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KCP-EUK-OPM-DPR-0003 Revision: 04 Project Title: Document Title: Kingsnorth Carbon Capture & Storage Project Inspection & Maintenance

Philosophy Page 1 of 10

Inspection & Maintenance Philosophy

Table of Contents 1. 2. 3. 4. 5. 5.1 5.1.1 5.1.2 5.2 5.3 5.3.1 5.3.2 5.3.3 5.3.4 5.4 5.5 6. 7. 8. 9. 10. Scope & Function Requirements Assumptions Rule One Construction Design and Management (CDM) Maintenance Requirements Whole Chain Powerplant & Capture Boiler & Turbine Generator Capture Plant Specifics Pipeline Pipeline Corrosion Protection Onshore Pipeline Specifics Offshore Pipeline Specifics Pipeline Pigging Platform Storage Operation & Maintenance Manuals Special Tools Spares Holdings Mandatory References Supporting References

Kingsnorth CCS De monstration Pro ject The information contained in this document (the Infor ma tion) is provided in good faith. E.ON UK plc, its subcontractor s, subsidiaries, affiliates, e mployees, advisers, and the Depart ment of Energy and Climate Change (DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Infor mation and neither E.ON UK plc nor any of its subcontractors, subsidiaries, affiliates, e mployees, advisers or DECC shall have any liability whatsoever for any direct or indirect lo ss howsoe ver arising from the use of the Infor mation by any party.

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1. Scope and Functional Requirements This philosophy identifies the high level expectations for the inspection & maintenance of Kingsnorth Power station, capture plant, pipeline, storage and wells. It also reinforces the responsibilities placed upon the designers of a new facility to ensure that inspection & maintenance tasks can be carried out safely.

2.

Assumptions

Major maintenance and inspection tasks for the whole chain will be synchronised to coincide with a statutory outage of the power plant when possible. The elements of the Power plant and CCS Chain have not been through a detailed design process and as such it is difficult to determine the equipment that will be installed as part of the project. For this reason it is not possible to detail the strategic spares holdings. Spares holding will be determined in more detail as part of the detailed design and tendering process. Operational manuals will be supplied both electronically and in hard copy formats. Platform and storage regulations for CO2 will be issued by the legislative authorities prior to detailed design. The pipeline will have a robust pipeline leak detection system over its entire length such that an onshore leak may be detected early by acoustic, sonic or similar systems whilst an offshore leak may be detected by rolling mass balance or similar. The offshore installation will be defined and designed as a Remote Normally Unattended Installation. Cathodic protection method for the intertidal area will be decided during FEED Platform and Well maintenance requirements will be developed in detail through the FEED process.

3.

Rule One

E.ONs Rule One underpins the companys whole safety ethos, it is the basis of a behavioural safety programme, it is implemented based on one statement and it is a fundamental aim that: We dont hurt people As part of the safety programme E.ON recognises that the contribution of all parties suppliers and contractors is critical to the achievement of its Health, Safety and Environmental performance objectives and aims to be recognised as a business which demands and delivers excellence in health, safety and environmental performance.
Kingsnorth CCS De monstration Pro ject The information contained in this document (the Infor ma tion) is provided in good faith. E.ON UK plc, its subcontractor s, subsidiaries, affiliates, e mployees, advisers, and the Depart ment of Energy and Climate Change (DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Infor mation and neither E.ON UK plc nor any of its subcontractors, subsidiaries, affiliates, e mployees, advisers or DECC shall have any liability whatsoever for any direct or indirect lo ss howsoe ver arising from the use of the Infor mation by any party.

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4. Construction Design and Management (CDM) Regulations The most effective means of reducing safety risk at a facility is to design out the requirement for a hazardous activity to take place. The elimination of hazards as part of the design process is detailed as a designers duty under the CDM regulations. Designers duties relate to ensuring their designs pay due consideration to health and safety and the avoidance of foreseeable risk. Their duties extend beyond the construction phase of a project. The Health and Safety of those who will maintain, repair, clean, refurbish and ultimately demolish all aspects of the structure must also be considered. At each stage designers from all disciplines can make a significant contribution by identifying and eliminating hazards, and reducing likely risks from hazards where elimination is not possible. Where risks cannot be eliminated the designer has a duty to limit and control the associated risk. The obligation on designers is to co-ordinate their work with others in order to improve the way in which risks are managed and controlled. A design risk assessment detailing how designers minimised the risks associated with maintaining and inspecting the plant and equipment should be supplied. Further CDM and Health and Safety Information can be found in the health and safety philosophy [M1]. In a similar manner, the offshore platform and wells will be designed under the Offshore Installations (Safety Case) Regulations, which requires the operator to identify all risks and reduce them to as low as reasonably possible.

