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Report to Congressional Requesters: 

United States Government Accountability Office: 
GAO: 

June 2010: 

Coal Power Plants: 

Opportunities Exist for DOE to Provide Better Information on the 
Maturity of Key Technologies to Reduce Carbon Dioxide Emissions: 

GAO-10-675: 

GAO Highlights: 

Highlights of GAO-10-675, a report to congressional requesters. 

Why GAO Did This Study: 

Coal power plants generate about half of the United States’ 
electricity and are expected to remain a key energy source. Coal power 
plants also account for about one-third of the nation’s emissions of 
carbon dioxide (CO2), the primary greenhouse gas that experts believe 
contributes to climate change. Current regulatory efforts and proposed 
legislation that seek to reduce CO2 emissions could affect coal power 
plants. Two key technologies show potential for reducing CO2 
emissions: (1) carbon capture and storage (CCS), which involves 
capturing and storing CO2 in geologic formations, and (2) plant 
efficiency improvements that allow plants to use less coal. 

The Department of Energy (DOE) plays a key role in accelerating the 
commercial availability of these technologies and devoted more than 
$600 million to them in fiscal year 2009. Congress asked GAO to 
examine (1) the maturity of these technologies; (2) their potential 
for commercial use, and any challenges to their use; and (3) possible 
implications of deploying these technologies. To conduct this work, 
GAO reviewed reports and interviewed stakeholders with expertise in 
coal technologies. 

What GAO Found: 

DOE does not systematically assess the maturity of key coal 
technologies, but GAO found consensus among stakeholders that CCS is 
less mature than efficiency technologies. Specifically, DOE does not 
use a standard set of benchmarks or terms to describe the maturity of 
technologies, limiting its ability to provide key information to 
Congress, utilities, and other stakeholders. This lack of information 
limits congressional oversight of DOE’s expenditures on these efforts, 
and it hampers policymakers’ efforts to gauge the maturity of these 
technologies as they consider climate change policies. In the absence 
of this information from DOE, GAO interviewed stakeholders with 
expertise in CCS or efficiency technologies to identify their views on 
the maturity of these technologies. Stakeholders told GAO that while 
components of CCS have been used commercially in other industries, 
their application remains at a small scale in coal power plants, with 
only one fully integrated CCS project operating at a coal plant. 
Efficiency technologies, on the other hand, are in wider commercial 
use. 

Commercial deployment of CCS is possible within 10 to 15 years while 
many efficiency technologies have been used and are available for use 
now. Use of both technologies is, however, contingent on overcoming a 
variety of economic, technical, and legal challenges. In particular, 
with respect to CCS, stakeholders highlighted the large costs to 
install and operate current CCS technologies, the fact that large 
scale demonstration of CCS is needed in coal plants, and the lack of a 
national carbon policy to reduce CO2 emissions or a legal framework to 
govern liability for the permanent storage of large amounts of CO2. 
With respect to efficiency improvements, stakeholders highlighted the 
high cost to build or upgrade such coal plants, the fact that some 
upgrades require highly technical materials, and plant operators’ 
concerns that changes to the existing fleet of coal power plants could 
trigger additional regulatory requirements. 

CCS technologies offer more potential to reduce CO2 emissions than 
efficiency improvements alone, and both could raise electricity costs 
and have other effects. According to reports and stakeholders, the 
successful deployment of CCS technologies is critical to meeting the 
ambitious emissions reductions that are currently being considered in 
the United States while retaining coal as a fuel source. Most 
stakeholders told GAO that CCS would increase electricity costs, and 
some reports estimate that current CCS technologies would increase 
electricity costs by about 30 to 80 percent at plants using these 
technologies. DOE has also reported that CCS could increase water 
consumption at power plants. Efficiency improvements offer more 
potential for near term reductions in CO2 emissions, but they cannot 
reduce CO2 emissions from a coal plant to the same extent as CCS. 

What GAO Recommends: 

GAO recommends that DOE develop a standard set of benchmarks to gauge 
and report to Congress on the maturity of key technologies. In 
commenting on a draft of this report, DOE concurred with our 
recommendation. 

View [hyperlink, http://www.gao.gov/products/GAO-10-675] or key 
components. For more information, contact Mark Gaffigan at (202) 512-
3841 or gaffiganm@gao.gov. 

[End of section] 

Contents: 

Letter: 

Although DOE Does Not Systematically Assess the Maturity of Key Coal 
Technologies, Consensus among Stakeholders Is That CCS Is Less Mature 
Than Efficiency Technologies: 

Commercial Deployment of Key Coal Technologies Is Possible, but 
Contingent on Overcoming Economic, Technical, and Legal Challenges: 

CCS Offers More Potential to Reduce CO2 Emissions than Efficiency 
Improvements Alone; Both Could Have Cost and Other Effects: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Briefing Slides to Congressional Staff: 

Appendix II: Scope and Methodology: 

Appendix III: Comments from the Department of Energy:
GAO Comments: 

Appendix IV: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: NASA's Technology Readiness Levels: 

Table 2: Scale Used to Gauge the Maturity of Coal Technologies: 

Abbreviations: 

ARRA: American Recovery and Reinvestment Act: 

CCPI: Clean Coal Power Initiative: 

CCS: carbon capture and storage: 

CO: carbon monoxide: 

CO2: carbon dioxide: 

DOD: Department of Defense: 

DOE: Department of Energy: 

EIA: Energy Information Administration: 

EOR: enhanced oil recovery: 

EPA: Environmental Protection Agency: 

EPRI: Electric Power Research Institute: 

GHG: greenhouse gas: 

IEA: International Energy Agency: 

IGCC: Integrated Gasification Combined Cycle: 

IPCC: Intergovernmental Panel on Climate Change: 

MIT: Massachusetts Institute of Technology: 

MW: megawatt: 

NAS: National Academy of Sciences: 

NASA: National Aeronautics and Space Administration: 

NERC: North American Electric Reliability Corporation: 

NSR: New Source Review: 

RD&D: research, development, and demonstration: 

SDWA: Safe Drinking Water Act: 

TRL: Technology Readiness Level: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

June 16, 2010: 

The Honorable James M. Inhofe: 
Ranking Member: 
Committee on Environment and Public Works: 
United States Senate: 

The Honorable George V. Voinovich: 
United States Senate: 

Coal power plants generate about half of the United States' 
electricity and are expected to continue supplying a large portion of 
the nation's electricity in the future. According to the Department of 
Energy's (DOE) Energy Information Administration (EIA),[Footnote 1] 
coal will provide 44 percent of the electricity in 2035 in the United 
States. The critical role that coal plays in supplying electricity is 
due in part to the large coal reserves in the United States, which 
some estimate will last about 240 years at current consumption levels, 
and the relatively low cost of this energy supply. However, coal power 
plants also currently account for about one-third of the nation's 
emissions of carbon dioxide (CO2), the most prevalent greenhouse gas. 
Concerns over rising greenhouse gas emissions and their potential 
effects on the climate have led some countries to adopt or consider 
adopting policies to reduce these emissions. In the United States and 
elsewhere, these concerns have also increased focus on developing and 
using technologies to limit CO2 emissions from coal power plants while 
allowing coal to remain a viable source of energy. 

Two key technologies show potential for reducing CO2 emissions from 
coal plants: carbon capture and storage (CCS) and efficiency 
technologies. CCS technologies separate and capture CO2 from other 
gases produced when combusting or gasifying coal, compress it, then 
transport it to underground geologic formations such as saline 
aquifers--porous rock filled with brine--where it is injected for long-
term storage. There are three approaches to capturing CO2--post- 
combustion, pre-combustion, and oxy-combustion. Post-combustion 
capture involves capturing CO2 from the exhaust stream created when 
coal is burned at pulverized coal plants, which make up nearly all 
coal plants operating in the United States. Pre-combustion capture 
involves capturing CO2 produced when gasifying coal at Integrated 
Gasification Combined Cycle (IGCC) plants, which are in limited use in 
the electricity industry. Oxy-combustion capture involves capturing 
CO2 from the exhaust stream created when coal is burned in an oxygen- 
enriched environment at pulverized coal plants. 

Efficiency technologies include more efficient designs for new coal 
power plants--such as IGCC plants, as well as ultrasupercritical 
plants--that operate at higher steam temperatures and pressures than 
conventional plants.[Footnote 2] Efficiency upgrades can also be made 
in existing coal plants, such as overhauling or replacing turbine fan 
blades. Improving the efficiency of coal plants allows them to use 
less coal per unit of electricity produced and achieve a corresponding 
reduction in CO2 emissions. CCS technologies and efficiency 
technologies can be used independently or in conjunction with one 
another. 

In the United States, regulatory efforts and proposed legislation that 
seek to reduce CO2 emissions could affect coal power plants. The 
Environmental Protection Agency (EPA) has taken steps to regulate 
greenhouse gas emissions under the Clean Air Act and plans to begin 
regulating emissions from certain stationary sources, including coal 
power plants, beginning in 2011. As part of this effort, EPA is 
compiling technical and background information on potential control 
technologies and measures, such as CCS, and developing policy guidance 
to assist permitting agencies in determining the best available 
control technology for greenhouse gas emissions. In addition, the 
American Clean Energy and Security Act passed the House of 
Representatives on June 26, 2009, and would require an 83 percent 
reduction in greenhouse gas emissions from 2005 levels by 2050. 
[Footnote 3] Among other things, this proposed legislation would 
create a cap and trade program, a market-based mechanism to establish 
a price for emissions of greenhouse gases, and require additional 
specific actions to reduce these emissions. For example, section 116 
of the bill would require new coal power plants permitted before 2020 
to reduce their CO2 emissions by half, 4 years after certain CCS 
deployment criteria are met or by 2025, whichever comes first. 
[Footnote 4] 

DOE plays a key role in accelerating the commercial availability of 
technologies to reduce CO2 emissions from coal power plants. 
Specifically, DOE's Office of Fossil Energy oversees research on these 
technologies through its coal research, development, and demonstration 
(RD&D) program. This program carries out three primary activities: (1) 
managing and performing energy-related research that reduce barriers 
to the environmentally sound use of fossil fuels, (2) partnering with 
industry to advance technologies toward commercialization, and (3) 
supporting the development of information and policy options that 
benefit the public. Such information could help EPA in its review of 
available technologies to reduce CO2 from coal plants along with other 
policymakers that are considering climate change policies. In the near 
term, according to DOE's fiscal year 2011 budget submission, DOE hopes 
to facilitate the development of CCS and efficiency technologies, with 
longer term goals of improving these technologies so that coal can 
remain part of the nation's fuel mix in generating electricity. In 
fiscal year 2009, DOE's coal RD&D funding was at least $681 million, 
and $3.4 billion was appropriated in the American Recovery and 
Reinvestment Act of 2009 (ARRA) for fossil energy RD&D.[Footnote 5] 

In this context, you asked us to review key technologies to reduce CO2 
emissions from coal power plants. Specifically, we examined (1) the 
maturity of technologies to reduce CO2 emissions from coal power 
plants; (2) the potential for these technologies to be used 
commercially in the future, and challenges, if any, to their use; and 
(3) the possible implications of deploying these technologies. We 
briefed your staffs on the results of our work on June 1, 2010 (see 
app. I). This report summarizes and formally transmits the information 
provided during that briefing. It incorporates technical and other 
comments provided by agencies since the briefing. 

