Specification For On Site Mercury Management 2087 SP Onsite

User Manual: 2087

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UNRESTRICTED Document ID: SP-2087
Jan-10 Filing Key: Business Control
Petroleum Development Oman L.L.C.
Engineering and Operations
Specification for Onsite
Mercury Management
User Note:
The requirements of this document are mandatory. Non-compliance shall only be authorised by
the Document Owner or his Delegate through STEP-OUT approval.
A controlled copy of the current version of this document is on PDO's EDMS. Before making
reference to this document, it is the user's responsibility to ensure that any hard copy, or
electronic copy, is current. For assistance, contact the Document Custodian or the Document
Controller.
Users are encouraged to participate in the ongoing improvement of this document by providing
constructive feedback.
Please familiarise yourself with the
Document Security Classification Definitions
They apply to this Document!
This document is the property of Petroleum Development Oman, LLC. Neither the whole nor any part of
this document may be disclosed to others or reproduced, stored in a retrieval system, or transmitted in any
form by any means (electronic, mechanical, reprographic recording or otherwise) without prior written
consent of the owner.
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i Document Authorisation
Authorised For Issue - January 2010
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ii Revision History
The following is a brief summary of the 4 most recent revisions to this document. Details of all
revisions prior to these are held on file by the issuing department.
Revision
No. Date Author Scope / Remarks
0 Jan-10 Robin Norman UOP6 Approved for Issue
Draft Mar-09 Robin Norman UOP6 Issued for Comment
iii Related Business Processes
Code Business Process (EPBM 4.0)
EP.64 Design Construct, Modify and Decommission Facilities
EP.72 Maintain and Assure Facilities Integrity
EP.80 Manage Abandonment
iv Related Corporate Management Frame Work (CMF)
Documents
The related CMF Documents can be retrieved from the CMF Business Control Portal.
CP-114 Maintenance and Integrity Management - CoP
CP-115 Operate Surface Product Flow Assets - CoP
CP-117 Project Engineering - CoP
CP-121 Production Chemistry - CoP
CP-122 Health, Safety and Environment Management System - CoP
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TABLE OF CONTENTS
1 Introduction ............................................................................................................................ 7
1.1 Background ...................................................................................................................... 7
1.2 Objective .......................................................................................................................... 7
1.3 Compliance with Specification ......................................................................................... 7
1.4 Review and Improvement ................................................................................................ 8
2 Scope..................................................................................................................................... 9
3 Information on Mercury and Requirements for Dealing with the Hazard ............................ 10
3.1 Mercury Contamination.................................................................................................. 10
3.2 Effects of Mercury on Humans and Environment .......................................................... 10
3.3 Roles and Responsibilities............................................................................................. 11
3.4 Training and Instruction.................................................................................................. 13
3.5 Personal Protective Equipment Use and Disposal ........................................................ 14
3.6 Mercury Measurement Plan and Report........................................................................ 14
3.7 Mercury Urine Tests (HgU) ............................................................................................ 15
3.7.1 Introduction.............................................................................................................. 15
3.7.2 Considerations for Carrying Out HgU Tests............................................................ 15
3.7.3 HgU Measurement Plans ........................................................................................ 16
3.7.4 Execution of the HgU Measurement Plans ............................................................. 16
3.7.5 Limit Values and Action Values for Mercury in Urine .............................................. 16
4 Developing, Designing and Modifying Facilities and Wells with Mercury Risk.................... 18
4.1 Developing and Designing Wells and Facilities............................................................. 18
4.2 Modification of Existing Facilities ................................................................................... 18
5 Pre-qualifying, Contracting and Employing Vendors for Work with Mercury....................... 19
5.1 Vendors that Carry Out Work at a PDO location ........................................................... 19
5.2 Vendors that Carry Out Work at a Non-PDO Location .................................................. 19
6 Preparing and Carrying Out Activities on Mercury-Contaminated
Installations, Wells and Soil ................................................................................................ 20
6.1 Planning / Preparing the Activities ................................................................................. 20
6.2 Measuring Mercury Vapour and Carrying Out Activities................................................ 20
7 Handling, Packing, Transporting and the Handover of Mercury-Contaminated Substances
............................................................................................................................................ 22
7.1 Handling Mercury-Contaminated Waste........................................................................ 22
7.2 Transport of Mercury-Containing Filters ........................................................................ 22
7.3 Handling Mercury-Contaminated PPE........................................................................... 23
7.4 Handling Mercury-Contaminated Tools and Equipment................................................ 23
7.5 Handling, Packaging, Transporting and the Handover of Mercury-Contaminated Return
Materials......................................................................................................................... 23
7.5.1 Handling and Packaging.......................................................................................... 23
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7.5.2 Readying for Transport and Transporting................................................................24
7.5.3 Handover .................................................................................................................24
Appendix 1 – Mercury Vapour Measurement Record Form .......................................................25
Appendix 2 – Measurement Equipment - Types.........................................................................26
Appendix 3 – Waste Consignment Note .....................................................................................28
Appendix 4 – Reference Material................................................................................................ 30
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1 Introduction
1.1 Background
When natural gas is produced, each reservoir also produces metallic mercury, mercury
compounds such as mercury salts and organic mercury compounds. For clarity of
understanding this shall be referred to as Mercury.
The majority of the mercury will remain behind in the facility after process and therefore
can be released during maintenance and modification activities, whenever the process
equipment and pipework is opened.
Mercury is a poisonous substance and is hazardous to health and the environment.
Requirements with respect to its management are covered in this specification.
