KCP-GNS-SHE-DPR-0003

Revision: 04

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Kingsnorth Carbon Capture & Storage Project
Fire and CO2 Impact & Prevention Design Philosophy - Pipeline and Offshore
Installation

Fire and CO2 Impact & Prevention Design Philosophy - Pipeline and
Offshore Installation
Table of Contents
1. Scope and Functional Requirements ................................................................................................. 2
1.1. Scope of Document ................................................................................................................. 2
1.2. Definitions ................................................................................................................................ 3
1.3. Abbreviations ........................................................................................................................... 3
2. Assumptions....................................................................................................................................... 4
2.1. Fire Prevention and Mitigation ................................................................................................. 4
2.2. CO2 Impact Prevention ............................................................................................................ 4
2.3. Pipeline Inventory and Storage ............................................................................................... 5
3. Design Requirements ........................................................................................................................ 6
3.1. General .................................................................................................................................... 6
3.2. Fire ........................................................................................................................................... 6
3.3. CO2 Impact Prevention ............................................................................................................ 6
3.4. Facilities Layout (Onshore and Offshore) ................................................................................ 7
4. Mandatory References ....................................................................................................................... 9
5. Supporting References .................................................................................................................... 10

Sch 7 ref.: 6.55

Approved for Knowledge Transfer

Signature:
Date:

Kingsnorth CCS Demonstration Project

The information contained in this document (the Information) is provided in good faith.
E.ON UK plc, its subcontractors, subsidiaries, affiliates, employees, advisers, and the Department of Energy and Climate Change
(DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Information and neither E.ON UK
plc nor any of its subcontractors, subsidiaries, affiliates, employees, advisers or DECC shall have any liability whatsoever for any
direct or indirect loss howsoever arising from the use of the Information by any party.

KCP-GNS-SHE-DPR-0003
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Kingsnorth Carbon Capture & Storage Project
Fire and CO2 Impact & Prevention Design Philosophy - Pipeline and Offshore
Installation

1. Scope and Functional Requirements

1.1. Scope of Document
The purpose of this document is to present the Fire and CO2 Impact and Prevention Design
Philosophy for the pipeline and offshore installation operations for the E.ON Kingsnorth
Carbon Capture and Storage (CCS) development. The focus of this document relates to the
sections downstream of the compression facilities, notably the pipeline and offshore
installation including any above ground installation. Figure 1-1 shows a schematic of the CCS
system, including the onshore plant, the pipeline and offshore facilities. As the initial pipeline
section is within the site boundary, this document references the Fire and CO2 Impact &
Prevention Philosophy document [S1]. This document describes the philosophy that would be
applied within the site boundary and, as such, it is relevant to the sections of the system
downstream of the compression facilities that are within the site.

Figure 1-1: Outline System Schematic

This Fire and CO2 Impact and Prevention Design Philosophy considers the facilities required
during the operational phase of the CCS Project alone, as this phase constitutes the primary
period when the hazards are present in the pipeline and offshore. Figure 1-1 shows that part
Kingsnorth CCS Demonstration Project
The information contained in this document (the Information) is provided in good faith.
E.ON UK plc, its subcontractors, subsidiaries, affiliates, employees, advisers, and the Department of Energy and Climate Change
(DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Information and neither E.ON UK
plc nor any of its subcontractors, subsidiaries, affiliates, employees, advisers or DECC shall have any liability whatsoever for any
direct or indirect loss howsoever arising from the use of the Information by any party.

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Kingsnorth Carbon Capture & Storage Project
Fire and CO2 Impact & Prevention Design Philosophy - Pipeline and Offshore
Installation

of the system covered here is within the onshore site, as it is downstream of the compression
facilities but upstream of the boundary ESDV on the pipeline. This scope of this philosophy
document starts immediately upstream of the Kingsnorth Power station flow meter and ends
at the connection at the well Xmas tree.

