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

aidan.whitfield@environment-agency.gov.uk