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fired power plants other than those granted exemptions. Whether carbon
capture and storage (CCS) technology has been adequately demonstrated is
one question they raise. Other questions involve whether the cost of
compliance, assuming CCS is available, and the increased energy required to
capture and store carbon should lead the Administrator to propose a less
stringent standard. Whether the agency should have proposed separate
standards for gas-fired and coal-fired units, and whether the proposed standard
is barred by statutory language that prohibits the Administrator from requiring
the installation and operation of any particular emission reduction system are
other issues. These questions and perhaps others may be addressed when EPA
re-proposes the GHG standard pursuant to the President's directive.
Has CCS Been Adequately Demonstrated?
EPA maintains that the components of CCS technology have been
demonstrated on numerous facilities. According to the agency, ―... at present,
CCS is technologically feasible for implementation at new coal-fired power
plants and its core components (CO 2 capture, compression, transportation, and
storage) have already been implemented at commercial scale.‖ 20 Specifically,
in its Federal Register notice proposing the standard, the agency said:
Capture of CO 2 from industrial gas streams has occurred since the
1930s using a variety of approaches to separate CO 2 from other gases.
Carbon dioxide has been transported via pipelines in the U.S. for
nearly 40 years. Approximately 50 million metric tons of CO 2 are
transported each year through 3,600 miles of pipelines. Moreover, a
review of the 500 largest CO 2 point sources in the United States shows
that 95% are within 50 miles of a possible geologic sequestration site,
which would lower transportation costs.
With respect to carbon sequestration/storage, there are at least four
commercial integrated CCS facilities sequestering CO 2 into deep
geologic formations and applying a suite of technologies to monitor
and verify that the CO 2 remains sequestered. 21
Critics of the agency maintain that even if the components have been
demonstrated, there is no plant that captures and stores CO 2 on the scale of a
large coal-fired power plant. There are several large power plants currently
under development that will demonstrate CCS at commercial scale when
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