Environment Enterprise and Transportation Committee 27th August, 2009 Agenda Item No. 24 Appendix MOSSMORRAN & BRAEFOOT BAY INDEPENDENT AIR QUALITY MONITORING REVIEW GROUP 2008 Annual Report August 2009 CONTENTS 1. INTRODUCTION 2. OBSERVATIONS 3. CONCLUSIONS APPENDIX 1 The Review Group: Constitution and Terms of Reference APPENDIX 2 Membership of the Review Group APPENDIX 3 Regulatory and Policy changes relating to air quality in 2008 APPENDIX 4 Regulated emissions to air APPENDIX 5 2008 flaring report APPENDIX 6 Atmospheric Monitoring Study at ExxonMobil Fife Ethylene Plant Mossmorran APPENDIX 7 Glossary MOSSMORRAN & BRAEFOOT BAY INDEPENDENT AIR QUALITY MONITORING REVIEW GROUP 2008 Annual Report 1. INTRODUCTION The Mossmorran & Braefoot Bay Independent Air Quality Monitoring Review Group (the Review Group) was formed to provide advice and recommendations to Fife Council (formerly Fife Regional Council and Dunfermline and Kirkcaldy District Councils) regarding the monitoring of air emissions arising from the operations at the Mossmorran plants and the Braefoot Bay terminal facilities (operated by Shell UK Limited and ExxonMobil Chemical Limited). The constitution and terms of reference of the Review Group are described in Appendix 1. Appendix 2 lists the members of the Review Group during 2008. Shell UK operates the Mossmorran Gas Fractionation Plant that extracts natural gasoline, ethane, propane and butane from natural gas liquids pumped from the St Fergus gas plant at Peterhead. The plant at Mossmorran comprises three identical process units fed directly from the pipeline. Large atmospheric pressure tanks store propane, butane and gasoline. These products are supplied by underground pipeline to the Braefoot Bay deep water loading facility, where they are loaded on to tankers. Ethane is piped to feed the Fife Ethylene Plant (operated by ExxonMobil) and to the BP site at Grangemouth. The plant also supplies approximately 5% of the total propane and butane to the Shell Gas Road Loading Terminal. The ExxonMobil Chemical Fife Ethylene Plant is one of Europe's largest and most modern ethylene plants. It has the capacity to produce 830,000 tonnes of ethylene a year. Previous air quality monitoring demonstrated that concentrations of benzene and other hydrocarbons were low in the vicinity of the facilities. The Review Group concluded in 1999 that its work was nearing completion and that further air quality monitoring was probably not required. However, the Review Group was reconstituted in 2001 following concern expressed by local communities, and highlighted in media reports, with regard to perceived air quality and cancer-related health issues in the vicinity of Mossmorran and Braefoot Bay. The Review Group continues to liaise with local communities and representatives of the local health service. The aims of this Annual Report are to: Outline any substantive changes in the facilities at Mossmorran and Braefoot Bay and their likely impact on local air quality; Describe any changes in air quality regulation and changes in knowledge on health effects of benzene or any other possible emissions from the plants; Comment on the results of ambient air quality monitoring undertaken by the National Physics Laboratory (NPL), on behalf of BP Exploration Operating Company Ltd, in terms of air quality policy, plant operations and risks to health in the local community; Comment on the emissions from point sources at the facilities; Summarise the available data on flaring during 2008; Review the local air quality measurement study that was undertaken by NPL on behalf of ExxonMobil during a period of planned flaring. Page 3 of 20 2. OBSERVATIONS The main observations of the Review Group in 2008 were as follows. i) There were no significant changes in the plant or its operation during 2008. ii) There have been no changes in the regulations governing air quality management and the prevention and control of emissions to air. The Technical Guidance for local authorities in relation to Local Air Quality Management was revised during 2008 but this has no implications for the operations at Mossmorran and Braefoot Bay which are regulated by the Scottish Environment Protection Agency (SEPA). SEPA have developed a new scheme to assess operator compliance which is being implemented from the beginning of 2009. In the future, good operator compliance