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EPA’s Carbon Pollution Standard May

INCREASE CO2 Emissions!

by William Yeatman on September 25, 2013

in Blog

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The Obama administration’s major new plan to reduce carbon dioxide emissions appears to have a major

flaw: It would increase carbon dioxide emissions.

Talk about an unintended consequence!

Last Friday, EPA proposed a regulation, known as the Carbon Pollution Standard, which would require

partial carbon capture and sequestration (CCS) at all new coal­fired power plants. In fact, it is highly

debatable whether CCS can actually be achieved. Industry claims—and I agree—that the technology is

not yet commercially viable, and therefore violates the Clean Air Act’s requirement that CCS be

“adequately demonstrated” before it can be imposed as a regulatory requirement. EPA, on the other hand,

claims that CCS is feasible.*

*For all the details: I’m currently working on a comprehensive review of the legality of EPA’s Carbon

Pollution Standard. It will be done soon and then I will post it here.

However, whether or not CCS technology is achievable may become a moot point, in light of the fact

that the technology as envisioned by EPA would increase greenhouse gas emissions, thereby rendering

the rule plainly absurd. Allow me to explain.

Due to the high cost of capturing, transporting, and sequestering carbon dioxide, EPA expects that any

new coal fired power plants built in the foreseeable future will defray the costs of CCS by selling its

carbon dioxide to oil companies, which can use the gas to help extract oil by displacing liquid fuels deep

underground, in a process known as CO2 enhanced oil recovery (or CO2­EOR). In the proposed rule,
EPA states that, “as a practical matter, we expect that new fossil fuel fired EGUs that install CCS will

generally make the captured CO2 available for use in EOR operations (p 262).”

Moreover, EPA expects the CO2 supply created by the Carbon Pollution Standard will spur development

of oil recovery. The agency claims,

“oil and gas fields now considered to be ‘depleted’ may resume operation because of

increased availability and decreased cost of anthropogenic CO2, and developments in EOR

technology, thereby increasing the demand for and accessibility of CO2 utilization for EOR

(p 232).”

So...EPA expects that plants complying with the Carbon Pollution Standard will sell their captured CO2

to oil producers. And by increasing the supply of commercial CO2 on the market, EPA posits that the

price of CO2 will decrease, leading to a boom in oil and gas production.

But there’s a HUGE problem with EPA’s proposal. It completely fails to take into account the expanded

carbon footprint of the oil industry caused by its power plant rule. And, if my admittedly simplistic

calculations are correct, EPA’s rule would result in an increase of carbon dioxide emissions.

I should note here that CO2­EOR is an engineering marvel, one that I would never pretend to

comprehend. So I called someone who does. And I asked him whether there was a relationship between

the amount of CO2 injected in an EOR well, and the amount of oil that comes out. He replied that there

was, and that it is known in the industry as the “utilization ratio.” He explained that a utilization ratio is

not a static figure. Evidently, the initial stages of drilling require much more CO2 than the later stages.

After cautioning that the calculation of a utilization ratio is highly sensitive to assumptions, he said that a

reasonably representative utilization ratio is 5,000 cubic feet of CO2 per barrel of oil. I then asked how

much does a standard cubed foot of CO2 weigh, and he answered .05189 kilograms. Finally, I looked up

online the weight of CO2 emissions from the combustion of a barrel of oil. The answer is 433 kilograms.

With this data, it is possible to calculate a rough approximation of how much CO2 will be created by

each kilogram of CO2 captured from a CCS coal plant, and used to enhance oil recovery.

1 Kg CCS CO2*(1 cubed foot CO2/.05189 Kg)*(1 barrel oil/5,000 cubed feet)*(433 Kg CO2/1 barrel

oil)

This works out to 1.66 Kg CO2 emitted for each 1 Kg CO2 captured and then used in EOR.

Assuming that a CCS project captures 600 lbs CO2/MWh and that the plant is running at 85% capacity,

then a typical coal plant in compliance with EPA’s Carbon Pollution Standard would result in the

emission of 1.3 million more kilograms of CO2 than the plant would “save” per megawatt capacity

annually. And that doesn’t include the emissions due to the energy input necessary to extract the oil.

Again, I’m no engineer. So if my math is wrong, please let me know (I can be reached at

wyeatman@cei.org ). If I’m right, however, then this rule is toast.

Comments on this entry are closed.

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