December 2024

Increased Flexibility

The Applicant is seeking to update the Draft DCO (AS-056) to facilitate an approach that would allow for flexibility and efficiency of the Proposed Scheme as identified by the ongoing design development.

• Work Number 1A – Design development has identified that the cooling system for the Proposed Scheme may be able to be optimised through additionally providing for the use of electrically driven fans passing air over finned tubes to cool fluid being used as part of the carbon capture process. These finned tubes would sit above the proposed process pipe and duct bridges and equipment components within the area of Work No. 1A. This change would involve the addition of “air-cooled heat transfer systems” at the end of Work Number 1A in Schedule 1 of the DCO. These fins would be within the overall height parameters set by the DCO.
• Work Number 1B – The Stack(s) may no longer be located directly on top of the Absorber Column(s), rather the Stack(s) could potentially be connected to, but forming a separate stack, or totally separate from, and directly adjacent to, the Absorber Column(s). This change would facilitate a ground-mounted gas heat exchanger, which may enhance heat recovery and reduce the cooling load for the Carbon Capture Facility. The height of the Stack(s) will remain similar to the current proposals. The Applicant will retain the minimum 30m distance between the top of the Stack(s) and the Absorber Column(s) to avoid downwash of pollutants. However, it is acknowledged that greater clarity of this potential design approach needs to be accounted for in how the parameters are expressed in Schedule 16 of the DCO, and so this will form the basis of the Change Application.

Parameters

The following relate to the parameters set by the Applicant, specifically those set out in Table 2-2 within Chapter 2: Site and Proposed Scheme Description of the Environmental Statement (APP-051) and Schedule 16 of Draft DCO (AS-056):

• Potential maximum increase in the height of the ‘Regenerator’ – The Applicant now seeks the flexibility for the Solvent Regeneration System to be able to be constructed, such that the Regenerator Column sits above the Solvent Processing System, rather than separately, thereby increasing the overall height of the System to 60m (63m AOD) 1 .
• Exclusion of the ‘Great Breach Pumping Station’ – This relates to the reduction of Order Limits to exclude the Great Breach Pumping Station (the removal of plot 1-122). The Applicant had originally included this plot to allow for the ability to undertake ‘protective works’ if these were required to the pumping station – although none had been assessed as necessary in the Environmental Statement, previous engagement with the Environment Agency indicated that they were concerned that this might be necessary in any event. However, given that the Environment Agency then in its Relevant Representation considered that they did not want the pumping station in the Order Limits, the plot was removed. As stated at ISH1 (Issue Specific Hearing 1), this change does not have any implications for any other aspect of the Application documentation save for the plans showing the Order Limits and the Book of Reference. In particular, the plot was a small plot and its removal has limited effect to the study areas of assessment (which post removal, would in any event become more precautionary).

Clarifications in Schedule 1

The following amendments to the Draft DCO (AS-056) comprise changes to the wording only. These revisions are intended to provide additional clarification as to what is able to be included within specific Work Numbers as defined by the Schedule 1 and the Works Plans (AS-053):

• Work Number 1A (i) – The word ‘system’ will be included. This is to all system processes which form part of flue gas pre-treatment are encapsulated in what is consented.
• Work Number 1A (v) – The word ‘system’ will be included. This is to capture all system processes which form part of solvent heat exchange are encapsulated in what is consented
• Work Number 1C (iii) – The phrase ‘and deoxidation’ will be added after liquefaction unit(s). This is to capture all processes, including deoxidation which form part of the CO2 conditioning system(s) (of which the liquefaction also forms part).
• Work Number 1C – Addition of ‘chemical storage and distribution handling facilities’. This is in addition to the ‘chemical storage and distribution handling facilities’ which will be located in Work Number 1E(viii). A number of chemicals are required for operation of the Carbon Capture Facility, including for flue gas pre-treatment and CO2 Processing Plant which are located in within Work Number 1.

At this early stage, the Applicant considers that the only EIA topics likely to be of relevance for these proposed changes are Townscape and Visual, Air Quality and Noise and Vibration.

From a Townscape and Visual perspective, these changes all relate to flexibility within a new industrial facility that has already been assessed, as such it is also considered unlikely that any new likely significant effects would arise. However, this will be considered in the Change Application, which will include revised iteration of Appendix 10-4: Photomontages of the Environmental Statement (Volume 3) (APP-104) to account for the proposed change to the Absorber Column(s) and Stack(s), cooling system and the Regenerator parameters. These have been produced to inform the consultation process and will be submitted as part of our Change Application. These images are available to view on this page as well as in our document library.

With regards to Air Quality, no additional air quality modelling to account for the potential change to stack design is considered to be necessary (i.e. the stack potentially being off-set from the absorber column). The Applicant has previously undertaken a suite of sensitivity tests that looked at various position and designs for the stack. The base parameters that informed the assessment in Chapter 5: Air Quality of the Environmental Statement (Volume 1) (APP-054) (i.e. that there is a 30m gap between the top of an Absorber Column(s) and Stack(s)) are remaining and as such the findings of, and the assessment presented in, Chapter 5: Air Quality of the Environmental Statement (Volume 1) (APP-054) are expected to remain as reported.

With regards to Noise and Vibration, it is acknowledged that the changes will generate a small amount of additional noise during the operation phase, concentrated in the north of the Site. However, this is unlikely to result in a change to the magnitude of impact of operational noise reported in Chapter 6: Noise and Vibration (Volume 1) of the Environmental Statement (APP-055). The findings of, and the assessment presented in, Chapter 6: Noise and Vibration (Volume 1) of the Environmental Statement (APP-055) are expected to remain as reported.

As such, at this stage is not considered that the proposed change is expected to result in changes to the overall likely significant effects as reported in the Environmental Statement. However, this will be confirmed in the Change Application.

Within the Change Application, the Applicant will include an environmental analysis to consider if the proposed changes would affect the environmental assessments reported in Chapter 5: Air Quality (APP-054) to Chapter 21: Cumulative Effects (APP-70) of the Environmental Statement (Volume 1), as amended, and the extent to which these would be different as a result of the proposed changes described above.