Chapter 8

Taking

care of

business

The fragile relationship between water and industry

hen I was a kid, granddad drilled a water bore at the bottom of our New Plymouth garden. W A dab hand with a divining rod, well-driller Henry Warner was about 80 when he used one to locate a likely spot, attached a garden hose to one end of a length of galvanised pipe and a drilling bit to the other, and tamped down, adding lengths of pipe as he went. At 29 feet, he struck an underground stream. He clamped a hand pump on top, and with some vigorous pumping was able to produce a trickle of murky water. None of us was game to drink it, so granddad's well was declared "for emergencies only". There never was an emergency, so the well's main benefit lay in its skite value around our neighbourhood. What granddad Henry demonstrated was not all water is found in rivers, the sea and the kitchen tap. Some exists mysteriously underground. He had spent a lifetime making a living from finding it and drilling for it. It's a practice others continue to this day - except most bores are located through more sophisticated means than a bent bit of number-8 wire. And some bores aren't for water.

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker While Taranaki enjoys obvious economic benefits rilling for oil began in Taranaki 13 from being the country’s energy province, that has years before Henry Warner was born. been achieved largely because of the vigilance of Taranaki Regional Council, whose regulatory D By the time he came along in 1878, the experience is now second to none in New Zealand. oil drilling business was well under way here, having started with the (initially) hand-dug Alpha well at Moturoa on the New Plymouth foreshore in early 1866.

That struck hydrocarbons at an even shallower depth than Henry Warner’s effort, with oil and gas found less than 20 feet (6m) down. It was the first of more than 50 oil and gas drilling ventures that over the next 85 years bored several hundred wells in Taranaki, mostly around New Plymouth.1 It was small-time stuff, but produced enough oil to support a couple of refineries, the last of which made local fuel called Peak Petrol for a few decades until 1978. The Moturoa oil field is regarded as one of the first in the world, but even though hydrocarbons

There have been relatively minor spills and other pollution incidents over the decades since the first major reservoir of hydrocarbons was discovered at Kapuni in 19592, but by and large the industry has built a good environmental record. still leak out at the Port Taranaki foreshore - as they So why is there such a fuss from environmentalists and others who say the industry is a major threat and may have done for millennia - the oil industry focus should not be allowed to operate here at all? has shifted away from the city. Aside from the global change in public perception Its spheres of interest now centre on the Kapuni gas about what oil and other businesses and those who field in South Taranaki, the offshore fields of Maui, Tui, Pohokura and others, to small oil and gas consume their products – us – have been doing to the discoveries scattered around various parts of the environment, the internet has brought ready access to province, and more recently to deep water prospects information (and some misinformation) about the off the North Taranaki coast. downsides of oil and mineral extraction if it is not properly managed and regulated. Drilling for oil and gas and dealing with the outcomes can be a messy business, potentially dangerous if Environmental watchdogs ask: if the oil industry does done without great care. stuff like that over there, is it doing it here?

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker A fair question, one that will be examined in this If a horizontal well is fracked – something not chapter, whose theme is how well the waterways of typically done in Taranaki - some of the fissures Taranaki are being protected from potential risks created are perpendicular and may head upwards as presented by oil and gas and other big industries. A far as 300 metres. theme of “past history versus potential”, if you like. That’s not usually considered an issue if the fracking is more than 2000 metres down. Almost all in racking is probably the best-known issue Taranaki have been, with a couple of notable linking the oil industry to freshwater aquifers, exceptions, on which more later. yet the word has only recently been added to Although an early first reference to its use in Taranaki F the public lexicon. appeared in 1993 in the annual stock market address Prior to 2011 - when it suddenly featured in New of Southern Petroleum’s chairman - when he said it Zealand headlines - it was jargon would bring an eight-fold used mainly by the oil industry. increase in gas production from the company’s Kaimiro- Otherwise called “fraccing” and 1 well - fracking was not “hydro-fracking”, the term refers to hydraulic fracturing, an oil publicly connected to Taranaki until early 2011.3 recovery technique that forces fluids and sand or ceramic pellets A journalism student at the under pressure into underground Western Institute of formations to create small cracks Technology in Taranaki wrote to get at pockets of oil and gas. a story for the Taranaki Daily It has been used in Taranaki since News, which gave it little about 1989, but achieved prominence. international prominence IMAGE: Commissioner That changed in March, when following the controversial 2010 for the Environment a newly formed US documentary, Gasland, whose environmental lobby group, images of a man setting light to Climate Justice Taranaki, tap water remain embedded in the called a meeting at Okato to consciousness of a new generation discuss oil industry issues. of environmentally concerned people. There, it became known fracking had been used in the Even though subsequent province for more than 20 investigations established the years, apparently unremarked methane gas in the tap water by anyone outside the shown in Gasland was a long- industry. established phenomenon that occurred naturally (and had From there, the controversy nothing to do with fracking), went media viral, as people in those images stuck in the public Southland, East Coast, mind. Hawkes Bay and the Wairarapa connected the dots There is a number of potential and demanded to know more hazards with fracking. about this perceived new Loss of well “integrity” is a threat, which was to be particularly vital issue (with all oil employed in exploiting their wells, fracked or not) because regions’ shale rock wells often pass through formations, and which freshwater aquifers, and a sounded very much like combination of simultaneous methods seen in Gasland. failures in the various metal and TRC may have been surprised cement containments could allow by the fury with which the formation and fracture fluids to fracking debate exploded. escape.

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker A TRC chart showing details of fracking.

IMAGE: TRC

In May, 2011, it contacted the oil companies and That led to investigations by TRC, whose reports asked for fracking information, and the following showed groundwater and streams in the area were month provided assurances to Green MP Catherine unaffected by oil drilling, although ironically there Delahunty about what was going on. was bacteriological pollution from farms and signs of “There is no known leakage of frack fluids to aquifers naturally occurring methane gas from the former 7 or to the surface water in the region,” wrote TRC chief Ngaere Swamp. 4 executive Basil Chamberlain to the MP. Despite assurances from various government A month later the council told oil companies that in politicians, including Prime Minister John Key, and a future they would need approval to frack.5 TRC report in November, 2011, that found no evidence of related environmental problems, the Its July letter to them said the practice would be furore would not go away.8 treated as a resource consent matter, but not one that needed notifying to the public in most cases, “given In March, 2012, Parliamentary Commissioner for the their no more than minor adverse effects and lack of Environment Jan Wright announced that as a result of affected parties given the depth that they (fracking) many requests to her office she would conduct an occur. However, each application will be assessed on inquiry. a case by case basis”. A year later, her report of 77 pages canvassed the issue That approach drew criticism from Climate Justice here and overseas and concluded there was no Taranaki and other environmentalists who felt the evidence fracking had contaminated New Zealand’s matter should be open to public scrutiny. underground freshwater.9 The TRC said it would re-examine the issue in its She said the environmental risks associated with review for the next 10-year regional water plan, due fracking could be managed effectively provided, to out in 2014. quote the Royal Society of London, “operational best By now, the anti-fracking campaign in Taranaki was practices are implemented and enforced through getting plenty of media traction. For example, a regulation”.10 farmer close to the Cheal oil field at Ngaere near She found among other things that: Stratford raised concerns about the water supply, claiming there had been an accident in one of the wells  the Taranaki tight gas sands11 had been fracked (it turned out to be a casing leak unrelated to 78 times since 1989, at an average depth of just fracking).6

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker under 3000 metres (deepest 4400m, shallowest to her report, commenting that “these components 1100m); have all been used in New Zealand fracking fluids”. Some operations use acids, corrosion inhibitors, iron  while the great majority of wells was fracked control agents and friction reducers. thousands of metres below freshwater aquifers, two put down in South Taranaki by Swift Her list seems light, given that in his ProPublica Energy in 2005 were within a couple of rugby report, “Hydrofracked”, US journalist Abrahm Lustgarten said up to 600 products - a number field lengths of the aquifer, albeit separated by 12 sometimes quoted by Climate Justice Taranaki – may impermeable rock; be involved, some of them highly toxic and  some fracking by one company used diesel- carcinogenic in concentrated form. based fluid (a practice now abandoned in favour However, Lustgarten is now unable to recall where he of water-based and synthetic products); obtained the figure of 600.13 It is highly unlikely to  fracking fluid was typically 97.25% water, with apply to a single fracking operation, which would use

the rest a mix of chemicals needed to make the a comparatively much smaller number. process work. A CJT website publication on fracking chemicals mentions only 46, although the organisation notes the Wright listed fewer than 20 products in an appendix TRC’s last fracking report included 67.14

What are the fracking products? Here is a list in the 2012 report by Parliamentary Commissioner for the Environment Jan Wright: Component Purpose Example Gelling agent thickens the fracking fluid into a gel so it can carry guar gum the proppant into the fractures Cross-linker further thickens the fracking fluid so it can carry even sodium tetraborate more proppant Surfactant lowers the surface tension of the fracking fluid to oxyalkylated alcohols or reduce friction during injection and to aid fluid oxyalkylated recovery to the surface after fracking alkanolamines Gel stabiliser ensures that the gel does not break down at high sodium thiosulfate temperatures Gel breaker turns the gel back into a free flowing liquid in the well Ammonium persulfate or (it may break the gel after a certain amount of time or hydrogen peroxide at a certain temperature) releasing the proppant and increasing the amount of fracking fluid returned to the surface Biocide or prevents the growth of bacteria that can produce gas Tetrakis bactericide (such as hydrogen sulphide), degrade other (hydroxymethyl), components of the fracking fluid, and corrode the well phosphonium sulfate or casing glutaraldehyde Scale inhibitor prevents scale from building up in the well and other ethylene glycol equipment Clay stabiliser prevents clay particles in the formation from swelling Tetramethyl, ammonium and blocking fractures when exposed to water chloride or choline chloride Buffer or acidity keeps the fracking fluid in the right pH range to allow potassium carbonate, adjuster other components to work effectively sodium hydroxide or potassium chloride Radioactive sometimes used to trace the proppant and locate the iridium-192 or tracers (low level) fractures scandium-46

