Mossmorran and Braefoot Bay complexes

Mossmorran Hub

Mossmorran Complex investigation update - 27 February 2019

SEPA has completed its investigation into a number of unplanned flaring events at the Mossmorran Complex during 2017 and 2018.

Whilst flaring is an important safety mechanism and is permitted through permit conditions, the impact of any flaring events must be mitigated so as not to have an unacceptable impact on local communities.

SEPA remains clear that the flaring in June 2017 was both preventable and unacceptable and Final Warning Letters were issued to ExxonMobil Chemical Ltd and Shell UK Ltd in that regard. Communities experienced further unplanned flaring in October 2017, March 2018 and again in May 2018.

In August 2018, SEPA announced an investigation into ExxonMobil Chemical Ltd and Shell UK Limited. SEPA also announced a review of, then served, operating permit variations on both operators to strengthen noise and vibration controls whilst the investigation was underway.

With a firm focus on ensuring stringent compliance and mitigating the impacts of flaring, SEPA has concluded that robust enforcement action taken is currently appropriate and effective. The environmental performance of ExxonMobil Chemical Ltd and Shell UK Ltd will be kept under review and SEPA will not hesitate to take further action in line with its Enforcement Policy if appropriate.

This update summarises the range of enforcement action that SEPA has taken, sets out what will happen next, and explains how SEPA will continue to liaise with communities.

Enforcement actions and environmental monitoring

  • SEPA served Final Warning Letters on both operators in April 2018.
  • Permit variations were served on both operators requiring ExxonMobil Chemical Ltd and Shell UK Ltd to ensure they take all appropriate preventative measures against noise and vibration emissions through the application of ‘Best Available Techniques (BAT)’ and ensure that no significant pollution is caused.
  • Both operators are required to complete an evaluation of the ‘Best Available Techniques (BAT)’ to prevent and, where that is not practicable, reduce emissions of noise, vibration and smoke associated with flaring.

  • In addition to SEPA’s investigation, the Health and Safety Executive has completed its investigation and confirmed that COMAH actions legal have been completed to its satisfaction.

  • An enhanced programme of air quality monitoring is being undertaken by SEPA, to inform relevant public agencies.
  • The environmental performance of ExxonMobil Chemical Ltd and Shell UK Ltd will be kept under review and SEPA will not hesitate to take further action in line with its Enforcement Policy if appropriate.

Summary of flaring events

Flaring event

Incident length

Impacts noted

Reason

Operators involved

 June 2017

Approximately 5.5 days

 Noise and vibration

 

Mechanical failure of a steam condensate return pump.

ExxonMobil

 

Flaring for approximately 1.25 days including

26 minutes

 
27 minutes

 

 


Black smoke

 
Black smoke

 

 

 


Lack of steam supply to the flare.

Loss of ethane feed causing rapid reduction in steam header pressure.

 

 


Shell


ExxonMobil

 

October 2017

3.25 days

Noise and vibration

Ethylene release from a flange.

ExxonMobil

March 2018

Approximately three days

Noise and vibration

Shut-down of a process gas compressor by a safety mechanism.

ExxonMobil

 May 2018

 

Approximately four days

Noise and vibration

Splitter product draw-off pump outage.

ExxonMobil

 

Final Warning Letters

Final Warning Letters were served on both companies by SEPA in April 2018 related to “preventable and unacceptable” unplanned flaring during June 2017. Both can be viewed on SEPA’s website.

Variation of permit conditions and evaluation of Best Available Techniques (BAT)

Notices of variations to their Permits were served on ExxonMobil Chemical Limited and Shell UK Limited in June 2018.

The variations included the requirement to complete an evaluation of the Best Available Techniques (BAT) to prevent and, where that is not practicable, reduce emissions of noise, vibration and smoke associated with flaring.

The outcome of the BAT assessment is an essential part of understanding what can be done to stop unacceptable and preventable impacts of flaring.

SEPA has held review meetings at key stages with both companies to ensure progress. The interim reports on progress towards the evaluation of Best Available Techniques for flaring, which were required by 30 November 2018, have been submitted and are available to view on SEPA’s Public Register.

They indicate that the Operators are progressing towards completion by the required date of the 30 April 2019 and that the scope of the assessment covers the appropriate breadth and depth.