1.2. Definitions
1.3. Abbreviations
AGI

Above Ground Installation - location of the Landfall valve

ALARP

As Low As is Reasonably Practicable

CAP 437 Offshore Helicopter Landing Areas Guidance on Standards, CAA publication
CCR

Central Control Room

CCS

Carbon Capture and Storage

CCSA

Carbon Capture and Storage Association

CO2

Carbon Dioxide

COMAH

Control of Major Accident Hazards Regulations

DCR

The Offshore Installations and Wells (Design and Construction, etc.) Regulations
1996

ESDV

Emergency Shutdown valve

HAZID

Hazard Identification (study)

HSE

The Health and Safety Executive (a UK Government agency)

MAH

Major Accident Hazard

MSDS

Material Safety Data Sheet

NFPA

National Fire Protection Association (USA)

TR

Temporary Refuge (a place of safety, the specification of which ensures the safety
of personnel against defined hazards for a defined period of time)

UPS

Uninterruptible Power Supply

Kingsnorth CCS Demonstration Project

The information contained in this document (the Information) is provided in good faith.
E.ON UK plc, its subcontractors, subsidiaries, affiliates, employees, advisers, and the Department of Energy and Climate Change
(DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Information and neither E.ON UK
plc nor any of its subcontractors, subsidiaries, affiliates, employees, advisers or DECC shall have any liability whatsoever for any
direct or indirect loss howsoever arising from the use of the Information by any party.

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Kingsnorth Carbon Capture & Storage Project
Fire and CO2 Impact & Prevention Design Philosophy - Pipeline and Offshore
Installation

2. Assumptions
2.1. Fire Prevention and Mitigation
For the onsite pipeline section, the fire prevention and mitigation approach shall correspond to
the approach adopted elsewhere within the CCS plant. Fire protection at this pipeline section
is expected to adopt the standard applied elsewhere within this site, which is likely to be
NFPA 850, as is common practice in the power industry [M1].
It is expected that there will be a single fire water supply system (water storage and pumps)
for the combined power station and CCS plant, which will also be available to the onsite
pipeline section and pig launcher area.
The length of escape routes and other fire safety arrangements within the site around the
pipeline and pig launcher facilities shall conform with the general site arrangements, are likely
to be according to BS9999:2008 [M3]. The combined fire detection and alarm system for the
site will also incorporate this area of the site and will be monitored and controlled from the
power stations central control room (CCR).
Outside the site boundaries, the same fire hazards are not present, as the source of fuel and
the means to ignite and sustain a fire are reduced to those in the normal environment. The
pipeline and any above ground installation will be unlikely to contribute to any fire or its
inception and would in fact act as an extinguishant should a release occur.
On the offshore installation, fuel sources may be present (in the form of transformer oil/resin,
diesel or a fuel gas pipeline in later life for CO2 heating prior to well injection), as well as
ignition sources such as electrical circuitry, so appropriate fire protection for the Normally
Unmanned Installation (NUI) would need to be in place.
2.2. CO2 Impact Prevention
Large releases of CO2 present a hazard to staff and the public, as high concentrations of CO2
are toxic and can cause asphyxiation. The design of the pipeline and offshore installation
shall include measures to eliminate the risk of release where possible, to detect releases and
to minimise the size and effect of a release. Onsite, escape routes and refuges will be
required. CO2 may accumulate in confined spaces and other locations with restricted
ventilation, especially low-lying areas, trenches and excavations along the onshore sections
of the pipeline and in areas of the offshore installation where ventilation may be restricted, so
specific means of prevention and detection against this hazard shall need to be adopted.
The hazard classification of CO2 is such that is does not currently attract the duties of major
hazard legislation (COMAH) normally required to control those activities that present
significant hazards [M2]. The HSE is currently considering whether the risks associated with
the CCS process merit extending the major hazard regulatory regimes to these projects by
looking at further research, practice in other countries and by informal consultation with
stakeholders [S2]. This would introduce CO2 as a hazardous substance at the EU Directive
level, ensuring similar MAH management response across the EU, rather than just in the UK.
Similarly, the HSE have issued a Consultative Document to revise the Pipeline Safety
Regulations to include CO2 as a dangerous fluid [S3]. The consultation period for this ended
on 1 March 2010, so the findings of this should become available in the near future.
For the offshore installation, the presence of CO2 would be treated the same as any potential
event capable of causing an MAH and treated as a toxic and asphyxiating substance capable
Kingsnorth CCS Demonstration Project
The information contained in this document (the Information) is provided in good faith.
E.ON UK plc, its subcontractors, subsidiaries, affiliates, employees, advisers, and the Department of Energy and Climate Change
(DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Information and neither E.ON UK
plc nor any of its subcontractors, subsidiaries, affiliates, employees, advisers or DECC shall have any liability whatsoever for any
direct or indirect loss howsoever arising from the use of the Information by any party.