The management of the mercury shall cover the whole life cycle (development, design
and modification, operations and execution of maintenance and abandonment) of a
facility. Therefore from concept, through design and operation, and up to and including
abandonment, account must be taken of the presence of mercury.
1.2 Objective
The objective of this specification is to ensure that the risks associated with mercury are
handled in a controlled manner throughout the life cycle of the facilities in which it
occurs.
The specification should be referenced by:
• HSE Specialists to ensure that appropriate procedures are utilised by PDO staff
and contractors when working on equipment that has conveyed or stored
natural gas.
• PDO In-House / Contracted Designers and Engineers to ensure that account is
taken of the occurrence or possible occurrence of mercury in the process
medium during design and construction of new or modifications of existing
facilities
• Delivery Team Leaders and Operations / Maintenance Supervisors when
overseeing activities associated with mercury or preventing the release of
mercury.
• Contract holders responsible for contracting out activities whereby personnel
can come in contact with mercury.
• Personnel involved in activities such as sampling, analysis, cleaning,
maintenance, packaging, treatment, processing, storage, transport and
disposal of installation components, materials and residual substances that are
or may be contaminated with mercury.
1.3 Compliance with Specification
For any deviation from this specification, a written agreement from the PDO Mercury
Specialist shall be obtained prior to performing related engineering work.
Compliance with this specification for modifications or extension work of existing
facilities may not always be possible; in such cases written instructions from PDO shall
be obtained to indicate whether a deviation is acceptable.
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1.4 Review and Improvement
The nominated Gas Directorate Mercury Specialist shall ensure that this specification is
maintained current and reviewed and updated subject to changes and improvements
within the Industry relating to Managing Mercury Risks in PDO oil and gas exploration
and development
Users of the Specification who identify inaccuracy or ambiguity can notify the Mercury
Specialist or a delegate and request changes be initiated.
The Expertise Holder shall ensure review and revalidation of this Specification every
4years.
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2 Scope
The scope of this Specification shall cover the following:
• Information on Mercury and Requirements for Dealing with the Hazard
• Developing, Designing and Modifying Facilities and Wells with Mercury Risk
• Pre-qualifying, Contracting and Employing Vendors for Work with Mercury
• Preparing and Carrying Out Activities on Mercury-Contaminated Installations,
Wells and Soil
• Handling, Packing, Transporting and the Handover of Mercury-Contaminated
Substances
The scope of the Specification listed above shall be reviewed and enlarged as more
experience is gained by PDO in the management of Mercury on-site. It will be the
responsibility of all management and supervisory staff involved in working where there
is a mercury risk, identified or potential, to provide feedback and suggestion as to how
the risks can be more effectively managed.
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3 Information on Mercury and Requirements for Dealing
with the Hazard
3.1 Mercury Contamination
All gas treatment facilities in PDO shall be considered as internally contaminated with
mercury until proven otherwise through mapping and monitoring. Moreover, it is
possible that the soil is contaminated at a number of locations outside of the facilities.
The locations and degree of soil contamination in PDO may or may not be recorded or
identified.
During maintenance, modification, abandonment or cleaning activities carried out on a
gas treatment facility, and the wells, or pipelines connected to it, mercury contamination
must be assumed to be present in all installation components that directly or indirectly
(i.e. condensate and glycol) are in contact or have been in contact with the production
flow in the low pressure system1. These installation components are by definition
suspected of being contaminated with mercury.
Because mercury can collect in cavities that cannot be accessed during cleaning and
because mercury can be absorbed in metal, there is no guarantee that even a cleaned
installation component that has been in contact with the production flow for a long time
is clean. It is always possible that mercury will be released as a result of it being
sweated out of steel and when facility components are dismantled.
Contact with mercury is possible:
• Where leaks occur
• When carrying out activities to or in facilities or equipment that has been
removed from the facility
• When carrying out activities on wells (for instance, workover activities, well
services, production tests and abandonment)
• Excavation activities in contaminated zones
• In storage halls that contain mercury vapour released from scrap metal or
waste
3.2 Effects of Mercury on Humans and Environment
Mercury is toxic to human health and hazardous to the environment. By far the greatest
risk of entry into humans is through inhalation, however organic mercury may be readily
absorbed through the skin and all forms ingested due to poor hygiene.
Effects on humans (and animals) include:
• Failure of the nervous system
• Subtle changes in behaviour or brain function.
• Allergic reactions (tiredness, headache)
1 Experience from PDO Operations in Saih Naihayda has shown that high concentrations of
mercury exist in the Low Temperature Separators due to pressure and temperatiure drops.
Mercury recovery beds in existing facilities are installed downstream of the facilities to reduce
mercury levels to customers. Future gas facility design shall aim to install mercury recovey beds
before the facility to reduce the mercury risk.
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• Reproductive effects; can damage the unborn child
Mercury vapours will readily release from open equipment in large quantities at ambient
temperatures in Oman. Applied heat through activities such as hot work, welding or
grinding in confined spaces may generate concentrations sufficient to render
employees unconscious.