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker The number of products was less concerning to “The risk of environmental damage depends on where Lustgarten in 2011 than what he said was reluctance a well is drilled – on the geology and hydrogeology. by oil companies to reveal the exact chemical makeup “Once granted permits which sometimes cover very of some proprietary substances, given their large areas, companies appear to decide where to drill commercial value, which made testing for them with no guidance from either central or local almost impossible.15 government about where drilling might best take place.” That point is disputed by unofficial oil industry sources, who say the products are well known and TRC says in fact there is guidance on land use, for easily identified. example the New Plymouth District Council’s rules on proximity to faults. The TRC’s 2012 report on fracking offered reassurance, saying most of the fracking fluids “are “Companies drilling wells are also using different found within products that are commonly used in design and construction standards. It is not clear who homes”.16 is responsible for ensuring well integrity – the High Hazards Unit or the regional councils. There is some While some are “extremely toxic in concentrated overlap between risks to the health and safety of form, they are diluted by the water carrier and, workers and risks to the environment. therefore, are present in relatively low concentrations. “For example, blowouts and methane leaks from wells “However, even in low concentrations care is needed are dangerous for workers and can damage the for the use of some products in the environment to environment. Well integrity is critical for both. In avoid potential for impacts on human health.” They New Zealand health and safety regulation is were unlikely to harm when used properly. completely separate from environmental regulation. At this point, it’s worth returning to the issue of depth. “Combining the two regulatory roles to at least some Although Wright’s report shows that fracked wells extent is a common theme in other reviews.”18 were on average nearly three kilometres down, one in She noted the country’s main environmental agency, particular, at the Cheal field in Ngaere, was fractured the Ministry for the Environment, had not provided five times at a depth of only 1700 metres. any guidance to councils specifically on fracking.19 A TRC investigation following local TRC’s Chamberlain took concern found nothing untoward. issue with a suggestion in the The fracking was 1100 metres Taranaki Daily News’ below the freshwater aquifer and coverage of the Wright report sealed off by impermeable rock that his organisation had been formations above.17 found wanting over fracking.20 The tenor of TRC reports suggested that this was not an issue because In a letter to the paper, he the majority of well fracking had said her findings “concur been deep. There is nothing in the with the council's position, council’s guidelines and regulations based on thousands of site that stipulates a minimum depth, visits and inspections, with consent applications being analyses of thousands of air treated on a case-by-case basis. and water samples, and hundreds of bio-monitoring After the release of Wright’s report surveys associated with oil in late 2012, some people chose to FRACKING SAFE: TRC director of and gas activities.” 21 interpret it as an all-clear for resource management Fred McLay fracking, but her main message was downs a glass of water from the The council agreed with more cautious than that. Cheal B drilling site on November 24, Wright that the regulatory 2011, the day his report on fracking frameworks around fracking, She found an absence of what she hydro-geological risks was released. and oil and gas development termed a “social licence” from the IMAGE: Daily News in general, were quite public for fracking, and also a complex and worthy of review. Which is what Wright fragmented approach to regulation, with the roles of and her staff have been doing for the past year, with a central and local government unclear on such crucial second report due in 2014. aspects as well location and integrity, and an over- reliance on the honesty of the oil companies. When that appeared in June, 2014, the commissioner's

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker concerns focused mainly on fracking proposed on the There, its central role in extracting gas and oil from east coast of the North Island, whose geology is much shale has been hailed as the means by which both more like the US gas shales than the comparatively countries could achieve energy independence, safe "tightsands" of Taranaki. She made a number of although some commentators dismiss that as a pipe recommendations for regional councils to take a more dream promoted by the oil industry and its political co-ordinated approach to consents and monitoring, allies.22 noting (with surprise) that no consent was even A similar view is espoused by the New Zealand needed to drill an exploratory oil or gas well in Government, which environmentalists have accused Taranaki.The fracking controversy is not yet settled. of weakening the Resource Management Act to clear Although public debate in Taranaki and elsewhere the way for a similar approach to oil and gas extraction diminished in 2013 in the wake of the Wright report, as that sweeping across the US. the topic continues to be heavily reported in the US However, despite the charge that it has been behind and the UK. the play in regulating the oil industry, the TRC has shown it is able to adapt and tighten its approaches quickly. Such responses are founded on the long experience of its staff, the fact the industry here is still relatively small and is ever more wary of public backlash, and the council being aware that these days, given the breadth of concern overseas, it has a political mandate for taking a stronger line. TRC director of environment quality Gary Bedford says that its long history of monitoring has produced records showing a high level of overall compliance for not only fracking but the oil industry as a whole. The oil industry is – with dairying – one of the province’s twin economic pillars, a reason why Taranaki enjoys an individual GDP of $73,200, compared with a national average of less than $46,000. Climate Justice Taranaki has vowed to end fracking, but a more likely outcome is its continued use, albeit with clearer lines of regulation.

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker As Basil Chamberlain noted when speaking to the petroleum industry in 2012, “inappropriate behaviours and incidents [overseas] normally occurred where poor operators engaged in poor practices, often with an almost total absence of meaningful compliance inspection and monitoring by regulators".23

The scale of many overseas operations dwarfed in almost every way what had or was likely to occur in Taranaki. The generic risks were quite similar, but the risk levels were often very different and significantly less, he said. “Without wishing to provide too blunt an analogy, we down a dud well under pressure so it was forced into have a few people crying ‘foul murder’, but no dead zones of sand or porous rock structures that in some bodies can be found and no missing persons are cases had a seemingly infinite capacity to absorb. reported. Once the process was finished, the well could be “The Council is confident, drawing on its own sealed with concrete, and nothing would ever be seen substantial expertise and experience, and having of the water again. accessed quality local and overseas advice, that fracking activities can and will be managed Even better, it presented an opportunity to send down effectively, with minimal risk to the environment, for other waste products from oil drilling, including the benefit of New Zealand." chemicals and other agents needed to combat algal growth and corrosion.

Re-injection wells can also provide access to depleted he water struck by granddad Henry in our reservoirs that are used to store hydrocarbons for later backyard back in the 1950s is part of what use. In the US and elsewhere, re-injection caught on T scientists call the freshwater aquifer system, or as a way to get rid of other toxic wastes, including in groundwater. a few instances radioactive material. It comprises underground “streams” and, further What ProPublica and others have been exposing is down, large aquifers of freshwater, and further down how it can go wrong when it’s done carelessly and still, even bigger aquifers of salt water that were once without tight regulatory control in places where there under the sea. are thousands of oil wells. Some of the aquifers are sealed off and under pressure Some deep well injection (DWI) wells have corroded in the earth’s geological formations hundreds of or the concrete used to seal them in and stop leaking metres underground; some are connected to the has been weakened by acid in the wastes, which – surface and may be replenished by waterways and being under pressure - have migrated up through rainfall that finds its way down to the shallow aquifers cracks in the earth to the surface, sometimes polluting through infiltration. freshwater aquifers on the way. One of the side effects of drilling for oil and gas is Some zones where the waste was supposed to be when you find it you tend to find water as well. It is confined were fractured by high pressure from the saline water that has been trapped underground with injection process. Some waste found its way to the the hydrocarbons. surface via nearby abandoned wells that had not been properly identified and plugged. When the oil comes to the surface, the water comes too, in ever-increasing amounts as the reservoir is The exact frequency of these accidents in the US is depleted; it may also be augmented by fracking fluid unclear. Federal regulator the Environmental (mostly water) or water pumped down to flood the Protection Agency declined to give ProPublica the reservoir to help push out the hydrocarbons. numbers. It’s called “produced water” by the industry, and as its ProPublica still found sufficient documented cases volume grows it has to be put somewhere after it has and anecdotal evidence of misadventure to suggest been separated from the oil or gas. The idea of re- that, with many hundreds of injection wells and injecting it into the earth originated in the US in the hundreds of thousands of abandoned wells in parts of 1920s24, when drilling companies experimented with the US like Texas, the deep well injection aftermath is pumping produced water back not going to be easily resolved.

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker So, is there a connection to Taranaki? Is deep well five million years ago), formed the Sugar Loaf Islands injection used here? Has it failed anywhere? Could it? 1.8 million years ago, and then the present system of Let’s look first at the province’s geology. Kaitake, Pouakai and Mt Taranaki half a million years

Geologists refer to the area as the Taranaki Basin ago. Mt Taranaki is still “live” in (above25) and say it was formed millions of years ago geological terms (last eruption by a large-scale faulting and folding process across 1750).26 New Zealand’s continental shelf that resulted in What’s down there – at least to a enormous blocks of subsidence, creating basins. depth of five kilometres – is well For the last 80 million years, over six geological known because of data provided epochs, the Taranaki Basin has been filled with by the oil and gas industry. Its sediments from the eroding landscape, swamps, extensive seismic soundings and forests, various coastlines and deposits from sea-life nearly 600 wells (deepest about as shallow sea at times encroached as far as the eastern 5.5 kilometres) have provided a hill country. wealth of information. It was a process complicated by fault zones that run So far as the oil industry is concerned, prime interest is in locating formations containing economically north-east/south-west off Cape Egmont and parts of 27 inland Taranaki beneath the eastern hill country, recoverable hydrocarbons – oil, gas, and condensate. Opunake, Inglewood, Manaia and Waverley. But of equal importance to the community is the The various layers of sediment laid down were environmental impact of removing them, especially eventually buried when the beginnings of today’s the potential effects on surface and ground water. visible landscape were created by volcanic activity. That brings us back to freshwater aquifers. There are That started offshore to the north off Kawhia in the five principal aquifer systems found in rock middle Miocene era (15 million years ago), moved formations up to several kilometres beneath the south in the Pliocene-Pleistocene era (a half million to surface.28 The shallower, freshwater ones are called the Marine Terrace and Taranaki Volcanics aquifers. The Matemateaonga, Whenuakura and Tangahoe aquifers are freshwater at first, but start to become saline less than a kilometre down, depending on the location. IMAGE: Scioly.org Water comes and goes from the former quite quickly, in wet weather percolating down after rainfall and from rivers. It can go the other way when the weather is dry and rivers need replenishing, meaning the levels change constantly.

