TL: POLLUTION OF TURKEY AQUIFER BY SHELL - REPORT TL: POLLUTION OF TURKEY AQUIFER BY SHELL - REPORT SO: GREENPEACE COMMUNICATIONS, Greenpeace International (GP) DT: March 15, 1996 Keywords: environment oil energy shell transnationals turkey europe / MAIN REPORT GREENPEACE INTERNATIONAL March 15 1996 THE SYSTEMATIC POLLUTION OF AN AQUIFER The following report demonstrates that Shell have been injecting production water into the Midyat aquifer, which is a potable water supply. The documents acknowledge that this is unacceptable and is against European regulations and practice. Furthermore, the solution was to inject the water into the Mardin oil reservoir, where the water came from, but the funding for this was cancelled. 1. The problem is acknowledged in 1986 and the relevant legislation identified. A memo signed by C.E. Fay, and dated 04/09/86 from "GM to Mep" [1] states: "Further to the initial water study tests, which gave an indication that there may be several hundred bbls. of crude being injected per day... you are requested to provide the following: ... What additional measures are needed to reduce current pollution threat and also to enhance our production level by reducing the "loss" of oil". [1: C.E. Fay is assumed to be Dr Christopher Fay, currently Chairman and Chief Executive of Shell UK. GM is assumed to be General Manager; Mep is believed to be Manager Exploration and Production.] A response to "GM", signed by Recep Aksulu, Head of Production, dated 23/9/86 states: "We are quite confident that under normal operating conditions the oil content in the disposal water is less than 500ppm. We hope that the recent sampling analysis will confirm this figure. If we go this maximum figure and assume that the total field drain is 80000 bbls/day then the loss of crude oil with the disposed water is about 40 bbls/day maximum. I should emphasize again this figure is quite pessimistic for normal operations and believe as an average it is under 20 bbls/day." A memo on the analysis of samples is signed by A.K. Lucas and dated 23/1/87 from "PET to CPE (MEP)" states: "As may be seen from the figures, correlation and consistency are poor. In terms of total oil, these data would suggest 15-35 bbls/d were being lost into disposal wells at that time. The economic incentive for improving water quality is therefore not great based on these figures." This memo also refers to the legislation: "EEC regulations are clear: "In EC countries it is not allowed to discharge dehydration water to shallow aquifers, to avoid any risk of contamination of sources of drinking/irrigation water" (ref. HAG 10819003 of 19.1.87). Turkish law is less definitive, although Art.8, section 3 of the Environment Law (no.2872) does not specifically cover pollution prohibition. Quote "it is prohibited to discharge, store, transport and dispose pollutants and residues to the receiving environment in a manner harmful to the environment directly or indirectly against standards and methods stipulated in regulations. In cases where there is a probability of pollution, those concerned are obliged to prevent pollution..." Unquote. The regulations referred to have not yet been promulgated." Then a reply to this, dated 26/1/87 from GM and signed simply CF. [2] states: "I have read PET's note with interest. It should be made quite clear that we need to take the utmost care to ensure that economics alone do not detract us from ensuring that all steps have been taken to safeguard the environment. The phrasing of "no economic incentive" and "unless (all) dehydration water could be (cheaply) disposed of" are most unfortunate. Please ensure that increasing efforts are made to resolve what is clearly a problem at this time." [2: It is assumed that CF. is Christopher Fay.] 2. The Turkish Authorities tell Shell to stop injecting into the aquifer. In a letter from GDPA (Turkey's General Directorate of Petroleum Affairs) signed for the General Director by Hasan Oktay, Deputy General Director and dated 18/11/91, No 10-15/8555, which is translated and sent to "MEP, DOM, DSE, HSSE", it is stated: "Disposal waters produced by your company from oil in districts X and XI are being injec[ted] into the Midyat Formation. Such action will inevitably create dangers, considering pollution and environmental sanitation, over the Midyat Formation which is an important fresh water aquifer in [the] area, and is taken up within the scope of wasteful and hazardous action according to the Petrole[um] Law" "We are informed through the reports entitled "Hydrogeological Survey of the Mar[din] Formation" sent to GDPA that your company is making certain efforts to have the produced dispo[sal] water injected into the Mardin Formation instead of Midyat, the former being located [at a] deeper level, and that you have a company carrying out a research for that matter". "In order to stop contamination in the Midyat aquifer you are emphatically requested to ens[ure] that henceforth the necessary measures are urgently taken to have the disposal waters injected in[to] the Mardin Formation through the wells that have ceased production, making sure that dispo[sal] waters are not injected into the Midyat Formation, and to inform GDPA about the matter." [] - indicate where the edge of the letter has not copied the end of certain words fully. 