Atomic Show #222 – How Proposed EPA Clean Power Plan Rewards States for Replacing Nuclear With Gas
On August 20, 2014, Remy DeVoe, a graduate student in nuclear engineering at the University of Tennessee, published an earthshaking piece on ANS Nuclear Cafe titled Unintended Anti-Nuclear Consequences Lurking in the EPA Clean Power Plan. Unfortunately, there has been a bit of a delayed reaction; so far, only the most carefully tuned instruments have noticed any movement.
In his article, Remy described how he and Justin Knowles, another UT nuclear engineering graduate student, chose to spend part of their summer in the very “nuclear” activity of digging deeply into a mathematical model to find out the basic assumptions underlying its results. The model they chose was the formula that the EPA has described as a “consistent national formula” for calculating each state’s existing CO2 intensity (CO2 mass per MW-hr) — using 2012 data.
Aside: Please forgive my use of the underline format for a phrase that is not a link. Though underlines generally indicate the existence of a link here on Atomic Insights, I wanted to reproduce the phrase exactly as it appears — including text formatting — on EPA Connect: The Official Blog of EPA’s Leadership in a June 4, 2014 blog post by Janet McCabe titled Understanding State Goals under the Clean Power Plan End Aside.
Remy and Justin entered a hypothetical scenario into the model in which each state with nuclear generating stations shut down all of their nuclear plants and replaced their zero emission electricity generation with natural gas fired generation. Remy and Justin uncovered a starting fact. In 15 states the carbon intensity in pounds per MWhr as calculated by the EPA’s spreadsheet model decreased.
That result made no sense to them. They thought that someone had to have made a mistake somewhere in the formulas used in the model that had not been caught by any of the reviews that must have taken place inside the EPA before the rule was issued for comment.
They dug into the spreadsheet and realized that the formula for calculating each state’s initial emission intensity gave every power source except nuclear credit for 100% of its actual generation in 2012, which was the year used for calculating the starting point from which each state’s carbon intensity reduction plan will be required a certain percentage reduction by 2030. For nuclear electricity production, the EPA’s “consistent national formula” applied a factor of .058 to its 2012 generation and then that far smaller number was added to the rest of the state’s 2012 power output to compute the overall carbon intensity.
That means that states with a substantial portion of power being produced by zero emission nuclear energy today have what appears to be a much higher carbon intensity than they actually have. If they close one of their operating nuclear plants, their EPA calculated carbon intensity number increases by a very small number because only 5.8% of the plant’s zero emission output was in that number in the first place. If the state chooses to replace the output of the nuclear plant with natural gas, there is a possibility — dependent on the state’s mix of other plants — that the carbon intensity number will actually decrease from what it was with the nuclear plant running.
Remy and Justin then met with the people who devised the formula and showed them what they had found. Those EPA staff members did not admit an error; they simply explained their methodology and assumptions in creating the model. They encouraged the pair to provide a comment to the proposed rule and said it would be considered during the process of finalizing the rule.
As young graduate students studying hard to become professionals in a field where integrity is highly valued and reinforced, Remy and Justin have graciously projected their personal honesty onto the EPA decision makers and believe that the formula was the result of an inadvertent misunderstanding that has “unintended” consequences.
I’m a little more experienced in the ways of Washington staffs and quite a bit more skeptical about the actions taken under the cover of pleasant sounding phrases. There is only a small chance that the formula’s results are unintentional. I suspect that it was created with the conscious goal of minimizing the CO2 benefits of nuclear energy.
During my 33-year career as a US naval officer, I learned to trust, but verify, and to stop trusting the work of anyone who would not admit an error, especially when confronted with proof.
Here are links to the spreadsheets documenting Remy”s and Justin’s analytical work.
State Goal Data Calculations:
https://docs.google.com/spreadsheets/d/1CAdDiE3beafN6sU0_iiw0gdGOHWbTC7OavHGrpdDp2A/edit?usp=sharing_eid
Plant Level Data Calculations:
https://docs.google.com/spreadsheets/d/1k2MSzvGbQDRAVeISPuX1rZczBxSc1UiH0lmWqQYOy2s/edit?usp=sharing_eid
These documents can be edited so you can view the equations. The pair has requested feedback.
