1. Regulatory
Framework
for CCS
UKCCS Winter School
10 January 2012
Aidan Whitfield
Senior Advisor: CCS & Energy
File: Regulatory Framework for CCS A Whitfield 10Jan12

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

3. 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

4. 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

5. 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

6. 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

7. 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.

8. 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

9. 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

10. 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

11. 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

12. 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

13. Environmental Regulators
Onshore
Environment Agency – England & Wales
SEPA – Scotland
Focus on power station permits not pipelines
Offshore
DECC Energy Development Unit, Aberdeen

14. CCS for coal and gas fired stations

15. 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

16. 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

17. CCS Pilot plants
Scottish & Southern Energy, Ferrybridge

18. 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

19. 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?

20. 2050s change in river flows UKCIP02
March (+- 5%) July (-10 to -80%)

21. 2050s change in river flows UKCIP02
September (-30 to -80%) November (+10% to -50%

22. 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.

23. 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

24. CCS Regulatory Framework
Aidan Whitfield
aidan.whitfield@environment-agency.gov.uk