EPA regs to kill nuclear power

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Remy and Justin entered a hypothetical scenario into the model in which each state with nuclear generating stations shut down all of their nuclear plants and replaced their zero emission electricity generation with natural gas fired generation. Remy and Justin uncovered a starting fact. In 15 states the carbon intensity in pounds per MWhr as calculated by the EPA’s spreadsheet model decreased.

That result made no sense to them. They thought that someone had to have made a mistake somewhere in the formulas used in the model that had not been caught by any of the reviews that must have taken place inside the EPA before the rule was issued for comment.

They dug into the spreadsheet and realized that the formula for calculating each state’s initial emission intensity gave every power source except nuclear credit for 100% of its actual generation in 2012, which was the year used for calculating the starting point from which each state’s carbon intensity reduction plan will be required a certain percentage reduction by 2030. For nuclear electricity production, the EPA’s “consistent national formula” applied a factor of .058 to its 2012 generation and then that far smaller number was added to the rest of the state’s 2012 power output to compute the overall carbon intensity.

That means that states with a substantial portion of power being produced by zero emission nuclear energy today have what appears to be a much higher carbon intensity than they actually have. If they close one of their operating nuclear plants, their EPA calculated carbon intensity number increases by a very small number because only 5.8% of the plant’s zero emission output was in that number in the first place. If the state chooses to replace the output of the nuclear plant with natural gas, there is a possibility — dependent on the state’s mix of other plants — that the carbon intensity number will actually decrease from what it was with the nuclear plant running.

Remy and Justin then met with the people who devised the formula and showed them what they had found. Those EPA staff members did not admit an error; they simply explained their methodology and assumptions in creating the model. They encouraged the pair to provide a comment to the proposed rule and said it would be considered during the process of finalizing the rule.

As young graduate students studying hard to become professionals in a field where integrity is highly valued and reinforced, Remy and Justin have graciously projected their personal honesty onto the EPA decision makers and believe that the formula was the result of an inadvertent misunderstanding that has “unintended” consequences.

I’m a little more experienced in the ways of Washington staffs and quite a bit more skeptical about the actions taken under the cover of pleasant sounding phrases. There is only a small chance that the formula’s results are unintentional. I suspect that it was created with the conscious goal of minimizing the CO2 benefits of nuclear energy.

During my 33-year career as a US naval officer, I learned to trust, but verify, and to stop trusting the work of anyone who would not admit an error, especially when confronted with proof.

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