It is possible that the person who made the decision to bury the policy choice deep inside of a spreadsheet is not in an executive leadership position, but it is unlikely that a lowly analyst made the decision without managerial or executive acceptance that it was the right thing to do.
If the economic performance of nuclear energy production in a state is already acceptably competitive, it is unlikely that any plant owner will decide to shut down a plant merely to gain a little credit in the CO2 intensity reduction effort. However, if the economics of the plant are marginal because of temporarily low natural gas prices or other factors, this perverse incentive might be one more factor incentivizing a premature closure decision.
On Tuesday, August 26, I recorded a phone conversation with Remy DeVoe, Justin Knowles and Lane Carasik, who was the leader of the Nuclear Engineering Student Delegation this summer. Please have a listen, get a little angry and take some effective action by producing your own comment.
This is a call to action. Don’t let the EPA get away with imposing this formula. Follow the process provided before October 16, 2014 deadline. This is a high interest proposed rule; there are already more than 1900 comments so attention to this specific issue might require a noticeable volume mentioning the same feature of the formula.
I accept the court decision that the EPA has the authority to regulate CO2 emissions, but that decision did not give the EPA the authority regulate badly. It seems unlikely that a court would support an agency that decided to issue a regulation with a known flaw resulting in the potential for rewarding an increase in the production of a pollutant.
Note: During the show, we briefly discussed the fact that nuclear energy capacity factors in 2012 were in a temporary valley and the lowest in the past 12 years. Here is the capacity factor history graph copied from NEI’s excellent nuclear energy statistics library.
Podcast: Play in new window | Download (Duration: 35:43 — 16.5MB)
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The link to the ‘process provided’ doesn’t work for me.
Even if it did, would a comment to the EPA from outside the US be just ignored?
@Jim Baerg
Based on your question and my testing of the link, I suspect that it is blocked for visitors coming from outside of the US. Generally speaking, our agencies ignore comments received on their rulemakings if they are coming from outside the US. However, if you are an American citizen who is living abroad, there are alternative communications paths available for submitting your comments.
Was it Jim Hansen who said that an environmentalist friend told him “natural gas was the nuclear power killer”. Now we know why. At times like this I wish I could find the precise quote.
Rod, I think existing hydro facilities are also not counted by the EPA in a state’s total energy production, so they may face the same disadvantage as nuclear power plants. (That’s what I gather from my cursory reading of the very turgid EPA documents, anyone else get a different take?)
There is an EVEN GREATER perverse incentive hidden in these proposed regs!
That is, a state gets credit for 100% of nuclear plant capacity that is “under construction” — but as soon as the plant starts operating, it becomes “at risk” for closure, and only 5.8% of its capacity is counted. So opening the plant REDUCES the counted energy generation by 94% of the nuclear nameplate, while the emissions don’t change at all; hence the carbon intensity APPEARS TO INCREASE substantially when the plant opens!
In other words, Georgia, South Carolina, and Tennessee will TAKE AN ENORMOUS HIT if they complete their under-construction nuclear and open the plants!
Essentially, the regs prevent those states from opening the plants … and also prevent them from abandoning construction … leaving the nuclear plants in a state of perpetual construction to meet the regulatory requirements.
Oh. My. God.
I like Rod’s allusion (near the end of the article) to court action. If public comment doesn’t work, I strongly believe that the nuclear industry (whoever that might actually be) should sue the EPA. I believe the applicable term is “capricious and arbitrary”. Those words would certainly describe the EPA’s current policy. Doesn’t that concept have tanglible legal meaning. If one can demonstrate that a law or regulation is capricious and arbitrary, isn’t that grounds for a (successful) court challenge?
It’s broken for me too. It tries to reload this page with the string “/onclick=” appended to the URL. Needless to say, it doesn’t work.
Okay. Let’s think this through. If Remy and Justin’s reading of the language is correct — and I’ve no reason to doubt them — then I believe it flies in direct contradiction to the stated purpose of the Clean Power Plan by EPA Administrator Gina McCarthy, as endorsed by previous administrators Carol Browner and Christine Todd Whitman. So let’s scrutinize the language, and if Remy and Josh’s interpretation holds up, then the language is either an inadvertent mistake or — at least as likely — the result of anti-nuclear activities at a level beneath the Administrator’s office.
