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Solving	Mercury	issues	onboard	FPSO,	
pipelines,	Platforms,	seabed,	process	facilities
•High	content	of	Mercury	(+	other	hazardous	materials)
•No	funds	for	decommissioning
•Notion	of	Duty	of	Care	
• DOE	Competent	Authority
•Definition	of	Waste
•No	waste	surveys	available
•Import	–export	of	Haz.	Waste
•Basel	Convention	- TFS
•No	yards	with	WM	License
•No	planning	permission
•Competent	person
•Yard	require	large	investment
•Absence	of	waste	Infrastructure
•Best	Practical	Economic Option
•Sustainability	issues
•PR	issues
APAC	issues	?
Act	A1441
Regulations ?
• Int’l	Regulations	state	that	you	have	to	remove	platforms
• Regional	Regulations	(Ascope)	state	that	you	have	to	remove	Platforms
• Local	Regulations	(Malaysian)		state	that	you	have	to	remove	Platforms
• Production	License state	that	you	have	to	remove	Platforms
• Industry	Practice	state	that	you	have	to	remove	Platforms
• Other	users	of	the	Sea	state	that	you	have	to	remove	Platforms
• IFRS	and	FAS	(Accountants)	state	that	you	must	the	funds	for	removal
• Environmental	Law	state	how	you	have	to	do	it.
• Geneva,	UNCLOS,	Basel	Convention,	COBSEA	Regional	Seas	to	be	Considered
• Duty	of	Care	principles	to	be	considered
• Sarbanes	Oxley	Act	state;	use	decommissioning	funds	for	decommissioning
Contaminated	North	Sea	oil	production	and	storage	tanker	ends	up	on	the	beach	in	
Bangladesh	October	2016.
Source:	NGO	Shipbreaking		Platform	- Maersk	owned		FPSO	North	Sea	Producer
Otapan
Clemeceau
Brent	Spar
The	greatest	proportion	of	by	humans	produced		
mercury	emissions	to	the	atmosphere	comes	from	
Asia,	which	contributes	about	50%	of	the	global	total.
Mercury	Monitoring
in	the	Gulf	of	Thailand
Section	5
Since	1997,	mercury	monitoring	in	the	Gulf	has	proceeded	annually	under	the	auspices	of	the	department	in	conjunction	
with	the	Center	of	Excellence	for	Marine	Biotechnology,	Department	of	Marine	Science,	Faculty	of	Science,	Chulalongkorn
University,	which	has	studied	and	analyzed	mercury	in	the	tissues	of	fish	found	around	petroleum	production	platforms.	
The	work	done	in	2009	showed	that	the	average	contamination	of	mercury	in	fish	tissues	was	below	the	0.5	
microgram/gram	standard	set	by	the	Ministry	of	Public	Health	and	below	the	average	mercury	level	in	fish	tissues	obtained	
from	domestic	markets.	Still,	the	department	will	continue	to	monitor	mercury	contamination	in	the	Gulf,	with	a	project	on	
monitoring	seawater	quality	in	the	Gulf	lined	up	for	2011.	This	effort	will	focus	on	the	quality	of	seawater	around	
production	platforms	to	support	the	department’s	effort	in	closely	monitoring	the	impacts	of	mercury	on	the	ecology	of	the	
Gulf,	and	its	defining	of	proper	measures	to	prevent	and	mitigate	environmental	impacts.
Source:	DMF	annual	report	2009
Stand	point	on	the	subject	from	Singapore	
National	Environmental	Agency
Quote
The	wastes	containing	heavy	metal	elemental	mercury	and	its	compounds	found	
onboard	the	ship	are	classified	as	hazardous	wastes	and	Singapore	does	not	allow	the	
import	of	hazardous	wastes	for	disposal.	Currently,	there	are	also	no	facilities	that	can	
recover	mercury	in	Singapore.
Hence,	we	are	unable	to	support	your	request	to	bring	into	Singapore	the	FSO	with	the	
metal	rust	scales	containing	heavy	metals	(mercury	and	its	compounds)	for	
decontamination	and	disposal.
