Regulatory Framework for CCS

Aidan WhitfieldSenior Advisor: CCS & EnergyUKCCS Winter School, 9 February 2011

File: Regulatory Framework for CCS v4 4Feb11

Topics

European Legislation

UK Regulations:Health and SafetyPlanning permissionEnvironmentalEmission Trading

OSPAR (Oslo-Paris) convention

Protects marine environment in North East AtlanticTreaties completed 1992, came into force 1998Not EC legislation – includes NorwayProhibits disposal of waste into the sea or under the seabed

2007 OSPAR amendment:Allows storage of CO2 in geological formations under the seabedProhibits CO2 into the sea water column or onto the seabed

EC Directive on CCS 2009/31/EC

Sets a new legal framework for environmentally safe geological CO2 storage

exploration: permits requiredoperation: storage permits, monitoring, inspectionsclosure: financial provision, monitoring, transfer of responsibility from operator -> state after min 20 yearsProhibits storage in the water column (on seabed)Public access to information, reporting to commission

EC Directive on CCS 2009/31/EC

Amends existing EC legislation to include CCS e.g.:

Environmental Impact Assessment (EIA) directive -planning applications to build capture, pipelines and storage facilities require a full EIALarge combustion plants directive (LCPD): new power stations >300MWe must be carbon capture readyIntegrated Pollution Prevention and Control directive: makes CCS a listed activity requiring a permitetc.

Health & Safety Executive HSE

Covers whole UK - HQ in Bootle, LiverpoolHazardous Installations Division HID

Offshore Unit based in AberdeenPipelines Unit Aberdeen & NorwichCOMAH Unit based in BootleEmerging Energy Technologies programme running for the last 3 years – renewable energy, CCS etc

Health & Safety Laboratory (HSL) based in Buxton, Derbyshire is now privatised

HSE legislation

Health & Safety at Work act 1974 covers all activitiesControl of Major Accident Hazards COMAH regs.

Transposes the EC Seveso directiveApplies to installations storing large quantities of dangerous substances e.g. petrol, chlorine, fireworksImplemented by a joint competent authority - HSE, EA & SEPAEC considering making CO2 a dangerous substance which will make COMAH apply to large scale storage/use

Pipeline Safety Regulations (PSR)UK not currently making CO2 a dangerous fluid under PSR

CO2 Pipelines research

More than 50 years experience of natural gas pipelines in UK and worldwideHSE wants CO2 pipelines as safe as natural gas pipelines so needs to know safety distances from pipeline to peopleHSE/HSL/Universities research:

Failure rates and modes: materials of construction, corrosionRelease rates: dense phase CO2 -> gas and solidDispersion: cold, dense, non-flammable gas

CCS pipelinesLongannet to

Peterhead will re-use gas pipeline

£850m pipe for Humberside cluster

European CO2 stored in UK waters?

Planning Permission

England & Wales:Section 36 consent to supply electricity – DECCMajor project decisions taken by Infrastructure Planning Unit using National Policy Statements e.g. power stations & pipelinesEnvironment Agency and HSE will be consultees

Scotland:Section 36 consent to supply electricity – Scottish Government.Major project decisions taken by local authority or Scottish GovernmentSEPA and HSE will be consultees

Offshore:Crown Estate give lease for storage under seabed

Environmental Regulators

OnshoreEnvironment Agency – England & WalesSEPA – ScotlandNorthern Ireland EA (but no CCS planned in NI)Focus on power station permits not pipelines

OffshoreDECC Energy Development Unit, Aberdeen

Large Combustion Plants directive (LCPD)

Original directive 1988 - revised as 2001/80/ECApplies to combustion plant >50MW thermal inputAims to reduce emissions of SOx, NOx and dustCoal fired plants have reduced SOx by fitting FGD and reduced NOx by fitting new burners or opted to run reduced hours and close by end of 2015

Integrated Pollution Prevention and Control Directive 2008/1/EC

Original directive 1996 - revised 2008/1/ECApplies to all process industries - power stations, metals, chemicals, incinerators, landfills etcIntegrated - one permit covering emissions to air, water & landApplications, permits and emissions information available to public

Requires Best Available Techniques (BAT) to minimise pollutionBAT is defined in guidance issued by bureau in SevilleThere is no established BAT for CCS

IPPC Permit does not cover CO2 releases

Power station regulation in the UK

PPC Regulations (Scotland) and Environmental Permitting Regulations (England & Wales) implement the IPPC directive and include requirements of the LCPD directivePermit variations will be issued for adding CCS plant to existing stationse.g. Ferrybridge power station in Yorkshire building a 5MW CCS pilot plant at a cost of £21m (£6m from Government). Permit variation issued in November 2010, start-up due in April 2011CCS will be regulated using the existing permitting systemCCS technology will have to comply with the same standards of environmental protection as any other industrial process.We expect to be able to issue permits for all the proposed CCS technologies

CCS for coal and gas fired stations

EA preparation for CCS

EA is producing a CCS Environmental Risk Assessment – to be published on the EA website in April 2011.The risk management measures identified in the ERA will form the basis the EA work programme on CCS from 2011 to 2020.Example measures:

Need for a life cycle assessment model to evaluate CCS options –will use the Imperial College LCA model.Amine releases from pilot plants will be used to design demo plants and then full-scale plantsResearch needed to find alternatives to using volatile aminesEA staff on project board for major university research projects

ERA Example: Water Resources

Amine scrubbing and CO2 compression will require additional cooling

Current academic research on process options could estimate additional cooling loadDemo plants results can be factored in by 2016-18Need to consider climate change effects on river flows up to the 2050sAir cooling or sea water cooling may become the preferred options. New stations on North Sea coast?

2050s change in river flows UKCIP02March (+- 5%) July (-10 to -80%)

2050s change in river flows UKCIP02September (-30 to -80%) November (+10% to -50%

EU Emissions Trading Scheme

Started 1995. Covers 11,000 installations such as power stations – 45% of EC emissions of CO2

Significant emitters of greenhouse gases must have an EUETS permit - issued by EA/SEPA in the UK.Operators must monitor and report emissionsAllowances are allocated by the permit or bought on the open market From 2013 CCS pipelines and storage sites will be included in the EUETSEUETS sets a price for CO2 releases but current price is too low to create investment in CCS technology.

Conclusions

EC directives & EUETS amended to allow CCSMost existing UK regulations for health, safety and the environment will be OK for CCSSome knowledge gaps will be filled by researchSome knowledge gaps will be filled by the pilot and demo plant programme New regulations for CCS storage not covered in this presentation. They may be a problem – especially long term financial liabilities