  • ExxonMobil Chemical Limited and Shell UK Limited have confirmed that five separate working groups have been established incorporating technical specialists from both operators and third party consultants to cover the full scope of the assessment.
  • Progress to date has highlighted potential ground flare technologies and site based techniques that may reduce and/or minimise noise, vibration and/or smoke from flaring. The companies have advised that further assessment is required to determine what combination results in the best overall benefit.
  • In addition to publishing the interim reports SEPA is committed to publishing the Operators’ final assessments.

Both operators must continue their commitment to implementing Best Available Techniques. SEPA will continue to work with Exxonmobil Chemical Limited and Shell UK Limited to provide advice and guidance if required, and will ensure any proposals are acceptable and appropriate. If this is not the case we will take any necessary action.

SEPA believes it is important that operators continue to explore opportunities for good communication links with local communities.

Investigations by SEPA and HSE

The Mossmorran Complex falls under the Control of Major Accident Hazards (COMAH) Regulations. These are enforced by the COMAH Competent Authority, represented by the relevant safety body (for Mossmorran this is the Health and Safety Executive) and the appropriate environmental regulator (SEPA).

SEPA’s focus is to ensure compliance in terms of the ability for the Installation to flare safely without causing unacceptable impact on the local community.

SEPA’s Enforcement Policy sets out the intent and principles underpinning our approach to enforcement action. The intent behind the enforcement action we have taken is to:

  • secure compliance and change the behaviour;
  • stop or reduce the risk of harm arising from the non-compliance to an acceptable level.

SEPA has used our enforcement policy to guide our decisions in taking what we consider to be the most appropriate and effective actions at this time in order to secure compliance.

In this instance the mechanism for compliance should be identified via the BAT assessment and both Operators have provided interim reports indicating that a suitable final assessment will be delivered.

If further events occur that show negligence and/or repeated root causes, further action can be taken to secure compliance.

Under COMAH SEPA and the HSE co-ordinate the approach as the Competent Authority. SEPA focuses on the environmental aspects of incidents, although there is often an overlap with safety aspects considered under COMAH by the HSE.

Further information on COMAH is available on the Health and Safety Executive website.

Monitoring programme

SEPA is currently undertaking air quality monitoring in the vicinity of the Mossmorran Complex. Following a consultation with community representatives, through the Mossmorran and Braefoot Bay Community Safety Liaison Committee, a trailer has been located at the farm to the North East of the complex and diffusion tubes will be placed in community locations.

SEPA Update on Environmental Monitoring Proposals in the vicinity of the Mossmorran Complex - as shared with the Mossmorran and Braefoot Bay Community Safety Liaison Committee

Information is being shared with the Independent Air Quality Review Group (including community representatives), Fife Council, NHS Fife and Health Protection Scotland.

A forward programme for environmental monitoring is being discussed with the Operators and partner organisations.

Communicating with communities

SEPA has worked within the limitations of communicating during a live regulatory investigation to keep local communities informed through:

  • Mossmorran Communities Working Group;

Co-chaired by Lesley Laird MP for Kirkcaldy and Cowdenbeath and Professor Wilson Sibbett from the University of St Andrews, the Mossmorran Communities Working Group allows elected members, community representatives, regulators and operators to discuss community-related issues and find solutions to them in the short, medium and long term

These community liaison meetings are held once a quarter and are attended by local councillors, representatives from local community councils, SEPA, ExxonMobil Chemical Limited, Shell UK and Fife Council. The minutes of the meetings should be made publically available to members of local communities through community council meetings, local libraries and the Fife Direct webpage.

The Mossmorran and Braefoot Bay Independent Air Quality Monitoring (IAQM) Review Group is independently chaired by Professor Sibbett of St Andrews University. Members are appointed by Fife Council and include representatives from Fife Health Board, SEPA, Fife Council, the Institute of Occupational Medicine and community representatives. The Group meets twice per year and publishes an annual report which is available from the Fife Direct webpage.

The group advises Fife Council regarding the quality of ambient air associated with air emissions from operations at the Mossmorran plants and the Braefoot Bay terminal facilities. The Review Group liaises with representatives from community councils and the local health service.

Of particular relevance are issues relating to any health concerns raised by residents within the local communities and a key role is assisting with the communication of information relating to environmental air quality.