3.3 Roles and Responsibilities
In general, people must not be exposed to mercury and mercury must not be released
into the environment. Responsibility for ensuring this shall be given to the following
roles:
• The Contract Holders of Contractors / Vendors:
o Prior to contracting out activities on (or with) mercury-contaminated
material, agreement is obtained from the PDO Mercury Specialist /
Focal Point regarding supplementary prequalification
o Prior to granting a contract it shall be ensured that that the contractors /
vendors have the experience, competence, resources and methods to
be able to carry out the activities on or with mercury-contaminated
materials.
o Ensure that the contractors are aware of the possible presence of
mercury at their workplace
o Ensure that contractors are aware of the PDO specifications and
procedures for mercury management
o When necessary, include supplementary HSE conditions with respect
to mercury in the contracts
• PDO Logistics Management and Contract Holders:
o Ensure that haulers and drivers are instructed in the risks and the
correct handling of mercury contaminated materials
o Ensure that contractual arrangements are made concerning the
contamination and use of equipment (i.e. trucks and cleaning
equipment) that can become contaminated with mercury. Prevent the
use of contaminated resources on clean locations. This to prevent the
spread of mercury.
• Concept and Design Engineers:
o Ensure that selection and design of new projects or modifications
comply to PDO Specifications with regards to mercury
o Consult with the Expertise Holder / FP Mercury on all matters regarding
mercury safety
• Work Schedulers:
o Ensure that effective scheduling of work where mercury is or could be
present is carried out
o Ensure that all risks are identified and that required HSE precautions
are highlighted in a Job HSE Plan
o Ensure that any work relating to mercury contamination is carried out
by suitable qualified and trained personnel and that all necessary
training and instruction is provided
• Operations Managers
o Have an awareness of all mercury risks with the area
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o Ensure that specification and procedures for management of mercury
are adhered to within the area
• Delivery Team Leaders / Production Coordinators / Maintenance Coordinators
o Ensure that prior to commencing the activities, the employees who can
come in contact with mercury have been informed about the risks of
mercury and the precautions that must be taken
o Ensure that all risks are As Low As Reasonably Practicable (ALARP)
o Check the effectiveness of the control measures in consultation with
the Expertise Holder / FP Mercury
o Ensure all workers who are required to wear respiratory protection for
the control of mercury undergo health surveillance in accordance with
the recommended protocol
o Check that sufficient storage space is available at the designated area
to accommodate the mercury-contaminated materials and waste that
shall be generated.
• Line Supervisors and Permit Holders
o Check that there is: a Permit to Work (PTW), correct Personal
Protective Equipment (PPE), measuring equipment and qualified
(certified) gas and mercury tester, and that the employees have had
the required training and instruction
o Discuss the risks and the protective measures with the employees
concerned in the Toolbox Talk and ensure the Job Safety Plan reflects
and records the details
o Ensure decontamination stations are set up
o Clean tools and equipment on location to restrict the spread of mercury
contamination
• Contractors
Contractors will be adhere to this Specification and PR-1515 – On-Site Mercury
Management Procedure; and any other relevant PDO Code of Practice,
Specification, Procedure and Guideline to enable them to effectively manage
mercury containment during work activities.
Contractors will be responsible for training their staff and sub-contractors to
enable them to comply with this Specification and PR-1515 – On-Site Mercury
Management Procedure and to effectively control exposures to mercury. This
shall include:
o Provision of approved and certified / calibrated metering equipment and
personal dose meters
o Mercury level metering using approved metering equipment
o Collection, sealing / containment, labelling and transportation of
mercury contaminated waste solid and liquid to an approved laydown
area for shipment and disposal
o Provision of the correct PPE and PTW for all workers who will or may
be exposed to mercury during work activities
o Monitoring and recording all activities relating to mercury throughout
the course of the works (including contaminated equipment storage
and transportation) and making the results available to the Asset
Owner and / or delegate for entry in to mercury data base for the Asset
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o Ensuring that discharges to the environment generated in the course of
carrying out their contractual requirements, are managed in
accordance with the requirements of this Specification and reported,
when applicable
o Provision of ‘fit-for-purpose’ procedures for all works carried out and
not already documented by PDO.
Specialist Contract companies, selected by the main contractor (EMC / ODC for
instance), may be used to undertake decontamination or other works
associated with mercury, however they (the specialist contractor) and any
solvents / chemicals used will be approved by PDO in the normal manner.
IMPORTANT NOTE: Currently only Chemicals supplied by ‘No Heat Resources’ have
been approved for use by PDO. For new chemicals a special approval procedure is to
be followed. Contact should be made to the PDO Mercury Specialist or GGO22R for
more details).
3.4 Training and Instruction
Training and risk assessment instruction is essential for all supervisors and personnel
(PDO and Contractor) who shall be required to undertake the work. Instruction and
training should cover the following:
• Hydrocarbon and Mercury measurement – Authorised mercury and gas testers
shall be instructed in the use of detection equipment for mercury vapour. Only
gas testers who have been trained shall be allowed to carry out gas testing in
mercury sensitive environments.
• Management of Mercury – PDO and contract supervisors who shall be involved
in activities with or to mercury-suspected or mercury-contaminated materials
should be instructed the risks and hazards of mercury and the measures to
take to control the risks. It shall be recommended that a refresher course be
repeated at least every 2 years to maintain current awareness.
• Awareness Training - Personnel PDO and contractors, who are to carry out
work in designated mercury risk areas or on systems / equipment that has a
potential mercury risk shall be given Awareness training prior to carrying out
any work. The Awareness Training should be accompanied with a mercury
HSE Permit card.
All training undertaken shall be recorded on the PDO HSE Passport.
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3.5 Personal Protective Equipment Use and Disposal
The working conditions and the results of mercury vapour measurements that are
carried out prior to the activities shall determine the choice of protection equipment.
