Customers must apply for a waiver before exporting contaminants into FPS. customers must apply for the waiver at least 72 hours before it is required. For methanol, water, H2S scavenger and frequently used chemicals we will accept waivers requests no earlier than 2 weeks prior to the commencement date; this is because before that period there is too much uncertainty about system throughput.
For new production chemical waivers, e.g. not previously approved, then a longer notice period, of approximately 2 months, is required in order for INEOS to carry out the right level of due diligence before we are able to make a decision whether or not to approve the waiver request. INEOS will not put FPS at risk by approving waivers without carrying out the full due diligence required.
INEOS acknowledges that there are occasions, such as plant trips, when short notice waivers are required and we will endeavour to accept these short notice requests but we make no guarantees.
INEOS will monitor waiver request notice periods and we will contact those customers who make short notice waiver requests, other than for plant trips. Failure to comply with the required notice period may result in your waiver request being delayed and/ or a penalty administrative charge being applied.
Waiver requests will be assessed on a first come first served basis.
INEOS has sole discretion as to whether or not it grants a waiver request. If INEOS does elect to grant a waiver it will only do so in consideration of the relevant customer paying INEOS’s administration costs and an estimate of the incremental costs incurred by INEOS to transport and process the off-specification liquids (see Waiver Fees section).
INEOS’s ability to approve a waiver will depend on the capacity available in FPS and on the use of that capacity by other customers at the time. If INEOS is unable to approve the waiver request we may suggest an alternative date or duration that could be accommodated.
Duration of Waiver
Normally waivers are granted based on hours of use during each 24 hour period. We accept that there may be some uncertainty as to when the contaminant will be injected and subsequently delivered into FPS and we will allow, wherever possible, some flexibly by granting a waiver for a longer period of time than is actually needed. We will not however tolerate customers sterilising capacity in FPS due to lack of planning, If we believe that the requested duration is excessive we will reject the waiver request and ask the customer to resubmit for a shorter duration.
If INEOS approves a waiver request we will e-mail an approved waiver form back to the requestor. The customer must strictly comply with the terms of the waiver, which will be set out in the accompanying e-mail. Failure to comply with the terms may result in the waiver being revoked.
If there are any changes to the details of the waiver requested then the customers must contact the FPS waiver team (firstname.lastname@example.org) immediately and request their advice. The customer must not export contaminants into FPS if to do so would be outwith the terms of the approved waiver.
Waiver Close Out
Customers must close out their waiver within 24 hours of exporting the off-specification pipeline liquids. If the waiver is not closed out promptly this sterilises capacity in FPS which could be used by other customers; which in turn could have an impact on other customers’ production.
Therefore, to encourage prompt close out of the waiver, if the waiver is closed out within 24 hours FPS will charge the customers for the actual volumes of contaminants exported, but if the waiver is closed out after 24 hours then the customers is charged the higher of the actual volumes of contaminants exported or the requested volumes of contaminants.
Failure to close out the waiver correctly or on time will result in the customer being charged an additional fee to compensate INEOS for the additional work that the FPS waiver team has to do to chase late close out or incorrect information.
Continuous failure to close out waivers will be followed up with the installation supervisor and/or senior management.
If customers discover that they have exceeded their TPA quality specification then they should complete a breach notification waiver (see waiver form) and send it to the FPS waiver team immediately. 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.
If customers discover that they have exceeded their TPA quality specification then they should complete a Breach notification waiver (see waiver form) and send it to the FPS waiver team immediately (email@example.com). 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.
If the breach impacts the safety of FPS (e.g. H2S), frequently occurs or the customer fails to provide INEOS with a satisfactory explanation as to how the breach occurred and /or the mitigation plan is inadequate then INEOS will consider what further action it wishes to take, including the possibility of shutting in the relevant field(s) until the issue is resolved.
INEOS will check that customers are complying with the TPA quality specification and/ or approved waivers. If it is found that customers are not complying with their TPA obligations then INEOS will contact the relevant customers as outlined in the breach section above.
FPS may also carry out an audit to compare waiver volumes approved vs. daily reports from platforms, hydrocarbon accounts or other official sources.
FPS may also choose to conduct random testing of customers’ liquids to test customers’ compliance.