  • SEPA’s dedicated Mossmorran information hub.

Updates are published online, as well as being proactively emailed to those who have signed up to the mailing list. Anyone who wishes sign up for the newsletter can do so at sepa.org.uk/regulations/air/air-quality/mossmorran-newsletter-signup/

We will continue to work to keep good lines of communications open with appropriate groups and elected representatives to explain what we are doing, hear concerns and provide reassurances where we can.

We have committed to keeping the public informed through our dedicated Mossmorran hub, and anyone with concerns or queries not related to an ongoing pollution incident can email communities@sepa.org.uk during office hours.

Information about a potential or ongoing pollution incident (including flaring) should go to our 24 hour pollution hotline on 0800 80 70 60 or via sepa.org.uk/report. The earlier we know about a potential issue, and the more information we have, the better we can investigate.

Mossmorran newsletter

SEPA is committed to keeping the local communities around Mossmorran informed. Sign up to our newsletter to receive the latest updates in our activities and the stages of the investigation being undertaken following the flaring incident in June.

Read the latest on the Mossmorran and Braefoot Bay complexes

You can read previous Mossmorran newsletters online or watch the video versions.

Flaring at Mossmorran - previous updates

Please follow this link to view previous updates on flaring incidents.

Site activities

Shell UK operates the Fife Natural Gas Liquids (FNGL) Mossmorran Fractionation Plant near Cowdenbeath in Fife that extracts natural gasoline, ethane, propane and butane from natural gas liquids pumped from the St Fergus gas plant at Peterhead. Three identical processes separate the different components.

Ethane is forwarded to the adjacent ExxonMobil Chemical Limited Fife Ethylene Plant (FEP), Mossmorran where it is converted into ethylene by steam cracking.

The products from both sites are transported by pipeline or road tanker, predominantly to the Shell UK Limited and ExxonMobil Chemical Limited Braefoot Bay marine terminal on the Firth of Forth near Aberdour in Fife, where it is shipped. Some of the ethylene produced is distributed via the UK ethylene pipeline to other manufacturing plants in the UK.

Regulation

Pollution Prevention and Control (PPC) (Scotland) Regulations 2012 (PPC)

Shell UK Fife NGL and ExxonMobil Chemical Limited FEP at Mossmorran and ExxonMobil Chemical Limited at Braefoot Bay are regulated under the PPC. The regulations permit and regulate many industrial activities that may pollute our environment. Licences, known as permits, set strict conditions that must be met to prevent or reduce any impact on the environment. For FNGL and FEP at Mossmorran the PPC Permits include specific conditions on flaring including a requirement to provide an incident report for any significant unplanned flaring. Similar licences are in place for ExxonMobil Chemical Limited at Braefoot Bay although these are less complex. We carry out regular inspections of both facilities and reviews monitoring and other returns to check compliance.

Annual compliance is also assessed using our Compliance Assessment Scheme and the results published on our website. For Mossmorran sites search under ‘Fife Ethylene Plant’ or ‘Fife NGL Plant’; and for Braefoot Bay search under ‘ExxonMobil Chemical Limited’.

Control of Major Accident Hazard (COMAH) Regulations 1999

The Shell UK and Exxon Mobil Chemical Limited Sites at Mossmorran and Braefoot Bay also fall under the COMAH Regulations which are jointly regulated by the Health and Safety Executive (HSE) and SEPA as the Competent Authority. Qualifying sites are divided into Lower Tier and Top Tier sites based on quantities of dangerous substances held on the site.

The Mossmorran and Braefoot Bay sites are classed as Upper Tier sites due to the quantities of highly flammable substances present. As such they must submit a Safety Report every five years which demonstrates the implementation of safety management systems to prevent major accidents and limit their consequences to people and the environment.

Further information on COMAH is available on the Health and Safety Executive website

In addition to carrying out routine regular inspections under both PPC and COMAH, SEPA has a duty to carry out investigations into incidents under both regulatory regimes. SEPA focus on the environmental aspects of incidents although there is often an overlap with safety aspects considered under COMAH by the HSE.

Air quality and SEPA position statement

Extensive air quality monitoring has demonstrated that concentrations of benzene and other hydrocarbons are consistently low in the vicinity of the facilities at Mossmorran and Braefoot Bay.

