by Rud Istvan
Many climate policy debates come down to coal as an electricity fuel, including the EPA’s proposed coal power plant CO2 regulations.
This post focuses on issues surrounding new coal plants. Those just proposed for existing plants are also controversial and legally dubious, but for different reasons.
Coal has been burned as fuel for a long time. One of the earliest known references is by the Greek Theophrastus: 
“Among the materials that are dug because they are useful, those known as anthrakes [coals] are made of earth, and, once set on fire, they burn like charcoal. They are found in Liguria … and in Elis as one approaches Olympia by the mountain road; and they are used by those who work in metals.”
Romans were exploiting coal in Britain by the second century AD. Marco Polo described 13th century Chinese coal use as “black stones which burn like logs”. Coal took off as the primary fuel of the industrial revolution with the development of steam engines. And industrializing London found in the 19th century that burning coal horribly smogged its air and blackened its buildings.
Burning coal is inherently ‘dirty’. During the Carboniferous era  when most coal formed, woody plant matter got buried in acidic swamps and peat bogs. The low pH from initial decomposition protected the remaining organic matter from further decomposition. It also released hydrogen sulfide (swamp gas) that leached metals into the muck that became coal. So coal inherently contains varying degrees of ash (silica and carbonate), pyrite (iron sulfide), arsenic, mercury, and other impurities.
If nothing is done about the impurities, burning coal to make electricity and steel remains a dirty business. China’s Beijing and India’s Dehli readily prove that today. This is a big global problem, since China has been the world’s largest coal consumer for decades. As domestic coal consumption in the US declines thanks to natural gas, US coal exports to China are rising and expected to double. It is low sulfur ‘clean coal’ from Wyoming, which helps China’s pollution problem.
The original meaning of clean coal was literally to clean it (or to mine cleaner coals from places like Wyoming). Coal can be pulverized and washed to remove some ash and pyrite (the source of SO2 and acid rain) before it is burned. Bag houses and electrostatic precipitators remove residual fly ash, wet scrubbers desulfurize, and activated charcoal removes mercury and arsenic before the (invisible but for scrubber steam condensation) flue gas is discharged. In the US, these methods have steadily reduced coal pollution for decades.
China is getting serious about its notorious air pollution. It is shutting old polluting steel mills. It is building the largest, most efficient ultra super critical (USC) coal generating plants in the world (160 of them, at a rate of about 3 per month through 2016), complete with powdered coal pre-washing plus flue gas scrubbing. The first such complex came fully on line at Yuhuan in 2006-2007. It produces 22 billion kwh/year. Its 4 boilers were built by a joint venture between Mitsubishi Heavy Industries and Harbin Boiler. A Siemens and Shanghai Electric JV built the 4 1000MWe turbine/generator sets. Siemens reports Yuhuan thermal efficiency is a world record 45% (for coal).
The first US USC coal plant came on line February 2013. SWEPCO’s Turk plant in Arkansas produces 600MW from a single unit and cost $1.8 billion, or $3000/MWe (a US capital cost benchmark). Its thermal efficiency is 42% compared to the US installed base average 34%, cutting emissions by a fourth.
Some coals, for example those in the US Midwest, are extremely dirty. They are difficult to sufficiently clean before/after combustion. That led to a different notion of clean coal, pre-combustion gasification. This allows impurities to be physically and chemically separated from the resulting syngas prior to combustion. Since the syngas fires a combined cycle gas turbine (CCGT) unit with about 60% efficiency (compared to USC coal at 42-45%) it cuts fuel costs and net CO2 emissions further (but not nearly as much as burning natural gas). Duke Energy built the world’s first commercial plant at Edwardsport, Indiana.
The intent was to utilize locally abundant, cheap, dirty Indiana coal. The facility came in almost $1billion over budget, $3.5 billion for a single 618MW CCGT or $5660/MWe. It came on line June 2013. It causes Indiana consumers to pay about 19% more for (blended rate) electricity than if the CCGT had simply been natural gas fired. But Indiana preserved an estimated 170 coal mining jobs.
CO2 itself is now (erroneously) deemed a pollutant. That has given rise to yet another notion about ‘clean coal’, near zero emissions using carbon capture and sequestration (CCS).
Southern Companies was persuaded to build the world’s first such ‘clean coal’ plant in Kemper, Mississippi. It relied on $700 million of federal subsidies. It would source dirty but locally abundant and very cheap ($10/ton) lignite (the lowest rank ‘brown’ coal), clean it through syngasification like Edwardsport, and then after CCGT combustion use carbon capture to sequester some of the exhaust CO2 ‘pollutant’ in depleted Louisiana gas fields.
“It’s a transformative project,” said John Thompson, a director of the Clean Air Task Force, a Boston-based environmental group.
It has not turned out well. WaPo just pointed out this transformative project cost $5.5 billion for 582 MW, or $9450/MWe! It is $2.5 billion over budget and a year late. Southern Companies has already written off $1.2 billion. And the Sierra Club is still trying to block it — only capturing 65% of CO2 is not ‘clean’ enough.