To conduct this work, we reviewed key reports including those from 
DOE's national laboratories, the National Academy of Sciences (NAS), 
International Energy Agency (IEA), Intergovernmental Panel on Climate 
Change (IPCC), Global CCS Institute, the National Coal Council, and 
academic reports. We conducted interviews with stakeholders such as 
power plant operators, technology vendors, and federal officials from 
EPA and DOE along with officials from the North American Electric 
Reliability Corporation (NERC). We then selected a group of 19 
stakeholders with expertise in CCS or efficiency technologies to 
answer a standard set of questions. This group included those from 
major utilities that are planning or implementing projects using key 
coal technologies, technology vendors that are developing these 
technologies, federal officials providing RD&D funding for these 
technologies, and researchers from academia and industry that are 
researching these technologies. We asked these stakeholders to 
describe the maturity of these technologies using a nine point scale 
we developed in conjunction with the Electric Power Research Institute 
(EPRI) based on the National Aeronautics and Space Administration's 
(NASA) Technology Readiness Levels (TRL).[Footnote 6] TRLs are a tool 
that is used by NASA and other agencies to rate the extent to which 
technologies have been demonstrated to work as intended. We also 
reviewed available data on the use of key coal technologies compiled 
by IEA and the Global CCS Institute. 

To identify the potential for these technologies to be used 
commercially in the future along with any associated challenges or 
implications, we reviewed key reports on CCS and efficiency 
technologies and examined goals set out by DOE, IEA, and electricity 
industry groups for deploying these technologies. We also asked our 19 
stakeholders with expertise in CCS or efficiency technologies for 
their views on the potential challenges and implications of using 
these technologies. Finally, we visited coal power plants and research 
facilities in three states--Alabama, Maryland, and West Virginia--that 
we selected because they contained projects involving advanced coal 
technologies. Importantly, our discussion focuses on the technological 
maturity of these technologies. TRLs describe the level of 
demonstration achieved for particular technologies, but they do not 
provide information on other factors that play a critical role in 
decisions to deploy them, such as their cost, availability of 
financing, and applicable regulations. Technological improvements 
could help these technologies overcome some challenges or potential 
negative implications. For example, novel approaches to CO2 capture 
could help to lower the cost of using these technologies. 

We conducted this performance audit from July 2009 through May 2010 in 
accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. A more 
detailed description of our scope and methodology is presented in 
appendix II. 

Although DOE Does Not Systematically Assess the Maturity of Key Coal 
Technologies, Consensus among Stakeholders Is That CCS Is Less Mature 
Than Efficiency Technologies: 

DOE's Office of Fossil Energy oversees research on key coal 
technologies, but DOE does not systematically assess the maturity of 
those technologies. Using TRLs we developed for these technologies, we 
found consensus among stakeholders that CCS is less mature than 
efficiency technologies. 

DOE Does Not Systematically Assess the Maturity of Key Coal 
Technologies: 

Although federal standards for internal control require agency 
managers to compare actual program performance to planned or expected 
results and analyze significant differences,[Footnote 7] we found that 
DOE's Office of Fossil Energy does not systematically assess the 
maturity of key coal technologies as they progress toward 
commercialization. While DOE officials reported that individual 
programs are aware of the maturity of technologies and DOE publishes 
reports that assess the technical and economic feasibility of advanced 
coal technologies, we found that the Office of Fossil Energy does not 
use a standard set of benchmarks or terms to describe or report on the 
maturity of technologies. In addition, DOE's goals for advancing these 
technologies sometimes use terms that are not well defined. The lack 
of such benchmarks or an assessment of the maturity of key coal 
technologies and whether they are achieving planned or desired results 
limits: 

* DOE's ability to provide a clear picture of the maturity of these 
technologies to policymakers, utilities officials, and others; 

* congressional and other oversight of the hundreds of millions of 
dollars DOE is spending on these technologies; and: 

* policymakers' ability to assess the maturity of CCS and the 
resources that might be needed to achieve commercial deployment. 

Other agencies similarly charged with developing technologies, such as 
NASA and the Department of Defense (DOD), use TRLs to characterize the 
maturity of technologies.[Footnote 8] Table 1 shows a description of 
TRLs used by NASA. 

Table 1: NASA's Technology Readiness Levels: 

TRL: 9; 
Summary of TRL descriptions used by NASA: Actual system "flight 
proven" through successful mission operations under operational 
mission conditions. 

TRL: 8; 
Summary of TRL descriptions used by NASA: Actual system completed and 
"flight qualified" through test and demonstration. Examples include 
test and evaluation of the system in its intended weapons system to 
see if it meets design specifications. 

TRL: 7; 
Summary of TRL descriptions used by NASA: System prototype 
demonstration in realistic environment. Requires demonstration of 
actual system prototype in a realistic environment, such as an 
aircraft vehicle or space. 

TRL: 6; 
Summary of TRL descriptions used by NASA: System/subsystem model or 
prototype demonstration in a relevant environment. 

TRL: 5; 
Summary of TRL descriptions used by NASA: Component and/or breadboard 
validation in a relevant environment, which could be lab or simulated 
realistic environment. 

TRL: 4; 
Summary of TRL descriptions used by NASA: Component and/or breadboard 
validation in lab environment. 

TRL: 3; 
Summary of TRL descriptions used by NASA: Proof of concept test in lab 
environment. 

TRL: 2; 
Summary of TRL descriptions used by NASA: Technology concept and/or 
application formulated. 

TRL: 1; 
Summary of TRL descriptions used by NASA: Basic principles observed 
and reported. 

Source: GAO analysis of NASA data. 

[End of table] 

DOE has acknowledged that TRLs can play a key role in assessing the 
maturity of technologies during the contracting process. The agency 
recently issued a Technology Readiness Assessment Guide, which lays 
out three key steps to conducting technology readiness assessments 
during the contracting process.[Footnote 9] 

* Identify critical technology elements that are essential to the 
successful operation of the facility. 

* Assess maturity of these critical technologies using TRLs. 

* Develop a technology maturity plan which identifies activities 
required to bring technology to desired TRL level. 

Although use of the Guide is not mandatory, DOE's Office of 
Environmental Management uses the Guide as part of managing its 
procurement activities--a result of a GAO recommendation--and its 
Office of Nuclear Energy has begun using TRLs to measure and 
communicate risks associated with using critical technologies in a 
novel way.[Footnote 10] Furthermore, the National Nuclear Security 
Administration has used TRLs recently as well. 

Consensus among Key Stakeholders Is That CCS Is Less Mature than 
Efficiency Technologies: 

In the absence of an assessment from DOE, we asked stakeholders to 
gauge the maturity of coal technologies using a scale we developed 
based on TRLs. Table 2 shows the TRLs we developed for coal 
technologies by adapting the NASA TRLs. 

Table 2: Scale Used to Gauge the Maturity of Coal Technologies: 

TRL: 9; 
Description of TRLs we developed for coal technologies: Commercial 
operation in relevant environment (500 megawatt [MW] coal plant or 
greater, or about 3 million tons of CO2 captured, transported, or 
stored annually). 

TRL: 8; 
Description of TRLs we developed for coal technologies: Demonstration 
at more than 5 percent commercial scale (at least 125 MW coal plant, 
or about 575,000 tons of CO2 captured, transported, or stored 
annually). 

TRL: 7; 
Description of TRLs we developed for coal technologies: Pilot plant at 
more than about 5 percent commercial scale (at least 20 MW coal plant, 
or 100,000 tons of CO2 captured, transported, or stored annually). 

TRL: 6; 
Description of TRLs we developed for coal technologies: Process 
development unit at between about 0.1 percent to 5 percent of 
commercial scale (between 0.5 MW and 20 MW coal plant, or between 
about 3,000 and 100,000 tons of CO2 captured, transported, or stored 
annually). 

TRL: 5; 
Description of TRLs we developed for coal technologies: Component 
validation in relevant environment (coal plant). 

TRL: 4; 
Description of TRLs we developed for coal technologies: Component 
tests in lab. 

TRL: 3; 
Description of TRLs we developed for coal technologies: Proof of 
concept test. 

TRL: 2; 
Description of TRLs we developed for coal technologies: Application 
formulated (on paper). 

TRL: 1; 
Description of TRLs we developed for coal technologies: Basic 
principles observed. 

[End of table] 

Source: GAO framework analysis based on adaptation of TRLs to coal 
power plants and conversations with EPRI officials. 

Note: We described commercial scale coal plant as 500 MW that emits 3 
million tons of CO2 annually. This is the size of a plant that has 
been used as a reference plant in engineering studies. Actual 
emissions from a coal plant can vary based on a variety of factors, 
including how often a plant operates. 

Using the scale we developed for coal technologies, the consensus 
among key stakeholders we spoke with is that CCS is less mature than 
efficiency technologies. While all of the components of CCS--CO2 
capture, transportation, and storage--have been used commercially in 
other industries, such as natural gas processing and oil production, 
stakeholders generally reported that the application of these 
technologies remains at small scale in coal plants. Using TRLs, 
stakeholders generally reported that the largest demonstration of 
carbon capture in a coal plant was at a pilot scale (TRL 7) or less. 
Moreover, stakeholders identified only one integrated CCS system in a 
coal power plant--the Mountaineer Plant in West Virginia--which aims 
to capture and store more than 100,000 tons of CO2.[Footnote 11] This 
project captures CO2 from a portion of the plant's exhaust--20 MW or 
about 4 percent the size of a typical 500 MW coal plant. DOE has 
announced funding for several integrated CCS projects in coal plants 
at larger scales--60 to 450 MW. In contrast to CCS, stakeholders 
generally told us that technologies that improve the efficiency of new 
or existing plants have already been demonstrated commercially. For 
example, a number of ultrasupercritical plants ranging from 600 to 
more than 1,000 MW have been built or are under construction in Europe 
and Asia, and there are five IGCC plants in operation around the 
world, including two in the United States.[Footnote 12] 

Commercial Deployment of Key Coal Technologies Is Possible, but 
Contingent on Overcoming Economic, Technical, and Legal Challenges: 

Commercial deployment of CCS within 10 to 15 years is possible 
according to DOE and other stakeholders, but is contingent on 
overcoming a variety of economic, technical, and legal challenges. 
[Footnote 13] Many technologies to improve plant efficiency have been 
used and are available for commercial use now, but still face 
challenges. 

Commercial Deployment of CCS Is Possible within 10 to 15 Years, but 
Faces Major Challenges According to Reports and Stakeholders: 

While DOE, electric industry groups, and other stakeholders have set 
goals to commercially deploy CCS in coal plants in the next 10 to 15 
years, they acknowledge that these goals present significant 
challenges. In particular, they have highlighted the large costs to 
install and operate current CCS technologies. In 2007, DOE estimated 
the cost to install current CCS technologies was 85 percent higher for 
plants with post-combustion capture and was 36 percent higher for pre- 
combustion capture at IGCC plants, compared to comparable plants 
without CCS.[Footnote 14] In addition, the large amount of energy that 
current CCS technologies require to operate--known as parasitic load-- 
reduces the electricity plants can sell and raises operating costs. 
Parasitic load is estimated to be between 21 percent and 32 percent of 
plant output for post-combustion CO2 capture and between 15 percent 
and 22 percent for pre-combustion CO2 capture. To help reduce 
parasitic load of current technologies, DOE is supporting research on 
more advanced capture processes, including post-combustion work on 
membranes to capture CO2 that may lower the cost of the current method 
of using chemical solvents. 

In addition, key studies report that demonstration of large scale 
integrated CCS systems is a technical challenge and is needed to 
demonstrate the performance and potential costs of these systems. Some 
stakeholders also reported that additional demonstration was needed to 
lower perceived risk of technologies. For example, officials from one 
large utility told us that demonstration projects were needed to build 
experience with the technologies and to build vendor confidence so 
that they could provide technology performance guarantees. Similarly, 
officials from one state public utility commission reported that they 
considered CCS immature and were unlikely to approve cost recovery for 
such a project in the foreseeable future. Officials from two financial 
firms reported that they considered the application of CCS 
technologies at coal plants largely unproven and they would require 
additional demonstration projects or technology cost and performance 
guarantees from vendors or utilities to reduce the risk of financing 
these types of projects. 