There has recently been local concern over the perceived impact of the Little Raith Wind Farm on the dispersion of air emissions from the Mossmorran complex during normal operation and flaring. Concentrations of benzene measured in the vicinity of the plant were low throughout 2012 and are similar to those you would expect to find in a typical rural setting. The concentrations were well below the Air Quality Standards before and after the turbines came into operation.

We have published the following position statement.

Community liaison

We participate in the following external meetings with other organisations:

  • Mossmorran and Braefoot Bay Community and Safety Committee
    These community liaison meetings are held once a quarter and are attended by local councillors, representatives from local community councils, SEPA, ExxonMobil Chemical Limited, Shell UK and Fife Council. The minutes of the meetings should be made publically available to members of local communities through community council meetings, local libraries and the Fife Direct webpage.

  • Mossmorran and Braefoot Bay Independent Air Quality Monitoring Review Group
    The Mossmorran & Braefoot Bay Independent Air Quality Monitoring (IAQM) Review Group advises Fife Council regarding the quality of ambient air associated with air emissions from operations at the Mossmorran plants and the Braefoot Bay terminal facilities.

Of particular relevance are issues relating to any health concerns raised by residents within the local communities and a key role is assisting with the communication of information relating to environmental air quality. The IAQM Review Group is independently chaired and includes representatives from Fife Health Board, SEPA, Fife Council, the Institute of Occupational Medicine and community representatives. The Group meet twice per year and publishes an annual report which is available from the Fife Direct webpage.

Incidents, complaints and enquiries

Members of the public who are concerned about a potential pollution issue are encouraged to contact our pollution hotline on 0800 80 70 60. This is 24 hours a day, 7 days a week. We aim to follow up all complaints within 24 hours.

Frequently asked questions


Who is SEPA working with regarding Mossmorran?

The site is regulated by a number of organisations including the local authority, SEPA, and the Health and Safety Executive. We also consult with NHS Fife, Health Protection Scotland and Forth Ports in order to gain information and views to support our regulatory work.

You can see more about SEPA-specific regulatory activities under the section titled ‘Regulation’ above

What monitoring activity does SEPA undertake during flaring events?

Flaring events can vary from a few seconds, minutes or hours to days or even weeks. Some events are planned and some are unplanned and the root causes and impacts can vary significantly (i.e. the rate at which gas is flared, steam is managed and whether there is emission of dark smoke or not). Monitoring could not be justified on all occasions and the focus for us as a regulator is on ensuring compliance and working with the companies at Mossmorran to minimise the need to flare and to reduce the impacts.

Following the flaring events in June and October SEPA will review our arrangements for monitoring these events both proactively and reactively. SEPA will also review the monitoring undertaken by the company and if necessary we will require the company to undertake additional monitoring. We will engage with the local community to inform our view as to what is required.

Why do Shell UK and ExxonMobil Chemical Limited at Mossmorran need to flare?

The flares are part of the safety system and are used to burn off gas that cannot be processed safely due to the volumes involved or the gas being off specification. This might be due to scheduled maintenance requiring the plant to be ‘gas free’ prior to entry; or, following an unplanned operational interruption. The flare systems include:

  • two 80 metre high flares at Shell FNGL;
  • one 100 metre high flare at ExxonMobil FEP;
  • two ground flares which are operated by Shell FNGL but used by both sites as required.

How often do plants flare?

The number and type of flaring events varies year to year. These events can last just a few seconds and minutes to hours and days depending on the circumstances at the time. The primary reason for flaring is safety and events can be either planned or unplanned in nature. In years where there are more planned maintenance activities an increase in the number of flaring events can be expected.

To understand the frequency, type and duration of flaring events that occur, both operators at Mossmorran are required to provide an annual report to SEPA. A summary of the data provided to SEPA for the years 2008 to 2016 is available below (some additional comments have been taken from the Independent Air Quality Review Group reports):

This data is used as part of the regulatory controls applied by SEPA to both operators under their PPC permits. Flaring incidents must also be notified to SEPA and an incident report submitted (normally 1-2 pages in length) which SEPA then follows up directly with the relevant operator.

Under the Energy Act 1976 and Petroleum Act 1998, Shell are also required to have consents in place from the Oil and Gas Authority for flaring and venting of hydrocarbons.