Mercury can bind to clothing and leather and as a result lead to mercury exposures
through inhalation or skin contact and absorption if re-used. To prevent this occurring,
the clothing and shoes that are worn must be made of a material to which mercury does
not bind. The following materials are suitable: PVC (Polyvinylchloride), PP
(Polypropylene) and PE (Polyethylene), Neoprene (Viton).
Uncleaned boots may only be transported in vapour-tight packaging.
IMPORTANT NOTE: Contaminated clothing must not be taken outside of any
exclusion zones unless packed in sealed containers or strong polythene bags.
The decision on when PPE should be treated as ‘hazardous’ and disposed of in a
controlled manner or whether it is safe to clean as normal will be at the discretion of the
supervisory personnel. Personnel exposed to gaseous contamination, such as might be
the case when breaking a containment flange on a prepared system are unlikely to be
soil their coveralls, whereas personnel performing work in a confined space, where
liquid or sludge containing possible mercury traces, will. Therefore in the latter the PPE
should be removed, monitored and if required disposed of as ‘hazardous’.
Regardless of what the exposure source all personnel will be monitored and all PPE
removed before leaving the containment zone.
3.6 Mercury Measurement Plan and Report
On facilities known to have or suspected of having mercury contamination in the
process streams a map of the facility with known / predicted exposure levels shall be
prepared and maintained. This can be achieved in the following manner:
a. Historical Data - Mapping the mercury contamination during a previous
shutdown or when intrusive maintenance has been undertaken
b. Predictive Data – Obtaining mercury contamination data from a facility that is
operating under similar conditions and using this as a ‘benchmark’ OR using
facility operating parameters and data from the industry to predict possible
contamination levels and ‘hot spots’.
Based on the above a Mercury Measurement Plan shall be initiated. The mercury
measurement plan shall be agreed with the appropriate assets, who shall have the
responsibility of carrying out the measurement. The plan shall describe where, when
and how often the measurements are taken. The Expertise Holder Mercury shall
oversee the drafting of the plan.
The Expertise Holder / FP Mercury must evaluate the measurement plan annually and
report on the results of the measurements. Where necessary, the expertise holder will
initiate actions to supplement or amend the control measures.
Data gathered from the measurement plan should be stored in an easily accessible way
and shall indicate:
• Who is responsible for the data, and
• The period the data refers to
Mercury data shall be stored, preferably at a central location where it is readily
accessible. Essentially all data on toxics i.e. NORM, H2S etc, should be stored together,
the responsibility being handed to one source. Each asset will be responsible to collect
and record the data, and then pass this on to the central source for storing.
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For offplot and well engineering / C&WI activities, high risk wells will be monitored bi-
annually and the results logged. Opportunity inspection and monitoring will be carried
out on tubing strings and casings during workovers to provide data on downhole
conditions.
Additionally all work on wellheads and flowlines in risk areas will be preceded by
monitoring.
NOTE: All currently held mercury data (by Production Chemistry) on wells will be
collated in to the central data base.
The above may necessitate an approved type meter being maintained by the drilling
contractor, EMC / ODC contractor or C&WI with suitably trained personnel to undertake
monitoring activities.
Contractors will be required to supply their own mercury monitors, of a type approved
by PDO. The contractor shall also ensure that the meter(s) are maintained and
calibrated.
Reference should be made to Appendix 2 for types of portable and fixed meters
recommended for use in PDO.
3.7 Mercury Urine Tests (HgU)
Urine testing shall be conducted on personnel considered at risk to mercury
contamination. The test will be conducted under the guidance of the MAF Clinic for
PDO personnel and similarly by the contract companies.
3.7.1 Introduction
Preventative measures shall be employed to prevent personnel carrying out
unnecessary activities associated with mercury. The mercury urine test programme is a
means of checking if the preventative measures are working. The programme is aimed
at determining the amount of mercury absorbed into the body.
The objectives of the test are:
• To determine the concentration of mercury in urine as a parameter for the
exposure to mercury.
• To examine whether the preventive measures are sufficiently effective to limit
the exposure to mercury to the minimum (check of demonstrable control).
• In the event of an increased exposure of an employee, he/she can be removed
from the job as soon as possible. In addition, the cause can be traced and
corrective measures can be taken.
The test should target PDO and Contractor personnel who due to their activities have
an increased risk of exposure to mercury.
NOTE: If a worker is exposed to airborne concentrations of greater then half the
occupational exposure limit, regardless of the controls, he shall undergo biological
monitoring.
3.7.2 Considerations for Carrying Out HgU Tests
The type, nature and duration of the activities carried out are key criteria when making a
selection of personnel who will be asked to take the mercury urine test.
Personnel who are eligible for the test are those who are occupied in:
• The repair, overhaul and maintenance of mercury-contaminated materials
• Cleaning mercury-containing installation components
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• Clearing up mercury
• Cutting, welding and heating mercury-contaminated material
• Working in mercury-contaminated soil
• Work during periodic maintenance on gas treatment facilities where mercury
can be present
• Removing gas filters
The employees must carry out the above-mentioned activities for several consecutive
days to weeks or in a defined period.
NOTE: Experience with HgU tests from Shell Operations in the Netherlands (NAM) has
shown that in certain working situations samples from only a representative group of
personnel is required to obtain the required results.
In view of the extensive experience, in it can be sufficient to only allow a limited number
of representative employees to take the test.