may be rewarded by a lowering of inspection frequency and the fees paid to SEPA (Appendix 3). iii) Emissions from all regulated sources at Mossmorran and Braefoot Bay in 2008 were below the emission limits set by SEPA (Appendix 4). Emission limits are set to ensure that the impact of emissions are minimised through the efficient operation of a process. As it can be difficult to monitor a substance once it has been released into the atmosphere, operators are required to carry out periodic measurements of gases before they exit the stacks. Emission Limit Values (ELVs) are specified in a Permit or Authorisation and generally focus on the principal emissions from industrial processes where control is necessary. ELVs can be a direct requirement of legislation, set in connection with what is achievable in terms of Best Available Techniques, or be generated on a site specific basis. ELVs are set for the protection of human health and the environment. iv) NPL, on behalf of BP Exploration Operating Company Ltd, reported on 12 months of air quality monitoring around Hound Point (from 04/01/08 to 31/12/08). These measurements are made in order to provide information about the impact of BP’s operation at Hound Point on local air quality. Measurements were made at twelve sites on the south coast of Fife, between North Queensferry and Burntisland. Samples are collected over two-week periods throughout the year. The measurements made in 2008 are not directly comparable with those made in previous years because samples were collected on a different type of sorbent material giving an improved retention of lower molecular weight compounds. As a result of this methodological change, the concentrations of some compounds (isobutene, n-butane, isopentance, n-pentane) appear to be higher than previously reported. After taking account of the change in sorbent material, the concentrations of volatile organic compounds (VOCs) measured in most samples are believed to be similar to those measured in previous years. Samples collected near The Old Battery in North Queensferry, however, showed an increase in concentration since last year and concentrations of all the measured VOCs were higher than those measured elsewhere. The average benzene concentration at this location was 0.6 ppb, well below the current National Air Quality objective of 5 ppb (16.25 µgm-3) and the 2010 objective of 1ppb (3.25 µgm-3), but higher than at the other locations where monitoring was performed (0.2-0.4 ppb). Mean concentrations of total hydrocarbons over 12 months ranged from 5 ppb at The Belvedere Hotel in West Wemyss to 46 ppb near the Old Battery. Mean concentrations of n-hexane, n-heptane, toluene and xylene were less than 1 ppb at all locations including the Old Battery. Mean concentrations of iso-butane were generally less than 2 ppb but were 5.8 ppb at the Old Battery. Similarly, concentrations of n-hexane were generally less than 1 ppb but 2.2 ppb at the Old Battery. Concentrations of n-butane, iso-pentane and n-pentane Page 4 of 20 ranged from 1.1 to 30.8 ppb by pollutant and location with the highest mean measurements for each pollutant reported for the Old Battery. The second highest mean measurements reported for each of the pollutants were generally made at the Queensferry Lodge Hotel, North Queensferry. Although hydrocarbon concentrations at these locations were not clearly elevated in comparison to the other sites in 2007, higher levels of hydrocarbon have been reported at these locations in the more distant past, notably in 2001/2002. v) The quantities of gas flared in 2008 were greater than in 2007 but within the range reported in previous years (Appendix 5). Some flaring occurred in each month with increased levels during April, August and October with the latter two periods being associated with planned maintenance (Appendix 5). It is noticeable that the quantities flared over the last three years have been substantially greater than in 2005 or previously between 2001 and 2003. vi) ExxonMobil recently commissioned a study of air quality around the Mossmorran complex before, during and after a period of planned maintenance and related flaring activity. The study assessed the quality of the air at 8 different locations, including three residential areas (Lochgelly, Auchertool and Castlehill, near Cowdenbeath). A range of pollutants were