澳门玄机图

Featured in the government鈥檚 鈥�10 Point Plan for a Green Industrial Revolution鈥� and backed by 拢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听Tata Chemicals Europe's (TCE's) CCU Demonstration Plant, the UK鈥檚 first industrial-scale plant, in the final stages of construction. The Winnington site in Northwich, Cheshire manufactures high-grade sodium bicarbonate, TCE鈥檚 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.

澳门玄机图 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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Permitting challenges

The key permitting challenges posed by this project were:

1. The lack of defined BAT for carbon capture technology
2. The absence of defined emission limit values (ELVs) for key emissions
3. The absence of environmental assessment levels (EALs) for key emissions
4. 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. 鈥�Through our involvement on this project, 澳门玄机图 has been at the forefront of the EA setting BAT for future carbon capture projects鈥� 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 7^th February 2021.

To address the absence of a defined monitoring regime, we worked with the determining officer to have early sight of the EA鈥檚 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.

鈥�Working with TCE to bring their CCU project to life has been particularly exciting for 澳门玄机图鈥� concludes Jennifer. 鈥�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 澳门玄机图 in a leading position to support developers as these projects are increasingly deployed to meet net zero goals鈥�.

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