POWER February 2023 - 35

CARBON CAPTURE
The deployment goal for carbon capture
infrastructure is to be net-zero by
2050-just 27 years from now. Hopefully,
we have the bench strength of
engineers, scientists, and other professionals
needed to design and build
enough infrastructure to meet this goal.
Ownership
Who is installing carbon capture and
why?
Cole: From our vantage point, it has
primarily been owners of existing fossil
fuel-fired power generation facilities-
such as gas-fired combustion turbines
and coal-fired boiler steam generating.
The main driver has been the potential
sale of the CO2 and, more recently, tax
credits for CO2 removal. At $85/ton of
CO2 (or even $65/ton for EOR), combined
with the sale of CO2, the economics of
carbon capture is beginning to pan out.
I think this will continue to increase-it
has to if we have any chance at net-zero
by 2050.
Steven Babler: We have also seen an
influx of developers and venture capital
firms, specifically for installing new gasfired
capacity with carbon capture incorporated.
Developers are also expressing
interest in using the Allam cycle as an
alternative to the traditional combined
cycle, with carbon capture added at the
end to clean up the stack. This would be
particularly suitable for places like Illinois,
which passed the Climate and Equitable
Jobs Act (CEJA) in 2021. This legislation
requires phasing in zero-carbon electric
production between 2030 and 2045.
The Allam cycle is theoretically zero-CO2
emission, whereas, well-designed, traditional
amine scrubbing can achieve 95%
and possibly 99%-but that would not
satisfy the new Illinois law after 2045.
What issues are owners seeing?
Cole: The big issue is risk, in terms
of reliability. Theoretically, an owner will
make money based on the IRA tax credit
and obtaining a reasonable sale price of
CO2. The IRA has essentially removed
the economic barrier. Industry participants
indicate that the $85/ton tax credit
is a solid number on which to base the
economics.
However, the risk is whether the carbon
capture system will operate as designed
and promised, in terms of CO2 reduction
percentage and operating costs. Because
the economics are based on a very high
reduction assumption (in excess of 95%),
anything less than that means a significant
reduction in CO2 tons removed for tax
credit and for sale. Furthermore, generatFebruary
2023 | POWER
ing income from CO2 reduction and sale
depends on generating units operating under
dispatch from the independent system
operator (ISO) based on power production
cost. If the operating cost is too high, the
generator will not run-and the CO2 reduction
and sale doesn't happen. There are a
lot of moving parts an owner must consider
when investing in carbon capture.
Tom Rolfson: Another risk to owners,
developers, and investors is the
uncertainty of future. Through the years,
regulations come and go as political
winds blow. However, there is great momentum
behind decarbonization-and it
seems unlikely that the demand for carbon
reduction or its funding will dwindle
away. The CEJA legislation in Illinois,
mentioned earlier by Steven, indicates
that states are serious about this.
Permitting
Is permitting an issue with carbon capture
and sequestration?
Rolfson: Two issues are worth mentioning
here. First, although the currently
proposed amine scrubber technology is
already used and understood in the petrochemical
industry, it will be new to the
electric power industry. It's basically adding
a petrochemical plant to your power
plant-which means adding chemicals
such as solvents to the plant inventory,
which then impacts various Emergency
Planning and Community Right-to-Know
Act (EPCRA) reporting requirements like
the Toxic Release Inventory (TRI) reporting
requirements. New chemicals and oils
will also impact the site spill prevention
plan and stormwater discharge permits.
Second, the installed carbon capture
equipment is large-surprisingly large. It
will likely impact atmospheric dispersion
conditions from the existing and new
exhaust stacks and, as a result, permitting
authorities will likely require dispersion
modeling to prove that the non-CO2
emissions-NOx, SOx, CO, and particulate-will
be acceptable. This takes additional
time for preconstruction permitting
and adds uncertainty to projects.
Babler: Although motivated by significant
CO2 reductions (and resulting tax
incentives and revenue stream), there is
a potential for triggering new permitting
requirements. The biggest issue is adding
numerous compliance requirements. As
equipment is installed and transitioned,
the source must continue complying with
their existing permits. They will also need
to modify permits to account for new
emission points (air and water discharge)
and/or changes to the emission rates of
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existing sources. When adding and modifying
equipment, the concern is triggering
new requirements as a " modification, "
which means new dispersion modeling,
control technology, and purchase of offsets.
Changes of permit modifications
must be carefully examined, so that strategic
assumptions and operating restrictions
can be developed that limit the triggering
of new regulatory requirements.
What about transportation of the
captured CO2
and
sequestration?
Wouldn't that require permitting?
Rolfson: Typically, the captured CO2 is
either compressed and transported to a
market through a pipeline; injected into
the ground for EOR; or is further compressed
to a much higher pressure and
injected into a permanent sequestration
underground storage. In all three scenarios,
we are only dealing with CO2 and
not other regulated pollutants; therefore,
air permitting is not an issue (unless gas
turbines or reciprocating engines are installed
for compression).
Where permitting can become an issue
is the siting, routing, approvals, construction,
and operation of the pipeline system
and sequestration. As with any linear facility,
this involves land acquisition, environmental
studies, mitigation measures, and
agency approvals. It can also trigger the
National Environmental Policy Act (NEPA)
process and a years-long Environmental
Impact Statement. The recent rise of environmental
justice as an additional consideration
will also play a role-especially
in the appropriate siting of infrastructure.
This may also be the case with sequestration
with underground injection.
What is the future of carbon capture?
Will environmental and permitting issues
obstruct the progress of this key
strategy for national decarbonization?
Rolfson: The future is bright! The key
to any infrastructure development is considering
environmental impacts in the feasibility
stage and then designing features
that minimize impacts (instead of adding
them) during the permitting phase.
We should also carefully consider environmental
justice in the siting process.
With proper site selection, the required
infrastructure should be permittable and
approvable-especially when considering
the significant environmental benefit
of CO2 reduction. We all know it needs to
happen-so if we will all share the commitment
to carbon capture, we will also
share the invaluable benefits. ■
-Brian Petermann, PE is senior air
quality project manager with
POWER Engineers.
35
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POWER February 2023

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