From: Frey, Nathan J.

To: Wayland, Robertj

Cc: Culligan, Kevin; Hutson, Nick; Fellner, Christian

Subject: RE: Cost of CCS Response

Date: Friday, August 23, 2013 2:31:05 PM

Thanks Bob. I’ll get you that agenda ASAP.

From: Wayland, Robertj [mailto:Wayland.Robertj@epa.gov] 

Sent: Friday, August 23, 2013 2:12 PM

To: Frey, Nathan J.

Cc: Culligan, Kevin; Hutson, Nick; Fellner, Christian

Subject: Cost of CCS Response

Nathan –

Attached to this email is our updated response to your inquiry regarding the cost of CCS.

Please let us know if you have any questions/concerns. Also, it would be most helpful if

you could provide us agendas for the two calls next week. If we know which issues you

want to discuss on the calls, we can make sure we have the appropriate EPA folks on each

call. Also, it will free-up more lines if we don’t need all the EPA team on both calls. If you

can shoot me something later today or early of Monday, we’ll make sure the right staff are

available for each call.

thanx!

bob

Robert J. Wayland, Ph.D.

Leader, Energy Strategies Group

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

Mail Code D243-01

Research Triangle Park, NC 27709

Office: (919) 541-1045

Cell: (919) 306-2290

Fax: (919) 541-5450

Email: wayland.robertj@epa.gov

*************************************

DRAFT/Deliberative Document - FOIA Exempt

*************************************
Summary of Interagency Working Comments on Draft Language under

EO12866 Interagency Review.  Subject to Further Policy Review 

‐ EPA RESPONSE ‐

Costs of CCS:

 Below is a table produced by NETL that provides a range of cost estimates for next of a 

kind plants The commenter believes that it would be appropriate for the proposed rule to 

consider the full range of cost estimates developed by NETL, recognizing the level of 

uncertainty in these estimates. 

[EPA Response: We will add language to the preamble indicating the uncertainties 

associated with the estimates and indicate that the costs may be higher than estimated. 

We will also acknowledge that ‘first-of-a-kind’ technology implementation is often more 

expensive than ‘next-of-a-kind’ implementation and the yet-to-be-built plants will benefit 

from technology demonstrations at Kemper, Boundary Dam, Summit, etc.] 

 Commenters also note NETL baseline studies issued in 2010 and 2013 that present status 

of coal technologies with estimates on efficiency and CO2 emissions. Volumes 1 and 3 

of this study list various technologies for bituminous and low-rank coals (e.g., ultrasupercritical technology is covered for only low-rank coals in Volume 3). You can find 

these reports at: http://www.netl.doe.gov/energy-analyses/baseline_studies.html (See 

Volume 1, page 26 for bituminous coal CO2 emissions, and Volume 3, page 37 for subbituminous coal CO2 emissions and page 38 for lignite coal emissions.) The commenters 

ask that EPA consider this information in its assessment of costs for CCS technologies 

and provide language in the preamble of the rule discussing the uncertainties associated 

with CCS cost estimates and the implications for EPA’s determination of BSER for coal. 

[EPA Response: The EPA is aware of and familiar with all available volumes of the 

DOE/NETL “cost and performance” reports – we believe them to be the best and most 

thorough reports available. For simplicity we have chosen to base our cost assumptions 

on information contained in Volume 1 (bituminous) since that information is also used in 

the companion report on partial capture cost and performance. As noted above, we are 

adding language to the preamble to discuss uncertainties associated with the cost 

estimates.]