5.

Maintenance Requirements Whole Chain

The level of maintenance is expected to vary considerably between plant components with some (e.g. vessels) expected to operate continuously between major outages (expected every four years) without issue, whilst others which might be subject to more wear and tear (e.g. pumps and compressors) will by necessity require more frequent inspection and maintenance. In the latter case, standby plant is envisaged to allow maintenance without taking the system off-line. Likewise, within plant design and selection the need to perform regular activities such as lubrication & filter inspections must be considered and appropriate procedures developed to allow these activities to take place without requiring any cessation of process. Such equipment must be 100% isolatable with the remaining plant in service such that maintenance can be performed without cessation of process. Access for maintenance should also be considered and regular maintenance & inspection tasks should not require the use of scaffolding or other special equipment wherever it is cost effective to have permanent access or different arrangements (e.g. floor level valves). Platforms, walkways, stairways and ladders with hand railing should be provided for safe access to, and escape from, all plant; and where routine
Kingsnorth CCS De monstration Pro ject The information contained in this document (the Infor ma tion) is provided in good faith. E.ON UK plc, its subcontractor s, subsidiaries, affiliates, e mployees, advisers, and the Depart ment of Energy and Climate Change (DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Infor mation and neither E.ON UK plc nor any of its subcontractors, subsidiaries, affiliates, e mployees, advisers or DECC shall have any liability whatsoever for any direct or indirect lo ss howsoe ver arising from the use of the Infor mation by any party.

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maintenance is required adequate space should be left for equipment handling. Where lifting equipment is unavoidable provision should be made to allow inspection in line with the requirements of the Lifting Operations and Lifting Equipment Regulations (LOLER). In order to reduce spares holdings efforts should be made wherever possible to standardise equipment for the power station and capture plant, if this means over sizing items (e.g. Drives) then this should be considered on a cost benefit basis. Access to lubrication systems shall be such as to permit maintenance, draining and refilling without contamination of the new lubricant and without the removal of guarding with due consideration of suitable spillage collection equipment. Use of condition monitoring where applicable should be considered as part of an overall risk based maintenance strategy. It is expected that the power plant and associated equipment should be designed for the minimum amount of maintenance and inspection without incurring excessive cost. Cost benefit analysis should be performed on components where there is a choice between designed maintenance life and overhaul. The chain is expected to be fitted with sufficient redundancy and reliability to provide >90% availability following full commissioning. All suppliers of equipment will be tasked with providing items of plant that will, subject to correct operation and scheduled maintenance, continue to give satisfactory performance for their expected design life without failure. It is expected that the maintenance & inspection regime for the entire CCS Chain will not follow a set pattern during commissioning and up to the first two years of operation bit will where possible merge with the power plant maintenance regime after that. Specific details of maintenance and inspection requirements are detailed in the following sections. 5.1 Power Plant & Capture Wherever possible, maintenance intervals should be standardised to coincide with statutory outages for the boiler. In the initial period following commissioning it is expected that the power plant will undergo an inspection every two years until the insurers have confidence that the period can be extended to four years. Extension of the inspection period beyond four years will have to be negotiated with the insurers but the duration between inspections will never exceed 50,000 operational hours. A major outage is expected to be between eight and twelve weeks in duration and is anticipated to occur every four years with the potential to take a minor outage or inspection between major outages lasting between two and four weeks. In the run up to outages spare holdings may change in readiness as a result of inspections and condition monitoring but this cannot be detailed at this time. 5.1.1 Boiler & Turbine The power station boiler is expected to undergo periodic inspection cycles following full commissioning and insurance approval approximately every 2 years. At least a 6 week
Kingsnorth CCS De monstration Pro ject The information contained in this document (the Infor ma tion) is provided in good faith. E.ON UK plc, its subcontractor s, subsidiaries, affiliates, e mployees, advisers, and the Depart ment of Energy and Climate Change (DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Infor mation and neither E.ON UK plc nor any of its subcontractors, subsidiaries, affiliates, e mployees, advisers or DECC shall have any liability whatsoever for any direct or indirect lo ss howsoe ver arising from the use of the Infor mation by any party.

