TL: SHELL OPERATIONS IN TURKEY SO: Greenpeace Communications, Greenpeace International (GP) DT: March 21, 1996 Keywords: environment oil energy shell transnationals / Greenpeace International March 1996 This briefing illustrates many of the environmental and safety aspects of Shell's general operations in Turkey. The extracts and summaries are taken from the following two documents: 1. "Technical Safety Audit, N.V. Turkse Shell, Production Diyarbakir. Dated Sept 1991 Report EP 91-1810 2. "Exploration and Production Programme Support 1995" June 1994. Document 1 shows that in 1991 there were many concerns about the environmental and safety aspects of the operations and the difficulties which were being experienced. The report highlights a number of issues which should be acted upon and raises the point that the "present standard of operation may be understandable, ... but it is unacceptable in a Shell company. Operations which cannot achieve the required minimum standard should be closed down or disposed of." Futhermore it is noted that if is not possible for the company to "establish control of its operation" then it "should reconsider whether it wishes to continue as the operator". The following Action (s21 3.1 (a)) is identified: "Set a time limit for the achievement of aceptable minimum standards of operation, and contract out or dispose of the operation if the targets are not achieved Document 2 (1994) is clearly an update on the recommendations made in document 1 and identifies some of the current environmental problems, which include land contamination and the continued mixing of fuels despite acknowledged air pollution problems. These are in addition to the water injection and dam contamination. It is clear the situation had not improved substantially by the time this report was produced. Subsequently, NV Turkse Shell was sold off to Perenco in 1995. 1. "Technical Safety Audit, N.V. Turkse Shell, Production Diyarbakir. Dated Sept 1991 Report EP 91-1810 The summary of this report notes: "Industrial and community relations have been a major weakness from the start with considerable pressure on NVTS for excessive payments for pollution and access. The result has been that communications between management and operatives are ineffective and management cannot control the safety of the work site or set the standard for the operation. This has been recognised and the field manager is devoting himself full time to the equitable resolution of land claims within an improved long term framework. One of the objectives of this audit has been to identify actions that would help NVTS in its present drive to re- establish control. Other recommendations assume that the company is able to establish control of its operation, if this is not possible the company should reconsider whether it wishes to continue as the operator. Since the management controls to ensure safety at the work site are not effective the overall rating is: UNSATISFACTORY." It is possible that this could be the first indication that Shell might be considering getting out of its operations in Turkey. Indeed under Section 3: paragraph 3.1 (page 9) it is noted that: "The manpower burden is itself intolerable, but NVTS has also been unable to raise the standard of operation and safety to an appropriate level. Housekeeping is inadequate unless it is contracted out through the landowner (other contractors cannot get access), the quality of technical work is inadequate and operating procedures such as work permits, limiting access to facilities or restricting smoking to safe areas are not properly enforced. Without the freedom to apply know-how to make the operation more efficient or the discipline to achieve safe standards there seems to be little benefit in Shell remaining as the operator, and other possibilities, such as acting as Technical Adviser but contracting out the operation, should be explored if the situation cannot be significantly improved. The present standard of operation may be understandable, as a result of a long history of concessions, but it is unacceptable in a Shell company. Operations which cannot achieve the required minimum standard should be closed down or disposed of." The main findings of the report can be found in the summary from pages 2 to 5; these are as follows: "The facilities are relatively simple and have been operating over 25 years in much the same configuration with very little turn over at junior staff level." "The local communities' influence on elected officials often outweighs the company's." "There has been a rapidly increasing number of land claims for pollution damage, some of it caused by leaks due to age and design of the equipment, but some of it also caused by community damage to the equipment either in the course of stealing crude or in order to create a pollution incident for which a cash claim can be made." " well performance monitoring is improving, though there are still a considerable number if the 192 wells which have not been tested, in spite of the recommendations of a 1986 review of field measurement. The main recommendation, to provide test lines for the 60% of the wells which cannot be tested except by using the Mobile Test Unit (MTU), has been repeatedly postponed. Even operated flat out the MTU takes two years to complete a testing cycle of all wells, though a second MTU is planned." "Management commitment to safety is good at the senior level in Diyarbakir, but duty rosters have prevented some field staff from being involved in management visits. The commitment has not yet penetrated the middle of the organisation, where safety and the environment is subordinate to production" "Production water (and sludge from tank cleaning) is still dumped through disposal wells into the shallow potable water aquifer. A specialist has been recruited to evaluate the long term environmental impact; legislation is pending that will affect the present water disposal system." "Oil saver pits in the block stations are ineffective, with both streams being returned to the incoming crude lines. The oil saver pit in the BOTAS terminal at Pirinclick is also ineffective with heavily contaminated tank drainings being disposed of to an evaporation pit. The crude dehydration tanks in the block stations are