IMAGE: Scioly.org These systems provide good quality freshwater estimated to be about two

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker years old and generally suitable for drinking and council says it is not concerned about groundwater farming.29 running out. The Matemateaonga, Whenuakura and Tangahoe The total draw-off is low compared to what is aquifers are confined, meaning they have layers of available in some parts of the country like Canterbury, impermeable rock above and below them and their and constant monitoring of a dozen test water bores state changes only very slowly as water infiltrates shows no sign that aquifer water levels are dropping.33 through soil or river beds. Some of the accumulated The key thing about groundwater so far as this chapter water is thought to be 140 to 170 years old. is concerned is not its usage and quality, but the threats 34 An idea of how this works is gained from a recent some say it faces from the oil and gas industry. report by Shell Todd Oil Services that described water aquifers below Kapuni.30 s Stuart Tullett reported in his history of New “In the Kapuni field area, a freshwater aquifer is found Plymouth, many of the first oil wells drilled in in the upper section of the Matemateaonga formation A Taranaki found traces of hydrocarbons, but in (down to approximately 650m below ground level), the end most of them were flooded by water. whilst more saline water is found towards the base of This highly saline brine may have originated as sea that formation at approximately 1,650m below ground water trapped when the geology changed; its saltiness level. grew over geological time as it absorbed minerals “Transition to higher salinity is gradual, with a from surrounding rock. possible transition zone near the base of the In new or re-entered oil fields in Taranaki, when a well Matemateaonga where the water is brackish (1000 31 was first drilled and set up for production, the volume parts per million to 2000ppm total dissolved solids ).” of produced water and other wastes was not great and Groundwater is gaining in significance in Taranaki. could be disposed of at a de-ballasting plant at Port Most takes have been for watering stock and Taranaki or through municipal sewerage systems like supplying households from shallow aquifers, but that the Waitara outfall. 32 has been changing. The amount of water produced has greatly increased The TRC’s 2009 environment report said between since the advent of fracking in the late 80s, since 2003 and 2008 some 85 water bores were added to the hydraulic fracturing involves pumping down big 1465 listed on the council’s database, with the biggest volumes of fluid – 97% to 99% water, the rest growth in the volume of abstraction being for town chemicals35 – which then has to be removed if the well water supplies and farmers installing irrigation in produces hydrocarbons. South Taranaki. As they have moved into potential fields, the The so-called “produced water” from wells makes the companies have obtained resource consents from oil and petrochemical industries the biggest Taranaki Regional Council to re-inject wastes into abstracters in the province, between them taking an most of their projected wells, but in the end the average 13,500 cubic metres of saline water a day by process has devolved mostly to just a few holes whose 2008. Even though usage continues to grow, the depth and characteristics were deemed suitable. What’s “suitable”? When deep well injection was first used in Taranaki at the Kapuni gas field in 1973, the practice was not subject to the same stringent regulatory regime as today. The field’s developers, Shell BP and Todd Oil Services Limited, later Shell Todd Oil Services (STOS), used a well (KW-1) to re-inject at only about 500 metres for the first EARLY DRILLERS: The Kapuni-1 well and its crew as development got 10 years or more into the base under way at the Kapuni gas field in Taranaki. of a freshwater aquifer.36

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker In 1981, as it gained greater knowledge of the sub- There was also some concern that clays in the surface environment, the Taranaki Catchment formations might hinder the ability of the shallower Commission insisted the company drill a deeper well, layers to easily absorb injected wastes. The deeper which was operating by 1984. zones (1250m to 1300m) seemed less likely to clog Since then, wastes have been pumped down to about up. 1200 metres, with the old shallow well kept available When the application went before a special catchment for emergencies until 1990, before being plugged and commission hearing, the commission’s own geologist, abandoned in 2000.37 Marion King, agreed the With nearly a million cubic risks to freshwater sources metres of produced water used by farms in the area going down the first re- were minimal, given they injection well and into the drew water from bores and freshwater aquifer between wells no deeper than 30m. 1973 and 1984, was the However, she noted there water polluted? were a lot of unknowns Nobody knows for sure, but a about what the company was freshwater bore put down going to do. about 450 metres into the These included what was in same aquifer zone by the South Taranaki District the wastewater, the salinity Council about two kilometres of the produced water (none away has found no problems. had yet been produced), and the suitability of the various As this suggests, oversight of sandstone strata that might deep well injection tended to be used for injection. be light in the early decades. After what happened at She recommended that Kapuni, however, the before permission was catchment commission took granted, the company should a closer look. find out more about the receiving zones and say That shows in 1983 what exactly and how much catchment commission it intended to inject.40 papers recording what happened when government- She said there was time available for a delay. owned oil drilling company Petroleum Corporation of The company at first expected to truck wastes away New Zealand (Exploration) applied to operate a deep for disposal at the Shell BP and Todd de-ballast well injection bore at the McKee oilfield at system41 at Port Taranaki. Tikorangi.38 The deep well injection right – for 40 years - was The company presented a geology report about granted conditional on the company coming back to various formations a kilometre or more underground satisfy the commission “that the injection stratum that could receive the wastewater, whose volumes could absorb all of the waste whilst not, due to faulting over the succeeding 15 years, it said, would be small of the structure or the presence of discontinuous sandy in relation to the overall size and estimated capacity of layers, causing contamination of higher freshwater the target formation. aquifers or surface waters”.42 But its writer could give no absolute guarantees, only The company responded the following year. By then, guestimates, about whether the porous, sandy late 1984, there were nearly 20 exploratory wells in structures were completely sealed off from the surface the area’s two oilfields, the McKee-Pouri and the 39 by overlying, impermeable rock strata. Pukemai-Tuhua, and the company’s experts were able The geologist was confident the formation was well to produce a clearer picture of what lay beneath. contained to the west towards New Plymouth and A series of technical reports produced by six Inglewood, but conceded it came to the surface about scientists, some working for the company, but 20km to the east in the hill country. independently of each other, concluded the best place

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker SOURCE: W.O Boeren, Todd Petroleum, 2004 to drill a disposal well was at the north-eastern margin The McKee field wells - including dry holes as well of the field into the Waikiekie formation. as specially drilled disposal ones – would eventually This was between 700m and 800m down, varied in play a major role in deep well injection in Taranaki, thickness between 250m and 500m, and was well with about 20 wells swallowing seven million cubic contained by a 600m-thick layer of impermeable rock metres of wastes up to 2006. above it. Most of it went into the first McKee disposal well The ability of this layer to absorb injected wastewater (McKee-1 took nearly 2.4 million cubic metres) and was open to question because of low porosity and four others bearing the McKee name. 44 complicating clays, but experience with some of the wells – sudden loss of drilling mud when they reached To put that in context, seven million cubic metres this zone – suggested there would be no problems. amount to less than a quarter of all the waste that has They estimated the zone could be injected at a been injected beneath Taranaki. balanced pressure for a horizontal distance out to six In the 27 years up to 2012, the injection total reached kilometres, which meant the Inglewood fault (still about 31 million cubic metres; by way of contrast, the active and reaching as far as the McKee field) and the 1350 reinjection wells in Alberta, Canada (Taranaki outcrop where the layer reached the surface in the east, usually has fewer than 10 operating at any one time) were too far away to be a risk. pump down that much every 44 days.45 They believed another formation, the McKee, was also suitable for injection, but was more expensive So, how much of a problem is all this for Taranaki? because it was deeper (between 1900m and 2200m). The TRC’s publicly available records show there have been a couple of known instances of receiving strata Now that exploration was advanced and wastewater being fractured by too much pump pressure. was being produced, Petrocorp had a better idea what it was dealing with. Produced water from one of the But the consequences, if there were any, don’t seem to McKee wells contained nearly 20 different have been significant, given the incidents happened substances, dominated by sodium, chloride and about a kilometre underground and in strata with bicarbonate, the key constituents of salty water.43 overlying formations of impermeable rock.46 The water to be injected would be only half as saline The many incidents reported in the US are mainly the as water already in the Waikiekie formation, which result of injection wells being improperly constructed itself was about two-thirds as salty as seawater. – leading to leaks – or injected fluid finding its way to

