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Current regulatory framework that can be adapted to define CO2quality requirements and allowable emissions from the power plant.

Oxyfuel Combustion Working Group Meeting on CO2 QualityRåcksta, Stockholm, 2008-10-22

Sara Eriksson, Vattenfall Research & Development

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Scope

• The scope of this presentation is to give an overview of legislation other than the proposed CCS Directive that applies to CCS

• Requirements/potential for amendments/adaptions to define CO2quality aspects (quality requirements and allowable emissions from the power plant)

• Focus on EC legislation

• Covering the entire CCS chain (capture transport storage)

• A more detailed study may be necessary to ensure that no legal barriers are overlooked.

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Regulating CO2 quality - rationale

Relating to a potential leakage• Protecting the environment (local, global, air quality)• Protection of health and safety

Relating to integrity (preventing corrosion, hydrate formation, chemical reactions etc.)

• Transport system (pipeline etc.) • Storage formation

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Directives that apply to CCS

For CO2 capture, transport and storage, existing provisions have been used where possible to manage the risks of CCS, as stated in the proposed CCS Directive:

• IPPC Directive: Directive 96/61/EC concerning Integrated Pollution Prevention and Control (IPPC) is used for regulating the risks of CO2 capture.

• EIA Directive: Directive 85/337/EEC on the assessment of the environmental impact of certain projects (EIA) is used for assessing environmental impact of capture, pipeline transport and storage.

• Environmental Liability Directive (regulates liability for local damage): Directive 2004/35/EC on Environmental Liability is used for regulating the liability for local environmental damage from CCS.

• ETS Directive (regulates liability for global damage): Directive 2003/87/EC establishing a scheme for greenhouse gas emission allowance trading is used for regulating the liability for climate damage by requiring surrender of allowances

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Composition of CO2 stream

• In the CCS Directive consultation process, it was discussed whether the requirements on denitrification/desulphurisation levels could be the same as would be required under current air pollution legislation if the exhaust were vented to air.

But:Air pollution legislation is not focussed on transport/storage risks, only the potential risk from venting to the atmosphere.CO2 quality requirements should be set so as to ensure the integrity of CO2

transport and storage, and potential environmental consequences in case of leakage (in line with OSPAR and London Conventions).

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CO2 capture installations

• Combustion installations (except small installations) are covered by the IPPC directive1 (96/61/EC; revised 2008/1/EC) which aims at minimising pollution from point sources in Europe

• subject to permit procedures (covered by EIA legislation /national law).

• The 2008 revision of the Directive resulted in the inclusion of several other Directives (including the Large Combustion Plant (LCP) Directive, Waste Incineration Directive etc.)

• Revision includes introduction of new requirement to periodically monitor the soil and groundwater on the site to ensure that appropriate information is available to protect them from contamination by dangerous substances.

1 Directive concerning integrated pollution prevention and control

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IPPC Directive (2008/1/EC)

• The IPPC Directive will be used to regulate CO2 capture related risks, and for setting the requirements for the capture and quality of CO2 streams for geological storage.

• Does not set standards for captured CO2 - IPPC identifies and suggests Best Available Techniques (BAT) that can be applied to limit emissions from industrial installations that it covers. but:There is yet no BAT data for CCS to be used as input to establish the so called Best Available Technique Reference Documents (BREFs).

• LCP BREF to be reviewed in 2010 Inclusion of BAT for carbon capture within a horizontal BREF?

Horizontal BREF = BAT reference documents prepared to deal with topics common to more than one IPPC industrial sector (f.i. storage, cooling, waste water and waste gas and monitoring).

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IPPC Directive (2008/1/EC)

• Adding CCS to existing coal fired plants would lead to similar or lower emissions of most impurities in the flue gas of CCS equipped plantsbut:the concentration can be higher due to a smaller volume emitted, for oxyfuel only a few % of the normal flue gas flow – previously identified as potential problem due to emission limits given in mg/Nm3. However, according to the definitions – “emission limit values” means the mass, expressed in terms of certain specific parameters, concentration and/or level of an emission, which may not be exceeded during one or more periods of time.”

and: “The permit shall include emission limit values for polluting substances, in particular

those listed in Annex III, likely to be emitted from the installation concerned in significant quantities, having regard to their nature and their potential to transfer pollution from one medium to another (water, air and land). "“…emission limit values may be supplemented or replaced by equivalentparameters or technical measures.” (Art. 15)This should not constitute a problem

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ETS Directive

Potentially applicable in the future for other greenhouse gasespresent in the CO2 stream

• January 2008: Changes proposed to ETS – including the inclusion of other greenhouse gases in the scheme.

