GREENPEACE SUMMARY
SHELL DOUBLE STANDARDS AND ETHICS
POLLUTING AN AQUIFER IN TURKEY
Greenpeace is in possession of a number of confidential internal reports and memos, written
over a number of years by employees of N.V. Turkse Shell oil company (Shell's company
operating in Turkey). These demonstrate some of the environmental and safety standards which
Shell operate in that country. A specific case of systematic pollution is illustrated as the
documents reveal how Shell has been injecting huge amounts of contaminated water into an
aquifer in the Diyarbakir area in eastern Turkey for over 20 years. This is the Midyat aquifer
which is a potable water supply.
The documents not only reveals that this practice has been ongoing, but that Shell were aware
that it is against European Union (EU) regulations. Furthermore, the documents show that it is
mainly relatively small cost savings which prevented Shell from stopping the practice. In some
of the documents it is acknowledged that there is a potential threat to the water supply of the city
of Diyabkir over future generations. About two million people live today in Diyarbakir. The
solution to the problem is to inject the produced water back into the Mardin oil reservoir, from
which the water originally came and funding was allocated to change the injection from the
aquifer to the oil reservoir, however, funding for this project was cancelled.
Extracted crude oil usually contains water. An operating company splits the water from the
crude with the help of solvents and other chemicals. The production water, which is
contaminated with crude oil and chemicals, is then normally injected deep into the ground under
aquifers.
THE POLLUTION OF MIDYAT AQUIFER
Internal memos from 1986 and 1987 signed by the then General Manager, C. E. Fay, identified
the problem and called for increasing efforts to resolve it. Subsequently, in 1991, the General
Directorate of Petroleum Affairs (GDPA) in Turkey wrote to Shell and demanded: "In order to
stop contamination in the Midyat aquifer you are emphatically requested to ensure that
henceforth the necessary measures are urgently taken to have the disposal waters injected into
the Mardin Formation through the wells that have ceased production, making sure that disposal
waters are not injected into the Midyat Formation, and to inform GDPA about the matter."
Above the Midyat aquifer is a geological gravel formation called Selmo, through which the
wells have to be drilled in order to reach the aquifer (a diagramatic cross-section of the area is in
one of the reports.) Other memos note that drilling muds have been lost into this formation and
that, because of corrosion of the pipelines, it is possible that produced water has also
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contaminated the Selmo. This threatens the local rivers and lakes - in particular a local reservoir
called Devegecidi.
The alternative to disposal into the Midyat aquifer, as noted in the letter from the authorities, is
to re-inject the produced water into the Mardin oil field. It is noted that only "a Mardin disposal
scheme ... will give a fully acceptable disposal method satisfying International legislation".
Hence a Mardin injection pilot test was being considered in 1989.
However injecting into the aquifer was ongoing in 1994, as a letter from Turkse Shell to Shell
International demonstrated. This letter also states that if "as a result of water disposal into
Midyat, the water supply of Diyarbakir is affected then the water produced for domestic use
from wells spread over a large area is required to be treated or an alternative water supply has to
be found. In both cases the cost is expected to be high."
This letter shows that between 1973 and 1994, 487.5 million barrels of production water has
been injected into the Midyat aquifer. According to earlier memos the amount of oil lost into the
aquifer is between 15 and 35 barrels per day (b/d). In 1994, it is reported that the current
situation is that 82.8% of the daily produced water is injected into the Midyat aquifer. In a worst
case scenario, by the year 2006 the polluted water will be 14-20 km away from the injected well
and contaminate the aquifer under the city of Diyarbakir for the next 100-300 years. The "likely
case" is reported to be contamination after 800-1000 years.
A further report indicates that, not only has produced water been injected into the aquifer, but
the recommended method for dealing with radioactive LSA scale (a scale which builds up inside
pipelines and wells) is to grind it up and inject it with the disposal water. In fact a valve
replacement on one of the lines showed a high build up of scale and the "radiological testing
indicated this scale to be highly radioactive". While LSA scale is described as 'naturally
occurring', this is in the oil reservoir and not in the aquifer.