Unquote
Is	Mercury	important	if	it	is	mentioned	in	787	Int’l	ISO	standards	and	in	
752	UNEP	documents	?
CONTENTS	of	PBConsultants report
0. REVISION	RECORD
1. SUMMARY
2. INTRODUCTION
2.1 Introduction	and	study	objective
2.2 List	of	abbreviations
3. PROVEN	MERCURY	DECONTAMINATION	TECHNOLOGIES
3.1 Introduction
3.2 Vacuum	Distillation
3.3 Chemical	cleaning
3.4 Removal	of	contaminated	piping	and	equipment
3.5 Melting	of	contaminated	steel	at	Siempelkamp
4. FUTURE	MERCURY	DECONTAMINATION		TECHNOLOGIES
4.1 Onshore	Vacuum	Distillation	Large	Scale
4.2 Offshore	vacuum	distillation
5. ONSHORE	TREATMENT	OF	MERCURY	CONTAMINATED	TOPSIDES
5.1 Yard	requirements
5.2 Risk	of	mercury	pollution	of	yard	and	personnel
6. DOMESTIC	TREATMENT	OR	EXPORTING	OF	MERCURY	WASTE
6.1 General
6.2 Injection	into	deep	well
6.3 Temporary	storage	of	mercury	contaminated	waste
6.4 Permanent	Storage
7. EVALUATION	OF	DIFFERENT	METHODS
8. CONCLUSIONS	AND	RECOMMENDATIONS
9. REFERENCES
10. APPENDICES
•Vacuum	distillation
•Chemical	Cleaning
•Chemical	Oxidation
•Melting	at	Siempelkamp
•Onshore	Vacuum	distillation
•Offshore	vacuum	distillation
•Injection	into	deep	well
•Temporary	storage
•Permanent	Storage
Vacuum	Distillation.
Acid	cleaning
Chemical		decontamination
Mercury	storage	cost:
An	EU	consultancy	report	published	in	2010	concluded	that	salt	mines	were	the	most	cost-
effective	location	for	the	permanent	storage	of	mercury	waste.	
To	permanently	store	10	to	20000	Tons	of	Mercury	waste	cost	US$	36M.	
Source:		Swedish	EPA	report
The	Swedish	EPA	report	estimated	the	cost	of	a	deep	bedrock	repository	having	a	capacity	of	
about	1,000	– 20,000	tonnes of	high-level	mercury	waste	to	be	about	SEK	200	– 300	million.
This	represents	a	cost	of	approximately	US$	27K	– 70K.		per	tonne of	“pure	mercury”.
http://ec.europa.eu/environment/chemicals/mercury/pdf/hg_flows_safe_storage.pdf
Floating	Decontamination	and	Disposal	Vessel	concept
Lessons	learned	?	
Convert	hazardous	waste	into	green	waste
FDDV	stands	for	Floating	Decontamination	and	Decommissioning	Vessel	a	solution	invented	
by	Thor	Sterker
The	“IDEA”
Vessel	cost		US$	30	– 150M.	?
Competitive	priced	at	$32	M.	only
“FDDV”	(Floating	Decontamination	and	Dismantling	Vessel)
• Solves	practical	issues	HSE	problems,	Permitting	and	Licensing	
headaches	– Maritieme law	
• Classed	and	certified	to	decontaminate	platforms,	FPSO’s,	pipelines,	
seabed,		deep	draft	ships	&	vessels
• Tackle	the	Haz-Mat	problem	in	situ,	at	the	beginning	of	the	pipeline	
not	at	the	end.
• All	hazardous	operation	under	Owners	Safety	Management	System
• Containment	- process	facilities	are	kept	intact	and	can	be	
decontaminated	as	one	complete	system	
• No	need	to	train	Onshore	Yard	personnel	how	to	deal	with	Hazardous	
Materials
“FDDV”	(Floating	Decontamination	and	Dismantling	Vessel)
• Only	need	to	train	a	select	group	of	skilled	laborers	/	engineers	
working	on	the	FDDV
• Decontaminated	platforms	classed	as	Green	waste.	
• No	need	to	worry	about	Trans	Frontier	Shipment	Reg’s (Basel	&	Hong	
Kong	Convention)	
• No	need	for	dedicated		onshore	Decontamination,	Dismantling,	
Disposal	Yard.	
• No	special	planning	permission	issues	for	the		onshore	
decontamination	facilities.
• More	(any)	yards	would	now	be	able	to	accept	an	platform	which	is	
certified	“free	from..”		– less	congestion
“FDDV”	(Floating	Decontamination	and	Dismantling	Vessel)
• Re-use	of	topsides	and	equipment	becomes	more	feasible	as	there	is	
no	liability	issue	with	handing	over	a	Clean	Platform	/	equipment	
• No	Risk	to	Health,	Safety	&	Environment	as	a	result	of	the	presence	
of	Mercury		(and	other	contaminants)
• ZERO	emissions	(other	than	emissions	from	FDDV	engines)
• No	Reputation	Damage
• Use	FDDV	to	prepare	platform	prior	to	HLV	arriving	in	field	– thus	
reducing	risks	of	delay	to	high	value	asset
• Pre-cutting	of	Topsides	and	jacket	foundation	piles
• Pre	cleaning	/	removal	of	contaminated	drill	cutting	piles	on	seabed	
• More	reasons	spring	to	mind
Funding	to	perform	feasibility	study
Because	of	its	efficiency	and	its	capability	to	operate	in	international	waters	it	can	work	
continuously	in	waters	from	ASCOPE	members,	therefore	Co-funding	of	the	FDDV	Feasibility	
study	by	Operators	of	the	eight	(8)	ASCOPE	member	States	eases	the	financial	burden
Together	with	Universiti Technologi Petronas (and	others	to	be	identified)	we	intent	to	perform	a	
feasibility	study	to	prove	the	concept	and	to	be	able	to	estimate	the	cost	efficiency	and	HSE	
benefits.	This	feasibility	study	would	take	approx	12	months	with	as	small	dedicated	team	of	
4	to	6	fulltime	Scientists	/	 Naval	Architect,	Process	– Facilities	Engineers	/	Chemist	/	
Environmental	engineer.	
