific conditions or costs, uncertainty in O&M costs including fuel, variability in finance structure, etc. The LCOEs are no t directly comparable to EIA/ EPA LCOEs due to differing finance structur es, year dollars, scope of capital cost estimate, etc. 6 EIA AEO 2014. EIA’s point estimate is $96.10 per MWh in 2012$; Regional Variation is $93 to $102 per MWh in 2012$. 7 Staff estimate of LCOE for the next commercial offering of an advanced nuclear po wer plant. 8 Multiple sources in multiple year- dollars : NREL ReEDS at $100 – $118/MWh; Lazard (2014) at $124/MWh; Rothwell for SMRs (2014) at $74 - $140/MWh. 9 Staff estimate. Assumes coal contains 201.3 Lb CO 2/MMBtu and natural gas contains 117 Lb CO 2/ MMBtu. Assumes that IGCC has no heat rate penalty for natural gas co - firing, and assumes SCPC has a 1.5% heat rate penalty for natural gas co - firing. IGCC unit heat rate of 8,756 Btu/KWh (~39% efficient) with net power between 595 MWh to 622 MWh. SCPC unit heat rate of 8,379 Btu/KWh (~41% efficient) with a net power of 550 MWh.DELIBERATIVE PRE - DECISIONAL DRAFT – NOT FOR DISTRIBUTION – NOT A STATEMENT OF ADMINISTRATION POLICY 

# Summary	of	Interagency	Working	Comments	on	Draft	Language	under	EO12866/13563	Interagency	Review.		Subject	to Further	Policy	Review.

Page **2** of **3** Study/Technology Notes Forthcoming 2015 NETL report with updated post - combustion capture (Cansolv ** ), CO 2 compression and steam turbine quotes; natural gas co -firing is a Staff estimate Forthcoming 2015 NETL report derived from 2010 performance data and 2012 cost update; GE gasifier case; natural gas co -fir ing is a Staff estimate Multiple sources; see respective footnotes * These LCOE estimates for coal without carbon capture use a lower- cost financing structure in comparison to IGCC units and units with carbon capture; **Cansolv – The CANSOLV CO 2 Capture System is an amine - based CO 2 capture technology.DELIBERATIVE PRE - DECISIONAL DRAFT – NOT FOR DISTRIBUTION – NOT A STATEMENT OF ADMINISTRATION POLICY 

# Summary	of	Interagency	Working	Comments	on	Draft	Language	under	EO12866/13563	Interagency	Review.		Subject	to Further	Policy	Review.

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

# Net and Gross Emissions for PC and IGCC Units

0% Capture

22% Capture 26% Capture

32% Capture 0% Capture

16% Capture

29% Capture 35% Capture

900 1,000 1,100 1,200 1,300 1,400 1,500 1,600 1,700 1,800

900 1,000 1,100 1,200 1,300 1,400 1,500 1,600 1,700CO2Emissions*(lb/MWh-net)



### CO 2 

### Emissions* (lb/MWh - gross)

IGCC PC