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Kingsnorth Carbon Capture & Storage Project
Fire and CO2 Impact & Prevention Design Philosophy - Pipeline and Offshore
Installation

of causing multiple fatalities. As the offshore installation would be considered a nonproduction installation, the assessment of MAH management would be provided in an
Offshore Safety Case, with sections covering installation description, offshore installation
management and the management of Major Accident Hazards.
At present it would therefore be appropriate to assume CO2 will be classified as a dangerous
substance under COMAH and a dangerous fluid under the Pipeline Safety Regulations and
will also require an Offshore Safety Case to be prepared.

2.3. Pipeline Inventory and Storage

The scope of this document includes the hazards from the offsite pipeline inventory. Hazards
include backflow from the offsite pipeline (until isolated by ESDV at the site boundary), losses
of containment along the land section of the pipeline and the offshore section, through the
estuary and into the North Sea, and those associated with the offshore installation, such as
releases from the subsea pipeline or riser at the installation.
CO2 storage at Kingsnorth has been confirmed to be not required. At the Cross-System High
Level HAZID/ENVID, (held on 30 June 2010 [S4]) it was agreed that storage would not be
required on the condition that the wells and reservoir can withstand periodic stoppages of flow
to each well. This was subsequently confirmed as acceptable by Baker RDS.

Kingsnorth CCS Demonstration Project

The information contained in this document (the Information) is provided in good faith.
E.ON UK plc, its subcontractors, subsidiaries, affiliates, employees, advisers, and the Department of Energy and Climate Change
(DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Information and neither E.ON UK
plc nor any of its subcontractors, subsidiaries, affiliates, employees, advisers or DECC shall have any liability whatsoever for any
direct or indirect loss howsoever arising from the use of the Information by any party.

KCP-GNS-SHE-DPR-0003
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Kingsnorth Carbon Capture & Storage Project
Fire and CO2 Impact & Prevention Design Philosophy - Pipeline and Offshore
Installation

3. Design Requirements
3.1. General
The whole capture and storage chain must be acceptable to E.ONs insurers and comply with
all relevant legal requirements and HSE guidance. Specific requirements are set out below.
3.2. Fire
Due to the nature of CO2 as an extinguishing agent, the pipeline and associated above
ground installations pose little risk of a fire. The pipeline therefore presents little in terms of
design requirements for managing fire hazards. The above ground installation (AGI) at the
landfall valve is one location where fire hazards may arise along the onshore pipeline. There
will be electrical equipment here, along with a UPS for valve actuation. As this facility is
manned only during periods of maintenance and inspection, it is considered appropriate that
any portable fire fighting equipment for this facility would be transported with the personnel to
the site, rather than maintain and secure storage facilities for the firefighting equipment at the
AGI.
Impacts on the environment due to the use of fire prevention techniques will be eliminated by
design where possible or where it is not practical to do so, minimised so as to meet relevant
environmental standards or limits.
On the offshore installation, a risk assessment of sources of fire and their potential for causing
harm will be undertaken, to identify appropriate means of effective control. The presence of
electrical equipment, transformer oils or resins, heaters and of a storage vessel for methanol
provide the main sources of fire and ignition, which will be documented along with the
appropriate means of effective control. With the exception of the helideck fire fighting
capabilities, which will need to conform to the requirements of CAP 437 (See Ref. [M5]), it is
anticipated that effective fire control will be achieved via the provision of portable fire
extinguishing appliances.
3.3. CO2 Impact Prevention
The FEED1A study shall include an assessment to:
1.
2.
3.
4.
5.
6.

Identify areas where there is a risk of a significant release of CO2 (a HAZID study).
Identify appropriate design codes to minimise the risk of release through appropriate
layout design and design with appropriate levels of integrity.
Identify means to detect releases of sufficient magnitude that give rise to consequences
of concern.
Identify the means to minimise the quantity of any release and the remaining risk.
Assess the hazard arising from a release and the measures to manage this.
Demonstrate that the residual risks are ALARP.

