Testimony of Pam Hardwicke Clean Air Task Force May 24 , 2012 

# CLE 

# :F') TASK FORCE

On behalf of the Clean Air Task Force, I would like to offer comments on U.S. EPA ' s proposed lll(b) rule that will establish C02 emissions limits on new fossil power plants. The Clean Air Task Force is an international nonprofit environmental organization headquartered 

### in Boston , Massachusetts that operates throughout the United States and China. CATF focuses on the key atmospheric air pollution issues of the 21 s t century: greenhouse gas emissions that drive climate change , and particulate matter that linked to premature death and disease . Our staff works exten s ively with companies in both the US and China that develop advanced low-carbon technologies , including carbon capture and storage (CCS). Carbon capture and storage is an available technology that U.S. EPA can and should rely upon in establishing C02 emission limits for new fossil fuel electrical generating units (EGU). In Kemper County Mississippi , Plant Radcliffe is a new 582 MW coal power plant that is under construction. When it opens in 20 J4 , the plant will capture 65% of its 18 Tremont St. , Suite 530 

### I Boston , MA 021081 www .catf . us 1 617 . 624 .0234C02 and seque s ter them deep und erg round. Th e C02 emissions from this p lant are estimated at 550 lb/MWWh (gross) . In Odessa Texas , th e Texas C lean Energy Project (TCEP) is e xpected to break g round later this year. The 400 MW project will turn coal into ba se load power, f ertilizer and produce C 02 that will b e seque stered d eep underground. TCEP will capture over 90% of the C02 it wo u ld otherwise emit. The emission rate for this plant wh en it goes into operation in 2015 will be 228 lb/MWWh (gross). Other proj ects th a t u se CCS are advancing a s well. E PA is not limited to lookin g at EGU applications. Earli er thi s month, the Indiana D ep artm ent of Environmental M anagement ( ID EM ) fil ed an 

### air permit with U.S . E PA r eg ion 5 for the Indiana Gasification LLC proj ec t in Ro ckport . Whil e thi s proj ect is not intended to produc e s ignifi cant e lec tricity generation , it w ill tum coal into natura l gas and the permit requires CCS. The plant will capture at lea st 80% of th e C02 that would otherwise be emitted . The liqu efie d C02 from the plant will b e se qu estere d d eep underground and thereby p erman en tly iso l a ted from the atmosphere. Whil e th ese proj ects are n ew , it i s import ant to emphasize that the components of CCS ha ve b een demonstrated and used successfull y both in thi s country and abroad for many , many year s.

### o In Texas alone, over 1 billion tons of carbon dioxide already has been sequestered underground. EOR is an important technology because revenue from the sale of C02 helps pay for CCS costs. The capacity of EOR to handle C02 emissions is large in the United States . A 

### new DOE study notes that 67 billion barrels of oil are economically recoverable at an oil price of $85 per barrel. This would require the purchase of 20 billion metric tons of C02 at a projected price of $40/ton. This is equiva lent to 30 years of C02 emissions from 93 GW of coa l plants. 1



### o In evaluating BSER, EPA i s not limited only to domestic applications . In Norway, the Sleipner C02 injection operation in the North Sea has isolated 8-9 million t ons of C02 in a saline formation since 1996 without evidence ofleakage.z

o Moreover, the US already has over 4,000 miles of C02 pipelines in operation. C02 pipelines carry C02 from natural reservoirs as well as industrial sources to EOR sites. The expansion ofthis network to meet

1 

### NETL, Improving Domestic Energy Security and Lowering C02 Emissions with Next Generation C02-Enhanced Oil Recovery (C02-EOR) , 

### June 2011, page 1 . 2 

### Sleipner Fact Sheet: Carbon Dioxide Capture and Storage Project, available at http:// se qu es t ration.mit.edu/tool s /proj e cts / s le ipn e r.htmlfuture C02 transportation needs presents no new technical or regulatory uncertainties.

o In addition to the plants described above, carbon capture technology is operating in a variety of settings and fuels in the United States and across the world. For example, in the U.S., Plant Barry near Mobile, Alabama is capturing C02 using post-combustion capture technology, and the Dakota Gasification Plant in North Dakota has been using pre-combustion capture technology to capture C02 and send it via pipelines to oil fields in Canada, where it is sequestered via enhanced oil recovery options. In China, the Shidongkou post-combustion CCS facility has been removing over 120,000 tons of C02 from a coal-fired power plant outside Shanghai since 2010 . I appreciate thi s opportunity to comment at this hearing . CATF intends to file more detailed materials into the record as part of our written comments due by June 24 , 2012. Thank you , Pam