Compliance and enforcement at the Mossmorran Complex and Braefoot Bay
This page details the ongoing compliance and enforcement work SEPA is carrying out at the Mossmorran and Braefoot Bay complexes. This includes information about complaints, inspections and permit variations.
Complaints
SEPA continues to review and follow up on complaints and will publish information on this page to show what action was taken.
The information below is updated in-line with meetings of the Mossmorran and Braefoot Bay Community and Safety Liaison Committee. For further information on this committee visit Air quality | Fife Council.
The next update will be in-line with the next committee meeting which is due in the next few months. Only the information from the last 12 months we have reported to the committee is available here. Previous reports will be included on our previous updates page.
25 March 2022 – 24 November 2022: 24 complaints
- Most complaints related to concerns about flaring at the Mossmorran Complex and were related to planned flaring events or operation flaring. A small number related to unplanned flaring events (plant trips)
25 November 2022 – 23 February 2023: 3 complaints
- One related to a concern over dark clouds or smoke observed above the complex. SEPA believes that these particular clouds were not smoke but normal emissions which can often appear dark depending on the light conditions at the time.
- Two related to a methane type odour, which did not appear to be coming from Mossmorran.
24 February 2023 – 25 May 2023: 1 complaint
- One complaint has been received since our last update (23 February 2023) relating to a low frequency noise in Cowdenbeath. The SEPA noise monitors were reviewed, and no change was identified from Mossmorran. The noise was subsequently attributed to a source in Cowdenbeath and has now ceased.
26 May 2023 – 24 August 2023: 4 complaints
- Three noise complaints received. One was found to be a source in Cowdenbeath, and the others may have been linked to Mossmorran, although only minor changes were picked up on the SEPA noise monitors, with no additional complaints received on these occasions.
- One dust complaint was also received in June. This was during a period of high dust levels across Scotland due to pollen and agricultural activities coupled with the very dry weather.
Inspections
Desktop and on-site inspections are continuing with the focus on maintenance and the FEP ground flare installation.
Latest inspections undertaken
FEP
- Monthly updates on new FEP ground flare meeting held until June 2023
- 5 year review of Major Accident to the Environment assessment
FNGL
- Inspection of new FNGL flare tip
- Inspection of FNGL gasoline storage and Leak Detection and Repair Programme.
- Quarterly meetings on new ground flare project
Review of data returns
Both ExxonMobil and Shell are required to submit a range of data returns throughout the year for SEPA to review.
The full list and associated documents can be viewed at Mossmorran Complex annual data returns.
Upcoming compliance work
FEP
- Inspection of new FEP ground flare
- FEP and SEPA air emission monitoring
- Work to reduce nitrogen dioxide emissions from the furnaces
- Inspection of Leak Detection and Repair Programme
FNGL
- Inspection of drainage system
- SEPA air emission monitoring
Braefoot Bay
- COMAH and PPC Inspection
Permit variations
If a proposed change requires changes to the permit conditions the operator must apply to us to vary the permit. We also have the right to vary the permit at any time if we consider that we need to do so. Variations to a permit can range from a simple correction of a typographical error to including a new process.
Where the proposed variation is assessed as being in relation to a “substantial” change we must consult the public on the application. We have published guidance on how this is done. Additionally, under the regulations, we can choose to consult on any variation if we consider that it would benefit from public consultation.
Public consultation is undertaken at both the beginning and end of the determination process, the former being by advertisement in the local press and the latter via the SEPA website. Where this takes place, the public are only consulted on the aspects of the permit which are being considered as part of the determination.
- SEPA varied both Operators permits in February 2022 to require the submission of noise assessments in the event of Major flaring events.
- SEPA varied ExxonMobil’s permit in February 2022 to require the new ground flares to be operational by 01 April 2023 and to submit updates on progress towards delivery (FEP has already been publishing these on its website).
- SEPA varied Shell’s permit in June 2022 to require:
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- The site Environmental Monitoring Plan to be reviewed at least every two years.
- A project plan for a new totally enclosed ground flare.
- The new totally enclosed ground flare shall be operational from 31 December 2025.
- Updated monitoring requirements for emissions to air from the processing modules.
- An explanation of what SEPA has varied and the reasons for the changes can be found in our decision document for PPC/A/1013495 VAR02.
- The changes to the permit can be found in our variation notice for PPC/A/1013495 VAR02.
- The site Environmental Monitoring Plan to be reviewed at least every two years.
Improvements
We are continuing to work with the companies to deliver flaring improvements in the shortest possible timeframe.
Ground Flares at ExxonMobil FEP
ExxonMobil Fife Ethylene Plant (FEP) issues updates on its progress towards the installation and operation of its new Enclosed Ground Flare on its website at FEP project updates | ExxonMobil UK.
What will this improvement mean?
Flaring events should occur less often, but if there is a flaring event at ExxonMobil FEP there may still be elevated flaring for a short period. After that the flaring will be contained within the ground flare. This will significantly reduce the amount of elevated flaring from this site.
Elevated flare tips at both ExxonMobil and Shell
- ExxonMobil FEP installed a new elevated flare tip in Spring 2021.
- Shell FNGL has just installed a new elevated flare tip.
What will this improvement mean?
Flaring events should occur less often, but if there is an elevated flaring event then both ExxonMobil and Shell will be using technology that should minimise the impact of noise and vibration when it does occur.