WAIVER TYPE (VALID FROM JANUARY 2021)
There are two waiver categories and two waiver types. All waivers are further classified based on their duration.
Category 1 waivers
All waivers that pose a low to medium level of risk to FPS fall into Category 1. The impact and likelihood of risks associated with Category 1 waivers form the basis of the risk charges described under the Waiver fees section. The risk posed by Category 1 waivers is relatively well understood and a majority of the waivers are covered by this category. Typical chemical products that are not covered by a Category 1 waiver are: Ethanol, Sealants, Gels, Gases (e.g. N2). FPS will inform the customer if the chemical product in question would require a Category 2 waiver.
Category 1 waiver process follows the following steps:
NOTE: 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.
Category 2 waivers
Waivers 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.
Waiver types based on the chemical product
Standard waivers cover the following chemicals:
- - Methanol
- - Glycol
- - Water
- - Biocide
- - Contaminants (e.g. 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.
The assessment 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
Methanol partitions into both oil and water phase within exported crude oil and impacts both the gas quality and the effluent water quality at Kinneil.
Methanol has a significant impact on the six Kinneil molecular sieve beds that absorb water and H2S from the propane product stream, as methanol is absorbed by the beds in preference to water and H2S. This reduces the molecular sieve’s absorption capacity which leads to the production of off-specification propane. Once methanol has been absorbed by the bed it cannot be totally regenerated; this significantly reduces the molecular sieve bed’s lifespan which increases the frequency that the bed has to be changed out.
Methanol 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.
Due to the risks described above, agreeing a 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.
Glycol 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.
Only tetrakis (hydroxymethyl)phosphonium sulfate (THPS) based biocide is classified as standard biocide and is the preferred biocide for the use within FPS. Any other biocide request is classified as a non-standard waiver and must follow non-standard waivers assessment process. THPS based biocide impacts effluent water toxicity level at Dalmeny tank farm. Prior to water tanks rundown effluent water must be below THPS level limit of 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 (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.
Ethanol has a significant impact on the butane specification leading to the loss of product and flaring.
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.
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.
Summary of the risks associated with Non-standard chemicals
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.
Waiver types based on injection frequency and duration
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 criterial for annual waivers.
Chemicals that are injected on a continuous basis throughout the year are covered by the Annual waivers process. The frequency required for injection to be classified as continuous is anything between daily and every 2 weeks. Standard chemicals cannot be covered by the Annual waivers process as injection of these chemicals is assessed based on the daily flowrate and daily loading and capacity availability at Kinneil and Dalmeny. Annual waiver requests should be submitted by the 30th of November of each year covering injection over the year ahead. Granted waiver forms will be issued by the 31st December. For example, annual waiver requests covering injection between 1st January 2022 and 31st December 2022 should be submitted by the 30th November 2021 and would subsequently be granted by the 31st December 2021. Please see Waiver Fees section for Annual waiver charges.
If customers discover that they have exceeded their TPA quality specification then they must complete a breach notification form (see Waiver forms section) and send it to FPS waiver team immediately. The same process must be followed if customers exceed the volume indicated in their granted waiver form for any chemical product. All breaches must be reported within 24 hours of the chemical injection time. Early reporting of the breach is essential, which should include a full explanation as to why the breach occurred and the mitigation plan that will be put in place to prevent future occurrences. Please see Waiver Fees section for the charges associated with the late breach notification.
Waiver close outs
Any granted ad-hoc requires submission of a corresponding close out form by the customer within 24 hours of completion of the chemical export. For example, if the export of the chemical started at 00:00 on the 1st Jan 2021 and continued for 30 hours (till 06:00 on the 2nd Jan), the close out form must be submitted by 06:00 on the 3rd Jan the latest. The close out form must contain the actual volume of the chemical injected, the start date and time of the chemical export into FPS and the duration of the chemical export. (See Waiver Forms section for more detail) Timely close out submission are important to ensure the impact of the chemicals on Kinneil is recorded and traceable and any unused capacity booked in the system is made available to other users as soon as possible. Submission of waiver close outs outside 24 hour period or no close out submission is subject to the late close out fee (see Waiver Fees section for detail).
Any granted annual waiver requires quarterly reporting of the actual injected chemicals volume over each quarterly period. 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 waiver close outs outside 24 hour period or no close out submission is subject to the late close out fee (see Waiver Fees section for detail).