monitored, including benzene and particulate matter (microscopic material that is carried in the atmosphere). The assessment was carried out by the National Physical Laboratory between 21 August and 1 October 2008. The monitoring study concluded that there was no evidence to show that maintenance and flaring activities on the Mossmorran site were having a detrimental impact on local air quality (Appendix 6). vii) Fife Council’s air quality review and assessment progress report for 2007/8 indicates that national air quality objectives are expected to be met in the area around Mossmorran and Braefoot Bay for all pollutants included in the Air Quality Standards (Scotland) Regulations 2007. [To date, only one Local Air Quality Management Area has been declared in Fife. It is over 20 miles from Mossmorran at Bonnygate, Cupar, where air quality objectives are exceeded for nitrogen dioxide and PM10 as a result of traffic emissions.] viii. ExxonMobil have introduced an e-mail communication which is sent to key contacts if flaring or unusual operations are taking place. The aim of this communication is to provide additional information and not to replace the phone messages presently made to key contacts. Page 5 of 20 3. CONCLUSIONS i) Emissions from regulated sources within the plants in 2008 remained well below the limit values set by SEPA for the protection of public health and the environment. ii) These results are consistent with the previous work of the Review Group. In the areas around Mossmorran and Braefoot Bay the 2010 air quality objective for benzene is being satisfied readily. iii) The quantities flared during 2008 were higher than in 2007 but within the range reported previously. The results of an air quality measurement survey undertaken during a period of planned plant shutdown indicated that the impacts of flaring on local air quality were negligible. iv) The work undertaken in 2008 demonstrates that emissions from Mossmorran and Braefoot Bay continue to pose no significant risk to the health of the local community. Page 6 of 20 APPENDIX 1 The Review Group: Constitution and Terms of Reference The Review Group reports to Fife Council which requires its operating costs to be financed by ExxonMobil Chemical Limited (ExxonMobil) and Shell UK Limited (Shell). Review Group members are appointed by Fife Council. Professor Sibbett continues as Independent Chair, with representatives from Fife Council, SEPA and the Institute of Occupational Medicine participating as members. The Review Group also includes representation in public health from the Dunfermline and West Fife Community Health Partnership (formerly West Fife Local Health Care Co-operative) on behalf of NHS Fife and two members represent the local Community Councils. This is designed to ensure that timely and informative communications can be provided in respect of any relevant health issues that might arise in the local communities. Representatives of ExxonMobil and Shell attend the Review Group meetings by invitation. The full constitution and terms of reference of this reconstituted group are given below. Briefly, the Review Group’s approach to carrying out its functions has been re-assessed, allowing it to take less involvement in the monitoring of air quality, but instead to focus attention on the review of such data. 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. Detailed Constitution and Terms of Reference 1.0 TITLE 1.1 The Group is known as the Mossmorran & Braefoot Bay Independent Air Quality Monitoring Review Group (referred to below as the Review Group). 2.0 INTRODUCTION 2.1 The Review Group was formed to provide advice and recommendations to Fife Council (formerly Fife Regional Council and Dunfermline and Kirkcaldy District Councils) regarding the monitoring of air emissions arising from the operations at the Mossmorran plants and the Braefoot Bay terminal facilities. Specific terms of reference which previously pertained were as required by planning conditions applying to the operation of the plants. 2.2 The Review Group’s approach to carrying out its functions has been re-assessed, allowing it to take less involvement in the monitoring of air quality, with its primary responsibilities being re-directed towards reviewing such data. Of particular relevance are issues relating to any health concerns raised by residents within the local communities, and a key role is assisting with communications of air quality related information. 