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker the surface through unmapped abandoned oil wells  provided records for discharge volumes, rates, that were never properly plugged. and pressures; So far as the latter is concerned, the TRC says it knows  provided records of chemical analysis of the the location of all the 600-plus wells ever drilled in the discharge; province.  did not fracture stratigraphic seals of injection After a couple of shallow wells in the Moturoa oilfield formation; in New Plymouth that pre-dated regulation began to  provided an annual report on deep well injection give problems with oil and gas leaks in 2002, an activities; investigation found some of the 40 abandoned wells  gave notice of the exercise of its consent; in the city were poorly sealed: but these are far  and discharged only approved chemicals. removed from deep-well injection activity.47 The increased rigour was evident in 2013 when Todd There are no known cases of Taranaki injection wells Taranaki Ltd - which took over the McKee field leaking, although there may be a future complication: some early wells (before 1990) were sealed with cement that is not acid-resistant. Modern wells use acid-resistant cement. The Taranaki deep well injection sites are regularly inspected by TRC field officers and samples of the injected fluids are analysed at TRC’s laboratories. The aim is to produce an annual, biennial or triennial report on what each oil company has been doing for the scrutiny of council members and the public via the council’s website. Some major exploration companies in the past - like the government’s Petroleum Corporation of New Zealand (Exploration) and Fletcher Challenge Energy Taranaki (FCET) – largely ignored the TRC’s requests for DWI data, but these days, such waywardness is not tolerated by the council.48 How performances have improved over the past decade can be judged by comparing earlier reports with the latest. For example, the 2003-2006 STOS report found the company’s Kapuni operation did not comply with the daily discharge limit on a couple of occasions, did not provide chemical analysis data, and failed to file an annual report on its deep well injection activities. Parts of the McKee The report said there was concern about the integrity field complex inland of the strata where fluids were injected, and the from Tikorangi consent condition labelled “no contamination of freshwater aquifers” received a question mark. injection wells in 2006 - copped a serve from the In contrast, the latest report (2009-2012) showed the council merely for failing to file an annual report. company achieved a “high” standard of performance on the TRC’s scale, having: The offence seemed minor, given the company made its injection data available and there were no actual  adopted best practice operations for DWI; environmental impacts from the lapse.  exercised its consent in accordance with the consent application; Another way of judging how the companies and TRC are performing in the deep well injection arena is to  provided well and injection zone information; check a 2013 report by the Institute of Geological and  caused no contamination of freshwater aquifers; Nuclear Sciences (GNS Science), the government’s

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker scientific research arm, which was asked by TRC to GNS noted that New Zealand’s Department of Labour have a look at its regulatory practices.49 1999 petroleum regulations on deep well injecting needed upgrading, since they focused on health and GNS reviewed DWI practice and regulation in Canada safety rather than environmental issues. and the US and concluded TRC was ahead of the game. Its 2005 guidelines were based on the more “While there have been few well integrity incidents in stringent Class 1 wells used in North America for this country, it is considered self-regulation needs to nuclear and other hazardous wastes, even though be upgraded to a more active and comprehensive produced water disposal would usually fall under the regulatory regime to manage the risks going forward, less exacting Class 2 grading.50 particularly with the likely increased activity in the sector.”51 These days TRC continues to tighten the conditions under which it will grant consent for a DWI well, Could TRC improve? GNS had only two suggestions including adding one that monitoring water bores – when considering a consent application, the council must be drilled in the immediate vicinity before and should insist an “area of review” (the affected during the operation. So far, none has found neighbourhood) be designated and its relevant contamination problems. characteristics described comprehensively. The life of new consents has also been dropped back And it should change its designation of unusable salt significantly from the 40 years granted last century to water aquifers to a much higher level of salinity, given as little as four years. the continuing improvements to desalination technology. Whereas for a decade or so there were no limits on how much fluid could be injected daily (these were In other words, it thought some shallower salty initially applied, then inexplicably dropped), aquifers might end up being usable (even though maximums are now explicitly listed, along with other demand in Taranaki is low by national comparison). standard conditions numbering about 20. A question remains: how much of this stuff can the Taranaki geology take? The TRC's view is that the formations into which reinjection is done are so extensive and well-contained, and the amounts being pumped of such minor proportions, that capacity is infinite. Jan Wright said in her 2012 report on fracking that “as with fracking fluid injection, there is a risk that wastewater injection could trigger earthquakes". But there were no signs wastewater injection from oil and gas operations had caused earthquakes in Taranaki, a view supported in 2012 by GNS scientists, who provided TRC with an assessment of seismic risk from fracking and deep well injection. It said there was “no evidence that hydraulic fracturing activities in Taranaki between 2000 and mid-2011 have triggered, or have had any observable effect on, natural earthquake activity.52

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker “There is no evidence that long-term deep injection a “wet region” like Taranaki with its current activities, typically associated with wastewater abundance of freshwater.56 disposal at oil and gas operations in Taranaki, have had any observable effect on natural earthquake activity. and-farming is an odd expression. After all, “…Observations do not support any suggestion that most farming is on land. hydraulic fracturing or deep well re-injection L But for oil operators, the word has a distinct activities could trigger in Taranaki a large earthquake, meaning – to use land to treat some of the hydrocarbon a sequence of moderate-sized earthquakes, or a wastes derived from the industry’s exploration widespread zone of earthquakes.” activities, the outcome being the conversion of However, as is the way with science, the global debate marginal grazing land into productive pasture. about DWI and seismic risks resurfaced in July, 2013, In Taranaki’s case, it has been used successfully to when Science magazine published new research into convert land bordering coastal sand dunes, as can be possible links between the two.53 seen in this photograph taken in South Taranaki. The study, led by researchers from Columbia University’s Earth Institute in the US, found the pressure created by pumping millions of gallons underground seemed to put extra pressure on nearby fault lines. So much so that when major quakes struck thousands of miles away - like the 2011 one in northern Japan that caused an epic tsunami - the resulting seismic waves could trigger swarms of small quakes near the injection sites.54 Lead author of the Columbia study Williams Ellsworth said injection-induced earthquakes, such as some that struck in the US in 2011, clearly contributed to the seismic hazard. He said seismic monitoring capabilities in many of the areas in which wastewater injection activities had increased in the US were not capable of detecting One method typically involves stripping the top soil small earthquake activity that might presage larger off and spreading a layer of solid and liquid oil- seismic events. drilling material that has come out of a well (crushed However, that does not apply to Taranaki, where TRC rock, clay, water, chemicals and oil), mixing in some receives regular data on small-scale seismic events nutrients and water, allowing the sun and microbes to from its monitoring for potential volcanic activity start breaking down the hydrocarbons, then covering associated with Mt Taranaki. and re-sowing the area.57 In addition, TRC believes the context of the Columbia In 2013, land-farms became one of the most study is not applicable to Taranaki. Reference to it by controversial waste management techniques used in environmentalists here appears to be another example Taranaki. of overseas research and experience not readily translating to the Taranaki experience. News media reported that wastes from outside the province were headed for some of the land-farms As some researchers note, while deep-well injection is an invaluable technology for waste disposal operating on mostly marginal pastoral properties between Bell Block and Waitara and around the South (eliminating wastes for a theoretical minimum of 58 10,000 years), there is a “growing movement in Taranaki coast down to Whanganui. industry to eliminate waste production at the source, What is hailed by most scientists as an environmental thus reducing the amount and capacity of waste success because of its ability to convert sandy or poor 55 disposal facilities required.” country into productive dairy pasture – at no direct These options include re-using produced water in cost to the land owner - was suddenly condemned as a fracking operations, or even treating and de-salinating threat to milk, groundwater, streams and rural it, although that path has not been seen as necessary in communities.59

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker The TRC was well placed to respond when the “Land spreading involves spreading the drilling solids controversy erupted, having given consents to on the land surface and mixing them into the surface companies operating land-farms for more than a soil. decade, publishing annual monitoring reports on their performance since 2004, and reviewing the practice as “MBC involves mixing the drilling solids with clean further scientific research emerged. soil and burying the mixed material in an unlined pit to allow natural processes to occur. At the outset of any discussion on the topic, TRC is at pains to point out that none of it happens while there “Guidelines have been produced in Canada (Alberta are farm animals on the land. Energy and Utilities Board 1996 G50 guidelines) for both these methods. And that the process is a two-step one, so far as the consent application is concerned. “The guidelines specify, amongst other conditions, minimum dilution with clean soil, burial depths, and What that means is an application to use the land for contaminant loadings. G50 has been adapted by the this purpose allows it to happen but insists that the Council for soil conditions in Taranaki. property cannot then be used for farming (or anything “The Taranaki Regional Council assesses any else) until a second application is made. proposal for the disposal of drilling solids by these Before that is granted, the land must pass stringent methods on a case-by-case basis. Particular attention safety tests for hydrocarbons and especially for traces is paid to the potential effects on ground [soil] and of heavy metals, since such residues are not treated by surface water.” the process. The report said soil and water samples were taken By 2012, there were about 12 “land treatment” sites in from the Toetoe A, Toetoe B, and McKee B sites on the province. The TRC’s annual monitoring reports one occasion in the 2005-2006 monitoring year. now number in the many dozens, and with consent Soil samples were taken from the Toetoe A, McKee conditions and testing changing over the years, B, Ohanga A and Patea A, and water samples were gaining an independent insight into the acceptability taken from the McKee B and Toetoe A sites on one of the practice is challenging for the lay person. occasion in the 2004-2005 monitoring year. Sampling the reports suggests that most land treatment What did they find? operations have been reasonably well managed and have had little immediate impact on the environment, No apparent environmental effects, although the although more testing of groundwater and for traces outcome was limited because while the soil and of metal may be needed at some of the earlier ones surface water were tested, there was no groundwater before final judgement can be made. monitoring and soil samples were not analysed for metals: “Such analysis would need to be carried out The latter was addressed by a consultant’s report on prior to the expiry or surrender of these consents.” three completed land-farms in 2013, when TRC also got another consultant to review the way it handles The next report, published in 2008, said the land-farming (see below). monitoring regime had changed: “…the programme The TRC’s early reports on the McKee field area for 2006-2007 was altered from that for 2005-2006 by specifying soil sampling instead of surface or illustrate the point about land-farming being a highly 61 technical process. receiving waters or soil sampling. In its first public report on nine STOS (later Todd “Also the individual requirements for each site were Taranaki Ltd) land treatment and mix-bury-cover replaced with a more generic format, on the grounds (MBC) sites around the McKee field, TRC outlined its that this was a more appropriate format.” approach to the two methods used to dispose of drill It said the sites were well managed by the company cuttings (mainly solids) and drilling muds (slurry).60 and soil and surface water tests showed no problems. “In the past, at the completion of drilling operations, The report noted more stringent conditions now drilling solids (muds and cuttings) were often left in applied for the granting of new consents for land- lined sumps with the intention of disposing of them farming (Todd had met these, anyway), and reporting finally when the site lease was relinquished. would be annual rather than biennial. “Improvements in good practice now mean that The TRC’s scrutiny intensified as new consents for drilling solids are generally disposed of by MBC or land treatment were approved, as can be seen in the land spreading as they are created. 2006 annual report on Greymouth Petroleum’s land-