3.7.3 HgU Measurement Plans
If it is considered necessary to carry out HgU tests, an HgU Measurement Plan will be
initiated. The measurement plan includes the following:
• What is the purpose for undertaking the tests
• Why are the tests being carried out
• How are the tests to be carried out - (measurement strategy, at what times
will samples be collected, who are the participants)
• How will the results be circulated
• Who is requesting the information
• Who will approve the test being undertaken
3.7.4 Execution of the HgU Measurement Plans
The HgU test for PDO employees shall be coordinated through PDO clinics
(interior/coastal). The HgU test for contractor personnel shall be coordinated through
the interior PAC clinics.
3.7.5 Limit Values and Action Values for Mercury in Urine
The Table indicates what actions must be started at what measurement values.
Value HgU in µg / g
creatinine Action
Normal value < 35 • None
Slight increase 36 – 75 • Further investigation into the conditions that
caused the increase and take corrective
measures
• Repeat the HgU test + visit to company doctor
• Measure the NAG (N-Acetyl-Glucosamidase)
enzyme. Check early effects.
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Value HgU in µg / g
creatinine Action
Increase > 75 • Further investigation into the conditions that
caused the increase and take corrective
measures
• Repeat the HgU test + visit to company doctor
• Measure the NAG (N-Acetyl-Glucosamidase)
enzyme. Check early effects.
• The employee concerned will no longer be
employed in activities that pose an increased
risk of mercury exposure until the HgU content
has dropped below the normal value
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4 Developing, Designing and Modifying Facilities and Wells
with Mercury Risk
4.1 Developing and Designing Wells and Facilities
The Concept Engineers shall consider in the design:
• Presence of mercury
• Measures that require to be taken to preventing the release of mercury and
manage any mercury in a safe manner.
• Technical measures to control the risks resulting from mercury to ALARA
• Minimising the creation of mercury-containing waste
• Involvement and input from specialists with knowledge of mercury in the
Operational, Maintenance and Waste disposal fields.
• Inclusion in design of mercury recovery units upstream of new facilities to
prevent / reduce excessive mercury contamination.
For newly to be built gas treatment plants the following criteria apply:
Process Phase Criteria Comment
Mercury vapour in
sales gas Export to SUR 5 ppb Measured ex PDO locations and
inlet SUR
Mercury in
condensate No export limits in PDO
contracts Practical limit to make export to
all locations possible ca 10-15
ppb.
NOTE: Unwritten limit for
refineries is 50 ppb due to
sensitivity on catalyst
Mercury in sour gas
condensate Export 5 ppb , less of an
issue due to HgS
formation as a solid
Normally less of a problem
Emissions to air Local environmental law Varies country to country
Emissions to the soil 150 mg/Kg RE-USE OF SLUDGE IN
AGRICULTURE -CONDITIONSFOR
APPLICATION TO LAND MD145/93
Emissions to water 0.001 mg/L MD145/93
4.2 Modification of Existing Facilities
When designing modifications to installations, the ALARP principle is followed for
controlling the risks associated with the presence of mercury.
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5 Pre-qualifying, Contracting and Employing Vendors for
Work with Mercury
5.1 Vendors that Carry Out Work at a PDO location
Vendors that carry out work on (or with) suspected mercury-contaminated material at
PDO locations, must satisfy this PDO specification by having developed mercury safe
systems of work.. The safe system of work guarantee controlled execution of the
activities. Contracts with Vendors must include the fact that the PDO specification and
associated procedures concerning management of mercury apply.
5.2 Vendors that Carry Out Work at a Non-PDO Location
Vendors that carry out work on mercury-contaminated materials in a workshop at a
non-PDO location will be required to reference to this Specification and PR-1515 – On-
site Mercury Management. Additionally their employees should be instructed in the
dangers and protection from mercury exposure and be audited by PDO as to their
‘fitness’ to undertake work on equipment that is or could be contaminated by mercury.
The audit will take place concurrently and be in accordance with the regular
qualification.
NOTE: For additional prequalification, the contract holders must contact the Expertise
Holder Mercury.
During the prequalification the following aspects are examined:
• Safe systems of working with mercury.
• occupational health and safety risk inventory and evaluation (for the tasks to be
carried out),
• environmental permits (for the workshop),
• competencies (training),
• facilities and
• means and methods
The capacities of the Vendors shall be recorded.
During the selection, account is taken of the nature and scope of the activities to be
carried out. Based on this it is determined whether the Vendor must satisfy the basic or
other supplementary2 conditions.
If an unknown Vendor is concerned or if there is any other doubt, these aspects must
be verified at the workshop of the Vendor in question.
2 Supplementary conditions apply if activities with an additional risk, such as heating, welding,
annealing and machining, are concerned
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6 Preparing and Carrying Out Activities on Mercury-
Contaminated Installations, Wells and Soil
6.1 Planning / Preparing the Activities
• Planning / preparation are essential when carrying out activities where mercury
is possibly present. The following requirements must be satisfied:
o Take an inventory and cover the risks resulting from the (possible)
presence of mercury
o Check whether personnel involved are competent and have been
adequate work instructions (safe methods of work) to carry out the
work
o Personal hygiene is adhered to
o Be alert to temperature increases or actions that will increase the
temperature such as cutting and welding
• Based on the risk analysis that has been made, determine the measures that
must be taken when the measurement value exceeds the action value. For
example:
o Employing a dedicated supervisor
o Setting up clean and contaminated areas or making provisions for them
to be set up
o Selecting the correct personal protection equipment and making it
available to all personnel that require it
o Using extraction (if required with a filter)
o Making provisions for the collection of mercury and other waste
materials (in case of insufficient knowledge, MSE2 corporate
environment).
o Positioning plastic leak trays that are partially filled with water to collect
the released mercury.
