CORRECTION: Kentucky IGCC changed
design to "SNG-NGCC" before EPA order

A comment to our March 21 posting requires that we call attention to a possible misinterpretation of recent news concerning the Cash Creek IGCC project in Kentucky.

According to an anonymous comment received in response to our March 21 posting (see text of comment below), the developers of the Cash Creek project in Kentucky had already decided to change the project design to a hybrid IGCC (or "SNG-NGCC") configuration more than a year before the EPA order of December 2009 was issued.

Moreover, it is claimed that this was done on the basis of "business models" - not due to EPA pressure as suggested by our posting.

After more research into the matter, thanks to a reader who provided a copy of the EPA order, it was learned that the EPA was responding to two petitions filed in Jan/Feb 2008 - one by the Sierra Club and the other by Valley Watch - both objecting to the original air permit issued for the project by the Kentucky Division of Air Quality (KDAQ) at that time.

It took the EPA almost two years to issue its order directing the KDAQ to address certain issues with that permit - the main one being failure to consider use natural gas as the primary fuel instead of coal-derived syngas. Apparently, as pointed out by the comment, this was well after the project developers had already decided to change the project design and applied to the KDQA for modifications to its air permit.

Perhaps, as the comment says, we "missed the point" of the EPA order. Admittedly, we did post our remarks with incomplete information, and should have done more homework.

But the comment raises new issues, and further comment is invited to add clarification.

Since the decision to change the project design supposedly took place around mid-2008, it was done after those petitions were filed. Perhaps, just perhaps, those "business models" included analysis of the cost and risks of continued battles over environmental objections.

Could it be that the decision to change to an "SNG-NGCC" configuration was made to quiet those objections?

How else could those "business models" have justified the extra cost of producing SNG, and the loss of about 10% of the syngas heating value in the process?

If in fact the project design had already been changed, and requests for permit modifications were duly filed, why wasn't that noted in the EPA order of December, 2009 along with other permit history?

As it turned out, due to the long delay in KDQA action on the permit modifications, the EPA order would appear to be totally irrelevant, and a waste of time, since the main objection to the permit (failure to consider natural gas as the primary fuel) was already a moot point.

Why didn't the KDAQ act in a more timely manner instead of waiting until after the EPA order to issue a new permit? Was not the original permit already invalidated by the change in design filed in 2008?

Again, "anonymous" is invited to add further comment to help clarify these issues.


Finally, the comment points out that the EPA order "seemed to go out of its way to praise IGCC" as a cleaner alternative to conventional coal-based power generation.

That may be true. And it may also true that the EPA is now selectively reviewing existing permits for conventional coal plants to decide whether IGCC should be included in the BACT analysis.

True, all of this may be positive for IGCC.

But if IGCC power projects continue to cave under the pressure (be it economical or environmental), and convert to "hybrid IGCC" or "SNG-NGCC", then, as we said at the outset of yesterday's posting, this very well could mean the end of the IGCC concept as we know it.


Text of anonymous comment to original posting:

The developers of Cash Creek made the decision to switch from IGCC to SNG with a co-located NGCC plant in 2008-- some 12 -18 months before the December 2009 EPA objection letter to the original IGCC permit.

The plant's developers filed air permit and water permit modifications to the original IGCC permit in 2008, and hearings on both of the modifications were held months before the EPA objection letter was received.

So I think the article misses the point on the letter. The technology change from IGCC to SNG-NGCC was driven by business models, not by some EPA-imposed permit letter.

KY regulators had 90 days to respond to the December 2009 objection letter. They could have agreed with EPA and voided the permit, modified the existing permit, or issued a new one. Because the developers had long before filed applications for a different technology and the permitting process was so advanced, KY addressed the question by issuing the new air permit.

What EPA intended to say about IGCC in the objection letter is open to some debate. I respect the opinions of those in industry that see it as an attack on coal, but I read the letter differently. The EPA seemed to go out of their way to praise IGCC in the letter, stress this wasn't about coal, and only about documentation in the record.

Time will tell what EPA really intended.












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