Emerging Technologies: CCS and Siting Issues 5th Annual National Coal Meeting Washington, D.C. July 16, 2008

Transcription

1 Emerging Technologies: CCS and Siting Issues 5th Annual National Coal Meeting Washington, D.C. July 16, 2008 Suzi Ruhl, JD, MPH Director, Public Health and Law Program Environmental Law Institute* Washington, DC * Identification purposes only

2 Alternative Evaluation Framework View CCS in the Context of a Public Health Framework Medical Diagnosis Iceberg Concept Prevention Hierarchy Public Health Paradigm

3 Medical Diagnosis Continuum of CCS Debate Paranoia...Cognitive. Dissonance...Delusional Con-CCS Confused about CCS Pro-CCS

4 Medical Diagnosis Continuum of CCS Debate Paranoia...Cognitive Dissonance...Delusional Con-CCS Confused about CCS Pro-CCS Apply to CCS Daily As Directed: 1. A New Framework of Thinking 2. Scrutiny for all Impacts 3. Evaluation of Assumptions 4. Contingency for Failure Refills: PRN *No Generic Substitutes Allowed

5 Cognitive Dissonance Theory Reality CO2 will be isolated in perpetuity in impermeable formations in the subsurface Deep Formations feet bls No Migration of Fluids into USDWs Applied in Limited Parts of the Country Pilots at feet bls Flexible Regulations, Liability Protection Map of states with coal dependence

6 Iceberg Concept Only clinical symptoms are apparent Sub-clinical disease has public health implications Human Health Environment/Planet Health

7 Clinical Symptoms from Surface Exposure Human Chronic Human Acute Environmental Cardiovascular Dermal Natural Resource/ Ecosystem Respiratory Respiratory Other? Other? Public and worker safety

8 Sub-clinical: Contamination of Underground Sources of Drinking Water Pathways of Contamination Upward migration through improperly abandoned or completed wells Upward migration through mechanical integrity violations (e.g. faulty casing, annulus between casing and well bore) Upward migration through faults, fractures and fissures Dissolution of confining zones Lateral displacement of formation fluid, subsurface waters

9 Sub-clinical: Contamination of Underground Sources of Drinking Water Nature of Migrating Fluid Captured CO2 stream Impurities (e.g. heavy metals) Liquid wastes (e.g. solvents) By-products of interaction between injectate and formation (e.g. metals and toxic organic compounds) Native/formation fluid (>10,000 mg/l TDS)

10 Prevention Hierarchy Siting Delegation Permitting Abatement PWS Safety Primary Secondary Tertiary Those activities that are intended to prevent the disease in the first place Techniques that find problems early in their course so that actions can be taken to minimize the risk of progression and transmission Focused on rehabilitation in an effort to prevent the worsening of a condition in the face of a chronic problem

11 Tertiary Prevention Abatement Response to System Failure Illustration: UIC Class I Municipal Wells in Florida Analogy to CCS Chronology of events Implications for CCS

12 Tertiary Prevention Abatement Response to System Failure 40 CFR : Brevard, Broward, Charlotte, Collier, Flagler, Glades, Hendry, Highlands, Hillsborough, Indian River, Lee, Manatee, Martin, Miami- Dade, Monroe, Okeechobee, Orange, Osceola, Palm Beach, Pinellas, St. Johns, St. Lucie, Sarasota, and Volusia.

13 Public Water Supply Safety Tertiary Prevention Water infrastructure Drinking water standards Monitoring costs Treatment costs

14 Secondary Prevention Delegation of UIC Program to States: Primacy

15 Secondary Prevention Delegation of UIC Program to States: State Duties Legal and Regulatory Authority Permitting Monitoring Enforcement Personnel Funding Public Participation

16 Secondary Prevention Delegation of UIC Program to States: Procedural Tools Review of State Program Capabilities Petition for Rulemaking for State UIC programs EPA Oversight Authority Petition for Rulemaking to Withdraw Delegated UIC Programs

17 Permitting Secondary Prevention Permitting Process Strategic Organizing Public participation Permit Challenge Administrative Record Vulnerabilities (e.g. corrective action plan)

18 Primary Prevention Siting Endangerment Standard Siting Requirements Conditions for sufficient confinement Molecular diffusion Exclusionary criteria permeability lateral displacement (e.g. hazardous waste) Mapping Comparison Coal operations Permeability factors Hazardous waste injection

19 Surveillance: What are the problems? Descriptive Risk Factor Identification: What are the causes? Analytical Intervention Assessment: What works? Monitoring Implementation How do you do it? Regulations Public Health Paradigm

20 Conclusion: Preventing Planetary Disability

21 CCS and Siting Issues Adopting a Public Health Framework Suzi Ruhl, JD, MPH Suzi Ruhl, JD, MPH Director, Public Health and Law Program * Environmental Law Institute Washington, DC (203) ruhl@eli.org * Identification purposes only