At	this	moment	and	time	we	estimate	that	the	budget	for	the	entire	feasibility	study	to	be	around	
US$	400k.	to	prove	the	FDDV	concept.
Plan	is	to	circulate	a	definitive	concept	study	proposal	in	Q1	2017,	describing	deliverables,	
schedule	and	finish	date	of	the	study	and	resources	required		to	perform		the	study.
Per	Ascope members	that	would	be	around	US	75,000=	(plus	or	minus	15%)
Conclusion	&	Recommendation
This	feasibility	study	is	timely	given	that	the	price	of	oil	is	low,	means	day-rates	will	be	low	as	well.	The	amount	may	not	be	
enough	to	cover	decommissioning	costs	for	all	platform,	which	continuously	increasing	due	to	various	drivers	ie
regulators,	operators,	industry	dynamics.
1.	The	potential	decommissioning	market	with	regards	to	mercury	decontamination	will	greatly	benefit	from	FDDV	because	
it	resolves	a	lot	of	practical	issues,	HSE	problems	and	Permitting	&	Licensing	issues	for	respective	APAC	countries.
2.	The	economy	of	scale	for	all	platform	owners	and	government	in	APAC	countries	– more	platform	can	be	removed	with	
reduced	cost	and	in	environmentally	feasible	options,	in	line	with	owners’	sustainability	goals
3.	Create	new	industry	which	can	compete	with	Malaysia,	Vietnam,		Indonesia,	China,	India	and	Turkey
4.	Development	of	local	content	i.e skilled	laborers,	local	capabilities	and	technology
5.	Reduced	risks	of	HSE	as	a	result	of	presence	of	mercury,	and	platform	is	prepared	prior	to	HLV	arriving	in	the	field	thus	
reducing	risks	of	delay	to	high	value	assets
6.	Reduce	hazardous	waste
7.	No	need	for	temporary	storage	only	permanent	underground	storage	facilities	for	Metallic	Mercury	and	NORM
6.	Turn	a	cash	out	flow	into	a	cash	inflow.
Opportunities	continued
• Maintain	skilled	labor	in	lean	times	by	re	deployment
• Create	new	Industry	which	can	compete	with	China,	India,	Turkey
• Export	Decommissioning	expertise	to	Ascope members
• Owners	then	comply	also	with	their	SUSTAINABILITY	goals
Decommissioning	is	teamwork
Deliverables
The	research	sets	out	to	perform	a	feasibility	study	to	prove	the	concept	of	FDDV,	and	to	be	able	
to	estimate	the	cost	efficiency	and	HSE	benefits.	This	feasibility	study	would	take	
approximately	12	months	with	a	small	dedicated	team	of	4-6	fulltime	research	scientists,	
Naval	architect,	process	facilities	engineers/	chemist/	environmental	engineers.	
The	economy	of	scale	(removal	of	a	group	of	platforms	instead	of	individual)	is	highly	likely.	
The	offshore	platforms	can	be	pre-cleaned	and	decontaminated	in-situ	with	this	FDDV	concept.
This	study	embarks	on	the	following	objectives:
1. To	prove	the	concept	of	FDDV
2. To	estimate	the	cost	efficiency	of	the	FDDV	business	model
3. To	estimate	the	HSE	benefits	of	FDDV
Work	scope	and	Methodology
Stage	1:	Prove	FDDV	concept	– Bankability/	cost	efficiency
1.	Engagement	with	platform	owners	on	decommissioning	outlook	– to	explore	the	financial	commitment	of	potential	
investors	in	order	to	determine	the	financial	feasibility	of	the	project	locally	(Malaysia,	Thailand)	and	regionally	(APAC)
2.	Engagement	with	key	engineering	consultants	on	service	providers’	requirements	with	regards	to	mercury	
decontamination
3.	Benchmark	study	on	critical	parameters	required	for	mercury	decontamination	in	decommissioning
4.	Benchmark	study	on	cost	elements	in	FDDV
5.	Study	on	weightage of	the	cost	elements
Stage	2:	Prove	FDDV	concept	– Implement	ability	/	business	efficiency
1.	Evaluation	on	technical	competency	locally	and	external	outsourcing	and	technology	transfer	to	undertake	FDDV	in	APAC
2.	Engagement	with	owners	on	end-user	technical	requirement	
3.	Engagement	with	key	engineering	consultants	on	service	providers’	requirements
4.	Benchmark	study	on	critical	parameters	on	FDDV
Stage	3:	Compliance	to	standards	and	regulations	(HSE)
1.	Benchmarking	on	engineering	criteria	based	on	standards	and	regulations
2.	Development	of	engineering	criteria	based	on	standards	and	regulations
Stage	4:	Conclusion	of	feasibility	study
1.	Consolidation	of	Phase	1	findings	and	engagement	with	owners/governments
2.	Benchmark	and	field	verification	of	tool
3.	Rollout	and	engagement	with	owners/	service	providers/governments
Technical	&	Commercial	evaluation
Technical	Evaluation
Highlight	the	value	of	the	project	and	the	differences	or	strength	of	the	project	compared	to	the	one	available	in	the	market
1.	Currently	there	is	no	similar	facility	in	the	market.	This	is	the	first	business	model	for	floating	mercury	decontamination	
facilities.
