Determining the Applicability of Carbon Capture and Storage under Best Available Control Technologies (BACT) for Any New or Modified Prevention of Significant Deterioration (PSD)

Steven M. Carpenter
Advanced Resources International, Batavia, Ohio, [email protected]

The Environmental Protection Agency is anticipated to issue the first limits on greenhouse gas emissions from new power plants. This regulatory act may end the construction of conventional coal-fired facilities in the United States. The proposed rule will require any new power plant to emit no more than 1,000 pounds of carbon dioxide per megawatt hour of electricity produced. The average U.S. natural gas plant, which emits 800 to 850 pounds of CO2 per megawatt hour, meets that standard; coal plants emit an average of 1,768 pounds of carbon dioxide per megawatt hour.

A mechanism to evaluate the potential applicability of CCS for coal fired power production in the US. The ever changing, ever increasing, ever tightening regulatory climate that requires consideration of Best Available Control Technologies (BACT) for any new or modified Prevention of Significant Deterioration (PSD) and Title V requirements is a key mechanism to accomplish both the “letter and spirit of the law”.

In principle, Carbon Capture & Storage (CCS) would provide reduction of greenhouse gases and therefore should be considered. However, since CCS is neither a proven commercial technology nor is it mandated (as of yet), it seems that requiring consideration now is confusing at best.

EPA guidance states that permit applicants and permitting authorities should consider all “available” GHG control options that have the potential for practical application to the source under consideration. The guidance further suggests that once permitting authorities gain experience with GHG BACT determinations, useful information on GHG permitting decisions will be presented.

The expression of regulatory decisions and permitting based on “future tense” terms makes planning, operational, and strategic decisions very difficult for the electric generation market. This presentation will endeavor to discuss and navigate specific details in the PSD requirements for power generation as they apply to carbon capture and storage, and more specifically, how coal fired plants can comply with both the spirit and intent of the rule.

AAPG Search and Discovery Article #90154©2012 AAPG Eastern Section Meeting, Cleveland, Ohio, 22-26 September 2012