All studies relating to CO2 risk assessment shall take into account guidance based on
industrial best practice with respect to CO2, including that produced by the Energy Institute on
behalf of the Carbon Capture and Storage Association [S5][S6][S7][S8][S9]. This applies
both onshore (on the land section of the pipeline) and offshore on the installation. The above
ground installation (AGI) at the landfall valve presents a potential location for an unhindered
release of CO2, whereas any release below ground on the onshore pipeline section would
need to first find a path through the ground to reach the surface. It should be noted that the
design has only the bypass valve section above ground. The main landfall valves are located
Kingsnorth CCS Demonstration Project
The information contained in this document (the Information) is provided in good faith.
E.ON UK plc, its subcontractors, subsidiaries, affiliates, employees, advisers, and the Department of Energy and Climate Change
(DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Information and neither E.ON UK
plc nor any of its subcontractors, subsidiaries, affiliates, employees, advisers or DECC shall have any liability whatsoever for any
direct or indirect loss howsoever arising from the use of the Information by any party.

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Kingsnorth Carbon Capture & Storage Project
Fire and CO2 Impact & Prevention Design Philosophy - Pipeline and Offshore
Installation

below ground. For a minor releases at flanges or valves, the difference between below and
above ground releases is considered to be significant, but for a major fracture, this issue is
not considered to influence the overall behaviour of the release to a great extent, or its
subsequent dispersion.
Impacts on the environment will be eliminated by design where possible or where it is not
practical to do so, minimised so as to meet relevant environmental standards or limits. The
risk assessment shall include risk to health and the environment of impurities released with
the CO2 and of any pipeline fragmentation caused by rapid liquid depressurisation causing an
unconfined expanding vapour release from the pipeline during dense phase operations.
On the offshore installation, the design shall consider the effects of venting CO2 from high
pressure when equipment is vented to allow maintenance, including the potential
depressurisation of the pipeline. This will require the selection of appropriate valves and
materials, and vents to be located in safe locations where the vented gas will not impinge on
other facilities or create a hazard to personnel, including those on vessels in the vicinity.
The HAZID study should consider the effect of unexpected, sudden release of CO2
downstream of the compression plant in the event of containment failure, as well as along the
pipeline (onshore and offshore sections) and at the offshore installation.
3.4. Facilities Layout (Onshore and Offshore)
The facilities layout should, where practical, be such that the hazard arising from a CO2
release is minimised, and thus subject to emergency procedures. If the onshore effects are
significant beyond the site boundary or as a result of a pipeline leak on the onshore pipeline
section, then the onsite emergency plan will need to address this risk to the public and include
appropriate action initiated from the site.
As the pipeline section within the site boundary is located remotely from the carbon capture
plant, the hazards from CO2 releases within the carbon capture plant are likely to have an
impact on the pipeline section only for the upper end of credible scenarios. Thus, a site
emergency is likely to have been initiated elsewhere within the plant and any personnel in the
pipeline section area would have needed to respond appropriately, in line with the site
emergency plan, before any immediate impact on the pipeline section would arise.
For an onshore pipeline release, there is the potential for impact on the neighbouring areas of
population as well as a potential impact back onto the Kingsnorth site. The pipeline follows a
route to the east of the Kingsnorth site and then northwestwards, so that it runs to the north of
the Kingsnorth Power Station. The onsite emergency plan would need to account for the
potential impact the pipeline may have on the site, as this has the potential to be the largest
available inventory to sustain a release affecting either the local population or the site.
The offshore pipeline poses some risks to passing vessels, in the event of a loss of
containment, as well as to any population along the estuary. Once the pipeline is in clear
water, this risk reduces to those vessels that might be in the vicinity when a major loss of
containment occurs. The route selection shall take account of the hazards posed to local
populations. Other than provision of a suitable radio warning to shipping, an emergency
response plan to mitigate the effect of a major offshore loss of containment is considered
impractical.
On the offshore installation, the layout of the facilities, including the location and design of the
Temporary Refuge (TR) and the access and escape routes, shall take account of the need for
Kingsnorth CCS Demonstration Project
The information contained in this document (the Information) is provided in good faith.
E.ON UK plc, its subcontractors, subsidiaries, affiliates, employees, advisers, and the Department of Energy and Climate Change
(DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Information and neither E.ON UK
plc nor any of its subcontractors, subsidiaries, affiliates, employees, advisers or DECC shall have any liability whatsoever for any
direct or indirect loss howsoever arising from the use of the Information by any party.

