“GHG Compliance Strategies, Reduction Technologies and Measurement” was the Hot Topic Hour on July 25, 2013

During the Hot Topic session yesterday, all four speakers discussed greenhouse gas (GHG) regulations being developed by the U.S. EPA for the electric power industry. GHG emissions standards for new units were proposed by EPA in April 2012, suggesting a standard of 1,000 lb CO₂  per MWh. The four speakers agreed that a revised proposal to be issued in September is likely to contain separate standards for gas and coal-fired units, with the limit for coal-fired units being raised to somewhere between 1,100 and 1,700 lb/MWh. A proposed rule regulating GHG emissions from existing units is expected next Spring.

Dr. James (Jim) E. Staudt PhD, President of Andover Technology Partners, reviewed the status of GHG regulations in the U.S. He also reviewed various technologies for mitigating GHG emissions in the power and cement sectors. According to his analysis, a new coal-fired power plant with carbon capture and storage (CCS) would cost at least $5,000/kW. A decision regarding whether to build a new coal-fired or a new gas-fired power plant will depend on the relative cost of coal vs. natural gas and the “cost” of CO₂.  A price of at least $25/ton for CO₂ emissions will be necessary in order to economically justify a new coal-fired power plant. With respect to cement kilns, Dr. Staudt said that the clear trend is to retire old long kilns in favor of more efficient pre-calciner and pre-heater kilns.

Andrew D. Shroads, QEP, Regional Director for Sanford Cohen & Associates (SC&A, Inc.), pointed out that EPA’s proposed GHG standards for new power plants include a 30-year averaging option. This long term option is a clear sign that EPA is attempting to adopt an emissions standard years before a corresponding mitigation technology is expected to be available. Mr. Shroads also discussed Obama’s Climate Action Plan and his follow up memorandum to EPA outlining deadlines for greenhouse gas regulations:

§  September 20, 2013:  Issue revised proposal for new EGUs, to be finalized in a “timely fashion.”

§  June 1, 2014:  Issue proposed rule for existing EGUs.

§  June 1, 2015:  Finalize rule for existing EGUs.

§  June 30, 2016:  States required to submit State Implementation Plans (SIPs).  

Mr. Shroads also noted that the regulation of GHG emissions will greatly expand the scope of units at a power plant which could become subject to Title V permitting.

Roger Martella, a partner in the Environmental Practice Group at Sidley Austin LLP, emphasized that even though very few new power plants are being built, the New Source Performance Standards will have a significant impact on subsequent standards for existing units, as well as future standards for other industries such as Portland cement and petroleum refineries.  He also pointed out that June 2016 will be an important date – that is when states will be required to submit SIPs. It also falls just before the 2016 presidential election and the end of Obama’s second term in office.

Michael Obeiter, Senior Associate at the World Resources Institute (WRI), discussed four near-term opportunities for reducing greenhouse gas emissions: reducing power plant emissions, HFC emissions, and methane emissions from natural gas systems, and developing energy efficiency standards (e.g., for appliances). With respect to natural gas-fired systems he referred to a recent WRI report comparing the GHG impacts of natural gas versus coal. In essence, the report concludes that a methane leakage rate of 3½ percent or more puts natural gas on roughly equal footing with coal. Based on his review of numerous studies, Mr. Obeiter believes that the average methane leakage rate is currently around two to three percent. Mr. Obeiter also referred to a recent report issued by WRI entitled “Can the U.S. Get There from Here?” which concludes that that the U.S. could meet its commitment to reduce emissions 17 percent below 2005 levels by 2020 without new federal legislation, but that Congressional action will be required to go beyond that, towards the goal of reducing emissions 80 percent below 2005 levels by 2050.

Bios, Abstracts and Photos can be seen at: BIOS, ABSTRACTS, PHOTOS - 7-25-13.htm

The individual presentations are as follows: 

• GHG Compliance Strategies, Reduction Technologies and Measurement - Hot Topic Hour July 25, 2013  (Webinar Recording  Dated:  7/25/2013)

• Greenhouse Gas Mitigation from the Power and Portland Cement Sectors by James E. Staudt, Andover Technology Partners - Hot Topic Hour July 25, 2013  (Presentation  Dated:  7/25/2013)
• President Obama's National Climate Action Plan by Michael Obeiter, World Resources Institute - Hot Topic Hour July 25, 2013  (Presentation  Dated:  7/25/2013)
• Greenhouse Gas Limits on New Electric Generating Facilities: First Strike by Andrew D. Shroads, Sanford Cohen and Associates - Hot Topic Hour July 25, 2013  (Presentation  Dated:  7/25/2013)
• Implementing Pres. Obama's Climate Action Plan: Process, Framework, and Impacts by Roger Martella, Sidley Austin LLP - Hot Topic Hour July 25, 2013  (Presentation  Dated:  7/25/2013)