3.0 TERMS OF REFERENCE 3.1 The Review Group (as reconstituted in terms of para. 2.2 above) has the following remit: (i) To provide advice on air quality related monitoring arrangements. (ii) To review air quality monitoring data obtained at sites in the vicinity of the Mossmorran complex and the Braefoot Bay terminal. (iii) To consider, advise and make recommendations on the outcome of monitoring data. The Review Group intends by inclusion in its membership of public health representation that timely and informative communications can be provided in respect of any relevant health issues that might arise in the local communities. Page 7 of 20 (iv) To submit reports to Fife Council and to make presentations as appropriate to representatives of the Community Councils that are local to the Mossmorran plants and the Braefoot Bay terminal. The Review Group intends inclusion in its membership of representation from the local Community Councils to assist with this communications related responsibility. 3.2 These terms of reference shall not imply any responsibility for, control over, or restriction of the statutory or common law positions of Fife Council, Shell UK Limited (Shell), ExxonMobil Chemical Limited (ExxonMobil), or any other local authority, statutory authority or agency, or company, or institution, nor derogate from the rights, powers and responsibilities of such authorities, agencies, companies or institutions. 4.0 APPROACH 4.1 The Review Group’s approach will be based on: (i) Making the Minutes of its meetings publicly available; (ii) Ensuring that all reports produced by, or on behalf of, the Review Group are fully documented and contain source references to all relevant data; (iii) Providing regular and non-technical summaries on its activities; (iv) Informing the local communities through submissions to existing liaison structures (i.e. primarily the Mossmorran & Braefoot Bay Community & Safety Committee) and through direct presentations by Review Group members as appropriate, and (v) Being open to approaches from local communities and individuals. 5.0 MEMBERSHIP 5.1 Membership of the Review Group comprises appropriate representation from the following: An Independent Chair Fife Council officials Institute of Occupational Medicine (IOM) Scottish Environment Protection Agency (SEPA) Public health services Community Councils on the Mossmorran & Braefoot Bay Community & Safety Committee (inland and coastal) 5.2 The Review Group will invite representatives of Shell and ExxonMobil to attend meetings, and may invite others to address group members on issues related to the terms of reference set out at para. 3.1 above. 5.3 The Review Group Secretary (see para. 6.2 below) shall maintain a current register of members, for distribution and information purposes. 5.4 ExxonMobil maintains a list of Community Council contacts who are notified of flaring. 6.0 OFFICE BEARERS 6.1 The Independent Chair may be nominated by any member of the Review Group. If any change in the appointment as Chair is proposed, the agreement of Fife Council will be required. 6.2 The Review Group approves the appointment of a Secretary, who prepares a record of meetings and is responsible, in consultation with the Chair, for preparing agenda papers, summoning the meetings, and circulating a record of meetings to the membership. Page 8 of 20 6.3 The finalisation of reports by the Review Group shall be as determined by the Chair. 7.0 MEETINGS 7.1 The Review Group will meet as frequently as is considered necessary by the Chair (normally at least once a year), having regard to the remit set out at para. 3.1 above. 7.2 The Secretary shall send to all members and others, as appropriate, a record of the previous meeting, together with notice and agenda papers for all meetings of the Review Group, at least seven days before the day of the meeting. 7.3 Business shall be in keeping with the terms of reference set out at para. 3.1 above. 8.0 FINANCE 8.1 The companies, having met the cost of monitoring work previously undertaken in fulfilment of planning conditions, shall meet relevant costs based on the advice of the Review Group. 