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outage is intended which will be used for the internal inspection of the steam generator. Every 4 years approximately a minimum of a 10 week inspection shall be performed. The maintenance expenditure for the components shall be adapted to these periods/time intervals (e.g. a basic overhaul of all burners shall be possible within the outage period, the service life of one burner until basic overhaul shall be 8 years). It would also be prudent to stagger the boiler outages for the units to prevent overhauls occurring during the same year. The following intervals (specific fabrication requirement) are detailed below; Initial Internal inspection 2 years Internal inspection (following insurance approval) 4 years Major Overhaul 8 years Turbine inspections are not required to meet any specific regulations as in the case of the boiler, hence inspections are required in line with requirements of the manufacturer and advice from the competent authority (e.g. EEN). The turbine overhaul will usually run concurrent with the boiler overhaul so opportunity to carry out minimal inspections is likely when the boiler is off for its first inspection. No components of the feed pump sets shall include materials that are degradable or which shall wear out and require replacement within 45,000 hours. Mechanical seals on other pump sets, and booster pumps if supplied, shall have a minimum life between overhauls of 35,000 operating hours and shall be a cartridge type design. 5.1.2 Generator - Inspection/overhaul cycle The generator must be suitable for daily start-up and shut-down. A major overhaul cycle of 12 years is aimed for. Intermediate maintenance inspections are to be carried out every 8 years and minor maintenance inspections are to be carried out every 4 years. 5.2 Capture Plant Specifics The capture plant is expected to have up to a two year period where maintenance and inspection is carried out in relation to commissioning and fine tuning activities. Following this period the capture plant should synchronise with main boiler outages for the unit to which capture is fitted. It is expected that there will be a variety of redundancy and spares holding solutions. Within the CCS Chain, similar principles may lead to duplication on high usage pumps and compressors that may require periodic maintenance to ensure plant output is maintained without cessation of process and results of investigations may also lead to holding spares in this critical area. The current concept of Capture Plant design is to have 2 trains of regeneration such that loss of one still leaves 50% and likewise with compressors where 2 x 50% is the minimum position envisaged at present. However, as the full interactions of all items across the CCS Chain are considered in depth strategic spares information will become available.

Kingsnorth CCS De monstration Pro ject The information contained in this document (the Infor ma tion) is provided in good faith. E.ON UK plc, its subcontractor s, subsidiaries, affiliates, e mployees, advisers, and the Depart ment of Energy and Climate Change (DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Infor mation and neither E.ON UK plc nor any of its subcontractors, subsidiaries, affiliates, e mployees, advisers or DECC shall have any liability whatsoever for any direct or indirect lo ss howsoe ver arising from the use of the Infor mation by any party.

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5.3

Pipeline

Major overhauls and inspections of the pipeline, valves & inlet filters will be in line with design code requirements, however, where possible they should be synchronised with the main station outage cycle. The operation of the pipeline is not expected to have a direct relationship to the power plant operation, however, inspections should be synchronised with the main station in order to ensure there are no restrictions in powerplant operation due to maintenance activities. It is not expected that liquid water will be formed within the pipeline however; requirements for oxygen stripping or injecting scavengers during shutdowns will be investigated during FEED. Maintenance procedures carried out on the pipeline will conform to all relevant legislation and will be to agreed standards with E.ON UK. It is currently expected that there will be no siting of sub sea isolation valves however, any requirement for the provision of sectional barrier valves and any potential sub sea isolation valves for the offshore pipeline shall be identified and agreed with the Health and Safety Executive during the course of the FEED study. 5.3.1 Pipeline Corrosion Protection

Corrosion monitoring will be carried out using probes and coupons installed at locations that are easily accessible, inspection periods will be more intensive during commissioning and the period immediately afterwards however, thereafter they are expected to be aligned with station outages. Internal corrosion of the pipeline operation is not expected during normal operation however, an allowance for internal corrosion will be investigated during the FEED process. Corrosion protection for the onshore pipeline is expected to be achieved through the application of appropriate coatings and/or wrappings. A coating is expected to form the first line of defence against corrosion and the quality and coverage of the coating will be monitored using holiday detection during the pipe laying process. The onshore pipeline will also have a cathodic protection system installed that is expected to utilise an impressed current system. It is envisaged that test posts for the system will be located nominally every 1km for maintenance reasons. The offshore pipeline will be coated with insulating and anti corrosion paint as well as being concrete covered, it will also benefit from the installation of Al-Zn-In sacrificial bracelet anodes to provide cathodic protection to the required standards. Anti-corrosion and insulating coatings as well as anodes shall be compatible with the anticipated design temperatures. 5.3.2 Onshore Pipeline Specifics

Following commissioning, during normal operation it is anticipated that the onshore pipeline will be monitored on a weekly basis in the form of a walkover inspection for any
Kingsnorth CCS De monstration Pro ject The information contained in this document (the Infor ma tion) is provided in good faith. E.ON UK plc, its subcontractor s, subsidiaries, affiliates, e mployees, advisers, and the Depart ment of Energy and Climate Change (DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Infor mation and neither E.ON UK plc nor any of its subcontractors, subsidiaries, affiliates, e mployees, advisers or DECC shall have any liability whatsoever for any direct or indirect lo ss howsoe ver arising from the use of the Infor mation by any party.