3. Drilling muds have also been lost into the porous rock around the aquifer. In addition to production water being injected into the Midyat aquifer, further documents reveal that drilling muds, used in the oil drilling, have been lost into the gravel (called Selmo) which is the geological formation covering to the aquifer. A letter, dated 18/10/1988 signed by C.G. Finlayson, Chief Petroleum Engineer, from N. V. Turkse Shell to Shell International headquarters in the Netherlands provides information about the Midyat Aquifer and geology. It states that there are difficulties with the sampling of injection water and that of the aquifer. Furthermore, reference is made to the drilling mud [3] used when drilling through the aquifer: "While drilling through the Midyat Fm. [4] total loss of mud returns is commonly experienced". [3: drilling muds contain a range of toxic chemicals. The letter indicates that drilling muds have been lost into the porous rock formation which covers the aquifer. Depending on how long this has been ongoing, it is possible that 1000's of tonnes of drilling muds could have been deposited in the aquifer]. [4: Fm is short-hand for formation.] 4. The Selmo Formation could also be contaminated by production water leaking from corroded disposal wells. In order to reach the Midyat aquifer it is necessary to drill through the Selmo Formation, which is gravel. The production water is then pumped into the aquifer. The following extracts from various documents indicate that, over the years, there has been corrosion of the pipe lines and some of the production water has "possible communication with the Selmo Formation", ie production water has possibly come into contact with, and, therefore, contaminated the aquifer formation gravel, which could drain into local rivers and lakes, one of which is the Devegecidi reservoir. 1. A memo from EDR/3, to EDM dated 3/10/1995 called "Subject: Midyat and Selmo Observation at Beykan", signed by Umur Eminkahyagil, states: "PLT survey carried out on 1/7/95 at Beykan AZCA water disposal well raised concerns on its completion integrity and the injection interval. The survey showed that the Selmo formation overlying Midyat is unprotected due to well completion and extensive corrosion of the injection conduit And further that: "One well will be used to monitor and verify the possible communication with the Selmo Formation. Beykan WDW-02 is planned to be converted to an observation well on the Selmo Formation. A workover is required to ensure the integrity of the well conduit. 7" casing in the WDW-02 needs to be pulled back and a new casing will be run. Midyat needs to be plugged back and selmo will be perforated for monitoring purposes." And that: "Since the other disposal wells and WDW-02 are very close (ca. 1030m) the effect of possible communication with current disposal wells and Selmo Formation can be verified in an short period of time with an Amerada gauge. If such comunication is present, further investigation may be required to assess the effects on Devegecidi Reservoir." A report on a survey at Beykan Azca Water Disposal Well sent from EDR, signed by A. Eryurt and dated 4/7/1995 has a covering note which states: "The attached report on the Azca Midyat water Disposal Well injection survey raises concerns on its completion integrity and the injection interval. The survey shows that the Selmo formation (Gravel) above Midyat is unprotected. Consequently the impact of communication with the Selmo Formation needs to be investigated. In the absence of an integrity review similar results may be obtained from the other Azca Disposal Wells. I suggest that the completion integrity and injection profiles of these Azca injectors, starting from the Beykan area are established as recommended in the report." In the conclusions of the report it states: "The current status of the 7" conduit indicates potential communication with behind casing below 19 m. Presence of cement and/or another size casing is unkown." And recommends: "The current situation of Midyat disposal and the diposal wells requires closer attention. Therefore, further surveys to assess the effect of water disposal and the integrity of disposal wells is recommended. Since another electric logging entry is considered risky and likely to give no further information utilisation of a workover hoist for pulling out 7" casing, and to carry out this investigation is recommended." 5. Identification of alternative disposal methods. In 1989 it is acknowledged that the alternative to injecting production water into the Midyat aquifer is identified as re- injection into the Mardin oil reservoir (which is where the water came from) via wells converted specifically for injection. The following extracts show that the alternative is agreed, is investigated and costed at US$ 2.2 million over 1994-1995. It is proposed to have about 50% of the produced water injected into the Mardin oil reservoir by the end of 1995 however, due to cancellation of US$1.2 million in funds the target of 50% Mardin injection was not reached. The minutes from a meeting with the new owners, Perenco, showed that they were not aware of the investigations and had no plans to continue. In a Summary document entitled "Water Disposal in NV Turkse Shell", dated 29/9/89 from "PTR3" (the signature is difficult to read) it is stated: "Alternatives to the current disposal practices appear limited. Surface disposal into the Dicle [Tigris] river, as applied by other companies in the area, is discounted because of the direct environmental impact and potential for third party claims[5]. Evaporation and soakaway pits are similarly rejected because of the lack of an adequate evaporation rate throughout the year and the presence of impermeable surface rock in the lease areas. As no industrial water users or disused mine workings are known, disposal in the (producing) Mardin reservoir therefore, would seem the only alternative." "A feasibility study carried out in 1987 ... indicated the capital investment for such a scheme-covering hydraulic fracturing and conversion of existing watered out wells, installation of surface pumps, generators, etc. - to be of the order of 5 to 8 million US Dollars with yearly operating costs exceeding 400,000 US Dollars...." "If