Moreover, without a national carbon policy to reduce CO2 emissions 
nearly all stakeholders said CCS would not be widely deployed. Without 
a tax or a sufficiently restrictive limit on CO2 emissions, plant 
operators lack an economic incentive to use CCS technologies. Reports 
by IPCC, NAS, and the Global CCS Institute have all highlighted the 
importance of a carbon policy to incentivize the use of CCS. In 
addition, nearly all stakeholders cited as challenges the lack of a 
regulatory framework to govern the permanent storage of large amounts 
of CO2 in saline formations and legal uncertainty regarding long-term 
liability for the storage of CO2. In 2008, EPA proposed a rule for 
injection of CO2 for geologic sequestration under the Safe Drinking 
Water Act (SDWA).[Footnote 15] EPA has stated that it lacks authority 
to release CO2 injection well operators from liability for 
endangerment of underground sources of drinking water until the 
operator meets all the closure and post-closure requirements and EPA 
approves site closure of the well. According to EPA, once site closure 
is approved, well operators will only be liable under the SDWA if they 
violate or fail to comply with EPA orders in situations where an 
imminent and substantial endangerment to health is posed by a 
contaminant that is in or likely to enter an underground source of 
drinking water.[Footnote 16] EPA plans to finalize the geologic 
sequestration rule in fall 2010. Neither the proposed rule nor the 
final rule will address liability for unintended releases of stored 
CO2 that have other harmful effects. However, potential storage site 
operators are unlikely to assume these risks. 

Many Efficiency Technologies Have Been Used and Are Ready for 
Commercial Use Now, but Also Face Challenges. 

Several stakeholders told us that building ultrasupercritical or IGCC 
plants may not be cost-effective for power plant owners in the United 
States because low coal prices limit the incentive to build highly 
efficient, but more costly, plants. Ultrasupercritical plants have 
higher capital costs because they use advanced materials, which may 
not justify expected fuel savings. To date, all of the more efficient 
ultrasupercritical plants have been built outside the United States, 
where coal prices are generally higher. Similarly, IGCC plants are 
more expensive than traditional pulverized coal units. According to 
some stakeholders, if low natural gas prices persist, utilities may 
choose to build natural gas power plants to reduce CO2 emissions in 
lieu of more efficient coal plants. 

In addition, some higher efficiency plant designs also face technical 
challenges in that they require more advanced materials than are 
currently available. For example, "advanced" ultrasupercritical plants 
require development of metal alloys to withstand steam temperatures 
that could be 300 to 500 degrees Fahrenheit higher than today's 
ultrasupercritical plants according to DOE.[Footnote 17] From a legal 
perspective, most stakeholders reported that making efficiency 
upgrades to the existing fleet of coal power plants was limited by the 
prospect of triggering the Clean Air Act's New Source Review (NSR) 
requirements--additional requirements that may apply when a plant 
makes a major modification, a physical or operational change that 
would result in a significant net increase in emissions. 

CCS Offers More Potential to Reduce CO2 Emissions than Efficiency 
Improvements Alone; Both Could Have Cost and Other Effects: 

CCS technologies offer more potential to reduce CO2 emissions than 
efficiency improvements alone but could raise electricity costs, 
increase demand for water, and could affect the ability of individual 
plants to operate reliably. Technologies to improve plant efficiency 
offer potential near-term reductions, but also raise some concerns. 

CCS Could Help Meet Emissions Limits but Raises Key Concerns: 

According to key reports and stakeholders, the successful deployment 
of CCS technologies is critical to helping the United States meet 
potential limits in greenhouse gas emissions. In addition, CCS could 
allow coal to remain part of the nation's diverse fuel mix. IEA 
estimated that CCS technologies could meet 20 percent of reductions 
needed to reduce global CO2 emissions by half by 2050.[Footnote 18] 
This report also noted that the cost of meeting this goal would 
increase if CCS was not deployed. Massachusetts Institute of 
Technology (MIT) researchers called CCS the "critical enabling 
technology" to reduce CO2 emissions while allowing continued use of 
coal in the future.[Footnote 19] In 2009, NAS reported that if CCS 
technologies are not demonstrated commercially in the next decade, the 
electricity sector could move more towards using natural gas to meet 
emissions targets.[Footnote 20] Our past work has also found that 
switching from coal to natural gas can lead to higher fuel costs and 
increased exposure to the greater price volatility of natural gas. 
[Footnote 21] 

On the other hand, most stakeholders told us that CCS would increase 
electricity prices, and key reports raise similar concerns. MIT 
estimated that plants with post-combustion capture have 61 percent 
higher cost of electricity, and IGCC plants with pre-combustion 
capture have a 27 percent higher cost compared to plants without these 
technologies.[Footnote 22] Similarly, DOE estimated that plants with 
post-combustion capture have 83 percent higher cost of electricity, 
while IGCC plants with pre-combustion capture having a 36 percent 
higher cost.[Footnote 23] DOE has also raised concerns about CCS and 
water consumption. Specifically, DOE estimated that post-combustion 
capture technology could almost double water consumption at a coal 
plant, while pre-combustion capture would increase water use by 73 
percent.[Footnote 24] Some utility officials also said CCS could lead 
to a decline in the ability of individual plants to operate reliably 
because a power plant might need to shut down if any of the three 
components (capture, transport, and storage) of CCS became 
unavailable. In addition, more electricity sources would need to make 
up for the higher parasitic load associated with CCS. The National 
Coal Council has also reported temporary declines in reliability 
during past deployments of new coal technologies.[Footnote 25] 

Plant Efficiency Improvements Offer More Potential for Near-Term 
Emissions Reductions but Also Raise Concerns: 

Because they have been used commercially already, technologies that 
improve plant efficiency offer the potential for near term reductions 
in CO2 emissions. For example, DOE has estimated that efficiency 
improvements to the existing coal fleet could reduce CO2 emissions by 
100 million tons annually, or about a 5 to 10 percent reduction in 
overall emissions from these plants. According to the National Coal 
Council, increasing efficiency is the "only practical method for 
mitigating CO2 emissions now" in coal plants.[Footnote 26] 

However, there are limits in the amount of CO2 reductions that 
efficiency technologies can achieve. An ultrasupercritical plant emits 
about one-third less CO2 than an average plant in the United States. 
By comparison, CCS offers the potential to capture 90 percent of a 
plant's CO2 emissions. DOE officials and other stakeholders told us 
that plant efficiency improvements alone cannot reduce the CO2 
emissions from a coal plant to the same extent as CCS. However, plant 
efficiency improvements can help to facilitate CCS because they reduce 
the amount of CO2 that must be handled by the system. Finally, 
stakeholders' views were mixed on the potential effect of efficiency 
technologies on electricity costs, but they generally did not think 
efficiency technologies would increase water demand or compromise 
reliability. 

Conclusions: 

Addressing climate change while retaining the use of coal to generate 
electricity will likely require the successful deployment of CCS and 
efficiency technologies in coal power plants. CCS, in particular, 
remains relatively immature compared to efficiency technologies, but 
offers the potential to reduce CO2 emissions from power plants to a 
greater extent. The current regulatory and legislative efforts to 
reduce CO2 emissions at coal power plants include consideration of the 
commercial availability of CCS. DOE plays a key role both in its 
efforts to advance CCS and efficiency technologies toward 
commercialization and in giving policymakers an accurate view of their 
maturity. However, because the agency does not systematically assess 
their development, DOE is unable to provide a clear picture of the 
maturity of these technologies or the necessary resources that might 
be required to move these technologies toward commercial 
demonstration. This lack of information limits congressional oversight 
of the hundreds of millions of dollars DOE is currently spending 
annually on efforts to advance coal technologies, and it hampers 
policymakers' efforts to gauge the maturity of these technologies as 
they consider climate change policies. 

Recommendation for Executive Action: 

To improve decision making and oversight for coal research efforts, 
including how technological maturity is measured and reported, we are 
making one recommendation to the Secretary of Energy. We recommend 
that the Secretary of Energy direct the Office of Fossil Energy to 
develop a standard set of benchmarks to gauge the maturity of key 
technologies and report to Congress on the maturity of these 
technologies. As part of this process, the Office of Fossil Energy 
should consider consulting DOE's Technology Readiness Assessment Guide 
to develop benchmarks and reporting requirements. 

Agency Comments and Our Evaluation: 

We provided a draft of our report to the Secretary of Energy and the 
Administrator of EPA for review and comment. In addition, we provided 
selected slides on reliability of electricity supply to NERC for 
comment. We received written comments from DOE's Assistant Secretary 
of the Office of Fossil Energy, which are reproduced in appendix III. 
The Assistant Secretary concurred with our recommendation, stating 
that DOE could improve its process for providing a clearer picture of 
technology maturity and that it planned to conduct a formal TRL 
assessment of coal technologies in the near future. The Assistant 
Secretary also provided technical comments, which we have incorporated 
as appropriate. In addition, EPA and NERC provided technical comments, 
which we have incorporated as appropriate. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies of this report 
to the appropriate congressional committees, Secretary of Energy, 
Administrator of EPA, and other interested parties. In addition, the 
report will be available at no charge on GAO's Web site at [hyperlink, 
http://www.gao.gov]. 

If you or your staffs have any questions regarding this report, please 
contact me at (202) 512-3841 or gaffiganm@gao.gov. Contact points for 
our Offices of Congressional Relations and Public Affairs may be found 
on the last page of this report. GAO staff who made major 
contributions to this report are listed in appendix IV. 

Signed by: 

Mark Gaffigan: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Briefing Slides to Congressional Staff: 

Technologies to Reduce Carbon Dioxide Emissions from Coal Power Plants: 

Briefing to the Senate Committee on Environment and Public Works: 

June 1, 2010: 

Introduction: 

Coal Plays Key Role in U.S. Electricity Sector but Emits Large Amount 
of Carbon Dioxide (CO2): 

Coal power plants: 
* provide about half of U.S. electricity (see figure 1); 
* provide over 90% of electricity generated in some states; 
* account for about one-third of all U.S. emissions of CO2. 

CO2 is the most prevalent greenhouse gas (GHG): 
* Concerns over rising GHG emissions and their potential effects on 
climate have led some countries to adopt or consider adopting policies 
to reduce these emissions. 

Figure 1: U.S. Power Generation by Fuel Type, 2008: 

[Refer to PDF for image: pie-chart] 

Coal: 48.2%; 
Natural gas: 21.4%; 
Nuclear: 19.6%; 
Hydroelectric Conventional: 6.0%; 
Other renewables: 3.1%; 
Other: 1.7%. 

Source: GAO analysis of U.S. Energy Information Administration, Form 
EIA-923, "Power Plant Operations Report" January 21, 2010. 

[End of figure] 

Two Key Technologies Show Potential for Reducing CO2 Emissions from 
Coal Plants: 

Carbon capture and storage (CCS) is one of two key technologies for 
reducing CO2 emissions from coal plants: 

* CO2 is captured in one of three ways (see figures 2, 3, and 4): 
- Post-combustion; 
- Pre-combustion; 
- Oxy-combustion. 

* Captured CO2 is compressed and transported via pipelines to 
underground geologic formations, where it is injected for long term 
storage, also known as sequestration. 

Integrated CCS projects involve all of these components: CO2 capture, 
compression, transportation, and storage. 

Figure 2: Post-combustion Capture: 

[Refer to PDF for image: illustration] 

The following are depicted on the illustration: 

Post-combustion: 

Coal; Air: into: 

Boiler: Combustion. 

Steam turbine: Electricity. 

Flue gas (mostly nitrogen and oxygen): 

CO2 capture: Nitrogen released. 

CO2: 
CO2 clean-up and compression. 

Source: GAO analysis of IPCC and DOE data. 

[End of figure] 

Post-combustion captures CO2 produced when burning coal in air: 

* Compatible with traditional pulverized coal plants, which make up 
nearly all coal plants currently operating worldwide. 

