Carbon Capture &Storage

and the new proposed EU legislation on CCS

Daniel Reger Environmental Management 15-09-2008

Table of contents

IntroductionWhat is CCS?Chronology of the decisionson EU basisExcurse: KYOTO protocolCommission’s proposal on CCS

IPPC DirectiveEIA DirectiveLegal framework on CO2 storageModifications to other Directives

Economic aspects & Impacts on EU ETSConclusions

Introduction

CO2 as a greenhouse gasNatural greenhouse effectConcentration in the atmosphere:

2006: 381ppm (2ppm/year)“Man-made” emissions: 36,3 Gt/yearCO2 emissions play great part of the global warming

Introduction

www.en.wikipedia.org/wiki/Image:Carbon_Emission_by_Region.png

What is CCS?

Approach to mitigate global warming by CO2 capture and storage3 parts: capture, transport and storage

Costs?

+ MORE FUEL - EOR+ TANSPORT - EGR+ STORAGE - ECBM+ CAPTURING+ MONITORING

=> Benefits do not outweigh the costs=> Costs for power production will rise

What is CCS?

Environmental aspects?

Reduction of CO2 emissions (75-90% per plant) But:

Increase in other emissionsAdditional energy required more fuel (11-40%)Mining (coal, limestone)

Use of CCS can entail a reduction in air quality

Table1: Emissions to air from plants with CCS (kg/(MW*h)) [IPPC 2005]

What is CCS?

CO2 Capture TechniquesPost combustionPre combustionOxy-fuel combustion(Ethanol production with fermentation)Chemical looping combustionDirect capture from air

CO2 TransportPipelines Already in use today for EOR

What is CCS?

Storage options (sequestration)Geological storageOcean StorageMineral storage

It is estimated that over 1000 years 99% of the injected CO2 could be retained (e.g. Sleipner gas field)

Alternative: CO2 Re-use?

CO2 + H2 MethanolCO2 CO Hydrocarbons

What is CCS?

from: www.ieagreen.org.uk

What is CCS?

from: www.ieagreen.org.uk

Chronology of the decisions on EU basis

9 May 1992 UNFCCC signatory to theKYOTO protocol

11 Dec 1997 3. UNFCCC conference adopted the KYOTO protocol

May 2000 EC launched the ECCP31 May 2002 Ratification (KYOTO) by council

decision 2202/358/EC 16 Feb 2005 KYOTO protocol entered into force2007 third working group meeting of

the ECCP discussed CCS23 Jan 2008 proposal on geological storage (CO2)

Directive 96/61/EC regulates CO2 captureDirective 85/337/EC regulates capture and pipeline transport and storage

Excursus: KYOTO protocol

36 developed countries + EU (Annex 1 countries)Kyoto includes "flexible mechanisms" for Annex I countries and companies (EU ETS) 137 developing countries have ratified the protocol, but have no obligation beyond monitoring and reporting emissions (non Annex 1 countries)The first commitment period of the Kyoto Protocol ends on December 31, 2012

green: signed & ratifiedyellow: signed, ratification

pendingred: signed, ratification

declinedblank: no position

www.en.wikipedia.org/wiki/Image:Kyoto_Protocol_participation_map_2005.png

The EU Commission’s proposal on CCS

Separate consideration of the three components of CCS – CAPTURE / TRANSPORT / STORAGEConservative approach: Include CCS in existing legal frameworkFor storage (injection): free standing legal framework

storage on territory, economic zones & continental shelves of the member statesno storage in the water column and on the seabed

IPPC Directive (96/61/EC)

IPPC Directive is about minimizing pollution from various sources throughout the EUANNEX 1 operators need permission (EU)Articles 1 and 2: Purpose and scope of the directive + definitionsArticle 3: sets out obligations for operatorsArticles 4-9: procedural matters (in permit system)Articles 9-10: competent authorities, BAT, emission and environmental standards, efficient energy use, safety and waste managementIPPC contains elements of flexibilityPublic participation

IPPC – Integration of CO2 capture

ANNEX 1 point 6.9:

“Capture of CO2 steams from installations covered by this directive (and its possible successor) for the purpose of geological storage pursuant to Directive XX/XX/EC…”

IPPC – Main problems with changes made

The proposal does not contain a definition of “capture of CO2” and what an “installation” is.

conflicts might arisedefinition of “installation” in IPPC directive applies to “technical connections” as well

IPPC Directive does not set standards for CO2 capture; instead it only suggests Best Available Techniques (BAT)

CSS under EIA Directive (85/337/EC)

CO2 transport is similar to other regulations in the EIA directive (ANNEX 1)Additions to the directive:

“16. Pipelines for the transport of gas, oil chemicals and pipelines for the transport of carbon dioxide steams for the purposes of geological storage…”

“23. Storage sites pursuant to directive XX/XX/EC“24. Installations for the capture of CO2 steams

for the purposes of geological storage pursuant to directive XX/XX/EC … from installations covered by this annex, or where the total yearly capture of CO2 is 1.5 mega tones and more”

ANNEX 2 point 3: “(j) Installations for the captureof CO2 … not covered by ANNEX 1 of this directive

EIA – Critique Points

Only pipeline transport coveredEIA requires no permit (Article 8)leakage of pipelines during construction is not

covered by the directive

Legal Framework for CO2 storage

Legal Framework for CO2 storage

ExplorationSpecific procedure (e.g. geological surveys )Requires a exploration permit by a competent authority

Storage permitOperator needs: e.g. information on storage site, technical competence, amount and composition of CO2 steams, environmental impact assessment, monitoring and post-closure planIf the competent authority is satisfied forward the draft to the commission which gives advise in within 6 month Authority may issue the permit!

