Regulatory Framework for CCS

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1 Regulatory Framework for CCS Aidan Whitfield Senior Advisor: CCS & Energy UKCCS Winter School, 9 February 2011 File: Regulatory Framework for CCS v4 4Feb11

2 Topics European Legislation UK Regulations: Health and Safety Planning permission Environmental Emission Trading

3 OSPAR (Oslo-Paris) convention Protects marine environment in North East Atlantic Treaties completed 1992, came into force 1998 Not EC legislation includes Norway Prohibits disposal of waste into the sea or under the seabed 2007 OSPAR amendment: Allows storage of CO 2 in geological formations under the seabed Prohibits CO 2 into the sea water column or onto the seabed

4 EC Directive on CCS 2009/31/EC Sets a new legal framework for environmentally safe geological CO 2 storage exploration: permits required operation: storage permits, monitoring, inspections closure: financial provision, monitoring, transfer of responsibility from operator -> state after min 20 years Prohibits storage in the water column (on seabed) Public access to information, reporting to commission

5 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.

6 Health & Safety Executive HSE Covers whole UK - HQ in Bootle, Liverpool Hazardous Installations Division HID Offshore Unit based in Aberdeen Pipelines Unit Aberdeen & Norwich COMAH Unit based in Bootle Emerging Energy Technologies programme running for the last 3 years renewable energy, CCS etc Health & Safety Laboratory (HSL) based in Buxton, Derbyshire is now privatised

7 HSE legislation Health & Safety at Work act 1974 covers all activities Control of Major Accident Hazards COMAH regs. Transposes the EC Seveso directive Applies to installations storing large quantities of dangerous substances e.g. petrol, chlorine, fireworks Implemented by a joint competent authority - HSE, EA & SEPA EC considering making CO 2 a dangerous substance which will make COMAH apply to large scale storage/use Pipeline Safety Regulations (PSR) UK not currently making CO 2 a dangerous fluid under PSR

8 CO 2 Pipelines research More than 50 years experience of natural gas pipelines in UK and worldwide HSE wants CO 2 pipelines as safe as natural gas pipelines so 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

9 CCS pipelines Longannet to Peterhead will re-use gas pipeline 850m pipe for Humberside cluster European CO 2 stored in UK waters?

10 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 Environment Agency and HSE will be consultees Scotland: Section 36 consent to supply electricity Scottish Government. Major project decisions taken by local authority or Scottish Government SEPA and HSE will be consultees Offshore: Crown Estate give lease for storage under seabed

11 Environmental Regulators Onshore Environment Agency England & Wales SEPA Scotland Northern Ireland EA (but no CCS planned in NI) Focus on power station permits not pipelines Offshore DECC Energy Development Unit, Aberdeen

12 Large Combustion Plants directive (LCPD) Original directive revised as 2001/80/EC Applies to combustion plant >50MW thermal input Aims to reduce emissions of SOx, NOx and dust Coal 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

13 Integrated Pollution Prevention and Control Directive 2008/1/EC Original directive revised 2008/1/EC Applies to all process industries - power stations, metals, chemicals, incinerators, landfills etc Integrated - one permit covering 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 IPPC Permit does not cover CO 2 releases

14 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 directive Permit variations will be issued for adding CCS plant to existing stations e.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 2011 CCS will be regulated using the existing permitting system 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

15 CCS for coal and gas fired stations

16 EA preparation for CCS EA is producing a CCS Environmental Risk Assessment to be published on the EA website in April The risk management measures identified in the ERA will form the basis the EA work programme on CCS from 2011 to 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 plants Research needed to find alternatives to using volatile amines EA staff on project board for major university research projects

17 ERA Example: Water Resources Amine scrubbing and CO 2 compression will require additional cooling Current academic research on process options could estimate additional cooling load Demo plants results can be factored in by 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?

18 2050s change in river flows UKCIP02 March (+- 5%) July (-10 to -80%)

19 2050s change in river flows UKCIP02 September (-30 to -80%) November (+10% to -50%

20 EU Emissions Trading Scheme Started Covers 11,000 installations such as power stations 45% of EC emissions of CO 2 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 CO 2 releases but current price is too low to create investment in CCS technology.

21 Conclusions EC directives & EUETS amended to allow CCS Most existing UK regulations for health, safety and the environment will be OK for CCS Some knowledge gaps will be filled by research Some 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