8.2 The local authority shall meet any reasonable costs of the administration of the Review Group. Page 9 of 20 APPENDIX 2 Membership of the Review Group (as at December 2007) Name Designation/ Representing Address Prof. Wilson Sibbett Independent Chair School of Physics & Astronomy, University of St Andrews Stuart Wilson Interim Team Leader (Development, Promotion and design) Fife Council Development Services, Dunfermline Douglas Mayne Fife Council (Environmental Services) Environmental Services, Glenrothes Liz Box Committee Administrator, Fife Council Democratic Services, Dr Alison Searl Institute of Occupational Medicine (IOM) Edinburgh Michelle Hickson Scottish Environment Protection Agency (SEPA) Perth Lynn Campbell Dunfermline & West Fife Community Health Partnership Lynebank Hospital, Dunfermline Robert Arnott Crossgates & Mossgreen Community Council Crossgates (Inland) William Dryburgh Aberdour Community Council Aberdour (Coastal) Barry Jarvis Shell UK Limited Fife NGL Plant, Mossmorran Norman White Shell UK Limited Fife NGL Plant, Mossmorran Alex Baird Shell UK Limited Fife NGL Plant, Mossmorran Ian Hackers ExxonMobil Chemical Limited Fife Ethylene Plant, Mossmorran William Sweenie ExxonMobil Chemical Limited Fife Ethylene Plant, Mossmorran Kenny Bisset Fife Council (Environmental Services) Environmental Services, Glenrothes Dr. Alastair Robertson Institute of Occupational Medicine Edinburgh John Lamb Air Quality Management Specialist, SEPA Edinburgh Dr Jackie Hyland NHS Fife, Cameron Hospital Leven, Fife Linda Whetren NHS Fife A. MEMBERS B. BY INVITATION Page 10 of 20 Fintan Hurley Institute of Occupational Medicine Edinburgh Chris Rushton Auchtertool Community Council Auchtertool Alexander Macdonald Burntisland Community Council Burntisland David Taylor Cardenden & Kinglassie Community Council Cardenden Alex Haddow Cowdenbeath Community Council Cowdenbeath Colin McPhail Dalgety Bay & Hillend Community Council Dalgety Bay Ernest McPherson Lochgelly Community Council Lochgelly Page 11 of 20 APPENDIX 3 Regulatory and Policy changes relating to air quality in 2008 There were no changes in regulation relating to air quality in Scotland during 2008. The technical guidance for local authorities on how to undertake assessments to meet their obligations with respect to Local Air Quality Management under the Environment Act, Part IV (1995) was revised during 2008. A draft copy of the revised guidance made available as TG(08). There are no implications arising from the revised guidance for the operations at Mossmorran and Braefoot Bay which are regulated by the Scottish Environment Protection Agency (SEPA). During 2008, SEPA adopted a “Better Regulation Initiative” which aims to reduce the administrative burden and costs to operators and to improve the consistency, transparency and accountability of regulation. As part of this initiative, SEPA is introducing a new compliance assessment scheme in 2009. The aim of the new scheme is to create a consistent approach across various regulatory regimes. It will be used to assess compliance with the Radioactive Substances Act 1993 (RSA), waste management legislation, the Pollution Prevention and Control (Scotland) Regulations 2000 (PPC) and the Water Environment (Controlled Activities) (Scotland) Regulations 2005 (CAR). The scheme will not apply to the Control of Major Accident Hazard Regulations (COMAH). The new compliance scheme will be phased in across the different regimes regulated by SEPA and gradually replace the existing Operator Performance Assessments (OPA). The scheme will apply to Pollution Prevention and Control (PPC) from January 2009, resulting in the first assessments of these permits being produced in spring 2010. The final OPA for PPC activities for calendar year 2008 will be completed in the first half of 2009. The new scheme is not directly linked to inspection frequency in the way that the current OPA scheme is. The performance of the site will have an impact on the regulatory effort applied to the site and this may well take the form of additional inspections where poor compliance is observed. In the future, the compliance assessment may also be used as a basis to reward operators achieving a high level of compliance through a lowering of their annual permit charges (subject to the outcome of a consultation process to be completed in 2009). The scheme will not alter the basic content of permits. Page 12 of 20 APPENDIX 4 Regulated emissions to air Emissions from all regulated sources at Mossmorran and