Comment period is open for the EPA proposed rule that would require CCS, carbon capture and storage.

The Environmental Protection Agency (EPA) proposed rule, "Standards of Performance for Greenhouse Gas Emissions for New Stationary Sources: Electric Utility Generating Units," is open for comment until March 10.

This rule would amend the new source performance standards (NSPS) for electric generating units (EGUs) and will establish the first NSPS for greenhouse gas (GHG) emissions. The rule will establish CO2 emission standards for certain new and reconstructed fossil fuel-fired electric generating units. Rules for existing sources can only be implemented after finalization of new-source rules.

You may comment on any element of this regulation and/or EPA’s lengthy justification, but the requirement for geologic storage of the captured CO2 or its use in enhanced oil recovery (EOR) may be of special interest to some AAPG members.

See http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2013-0495-0001, for the full notice in the January 8, 2014, Federal Register, including the supplementary material that discusses geologic storage and enhanced oil recovery.

With regard to geologic storage and EOR, EPA states:

• “This action proposes a standard of performance for utility boilers and IGCC units based on partial implementation of carbon capture and storage (CCS) as the BSER.” BSER is “best system of emission reduction."
• The Federal Register notice also states, “The EPA believes the cost of “full capture” CCS without EOR is outside the range of costs that companies are considering for comparable generation and therefore should not be considered BSER for CO 2 emissions for coal-fired power plants.”

Comments are due by March 10, 2014. Submit comments using one of the following methods:

• Submit comments at www.regulations.gov under Docket ID: EPA-HQ-OAR-2013-0495.
• E-mail: Comments may be sent by electronic mail (e-mail) to .
• Fax: Fax your comments to: 202-566-9744.
• Mail: Send your comments to: Air and Radiation Docket and Information Center, Environmental Protection Agency, Mail Code: 2822T, 1200 Pennsylvania Ave., NW, Washington, DC, 20460.

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