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker residue guidelines, although the original storage pits did not. While hydrocarbons levels in the pits were expected to reduce naturally over time, they would need further testing and might have to be remediated, as required to attain the all-clear consent. The lakes had not shown any signs of harm in previous reports, so no further testing was done. Pasture was established in some parts of the farm, the report said, but not all, and the company had so far not followed up on the council’s request to re-sow bare patches. “While not a breach of consent farms off Manawapou Rd south of Hawera (above, in conditions, the permanent establishment of pasture is the Tangahoe River catchment and adjacent to an expected outcome of land-farming activities. 62 Nowell’s Lakes). “Greymouth’s Site Management Plan states that an It recorded 15 visits to the site to inspect and to take objective for the site is ‘to convert unstable sandy soils water and soil samples for analysis, which looked at to productive pasture…’, and the general actions levels of total hydrocarbons, benzene, toluene, section includes ‘the disposal area(s) shall be tilled and ethylbenzene, xylenes, naphathalene, pyrene and sown as soon as is practical following completion of benzo(a)pyrene, and metals like chromium, cadmium, the disposal, and reworked as necessary thereafter to arsenic, copper, lead, mercury, nickel and zinc. achieve the satisfactory establishment of pasture’.” The report recorded one incident where material had Over the years, the TRC has developed detailed breached a bund, but said the company reported it to guidelines for the control of disposal of drilling wastes TRC and cleaned it up. onto and into land, and it has gone to some pains to Overall, the company had met most of the 29 publicise the success of land-farming in sandy coastal conditions of its consent, and tests showed water in the areas where pasture fails to thrive because of the soil’s lakes was unaffected by the operation. inability to hold water and salty spray from the sea.64 Seven years later, the 2013 annual report on the same Not all land-farms perform consistently up to operation said the farm had not been used for waste standard. treatment for some years and was unlikely to be One near Inglewood in the Mangamawhete Stream again.63 catchment was given an abatement notice by the Areas where wastes were spread met hydrocarbon council in 2009 after one of its 12 inspections (which

GRASS SEEDING: Greymouth Petroleum land-farm south of Hawera. And at right, a stockpiling area. IMAGES: TRC

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker “At the end of the monitoring period, pasture was still not well IMAGES: TRC established in the area that had received the heaviest application of cuttings.” Sampling of that area showed “many parameters exceeded the

overall included 23 water samples and four soil samples) found drilling waste was applied to land without first being blended with uncontaminated soil, meaning its content exceeded hydrocarbons and 65 nitrogen limits. NEW GROWTH: Land-farm The farm’s operator also spread waste closer than 25 paddock four months after sowing. metres from a nearby waterway. The council had tested groundwater prior to the start of the operation so it could compare water quality afterwards. No relevant consent surrender criteria” (the minimum problems were found. level of contaminants needed to make the ground safe Similarly, the physicochemical quality of the for farming). waterway showed no significant changes, but the The TRC stepped up its monitoring the next year, with stream’s macro-invertebrate community was largely destroyed by alterations to the watercourse and high its 2010-11 annual report recording 26 inspections, 86 sediment loads resulting from earthworks done to set water samples and five soil samples collected for up the land-farm, although the community was analysis, four bio-monitoring surveys of receiving expected to re-colonise. waters, and a review of annual reports provided by the consent holder.67 The following year’s report was also less than satisfactory, although it noted the operator responded Overall performance rating on the consent for the first quickly to TRC staff concerns.66 land-farming operation granted in 2006 was a “high”, while the rating for the second farm given consent in The operation had been expanded to 2009 was “good”, as was that a second property by this time, but awarded for a different method there an underground spring caused at the second farm called “land unexpected problems. It acted as a spreading” using a trailer. conduit and caused hydrocarbons to discharge into an unnamed tributary But there were still occasional running along the southern boundary problems. The stream was of the site. polluted on August 28, 2010, after a mishap with one of the “An oily sheen was visible for over trucks carting wastes to the first 100m downstream. Extensive works farm (left). were required to remedy the situation…Continued monitoring will “It was discovered that there show whether an apparent increase in may have been detergent groundwater concentrations of residues in a Transpacific truck chloride and nitrogen is of concern.” which delivered drilling mud to Cuttings that had been poorly applied Pit 8. Stormwater from the pit was discharging to the tributary in to one paddock were disced, IMAGE: TRC contoured and sown. via the stormwater ponds.”

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker The biochemical oxygen demand in the stream In a later story on RadioNZ’s website, TRC chairman jumped from 1.6 grammes per cubic metre upstream and Fonterra director David MacLeod was reported as from the discharge point to 31 three metres saying “scientifically there is no problem with regard downstream (limit is 5), while conductivity increased to having milking cows on land-farms, but Fonterra by a factor of 11 and the stream tested high for also needs to consider how the market will react to chloride, suspended solids and dissolved salts. that”.71 On May 13, 2011, there was another incident, the He referred to dicyandiamide residues being found in report said. some dairy products, but said it was taken out of “During routine monitoring it was found that an oily context and there was no risk to food. sheen was present in a drain at the Derby Road North Since the main benefit to farmers in land-farm deals site. The source of the sheen was found to be the drain was having marginal paddocks turned into quality from Paddock 113, which flowed around Pit 8 and dairying pasture, the Fonterra announcement appeared behind the Portacom. to take away a major incentive. “The area had been identified as a problem in the past Where that left land-farming in the province seemed and works were undertaken to remedy the situation. unclear, although in 2013 TRC commissioned two The problem was finally solved by redirecting the reviews in a move to reassure people the practice is drain away from Pit 8.” stringently monitored and safe. Further on, the report noted: “Monitoring of Both reports confirmed that, although one suggested landspreading activities showed that this method of waste disposal generally has less effects than the traditional method of spreading and incorporation of solids. “However, elevated conductivity (indicating salinity and/or high hydrocarbon levels) was found on some occasions.” With environmental scrutiny and condemnation mounting about land-farms after the March, 2013, newsbreak of “outside” material headed for the province 68 , the Taranaki Daily News on June 15, 2013, filled its front page (right) with a detailed article on land-farming under the headline “How they turn oil into milk”.69 That was enough for the country’s largest dairy company, Fonterra. further improvements. Within three days, it announced it would not collect The first was by groundwater hazards authority milk from dairy farms with land-farming taking place Graeme Proffitt, director of environmental on them, even though it was confident there would be consultancy Pattle Delamore Partners Ltd, who nothing wrong with the milk, and would continue responded to TRC in June, 2013, with a “desk-based” taking it from former land-farms that had previously assessment of how the council was handling its 70 met the all clear consent standards. consent monitoring for land-farms.72 “Fonterra said it was 100 per cent confident there were He found land-farming of oily wastes was an no food-safety issues from cows grazing on the waste, appropriate and sustainable means of dealing with the but testing for petrochemical contaminants in the milk wastes and the controls imposed by TRC seemed, with was costing $80,000 a year,” the article said. some exceptions, generally appropriate.73 “In Taranaki there are 12 land-farms, where drilling “While some of the earlier consent conditions wastes from oil and gas exploration are treated by displayed some deficiencies, particularly the absence being spread on to land. of specific groundwater monitoring requirements, “Fonterra collects milk from six land-farms in requirements to report contaminant concentrations of Taranaki and will continue to do so. The remaining six wastes applied to land, rather than just that received land-farms are coastal dry-stock properties.” into storage, and no requirement to line storage pits,