Figure 3: Pre-combustion Capture: 

[Refer to PDF for image: illustration] 

The following are depicted on the illustration: 

Pre-combustion: 

Coal: 

Air: Air separation (Nitrogen released): 

Oxygen and Coal: Gasification: 

Syngas: 

CO2 capture: 

H2: Combustion turbine: produces Electricity 

CO2: CO2 clean-up and compression. 

Source: GAO analysis or IPCC and DOE data. 

[End of figure] 

Pre-combustion captures CO2 produced when gasifying coal: 

* Compatible with Integrated Gasification Combined Cycle (IGCC) 
plants, which are in limited use in electricity industry; 

* The gasification process transforms coal into a syngas, a mixture of 
hydrogen and carbon monoxide (CO). The CO is then converted into CO2 
and captured. 

Figure 4: Oxy-combustion Capture: 

[Refer to PDF for image: illustration] 

The following are depicted on the illustration: 

Coal: 

Air: Air separation (Nitrogen released): 

Boiler: Combustion; 

Steam turbine: produces Electricity; 

Flue gas (mostly CO2): CO2 recycle to Boiler; 

CO2 clean-up and compression. 

Source: GAO analysis of IPCC and DOE data. 

[End of figure] 

Oxy-combustion captures CO2 produced when burning coal in oxygen-rich 
environment: 

* Compatible with traditional pulverized coal plants, which make up 
nearly all coal plants currently operating worldwide 

The other key technology for reducing CO2 emissions improves the
efficiency of coal plants (efficiency technologies) by allowing plants 
to use less coal and therefore reduce their CO2 emissions 

* Existing plants: 
- Are about 32.5% efficient on average in the U.S. according to a 
recent Department of Energy (DOE) analysis[Footnote 1]; 
- Can be upgraded to improve efficiencies by a few percentage points. 

* New plants: 
- Can use more efficient designs, such as ultrasupercritical[Footnote 
2]—which operate at higher temperatures and greater steam pressures 
than conventional plants—and IGCC plants; 
- Can achieve efficiencies of 40-44%. 
CCS and efficiency technologies can be used independently, or in 
conjunction with one another 

Regulatory Efforts and Proposed Legislation Seek to Reduce CO2 
Emissions in U.S. 

The Environmental Protection Agency (EPA) is taking steps to regulate 
CO2 and other GHGs under the Clean Air Act including: 

* developing policy guidance to assist permitting agencies in making 
best available control technology determinations for GHGs that 
consider the commercial availability of CCS. 

The American Clean Energy and Security Act, H.R. 2454, passed the 
House of Representatives on June 26, 2009. Among other things, the 
proposed legislation would: 

* establish a GHG cap and trade program; 

* require new coal power plants permitted before 2020 to reduce CO2 
emissions by half, 4 years after specified CCS deployment criteria are 
met or 2025, whichever comes first[Footnote 3]. 

Federal Investments in Coal Research, Development, and Demonstration 
(RD&D) Aim to Reduce CO2 Emissions: 

DOE's Office of Fossil Energy oversees coal RD&D: 

* conducts research to accelerate the availability of key coal 
technologies; 

* partners with industry and others to move research toward 
commercialization. 

In FY09, DOE's coal RD&D funding was at least $681 million. 

In addition, $3.4 billion was appropriated in the American Recovery 
and Reinvestment Act for fossil energy RD&D. 

Table: Information on Selected DOE Coal Programs: 

Fossil Energy coal programs: Innovations for Existing Plants: 
Technology focus: Develop cost-effective post-combustion and oxy-
combustion capture technologies. 

Fossil Energy coal programs: Advanced IGCC; 
Technology focus: Develop more efficient IGCC plants and integrate 
these with pre-combustion capture technologies. 

Fossil Energy coal programs: Carbon Sequestration; 
Technology focus: Demonstrate storage of CO2 in geologic 
formations.[A] Develop improved capture technologies. 

Fossil Energy coal programs: Advanced Research; 
Technology focus: Develop technologies to improve plant efficiency, 
including development of metals for advanced ultrasupercritical plants. 

Fossil Energy coal programs: Clean Coal Power Initiative (CCPI); 
Technology focus: Provide money for commercial demonstration of coal 
technologies, including CCS. 

Source: GAO summary of DOE documents. 

[A] Geologic formations being examined include saline aquifers, which 
are composed of porous rock, filled with brine. 

[End of table] 

[End of Introduction section] 

Objectives: 

In this context, you asked us to review key technologies to reduce CO2 
emissions from coal power plants. 

Our objectives were to examine: 

* the maturity of technologies to reduce CO2 emissions from coal power 
plants; 

* the potential for these technologies to be used commercially in the 
future and challenges, if any, to their use; 

* the possible implications of deploying these technologies. 

[End of Objections section] 

Scope and Methodology: 

Reviewed key reports from: 

* DOE's national laboratories; 
* National Academy of Science (NAS); 
* Intergovernmental Panel on Climate Change (IPCC); 
* International Energy Agency (IEA); 
* Global CCS Institute; 
* National Coal Council; 
* Academic reports. 

Conducted scoping interviews with many stakeholders, such as power 
plant operators, technology vendors, and federal officials. 

From these scoping interviews, we selected 19 key stakeholders with 
expertise in coal technologies and asked them a standard set of 
questions. This group of stakeholders included those from: 

* Major electric utilities that are planning or implementing projects 
using key coal technologies; 
* Technology vendors that are developing these technologies; 
* Federal officials providing RD&D funding for these technologies; 
* Researchers from academia and industry that are researching these 
technologies. 

Reviewed DOE budget documents and program goals for its RD&D program 
and interviewed senior DOE staff on these. 

Visited coal power plants and research facilities in three selected 
states—AL, MD, and WV[Footnote 4]. 

We conducted this performance audit from July 2009 through May 2010, 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of Scope and Methodology section] 

Results in Brief: 

DOE does not systematically assess the maturity of key coal 
technologies, but we found consensus among stakeholders that CCS is 
less mature than efficiency technologies. 

Commercial deployment of these technologies is contingent on 
overcoming economic, technical, and legal challenges. 

CCS technologies offer more potential to reduce CO2 emissions than 
efficiency improvements alone, and both could have cost and other 
effects. 

Objective 1: Maturity of Key Technologies: DOE Does Not Systematically 
Assess their Maturity, but We Found Consensus that CCS Is Less Mature 
than Efficiency Technologies: 

DOE does not systematically assess the maturity of key coal 
technologies, although tools for doing so are available: 

* DOE does not systematically assess maturity of key coal technologies; 

* Other agencies charged with developing technologies use Technology 
Readiness Levels (TRL) to characterize technologies' maturity[Footnote 
5]; 

* DOE acknowledges TRLs as key practice in contracting, and some DOE 
offices use this tool for other technology programs. 

We found consensus among stakeholders that CCS technologies are less 
mature than efficiency technologies in coal plants: 

* Key aspects of CCS for use in coal plants still under development; 

* Efficiency technologies in commercial use. 

Objective 1: Maturity of Key Technologies: DOE Does Not Systematically 
Assess Maturity of Key Coal Technologies: 

Federal standards for internal control require agency managers to 
compare actual program performance to planned or expected results and 
analyze significant differences. 

DOE's Office of Fossil Energy does not systematically assess the 
maturity of key coal technologies as they progress toward 
commercialization. 

* The agency does not use a standard set of benchmarks or terms to 
describe the maturity of technologies; 

* DOE's goals for advancing these technologies sometimes use terms 
that are not well-defined; 

* DOE officials reported that individual programs are aware of the 
maturity of technologies, but we found the agency does not formally 
report on the maturity of these Technologies as they progress to 
commercial scale. 

Lack of an assessment or benchmarks limits: 

* DOE's ability to provide a clear picture of the maturity of these 
technologies to policymakers, utility officials, and others; 

* Congressional and other oversight of the hundreds of millions DOE is 
spending on these technologies; 

* Policymakers' ability to assess the maturity of CCS and the 
resources that might be needed to achieve commercial deployment. 

Objective 1: Maturity of Key Technologies: Other Agencies Charged with 
Developing Technologies use TRLs to Characterize Technologies' 
Maturity: 

TRLs were developed by National Aeronautics and Space Administration 
(NASA), and the agency began using them in the mid 1990s
In 2002, Department of Defense (DOD) specified TRLs as preferred 
method to conduct technology assessments of weapons programs
TRLs provide a standardized terminology to rank and describe maturity 
of technologies on a scale of 1 to 9: 

Table: 

TRL: 9; 
Summary of TRL descriptions used by NASA: Actual system "flight 
proven" through successful mission operations under operational 
mission conditions. 

TRL: 8; 
Summary of TRL descriptions used by NASA: Actual system completed and 
"flight qualified" through test and demonstration. Examples include 
developmental test and evaluation of the system in its intended 
weapons system to see if it meets design specifications. 

TRL: 7; 
Summary of TRL descriptions used by NASA: System prototype 
demonstration in realistic environment. Requires demonstration of 
actual system prototype in a realistic environment, such as an 
aircraft vehicle or space. 

TRL: 6; 
Summary of TRL descriptions used by NASA: System/subsystem model or 
prototype demonstration in a relevant environment. 

TRL: 5; 
Summary of TRL descriptions used by NASA: Component and/or breadboard 
validation in a relevant Environment, which could be lab or simulated 
realistic environment. 

TRL: 4; 
Summary of TRL descriptions used by NASA: Component and/or breadboard 
validation in lab environment. 

TRL: 3; 
Summary of TRL descriptions used by NASA: Proof of concept in lab 
environment. 

TRL: 2; 
Summary of TRL descriptions used by NASA: Technology concept and/or 
application formulated. 

TRL: 1; 
Summary of TRL descriptions used by NASA: Basic principles observed 
and reported. 

Source: GAO analysis of NASA data. 

[End of table] 

Objective 1: Maturity of Key Technologies: DOE Has Acknowledged TRLs 
as Key Practice in Contracting, and Some DOE Offices are Using This 
Tool: 

DOE's Technology Readiness Assessment Guide lays out three key steps 
in making a technology readiness assessment during the contracting 
process[Footnote 6]: 

* Identify critical technology elements that are essential to 
successful operation of the facility; 
* Assess maturity of these critical technologies using TRLs; 
* Develop a technology maturity plan which identifies activities 
required to bring technology to desired TRL level: 
- Describes current state of technology; 
- Describes schedule and budget to move technology to necessary 
readiness level. 

Use of the Guide is not mandatory. 

DOE offices have begun to use the Guide or TRLs: 
* Office of Environmental Management uses the Guide as part of 
managing its procurement activities—a result of a GAO recommendation; 
* Office of Nuclear Energy has begun using TRLs to measure and 
communicate risks associated with using critical technologies in a 
novel way; 
* National Nuclear Security Administration has used TRLs recently as 
well; 

Objective 1: Maturity of Key Technologies: We Asked Stakeholders With 
Expertise in Technologies to Gauge Maturity Using a Scale Based on 
TRLs: 

In the absence of a DOE assessment of maturity, we developed a scale 
for coal technologies based on TRLs in consultation with the Electric 
Power Research Institute (EPRI), which used a similar approach recently.
[Footnote 7] 

GAO has used TRLs to gauge the maturity of technologies: 

Table: 

TRL: 9; 
Description of TRLs we developed for coal technologies: Commercial 
operation in relevant environment (500 megawatt MW] coal plant or 
greater, or about 3 million tons of CO2 captured, transported, or 
stored annually)[A]. 

TRL: 8; 
Description of TRLs we developed for coal technologies: Demonstration 
at more than 25% commercial scale (at least 25 MW coal plant, or about 
575,000 tons of CO2 captured, transported, or stored annually). 

TRL: 7; 
Description of TRLs we developed for coal technologies: Pilot scale at 
more than about 5% commercial scale (at least 20 MW coal plant, or 
100,000 tons of CO2 captured, transported, or stored annually). 

