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Compliance and enforcement at Mossmorran

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 at 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 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.

10 September 2021 – 13 January 2022: 25 complaints

  • Most complaints related to concerns about flaring at the Mossmorran Complex.
  • A number of complaints expressed concerns over dark clouds or smoke that people are observing above the complex. There was no indication of smoke at these times, but it is noted normal emissions can appear dark depending on the light conditions at the time.

14 January 2022 – 24 March 2022: 7 complaints

  • Most complaints related to planned flaring events at the Complex in March which were required to allow inspection and maintenance work.
  • This flaring was required to carry out planned maintenance to ensure the ongoing safe and compliant operation of the site.
  • During Monday 7 March planned flaring at the ExxonMobil Chemical Limited Fife Ethylene Plant, one of our noise scientists attended locations in Lochgelly, Donibristle, Auchtertool and Hill of Beath to assess the noise being experienced in the community.
  • Our monitoring work involves us carrying out an initial assessment to judge if a more detailed assessment using the British Standard (BS 4142) will then be required. BS 4142 would use data from our noise monitors to assess impact on the community.
  • In this case, since flaring noise was not audible or not distinguishable above general site noise, no quantitative BS4142 assessments were undertaken. More detail is given in our Investigation of Environmental Noise report.

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).

Inspections

Desktop and on-site inspections are continuing with the focus on maintenance and the FEP ground flare installation.

Latest inspections undertaken

  • Monthly update on new FEP ground flare meeting held
  • Inspection of new FEP flare tip

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

2022

  • Monthly update meeting on new FEP ground flare planned
  • Braefoot Bay Inspection Planned
  • Inspection of new FNGL flare tip
  • Inspection of FNGL gasoline storage and Leak Detection and Repair Programme.

2023

  • 5 year review of Major Accident to the Environment assessment
  • Inspection of new FEP ground flares

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:
    • 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.

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.

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.