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker the Council has worked to update the standard consent limits and therefore a toxicity issue probably does not conditions and also revise requirements for active arise. landfarms. “However, it is recommended for future consents that “All active landfarms now have groundwater the wording be changed so that, on average, TPH is no monitoring and lined storage pits. more than 20,000 mg/kg after mixing into the surface “However, within the limited extent that particular soil, with no more than 30,000 mg/kg at any location.” consent and compliance reports were sighted during He said there was also a question whether various mud this review, no evidence was seen suggesting additives could be toxic, inhibiting bio-remediation, significant adverse effects have occurred from past reducing soil biodiversity and affecting the landfarming activities in compliance with their subsequent re-use of the land for pasture or crops. consents. The council was currently carrying out research which “Notwithstanding the revised groundwater monitoring should help answer the question, and presumably lead and pit lining requirements, there are some other more to modified consent conditions if necessary. “Interim minor matters in older consents that are less stringent results suggest mud additives are not contributing to than some more recent consents. significant toxic effects.” “It is therefore recommended that the Council review The consented heavy metal end-points after land- farming were appropriate for protection of the productive capacity of agricultural land. “However, consideration should be given to adopting the lower human health NE75 standards for arsenic and lead to cover the possibility that the land use may change in the future.” Given the heavy metal concentrations in the waste were not particularly elevated, the consent limits were unlikely to be exceeded, he said. The hydrocarbon guidelines being employed as land-farming end-points were derived considering human health only, not the protection of productive capacity of the land or the soil flora or the older but still active landfarming consents as the fauna, and were therefore out of step with the heavy opportunity arises (i.e. as review dates in the consents metal limits. fall due, if a review is not possible otherwise) and, as “It is understood the Council has engaged expert appropriate, impose conditions consistent with the advisers to recommend hydrocarbon guidelines more recent consents.” specifically intended for protection of agricultural He questioned whether current hydrocarbon limits for land.” waste applied to land were appropriate. “Viewed as a whole, the landfarming process seems “The intent is to achieve no more than 20,000 mg/kg to be both reasonably well conducted by site operators TPH74 after mixing into the soil, but the wording of (although it is understood the Council has taken action the consents suggests that a maximum of up to 50,000 against some operations when non-compliance was mg/kg would be permissible. observed) and monitored by the Council. “A hydrocarbon concentration up to 50,000 mg/kg “Given this, and subject to the Council continuing to could inhibit the bioremediation process, being review general and site-specific consent conditions possibly toxic to soil micro-organisms. and landfarming practices to reflect experience “The reality is that, in general, hydrocarbon gained, there seems no reason why landfarming of concentrations are much lower than the consented hydrocarbon-containing wastes should not continue.

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker “As at present, each proposal should be considered on complete. Regardless of the actual risk, this is not its merits as a discretionary activity and either turned acceptable, and the situation needs resolving. The down, or allowed with controls imposed appropriate waste from the few exploration wells now being to the particular circumstances.” drilled in the East Coast Basin is being trucked to Taranaki for disposal. This will not be tenable if wells As a follow-up to that report, TRC hired Hamilton consultant soil scientist Dr Doug Edmeades later in begin to multiply there – again there is a need to ‘get 2013 to sample the ground at three land-farms that had ahead of the game’." been returned to standard farming. TRC has since announced a further investigation into Edmeades – formerly national science programme land-farming. leader for soils and fertiliser at government science centre, AgResearch, until he formed his own consultancy in 1997 – took samples on two occasions ccidents happen. They cause most of the and after comparing the results with the TRC’s own visible pollution noted by the public these testing at the sites declared the soil on the three farms A days, and when they happen in the oil industry safe for dairy grazing. they tend to look nasty. “Based on the available evidence it is concluded that Given the amount of exploration and extraction of the Taranaki ‘Landfarms’ are ‘fit for purpose’ in terms hydrocarbons going on in the province, they are of pastoral farming and particularly dairy farming,” he comparatively rare, with the TRC regarding the concluded. industry’s compliance rate as very high. He based that on considering concentrations of While long-term environmental damage from nutrients (both macro and micro), heavy metals, accidents is hard to determine, the immediate impact barium and petrochemical hydrocarbons residues in of something like a hydrocarbons spill into a both the soils and pastures at three sites.76 waterway can be destroyed fish life, unpleasant smell, blackened margins and oily water. “The re-contoured sand dunes, after the inclusion of the drilling wastes (as per the consents), and with the TRC has made it clear to all companies that they are addition of appropriate fertilisers and water best to ‘fess up as quickly as possible when something (irrigation) are capable of producing high quality clover-based pastures and thus increasing the value of goes wrong, and judging by the tenor of annual reports the land from about $3000-4000/ha to $30,000- on oil and gas drilling and production activities, most 40,000/ha.” have got that message. Further controversy about land-farming arose in a Such spills are infrequent, so when one happened in Radio New Zealand report on December 17, 2013, South Taranaki, with the company’s agreement TRC which claimed the Alberta government did not allow published a detailed account of how the incident fracking wastes on land-farms. unfolded, as an exemplar of minor oil leak management.78 TRC said only one Taranaki land-farm had ever been used for fracking wastes and it was now closed to In October, 2010, a corroded pipeline sprang a pin- further disposal. The site was being reinstated and hole leak at Origin Energy’s Rimu site off Mokoaia Rd checked out in preparation for grazing. Such waste in South Taranaki and up to 500 litres of oil and water was now disposed of by deepwell injection. Edmeades reiterated during a Radio New Zealand interview on December 17 that he had found no evidence of problems with land-farms. He dismissed as “nothing much” criticism by the Green Party that his sampling was too confined to be meaningful.77 He had tested three farms and analysed data from TRC’s own soil testing. In her June 2014 report, the Commissioner for the Environment expressed concerns about land- farming in Taranaki. "There are instances of cattle grazing on landfarmed areas before the bioremediation is

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker seeped into a tributary of the nearby Manawapou amount is disputed) of crude oil to escape and find its River. way over the next couple of days to 14 kilometres of The waxy discharge solidified in the water, affecting coastline. the stream for about 80 metres and catching the According to the TRC’s extensive report on the attention of a neighbouring farmer. incident, it led to a cleanup effort that went on for weeks and eventually removed more than 80 tonnes of oil tar balls, contaminated sand and clean-up materials (rags and litter) that were disposed of at a landfill.79 “The spill occurred on a high energy coastline with minimal environmental effects,” the report said. “Most oil was collected before dispersing into the sand and water column, which also minimised environmental effects. "Rocky areas, which comprised 65% of the area affected, proved more difficult to clean up and oil was remobilised for several months from these areas to the sandy beach, considerably extending the clean-up period. Lightly oiled rocks were left to weather with minimal environmental effects expected.” The company responded quickly and followed its contingency plan, the report said, shutting the pipeline It was a costly mistake for the two companies down and containing contaminants with hay bales and involved, Australian Worldwide Exploration Limited absorbent spill booms that stopped the discharge and Prosafe Production Services Pty Limited, who getting to the Manawapou. were later fined $52,500 each and spent a lot more on the clean-up. The leak killed off stream life for about 250m downstream, but after the company reinstated the waterway and planted riparian margins, subsequent TRC sampling seven months later showed the macro-invertebrate community and fish life were starting to recover. For accidents on land, then, the consent holders have contingency plans, which TRC insists oil companies must build into their operations for every resource consent.

But what happens when it’s at sea beyond the TRC’s legal reach? The region got a chance to find out on October 23, 2007, when the country experienced its biggest marine crude oil spill to date along the coast at Okato. Two days earlier, a mishap on a processing ship dealing with oil-contaminated produced water from the Tui field about 50 kilometres offshore (above right) allowed the liquid to discharge into the sea for what was later estimated to be about three minutes. Whatever the period, it was long enough to allow as much as 32 tonnes (the exact

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker The report said the TRC’s monitoring and remedial The Exclusive Economic Zone is the area of sea, costs came to more than $110,000, which was seabed and subsoil from 12 to 200 nautical miles recovered from AWE/Prosafe. offshore. “The companies were also involved in clean-up The Resource Management Act regulates natural activities and spent a total of $US464,000 on the resource management activities on land and in the clean-up and a further $US1,967,000 on transporting, territorial sea, out to 12 nautical miles. Beyond 12 by tanker, the problematic produced water from the nautical miles New Zealand has historically had no FPSO (Floating means to assess and regulate the environmental effects Production Storage of many activities. Offloading) to Port At the time of writing, the first deep sea well was Taranaki for drilled about 185km off the Raglan coast and was treatment and declared uneconomic. licensed discharge.” After maintaining a protest presence for a few days, The key outcome for the environmental movement launched court action the council was a against the enterprise, but the case was thrown out. chance to test its Greenpeace had already published a report estimating marine oil spill the extent to which Taranaki’s coastline was likely to contingency be affected by an uncontrolled blowout.83 operation, which was up to And in late 2013 the drilling company, Anadarko, expectations. It was released a 1700-page report confirming there was a later called in to assist when a container ship, the Rena, ran aground outside Tauranga Harbour and leaked oil along kilometres of coast. However, even though it cost the Taranaki oil industry more than $3 million and a lot of bad publicity, the Okato spill was miniscule compared to what happened in the Gulf of Mexico in 2010. An explosion on the Deepwater Horizon offshore oil platform set off a sea-floor gusher that took 87 days to control. The effects were still being felt in 2013.80 And the effects have been more than geographical. That incident fuelled fears about offshore oil drilling that reverberated in Taranaki and other parts of New Zealand as plans were announced to engage in deep- risk of coastal pollution in the unlikely event of a sea drilling off the Taranaki and Canterbury coasts.81 major accident.84 In June, 2013, the Taranaki Daily News reported that Oil exploration is not the only perceived threat to if a well blowout occurred during deepwater drilling Taranaki’s marine environment. As this was being operations, four jumbo jets full of equipment would written, iwi and environmental groups were voicing need to be deployed to deal with the emergency. It concern about a proposal to mine the seabed off South would take up to two weeks to get the equipment from Taranaki. the UK to the well site.82 Other estimates put the delay at more than a month. A company called Trans-Tasman Resources wants to “harvest” up to 10 million tonnes of ore a year from In May, 2013, the Government established new iron sand on the sea floor between Patea and Opunake. protocols for deep sea oil exploration that is beyond the mandate of TRC. They are part of the Exclusive In a submission to the Environmental Protection Economic Zone and Continental Shelf Authority, TRC’s McLay noted there was limited data (Environmental Effects) Act (the EEZ Act), whose on the regional benefits of the proposal, and he purpose was to promote the sustainable management requested more information on the long-term effects of a sediment plume on the ecology, fishing and of the natural resources of the EEZ and continental 85 shelf. marine mammals.