TRL: 6; 
Description of TRLs we developed for coal technologies: Process 
development unit at between about 0.1% to 5% of commercial scale 
(between 0.5 MW and 20 MW coal plant, or between about 3,000 and 
100,000 tons of CO2 captured, transported, or stored annually). 

TRL: 5; 
Description of TRLs we developed for coal technologies: Component 
validation in relevant environment (coal plant). 

TRL: 4; 
Description of TRLs we developed for coal technologies: Component 
tests in lab. 

TRL: 3; 
Description of TRLs we developed for coal technologies: Proof of 
concept test. 

TRL: 2; 
Description of TRLs we developed for coal technologies: Application 
formulated (on paper). 

TRL: 1; 
Description of TRLs we developed for coal technologies: Basic 
principles observed. 

[A] Actual CO2 emissions can vary based on several factors, including 
how often a plant operates. 

[End of table] 

Objective 1: Maturity of CCS Technologies: Components of CCS Widely 
Used in Other Industries, and a Few Integrated CCS Projects Are 
Operating: 

CO2 capture widely used in natural gas and chemical industries: 

* CO2 captured while refining natural gas; 
* CO2 captured when gasifying coal to make chemical products such as 
fertilizer, hydrogen, and synthetic natural gas. 

CO2 transported and injected for enhanced oil recovery (EOR) for over 
35 years: 

* CO2 injected underground to help increase amount of oil recovered; 
* EOR operations in the U.S. inject about 50 million tons of CO2 
annually, about half of which remains stored underground, according to 
oil industry officials; 
* EOR highlighted as a beneficial reuse of captured CO2. 

There are a few integrated CCS projects in these industries: 

* Sleipner and Snohvit (located in North Sea) and In Salah (located in 
Algeria) are natural gas processing facilities: 
- All capture about 1 million tons of CO2 annually and store it in 
saline aquifers; 
* Great Plains Synfuels Plant, located in North Dakota: 
- Captures over 3 million tons of CO2 and transports about 2 million 
tons of CO2 annually to the Weyburn oil field in Canada for EOR use. 

Objective 1: Maturity of CCS Technologies: Stakeholders Reported CO2 
Capture at Coal Plants Is at Small Scale: 

Post-combustion capture: 

* Stakeholders generally reported largest demonstration is at pilot 
scale (TRL 7) using our scale; 

* Largest project taking place is at Mountaineer Plant in WV, which 
aims to capture over 100,000 tons of CO2, according to DOE and EPRI. 

Pre-combustion capture: 

* Stakeholders offered a range of views on maturity from formulations 
on paper (TRL 2) to commercial (TRL 9): 
- Some stakeholders said technology is commercial in other industries 
similar to IGCC plants, such as the Great Plains Synfuels Plant, which 
captures 3 million tons of CO2; 
- Other stakeholders said that pre-combustion capture had not been 
demonstrated in an IGCC plant and that capturing a large proportion of 
CO2 at an IGCC plant required further demonstration of a class of 
turbines suitable for use with hydrogen fuels. 

Oxy-combustion capture: 

* Stakeholders about evenly split between ranking maturity as pilot 
scale (TRL 7) or process development unit (TRL 6); 

* Largest project taking place is at Schwarze Pumpe in Germany, which 
is a 10 MW scale and aims to capture about 75,000 tons of CO2 annually 
according to DOE and EPRI. 

Stakeholder views on maturity are generally consistent with a 2009 
report by the Global CCS Institute that used TRLs.[Footnote 8] 

Objective 1: Maturity of CCS Technologies: Only One Integrated CCS 
Project Operating in a Coal Plant, but DOE Has Announced Funding for 
Additional Projects: 

The only integrated CCS project in a coal power plant is the 
Mountaineer Plant in WV according to stakeholders:[Footnote 9] 

* CO2 is captured from slipstream of plant's total exhaust with goal 
of capturing, transporting, and storing over 100,000 tons annually; 

* Equal to about 20 MW capacity (1.5% of total plant output). 

DOE has announced funding for five integrated CCS projects in coal 
plants through the CCPI (see table below). 

Table: 

Project name: NRG; 
DOE award: $154 million; 
Project goals: Construct 60 MW demonstration facility using post-
combustion capture technology, with captured CO2 to be used for EOR. 

Project name: Mountaineer; 
DOE award: $334 million; 
Project goals: Capture 90% of CO2 from 235 MW flue gas slipstream on 
1300 MW plant using post-combustion capture technology. 1.65 million 
tons of CO2 captured annually will be stored in nearby saline aquifer. 

Project name: Texas Clean Energy Project; 
DOE award: $350 million; 
Project goals: Build 400 MW IGCC plant and capture 90% of CO2 using 
pre-combustion capture technology. Over 2.9 million tons of CO2 
captured annually will be used for EOR. 

Project name: Antelope Valley; 
DOE award: $100 million; 
Project goals: Capture 90% of CO2 from 120 MW flue gas slipstream at 
existing 450 MW plant. One million tons of CO2 will be captured 
annually and could be used for EOR or stored in saline aquifers. 

Project name: Hydrogen Energy; 
DOE award: $308 million; 
Project goals: Build advanced IGCC plant that is 250 MW and capture 2 
million tons of CO2 annually to be used for EOR. 

Source: GAO summary of CCPI funding announcements. 

Note: Additional integrated CCS projects are planned around the world, 
but not yet operating. 

[End of table] 

Objective 1: Maturity of CCS Technologies: CO2 Compression and 
Transport Commercially Demonstrated; 

Nearly all stakeholders reported CO2 compression and transport 
demonstrated commercially (TRL 9). 

CO2 is commonly compressed as part of transporting CO2. 

There are more than 3,900 miles of pipelines used to transport CO2 in 
the U.S. 

* These pipelines are primarily used to transport CO2 for FOR projects 
in certain areas of the U.S. 

* Some of these pipelines have the capacity to transport between 2-10 
million tons of CO2 annually. 

Objective 1: Maturity of CCS Technologies: CO2 Storage in Oil 
Reservoirs Considered More Mature than Storage in Saline Aquifers: 

CO2 widely injected into oil formations to enhance recovery resulting 
in some storage: 

* Stakeholders generally considered technology commercially 
demonstrated (TRL 9); 

* About 50 million tons of CO2 injected annually to stimulate 
additional recovery of oil from wells, and about half remains stored 
in the formation initially.[Footnote 10]. 

CO2 storage in saline aquifers still being demonstrated: 

* Stakeholders about evenly split between describing maturity at 
commercial (TRL 9) or demonstration scale (TRL 8); 

* Two industrial projects (Sleipner and In Salah) have been injecting 
over 1 million tons of CO2 annually into saline formations; 

* DOE's Sequestration Program has 7 projects that aim to store over 
1,000,000 tons of CO2 in the future, and the majority of these 
projects are to begin injecting into saline aquifers in 2011 or later. 

Objective 1: Maturity of Key Technologies: Efficiency Improvements 
Have Been Deployed Commercially at New and Existing Plants: 

Efficiency technologies deployed at new plants: 

* Most stakeholders considered ultrasupercritical and IGCC plants 
commercially demonstrated (TRL 9); 

* A few stakeholders considered IGCC plants less mature than 
ultrasupercritical; 

* A number of ultrasupercritical plants ranging from 600 to over 1,000 
MW have been built or are under construction in Europe and Asia, with 
one under construction in U.S.[Footnote 11]; 

* Five IGCC plants are operating globally, including two in the U.S. 
with another under construction[Footnote 12]. 

Efficiency technologies deployed at existing plants: 

* Stakeholders told us efficiency upgrades had been deployed at 
commercial scale (TRL 9); 

* About 10% of U.S. coal plants undertook large efficiency 
improvements between 1998 and 2008 according to DOE analysis.{footnote 
13] 

Objective 2: Challenges to Use of Key Technologies: Commercial 
Deployment Possible, but Contingent on Overcoming Economic, Technical, 
and Legal Challenges: 

Commercial deployment of CCS possible within 10-15 years, but faces 
major challenges according to reports and stakeholders: 

* Current CCS technologies are costly to install and operate; 

* Demonstration of large scale integrated CCS systems needed to assure 
stakeholders; 

* U.S. lacks national carbon policy or legal framework to govern CO2 
storage. 

Many efficiency technologies have been used and are available for 
commercial use, but still face challenges: 

* High efficiency coal plants may not be cost-effective; 

* Some higher efficiency plant designs not fully demonstrated and 
require advanced materials; 

* Improvements made to existing plants may trigger additional 
regulatory requirements. 

Objective 2: Challenges to Use of Key Technologies: Several Groups 
Expect CCS Deployment in 10-15 Years: 

Table: 

Stakeholder group: DOE; 
Goals for commercial deployment of CCS: Widespread, affordable 
deployment of CCS should begin in 8-10 years. 

Stakeholder group: National Coal Council; 
Goals for commercial deployment of CCS: By 2020, deployment of CCS in 
5 to 7 gigawatts worth of power plants as part of a "pioneer phase of 
deployment. 

Stakeholder group: IEA; 
Goals for commercial deployment of CCS: Commercial deployment of CCS 
should begin by 2025 

Stakeholder group: Coal Utilization Research Council, an industry 
group, and EPRI; 
Goals for commercial deployment of CCS: Identifies family of 
technologies to reduce emissions from coal plants, including CCS and 
efficiency technologies by 2025. 

Source: GAO summary of relevant reports. 

[End of table] 

Objective 2: Challenges to Use of CCS Technologies: Economic: Current 
CCS Technologies are Costly to Install and Operate: 

Current CCS technologies are costly to install: 

* In 2007 DOE estimated initial capital investment costs could be: 
- 85% higher for plants with post-combustion capture and; 
- 36% higher for pre-combustion capture at IGCC plants, compared to 
comparable plants without CCS[Footnote 14]; 

* Electric utilities not likely to adopt costly technologies without 
assured cost recovery. 

Current CCS technologies require significant energy to operate, 
reducing the electricity plants can sell and raising operating costs: 

* Parasitic loads—-energy used onsite-—for current CCS technologies 
are estimated to be: 
- between about 21% and 32% of plant output for post-combustion; 
- between 15% and 22% of plant output for pre-combustion;[Footnote 15] 

* DOE devoting R&D money to develop novel CO2 capture technologies to 
lower the parasitic road, but these remain at smaller scale: 
- DOE is funding post-combustion work on membranes, sorbents, and 
solvents in the hope of lowering the current cost of CO2 capture; 
- Research is also being conducted on using captured CO2 to grow 
algae, a potential liquid transportation fuel. 

Objective 2: Challenges to Use of CCS Technologies: Technical: 
Demonstration of Large Scale Integrated CCS Systems Needed to Assure 
Stakeholders: 

Key studies report that demonstration of large scale integrated CCS 
systems is needed to: 

* Demonstrate the performance and potential costs of these systems; 

* Gain experience in designing and building systems to help drive down 
the costs of these technologies. 

Some stakeholders also reported that additional demonstration needed 
to lower perceived risk of technologies: 

* Officials from one large electric utility told us that demonstration 
projects were needed to build experience with the technologies and to 
build vendor confidence so that they could provide technology 
performance guarantees; 

* Officials from one state public utility commission reported that 
they considered CCS immature and were unlikely to approve cost 
recovery for a plant with CCS in the foreseeable future; 

* Officials from two financial firms reported that they considered the 
application of CCS technologies at coal plants largely unproven and 
they would require additional demonstration projects and performance 
guarantees from technology vendors to help reduce the risk of 
financing these projects. 

Objective 2: Challenges to Use of CCS Technologies: Legal: U.S. Lacks 
National Carbon Policy or Legal or Regulatory Framework to Govern CO2 
Storage: 

Without national carbon policy, nearly all stakeholders said CCS would 
not be widely deployed: 

* Without a tax or A sufficiently restrictive limit on CO2 emissions, 
plant operators lack economic incentive to reduce emissions; 
* Reports by IPCC, NAS, and Global CCS Institute have all highlighted 
the importance of a carbon policy to incentivize the use CCS; 
* Such a policy driver could help to accelerate the development of CCS. 