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Kingsnorth Carbon Capture & Storage Project
Fire and CO2 Impact & Prevention Design Philosophy - Pipeline and Offshore
Installation

personnel to be able to escape to the safety of the TR in the event of a fire or CO2 release.
The specification of the TR shall be defined within the detailed design phase of the project.

The layout of equipment shall take into account the needs for appropriate access and egress
routes to the TR in the event of a major incident, including the location of the vent for
depressurisation. The requirement for installation escape and evacuation shall be assessed
as part of the review of MAHs offshore.

Kingsnorth CCS Demonstration Project

The information contained in this document (the Information) is provided in good faith.
E.ON UK plc, its subcontractors, subsidiaries, affiliates, employees, advisers, and the Department of Energy and Climate Change
(DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Information and neither E.ON UK
plc nor any of its subcontractors, subsidiaries, affiliates, employees, advisers or DECC shall have any liability whatsoever for any
direct or indirect loss howsoever arising from the use of the Information by any party.

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Fire and CO2 Impact & Prevention Design Philosophy - Pipeline and Offshore
Installation

4. Mandatory References
[M1]

NFPA 850:2005 Recommended practice for Fire Protection for Electric Generating
Plants and High Voltage Direct Current Converter Stations.

[M2]

L111 A Guide to the Control of Major Accident Hazards Regulations 1999 (as
amended).

[M3]

BS 9999:2008 Code of practice for fire safety in the design, management and use of
buildings.

[M4]

BS 5908:1990 Code of practice for fire precautions in the chemical and allied
industries.

[M5]

Offshore Helicopter Landing Areas Guidance on Standards, Civil Aviation Authority,

CAP 437, December 2008.

Kingsnorth CCS Demonstration Project

The information contained in this document (the Information) is provided in good faith.
E.ON UK plc, its subcontractors, subsidiaries, affiliates, employees, advisers, and the Department of Energy and Climate Change
(DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Information and neither E.ON UK
plc nor any of its subcontractors, subsidiaries, affiliates, employees, advisers or DECC shall have any liability whatsoever for any
direct or indirect loss howsoever arising from the use of the Information by any party.

KCP-GNS-SHE-DPR-0003
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Kingsnorth Carbon Capture & Storage Project
Fire and CO2 Impact & Prevention Design Philosophy - Pipeline and Offshore
Installation

5. Supporting References
[S1]

Fire and CO2 Impact Prevention Design Philosophy, KCP-EEN-FPC-DPR-0001 Rev

03, 17 July 2010

[S2]

HSE, The Inclusion of CO2 as a Hazardous Substance in the Seveso Directive

[S3]

HSE, Consultation on Amendments to the Pipeline Safety Regulations 1996 and the
Health and Safety (Fees) Regulations, CD 228, 2009.

[S4]

Genesis Oil and Gas Consultants, Cross-System High Level HAZID/ENVID Overview
Report, KCP-GNS-SHE-HZI-0002 Rev 02, 24 August 2010.

[S5]

HSE RR749. Comparison of risks from carbon dioxide and natural gas pipelines.

[S6]

CCSA & Energy Institute. Good Plant Design and Operation for Onshore Carbon
Capture Installations and Onshore Pipelines

[S7]

CCSA & Energy Institute. Technical Guidance on Hazard Analysis for Onshore
Carbon Capture Installations & Onshore Pipelines.

[S8]

DNV 2009-0545. Project Specific Guideline for Safe, Reliable and Cost Effective
Transmission of CO2 in Pipelines

[S9]

DNV 2008-1993. Mapping of potential HSE issues related to large-scale capture,

transport and storage of CO2

Kingsnorth CCS Demonstration Project

The information contained in this document (the Information) is provided in good faith.
E.ON UK plc, its subcontractors, subsidiaries, affiliates, employees, advisers, and the Department of Energy and Climate Change
(DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Information and neither E.ON UK
plc nor any of its subcontractors, subsidiaries, affiliates, employees, advisers or DECC shall have any liability whatsoever for any
direct or indirect loss howsoever arising from the use of the Information by any party.