Braefoot Bay during 2008 were well below the limits set by SEPA. SEPA authorises the operations carried out by both Shell and ExxonMobil at Mossmorran under the Pollution Prevention and Control (Scotland) Regulations 2000 (PPC). The PPC permits are based on the concept of Integrated Pollution Prevention and Control (IPPC) and define limits for emissions from the facilities at Mossmorran to air, water and land. SEPA has set permit conditions that ensure that Best Available Techniques are being employed by the companies to prevent or generally reduce the impact of emissions on the environment. ExxonMobil’s vapour control unit at Braefoot Bay is authorised under the Environmental Protection Act 1990. For airborne emissions from Mossmorran, the Shell and ExxonMobil permits concentrate on stacks from furnaces, boilers and a gas turbine. They define emission limits for each regulated source and set out sampling and reporting regimes for assessing compliance with these limits. The companies must report results to SEPA’s Strathearn Office in Perth for appraisal. SEPA also make these results available in a public register. The emissions monitoring measurements for 2008 submitted to SEPA are summarised for each regulated Shell and ExxonMobil source at Mossmorran in Tables A4.1 and A4.2 respectively, and for Braefoot Bay in Table A4.3. The emission limits, authorised by SEPA for each emission source, are also listed in these tables. During 2008, emissions from all regulated sources at Mossmorran were well below the limits set by SEPA. Table A4.1: Emissions from Regulated Shell Sources at Mossmorran during 2008 CO Concentration (mg/m3) NOx Concentration (mg/m3) SO2 Concentration (mg/m3) Authorised Emissions Limit 2008 average Authorised Emissions Limit 2008 average Authorised Emissions Limit 2008 average Furnace 1 100 <20 150 73.8 10 0.62 Furnace 2 100 <20 150 86.2 10 0.20 Furnace 3 100 <20 150 75.0 10 0.68 Page 13 of 20 Table A4.2: Emissions from Regulated ExxonMobil Sources at Mossmorran during 2008 CO Concentration (mg/m3) Authorised PPC Emissions Limit no limit no limit no limit no limit no limit no limit no limit 2008 Average nm nm nm nm nm nm nm Furnace 1 Furnace 2 Furnace 3 Furnace 4 Furnace 5 Furnace 6 Furnace 7 Gas Turbine Stack no limit nm Boiler A 200 0.0 Boiler B 200 0.0 Boiler C 200 0.0 No limit: no emission limit applied by SEPA nm: not measured NOx Concentration (mg/m3) Authorised PPC Emissions 350 350 350 350 350 350 350 550 350 350 350 SO2 Concentration (mg/m3) 2008 Average 88.9 103.7 99.4 93.3 108.0 91.2 170.9 Authorised PPC Emissions Limit no limit no limit no limit no limit no limit no limit no limit 2008 Average nm nm nm nm nm nm nm 148.0 107.6 132.1 122.1 no limit no limit no limit no limit nm 37.4 14.3 0.5 Table A4.3: Emissions of Benzene and Total Hydrocarbon from ExxonMobil Regulated Source at Braefoot Bay (Vapour Control Unit) measured in 2008 Benzene (mg/m3) VOCs (ppm) (Authorised Limit = 10 mg/m3) (Authorised Limit = 20 mg/m3) 04-Jan-081 1.4 8.7 02-Feb-08 0.1 0.0 24-Mar-08 0.6 0.1 26-May-08 <0.04 <0.05 29-May-08 <0.05 <0.05 30-Jul-08 <0.043 <0.1 31-Jul-08 <0.045 <0.1 19-Dec-08 <0.07 <0.1 Date January 2008 readings were taken with a portable analyser known to over-estimate concentrations of VOCs. The January measurement is expressed in ppm, not mg/m 3. From February 2008 onwards, concentrations were measured by an external consultant using more accurate procedures. Page 14 of 20 APPENDIX 5 2008 Flaring Report A5.2 ExxonMobil Fife Ethylene Plant Table A5.1, below, indicates the quantities flared during 2008. There were a number of periods of planned and unplanned maintenance that led to plant shutdown and flaring during the year. Table A5.1 Quantities Flared from the ExxonMobil Fife Ethylene Plant Flaring from Planned Start Up/Shutdown Flaring Month Flaring from Routine, Normal Baseline Operations Flaring from Abnormal or Non Routine Operations Elevated Flare Tonnes Flared Ground Flares Tonnes Flared Elevated Flare Tonnes Flared Ground Flares Tonnes Flared Elevated Flare Tonnes Flared Ground Flares Tonnes Flared 0 0 0 496 2572 667 April 0 0 2800 0 0 1247 7 0 0 266 397 470 613 0 0 324 0 0 May 0 0 21 528 0 0 June 0 0 58 387 0 0 August 0 1425 0 726 0 53 376 549 0 0 0 0 September 2832 4160 0 345 0 0 November 0 0 0 0 0 6 405 359 0 2282 0 2200 December 0 0 4 298 632 240 January February March July October