Lack of a regulatory framework for storing CO2 and uncertainty 
regarding liability for stored CO2 are also challenges: 

* Nearly all stakeholders reported these as large or very large 
challenges to storing CO2; 
* EPA to issue a final rule for infection of CO2 for geologic 
sequestration in fall 2010 under the Safe Drinking Water Act (SDWA): 
- EPA lacks authority to release well operators from liability for 
endangerment of underground sources of drinking water until the 
operator meets all of the closure and post-closure requirements and 
EPA approves site closure; 
- Once site closure is approved, operators are only liable under the 
SDWA for violating or failing to comply with EPA orders in situations 
that pose an imminent and substantial endangerment; 
- Potential storage site operators are unlikely to assume this risk; 
* EPA's rule will not address who is liable for unintended releases of 
stored CO2 that have other harmful effects; 
* Determining ownership of subsurface pore space presents additional 
challenge. 

Objective 2: Challenges to Use of Efficiency Technologies: Economic: 
High Efficiency Coal Plants May Not Be Cost-Effective: 

Low prices for coal and other fuels in the U.S. may limit the 
incentive to build more efficient, but costly, plants: 

* Ultrasupercritical plants have.higher capital costs because they use 
advanced materials, which may not justify expected fuel savings; 
* IGCC plants are more expensive than pulverized coal units, and there 
are few in operation globally; 
* If low natural gas prices persist, utilities may choose to build 
natural gas power plants to reduce CO2 emissions in lieu of efficient 
coal plants. 

Incentives complicate construction of more efficient plants in 
regulated states: 

* Building new, more efficient coal plants faces hurdles: 
- State utility commission approval required to build new plants; 
- Demonstrating merits of more efficient plants may be difficult; 
* Fuel clauses may limit utility interest in fuel savings: 
- Some utilities can "pass through" coal price increases to customers 
using fuel adjustment clauses. 

To date, all of the more efficient ultrasupercritical plants have been 
built outside the U.S., where coal prices are generally higher. 

A tax or limit on CO2 emissions could increase the price of coal and 
help to incentivize the adoption of efficiency technologies. 

Objective 2: Challenges to Use of Efficiency Technologies Technical: 
Some Higher Efficiency Plant Designs Not Fully Demonstrated and 
Require Advanced Materials: 

Some advanced power plant designs require materials that can withstand 
more extreme conditions than those found in current plants. 

"Advanced" ultrasupercritical plants require development of metal 
alloys to withstand steam temperatures that could be 300 to 500 
degrees Fahrenheit higher than today's ultrasupercritical plants.
[Footnote 16] 

Advanced IGCC plants require development of certain components, 
including more efficient ways to generate oxygen and improved 
gasifiers that can gasify coal at higher pressures. 

Objective 2: Challenges to Use of Efficiency Technologies Regulatory: 
Improvements May Subject Existing Plants to Additional Regulations: 

Most stakeholders said the Clean Air Act's New Source Review (NSR) 
requirements limit efficiency improvements at existing plants: 

* NSR is triggered when a company constructs new facilities or makes a 
major modification—a physical or operational change that would result 
in a significant net increase in emissions; 

* Under NSR, permitting authorities establish emissions limits for the 
facility and ensure the appropriate pollution controls will be used. 

Several stakeholders said that utilities could improve their plants' 
efficiency but were reluctant to do so because they feared this would 
trigger NSR which could require the installation of costly pollution 
controls. 

Objective 3: Implications of Using Key Technologies: CCS Offers More 
Potential to Reduce CO2 Emissions than Efficiency Improvements Alone, 
and Both Could Have Cost and Other Effects: 

CCS has positive and negative implications: 

* A key advantage is that CCS could help meet GHG limits and allow 
coal to remain part of the nation's fuel mix; 
* The use of CCS raises some key concerns: 
- Electricity costs and demand for water could increase;[Footnote l7] 
- Could affect ability of individual plants to operate reliably. 

Technologies to improve the efficiency of coal plants have positive 
and negative implications: 
* A key advantage is that plant efficiency improvements offer more 
potential for near term emissions reductions; 
* The use of efficiency technologies raises some concerns: 
- Unlikely to meet ambitious cuts in CO2 by themselves; 
- Stakeholders had mixed views on other potential effects, such as 
cost. 

Objective 3: Implications of Using CCS: CCS Could Help Meet GHG Limits 
and Allow Coal to Remain Part of Fuel Mix: 

Key reports have highlighted the key role that CCS could have in 
meeting potential limits on GIG emissions: 

* EPRI — Estimated that CCS could help meet 1?8% of reductions needed 
to reduce emissions in electricity sector by 41% by 2030;[Footnote 18] 

* IEA — Estimated that CCS could meet 20% of reductions needed to 
reduce global CO2 emissions by halt by 2050:[Footnote 19] 
- Both studies note that cost of meeting these limits would increase 
if CCS not deployed. 

CCS could allow coal to remain part of fuel mix according to 
stakeholders and reports: 

* Majority of stakeholders said CCS would allow coal to remain part of 
fuel mix for generating electricity; 

* Massachusetts Institute of Technology (MIT) researchers called CCS 
the "critical enabling technology" to reduce CO2 emissions while 
allowing continued use of coal in the future;[Footnote 20] 

* NAS stated if CCS does not develop, electricity sector could move 
more towards using natural gas to meet emissions targets;[Footnote 21] 

* GAO's past work found that switching from coal to natural gas could 
lead to higher fuel costs, and increased exposure tO the greater price 
volatility of natural gas.[Footnote 22] 

Objective 3: Implications of Using CCS: CCS Could Increase Electricity 
Costs and Water Demand: 

Most stakeholders told us that CCS would likely increase electricity 
costs In addition, key reports have estimated potential cost increases: 

* MIT estimated that plants with post-combustion capture have 61% 
higher cost of electricity and IGCC plants with pre-combustion capture 
have a 27% higher cost;[Footnote 23] 
* DOE estimated that plants with post-combustion capture have 83% 
higher cost of electricity, while IGCC plants with pre-combustion 
capture have a 36% higher cost;[Footnote 24] 

DOE has raised concerns about water consumption associated with CCS: 

* DOE estimated that post-combustion capture technology could almost 
double water consumption at a coal plant, while pre-combustion capture 
could increase water use by 73%; 
* DOE officials said that continued development of CCS and cooling 
technologies could significantly reduce water use for CCS. 

Objective 3: Implications of Using CCS: CCS Could Compromise 
Reliability: 

Some utility officials said CCS could lead to decline in reliability 
of individual plants: 

* A power plant might need to shut down if any of the three components 
(capture, transportation, storage) of CCS became unavailable; 

* Such unplanned shutdowns could impact reliability of electric supply. 

Other sources of electricity would need to make up for the parasitic 
load associated with CCS 

National Coal Council reported temporary declines in reliability 
during past deployments of new coal technologies.[Footnote 25] 

Objective 3: Implications of Using Efficiency Technologies: Plant 
Efficiency Improvements Offer Potential for Near Term Emissions 
Reductions but Raise Some Concerns: 

Plant efficiency improvements offer potential for near term emissions 
reductions: 

* Making efficiency upgrades to existing fleet can happen much sooner 
than building new, more efficient plants; 

* DOE estimates that efficiency improvements could reduce CO2 
emissions by 100 million tons annually, about an overall 5-10% 
reduction in fleet emissions; 

* According to National Coal Council, increasing efficiency is "only 
practical method for mitigating CO2 emissions now" in coal plants.
[Footnote 26] 

Plant efficiency improvements alone cannot reduce CO2 emissions from a 
coal plant to the same extent as CCS according to DOE and others: 

* Ultrasupercritical coal plant with 44% efficiency will emit about a 
one-third less CO2 than an average U.S. plant; 

* Upgrades made to existing plants can improve efficiency by a few 
percentage points, resulting in a decline in CO2 emissions from the 
plant by about 5-10%; 

* CCS offers potential to capture 90% of a plant's CO2 emissions; 

* Efficiency improvements the can however, facilitate CCS because they 
help reduce the amount of CO2 to be handled by CCS system. 

Stakeholders had mixed views on other potential effects: 

* Stakeholders' views were mixed on potential effect on electricity 
costs; 

* Stakeholders generally did not think efficiency technologies would 
increase water demand or compromise reliability. 

[End of section] 

Concluding Observations: 

Addressing climate change while retaining the use of coal power plants 
will likely require the successful deployment of new technologies: 

* CCS, in particular, remains relatively immature compared to 
efficiency technologies; 
* Some of the discussions surrounding regulatory efforts and proposed 
climate change legislation have focused on the commercial availability 
of CCS technologies; 

* DOE plays a key role in helping to accelerate commercial 
availability of CCS technologies and is spending hundreds of millions 
of dollars annually for this effort; 

* Standards for internal controls require agency managers to compare 
actual program performance to planned or expected results and analyze 
significant differences; 

* DOE is not systematically. assessing the maturity or progress of CCS 
or other advanced coal technologies toward commercialization; 

* As a result, DOE cannot provide: 
- A clear picture of the maturity of technologies, and resources 
needed to achieve commercial demonstration; 
- Critical information for policymakers as they consider climate 
change policies. 

[End of section] 

Potential Next Steps for DOE: 

Develop a standard set of benchmarks to gauge the maturity of key coal 
technologies and report to Congress on the maturity of these 
technologies. 

Consider using its Technology Readiness Assessment Guide to develop 
benchmarks and reporting requirements for coal technologies. 

[End of section] 

Briefing Slides Footnotes: 

[1] This analysis also found that the top 10% of the U.S. coal fleet 
had an average efficiency of 37.6%. See DOE, Improving the Efficiency 
of Coal-Fired Power Plants for Near Term Greenhouse Gas Emissions 
Reductions (April 16, 2010). 

[2] For the purposes of this report, we have defined 
ultrasupercritical to mean steam temperatures of about 1,100 degrees 
Fahrenheit. 

[3] EPA must determine whether certain CCS deployment criteria are 
met, including whether commercial power plants and other stationary 
sources have captured and sequestered at least 12 million tons of CO2 
annually to trigger the emission reduction requirement before 2025. 

[4] We selected this nonprobability sample of states because they 
contained projects involving advanced coal technologies. 

[5] TRLs are used to gauge technology maturity and use a 9 point scale 
to rate the extent to which technologies have been demonstrated to 
work as intended. 

[6] DOE, Technology Readiness Assessment Guide, DOE G413.3-4, 
(Washington D.C., Oct. 12, 2009). 

[7] EPRI is an independent nonprofit company funded by electricity 
producers that conducts research and development in the electricity 
sector. EPRI's work was part of the following report: Global CCS 
Institute, Strategic Analysis of the Global Status of Carbon Capture 
and Storage: Synthesis Report (Canberra, Australia, 2009). 

[8] Global CCS Institute, Strategic Analysis of the Global Status of 
Carbon Capture and Storage: Synthesis Report. 

[9] While gasifying coal to make synthetic natural gas, the Great 
Plains Synfuels plant captures and transports CO2 for EOR use. 
However, this plant does not produce electricity. 

[10] According to oil industry officials, the other half of the CO2 is 
captured during the process of recovering oil to be injected again for 
EOR. They also reported that the intention of EOR is to recover 
additional oil, not to store CO2, but this is an unintended 
consequence of injecting the CO2. The Global CCS Institute has 
reported that experiences with EOR have yielded experience with 
transporting and injecting CO2, but have yielded little information on 
CO2 storage and long-term monitoring of the stored CO2. 

[11] This ultrasupercritical plant is known as the John W. Turk, Jr. 
Plant. This 600 MW plant is being built in Arkansas and is scheduled 
to be completed in 2012. 

[12] This IGCC plant is known as the Edwardsport plant. This 630 MW 
plant is being built in Indiana and is scheduled to be completed in 
2012. 