2.	The	FDDV	will	provide	a	solution	to	the	dilemma	of	costly	decommissioning
Commercial	Evaluation
Highlight	the	potential	of	the	project	to	be	commercialized	in	the	current	market)
1.	FDDV	provides	a	solution	to	practical	issues,	HSE	problems,	Permitting	&	Licensing	headaches
2.	Cost	savings	due	to	elimination	of	onshore	facilities	at	respective	countries	to	decontaminate	decommissioned	platform,	
the	FDDV	will	service	all	countries	in	APAC	region.	Its	efficiency	and	capability	to	operate	in	international	waters	means	
it	can	work	continuously	in	APAC	waters.
3.	The	feasibility	study	will	establish	and	prove	the	concept	and	estimate	the	cost	efficiency	and	HSE	benefits.
Benefit	to	both	Malaysia	and	Thailand
1.	The	economy	of	scale	for	all	platform	owners	and	government	in	APAC	countries	– more	platform	can
be	removed	with	reduced	cost	and	in	environmentally	feasible	options,	in	line	with	owners’	sustainability	goals
2.	Create	new	industry	which	can	compete	with	China,	India	and	Turkey
3.	Development	of	local	content	ie skilled	labors,	local	capabilities	and	technology
4.	Reduced	risks	of	HSE	as	a	result	of	presence	of	mercury,	and	platform	is	prepared	prior	to	HLV
arriving	in	the	field	thus	reducing	risks	of	delay	to	high	value	assets
5.	Reduce	the	need	to	train	onshore	yard	personnel	on	how	to	deal	with	hazardous	waste	materials
6.	Solves	a	lot	of	practical	issues,	HSE	problems,	permit	and	licensing	headaches
Cost	comparison
Comparison	of	the	project	output	/	process	with	the	output	/	process	available	in	the	market	if	available
A	UN	Environmental	Program	(UNEP)	provided	a	cost	estimate	for	a	land	fill	facility	for	comparison	purposes:
a.	A	land	disposal	facility	of	tonnage	capability	between	25,000	tonnes	to	100,000	tonnes	had	a	cost	estimate	of	anywhere	
in	between	USD	11.1m	to	USD	30.4m
b.	Such	a	solution	would	be	very	geographically	rigid	and	would	not	provide	logistical	advantage	for	facilities	which	are	far
away	from	the	disposal	site
c.	In	addition,	a	land	facility	would	be	subject	to	local	authority	regulations	and	levees	as	opposed	to	a	disposal	vessel	
operating	in	international	waters
IKIMP	report	(mercury	knowledge	exchange)
5.	Release	of	mercury	during	transportation
Many	smelters	set	a	2000	μg/kg	limit	on	mercury	in	scrap	steel	to	avoid	damage	to	the	off-gas	
clean-up	filters	– with	higher	concentrations	requiring	disposal	as	hazardous	waste	(9).	
The	difficulties	in	disposing	of	material	classified	as	hazardous	waste	means	that	some	natural	
gas	pipelines	set	entry	specifications	that	limit	mercury	content	(e.g.	the	Frigg	pipeline,	38).	
This	requires	the	installation	of	a	mercury	removal	process	prior	to	gas	entering	the	pipeline,	
upstream	of	the	refinery	process.	
As	an	approximate	calculation	to	establish	an	upper	bound	on	the	mercury	retained	within	the	
pipeline	network,	if	one	assumes	2000	μg/kg	mercury	absorbed	up	to	a	1mm	depth	across	the	
whole	pipeline	system,	an	average	pipeline	diameter	of	0.27	m	(37)	and	density	of	8	
tonnes/m3,	this	would	suggest	that	up	to	207	kg	(5)	of	mercury	could	be	absorbed	on	UK	
pipeline	walls.

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