Still in a draft stage; amendments only likely to become effective from January 2013 onwards (i.e. in the 3rd Trading Period under the EU ETS)

For the substances considered in this workshop, this applies only to N2O –which is considered a minor impurity (in the workshop list).

[CH4 is also a potent greenhouse gas - not relevant for Oxyfuel combustion, but for Precombustion capture!]

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Transport legislation

• CO2 is classified as dangerous goods according to international law and EU legislation when transported by road, rail or ship and thus subject to detailed regulation.

• No international or European regulation of this kind is available for the transport of pipelines.

• Pressure Equipment Directive (PED) 97/23/EC – on choice of materials for pressurisedvessels and pipelines– does however apply

• Transport of CO2 is regulated in the EIA Directive

• Regulations for pipeline transport mainly at national level

• ETS Directive will apply

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Health and safety legislation• Attributes of gas stream components such as flammability, toxicity, being an irritant, etc.

will trigger multiple health, environmental, and safe handling requirements in operations relating to the capture facilities and the transport and storage system.

• At present, determining characteristics of gas quality in detail will be handled by the national authorities in the permitting process (Worker’s safety regulations, safety distances, precautionary measures etc.).

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Limit values

• Presence of other components cannot lead to significant or unacceptable risks for health, safety and environment.

The CO2 stream will consist overwhelmingly of CO2 (disussions on quantification of this are ongoing). When considering HSE risks and CO2 gas stream design - no other component in the gas stream should be present at concentrations that makes it a greater hazard than CO2 itself since CO2 is the main constituent.

CO2 should be the limiting component from a HSE perspective!

• This is the same approach used in the study of CO2 gas quality specifications in the Dynamis EU project.

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Removal of legal barriers - storage

Within the EC• Waste Framework Directive and Waste Shipment Regulation amended to

remove CO2 for the purposes of storage • Water Framework Directive amended to allow storage of CO2 in saline aquifers

Internationally (offshore)• Amendment in 2006 of the London Protocol

(1996) to the London Convention (1972) on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter

• Amendment in 2007 of the OSPAR Convention (1992) for the Protection of the Marine Environment of the North-East Atlantic

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Some applicable Directives and need for amendments

• EIA Directive – applicable –amended for CCS to include capture, transport and storage of CO2 streams. No further amendments assumed to be required.

• IPPC Directive – applicable; amended to include Capture of CO2 streams; BREFsfor CCS yet to be formulated

• Water framework Directive - amended to allow for geological storage of CO2

• ETS Directive – applicable for CCS – may apply to other GHGs in the future (post 2013)

• Environmental Liability Directive – applicable - liability for post-closure damage

• The application of the Seveso II Directive (imposes safety management requirements on installations that present an elevated accident hazard risk) to CO2capture is currently under examination.

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Equal access to transport and storage networks

• In the future, determining CO2 quality standards in a specific transport and storage network to be used by several actors will be an issue.

At present, a basic approach of access to networks as well as to storage sites to be granted on a non-discriminatory basis* has been chosen instead of imposing specific rules (such as for gas and electricity). This may have to be developed into more elaborate detail in the future.

* subject to limitations on access for reasons justified by public interest pursuant to Articles 46 and 55 EC

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Conclusions

• No immediate needs for amendments have been identified

• However, several Directives apply or may apply in the future to capture, transport and storage of CO2 streams containing other substances.

• Future development of CCS BREF

• Standards and guidelines will complement legislation relating to stream quality characteristics.

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Recommendations and further investigations

• National legislation may provide barriers for CCS and presence of other components in the CO2 stream – must be reviewed for each country

• Health and safety legislation – limit values, safety distances etc. needs further investigations

• This overview is given by an engineer, some issues may warrant further evaluation by someone schooled in law, to ensure that no issues have been overlooked.

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Thank you!

Sara ErikssonVattenfall Research and Developmentsara.eriksson@vattenfall.com