[13] DOE, Improving Efficiency of Coal-Fired Power Plants for Near 
Term Greenhouse Gas Emissions Reductions (Feb. 25, 2010). 

[14] DOE, Cost and Performance Baseline for Fossil Energy Plants—
Volume 1: Bituminous Coal and Natural Gas to Electricity, Final Report 
(2007). 

[15] MIT. The Future of Coal (Cambridge, Mass. 2007). DOE. Cost and 
Performance Baseline for Fossil Enerav Plants—Volume 1. 

[16] Today's ultrasupercritical plants have steam temperatures of 
about 1,100 degrees Fahrenheit. DOE has a goal to develop materials to 
withstand steam temperatures of 1,400 to 1,600 degrees Fahrenheit. 

[17] Water is needed to generate electricity and process fuels to 
generate electricity. Due to the parasitic load associated with 
current CCS technologies, more electricity must be produced to supply 
the same amount of electricity to consumers, leading to additional 
water consumption. See GAO, Energy-Water Nexus: Improvements to 
Federal Water Use Data Would Increase Understanding of Trends in Power 
Plant Water Use, [hyperlink, http://www.gao.gov/products/GAO-10-23] 
(Washington, D.C.: Oct. 16, 2009). 

[18] EPRI, PRISM/MERGE Analysis (Palo Alto, California, 2009). 

[19] IEA, Technology Roadmap: Carbon capture and storage (Paris, 
France, 2009.) 

[20] MIT, The Future of Coal. 

[21] NAS, America's Energy Future (Washington, D.C., 2009). 

[22] GAO, Economic and Other Implications of Switching from Coal to 
Natural Gas at the Capital Power Plant and at Electricity-Generating 
Units Nationwide, [hyperlink, http://www.gao.gov/products/GAO-08-601R] 
(Washington, D.C.: May 1, 2008). 

[23] MIT, The Future of Coal. 

[24] DOE. Cost and Performance Baseline for Fossil Enerav Plants—
Volume 1. 

[25] National Coal Council, Low-Carbon Coat Meeting U.S. Energy, 
Employment and CO2 Emission Goals with 21st Century Technologies 
(Washington, D.C., December 2009). 

[26] National Coal Council Issue Paper, Higher Efficiency Power 
Generation Reduces Emissions (2009). 

[End of Appendix I] 

Appendix II: Scope and Methodology: 

To conduct this work, we reviewed key reports including those from the 
Department of Energy's (DOE) national laboratories, the National 
Academy of Sciences, International Energy Agency (IEA), 
Intergovernmental Panel on Climate Change, Global CCS Institute, the 
National Coal Council, and academic reports. 

To identify stakeholders' views on these technologies, we conducted 
initial scoping interviews with power plant operators, technology 
vendors, and federal officials from the Environmental Protection 
Agency (EPA) and DOE. Following this initial round of interviews, we 
selected a group of 19 stakeholders with expertise in carbon capture 
and storage (CCS) or technologies to improve coal plant efficiency and 
asked them a set of standard questions. This group of stakeholders 
included representatives from major utilities that are planning or 
implementing projects that use these technologies, technology vendors 
that are developing these technologies, federal officials that are 
providing research, development, and demonstration funding for these 
technologies, and researchers from academia or industry that are 
actively researching these technologies. 

During these interviews, we asked stakeholders to describe the 
maturity of technologies in terms of a scale we developed, based on 
Technology Readiness Levels (TRL). TRLs are a tool developed by the 
National Aeronautics and Space Administration and used by various 
federal agencies to rate the extent to which technologies have been 
demonstrated to work as intended using a scale of 1 to 9. In 
developing TRLs for coal technologies, we consulted with the Electric 
Power Research Institute (EPRI), which had recently used a similar 
approach to examine the maturity of coal technologies.[Footnote 27] 
Specifically, EPRI developed specific benchmarks to describe TRLs in 
the context of a commercial scale coal power plant. For example, they 
defined TRL 8 as demonstration at more than 25 percent the size of a 
commercial scale plant. We applied these benchmarks to a commercial 
scale power plant, which we defined as 500 megawatts (MW) and emitting 
about 3 millions tons of carbon dioxide (CO2) annually. We based this 
definition on some of the key reports we reviewed, which used 500 MW 
as a standard power plant, and stated that such a plant would emit 
about 3 million tons of CO2. Actual CO2 emissions from a power plant 
can vary based on a variety of factors, including the amount of time 
that a power plant is operated. We also reviewed available data on the 
use of key coal technologies compiled by IEA and the Global CCS 
Institute. 

To identify the potential for these technologies to be used 
commercially in the future along with any associated challenges or 
implications, we reviewed key reports on CCS and efficiency 
technologies. We also examined reports developed by DOE, IEA, and 
electricity industry groups, which lay out goals for the deployment of 
advanced coal technologies to reduce CO2 emissions. We also used our 
interviews with stakeholders with expertise on these technologies to 
seek their views on the potential challenges to the commercial 
deployment of these technologies and implications that could be 
associated with their use. 

Finally, we conducted site visits to coal power plants and research 
facilities in three states--Alabama, Maryland, and West Virginia. We 
selected this nonprobability sample of states because they contained 
projects involving advanced coal technologies. During these visits, we 
interviewed utilities and technology vendors about the goals for these 
projects along with any challenges they were encountering. 

[End of section] 

Appendix III: Comments from the Department of Energy: 

Note: GAO comments supplementing those in the report text appear at 
the end of this appendix. Page numbers in draft report may differ from 
those in this report. 

Department of Energy: 
Washington, DC 20585: 

June 4, 2010: 

Mr. Mark E. Gaffigan: 
Director: 
Natural Resources and Environment Team: 
U.S. Government Accountability Office: 
441 G Street, NW, Mail 2T23A: 
Washington, DC 20548: 

Dear Mr. Gaffigan: 

Thank you for the opportunity to review the Government Accountability 
Office (GAO) draft report entitled, "Coal Power Plants: Opportunities 
Exist for DOE to Provide Better Information on the Maturity of Key 
Technologies to Reduce Carbon Dioxide Emissions" (GAO-10-675) Enclosed 
pleased find the U S Department of Energy's comments on the draft 
report. 

If you have any questions or comments please contact Dr. Darren Mollot 
of my staff at (301) 903-2700. 

Sincerely, 

Signed by: 

James J. Markowsky: 
Assistant Secretary: 
Office of Fossil Energy: 

Enclosure: 

DOE Comments on Draft GAO Report: 

[End of letter] 

Department of Energy Comments on GAO "Coal Power Plants: Opportunities 
Exist for DOE to Provide Better Information on the Maturity of Kev 
Technologies to Reduce Carbon Dioxide Emissions (GA0-10-675) (GAO 
Draft Report): 

This responds to your request for comments by the Department of Energy 
on the above referenced GAO Draft Report. 

Our main response is that we agree with GAO's statement that DOE plays 
a "key role" in working to advance carbon capture and storage (CCS) 
and efficiency technologies toward commercialization and in helping 
policy makers have an accurate view of their maturity (pages 3, 14, 
53). However, we take some exception with GAO's assessment that DOE is 
unable to provide a clear picture of the maturity of these 
technologies or quantify the necessary resources that might be 
required to move these technologies toward commercial demonstration 
(this assertion can be found in several places within the report 
including pages 6, 14, 30, 53). [See comment 1] 

The Office of Fossil Energy (FE) acknowledged that it could improve 
upon its current process of providing a clearer picture of technology 
maturity. FE, working with several national labs, conducts a great 
deal of research, development, and demonstration activities on CCS and 
other carbon reduction technologies. These efforts are reported, 
analyzed, reviewed, and studied, the outcomes from which frequent and 
continued assessments are made regarding the current status of CCS 
technologies including their commercial readiness. Included in many of 
these assessments are specific development timelines that can be used 
to ascertain how long development will take, and how much development 
will likely cost These activities also feed into the development of 
CCS Roadmaps (e.g. Carbon Sequestration Technology Roadmap and Program 
Plan [hyperlink, 
http://www.netl.doe.gov/technologies/carbon_seq/refshelf/project%2Oportf
olio/2007/2007Roadmap.pdf]) for the specific development of core CO2 
reduction technologies. These activities and others collectively paint 
a very accurate picture of the current status of CCS technologies, and 
provide an excellent gauge on what resources would need to be 
committed in order to achieve deployment of CCS by the 2020 timeframe. 
[See comment 1] 

Furthermore, GAO made the following recommendation beginning on page 
14 (also repeated on pages 6-8, and the lower left hand corner of the 
front cover): 

"We recommend that the Secretary of Energy direct the Office of Fossil 
Energy to develop a standard set of benchmarks to gauge the maturity 
of key technologies and report to Congress on the maturity of these 
technologies. As part of this process, the Office of Fossil Energy 
should consider consulting DOE's Technology Readiness Assessment Guide 
to develop benchmarks and reporting requirements." 

Consistent with our continued efforts to supply policy makers with 
clear information in a form more amenable for them to gauge the 
maturity of CCS technologies, we concur with this recommendation. The 
Office of Fossil Energy will commit to develop a Corrective Action 
Plan, and will, at regular intervals, report to Congress on the status 
of its actions toward instituting GAO's recommendation. 

Specific clarifying comments on the GAO report are as follows: 

1. On page 28, the report states: 

"DOE does not systematically assess the maturity of key coal 
technologies, but we found consensus among stakeholders that CCS is 
less mature than efficiency technologies." 

Although DOE has not assessed the maturity of coal technologies using 
technology readiness levels (TRLs), we are very aware of the maturity 
of all the technologies in the portfolio. We plan to do a formal TRL 
assessment in the neat future. 

It would also he important to clarify the precise meaning of the term, 
"efficiency technologies" in this context. There is a considerable 
difference between improving coal plant efficiencies as opposed to 
more efficient light bulbs. [See comment 2] 

Furthermore, this is an overly broad statement. For example, one could 
argue that post-combustion CO2 capture via amine scrubbing, plus 
enhanced oil recovery (EOR) for CO2 storage, is much more mature than 
1400°F ultrasupercritical "efficiency" technology. [See comment 2] 

2. In response to the comments on page 30, we would like to point out 
that we are currently in compliance with the policy stated in bullet 
point #1: 

"Federal standards for internal control require agency managers to 
compare actual program performance to planned or expected results and 
analyze significant differences." 

The way this particular set of points is organized gives the 
appearance that DOE may not be fulfilling this Federal standard 
However, variances are routinely calculated and analyzed in accordance 
with these standards. [See comment 3] 

3. On page 35, the report states that there is: 

"Only One Integrated CCS Project Operating in a Coal Plant" and goes 
on to state, "The only integrated CCS project in a coal plant is the 
Mountaineer Plant in WV according to stakeholders." 

There is a second integrated CCS project operating in a coal plant. It 
is the Great Plains Gasification plant. In this project, the CO2 is 
captured and piped to Canada for Enhanced Oil Recovery (EOR) where it 
is permanently stored. [See comment 4] 

4. Page 39 discusses several issues related to efficiency technologies 
being deployed at new plants: 

"Most stakeholders considered ultrasupercritical and IGCC plants 
commercially demonstrated (TEL 9)." 

and: 

"A few stakeholders considered IGCC plants less mature than 
ultrasupercritical." 