Event Reason Process Compressor R-C-01 unplanned shutdown. Valve positioner maintenance No events Plant shutdown for essential maintenance Shell Ground Flares out of service for maintenance Shell Ground Flares out of service for maintenance Plant shutdown for essential maintenance Plant shutdown for essential maintenance No events Gas Turbine unplanned shutdown The quantity flared varies from year to year depending on circumstances and the quantity flared in 2008 was greater than in 2007 (7,797 tonnes elevated flares, 10,563 tonnes ground flares) but within the range reported in earlier years as shown in the graph below. It is noticeable that the quantities flared over the last three years have been substantially greater than in 2005 or previously between 2001 and 2003. Page 15 of 20 40000 Tonnes flared 35000 30000 25000 20000 15000 10000 5000 0 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 Year A5.2 Shell Natural Gas Liquefaction Plant A total of 392 tonnes of gas was flared from the Shell NGL plant during 2008. There were no unplanned flaring events during 2008, with all flaring from the NGL plant arising during planned maintenance and routine events. Table A5.1 summarises the monthly flaring from the NGL plant. Table A5.2 Quantities flared from the Shell Natural Gas Liquefaction Plant during 2008 Month January February March April May June July August September October November December TOTALS Tonnes Flared 31.8 32.8 27.3 17.2 24.7 41.6 36.1 65.6 25.6 24.2 34.0 31.4 392.3 Page 16 of 20 APPENDIX 6 Atmospheric Monitoring Study at ExxonMobil Fife Ethylene Plant Mossmorran Non Technical summary ______________________________________________________________ Introduction 1) ExxonMobil recently commissioned a study of air quality around the Mossmorran complex before, during and after a period of planned maintenance and related flaring activity. The study assessed the quality of the air at 8 different locations, including three residential areas. The assessment was carried out by the National Physical Laboratory between 21 August and 1 October 2008. 2) It was important to ensure that the monitoring devices were positioned at locations where pollutants are most likely to be carried by the wind. Whilst the prevailing wind in Fife generally comes from the south west, north easterly winds are also quite common. Monitoring devices were therefore located in Lochgelly, Auchertool and Cuttlehill (near Cowdenbeath). A range of pollutants were monitored, but the two of most concern (with regards to human health) were benzene and particulate matter (microscopic material that is carried in the atmosphere). Benzene 3) The measured concentrations of benzene in the residential areas when flaring was underway were almost identical to those that were obtained when there was no flaring in progress. There was no evidence to show that flaring activity increased the concentrations of benzene at the residential areas. 4) The measured concentrations of benzene at the residential areas were consistently lower than the maximum permitted level that has been introduced to protect human health. This Scottish air quality standard is more stringent than the one that applies in England, Wales and other parts of Europe. Particulate Matter 5) The monitoring study measured the concentrations of microscopic material carried in the atmosphere. If the activities on the Mossmorran site were adding to the local concentrations, this would have been detected by the monitoring device that was located downwind of the plant at the time. However, the study found that monitors at all locations measured similar concentrations over the same time period, thus suggesting that the material is likely to have been carried in from areas outside Fife. This ‘background’ level will consist of a wide range of materials that have been created by human and natural activities (for example: dust from agricultural activities, sea salt, smoke from domestic fires, fungal spores and sand from the Sahara). 6) Again, the Scottish air quality standards for particulate matter are more stringent than those that apply to the rest of the United Kingdom and Europe. The measured concentrations indicate that the local concentrations of particulate matter were lower than the maximum permitted levels that have been set to protect the most sensitive individuals in society. 