The Clean Air Mercury Rule impacts new and existing coal-fired electric generating plants through a market-based cap-and-trade program similar to the EPA’s highly successful Acid Rain Program. The...
The Capture-Committed Power Plant
Moving coal forward requires a clear path to CCS.
to CCS. That technical path should address each of the components of CCS—capture, transport and storage.
• Capture: At least one capture method that could be used for the plant should be identified and a preliminary design developed for capture using that method. At the most basic level for a pulverized coal plant, this means choosing between post-combustion and oxyfiring or, if possible, allowing for both. Given the uncertainties of technical development, flexible designs would be most useful. The design of the original as-built plant should include all necessary modifications to the original plant to ensure that the capture design can be implemented. In addition, a work plan for implementation that minimizes the plant’s down time for modifications should be developed.
• Transport: Ideally, the plant would be sited directly above a useable storage formation. Where this would not be possible, the route from the plant to the storage site should be identified. In the vast majority of projects, CO 2 is likely to need to be transported by pipeline. All permits and rights for this pipeline transport should be acquired.
• Storage: For the storage component, a site should be identified with capacity adequate for the operational life of the facility. The storage site should also be proven to have effective trapping mechanisms with very low risk of leakage. This would require an up-front investment in geologic and geological engineering work including: review of available geologic information; seismic studies of the potential reservoir; and possibly, the drilling of test wells to verify seismic information.
Methods for estimating storage capacity and evaluating storage integrity have been developed and are being refined. 13 They have reached a state of the art adequate to develop regulatory requirements for capture-committed plants. To the extent test wells are drilled, it might sometimes be most cost-effective if these could be designed in such a way that they could be used later as either injection or monitoring wells.
It’s important that the project developer not actually be required to implement CCS as originally designed, but rather meet a CCS performance standard at least equal to the commitment that was made. The technology and options for CCS likely will improve considerably between the time the plant is built and the time CCS actually is implemented. That, after all, is one of the reasons for having the capture-committed concept. In particular, the best capture option for the plant may well change due, for example, to an unforeseen breakthrough in one of the capture technologies under development. A better storage opportunity also may be found.
In addition to specifying a clear technical path to CCS, the capture-committed plant would acquire the necessary permits to operate the original plant without CCS, as well as the permits and rights for CO 2 transport, injection and storage. This means acquiring at least options for the right to store CO 2 from the owner of the subsurface rights involved, as well as options on the rights-of-way of any pipelines. If required, this provision should be drafted in such a way that it does not lead