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  • Carbon Capture Utilisation and Storage (CCUS) guidance

Carbon Capture Utilisation and Storage (CCUS) guidance

As Scotland’s environmental regulator, we are responsible for some of the primary environmental legislation that covers Carbon Capture Utilisation and Storage (CCUS), and have statutory duties within the land use planning system and local air quality management system.

We are also involved in working with UK and Scottish Governments as well as other environment agencies. In addition, we provide advice to and have regular interactions with academia, industry and the general public.

Background

CCUS refers to a variety of techniques that capture Carbon Dioxide (CO2) from flue gases, process emissions or the atmosphere for use, to make products or permanent storage underground.

The whole process involves one or more of three parts:

  • CO2 capture - from a large point source, such as a power station, other industrial installation, or directly separated from the air,
  • CO2 transportation – by pipeline or ship,
  • CO2 storage - in underground geological formations or used to make products and materials.

For further information, please visit the International Energy Agency and the UK Carbon Capture and Storage Research Centre webpages.

Implementation in the UK

At present, several CCUS projects are in development across the UK. The UK government is supporting CCUS deployment via a cluster sequencing approach. To date two clusters in England have been supported in the first phase of funding. A further two clusters are being supported in the second wave of funding, one of which is in Scotland - the Acorn project which aims to store CO2 in a depleted oil field in the North Sea. See links below for projects related to the Acorn CCS project:

  • The Acorn Project at St. Fergus in Aberdeenshire, aims to capture CO2 from combustion plant in the St Fergus gas terminal and will build the transport and storage network to facilitate geological storage of the CO2.
  • Peterhead CCS Project at Peterhead gas-fired power station, in Aberdeenshire. The project aims to capture CO2 from combustion of power station's fuel and send it for geological storage at the Acorn project's geological storage site.

SEPA is a statutory consultee in the planning process and has responded to the Peterhead CCS Project planning application. The Peterhead CCS project proposes to use an amine-based post-combustion carbon capture technology to capture CO2 from the exhaust of a new gas turbine. The activity of carbon capture is regulated by us, primarily through the Environmental Authorisation (Scotland) Regulations (which superseded the Pollution Prevention and Control (Scotland) Regulation s2012) and the UK Emissions Trading Scheme (UK ETS).

For an overview of CCS projects around the world, please see the global map provided by the Scottish Carbon Capture and Storage research group.

Environmental regulation of CCUS

SEPA is one of the regulators in a full chain CCUS project. SEPA is responsible for regulation relating to the protection of the environment and human health.

In England and Wales the environmental regulators with similar roles to ours are the Environmental Agency and Natural Resources Wales, respectively. The primary environmental legislation under which we will regulate carbon capture activities is outlined below:

We regulate the operators of installations which emit CO2 whilst carrying out activities specified in the Environmental Authorisation (Scotland) Regulations (EASR).

Carbon capture for the purposes of geological storage is a listed activity under EASR. This means operators of plant capturing CO2 from an industrial activity for geological storage will require an EASR permit. Carbon capture for utilisation is also listed activity in EASR.
EASR also requires operators of activities likely to have an impact on the water environment to be authorised by SEPA.

We are a statutory consultee to the environmental impact assessment (EIA) conducted on major planning applications, including applications for consent submitted under the Electricity Act 1989. We engage in the EIA and planning processes at an early stage in order to address potential environmental issues.

We review local air quality management plans, and consider how emissions from regulated installations affect UK Air Quality Standards.
We will provide advice to Scottish Government as to whether a proposed new power station has met the requirements of the carbon capture readiness guidance provided by the Scottish Government in demonstrating that there is adequate space for carbon capture and that there are no barriers to retrofitting carbon capture equipment in the future.

We are the competent authority for the UK Emissions Trading System (UK ETS) in Scotland. We issue permits to eligible installations and ensure that operators comply with the system’s operational rules. CO2 captured and stored will be considered as ‘not emitted’ under the EU ETS.

The presence of dangerous substances has the potential to bring some installations not previously subject to the Control Of Major Accident Hazard Regulations 2015 (COMAH) within the scope of that regime. At non-nuclear sites in Scotland, SEPA and the HSE are the COMAH Competent Authority. At nuclear sites in Scotland, SEPA and the Office of Nuclear Regulation (ONR) are the COMAH Competent Authority

Environmental impacts of amine-based post-combustion carbon capture technology

The proposed technology for both the Peterhead CCS Project and Acorn CCS project is an amine-based post-combustion carbon capture process. This technology is in use at the world’s first commercial scale CCS project at the Boundary Dam power station in Saskatchewan, Canada which began commissioning in October 2014.

Review of amine emissions from carbon capture systems, reviews the emission of amines (and related amine reaction products) from post combustion carbon capture systems, their potential effects and considers the development of effective environmental standards.

The paper considers four main aspects:

  • emissions of amines and associated reaction products
  • the potential impact of such emissions on the environment and on human health
  • the extent of relevant environmental quality standards
  • issues associated with measurement of such compounds at low concentrations in emissions and in the environment

This document was originally prepared in the latter half of 2014 and developed through to the end of 2014. We are aware that further detailed technical information on emissions of amine compounds from carbon capture systems has been, or is now in the process of, being published.

The UK government published guidance “Post-combustion carbon dioxide capture: emerging techniques”. This guidance for emerging techniques is not a regulatory requirement but identifies best practice to address important environmental issues