If one really means this kind of ‘clean coal’, better not to burn it at all. The only zero emission dispatchable base load option (other than hydro) is nuclear. (Wind and solar are intermittent.) Southern Companies is also building the first new US nuclear reactors in 30 years, and is receiving no federal subsidies for them. Vogtle 3 and 4 are safe(r) gen 3 Westinghouse AP1000 designs providing 2200MWe at a cost of $10.5 billion. That is $4772 per megawatt, half of Kemper and 85% of Edwardsport. But it still costs 60% more than Turk or what the Chinese are building (although most future fuel costs are avoided).
The EPA cannot legally impose emission standards on new coal generating plants unless there are reasonable means to achieve them. CAA §111, 42 USC 7411, Standards of performance for new stationary sources, requires that any standard be based on “adequately demonstrated” technology. The tests for “adequately demonstrated” include feasibility and cost. Courts have generally held that technically feasible means ‘commercially available’, and that cost cannot be “unreasonable or exorbitant”.  Kemper was technically feasible only because close to depleted Louisiana gas fields (most coal generating stations are not). But it has very publicly failed on cost. The EPA specifically used Kemper to support its proposed rule.
And so the Texas Clean Energy Project (TCEP) arose. It is also a coal syngasification, CCGT generation, CCS facility. Estimated cost is now $3.5 billion (up from an original $2.5 billion), $8750/MWe. It relies on a $450 million federal grant plus $637 million in investment tax credits. It is only 400MW, but would supposedly capture 90% of CO2 combustion gas. It would sell the CO2 for enhanced (tertiary) oil recovery in nearby Permian Basin oil fields. TCEP isn’t going well either. On 1/13/14, contracted electricity buyer CPS Energy (a San Antonio utility) pulled out citing the much lower capital cost of natural gas fired CCGT ($800-1300/MWe). In May TCEP requested yet another years extension for ‘re-evaluation’ before construction. A massively subsidized un-built plant without a utility customer is what the EPA now principally relies on to justify its proposed ‘clean coal’ rule. The administration is in effect ‘buying’ justification.
Non-US CCS projects have not gone well either. Norway promised a demonstration project in Mongstad. It would have taken CO2 from a small 280MW CCGT gas fired facility and inject it into depleted Norwegian North Sea oil and gas fields. It was ‘only’ going to cost $1.3 billion ($220 million over original budget), or $4640/MWe. On 9/20/13 a new Norwegian government announced it was halting the project previously described as Norway’s AGW ‘moon landing’. Mongstad turned out to be another CCS crash landing.
Swedish utility Vattenfall received $63 million in EU subsidies for a CCS pilot program at a conventional coal fired plant at Jänschwalde, Germany. It was scheduled to come on line in 2011, but was postponed to 2016. On May 4, 2014, Vattenfall announced it was writing off 10 years worth of CCS research, cancelling Jänschwalde, and keeping the EU subsidy.
In the UK, DRAX proposed a medium sized ‘White Rose’ plant experiment (450MW CCGT gas fired with CCS) projected to cost £2 billion, or $7300/MWe. This made UK political sense, since £1 billion was to come from EU subsidies. Engineering delays caused the EU to waffle, so the UK announced it would provide £40 million for 18 months of further engineering feasibility studies, but not £1 billion of co-‘investment’. It appears White Rose is dead, but not yet buried.
There aren’t any ‘clean coal’ CCS projects anywhere for the EPA to rely on as required by 42 USC 7411. CCS is not commercially viable, even if there happens to be a handy depleted oil or gas field nearby. Yet the EPA’s proposed limits on new coal plant CO2 emissions mean no modern USC coal plants could be built without CCS. The EPA intent is to ban them using these extra legal means. Proof is in the EPA’s own regulatory impact analysis, which says there is no impact since no coal CCS plants will be built!  ‘Clean coal’ is a stark example of the increasingly distorted politicization of ‘climate policy’. The Chinese supposedly have an appropriate curse for their US coal supplier: May you live in interesting times. The Obama administration has certainly created interesting times. The US climate ‘legal wars’ are only beginning.
 Theophrastus, On Stones (16), from Massie and Keyser, Greek Science of the Hellenistic Era, p. 228. ISBN 0-415-23847-1
 It lasted from ≈360mya to ≈300mya, beginning with evolution of lignin in plants (e.g. bark bearing trees), ending with evolution of lignin digesting fungi. Floudas et. al., Origins of Enzymatic Lignin Decomposition…, Science 336: 6089 ff (2012)
 This is legally possible because of a poorly drafted CAA definition in 42 USC 7602. Until Congress fixes the statute, the courts have upheld the EPA’s right to do so under it. See Massachusetts v. EPA, SCOTUS 2007
 Drajen, Bloomberg BusinessWeek, 9/19/13
 Sierra Club v. Costle, 657 F.2d 298, 383 (1981)
 The RIA is available at www2.epa.gov/sites/production/files/2013-09/documents/20130920proposalria.pdf
JC notes: Rud sent this post via email, I suggested some minor edits. Previous Climate Etc. posts on coal:
As with all guest posts, please keep your comments relevant and civil.