What are the constituents of the flare?

The main constituents of the FEP flare are ethylene and/ or ethane. Other hydrocarbons may also be present as well as hydrogen, nitrogen and steam.

What restrictions are in place on flaring and why is the flare occasionally smoky?

ExxonMobil Chemical Limited at FEP and Shell UK at FNGL are permitted to flare for safety purposes. However, there are conditions in the PPC permits relating to flaring which aim to minimise community disturbance and pollution from flaring.

In general the visual and noise impact of flaring is minimised by using the ground flares; forward planning to maximise flaring during daylight hours; and, minimising the amount of material to be flared. However when the ground flares are not available, or the flow-rates are too great (e.g. in certain start-up or shutdown operations), then the elevated flare is also used.

Smoky flaring can be minimised by the addition of steam to optimise combustion. However, excessive steam addition can give rise to noise nuisance and must therefore be carefully managed.

Both the ground and elevated flares have restrictions on flaring in their PPC permit which prevent flaring of dark smoke for greater than 15 minutes.

Any major flaring resulting in burning of hydrocarbon above 5 tonnes per hour for a period of 30 minutes also requires 7 days prior notification to SEPA.

Any major flaring which is not notified in advance, requires the operator to follow the incident procedures in the PPC permit. This includes formal notification to SEPA without delay and a follow up investigation report within 14 days to confirm the causes of the flaring event, the environmental impact and measures to prevent a further flaring event due to similar causes.

What are the impacts to health of flaring?

A modelling study undertaken in 2009 assessed the impact of emissions during flaring and normal process emissions from Fife Ethylene Plant and Fife Natural Gas Liquids plant at Mossmorran, both separately and in combination.

The following pollutants were assessed:

  • carbon monoxide (CO);
  • oxides of nitrogen (NOx as NO2);
  • fine particulate matter (PM10 and PM2.5);
  • sulphur dioxide (SO2); 
  • volatile organic compounds (VOCs) including benzene and 1, 3 butadiene.

The study concluded that the long and short term predicted environmental concentrations of all of the pollutants considered were well within the air quality standards for the protection of human health.

The modelling work supports the findings of an earlier ambient monitoring study undertaken by FEP to assess emissions of VOCs and fine particulate matter (PM10) between 21 August 2008 and 1 October 2008.

The study was carried out by an independent contractor, The National Physical Laboratory (NPL) and all the data was submitted to the Air Quality Monitoring Review Group for independent analysis. This included a period of elevated flaring on 5 and 6 September 2008 during which specific VOC samples were collected.

Measured concentrations of PM10, benzene and 1,3 butadiene were all within the relevant air quality standards for the protection of human health.

What responsibilities do SEPA have regarding air quality?

Local authorities have a statutory duty to review and assess local air quality in their area against the air quality objectives for various pollutants (including benzene) that are in-place to protect human health. These air quality objectives are contained within the National Air Quality Strategy for England, Scotland, Wales and Northern Ireland which was last updated in 2007.

We have a statutory responsibility to ensure that regulated processes do not result in, or contribute to, an exceedence of European air quality objectives.

What is the impact to health of emissions from the Mossmorran Complex?

We are currently satisfied that the emissions from the Mossmorran complex are not having a detrimental impact on air quality in the local communities. Several modelling and monitoring studies have shown that the concentrations of benzene and other pollutants are currently well below the air quality objectives at local residential areas. This conclusion is backed up by the Mossmorran and Braefoot Bay Independent Air Monitoring Review Group referred to above.

What is the impact of Little Raith Wind Farm on the air emissions from Mossmorran?

Ambient monitoring was undertaken at Little Raith Farm, Lochgelly and Cowdenbeath between January 2011 and March 2013 by the wind farm developer Kennedy Renewables. The monitoring results indicate that Little Raith Wind farm is having no negative impact on the dispersion of air emissions from Mossmorran. Measured concentrations of benzene following the commissioning of the wind farm in September 2013 were no higher than the concentrations measured prior to installation, and were consistent with typical rural background levels.

A final report on the monitoring undertaken by the wind-farm developer, Kennedy Renewables was published in January 2014.

We published the report -  Impact of Little Raith Windfarm on air emissions from Mossmorran.