Waiver Types

There are two waiver categories and two waiver types. All waivers are further classified based on their duration.

豁免类别

Category 1 waivers

所有豁免都会对FPS造成低至中等风险的豁免属于类别1.与第1类豁免有关的风险的影响和可能性,以豁免部门描述的风险收费为基础。第1类豁免所带来的风险相对良好,但这一类别涵盖了大多数豁免。1类豁免不涵盖的典型化学产品是:乙醇,密封剂,凝胶,气体(例如N2)。如果有问题的化学产品需要第2类豁免,FPS将通知客户。

Category 1 waiver process follows the following steps:fps-flow1_Page_1 (1).jpgNOTE: Once a waiver is granted no changes can be made to the dates & volumes indicated in the granted form without closing out the existing waiver and raising a new request. INEOS has sole discretion as to whether or not it grants a waiver request. The waivers inbox is monitored 24/7 and there is an on call engineer for any genuinely urgent requests. However, INEOS does not guarantee timely review of the waivers submitted outside the normal notification window.

第2类豁免

豁免that pose a high risk to FPS operation fall into Category 2. High risk categorisation may be driven by previous experience of FPS with certain chemicals resulting in incidents or by the lack of experience leading to uncertainty in terms of the potential impact. Sealants and gels are examples of Category 2 chemical products due to the risk of blockages on Unity and Kinneil caused by products not fully breaking down prior to reaching FPS facilities. Blockages could lead to safety incidents (blocked instrument tubing or drain pipework), production restrictions and shut down (blocked inlet filters at the terminal) or result in additional maintenance requirements.

Another typical Category 2 waiver example is Ethanol. It can lead to poor gas product quality, resulting in extensive flaring and loss of gas product revenue. It is also a chemical with a high COD and BOD level, and could lead to breaching the water effluent specification at Kinneil.

Category 2 waiver might also cover more commonly used chemicals, such as methanol, if FPS have concerns about the entrant platform managing to achieve a certain partitioning factor to ensure the volume of methanol exported into FPS remains within the terminal limit.

The issue of a Category 2 waiver could take up to 3 months. The outline of Category 2 process is below.

NOTE: The decision whether the chemical product falls under Category 1 or Category 2 is at the sole discretion of Ineos FPS.fps-flow1_page_2(1).jpg

Waiver types based on the chemical product

Standard Waivers

Standard waivers cover the following chemicals:

  • 甲醇
  • 甘醇
  • 杀生物剂
  • 污染物(例如H2S)
  • Ethanol

These chemicals are classified as standard due to the frequency of which they are used within FPS. The risks posed by these chemicals are well understood and special trackers are used for determining the exact arrival times at Kinneil. The list of the data to be provided by the customers for these chemicals is short: volume, injection date, duration, partitioning factor. To request a standard waiver a customer needs to fill in a request form as per Waiver forms section and email it to FPS waivers inbox no later than 72 hours in advance of the expected injection date. Waivers submitted with less than 72 hour notice may still be reviewed and processed, however this cannot be guaranteed. See Waiver Fees section for short notice waiver fees.

Note that a chemical being determined as standard does not exclude it from falling under Category 2 process if other factors are present (i.e. the risk might be well understood but still high). All other chemicals are classified as ‘Non-standard’ waivers.

评估process of standard waivers is based on the forecasted flowrates and estimated arrival times of the chemicals at Kinneil versus the expected loading and available capacity on the corresponding dates of arrival. Due to the uncertainty associated with production forecast for more than 2 weeks ahead of any chemical injection date, standard waivers can only be granted maximum 2 weeks before the proposed injection date. Customers are welcome to request waivers more than 2 weeks in advance, however, the granted form will only be issued no more than 14 days before the requested injection date.

Summary of the risks associated with standard chemicals

甲醇

甲醇partitions into both oil and water phase within exported crude oil and impacts both the gas quality and the effluent water quality at Kinneil.

