EUROFER position paper on Directive for Geological Storage - 23 November 2008

EUROFER proposes that the Directive should not include a specific percentage for the purity of the CO2 stream. EUROFER is favour of maintaining the Commission text of Article 12 (“CO2 stream shall overwhelmingly consist” of carbon dioxide”). This is in line with the wording the OSPAR Convention has adopted for transport and geological storage of CO2 in the marine environment.

EUROFER proposes that the exemption from the Directive should apply to all R&D testing and demonstration projects. In the steel industry, demonstration projects could easily be larger than the threshold of 100 kilotonnes, as suggested by Amendment 11 in the Environment Committee of the European Parliament.

EUROFER notes that “corrective measures” as a first approach can only try to minimise release from CO2 from storage complexes. The obligation to “stop” such releases is the ideal situation with respect to health but from a legal perspective –due to the absolute character- may make operation technically impossible.

Background information on the issue of the purity of the CO2-stream:

Legislation should be technology neutral: Imposing a purity criterion without taking into account all possible capture and storage technologies and without assessing on a scientific basis of the risks associated with them, could result in excluding specific technologies from the market; particularly, the energy required by capture technique has to be assessed. The purity thresholds discussed are aligned to the levels which can be achieved with combinations of power plants and amine scrubbing but seem to a lesser extent to be based on analysis of overall risk, energy demand and costs. Such investigations will be part of the upcoming demonstration projects, such as the second phase of ULCOS II but also the research projects in the power sector.

Published specifications for CO2-purity of transport and storage are available from the ENCAP project another from the Dynamis project (both supported by the EU Framework 6 programme). ENCAP is oriented to the power sector and Dynamis is specific for hydrogen generation and electricity production. ENCAP proposes 90% as the lower limit of CO2 concentration, rising to 95% when there is a severe limit on toxic components, for example transport in the liquid phase by ship where a catastrophic accident could lead to the entire cargo being released. Dynamis has a higher threshold of >95.5% CO2 with tighter limits on toxic components, such as CO.

The partial pressure of CO2 (concentration multiplied by total pressure) is higher in steel making processes than is the case in power plants, at least in post combustion capture. Additionally, the top-gas recycling process under investigation for the blast furnace is an in-process capture, as no combustion is carried out but reduction. The concepts of oxy-combustion, pre and post-combustion capture do not fit to the specific situation of the steel industry processes. These two factors lead to a choice of a physical adsorption process (called Pressure Swing Adsorption - PSA- or its variant Vacuum Pressure Swing Adsorption - VPSA) for capture of CO2 in many scenarios we have investigated in ULCOS. A characteristic of the PSA and VPSA processes is that the CO2 rich gas cannot reach the >95.5% specification from Dynamis and may not reach the lower requirement of >90% from ENCAP. Meeting the tighter specifications is technically possible, but it imposes a higher cost in terms of money and energy.

Legislation should be drafted in a way which accommodates technologies in sectors other than the power sector: EUROFER therefore proposes that at this stage of development, legislation should not be unnecessarily prescriptive.