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Abstract Title: The Need for a Multilateral Acceptance Criterion of Mercury-Contaminated Facilities to Allow Safe Disposal
Presenter Name: Lee Hunter
Company/Institution: Total Hazardous and Integrated Solutions (THIS)
Session: Mercury Regulatory and Policy Matters
Co-Authors: Lee Hunter

Abstract Information :

The requirement to decommission aged Oil & Gas process facilities and infrastructure that have reached the end of their operational life is nothing new, but as our knowledge with regards the contaminants present increases, then the acceptance criterion for their required removal to enable reuse, abandonment, recycle or safe disposal becomes more prevalent. Ensuring compliance can become a quagmire of misinterpretation, loose references and non-relevant regulations, or even non-existent regulations only add to the costs and/or risks which can pose a serious risk to health and the environment if not done correctly. As everyone is already aware now, mercury is present in nearly all oil and gas fields and concentrations do vary widely, across the globe, although there are some regions that are naturally higher than others due to their tectonostratigraphic locality and now that large scale decommissioning campaigns need to be carried out, the navigation to a successful resolution becomes even more significant. This not only relates to how mercury is successfully removed but also with the final route of disposal for larger quantities of contaminated waste and a wider range of waste streams generated. If unable to decontaminate mercury in-situ then the subsea infrastructure would need to be removed in order to prevent toxic contamination of the aquatic ecosystem. Unless the decommissioned facilities are correctly decontaminated then the components cannot be sent for disposal, not even to a steel smelter. Subsequently, what is deemed safe or compliant for a steel smelter? What is the acceptable concentration of mercury to enable subsea infrastructures to be safely abandoned? Mercury contamination is surface bound so surely concentrations cannot be expressed in relation to the total mass of that item since it cannot be diluted through it or become bioavailable in smaller increments? What is the correct unit of measurement?

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