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indications of leaks or external damage. This walkover will include an inspection of the Above Ground Installation and should be timed to allow viewing of the intertidal area of pipeline under the mudflats. The pipeline will also be monitored for leaks and a pipeline monitoring system will be considered so that the operating conditions can be compared continuously to expected behaviour. The focus of monitoring will be to identify conditions that could give rise to internal or external corrosion and to confirm that the operating conditions are being maintained in a way that corrosion is being successfully inhibited. If it is required there may also be the installation of acoustic monitoring to provide a continuous detection system for leaks in addition to the techniques described above. 5.3.3 Offshore Pipeline Specifics

Following commissioning it is expected that the offshore pipeline will have an annual overhaul period lasting between one and two days for basic internal inspection and a thorough inspection of the catholic protection system. It would be prudent to synchronise any inspection with any annual maintenance requirement for the compressor system. The inspection methods and regime for the offshore pipeline will be developed throughout FEED however, a key requirement will be to maximise the amount of remote inspection and monitoring thereby reducing the requirement for specialised underwater maintenance activities. Maintenance to the offshore pipeline is expected to be limited by incorporating methods of protecting the pipeline mitigating damage from the following dropped objects, vessel anchoring and fishing activities 5.3.4 Pipeline Pigging

The geometry of the pipeline system will be designed to be compatible with running of a pipeline inspection device (PIG), with bend radii of a minimum of 5 x outside diameter included in the tie-in spool pieces and pipework. The pipeline shall have a constant internal diameter to allow smooth transit of PIGs. At branched connections, guide bars shall be incorporated where the branched connection diameters exceeds 25% of the pipeline diameter to ensure effective and safe pigging. Pigging considerations shall include the potential for future expansion of the system to cater for CO2 capture from the Thames cluster of power stations. The pipeline system will be equipped with a pig launcher at the Kingsnorth pipeline inlet and a receiver at the inlet to the offshore platform. The pig receiver will be specified to accommodate intelligent pipeline inspection devices that will need to be designed specifically for use in the flowing CO2 pipeline. The requirement for a pigging station at the on-shore AGI will be investigated as part of FEED.

Kingsnorth CCS De monstration Pro ject The information contained in this document (the Infor ma tion) is provided in good faith. E.ON UK plc, its subcontractor s, subsidiaries, affiliates, e mployees, advisers, and the Depart ment of Energy and Climate Change (DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Infor mation and neither E.ON UK plc nor any of its subcontractors, subsidiaries, affiliates, e mployees, advisers or DECC shall have any liability whatsoever for any direct or indirect lo ss howsoe ver arising from the use of the Infor mation by any party.

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Studies shall be carried out during FEED to develop tools that will be compatible with and reliable in the CO2 environment. The devices will be equipped with an ultrasonic inspection tool along with other equipment the frequency of their inspections will be determined during detailed design although it is currently expected that these will take place in a basic form every year and a more detailed study every five years or in sequence with a power station major outage. An operating strategy will be agreed in consultation with the suppler of the inspection services during product development and this will generate recommendations for the frequency of use. The device will be designed to seek any evidence of localised or general internal/external corrosion or damage to the pipe wall.

5.4 Platform A detailed description of the maintenance and inspection activities for the storage platform is expected to be developed in line with industry best practice during FEED. It is anticipated that annual inspections of the platform and periodic recertification of the topsides facilities will be required. Following certification of the offshore platform, major overhauls and inspections of the platform & equipment should be synchronised where possible with the main station outage cycle. The operation of the platform is not expected to have a direct relationship to the power plant operation however, inspections should be synchronised with the main station where possible in order to ensure there are no restrictions in power plant operation due to maintenance activities. The platform is expected to be unmanned and this should be taken into account when entering into a detailed design process, incorporating items such as condition monitoring. The chemical injection system will have the following maintenance package; pressure containment, pressure systems, atmospheric tanks, pumps & electric motors to be maintained in-line with relevant industry legislation. The electric heater pressure containment will initially be inspected in line with the five year initial design code requirements and following this phase in-line with the onshore powerplant. Any electrical maintenance will be covered by the relevant electrical legislation requirements and ATEX if it is appropriate. 5.5 Storage

Once the storage wells are drilled, completed and commissioned they will undergo periodic inspections, the frequency of which will be determined during the FEED process. The operation of the storage site is not expected to have a direct relationship to the Powerplant operation however, inspections should be synchronised where possible with the main station in order to ensure there are no restrictions in power plant operation due to maintenance activities. The injection site will be monitored to detect any leakage that will require reactive maintenance activities to take place.