Legal Framework for CO2 storage

CO2 steam acceptance criteria:Steam shall consist overwhelmingly of CO2No other matter may be added Safe concentrations of other substancesOperator must keep a exact register of all delivered CO2 steams (e.g. composition, origin)

MonitoringExcessive monitoring Monitoring plan best available practiceChange in CO2 behavior revision of risk assessment and new hazard scenariosReporting & Inspections

Legal Framework for CO2 storage

Access to transport network & storage sites:Fair and open access!Basic approachMember states take the necessary measures

Corrective measures:Corrective measures planReview of permits!

Legal Framework for CO2 storage

Closure and post-closure proceedings:Closure:

1. Conditions of permit have been met2. By request of the operator3. By request of the competent authority

Register of all closed storage sitesFinancial security (pledge, grant, funding etc.)Transfer of responsibility to the authorityPenalties are laid down by member states

Local environmental damage

Directive 2004/35/EC: Environmental Liability DirectiveDamage to protected species, habitats, water & land contamination and impact on human healthMeasures to restore damaged natural resources or provide an equivalent alternativeAfter transfer of responsibility the authority is liable for environmental damage

BUT: No Financial security from the operator required!

Modifications to other Directives

Water Framework Directive: exception from the prohibition on discharge of pollutants into groundwater (concerning injection into geological formations)

Large Combustion Plant Directive:New plants ≥ 300 MW need suitable space for capture and transport of CO2 and suitable storage sites

Waste Framework Directive:Exceptions captured, transported or stored CO2

Waste Transport Directive:Shipment of CO2 for purposes of geo. storage

Economic aspects

ETS Directive (2003/87/EC):CCS not included so farBut: Article 24 of ETS Directive: “Member Statescan, …, opt in a CCS installation for the second phase (2008-2012)”

o Should ETS cover the full chain of CCS?reduction of carbon pricesenhanced attractiveness of CCSETS on the basis of environmental integrity from 2013 at least parts of CCS will be included in

ANNEX 1 ETS1 ton stored = 1 ton avoided?

Conclusions

even though CCS can possibly be part of climate policies it should not reduce the attention and efforts on energy efficiency and renewable energies CCS will increase coal use If no specific measures are taken this will increase environmental (and health) issues:

Coal mining, processing and useMercury, dust, SO2 (sulphur dioxide), NOX (nitrates) and CO (carbon monoxide) emissionsNo legislation at all regulating mercury emissions

Conclusions

Not many sites for carbon storage in Europebut storage outside is not covered by theproposed directivestorage outside the EU will not receive credit under the ETS

http://news-service.stanford.edu/news/2007/june13/gifs/carbon_map.jpg This map shows carbon dioxide storage potential around the world. Estimates of worldwide storage capacity range from 2 trillion to 10 trillion tons of carbon dioxide

Conclusions

“Fast Track” process develop BAT for carbon capture by 2016.BREF’s as minimum requirement for permitsrevision clause in CCSD (2015) new developmentsCO2 steam acceptance criteria need to be more precise!robust minimum criteria for safety of storage placesFinancial security from the operator for environmental damage should be requiredThis Directive, and its successor, should be strengthened to further reduce all types of emissions from fossil fuel plants, and include emission limits for mercury as well.

Conclusions

Chances:Achieve the goals of climate protection (<450ppm)Option for use of coal with less CO2 emissionsTransfer technology to a regenerative futureElimination of large point sources Cost reduction of CCS through EOR, EGR and integration in ETSExport potential of CCS technologies

Risks:Higher energy-, transport-, and resource costs Higher discharge of other pollutants Higher electricity costsSecurity issues (Storage etc.)Long term liabilities?Unknown ecological implications

References

Rubin E. et al.: Cost and performance of fossil fuel power plants with CO2 capture and storage, Energy Policy, Volume 35, Issue 9, pages 4444-4454, September 2007 Schurmans M., Vaerenbergh A.: The new proposed EU legislation on geological carbon capture and storage (CCS): A first impression of the commission’s proposed framework on CCS, European Energy and Environmental Law Review, Volume 17, Number 2, pages 77-124, April 2008Metz, B. et al.: IPCC special report on Carbon Dioxide Capture and Storage (Prepared by working group III of the Intergovernmental Panel on Climate Change), Cambridge University Press, Cambridge, United Kingdom and New York (USA), 442 pp., 2005 Council Directive 96/61/EC of 24 September 1996 concerning integrated pollution prevention and controlCouncil Directive 85/337/EEC of 26.May 2003 on the assessment of the environmental impact of certain projects (EIA)

ReferencesCommission Of The European Communities, “Proposal for a directive of the European Parliament and of the Council on the geological storage of carbon dioxide and amending Council Directives 85/337/EEC, 96/61/EC, Directives 2000/60/EC, 2001/80/EC, 2004/35/EC, 2006/12/EC and Regulation (EC) No 1013/2006”, Brussels, 23.1.2008Commission Of The European Communities, “Accompanying document to the Proposal for a Directive of the European Parliament and the Council on the geological storage of carbon dioxide”, Impact Assessment, Brussels, 23.1.2008KYOTO Protocol to the United Nations framework convention on climate change, United Nations 1998EEB Position paper and amendments to the proposed Carbon Capture andStorage Directive, May 2008http://www.ieagreen.org.ukhttp://news-service.stanford.eduhttp://en.wikipedia.org/wiki/Carbon_capture_and_storagehttp://www.ipcc.ch