My understanding was that the 5.8% number was intended for precisely the opposite reason: to effect an across-the-board penalty on all states for the increased CO2 emissions the Administrator’s Office — and her analysts — anticipate to result from premature closing of otherwise licensed and viable nuclear plant over the remainder of this decade. I really don’t think Josh and Remy’s interpretation was Ms. McCarthy’s intent. But if the UT analysis upholds under literal interpretation — what the courts will have to consider — then this may have to be raised to the highest level within EPA. And possible elsewhere. Because if the actual language were the deliberate action of mid-level executives with an anti-nuclear agenda, addressing the issue through the official comment process might or might not get anywhere.
But first let’s verify the UT analysis, then get Gina McCarthy’s take. After that, well — Here in this briefcase I’ve documented a list of four influential congresspersons who might also be interested.
From EPA: Carbon rules could ensure nuclear power’s survival:
So let’s look into it, tactful but firm.
There is a climate march is going across the country (USA), stopping in many places. They will end in WashDC in 10 weeks. Several sponsors include PSR, NRDC, Nuke Free/Sierra Club, Begley Jr, James Hansen, Nelson Mandela’s grandson, & 350.org. This is currently winding through Illinois, gearing up for a major shindig in NYC Sept 18-12, and will end in Wash DC in 9 weeks. http://climatemarch.org/
Some of the accompanying meetings (town messages to the EPA) are being video recorded. There are also postcards which can be signed (postage paid by the sponsors!) which urge passage of the EPA’s CO2 rules as written. I didn’t realize this when I went to my own local meeting – and found a PSR flyer alongside instructions on how to comment to the EPA. I scribbled a few notes of my own (many there had prepared statements) & signed up to *testify* (5 min. limit). Sounded like it would get posted on youtube. Many of the talks centered on particulate emissions – an important tangential subject. My own testimony stressed the EPAs target of 1400 lbs per MW/hr of carbon here in Iowa. I mentioned this 5.8% misstep & uged that 100% of nuclear capacity be used on both sides of the equation. I then credited Ontario via CanadianEnergyIssues.com for their emissions rates, explaining why 200 lbs (~91 grams CIPK) would be a more appropriate goal for my state.
Rod considers this particular blog to be a call to action. I would urge his readers to not only write the EPA, but to go to one of these eco-marches and engage others, explaining that they are being duped again. Remember; blind support for ~30% renewables’ capacity is like a subsidy to fossil fuel’s electrical generation.
This link should work:
https://www.federalregister.gov/articles/2014/06/18/2014-13726/carbon-pollution-emission-guidelines-for-existing-stationary-sources-electric-utility-generating
I’m not sure what’s up with the original link but it appears to be using a tracking code that isn’t necessary. I’m sure Rod will correct the problem soon.
Keith, I don’t think that’s correct.
The relevant passage in EPA’s Goal Computation Technical Support Documentation says,
“the expected generation for new and “at risk” nuclear is simply added to the state goal denominator – resulting in a lower state goal emission rate. However, it is important to note that this “under construction and at risk” nuclear capacity is also part of the inventory that the state can count towards compliance with its state goal (i.e., zero emitting generation that can be averaged with that of the covered fossil sources in order to obtain a rate that is equal to or less than the state emission rate goal).”
To me this suggests that *all* the MWhs from the new plant once it begins operating will be added to the state’s total electricity production stats–the denominator for the emissions-over-generation ratio that determines the state’s carbon intensity figure, which EPA is trying to lower. So turning the new nuke on will definitely lower the state’s carbon intensity figure and contribute towards the EPA goals.
The problem is that old nuclear plant (and, I believe, hydro generators) don’t have any of their current generation accounted in the state’s generation figures (except for the negligible 5.8 percent of “at risk.”) That means that if the old nukes get switched off, the decrease of low-carbon generation doesn’t show up in the generation figures or the carbon-intensity figures (except for 5.8 percent of the lost low-carbon energy.) But the addition of a new gas plant to replace the old nuke will have 100 percent of its MWhs added to the state’s generation total, and if its emissions are lower than the state’s average, will also lower the state’s carbon-intensity ratio, in many cases more than the 5.8 percent “at risk” portion of old nuclear generation that will be “lost” according to the EPA formula.
So EPAs formula strongly encourages the opening of a new nuke, while mildly encouraging in some cases the replacement of an old nuke with a new gas plant.
