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Regulatory
Framework
for CCS
UKCCS Winter School
10 January 2012
Aidan Whitfield Senior Advisor: CCS & Energy
File: Regulatory Framework for CCS A Whitfield 10Jan12
Topics
UN and European Legislation
UK Regulations:
Health and Safety
Planning permission
Environmental
Emission Trading
Kyoto Protocol
United Nations Framework Convention on Climate Change (UNFCCC)
Aims to stabilise greenhouse gas emissions to limit anthropogenic climate change.
Implementation is being delayed by arguments over targets e.g. developed and developing countries in Durban 2011
USA has never ratified, Canada withdrew 12/2011
London Convention
United Nations convention protecting the marine environment
Implemented by International Maritime Organisation
Prohibits disposal of waste from vessels aircraft and platforms into the sea
2006 amendment (not yet ratified): Allows storage of CO2 in geological formations under the seabed
Material must be CO2 only, containing no other wastes
OSPAR (Oslo-Paris) convention
Protects marine environment in North East Atlantic
Prohibits disposal of waste into the sea or under the seabed
2007 OSPAR amendment (not yet ratified):
Allows geological storage of CO2 under the seabed
Prohibits CO2 discharge direct into sea water
EC Directive on CCS 2009/31/EC
Sets a new legal framework for environmentally safe geological CO2 storage
exploration: permits required
operation: storage permits, monitoring, inspections
closure: financial provision, monitoring, transfer of
responsibility from operator -> state after min 20 years
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 EIA
Large combustion plants directive (LCPD): new power
stations >300MWe must be carbon capture ready
Integrated Pollution Prevention and Control directive:
makes CCS a listed activity requiring a permit
etc.
Health & Safety Executive HSE
Covers whole UK - HQ in Bootle, Liverpool
Hazardous Installations Division HID
Offshore Unit based in Aberdeen
Pipelines Unit Aberdeen & Norwich
Major Accident Hazards Unit based in Bootle
Health & Safety Laboratory (HSL) based in Buxton, Derbyshire is now privatised
HSE legislation
Health & Safety at Work act 1974 covers all activities
Control of Major Accident Hazards (COMAH) regs.
Does not include CO2 as a dangerous substance but
may be amended to cover large scale CO2 storage
Pipeline Safety Regulations (PSR)
Do not include CO2 a dangerous fluid but may be
amended
CO2 Pipelines research
More than 50 years experience of natural gas pipelines in UK and worldwide
HSE wants CO2 pipelines to be as safe as natural gas pipelines - needs to know safety distances from pipeline to people
HSE/HSL/Universities research: Failure rates and modes: materials of construction, corrosion
Release rates: dense phase CO2 -> gas and solid
Dispersion: cold, dense, non-flammable gas
CCS pipelines
Peterhead proposal will re-use offshore gas pipeline
£850m pipe for Humberside cluster?
European CO2
stored in UK waters?
Poyry Energy Consulting report
http://www.berr.gov.uk/files/file36782.pdf
Planning Permission
England & Wales: Section 36 consent to supply electricity – DECC
Major project decisions taken by Infrastructure Planning Unit using
National Policy Statements e.g. power stations & pipelines
Scotland: Decisions taken by local authority or Scottish Government
Offshore: Crown Estate give lease for storage under seabed
Environmental Regulators
Onshore
Environment Agency – England & Wales
SEPA – Scotland
Focus on power station permits not pipelines
Offshore
DECC Energy Development Unit, Aberdeen
CCS for coal and gas fired stations
Integrated Pollution Prevention and
Control Directive 2008/1/EC Original directive 1996 - revised 2008 Applies to all process industries - power stations, metals, chemicals, incinerators, landfills etc Integrated permit - emissions to air, water & land Applications, permits and emissions information available to public Requires Best Available Techniques (BAT) to minimise pollution BAT is defined in guidance issued by bureau in Seville There is no established BAT for CCS
Power station regulation in the UK
IPPC power station permit will include CO2 capture plant (but not CO2 releases)
e.g. Ferrybridge power station in Yorkshire is building a 5MW CCS pilot plant at a cost of £21m (£6m from Government). Permit variation issued in November 2010, start-up due in Jan 2012
CCS 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 Pilot plants
Scottish & Southern Energy, Ferrybridge
EA preparation for CCS
EA produced a CCS Environmental Risk Assessment – 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 demonstration plants and then full-scale plants
Research needed to find alternatives to using volatile amines
EA staff on project board for major university research projects
ERA Example: Water Resources
Amine scrubbing and CO2 compression will require additional cooling
Research on process options is estimating additional
cooling load
Demo plants results can be factored in by 2016-18
Need to consider climate change effects on river flows
up to the 2050s
Air cooling or sea water cooling may become the
preferred options. New stations on North Sea coast?
2050s change in river flows UKCIP02
March (+- 5%) July (-10 to -80%)
2050s change in river flows UKCIP02 September (-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 emissions Allowances are allocated by the permit or bought on the open market From 2013 CCS pipelines and storage sites will be included in the EUETS EUETS sets a price for CO2 releases but current price is too low to create investment in CCS technology.
Conclusions
International agreements and EC legislation have been amended to allow CCS
Most existing UK regulations for health, safety and the environment will be OK for CCS
Knowledge gaps will be filled by research, 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
CCS Regulatory Framework
Aidan Whitfield