Solving the problem, i.e. injecting produced water into the Mardin oil reservoir, was estimated
by Shell to cost between US$ 2.2 million, (five converted wells over 1994-95) and US$ 15
million (7 converted wells by the end of 1995 with a futher 8 planned by the end of 1997). Shell
settled for the cheaper option, and in the minutes of a meeting held in October 1994, the
objective is stated as to achieve "50% injection into the Mardin" oil reservoir by the end of 1995.
However, during 1995 Shell sold the operation to Perenco. This sale is completed in December
1995, but a memo from a meeting with Perenco representatives in December 1995 states: "The
planned increase in the Mardin injection could not be achieved ... 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'S GENERAL STANDARDS OF OPERATIONS IN TURKEY
Two documents reveal the general standards of Shell's operations in Turkey. The first
document, written in 1991, is a Technical Safety Audit and highlights a number of environment
and safety issues. It identifies the fact that since "the management controls to ensure safety at
the work site are not effective the overall rating is unsatisfactory". The report also states that the
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"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".
Other issues raised in this report are:
- a rapid increase in claims for pollution damage;
- a recommendation made in "a 1986 review of field measurement ... 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";
- a commitment to safety and the environment is "subordinate to production" in the "middle of
the organisation";
- the atmospheric and health problems from a programme of mixing crude with diesel fuel;
- an action to stop "disposal of production water into the potable aquifer as soon as possible as
recommended by 1989 environmental audit."
The second document, written in June 1994 entitled: "Exploration and Programme Support
1995", discusses some of the problems highlighted in the technical audit of 1991. It notes that oil
spills reported in 1993 were 218, down from 290 in 1992, which represents a total of 1,171
tonnes of oil spilt. It states that there are plans to reduce the total land payments (compensation
for aquisition and damage) from over US$ 1 million in 1993 to US$ 0.5 million by 1997.
However, despite the concerns about atmospheric pollution arising from the mix of crude and
diesel fuels, further moves to use this mix are planned.
Furthermore, under the section discussing environment it is stated that the Turkish authorities
are demonstrating a growing interest in environmental issues with the possibility of "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
following concerns:
- produced water injection,
- land farming,
- Environmental Impact Assessments (EIA) studies,
- oil spillages,
- waste management, abandonment and clean up of oil contamination."
In fact there are standards in Europe for most of these issues and have been for years. In other
European countries, Shell would have to operate at these standards. However, a year after the
production of this report, Shell sold off the operations to the international operating company,
Perenco.
WHO IS PERENCO?
Perenco plc is an international oil and gas operating company formed by merging the two
companies, Kelt Energy plc and Perenco. It is based in London and Paris with exploration and
production interests in the US, Britain, Colombia, Gabon and Cameroon.
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The main business strategy, has been to buy unprofitable producing assets from majors and
operate them at a profit after paring staff and operating costs to a minimum. They boast that
they operate with 50 per cent of the staff of a major and without a substantial number of
expatriates and "are not afraid to make itself unpopular with other oil companies, contractors, or
government departments".
List of leaked memos and reports:
1. A memo signed by C.E. Fay, and dated 04/09/86 from "GM to Mep".
2. A response to "GM", signed by Recep Aksulu, Head of Production, dated 23/9/86.
3. A memo on the analysis of samples is signed by A.K. Lucas and dated 23/1/87 from "PET to
CPE (MEP)".
4. Then a reply to this, dated 26/1/87 from GM and signed simply CF.
5. 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".
6. 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".
15. NV Turske Shell Exploration and Development Department report of January 1994 by Neil
Harvey, EDR/6 called Water Injection Project.
16. "Technical Safety Audit, N.V. Turske Shell, Production Diyarbakir. Dated Sept 1991
Report EP 91-1810
17. "Exploration and Production Programme Support 1995" June 1994.
MARCH 1996
GREENPEACE MEDITERRANEAN
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