NOTE: The water prevents mercury vapour occurring and the spread of
mercury.
o Using plastic covers around and under equipment to contain spillage
and prevent soil contamination
6.2 Measuring Mercury Vapour and Carrying Out Activities
Prior to and when working on mercury-suspected facilities, soils or return materials or
confined areas, mercury vapour measurements must be taken to determine the
presence of mercury vapour using a calibrated portable Jerome J405 mercury Analyser
Requirements with respect to mercury vapour measurements are:
• Measurements must be carried out by approved gas testers (qualified to carry
out mercury vapour testing).
• Measurements shall be carried out using a Jerome 405 or Jerome 431-X
mercury vapour monitor
• The measuring tools shall be calibrated annually by an approved vendor and be
to at a minimum the manufacturer values guaranteed at delivery
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• Measurement shall be taken in the expected breathing zone. The results of
these measurements will determine whether to work with or without PPE. If
during the measurement in the breathing zone a value is found that exceeds
the action value, protective measures must be taken in accordance with
recommendations from the Expertise Holder Mercury and / or MSE.
NOTE: Internal measurements in dismantled equipment only give an indication of the
cleanliness of the equipment concerned. This measurement shall not be used for
determining whether the equipment is contaminated with mercury.
The frequency of the measurements shall require to be continually reviewed. This is
because the result of the measurements depends heavily on the circumstances (wind,
temperature, nature of the activities).
Mercury vapour must always be measured:
• When opening installation components
• When maintenance, welding and cutting activities are carried out on installation
components that are, or are suspected of being, contaminated with mercury
• When entering confined areas
• If there is any uncertainty
• When the working conditions changes (for instance after a break or in case of a
temperature rise).
The number of times that measurements must be taken depends strongly on the
circumstances. The following measurement strategy is recommended:
• The first measurement before work begins (the reference measurement,
measurement of the background value)
• Second measurement when exposure occurs.
If result < 50% of the Occupational Exposure Limit (OEL) value: repeat
measurement if required
If result ≥ 50% of the Occupational Exposure Limit (OEL) value: take
required control measures, repeat the measurements
• Carry out additional measurements if there are major changes in climatic
conditions.
• In case of doubt, always take additional measurements.
• Measurement results must be recorded on the Mercury Vapour Measurement
Record Form (see Appendix 1). The measurement form will be kept with the
PTW and the results entered in to the Mercury Database.
• If values are found that exceed the action value, the measures that were
anticipated in the preparatory phase must be taken.
It is recommended that additional measurements are taken in warehouses, work areas
and control, canteen and changing rooms. Areas concerned are those where due to a
lack of personal hygiene or otherwise (for instance the storage of contaminated return
material or contaminated equipment or waste) mercury vapour can be present.
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7 Handling, Packing, Transporting and the Handover of
Mercury-Contaminated Substances
Reference shall be made to SP-1009 - HSE Specification - Waste Management for
details of Waste Management.
7.1 Handling Mercury-Contaminated Waste
NOTE: Spent mercury absorbent (Chemicals) is waste, but will be recycled in Europe.
All of the materials that require disposal and that have been in contact with the
production process must be sampled for the presence of mercury.
Mercury-contaminated waste and waste that is not contaminated with mercury must be
kept separately. Liquids and sludge’s must be sampled and analysed in the QA
laboratory using the Nippon Analyser before being stored at the waste site. This will
enable comparison to the environmental limits for safe disposal.
NOTE: Sludge contaminated with mercury is one of the most expensive categories of
waste (several thousand Euros per tonne).
Materials contaminated with Mercury shall be placed in thick gauge, impervious, double
plastic bags, labelled and stored in a designated area within a waste management
facility. All work for dismantling, packing, removal, transport and disposal must only be
undertaken by a licensed hazardous waste contractor.
Labelling, packaging and readying for transport of waste must occur in accordance with
the SAP Workorder instruction.
A container that is used to transport mercury-containing scrap must be visually
inspected for the presence of metallic mercury. If required, an additional mercury
vapour measurement is carried out. If mercury is found, the container must be cleaned
in the same way as contaminated equipment (see Subsection 7.3).
PDO only owns mercury-containing waste arising from PDO locations. Mercury-
containing waste coming from PDO property, but that is released at a non-PDO
location, is the property of the contractor concerned and must be processed by the
contractor concerned.
NOTE: When dismantling facilities and after cleaning an inventory is made on site of the
mercury-contaminated scrap using representative sampling. In order to correctly
harmonise the activities, the production chemistry must be contacted and informed in
the planning stage of the dismantling operation.
Transportation of Mercury Contaminated Waste shall be carried out by a ‘Licensed
Hazardous Waste Transporter who has the appropriate Permit from the Ministry of
Environment and Climate Affairs (MERCA) to transport such waste and accompanied
by a Waste Consignment Note (see Appendix 3). The Waste consignment Note shall
be raised by the Waste Originator / Generator for each load transported. The Waste
Consignment Note shall be signed when the waste is received at the waste
management facility and a signed copy shall be returned and retained to / by the Waste
Originator / Generator as a record of safe arrival.
IMPORTANT NOTE: The Waste Consignment Note is not to be used for the
transportation of Mercury-Contaminated Return Materials.
7.2 Transport of Mercury-Containing Filters
Filters that contain mercury should be considered and handled as being ’hazardous’.
Filters must be packed in the liquid-tight containers intended for this purpose
Refer to Transportation of Mercury Contaminated Waste in Section 7.1.