the General Directorate of Petroleum Affairs would classify the project as "oil-related", the year 1 Capex/Opex figure of 5.4 million US $ would result in a tax relief of 2 million US $ in the same year." [5: although direct environmental impact and liability are given as reasons for not discharging into the river, it is noted, elsewhere in the documents, that this practice is against UK regulations.] The document concludes that: "Even if a zero level of oil in the disposal water could be achieved by further upgrading of the present dehydration facilities, the existing Midyat disposal practise would not fulfil EEC regulations, which simply forbid disposal of effluents into a potable aquifer." "Only a Mardin disposal scheme with considerable associated Capex and Opex will give a fully acceptable disposal method satisfying International legislation. To evaluate the practicality of such an injection scheme and establish well injectives, a Mardin injection pilot test is being considered." The document above shows that disposal into the Midyat aquifer is unacceptable and against the, then, EEC regulations and that the only alternative is to dispose of the produced water in the deeper Mardin oil reservoir (where the water originally came from). Further studies were then recommended to evaluate this option. A detailed report entitled "Technical Safety Audit, N.V. Turkse Shell, Production Diyarbakir, Report EP 91-1810, dated September 1991, notes in paragraph 5.1.9.1 (Process Drain System) that: "Production water is dumped through disposal wells in to the shallow potable water aquifer at about 400-500 m depth." And the Action to be taken E1H 5.1.9.1 (a) states: "Stop disposal of production water into the potable aquifer as soon as possible as between 1994 and the year 2002.] 2. The minutes of an "NVTS Water Injection Follow-up Meeting" held on 18.10.1994 illustrates that certain efforts were underway to reduce the injection of the aquifer by injecting into the Mardin oil reservoir - called the Water Injection Project. Present at the meeting were: Frank van Hest, OM (OPD); Ahmet Eryurt, EDR; Rob Boulstridge, EDA; Haluk Devran, A/OMS; Umur Eminkahyagil, EDR/3. The minutes were copied to: EDM, OMT, EDA/1. The objectives of the meeting were defined as: "to review NVTS Water Injection Project (into Mardin) progress and plans and to update wherever necessary, thereby increasing injection into Mardin." An addendum to the minutes, dated 19/10/1994 states that : "The objective is to implement the water injection project (i.e. 3 conversions in 1994 and 2 in 1995 with tie-ins). Target is to reach ca. 50% injection into Mardin by the end of 1995. Funds allocated for this purpose are US$ 2.2 million spread over 1994-1995."[note] [Note: this is in agreement with the base case scenario presented in the viewgraphs above.] A memo from "EDR to MEP and EDM", copied to OM, Mr D. Colomb (Perenco NVTS MEP Designate) and Mr, M, Veille (Perenco NVTS OM Designate), dated 22/12/1995 and called "Subject: NVTS Azca Water Disposal Wells" addresses the current situation and uncertainties. The document reports on a meeting held on 7/12/1995 with the new owners, Perenco, and states that: "When the NVTS water injection subject was being presented, it became apparent that Perenco representatives were not aware of the 'Beykan Azca Disposal Well' investigation. Consequently the new owner does not yet have a decision and plan to proceed with the investigation." [7] [7: This is the investigation to see if losses of injection water to the Selmo formation have been draining off and polluting Devegecidi water reservoir.] It is noted that: "Documentation at the time of data room preparation were made available to the data room team and they should have been included in the package due to its nature. The subject requires urgent attention but the speed of response to date is not considered adequate." The document ends with: "Furthermore the planned increase in the Mardin injection could not be achieved this year due to cancellation of funds (US 1.2 million) originally budgeted for the Mardin water injection projects. Thus the end of 1995 target of 45% Mardin injection was not achieved and remained at ca 25%. It is unfortunate to see a change of priorities towards maximising cash before divestment by sacrificing environmental targets. Shell should take action before departing from the E&P activities in the area to ensure the continuation of currently suspended NVTS water injection programme and the AZCA Wells investigation." The situation up to 1994 is summarised in the internal NV Turkse Shell Exploration and Development Department report of January 19 A letter, dated 18/10/1988 signed by C.G. Finlayson, Chief Petroleum Engineer, from N. V. Turkse Shell to Shell International headquarters in the Netherlands. 7. A memo from EDR/3, to EDM dated 3/10/1995 called "Subject: Midyat and Selmo Observation at Beykan", signed by Umur Eminkahyagil. 8. A report on a survey at Beykan Azca Water Disposal Well sent from EDR, signed by A. Eryurt and dated 4/7/1995. 9. A Summary document entitled "Water Disposal in NV Turkse Shell", dated 29/9/89 from "PTR3". 10. A report entitled "Technical Safety Audit, N.V. Turkse Shell, Production Diyarbakir, Report EP 91-1810, dated September 1991. 11. A letter from EDM, NV Turkse Shell Diyarbakir, to Shell headquarters (EPO/28 SIMP The Hague) in the Netherlands dated 9/9/1994) and signed by D. van Donk. 12. The minutes of an "NVTS Water Injection Follow-up Meeting" held on 18.10.1994. 13. An addendum to the above minutes, dated 19/10/1994. 14. A memo from "EDR to MEP and EDM", copied to OM, Mr D. Colomb (Perenco NVTS MEP Designate) and Mr, M, Veille (Perenco NVTS OM Designate), dated 22/12/1995 and called "Subject: NVTS Azca Water Disposal Wells".