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Permitting the UK’s largest carbon capture and utilisation plant
Carbon Capture and Storage (CCS), which includes carbon capture and utilisation (CCU), is positioned as one of our greatest weapons in the fight against climate change. Our Environmental Permitting team have played a vital role in bringing the UK's largest CCU project to life, helping to shape the future technology that will be key for industry in the pursuit of net zero carbon.
Jennifer Stringer
Featured in the government’s ‘10 Point Plan for a Green Industrial Revolution’ and backed by £1bn of funding, CCS will be used to decarbonise our most challenging sectors and work is underway to establish the process in two industrial clusters by mid 2020. Projects are already coming to life with Tata Chemicals Europe's (TCE's) CCU Demonstration Plant, the UK’s first industrial-scale plant, in the final stages of construction. The Winnington site in Northwich, Cheshire manufactures high-grade sodium bicarbonate, TCE’s largest export product; used in food and pharmaceutical applications.
Permit variation
The inclusion of the CCU plant into TCE's current operations meant that a variation to the existing Winnington CHP plant Part A(1) permit from the Environment Agency (EA) was required.
RPS provided permitting advice, supported pre-application and post-submission discussions with the EA, and provided support for full permit variation application and post-application services, including air dispersion modelling and odour assessment. We also supported the application to vary the water abstraction licence to incorporate the additional volume of cooling water required for the carbon capture process.
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How will TCE's CCU work?
The CCU plant will use an amine solution containing the solvent monoethanolamine (MEA) to capture carbon dioxide (CO2) from a portion of the exhaust gases from the gas-fired combined heat and power (CHP) plant on the same site, which supplies heat and power to TCE’s operations in the area as well as to other local industry.
Approximately 11% of the exhaust gases from the CHP plant will be redirected to the CCU plant (which will capture circa 85% of the CO2 from the exhaust gas) equating to approximately 40,000 tonnes of CO2 captured per year. The CCU plant will purify and liquefy the captured carbon dioxide, after which it will be stored prior to its use in the manufacture of sodium bicarbonate at TCE’s facility located just down the road.
As CCU is a relatively new technology which hasn’t been operated on this scale in the UK, there was a lack of existing data and guidance available. We worked together with TCE, the technology provider and the EA throughout the process to agree the approach and gather the necessary data to support the proposals for the facility in the absence of a defined regulatory position.
Jennifer Stringer
Technical Director
Permitting challenges
The key permitting challenges posed by this project were:
- The lack of defined BAT for carbon capture technology
- The absence of defined emission limit values (ELVs) for key emissions
- The absence of environmental assessment levels (EALs) for key emissions
- The lack of defined monitoring regime for key emissions
To address the lack of defined BAT and relevant ELVs for carbon capture technology in the UK, we conducted a BAT assessment early on in the process. This set out supporting information for BAT for the abatement of MEA, including information to support the proposed ELV for MEA. Reference was made to existing European guidance, such as Annex 4 of the German air quality regulations (TA Luft) and the BAT reference document for Production of Large Volume Organic Chemicals (LVOC), published works from the Ferrybridge pilot plant as well as information provided by the technology provider regarding their technology guarantees and what is in place at their existing plants elsewhere in Europe.
This BAT assessment was then discussed with the EA at the pre-application stage, their comments were addressed and the approach was accepted as BAT by the EA at the determination stage. “Through our involvement on this project, RPS has been at the forefront of the EA setting BAT for future carbon capture projects” adds Jennifer.
A further challenge was the lack of environmental assessment levels (EALs) for key pollutants such as MEA and nitrosamines (NDELA), which are emitted as a result of using MEA as the solvent. For MEA the EAL used in the assessment was derived from workplace occupational exposure limits whereas for nitrosamines, an EAL from the Norwegian Institute of Public Health was used. The Norwegian EAL is expressed as a NDMA (N-nitrosodimethylamine) equivalent and the modelled nitrosamines (NDELA) concentration had to be corrected to NDMA. In November 2020, the EA opened up a consultation[1] on new EALs, which proposes the introduction of EALs for MEA and NDMA. The consultation closed on 7th February 2021.
To address the absence of a defined monitoring regime, we worked with the determining officer to have early sight of the EA’s monitoring expectations. We reviewed the feasibility of the proposed suite with analytical laboratories to agree a revised monitoring suite that included only parameters where approved monitoring methods were available to ensure EA monitoring expectations could be delivered.
The varied environmental permit is currently being drafted by the EA prior to issue to the operator.
“Working with TCE to bring their CCU project to life has been particularly exciting for RPS” concludes Jennifer. “As the UK pushes forward with its roll out of carbon capture and storage solutions, we have been involved from the early days, helping to shape the future of this technology. CCU and CCS will be a vital part of achieving net zero for many of our industrial, energy and waste clients. Together with our expertise in setting science-based GHG targets, designing and consenting low-carbon developments, a thorough understanding of the processes, technology and environmental permitting for CCU and CCS puts RPS in a leading position to support developers as these projects are increasingly deployed to meet net zero goals”.
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