With respect to both statements, it is necessary to define the 
Ultrasupercritical (USC) temperatures being discussed here. The 
Ultrasupercritical term has been used for plants ranging from 1112°F 
to 1400°F In addition, the Tampa and Wabash IGCCs are operating 
commercially today as are other IGCC plants outside the US at TRL=9. 
[See comment 5] 

5. The information presented on page 40 is potentially misleading as 
it attempts to compare the commercial deployability of CCS versus 
efficiency technologies. Efficiency improvements may give a few 
percentage points of improvement resulting in perhaps 10% reduction in 
CO2 emissions, whereas commercial deployment of CCS could result in 
90% or greater CO2 reductions. Also, CCS should be deployable by 2020. 
Moreover, CCS can be considered to be essentially deployable today 
with IGCC plus EOR, albeit with additional integration risks and 
financial incentive to do so. In summary, while the information on 
page 40 is accurate from a certain point of view, the perspective 
infers that the two approaches can be easily compared whereas the 
scope and benefits of the two approaches are very different. [See 
comment 6] 

6. Page 48 summarizes the positive and negative implications of using 
CCS versus efficiency technologies. With respect to the advantages of 
using plant efficiency improvements, the following statement is made: 

"A key advantage is that plant efficiency improvements offer more 
potential for near term emissions reductions." 

While this statement may be technically true, it is important to note 
that there is far less potential to achieve the deep CO2 reductions 
that will be needed to meet our nation's climate-related goals solely 
using efficiency technologies. It is important to have that in mind 
when making these kinds of general statements. [See comment 6] 

7. On page 50, the report states: 

"DOE has raised concerns about CCS water consumption" 

"DOE estimated that post combustion capture technology could almost 
double water consumption at a coal plant, while pre-combustion capture 
would increase water use by 37%." 

While this is true, it should also be mentioned that the continued 
development of advanced CCS and cooling technologies could 
significantly reduce water use for CCS. [See comment 7] 

8. While the information presented on page 22 is factually correct 
concerning existing coal plants, it is important to note that in 2008, 
the U.S coal-fired power plant (CFPP) fleet had a generation-weighted 
average efficiency of 32.5% while the top ten percent of the fleet had 
an efficiency of 37 6%, five percentage points higher [hyperlink, 
(http://www.netl.doe.gov/energy-
analyses/pubs/ImpCFPPGHGRdctns_0410.pdf]. Furthermore, "Ultra-
supercritical steam parameters of 4350 psi and 1112°F (300 bar
and 600°C) are in operation today with generating efficiencies of 40% 
(1111V) There are several years of experience with these plants in 
Europe and Japan, with excellent availability, and plans have been 
announced for several USC PC plants in the United States" [hyperlink, 
http://mydocs.epri.com/docs/public/000000000001016877.pdf] [see pages 
3-5]. [See comment 8] 

Future plants could go much higher in efficiency using USC with 1400°F 
steam temps or IGCC with solid oxide fuel cells 9. With respect to the 
assertion on page 46 that advanced ultrasupercritical plants requiring 
metal alloys that withstand 27% higher steam temperatures, we 
recommend that absolute temperatures are used. A percent increase in 
temperature value is only meaningful if you use absolute temperatures 
(Rankine or Kelvin) To advance from 1116°F to 1300°F using absolute 
temperatures would be a 12% increase in temperature and going further 
to 1400°F would be an 18% increase. Under the circumstances, it might 
be better to, just say "a temperature increase of 300°F to 400°F." 
[See comment 8] 

The following are GAO's comments on the Department of Energy's letter 
dated June 4, 2010. 

GAO Comments: 

1. We acknowledge that DOE publishes reports that assess the technical 
and economic feasibility of some advanced coal technologies and 
revised our report accordingly. While some of these reports provide 
valuable information, we found that the agency does not systematically 
review these technologies, have a standard set of benchmarks to 
describe the maturity of technologies as they progress to 
commercialization, or prepare a formal report on a regular basis to 
assess their maturity or the resources needed to advance technologies 
toward commercialization. We are encouraged that DOE acknowledges that 
improvements can be made to the information it provides to 
policymakers and concurs with our recommendation that the agency 
develop a standard set of benchmarks and report on the maturity of 
these technologies to Congress. Finally, the agency notes that it 
plans to do a formal assessment using TRLs of coal technologies in the 
near future in line with our recommendation. 

2. Our draft report defines efficiency technologies as referring to 
new power plant designs such as Integrated Gasification Combined Cycle 
and ultrasupercritical along with efficiency upgrades made to existing 
coal power plants. The statement in our draft report that CCS is less 
mature than efficiency technologies in coal power plants is based on 
stakeholder views of coal technologies using our TRL scale. Our draft 
report notes that certain aspects of CCS have been used commercially 
in other industries such as natural gas processing or enhanced oil 
recovery. In addition, the draft report indicates that one of the 
challenges to using advanced ultrasupercritical plants is the lack of 
metal alloys to withstand increased steam temperatures. 

3. We are not suggesting that DOE is not complying with this standard. 
This standard outlines the broad duties federal agencies have in 
managing their programs. Our finding discussed in our comment one 
above identifies that DOE could do more to improve its efforts to 
address this standard. 

4. We have revised our draft report to indicate that there is only one 
integrated CCS project in a coal power plant. DOE states that the 
Great Plains Synfuels plant is an integrated CCS project. We agree 
that this plant is capturing and transporting CO2 to be used as part 
of enhanced oil recovery in Canada's Weyburn oil field. However, this 
plant gasifies coal in order to make synthetic natural gas; it is not 
a coal power plant that produces electricity, which is the focus of 
our report. 

5. Our report defines ultrasupercritical plants as having steam 
temperatures of about 1,100 degrees Fahrenheit. 

6. We agree with DOE that there is a difference in the ability for CCS 
and efficiency technologies to achieve reductions in CO2 emissions 
from coal power plants. Specifically, our report states that the use 
of efficiency technologies by themselves are "unlikely to meet 
ambitious cuts in CO2." In addition, we state that efficiency 
technologies cannot reduce CO2 emissions from the same extent as CCS. 
For example, we state that an ultrasupercritical plant emits about one-
third less CO2 than an average coal power plant in the United States, 
while CCS offers the potential to capture 90 percent of a plant's CO2 
emissions. 

7. We revised our draft report to note that advancements in CCS and 
cooling technologies could help to reduce water use for CCS. In 
addition, it is important to note that our report states that pre- 
combustion capture could increase water use by 73 percent, not 37 
percent as DOE's comment indicates. 

8. We have made these technical changes to our draft report. It is 
important to note that we state that advanced materials are needed to 
withstand temperature increases of 300 to 500 degrees Fahrenheit. This 
is because today's ultrasupercritical plants have steam temperatures 
of about 1,100 degrees Fahrenheit, while DOE has set goals to develop 
materials to withstand steam temperatures of 1,400 to 1,600 degrees 
Fahrenheit. 

[End of section] 

Appendix IV: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Mark Gaffigan, (202) 512-3841 or gaffiganm@gao.gov: 

Staff Acknowledgments: 

In addition to the contact names above, key contributors to this 
report included Jon Ludwigson (Assistant Director), Chloe Brown, Scott 
Heacock, Alison O'Neill, Kiki Theodoropoulos, and Jarrod West. 
Important assistance was also provided by Chuck Bausell, Nirmal 
Chaudhary, Cindy Gilbert, Madhav Panwar, and Jeanette Soares. 

[End of section] 

Footnotes: 

[1] EIA is the statistical and analytical agency within DOE that 
collects, analyzes, and disseminates independent and impartial energy 
information. 

[2] For the purposes of this report, we have defined 
ultrasupercritical to mean steam temperatures of about 1,100 degrees 
Fahrenheit. 

[3] H.R. 2454, § 311, 111th Cong. (2009). 

[4] EPA must determine whether certain CCS deployment criteria are 
met, including whether commercial power plants and other stationary 
sources have captured and stored at least 12 million tons of CO2 
annually, to trigger the emission reduction requirement before 2025. 

[5] Pub. L. No. 111-5 (2009). One of the stated purposes of the ARRA 
is to preserve and create jobs and promote economic recovery. 

[6] EPRI is an independent nonprofit company funded by electricity 
producers that conducts research and development in the electricity 
sector. EPRI's work contributed to the following report: Global CCS 
Institute, Strategic Analysis of the Global Status of Carbon Capture 
and Storage: Synthesis Report (Canberra, Australia, 2009). 

[7] GAO, Standards for Internal Control in the Federal Government, 
[hyperlink, http://www.gao.gov/products/GAO/AIMD-00-21.3.1] 
(Washington, D.C.: November 1999). 

[8] TRLs were developed by NASA and the agency began using them in the 
mid-1990s. In 2002, DOD specified TRLs as the preferred method to 
conduct technology assessments for weapons programs. 

[9] DOE, Technology Readiness Assessment Guide, DOE G413.3-4 
(Washington, D.C., Oct. 12, 2009). 

[10] GAO, Department of Energy: Major Construction Projects Need a 
Consistent Approach for Assessing Technology Readiness to Help Avoid 
Cost Increases and Delays, [hyperlink, 
http://www.gao.gov/products/GAO-07-336] (Washington, D.C.: Mar. 27, 
2007). 

[11] While gasifying coal to make synthetic natural gas, the Great 
Plains Synfuels plant captures and transports CO2 for EOR use. 
However, this plant does not produce electricity. 

[12] There is an ultrasupercritical plant under construction in the 
United States known as the John W. Turk, Jr. plant. This 600 MW plant 
is being built in Arkansas and is scheduled to be completed in 2012. 
In addition, there is also a 630 MW IGCC plant under construction in 
Indiana, known as the Edwardsport plant. This plant is scheduled to be 
completed in 2012. 

[13] Our past work has also highlighted some of the challenges to 
deploying CCS. See GAO, Climate Change: Federal Actions Will Greatly 
Affect the Viability of Carbon Capture and Storage As a Key Mitigation 
Option, [hyperlink, http://www.gao.gov/products/GAO-08-1080] 
(Washington, D.C.: Sept. 30, 2008). 

[14] DOE, Cost and Performance Baseline for Fossil Energy Plants-
Volume 1: Bituminous Coal and Natural Gas to Electricity, Final Report 
(2007). 

[15] Under the Underground Injection Control program, EPA regulates 
underground injections of various substances into injection wells. 
Currently, CO2 injection wells can be permitted as Class I (injections 
of hazardous wastes, industrial nonhazardous wastes, municipal 
wastewater) or Class V wells (injections not included in other 
classes, including wells used in experimental technologies such as 
pilot CO2 storage). EPA's rule will establish a Class VI well for 
injection of CO2 for geologic sequestration. 

[16] 42 U.S.C. § 300i. 

[17] Today's ultrasupercritical plants have steam temperatures of 
about 1,100 degrees Fahrenheit. DOE has a goal to develop materials to 
withstand steam temperatures of 1,400 to 1,600 degrees Fahrenheit. 

[18] IEA, Technology Roadmap: Carbon capture and storage (Paris, 
France, 2009). 

[19] MIT, The Future of Coal (Cambridge, Mass., 2007). 

[20] NAS, America's Energy Future (Washington, D.C., 2009). 

[21] GAO, Economic and Other Implications of Switching from Coal to 
Natural Gas at the Capitol Power Plant and at Electricity-Generating 
Units Nationwide, [hyperlink, http://www.gao.gov/products/GAO-08-601R] 
(Washington, D.C.: June 5, 2006). 

[22] MIT, The Future of Coal. 

[23] DOE, Cost and Performance Baseline for Fossil Energy Plants-
Volume 1. 

[24] DOE, Cost and Performance Baseline for Fossil Energy Plants-
Volume 1. DOE officials also said that continued development of CCS 
and cooling technologies could significantly reduce water use for CCS. 

[25] National Coal Council, Low-Carbon Coal: Meeting U.S. Energy, 
Employment and CO2 Emission Goals with 21st Century Technologies 
(Washington, D.C., December 2009). 

[26] National Coal Council Issue Paper, Higher Efficiency Power 
Generation Reduces Emissions (2009). 

[27] EPRI is an independent nonprofit company funded by electricity 
producers that conducts research and development in the electricity 
sector. EPRI's work was part of the following report: Global CCS 
Institute, Strategic Analysis of the Global Status of Carbon Capture 
and Storage: Synthesis Report (Canberra, Australia, 2009). 

[End of section] 

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