What is the ‘best available control technology’ for CO2 from coal plants? 11

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1. 

   Russ Posted 3:24 am
   19 Feb 2009

   BACT/MACTI'm mostly familiar with this from mercury emissions policy.
   Here's an example of the Bush admin's assaults upon it (from a newsletter I used to get,
   
   BushGreenWatch.org, which was hyper-informative about all sorts of stuff):
   The "delisting rule" rescinded a 2000 EPA finding that "it is necessary and appropriate" for all power plants to install "maximum achievable control technology" (MACT) to reduce mercury and other hazardous emissions. A MACT standard under the existing Clean Air Act would have required power plants to reduce their mercury emissions by about 90 percent by 2008, a decade earlier than the administration's timetable.
   So here the maximum/best technology was available, they just didn't want to pay for it.
   As for what's basically an all-or-nothing control tech situation like we currently have with coal plants and carbon, I guess that's unprecedented.
   I take it the CAA doesn't have language regarding this eventuality? I'm surprised the enemies of encompassing CO2 within CAA purview didn't bring that up. (Or at least they didn't so far as I heard.)
   On the one hand, it seems logical that "best available" means if nothing is available, nothing applies, and they could continue with BAU.
   But the SCOTUS ruling doesn't make much sense that way*. You will the end, you will the means.
   So from that point of view, a "control technology" could include shutting them down completely.
   Or, it could mean they have to deploy CCS with all deliberate speed, which of course they can't/won't do, in which case they'd be derelict, and subject to being shut down.
   [*To be honest, little the Supreme Court does nowadays makes sense. You have 8 judges with more or less coherent ideologies, and this loose cannon Kennedy who seems to be capable of voting anywhichway for any reason or none.
   (It's almost as bad as the fate of the world now lying in the hands of two Republicans from Maine, while everybody else can apparently go home.)
   Kennedy's CO2 decision as well was hardly a model of tight, clear reasoning and direction. Still, I'm glad we have it, even if it left questions like this unanswered.]    

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2. 

   Tom Laskawy Posted 3:51 am
   19 Feb 2009

   Joe Romm has an answer...As you might expect. In a post back in November when the EAB first ruled on carbon, Joe made this list of potential BACTs for new coal plants:
       * Co-firing with biomass -- up to 25% cofiring has been demonstrated
   
       * Highest efficiency plants
   
       * Cogeneration (i.e. recycled energy)
   
       * (possibly even) Gasification with, yes, carbon capture and storage (CCS)
   It's hard to see the EPA yet requiring CCS since you can't make a good argument that it's truly "available" (although I guess it all depends on what you think "available" means).  Still, the top three items alone would probably make new coal plants unattractive to utilities - coal would suddenly be <gasp!> expensive.
   Joe also posted here at Grist about this idea to use solar thermal as a BACT for existing coal plants...
   Also, keep in mind that this BACT we're talking about would be for new coal plants - existing plants would only qualify, as I understand it, under New Source Review.  And we've learned that utilities respond to NSR by avoiding any improvements at existing plants.
   My gut tells me that writing carbon BACT regs will take long enough that they get rolled into a bigger climate plan.

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3. 

   Gar Lipow Posted 3:52 am
   19 Feb 2009

   Worries me tooThinking like a coal company shill for a moment:
   Some means of burning coal are cleaner than others. For example, a typical coal plant runs at 45% efficiency, but I know of some that run at 55% efficiency. And then I could use the waste heat from that for an industrial process and end up with a 70% overall efficiency. And I could argue that is Best Available Technology. And it would better than a typical coal plant - just not enough better. And neither you nor I would be happy with that. But if you wanted to bet on how a court would rule if this issue came up, I'll bet no good lawyer would take either end of that bet if she had to offer five to one odds.

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4. 

   GreyFlcn Posted 3:55 am
   19 Feb 2009

   Should be interestingTo see coal advocates turning around and saying "OMG COAL CCS DOESN'T EXIST!"
   
   -David Ahlport

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5. 

   Ted Nace Posted 4:56 am
   19 Feb 2009

   BingoDavid - The BACT or MACT approaches are very problematic for the reasons you have identified.  If you read the proposed EPA carbon dioxide measures for EXISTING plants, they talk about milquetoast measures for running plants slightly more efficiently. That's because there's nothing else, unless you want to consider retrofits like adding thermal solar pre-heaters, etc. A possible approach would be to have a CO2/kWh ceiling applied for the utility level as a whole, and then make this ceiling decline over time. A simpler approach is simply to declare that coal plants must be retired at age 40 or 45. Yet another approach is to define some CO2/kWh ceiling that causes the most inefficient old plants to be retired as of a certain date. One other problem with all this is that adding scrubbers makes CO2 emissions worse, so complying with one set of Clean Air Act requirements could be contradictory with complying with any potential carbon restrictions. Of course, DOE continues to pursue research into retrofit approaches, but I don't think anybody expects these to be economically viable.
   