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker response to what environmentalists have ly exemplary. been claiming about the oil and gas industry came in an address by TRC chief executive “Putting greenhouse gas emissions arguably aside, at A this regional scale, across land, freshwater, air or Basil Chamberlain to the New Zealand Petroleum Summit in Wellington in 2012. coastal resources, the industry has negligible adverse impacts. He said efforts to manage the province’s water environment involved major commitments and “This is not surprising, but none-the-less a remarkable investments by industry, individuals and communities result, consistent over many years of state-of- - estimated at around $85 million a year - and many environment monitoring in Taranaki.” oil and gas, petrochemical and energy companies were The council was not a passive regulator, he said, but leaders in investing to ensure that Taranaki’s an active, on-the-ground one, currently responsible for environment was as good as any developed part of the world. 86 monitoring 692 resource consents for hydrocarbon exploration and production activities. He said TRC’s role was not narrowly constrained to Over the previous 10 years it had assessed and issued environmental protection, as some commentators 846 resource consents across the full range of wrongly suggested, but was a significantly broader hydrocarbon exploration and production activities, mandate, requiring competing objectives to be from well-site water takes, to waste treatment and weighed and balanced, and conflicting tensions to be disposal, to land-farming and deep-well injection, to reconciled, within the frameworks of the law and the production station operations and more recently, overall interests of the community. hydraulic fracturing. He acknowledged the “generally very high standards In that time, TRC had done more than 700 freshwater of RMA compliance achieved by the downstream [gas bio-monitoring surveys, 4600 water or soil samples processing] industries in Taranaki. and around 30,000 parameter analyses. “Whether you take Contact’s environmental award- In the last 30 years there had been more than 4500 site winning Stratford site, or Methanex’s outstanding visits and 13,000 compliance monitoring inspections Responsible Care programme, compliance is general- to monitor consent compliance, investigate consents

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker and incidents, and give advice and information to the unauthorised discharges since 1986, two of them industry. causing major fish kills. “Frankly, freshwater biological surveys around new Most came from the industries and there were exploration sites were severely scaled back a few prosecutions. 88 In 1992, the newly formed council years ago, because of the sheer lack of any effects decided to move on from general annual inspections being found.” of all industrial sites in the province (with no regular monitoring) to a systematic system of consents and The TRC also took action where it found cases of non- monitoring. compliance. "And as with any resource use sector, there are non-compliance incidents, most of which are This required companies to apply for licences to minor in nature." discharge stormwater. It set up the Mangati Stream He said the industry’s most significant onshore Catchment Resource Consents Monitoring incident was at McKee 13 about 18 years ago, a Programme to ensure the firms complied with moderate event, where the stream recovered within 18 standards and to begin testing discharges regularly to months. The company involved, Petrocorp, was see what effects they had on water quality and stream prosecuted and received a record fine for the time. life. In terms of presence in the region, the oil and gas “The intensity of monitoring was increased in industry had 96 well-sites and 10 production stations, response to the continued adverse effects that compared with more than 1800 agricultural systems. discharges from the area had on the stream,” the 2005- 2006 report said. In the previous 10 years, the council had prosecuted oil companies twice, and issued 13 abatement notices Routine monitoring would include inspection of and nine infringement notices (instant fines). industrial sites and drainage systems, chemical “It is worth noting that across all resource uses over analysis of discharges to the Mangati Stream, and the same time period, the Council issued well in biological surveys of the stream, as well as periodic excess of 1000 abatement notices and about 400 chemical analysis of soil and streambed sediment. infringement notices and completed 35 prosecutions.” By 2005, there were 14 companies holding 15 Chamberlain noted that because of its long resource consents, most of them to discharge experiences Taranaki was perhaps more advanced stormwater into the Mangati (or drains and tributaries than the rest of the country in its willingness to think leading to it), with two also having a permit to and act strategically about the oil and gas business.87 discharge cooling water, one treated wastewater and one wash-down water. The latter two were for oil

industry companies. il and gas are not the only big industries in Taranaki. The province has had dairy and O meat processing plants since the 1880s, and from the 1960s an industrial area became established at Bell Block, just north of New Plymouth. Most long-established industries now have a good record when it comes to caring for waterways, although in many cases, as TRC monitoring records show, it has taken a lot of work to get there. An example is the Bell Block group of industries, which were once notorious for polluting the Mangati Stream, a small waterway running along its boundary. The Mangati starts in farmland south of Bell Block and flows north about five kilometres to the sea, its narrow, 6.1 square kilometre catchment crossing lowland between the Waiwhakaiho and Waiongana River systems. The industrial area sits mid-catchment on the western bank. According to the TRC’s 2005-2006 annual report on the stream – its twelfth – there had been more than 54

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker  and oilfield industry servicing company Tasman Oil Tools (stormwater and washdown water). Standard conditions were applied to the companies from 1996, as well as site-specific requirements as appropriate.89 The 2005-2006 report was a 100 page-plus document containing a massive amount of detailed monitoring data from the TRC’s inspections of each industry and sampling of the waterways. As the report said, the Mangati remained the province’s most polluted stream. Zinc and copper levels originating from MCK Metals had likely caused the disappearance of a range of river-dwelling species. This had been showing improvement, however, after the plant closed down some operations, undertook site remediation and installed equipment to filter out air emissions that had been contaminating the area for many years. The stream deteriorated in two stages, the first below a stormwater drain coming from Tegel Foods and again below the main industrial drain, the report said. MCI and related monitoring of macro- invertebrate life showed levels dropping from less than 80 to less than 60 as the stream progressed past the area, with most remaining life being the kind that tolerated pollution.90 By far the biggest source was metal extrusion firm MCK Metals Pacific Ltd (formerly McKechnie Bros), The reports on individual companies showed “good” which discharged up to 1300 litres a second of to “high” performance. stormwater and cooling water. But there were eight “incidents” involving Tegel Foods Limited (poultry processing plant), Taranaki Other consent holders included: Powdercoating Limited, MI New Zealand Limited,  electrical transformer manufacturer ABB Greymouth Petroleum Acquisition Company Limited, Transformers Limited (stormwater); Clark and Rogers Limited, Natural Gas Corporation of  poultry processor and stock food manufacturer New Zealand Limited and Halliburton New Zealand Tegel Foods (stormwater); Limited.  oilfield industry servicing company Halliburton These included: NZ Limited (stormwater);  20 litres of industrial varnish being spilt (none  a synthetic liquid mud plant and storage site got into waterways); owned by MI New Zealand Limited (treated  a drain blockage causing 4000 litres of “frac stormwater); water” to overflow into a drain (none got into  electric wire and cable manufacturer Olex New waterways); Zealand (stormwater and cooling water);  the oil and grease content of stormwater  storage and maintenance premises for oil field discharged by one site to the Mangati being six exploration equipment owned by Schlumberger times the legal limit; Seaco Limited (treated washwater and  a spill of paraffin oil getting into the stream; stormwater);

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker  and a painting contractor washing out a paint chemical contaminants to the extent that was feasible) roller and discolouring a settling pond. before being discharged to the stream. There were two unsourced discharges of oil to a It would develop a riparian reserve to isolate industry wetland installed to filter some of the discharges. physically and hydrologically from the Mangati, give access for stream maintenance and enable “Unsourced” means the TRC inspectors could not development of flood detention and ponding areas. prove where the pollution came from, because the main drain travelled past several companies (none of By 2006, things were improving. The companies’ whom owned up). monitoring reports gave an overall impression their practices and intentions were generally good, but MCK Metals was under suspicion in one case, because occasionally compromised by careless workers and the oil was the same kind as it used. TRC investigated accidents. this as far as it could, but the matter went no further.91 What did it all look like six years later when the New Plymouth District Council redesigned the way in council published its 2011-12 report?93 which stormwater was directed to the stream from the Connett Rd and Paraite Rd areas, and in 2003 built the The number of industries had grown by three to 17. wetland mentioned above as part of work to combat Monitoring included “152 site inspections, the effects of stormwater carried by council discussions with site operators over site management, pipework.92 102 samples from chemical surveys of discharges and the receiving water, bio-monitoring of the Mangati The wetland (below) was intended to improve the Stream, and odour surveys. quality of water discharged to the Mangati Stream, and contain any spills or contaminants from the “A number of modifications to processes or industrial area, said the 2012 TRC report. wastewater treatment have been instituted by site operators as a result of the Council's investigations The aim was to develop an integrated water and land and requirements for remedial action to avoid, remedy management system in which industrial stormwater or mitigate adverse environmental effects. would be captured and passed through a constructed Connections to trade waste sewer have been made at wetland to trap litter, sediment, hydrocarbons (and several sites.”