7) The Scottish Government has published a method (1) that is used to assess how a pollutant is likely to affect a person who is sensitive to the effects of air pollution. All the 1) http://www.scottishairquality.co.uk/about.php?n_action=standards&t=5 Page 17 of 20 measured concentrations of particulate matter are typical of a rural environment and they all fell into the lowest categories of the Air Pollution Bandings and Index. 8) There is no evidence to indicate that the activities on the Mossmorran site were making a measurable contribution to the levels of particulate matter in the residential areas. Other Hydrocarbons 9) The assessment also measured a range of hydrocarbons that included 1,3-butadiene. These concentrations were generally so low, that they could not be detected by the monitoring equipment. Conclusion 10) The monitoring study concluded that there was no evidence to show that maintenance and flaring activities on the Mossmorran site were having a detrimental impact on the quality of the air in Lochgelly, Auchtertool or Cuttlehill. A copy of the monitoring study was submitted to Fife Council’s Environment Enterprise and Transportation Committee on 28th May, 2009. Page 18 of 20 APPENDIX 7 GLOSSARY Concentration Units ppb: parts per billion by volume, concentration unit for gases and vapours, equivalent to one cubic millimetre of gas mixed with one cubic metre of air. ppm: parts per million by volume, concentration unit for gases and vapours, equivalent to µg/m3: microgram per cubic metre, mass concentration unit for particulates and gases. There are 1,000,000 micrograms in a gram and 25,000,000 micrograms in an ounce. mg/m3: milligram per cubic metre, mass concentration unit for particulates and gases. 1 mg/m3 = 1,000 g/m3. Pollutants PM10: This is the fine fraction of airborne dust, defined by international convention, that can be deposited in the lung. It is the fraction of airborne dust around which the UK air quality standard is defined. There are many sources, including road traffic, agriculture, industry and many personal activities. It includes particles that are approximately less than 10 μm in diameter. PM2.5: This is a subfraction of PM10 sometimes referred to as “high risk respirable”. It is the fraction of airborne particles that can penetrate to the gas exchange region of the lungs in those with compromised respiratory health. PM2.5 is largely comprised of particles generated by combustion plus particles that form as a result of reactions in the atmosphere. These include particles that form from sulphur dioxide and nitrogen oxides. Benzene: This aromatic hydrocarbon is a minor component of petrol. Fuel distribution and car exhausts are its most important environmental source. It is present in cigarette smoke, some foods and drinks and widely in nature. Benzene is recognised as causing cancer in people. 1,3-Butadiene: Butadiene is a hydrocarbon that arises in air solely from human activity. It is an important industrial chemical, being used in synthetic rubber manufacture and is found in some liquid petroleum gases. Its main sources in the environment are, however, from road traffic emissions. It is considered as capable of causing cancer in people. Nitrogen Dioxide: This gas is produced by the reaction of oxygen and nitrogen during combustion. Vehicle emissions are a major source. It is well known as an irritant and, more recently, has been found to affect health at concentrations that can be found in the environment and indoors. Nitric oxide always occurs when nitrogen dioxide is formed. The two gases together are known as oxides of nitrogen, sometimes described in shorthand form as NOx.. VOCs or Volatile Organic Compounds: Carbon-based (or organic) chemicals that readily evaporate. Many hydrocarbons, including benzene, butane, pentane and hexane are VOCs. Organisations/facilities SEPA: Scottish Environment Protection Agency Page 19 of 20 FEP: Fife Ethylene Plant - ExxonMobil Chemical Limited (ExxonMobil)’s production facility at Mossmorran and ExxonMobil’s Braefoot Bay Marine Terminal. Fife NGL Plant: Fife Natural Gas Liquids Plant – comprises Shell UK Limited (Shell)’s production facility at Mossmorran for the fractionation of liquefied natural gas, and Shell’s Braefoot Bay Marine Terminal. NPL: National Physical Laboratory Other ELV: Emission Limit Value PPC: Pollution Prevention and Control Page 20 of 20