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7.3 Handling Mercury-Contaminated PPE
Contaminated PPE that is intended for one-time use will be disposed of as mercury-
contaminated waste:
• Gloves and clothing are put in special containers and disposed of.
• Used filter containers must be sealed and disposed of as being mercury-
contaminated waste.
The PPE that is to be cleaned is treated as follows:
• Filter masks are packed in their holders or in sealable plastic drums or thick-
wall foil bags
• Viton suits are rinsed in a chemical / water solution dried and stored for re-use.
• Boots must be cleaned when leaving the contaminated area. They can be
rinsed off with chemical / water solution, dried and stored for re-use.
Liquid waste from the rinsing exercise shall be collected and shipped in a sealed
container to the waste site at QA where it shall be tested for contamination and
disposed of in the approved manner.
7.4 Handling Mercury-Contaminated Tools and Equipment
Dry cloth is used as much as possible to clean tools and equipment that have been
used in a contaminated environment.
Dispose of used cloths as being mercury-contaminated waste.
If cleaning must be done by hosing down, the rules applying to return materials must be
followed.
All hosing down shall be conducted in a controlled manner into plastic lined
sumps/collection points. It shall not go to ground.
7.5 Handling, Packaging, Transporting and the Handover of Mercury-
Contaminated Return Materials
For the purpose of this Specification Mercury-Contaminated Return Materials shall be
defined as:
“Material that have been in contact with a known mercury contaminated source, and
that can not be effectively decontaminated on site. Such equipment may be valve
assemblies, instrument transmitters that have been connected to the contaminated
medium, pumping units used for flushing / circulating etc. All such equipment shall be
monitored for contamination prior to transport and levels recorded”.
7.5.1 Handling and Packaging
During handling and packaging of mercury the following shall apply:
• Take precautions (see work preparation/planning) to collect any spills during
disassembly
• Clean return materials immediately after they become available on site. To
prevent the formation of mist due to hosing down, dry cleaning is preferred
(polish)
• If it is necessary to clean goods by hosing down, precautions must be taken for
both man and the environment. The measures must be aimed at preventing soil
pollution (using leak trays and slabs) and protecting the personnel (consider the
wind direction). Rinsing water must be treated as mercury-contaminated waste
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• Be aware that goods remain suspected of being contaminated with mercury
even after cleaning
• Measuring mercury in equipment such as valves and pipes gives no information
about the mercury concentrations that an employee is exposed to. The
measurement results only give an indication of the degree of internal
contamination of the equipment or pipe involved. These measurements do not
give any information about the possible degree to which employees are
exposed to mercury vapour
• Whether or not to take preventive measures depends on the result of the
measurements taken in the breathing zone to be expected for the activities. If
the value of this mercury vapour measurement is above the occupational
exposure limit of 0.025 mg/m3, measures must be taken
• If a value greater that the action value is measured in the breathing zone of a
piece of return material that is to be shipped, the material is contaminated with
mercury. In this case, the breathing zone is meant to mean a distance of 0.30
m around the equipment concerned. If a value less than the action value is
measured, the material is (remains) suspected of containing mercury
• Measurements taken in the equipment are useful to determine whether the
cleaning has had any effect
• After the material has been cleaned as well as possible, all openings must be
sealed. Preferably using gaskets and flanges
• An approved PDO equipment label must be attached to every piece of return
material. The label shows whether the return material is not mercury
contaminated, suspected of being mercury contaminated or mercury
contaminated
• If measurement values are reported, the conditions under which the
measurements were taken (temperature, presence of wind, sunlight) must also
be given.
• Large pieces of equipment can, after the openings have been sealed, be
transported without packaging.
• Small pieces of equipment will be packed in vapour tight strong foil (PE) and
placed in crates or sealable drums before being transported.
7.5.2 Readying for Transport and Transporting
Mercury-contaminated return materials are classed as ‘Hazardous’ cargo.
7.5.3 Handover
To ensure that the receivers of the mercury-suspected or mercury-contaminated return
materials are aware of the possible presence of mercury, mercury-contaminated
materials or mercury-suspected return materials must be formally handed over to the
receivers. Receivers of these materials must sign the transport documents for formal
acceptance.
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Appendix 1 – Mercury Vapour Measurement Record Form
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Appendix 2 – Measurement Equipment - Types
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Appendix 3 – Waste Consignment Note
WASTE CONSIGNMENT NOTE Number:
(Separate Waste Consignment Notes are required for Hazardous and Non- Hazardous Wastes)
Section A: WASTE DETAILS
1. Please tick (4) box below to indicate the type of waste you are transferring
NON-HAZARDOUS WASTE TYPE
Domestic Waste (kitchen refuse)
Non-Hazardous Chemical Waste
Domestic waste (tree cuttings)
Metal Drums
Office waste
Plastic Drums
Waste wood materials
Construction debris
If other, please describe waste accurately here
HAZARDOUS WASTE TYPE
Oily sand / soil
Hazardous chemicals waste
Hazardous Laboratory Chemicals
Tyres (used)
Oily sludge
Sewage sludge
Mercury-contaminated waste
Other
Waste Lubricants
Batteries
NORM waste
Asbestos
Pigging sludge
Clinical waste
OBM & or OBM Cuttings
Empty Drums contaminated
with hazardous oil/chemicals
If other, please describe waste and physical state (solid, liquid or a combination) accurately here
_____________________________________________________________________________________________________________
2. Quantity:
3. Additional Information - Please provide any relevant information e.g. type of premises waste comes from, full analysis, process that
produced the waste, including details of any problems your waste may present during the handling, containment, transportation,
treatment or disposal by any subsequent holder:
Section B1: WASTE ORGINATOR (Asset )
1. PDO Asset (Marmul, Nimr, Qarn Alam, Bahja-Rima, Yibal, Fahud-Lekhwair, Gas, Well Engineering, Infrastructure,
Exploration, MAF Terminal , other) Please tick one (4)
2. Location source of waste Destination:
Return white copy to Originator by a) Fax/Fax No b) Mail c) Driver d) Monthly Waste Returns
3. The waste has been verified as being unsuitable for reuse/recycling Yes No
4. Signature ( Waste Originator) Date:
5. Full Name (Please print)
* I, the undersigned confirm that the waste material declared above has no value and therefore can be disposed off.