still operating with open hatches releasing vapour to atmosphere and mixing oxygen inside the tank, since manual gauging is still the norm. Level gauges being installed are not yet operational." "The recent development of mixing crude with diesel fuel to reduce operating costs appears to be a partial technical success but the sulphur and soot from the exhaust are creating environmental problems and are blamed for health problems. The project is under review to decide whether to continue it." "There is a good company safety programme but it has not reached down to the bottom of the organisation. Safety plans and objectives do not exist in the lower levels of the organisation." "Housekeeping varies with the number of contractors brought in to clean the facilities since none of the operators see it as part of their responsibility to keep their station clean. In general the surface drains are a continuous fire risk because of the sand and oil mixture they often contain." The main report goes into much more detail on the issues raised above. For example, on the issue of mixing diesel fuel with crude, under section 4.5.1 Operating procedures/manuals (Page 25) the report states: "The pollution by exhaust smoke from the 50/50 (crude/diesel) fuel project has had the unfortunate effect of causing staff to question the company's real concern for staff welfare and their commitment to safety and a healthy environment. The conversion project is under review but the workforce have not been kept informed." And in section 5.1.1. (page 52): "Conversion of the fuel from diesel to 50/50% blended crude/diesel in Kurkan block station has created a serious air pollution problem, asphaltines generating soot and the sulphur affecting breathing under the frequent weather conditions that allow the exhaust plumes to fall back to the ground. The original test with the blended fuel considered the effects on engine maintenance and output, but apparently did not consider the environmental impact." Under Safety Management, standards and procedures (page 24) it is noted that: " There is no procedure for hazardous area classification and there is little awareness of its importance in operations." On hydrogen sulphide (H2S) gas protection equipment (page 32) it states: "It was not possible to test the area for H2S at the time because there is only one Draeger test kit in NVTS and this was kept in the main office." Section 5, page 51, of the report deals with Process Hazards and Loss Control and under paragraph 5.1.1, environmental planning and control (page 53) it is noted that there has been a rapid increase in the number or oil spills. However, part of this is reported as a result of more stringent reporting and, although it reports sabotage as a cause of spills had almost doubled. it points out that: "the other causes account for the greater proportion of the increase. The graph showing the analysis of the non- sabotage causes, shows corrosion to be increasing, expecially if "weather" failures, frozen pipe splitting, are included as partly attributable to corrosion." A further paragraph in section 5 details the following Action 5.1.9.1.(a): "Stop disposal of production water into the potable aquifer as soon as possible as recommended by 1989 environmental audit." Other memos demonstrate that this pratice was noted as unacceptable as early as 1986 (see briefing on the systematic pollution of an aquifer), but it is clear that in 1991 it was ongoing. 2. "Exploration and Production Programme Support 1995" June 1994. This report deals with many of the problems identified in the previous document. For example under section 3.3, Technical Highlights, paragraph 2 page 12, it is noted that: "A total of 218 oil spills were reported in 1993, down from 290 in 1992. This represents a total of 2360 tonnes gross spillage and 1,171 tonnes net oil. A total of 380 tonnes gross volume was recovered." And that: "A major in-situ cleanup (land farming) scheme was commenced in 1993 and 10 locations have undergone clean- up with successful results. A total of 463,000 m2 was land farmed in-situ and a volume of 3500 m3 of untreated soil was removed for landfill to disposal locations." Under the heading Current Situation (section 8.6) on page 50 land payments are discussed (these are compensation payments for land aquired or damaged by the operations). "Some 1300 land damage cases are recorded annually" but it is noted that: "Minimising land acquisition and land damage payments remains a primary objective of the Department. Progress was made in 1992 and 1993 in reducing the overall level of payment, and plans are in place to reduce these payments even further in the future years. Efforts are also being made to improve relations with land owners to avoid interruptions to operations which are caused by disputes." And there are plans to reduce the total land payments from the 1993 level of US$ 1,282,000 to US$ 800,000 in 1994 and further reductions are planned to US$ 500,000 by 1997 (page 52). Despite the concerns expressed in the 1991 audit report about the environment and health aspects of mxing crude and diesel fuel oil, this report states that further moves to mix crude with diesel are planned, since "the use of diesel fuel is expensive and problematic the use of crude or fuel oil is being studied." Under the section dealing with environment (13.4, page 87) it is noted that: "There is growing interest by the Turkish authorities in environmental issues, with relatively stringent legislation being enacted, and a new draft law introduced which will replace the existing law when officially published" This increased interest provides Shell with the concerns outlined in the subsequent paragraph: "The main concerns for NVTS for the programme period are produced water injection, land farming, Environmental Impact Assessments (EIA) studies, oil spillages, waste management, abandonment and clean up of oil contamination." Operational and environmenal standards for these concerns have been established in Europe for years and clearly, Shell has to operate to these standards in other European countries. However, the year after the production of this report Shell has sold off the operation to Perenco who now has responsibility for the standards of operations. ENDS