甲醇对六个Kinneil分子筛床具有显着的影响,该六个Kinneil分子筛床从丙烷产物流中吸收水和H2S,因为甲醇被床吸收,优先于水和H2S。这降低了分子筛的吸收能力,从而导致丙烷的生产。一旦甲醇被床吸收,它就不能完全再生;这显着降低了分子筛床的寿命,这增加了床必须改变的频率。

甲醇is an alcohol and has a strong affinity to water. BOD is one of the criteria Kinneil effluent water has a specification for. Methanol that arrives at Kinneil partitioned into the water phase ends up in Kinneil’s effluent stream, resulting in significant contribution towards daily BOD loading.

由于上述风险,同意methanol partitioning factor (percentage of methanol injected upstream on each customer platform that gets exported into FPS) is very important to ensure methanol waivers are adequately assessed. Partitioning factor must be modelled for each field and formally reviewed and agreed by Ineos FPS (note that FPS safety factor is applied to any partitioning factor obtained by computer modelling). Once agreed, methanol partitioning factors are entered into FPS waivers system and revisited only if there are any significant process changes on the customers’ side.

甘醇

甘醇is an alcohol and primarily partitions into water. BOD is one of the criteria Kinneil effluent water has a specification for. Glycol that arrives at Kinneil within water phase ends up in Kinneil’s effluent stream, resulting in significant contribution towards daily BOD loading. Any glycol waiver request requires partitioning factor calculation to be included as part of the waiver request.

FPS has limited capacity for handling water and has been receiving an increasing number of requests from customers for excess water handling services, which have to be managed carefully within system limits. Incompatible produced waters can present a significant risk to FPS operations, either through scaling or inefficient separation.

杀生物剂

只有硫酸鏻(THP)硫酸鏻(THP)杀菌剂被归类为标准杀生物剂,是在FPS内使用的优选杀生物剂。任何其他杀生物剂请求被归类为非标准豁免,并且必须遵循非标准豁免评估过程。基于THPS的杀菌剂会影响Dalmeny坦克农场的流出物水毒性水平。在水箱之前,流出污水的水必须低于THPS水平限制5ppm。

Contaminants e.g. H2S & CO2

Crude oil contaminant waivers are reviewed and risk assessed on the case by case basis, as these often have a direct impact on the pipeline and terminal integrity. FPS has safe operating limits that cannot be breached, therefore any contaminant concentrations exceeding those agreed in individual TPAs are carefully reviewed by both the waivers and integrity teams.

Ethanol

乙醇(IMS)partitions into both oil and water phase within exported crude oil and impacts both the gas quality and the effluent water quality at Kinneil.

乙醇对丁烷规范产生重大影响,导致产品损失和燃烧。

Ethanol is an alcohol and has a strong affinity to water. BOD is one of the criteria Kinneil effluent water has a specification for. Ethanol that arrives at Kinneil partitioned into the water phase ends up in Kinneil’s effluent stream, resulting in significant contribution towards daily BOD loading.

Due to a high number of flaring events in the past being caused by ethanol arrival at Kinneil, all ethanol waivers fall under Category 2.

Non-standard Waivers

All chemicals that are not classified as Standard chemicals are covered by Non-standard waivers. These include corrosion inhibitors, scale inhibitors, H2S scavengers, foamers, anti-foams, wax inhibitors, clarifiers and other chemical products. The assessment process for non-standard waivers is more complex, as it involves assessment against 40 different criteria primarily based on Kinneil effluent specification limits. For all non-standard waiver requests, the customer must supply MSDS and CEFAS sheets in addition to the data covering the injection date and volume, partitioning factor calculation, toxicity, BOD, COD, pH, density, solubility and presence of any contaminants listed in the form. To request a Non-standard waiver a customer needs to fill in a request form as per Waiver forms section and email it together with the MSDS and CEFAS sheets to FPS waivers inbox no later than 1 month in advance of the expected injection date. Even if some data is still missing it is very important to inform FPS about the intent of using a non-standard chemical as early as possible. This is to ensure that there is enough time to complete an adequate assessment and feedback any clarifications and changes required to the customer with the minimal impact on the planned scope. The final waiver form must be submitted at least 72 hours prior to the proposed injection time. There is a high chance of the waiver not being granted in time if a non-standard waiver request is submitted with less than 72 hour notice. See Waiver Fees section for short notice waiver fees.

