Sober Thoughts About CCS for Retrofit or New Fossil Plants as a CO 2 Mitigation Measure from Theresa Pugh Director, Environmental Services American Public Power Association EPA GHG Mitigation Measures Workshop Research Triangle Park, NC November 3, 2009

APPA represents the interests of the 2,010 municipal or public power utilities, which provide electricity to residential, institutional, commercial and industrial customers. Created in 1940 as a non-profit, non-partisan organization. APPA’s purpose is to advance the public policy interests of its utility members and their consumers, and to provide member services to ensure adequate, reliable electricity at a reasonable price with the proper protection of the environment. Public Power provides electricity for approximately 45 million Americans. Public power utilities are in small, medium and large communities in 49 states (all but Hawaii). Seventy percent of public power systems are located in cities with populations of 10,000 or less. Overall, public power accounts for about 16 percent of all kilowatt- hour sales to consumers. More than 90% of APPA member utilities meet the definition and qualify under Small Business Regulatory Enforcement and Fairness Act of 1996 (SBREFA). Over half of APPA‘s members in the electricity sector burn coal, particularly in the Midwestern and Southeastern parts of the country. 2 Background on the American Public Power Association

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4 Public Power Generation (MWH) by Energy Source – 2007 Source: Ventyx (formerly Energy Velocity) Database

Most Favorable Locations – Deep Saline Aquifers – Proximity to CO 2 pipelines – No or extremely low Seismic Potential – Proximity to Transmission – Proximity to Rail for Coal Transportation Least Favorable Locations – Moderate or High levels of Seismic Potential – Unfavorable geology – Lack of Transmission and/or rail for coal transportation 5 Assessing Preliminary Guesses for Most & Least Favorable Locations for CCS

Deep Saline Aquifer Locations 6

Deep Saline Aquifer Locations & ‘Lenient’ Seismic 7

Deep Saline Aquifer Locations & ‘Stringent’ Seismic 8

Saline Aquifers, CO 2 Pipelines, & ‘Lenient’ Seismic 9

Other Considerations – Transmission Lines 10

Other Considerations – Railroads 11

Optimal Sites – Using Existing CO 2 Pipelines 12

Optimal Sites – Not Requiring Proximity to CO 2 Pipelines 13

Natural Gas Pipelines 14 In case Fuel Switching to Natural Gas is the GHG Mitigation – see States with Interstate Pipeline Shortage

15 Natural Gas Storage

States with UIC Primacy: CO 2 Injection Most Likely Under SDWA Source: 16

“Best Guess” Timeline for Baseload (<600 MW) CCS Plant in Non-EOR/EGR States 17

Subsurface space required for only 40% of the Carbon Dioxide from a 300 MW power plant for one year: 2,750 Acres Source: J. Gledhill, Policy Navigation for APPA 18

Subsurface space required to sequester 40% of the Carbon Dioxide from approximately Nine 500 MW Plants over their 40-year lifetime: 2,580 square miles Roughly 1.5 times the size of Rhode Island Roughly half the size of Connecticut 19

2009 EPRI Prism analysis assumptions: – 90% CO 2 capture for all new coal and natural gas combined-cycle plants built after 2020 – CCS retrofit for 60 gigawatts of existing coal generation at 90% capture efficiency For Retrofit of 60 90% capture efficiency: – Approximately 77,400 square miles of subsurface space – Roughly the size of Nebraska or – Roughly twice the size of Maine PLUS area for 90% capture for all new fossil plants built after This is highly dependent upon geology or access to CO 2 pipelines – all geology cannot promise sequestration for 50 years continuously 20 EPRI “Prism” Analysis OR

Parasitic Energy Losses Capital Requirements for Older Plants Pipelines Dealing with Financing older plants Lucky Location? Lucky Geology Proximity to USDW (drinking water source) and protective regulations 21 Retrofit of Existing Fossil Plants: How Realistic?

22 Dealing with approx. 30% Parasitic Energy Losses When Designing New Plants or Retrofitting Old Plants Source: Adapted from L.D. Carter, White Paper, "Retrofitting Carbon Capture Systems on Existing Coal-fired Power Plants," November 2007 Parasitic Energy Loss refers to power lost from existing plant to administer the technologies related to CCS which are circled in the above diagram

23 Source of Map: NatCarb Atlas; Overlay: APPA Optimal Location Criteria Maps without CO 2 pipelines Note: Optimal Locations are for new plants, not retrofit of existing power plants Existing Fossil Generation & Optimal CCS Locations Without Any Drinking Water Resource Location Analysis

Available at Marianne Horinko, "Carbon Capture and Sequestration Legal and Environmental Challenges Ahead," August 2007 L.D. Carter, "Carbon Capture and Storage From Coal-based Power Plants: A White Paper on Technology for the American Public Power Association (APPA)," May 2007 L.D. Carter, "Retrofitting Carbon Capture Systems on Existing Coal-fired Power Plants," November 2007 Jonathan Gledhill, Policy Navigation Group; James Rollins, Policy Navigation Group; Theresa Pugh, APPA, White Paper, "Will Water Issues/Regulatory Capacity Allow or Prevent Geologic Sequestration for New Power Plants? A Review of the Underground Injection Control Program and Carbon Capture and Storage," November 2007 Carbon Capture and Storage: Analysis of Potential Liabilities Associated with Groundwater Contamination Due to Geological Sequestration Operations, September 10, 2008 Prepared by Fredric P. Andes and Kari A. Evans, members of the Barnes & Thornburg LLP Water Team, for the American Public Power Association (APPA) Timothy Gablehouse, White Paper, "Geologic CO2 Issue Spotting and Analysis" July APPA’s White Papers on CCS

Link to APPA’s White Papers on CCS: For More Information, Contact: Theresa Pugh Director, Environmental Services For Questions on CCS Maps, Contact: J.P. Blackford Environmental Services Engineer APPA’s CCS Information & Contacts 25