Three things you need to know about permitting CCUS

Carbon capture, utilisation, and storage (CCUS) is fast becoming one of the key methods by which operators of energy generation facilities intend to reduce their climate impact and is therefore a growing and key area for industrial decarbonisation. The reason for a growing interest in CCUS is in part due to its inclusion in the UK Government's "The Ten Point Plan for a Green Industrial Revolution", where the Government used Tata Chemicals Europe's Winnington carbon capture and utilisation (CCU) plant as a case study, which was officially opened for commercial operation in June 2022.

In order to be able to operate your CCUS facility, one of the relevant permissions that you need to obtain is an environmental permit from the relevant regulator. The type and scale of the carbon capture activity, as well as the type and scale of activity from which the carbon is being captured - and its location - will determine who the relevant regulator is and which type of permit you need to apply for. For environmental permitting purposes, in the UK a post-combustion carbon capture (PCC) plant capturing carbon dioxide for geological storage is a Part A (1) 6.10 activity in its own right. It could also be a directly associated activity with a combustion installation activity when the carbon dioxide is captured and used for other purposes. In both cases, there is likely to be another activity that needs to be included on the permit, such as a combustion installation activity that the carbon dioxide is being captured from.

These are the key points you need to consider when applying for a permit for a carbon capture plant:

1. Early discussion with the regulator

CCUS is still considered a novel process and there are currently no provisions for all possible processes and configurations within the available legislation and guidance. It is therefore imperative that you start a dialogue with your relevant regulator as early as possible. This will help you know what type of permit to apply for and which supporting assessments are required, as well as the estimated costs and timescales. This will also aid the regulator to understand the process and have time to source the relevant subject experts for the determination of your application.

The dialogue might be initiated through a formal enhanced pre-application process or a more informal discussion with a local officer who will pass the case on to the relevant team. Ricardo, in our experience, believe that early dialogue with the relevant regulator helps to ensure a much smoother process during your application.   

2. Best Available Techniques (BAT) assessment

For installation permit applications, a BAT assessment is required to support the application. This will set out the process techniques and mitigation measures in place at the facility and will set out why these techniques are the best that are currently available for that process or facility. To cover the carbon capture activity, the BAT assessment will need to include a systematic review of the proposed operating techniques against the relevant BAT conclusions or guidance.

In England, the Environment Agency has published guidance on BAT for PCC from the flue gases of power and CHP plants fuelled by natural gas and biomass. The guidance does not however include carbon capture for use, though much of this BAT guidance is relevant where amine solvents are used. The BAT assessment will only need to cover the area of risk regulated by the permit; in most cases this would be emissions to air only. Hence you will need to address only the requirements of the PCC BAT guidance that are relevant to your activity.

3. Air quality assessment

In addition to the consideration of the usual pollutants for the associated process (e.g. combustion), the supporting air emissions risk assessment (or air quality assessment) will need to consider all the pollutants emitted as a result of the carbon capture process.

For amine-based systems, this includes ammonia, amines and their degradation products (e.g. nitrosamines) and the UK Government's Air Quality Modelling and Assessment Unit (AQMAU) has released recommendations for the assessment and regulation of impacts to air quality from amine-based PCC plants. As part of the air quality assessment the regulator will likely need information on how the composition of the amine-based solvent determines its emission profile, including emissions of amine degradation products.

How can we help you?

Ricardo has experience of providing permitting support to a range of activities, including carbon capture projects. Our experience includes liaising with regulators, producing BAT assessments and carrying out air quality assessments, as well as producing other supporting documentation such as operating techniques, site condition reports and environmental risk assessments.

We are currently in the process of setting up our own biomass energy, carbon capture and storage (BIOCCUS) demonstration project, with funding from BEIS. This project aims to design, build and test an innovative biomass pyrolysis-based cogeneration system with biochar production and CCUS to enable highly significant, practical and scalable greenhouse gas removal systems to help progression towards net zero carbon.

The BIOCCUS system uses forestry waste to create biochar, carbon dioxide, electricity and heat. In collaboration with Woodtek and Bluebox Energy, we are in the process of finalising the design of the BIOCCUS demonstration plant. We are also currently applying for the planning permission and environmental permit needed to build and operate the plant when the design is ready.

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