What’s not clear is whether EPA encourages the construction of new nukes beyond those projects that it has already factored into state goals–Vogtle, Summer and Watt’s Bar. So I’m not sure whether any other new nuke will get 100 percent of its generation added to state generation totals, or whether its generation will be ignored like the generation from the old nukes.
I’m mystified. When I look through the html code, everything looks correct for a properly formed link. When I hover over link using Chrome, the correct destination appears in my status bar. However, Safari on the same machine gives me the symptoms reported by E-P, Jason and Jim.
@Rod, it looks ok now in Chrome, but the link gives the same messy output as before when I look at it with Firefox.
Firefox is also showing this type of output with the other links.
The suit should be for one dollar to bring proper attention. This post does a public service by pointing out such discrepancies to the public.
Remy and Justin are correct. The utilities have found that error as well and we’ll definitely be commenting to the EPA on that flaw. If a gas plant replaces a nuke that retires, the intensity goes down in the state yet emissions will go up. Makes no sense.
David Bradish
NEI
Thanks David. We’ll hope it was an inadvertent oversight, that such are what public comments are for. I commented in person at EPA’s Denver hearings in June, mentioning our ongoing need for nuclear; I intend to write them further before the 16 October deadline.
Re: Jim Hoff
“I believe the applicable term is “capricious and arbitrary”.
Better: “maliciously arbitrary.”
Let’s have no PC illusions which energy side the EPA is coyly on.
James Greenidge
Queens NY
I would not be surprised to learn that the formula came not from an EPA employee, but rather from some industry lobbyist who understood the implications quite well but didn’t bother to spell them out. It almost worked, too.
Once might be an accident. Twice a coincidence. The third time is a clear indication of enemy action.
The nuclear industry has taken it on the chin so many many more times than three, I think your default assumption should be enemy action until proven otherwise. There are many avenues through which this could have been introduced by those in the pay of oil and gas.
For Rod Adams: The Sustainability and Reliability graph that you use is for overall capacity. The EPA calculates CO2 capacity for each state. In some states reactors have a lot of down time while in others the down time is very low and therefore the co2 capacity for each state shoud reflect this variability.
The assumptions used for the EPA Clean Power Plan should be checked. There is a lot of turnover in that agency and even if there were not no one is perfect and some may not have thought of the implications of a new rule. Congratulations to grad students Remy and Knowles for following up on a rule which appears to reward states for replacing nuclear with gas. Gas does prduces carbon co2 emissions while nuclear does not.
Federal government websites are often difficult to use. They could take some lessons from commercial sites.
Industry lobbyists don’t wander the halls of the EPA these days. NRDC people do, and have been the ones writing all the new rules and regs. Read the report. Cheers –
http://www.epw.senate.gov/public/index.cfm?FuseAction=Files.View&FileStore_id=8af3d005-1337-4bc3-bcd6-be947c523439
Meh. I’ll see you and raise you a Reid.
@agimarc
And what makes you absolve the NRDC of the potential of being industry lobbyists in green clothing? Do you know where they obtain their funding?
That is not a rhetorical question. Like most non-profits, the NRDC is not required to reveal their funding sources. Early this year I spend a considerable amount of time working with an NRDC guy to arrange a symposium about climate change and the use of nuclear energy as a tool in the battle against the possibility that humans are altering the balance that has produced the environment in which human society has developed.
We finally broke off discussions after reaching an impasse. The NRDC guy told me that his funders would not consider nuclear as a valuable tool, but might discuss ways to more gradually phase out existing nuclear. That makes me wonder who those string pullers might be.
Read the report, Rod. It will tell you who is funding the environmental movement and what the NRDC is doing in the EPA these days.
Note also that Saudi money has been involved in funding environmental opposition to the Alberta tar sands. Putin’s Russia has also been funding green opposition to fracing in Europe.
There a lot of players out there in anti-nuke land. The oilies aren’t the only ones. Cheers-
http://opinion.financialpost.com/2011/09/23/foreign-interests-attack-oil-sands/
http://www.thenewamerican.com/world-news/europe/item/18546-nato-head-russia-is-funding-anti-fracking-movement
@agimarc
What makes you think that Saudis and Russians do not qualify as “oilies?”
Both are dependent on oil and gas revenues for more than 50% of their government income.
BTW, NRDC has always been a big recipient of funds from the Rockefeller Foundation, which makes it also interested in oil and gas prosperity.