Kingsnorth CCS De monstration Pro ject The information contained in this document (the Infor ma tion) is provided in good faith. E.ON UK plc, its subcontractor s, subsidiaries, affiliates, e mployees, advisers, and the Depart ment of Energy and Climate Change (DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Infor mation and neither E.ON UK plc nor any of its subcontractors, subsidiaries, affiliates, e mployees, advisers or DECC shall have any liability whatsoever for any direct or indirect lo ss howsoe ver arising from the use of the Infor mation by any party.

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The wellhead maintenance philosophy will be in-line with industry requirements of six monthly inspections and verification of tree valves. A detailed description of the maintenance and inspection activities for the storage wells is expected to be developed in line with industry best practice during FEED.

Operation & Maintenance Manuals

A basic requirement for all plant will be manuals containing a detailed description of the whole plant and all the operating and maintenance instructions. The manuals must be submitted and approved by E.ON UK prior to the commencement of commissioning. The manuals will be fully indexed, the content must be complete and specific to all the plant, auxiliary systems and equipment supplied. They will include:Start up, operating, shutdown and emergency procedures, identifying precautions and critical points, and any differences in procedures for initial operation, normal operation and pre- and post maintenance activities. Schedules for planned maintenance and an indicative maintenance programme preferably in the form of a bar chart. Maintenance procedures including fault finding, diagnosis and rectification, dismantling instructions, maintenance instructions, settings, clearances and adjustment data, assembly instructions, re-commissioning instructions. Detailed drawings of all equipment and internals to allow maintenance to be carried out. Spare parts details including reference numbers, drawings and lists, details of suppliers and instructions for ordering, and any special handling or storage procedures required The manuals shall alert the operating staff to any hazard inherent in the equipment or likely to arise in the implementation of operating or maintenance procedures. The nomenclature, terminology and abbreviations used throughout the manuals shall be consistent and shall conform to internationally recognised engineering terms.

7 Special Tools Where possible the requirement for special tools and equipment to complete maintenance and inspection tasks should be avoided, if the need for special tools is unavoidable then an agreed number of sets should be provided to E.ON UK following completion of the commissioning process.

8 Spares Holdings It is expected that there will be a variety of redundancy and spares holding solutions. The best options should be selected with for the redundancy and spares holding philosophy taking into account analysis of items such as;
Kingsnorth CCS De monstration Pro ject The information contained in this document (the Infor ma tion) is provided in good faith. E.ON UK plc, its subcontractor s, subsidiaries, affiliates, e mployees, advisers, and the Depart ment of Energy and Climate Change (DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Infor mation and neither E.ON UK plc nor any of its subcontractors, subsidiaries, affiliates, e mployees, advisers or DECC shall have any liability whatsoever for any direct or indirect lo ss howsoe ver arising from the use of the Infor mation by any party.

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Required Availability & Reliability targets Health, Safety & Environmental effects of failure Operation Criticality (does it stop output, only reduce output or have no effect on output) Manufacturers holding and availability of spares Failure Rates & Failure Types The degree of on-line condition monitoring installed Wear/deterioration rates Plant failure protection measures Cost of maintaining back-up equipment Feasibility of installing back-up equipment Down Time required to repair / replace The availability of Cross-Fleet spares from other E.ON Installations

Mandatory References

[M1] KCP-EUK-SHE-DPR-0001. Health and Safety Philosophy

10 Supporting References Internal Reports

Kingsnorth CCS De monstration Pro ject The information contained in this document (the Infor ma tion) is provided in good faith. E.ON UK plc, its subcontractor s, subsidiaries, affiliates, e mployees, advisers, and the Depart ment of Energy and Climate Change (DECC) make no representation or warranty as to the accuracy, reliability or completeness of the Infor mation and neither E.ON UK plc nor any of its subcontractors, subsidiaries, affiliates, e mployees, advisers or DECC shall have any liability whatsoever for any direct or indirect lo ss howsoe ver arising from the use of the Infor mation by any party.

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