   Help build CoalSwarm -- a shared informational resource on coal and alternatives to coal.

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6. 

   Pompey Road Posted 5:24 am
   19 Feb 2009

   Massey or Gassy:T.Boone want NatGas for Transportation, Power Generations wants it to meet the co2 standard.
   Yes it looks as if the residential gas customer is going to get run off heating,cooking and heating water with NatGas. Then when all of these customers pile onto the grid you will have another major increase in demand and another set of problems to deal with.
   You can still lay this at the feet of the coal industry, had thirty years to gasify coal and walked away from a hundred projects trying to do it. They could have funded some of these projects they walked away from 20 years ago.
   They will spend thousands to run clean coal ads, while they do MTR to get their cost down to $4.00 a ton instead of paying the $20.00 a ton it takes to underground mine.
   No they will not buy a scrubber or do CCS unless you create the legislation that makes them if they can pay a lobbyist to undermine the Surface Mine and Reclamation Act and EPA
   
   The eons of time and nature was good to us down here. It was not until we become civilized that destroying our habitat become fathomable or fashionable.

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7. 

   Pangolin Posted 6:31 am
   19 Feb 2009

   ConservationThe BACT for coal fired power plants is to eliminate the need for their electricity. Take a coal plant find the nearest end user and apply ALL effective conservation techniques. Then go next door and do it again times the 200 million homes offices and workplaces in the US.
   The best way to do conservation is to convert whole areas at once. Park the trucks with the parts in the neighborhood and bring in the crews on buses. Since neighborhoods tend to have the same construction details from one house to the next this simplifies the whole process. Anybody who doesn't want their home or business converted to energy efficient alternatives can disconnect from the grid and natural gas lines.
   If we did this we'd be closing coal plants instead of trying to repair, retrofit or convert them. If would also provide 10x the economic stimulus of the current stimulus bill.
   
   Put the Carbon Back

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8. 

   Gar Lipow Posted 6:39 am
   19 Feb 2009

   Eliminating coal is the goalAt least our goal, don't know about Jackson. As, of course, part of the broader goal of eliminating emissions. But the EPA has only certain powers until new legislation is passed.
   The speculation here is not about the best answers (I think when it comes to coal agreement is pretty broad.) The speculation is about what loopholes will be available to the coal industry  under various plausible sets of regulations that could be passed without new legislation.

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9. 

   ids Posted 10:35 am
   19 Feb 2009

   geez usdeclare coal a valuable natural resource that must be conserved and EPA regulated & you'll have your stupid cogeneration, isn't that the goal?  

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10. 

    Gar Lipow Posted 7:49 am
    24 Feb 2009

    NO cogeneration is not the coalStopping the burning of coal is the goal.

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11. 

    Bmogan Posted 1:24 pm
    22 Oct 2009

    Best Avaialable Control Technology (BACT) simply means the best AVAILABLE control technology. "Available" means that the control scenario has been put into commercial use on a "similar" emission unit. If the control scenario is a prototype or is in use at a research lab, then it is not considered available.
    
    If there are, infact, no available control devices for controlling CO2 from a coal power plant, then the BACT would be "No Controls" and the coal power plant could go on about its business. If there are some really expensive control devices that have been put into commercial use on similar units (i.e., wood fired electrical generating facility), then you would have to consider these units in your BACT Analysis.
    
    After preparing a list of potentially applicable control technologies which are not technically infeasible, you must consider environmental, energy, and economic impacts associated with use of each control scenario. If a control device is "horribly expensive" then it will probably wind up being considered "economically infeasible", depending on how good of a job the person did preparing the BACT Analysis. If you can rule out all controls for economic, energy, or environmental reason, then you are not required to install any control device...or better put, "no controls" is considered BACT.
    
    As far as CO2 control devices..."carbon sequestration" refers to a number of processes which remove carbon (CO2). One would be a chemical scrubber, which is a widely used technology at coal fired power plants to control SOx.
    
    Check out BACTAnalysis.com for more info on BACT Analysis and applicable regulations.

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