***E.O. 12866 Review–Draft–Do Not Cite, Quote, Or Release During Review ***

2-1 11-4 draft

EO12866EGUGHGNSPSRIA2060-AQ9120111104Ch2.docx

SECTION 2

CONTROL STRATEGIES 

2.1 Synopsis

For this proposed GHG EGU NSPS, EPA considered a number of alternative emission 

control strategies. This section defines the source categories affected by the proposal, outlines 

regulatory actions considered in the analytical baseline, and describes the control strategies 

and regulatory alternatives for new, modified, reconstructed, and transitional sources. Existing 

EGU GHG sources are not addressed in this action, but will be the subject of a subsequent 

action by the EPA.

2.2 Definition of Affected Sources 

2.2.1 Electric Utility Generating Unit

For the purposes of this rule, the EPA is proposing to define an EGU as any fossil fuelfired combustion unit that has the potential to produce more than 25 megawatts (MW)

electrical output and serves as a generator that produces electricity for sale, with the exception 

of simple cycle turbines. For this rule, the term EGU includes steam generating units (“boilers”), 

natural gas combined cycle (NGCC) combustion turbines and their associated heat recovery 

steam generator (HRSG) and duct burners, and Integrated Gasification Combined Cycle (IGCC, 

"coal gasification") units – including their combustion turbines and associated HRSGs. A unit 

that cogenerates steam and electricity or that cogenerates feedstocks (e.g., hydrogen or 

hydrocarbons from an IGCC) for chemical or fuel production and supplies more than one-third 

of its potential electric output capacity and more than 25 MW output to any utility power 

distribution system for sale is also considered to be an EGU for purposes of this rule.

2.2.2 New Sources

Sources affected by the new source provisions of the proposal are sources) that are both 

considered “EGUs” and are considered “new” as defined by this rule. In the general NSPS 

provisions (40 CFR Part 60) a new source is one that begins construction (or reconstruction) 

after the date the provisions are proposed. For purposes of this rule the EPA is proposing 

several alternative definitions of “new”.

CAA section 111(a)(2) defines a “new source” as “any stationary source, the construction 

or modification of which is commenced after publication of regulations (or, if early, proposed 

regulations) prescribing a standard of performance under [CAA section 111] which will be 

applicable to such source.” In contrast, CAA section 111(a)(6) defines an “existing source” as 
***E.O. 12866 Review–Draft–Do Not Cite, Quote, Or Release During Review ***

2-2 11-4 draft

“any stationary source other than a new source.” The definition of a “new source” applies 

according to its terms for purposes of this rulemaking, except that special considerations come 

into play for sources undertaking physical or operational changes, transitional sources, and 

sources undertaking reconstruction.

This proposal requires that all new fossil-fuel fired units of 25 megawatt or greater

capacity be able to meet an emission rate standard of 1000 pounds of CO2 per megawatt hour 

(lb CO2/MWh). It also proposes an alternative standard that would allow units to meet the 

1000 lb CO2/MWh standard using a 30 year averaging period. These standards could be met 

either by natural gas combined cycle generation or coal-fired generation using carbon capture 

and sequestration technology. 

2.2.3 Modified Sources

The EPA is not aware of any EGUs that would undertake actions defined as 

modifications. A modification is any physical change in, or change in the method of operation 

of, a source that increases the amount of any air pollutant emitted by the source or results in 

the emission of any air pollutant not previously emitted. However, the types of projects that 

these EGUs are most likely to undertake that could increase GHG emissions are projects that 

put on pollution controls required under other CAA provisions and that emit CO2 as a 

byproduct, and those types of projects are specifically exempted from the definition of 

“modifications” under 40 CFR 60.14(e)(5). The EPA is soliciting comment on this issue, but in 

the meantime, the EPA is not proposing standards for modifications. The EPA believes that it 

does not at present have adequate information as to the type of action, its costs, or the amount 

of its CO2 emissions, to base a proposed standard of performance. Therefore, sources that 

undertake physical or operational changes that increase their maximum achievable hourly CO2

emission rate will be treated as existing sources and thus not subject to the proposed EGU GHG 

NSPS requirements.

2.2.4 Transitional Sources

In this proposal, EPA identifies transitional sources as those sources that have received 

permits to construct, but have not actually commenced construction. EPA believes that there 

are approximately 18 such units (see Appendix 2-A for a list of potential transitional units). 

Historically, obtaining a permit does not guarantee that a unit will end up being constructed. In 

the last 10 years, approximately 90 coal plants have been permitted. Of those, 40 (or less than 

half) have actually commenced construction. Thirty projects have been cancelled and 

approximately 18 sources (the transitional sources) have active permits. Based on this history, 

EPA believes that a number of units would not likely proceed to construction regardless of the 
***E.O. 12866 Review–Draft–Do Not Cite, Quote, Or Release During Review ***

2-3 11-4 draft

requirements of this rule. For these units, this rule adds no costs. Furthermore, in its rule, EPA 

is proposing that as long as units commence construction within one year of the effective date 

of this proposal, construction can proceed without being affected by this rule. For these units, 

this rule adds no additional costs and no benefits from the rule will accrue to society.