Full Name _________________________ Signature ____________________ Ref Ind: __________ Date: _____________
* Supervisor level
Section C: WASTE TRANSPORTER
1. Company Name: _________________________________________________________________________
2. Signature of Driver: _________________________________________ Date: _________________________________
3. Full name of Driver (Please print):
Section D: WASTE DISPOSAL FACILITY
1. Facility Location/Site:
2. Date & time waste received:
3. Name of Waste Disposal Site Operator:
4. Signature of Waste Disposal Site Operator
Distribution: Yellow Copy: Originator Blue Copy: Disposal Site White Copy : Waste Contractor Return to Originator
(MESC Number 93.55.81.500.9)
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Waste Consignment Note: EXPLANATORY NOTES
(to be printed at the back page of the Waste Consignment Note)
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Instructions to: Waste Generator, Vehicle
Driver & Waste Disposal Operator
1. Waste Generator fills Section A & B, retains
Yellow Copy and gives the White & Blue
Copies to the
Vehicle Driver
2. Vehicle Driver signs Section C, gives the
White and Blue Copies to Waste Disposal
Operator.
3. Waste Disposal Operator signs Section D,
gives the White Copy back to Waste
Contractor
4. Waste Contractor gives the White Copy to
the Waste Generator by either Fax, Mail or
Driver
Yellow Copy
( To be retained by
Waste Disposal Operator )
Section A: Waste details
6. Waste Disposal Operator retains Blue Copy
• Filled out by Waste Generator
Section B: Waste Originator
• Filled out by Waste Generator
Section C: Waste
• Signed by Vehicle driver
Section D: Waste Disposal Facility
• Signed by Waste Disposal
Blue Copy
Blue Copy
( To be carried by vehicle driver
and to return signed blue copy
Waste Generator )
Section A: Waste details
• Filled out by Waste Generator
Section B: Waste Originator
• Filled out by Waste Generator
Section C: Waste
• Signed by Vehicle driver
Section D: Waste Disposal Facility
• Signed by Waste Disposal
Yellow Copy
White Copy
( To be completed & handed to
driver with blue copy for delivery
to waste operator)
Section A: Waste details
• Waste Generator fills out
Section B: Waste Generator
• Waste Generator fills out
Section C: Waste
• no action
Section D: Waste Disposal Facility
• no action
White Copy
Yellow Copy
( To be retained by
Waste Disposal Operator )
Section A: Waste details
• Filled out by Waste Generator
Section B: Waste Originator
• Filled out by Waste Generator
Section C: Waste Transporter
• Signed by Vehicle driver
Section D: Waste Disposal Facility
• Signed by Waste Disposal Operator
Blue Copy
Yellow Copy
( To be retained by
Waste originator)
Section A: Waste details
• Filled out by Waste Generator
Section B: Waste Originator
• Filled out by Waste Generator
Section C: Waste Transporter
• Signed by Vehicle driver
Section D: Waste Disposal Facility
• Signed by Waste Disposal Operator
Yellow Copy
Blue Copy
( To be retained by
Waste Disposal Operator )
Section A: Waste details
• Filled out by Waste Generator
Section B: Waste Originator
• Filled out by Waste Generator
Section C: Waste Transporter
• Signed by Vehicle driver
Section D: Waste Disposal Facility
• Signed by Waste Disposal Operator
Blue Copy
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Appendix 4 – Reference Material
PDO Related Documents
The following PDO procedures have interface with this specification.
PR-1000 - Operations Handover Procedure
PR-1001x - Operations Variance and Change Management
PR-1073 - Gas Freeing, Purging & Leak Testing of Process Equipment (Excluding Tanks)
PR-1074 - Flowline Flushing Procedure
PR-1076 - Isolation of Process Equipment Procedure
PR-1077 - Preparation of Static Equipment for Internal Maintenance and Inspection
PR-1079 - Gas Freeing and Purging of Tanks Procedure
PR-1080 - Well Testing, Scheduling, Sampling and Validation
PR-1084 - Oil Spills Clean Up and Ground Restoration Procedure
PR-1096 - Sampling of Oilfield Liquids and Gases Procedure
PR-1148 - Entry into a Confined Space Procedure
PR-1154 - Gas Testing Procedure
PR-1515 - Onsite Mercury Management Procedure
SP-1009 - HSE Specification - Waste Management
International Documents
These documents may provide useful reference on the subject of Mercury Management.
Specialist Mercury Waste Disposal Companies (Worldwide)
UNEP Guidance, Training Materials and Toolkits Relevant to Mercury
UNEP Toolkit For Identification and Quantification of Mercury Releases
Guide for Reducing Major Uses and Releases of Mercury
Standard Test Method for total Mercury in Water – ASTM D-3223-02 (reapproved 2007)

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