与非标准化学品相关的风险概要

Due to a large range of chemicals that are covered by non-standard waivers there is a number of risks that are taken into account in the review process. Chemicals that are water soluble impact the effluent water specification, including the pH, BOD/COD levels, toxicity levels and contaminant levels. Even if the chemical is insoluble in water it could still impact the effluent water specification if oil in water limit is breached and some of the chemical ends up in the water stream. Surfactants can impact oil/water separation, dyes can impact the colour of the effluent water, corrosion inhibitors can cause compatibility issues with FPS corrosion inhibitor. Certain non-standard chemicals that pose a significant risk to FPS operation, such as gels and sealants, for example, are covered by Category 2 waiver process.

基于注射频率和持续时间的豁免类型

特别豁免

Ad-hoc waivers cover injection of any chemical for a maximum duration of 1 month required on ad-hoc (i.e. non-continuous) basis. All standard waivers are covered by Ad-hoc waivers. Application process involves submission of the individual waiver request form per chemical, described in Waiver forms section. For Non-standard waivers the customer can choose between having a monthly ad-hoc waiver or an annual waiver covering the injection of the chemical, as long as the injection frequency meets the criteria for annual waivers.

Annual Waivers

年豁免流程涵盖了全年持续注入的化学物质。注射所需的频率被归类为连续的是每天和每2周之间的任何东西。由于在Kinneil和Dalmeny的日常流量和日常装载和容量可用性,评估了标准化学品不能被年豁免流程所涵盖的。每年11月30日应提交年度豁免请求,涵盖未来一年的注射。授予豁免表格将于12月31日发布。例如,应在2022年1月30日和2022年12月31日至12月31日之间覆盖注射的年度豁免请求应于11月30日提交,随后将于2021年12月31日授予。请参阅豁免费用豁免部分。

Breach Notification

如果客户发现他们已超过TPA质量规范,那么他们必须填写违反通知表(请参阅豁免表格部分)并立即将其发送给FPS豁免团队。如果客户超过其授予的任何化学产品的豁免表格所示的卷,则必须遵循相同的过程。必须在化学喷射时间的24小时内报告所有违规行为。违规的早期报告至关重要,这应该包括对为什么发生违规行为的完全解释以及将在防止未来事件发生的情况下提出的缓解计划。请参阅与延迟泄露通知相关的费用的豁免费。

Waiver Close Outs

任何授予的ad-hoc豁免都需要在化学出口完成24小时内通过客户提交相应的近外表格。例如,如果在2021年1月1日00:00出口的出口开始,并持续30小时(1月2日期到06:00),必须在1月3日06:00提交近似表格最新的。关闭形式必须含有所注入的化学品的实际体积,化学出口的开始日期和时间进入FPS和化学出口的持续时间。(请参阅豁免表格部分了解更多细节)及时关闭提交对于确保化学品对Kinneil的影响是重大记录和可追溯的,并且在系统中预订的任何未被使用的能力就可以尽快提供给其他用户。在24小时内提交豁免关闭或关闭提交须遵守迟到的收费(请参阅豁免费用部分详情)。

Any granted annual waiver requires quarterly reporting of the actual chemicals volume injected. Quarterly annual waiver reporting must be submitted by the 28th of April for Q1 (total volume of each chemical injected between 1st January and 31st March), 28th July for Q2 (total volume of each chemical injected between 1st April and 30th June), 28th October for Q3 (total volume of each chemical injected between 31st July and 30th September) and 28th January for Q4 (total volume of each chemical injected between 1st October and 31st December). Granted Annual Waivers form must be used for quarterly volumes reporting. Submission of the quarterly reporting outside the 28 day window or no quarterly reporting submission is subject to the late annual waiver reporting fee (seeWaiver Feessection for detail).