EPA believes the units that are most likely to commence construction are those that 

have received government incentives to install CCS. These units would be able to commence 

construction within the proposed rule time-frame. 

2.2.5 Reconstructed Sources

The EPA’s CAA section 111 regulations provide that reconstructed sources are to be 

treated as new sources and, therefore, subject to new source standards of performance. The 

regulations define reconstructed sources as, in general, existing sources: (i) that replace 

components to such an extent that the capital costs of the new components exceed 50 percent 

of the capital costs of an entirely new facility, and (ii) for which compliance with standards of 

performance for new sources is technologically and economically feasible( 40 CFR 60.15). In 

theory existing power plants may reconstruct, however, EPA is not aware of any that have 

announced plans to do so. In addition to this provision being triggered rarely, the costs 

associated with reconstructing units are likely similar to the cost of building a new unit. Thus,

even if this provision is triggered, EPA believes that sources will make decisions that mimic 

those for new sources as previously discussed.

2.2.6 Existing Sources

The affected source is any existing fossil fuel-fired EGU that is not a new EGU. For the 

purposes of this rule an existing EGU is defined as any fossil fuel-fired combustion unit that has 

the potential to produce more than 25 MW output and serves a generator that produces 

electricity for sale and was in operation or commenced construction on or before publication of 

this proposed rule. Existing sources are not covered in this proposed action, but will be 

addressed in a subsequent rulemaking by the EPA.

2.3 Analytical Baseline 

EPA used the Integrated Planning Model (IPM) v.4.10 to assess the baseline conditions 

described for the proposed new source performance standards. IPM is a dynamic linear 

programming model that can be used to examine the economic impacts of air pollution control 

policies for CO2 and other air pollutants throughout the contiguous U.S. for the entire power 

system. The modeling conducted for this proposal is discussed more extensively in Section 7 of 
***E.O. 12866 Review–Draft–Do Not Cite, Quote, Or Release During Review ***

2-4 11-4 draft

this RIA. Documentation for IPM can be found in the docket for this rulemaking or at 

http://www.epa.gov/airmarkets/progsregs/epa-ipm/index.html. For more information on the 

analytical baseline see Section 5 of this report.

2.4 Control Strategies

This proposal requires that all new fossil-fuel fired units of 25 megawatt or greater 

capacity be able to meet an emission rate standard of 1000 pounds of CO2 per megawatt hour 

(lbs CO2/MWh). It also proposes an alternative standard that would allow units to meet the 

1000 lbs CO2/MWh standard using a 30 year averaging period. These standards could be met 

either by natural gas combined cycle generation or coal-fired generation using carbon capture 

and sequestration technology. 

2.5 Emission Reductions 

As will be discussed in more detail in this RIA, the EPA does not anticipate that the 

proposed GHG EGU NSPS will result in notable CO2 emission changes, energy impacts, benefits,

costs, or economic impacts by 2020. The EPA expects that owners of new units will choose 

technologies that meet these standards due to expected economic conditions in the 

marketplace. Likewise, we believe this rule will not have notable impacts the price of 

electricity, labor markets, or the general economy. 
***E.O. 12866 Review–Draft–Do Not Cite, Quote, Or Release During Review ***

2-5 11-4 draft

Appendix 2-A – Transitional Units

Plant Name Size CO2 Mitigation Plan Location 

Trailblazer 600 MW CCS – EOR (supercritical PC) TX 

Taylorville 602 MW CCS – EOR/Geologic (IGCC) IL 

Texas Clean Energy 

Project 400 MW CCS – EOR (IGCC) TX 

Sweeny Refinery 680 MW CCS - EOR (IGCC, pet coke) TX 

Cash Creek 

Generation 761 MW CCS - IGCC KY 

Power County 

Advanced Energy 

Center 

520 MW CCS – EOR (IGCC) ID 

Good Spring 270 MW CCS – IGCC PA

Limestone 3 750 MW 

Agreement to capture or offset 

50% of CO2 (subcritical PC) –

CCS ready 

TX 

Holcomb 2 895 MW None (supercritical PC) KS 

White Stallion 1320 MW None (subcritical CFB) TX 

James De Young 78 MW None (subcritical CFB) MI 

Wolverine 600 MW None (subcritical CFB) – CCS 

ready MI 

Coleto Creek 650 MW None (supercritical PC) – CCS 

ready TX 

Las Brisas Energy 

Center 1320 MW None (subcritical CFB, pet coke) TX 

Washington County 850 MW None (supercritical PC) GA

Longleaf 1200 MW None (subcritical PC) GA

Bonanza 110 MW None (subcritical CFB, waste 

coal) UT 

Two Elk 250 MW None (subcritical PC, waste coal) 

– CCS ready WY 

PC = pulverized coal

CCS = carbon capture and storage

CFB = circulating fluidized bed

EOR = enhanced oil recovery

IGCC = integrated gasification combined cycle
***E.O. 12866 Review–Draft–Do Not Cite, Quote, Or Release During Review ***

2-6 11-4 draft