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker The good news was there were “no significant adverse effects on macro- invertebrate communities resulting from discharges from Tegel Poultry, De Havilland Drive West, Tasman Oil Tools or Greymouth Petroleum.”94 Overall, scores indicated that the stream communities were of “poor health, but generally typical of the condition recorded in similar lowland Taranaki streams. “It is however noted that, in the November 2011 survey, the MCI score indicated ‘fair’ water quality at the sampling site below the [wetland] discharge for the first time, and a new maximum MCI was recorded for the site above De Havilland Drive in the March 2012 survey.”95 The March 2011 fish survey found a relatively high number of fish, but species Most companies were behaving well. diversity was low, with no older fish. The report said there was a high level of performance “It was concluded that the water quality was sufficient from seven organisations - McKechnie Aluminium to support a young population of certain species of Solutions Limited, MI New Zealand Limited, Natural fish, but that the absence of some expected species, Gas Corporation of New Zealand Limited, New and older fish, may be a cause for concern.” Plymouth District Council, Olex New Zealand The conclusion to be drawn is that “industrialised” Limited, Conveyorquip Engineering Services streams like the Mangati will always be under Limited, and W Abrahams Limited. pressure, even with the best of management plans and Another four were good - ABB Limited (Transformer intentions. Division), Halliburton New Zealand Limited, Tegel To the credit of the councils (TRC and NPDC) and the Foods Limited’s feedmill and Tegel Foods Limited’s industries, by 2013 the MCI scores being achieved poultry processing plant. showed the Mangati was the most improved waterway Three others were good, but could make some of all those monitored in Taranaki (see final chapter). improvement - Schlumberger Seaco Limited, Shaycar Accidents continue to happen. But the chances of Trust and Tasman Oil Tools Limited. Three others them going unnoticed these days are virtually nil. needed to improve. They included BLM Feeds Limited (exceeding the hemical company IWD - Ivon Watkins-Dow, biological oxygen demand in its discharges to the now Dow Agrosciences (NZ) Limited - had stream, and other unresolved matters); Greymouth C already attracted public attention in 1972, Petroleum Acquisitions Company Limited (two non- when an explosion at its plant near Paritutu compliances with stormwater discharge limits); and Rock released chemicals into the city’s atmosphere.96 Hooker Bros Investments Limited (exceeding the That year, the Taranaki Herald published a biochemical oxygen demand limit, and installing an photograph of the company’s Back Beach stormwater unauthorized overflow pipe). drain outlet foaming on the foreshore at the foot of And the macro-invertebrate communities? There had Paritutu Rock. been some small improvements, with median scores The company made headlines again in March, 1983, getting as high as 84 in one part of the stream. But at when a rock pool on the foreshore south of Back the bottom reach, the median was still low, just 69. Beach was shown to be polluted by chemicals The report said increased “urbanisation” at Bell Block leaching out of the cliff above. was having an impact on water quality, as was the The company reacted by applying to the catchment discharge from the filtering wetland. commission for a water right to discharge chemical

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker But the controversy didn’t end there. Later, there were allegations IWD had dumped drums of chemical waste in numerous locations around the western end of the city. In 2001, TRC produced a report99 showing there was no evidence of illegal dumping or damage to the water environment.100 What of the company today? It still operates at the site (below), but not as a manufacturer, instead formulating and packaging a range of agricultural chemicals. It is considered a good environmental citizen by the TRC, whose annual monitoring reports describe a range of tests done by its scientists and those of the company, including samples of

The IWD outfall on Back Beach in 1972. The company denied there was anything harmful in the foam. wastes into groundwater and to dam, divert and take away the contaminated groundwater that accumulated.97 That led to an investigation and a public hearing by a TCC special tribunal in 1984, where it emerged that in late 1982 a “malodorous seepage” was noticed on the foreshore near the mouth of the Waireka-nui Stream. It contained phenoxy herbicide from the manufacture of dioxin- toxic 2,4,5-T herbicide, which was widely used in Taranaki up until 1987 to kill gorse and other pest plants, constituents from two waste chemical landfills on a small headland above, stormwater discharged from the factory site into the 98 established there by IWD in 1975 and 1976. nearby Herekawe Stream. Freshwater biological The company said it had Health Department approval surveys of the Herekawe in January and March in to dump the wastes there, but no evidence was given 2012 indicated “the streambed communities had not to the tribunal indicating the department knew where been significantly affected by stormwater discharges the dumps would be or that there was any department from the Dow AgroSciences site or other industrial supervision. sites in the vicinity”. Eventually, IWD collected what was leaching out of A survey of marine ecology showed “the diversity of the cliff substrata and destroyed it. reef biota is typical to that seen at other local inter- tidal reefs in the Taranaki region”.101 The company was closely scrutinised by the commission over the next couple of years, having to The company tests for chemicals in water from 28 produce a monthly report on how the cleanup of wells around the site and nearby. Traces of phenoxy residues was progressing. acid herbicide and chlorophenol are still found in

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker some located at the centre of the site, but TRC says decided not to prosecute after accepting the concentrations have not exceeded the company’s company’s explanation.106 groundwater management plan trigger levels since On April 13, 1984, it let go another toxic discharge sampling began in 1993, and “if detected, concentrations typically continue to show a into the river, killing replacement fish only just decreasing trend”.102 released by the acclimatisation society. This time, TCC prosecuted: on May 3, the corporation was fined Under the terms of its consents, the company must $75,000 at today’s values, by far the biggest penalty hold an annual public meeting to tell people what’s against anyone in a catchment commission case to that happening with its operation. date.107 The last one attracted three people. No further incidents involving the river were recorded in TCC minutes, but it was later found the waste irrigation area discharged ammonia in the 1980s and ne of the less well-performed industries in its 1990s, a legacy still apparent today in the presence of early days was the third of the Think Big two “plumes” of contamination that extend into the projects, the Kapuni ammonia-urea plant subsoil.108 O (below), which was operated from the early 1980s by the government-owned Natural Gas TRC says today that the matter was complicated by Corporation. the original consent issued by the Planning Tribunal when the plant was first approved, which was why no Now owned by Ballance Agri-Nutrients (Kapuni) Ltd enforcement action was taken by the catchment (since 2001103), it was barely under way before the commission. corporation had to pay the Hawera Acclimatisation Society $9000 in 1982 for killing all the fish in the TRC’s latest biennial monitoring report on the plant lower Kapuni River.104 says neither plume currently extends beyond the Ballance land and both are monitored. It was at it again in October the same year, with the society threatening to prosecute once more.105 In early The report says they pose no short-term threat to 1983, TCC found the corporation had dumped urea freshwater ecosystems; one is slowly migrating waste over a cliff at the end of Normanby Rd, but towards a tributary of the Kapuni River, though TRC

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker scientists expect any concentrations getting that far rights and responsibilities, whereas oil and gas was will be low.109 more the itinerant worker, here on a short-term permit. Ballance’s activities are closely monitored by TRC It was regarded as a visitor, “albeit a generally these days, mainly to ensure its spraying of wastes thoughtful, tidy and mostly welcome visitor, that onto farmland doesn’t result in unacceptably high brings a bottle or two and some after-dinner mints in levels of ammonia and nitrate getting into soils and the form of taxes, royalties and the like". groundwater. That status needed to change, he said. The task of Nearly 30 bores are used around the plant to sample reforming and nurturing ownership of a national groundwater for contamination. Traces are found, but sense of purpose for the New Zealand oil and gas they are within acceptable tolerances. TRC regards the sector needed to be actively addressed by both the plant as a high performer in the environmental stakes Government and the sector, and supported at local these days. government level as appropriate. Although there have been recent minor issues withthe “If New Zealanders better understand and own the discharge of ammonia to the air, the council concludes purpose of our oil and gas sector, then our collective the operation’s effects on surface and ground water ability to act strategically and to make good are negligible and well-managed.110 investment decisions in the national interest, will be greatly improved.” ast words on the impact of big industry on the environment in Taranaki go to TRC Chief Executive Basil Chamberlain. L He told the 2012 petroleum summit that in New Zealand as a whole, agriculture was seen as the long-term permanent resident with full citizenship

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker

NOTES 1 Tullett, J S, 1981, “Nodding Neddy”, The Industrious Heart: A History of New Plymouth, Chapter 5, New Plymouth City Council, New Plymouth. 2 By Shell BP and Todd. 3 Southern Petroleum Chairman's Address, Stock Exchange Announcements - 21/10/1994: On the gas front, the success of the recent hydraulic fracturing procedure at Kaimiro-1 (which saw gas production increase eightfold) has added a new dimension to the company's asset base by significantly boosting both the gas production and reserves potential of Southern's portfolio of licences. 4 Taranaki Regional Council, Chamberlain, B G, June 16, 2011, Document 908057, Response to Catherine Delahunty MP for Official Information Act Request – Hydraulic Fracturing. 5 Taranaki Regional Council, Chamberlain, B G, July 29, 2011, Document 928045, Fraccing under the Resource Management Act 1991, letter to oil companies: Some members of society have recently expressed concern about the potential adverse environmental effects of the activity of fraccing, a practice used by the oil and gas industry to enhance hydrocarbon recovery. The Council had held the view that the activity had very minimal environmental effect, given the depth it was undertaken beneath the surface and the thickness and nature of any overlying geological formations. Therefore it was considered the activity did not require regulation under the Resource Management Act (RMA). However, legal advice was recently sought on the matter to provide clarity. The legal opinion has recently been received and it notes while the situation is complex a resource consent under the RMA could be required. A resource consent could be required under section 15 1 (d) and possibly under sections 15 1 (a) and (b) of the RMA, depending on the temperature/depth and particular circumstances of the situation. The Council has accepted this advice and accordingly reviewed its position… On 24 May 2011 the Council requested that you voluntarily supply information on fraccing undertaken by your company as part of a review of the activity. There was an excellent response to the request with most supplying the data by the end of June 2011 deadline. The Council thanks those who have replied. The data is currently being reviewed. For the few who have not supplied the information a follow up letter will be sent shortly. Those who choose not to reply will be identified in any public communication on the matter. 6 Evans, Ryan, October 10, 2011, “Ngaere residents want answers on water quality”, Taranaki Daily News/Stuff, New Plymouth: 7 McMurray, Kirsty, March 14, 2012, “Well sites free of fracking pollution”, Taranaki Daily News/Stuff, New Plymouth: http://www.stuff.co.nz/taranaki-daily-news/news/6570010/Well-sites-free-of-fracking-pollution. And: March, 2013, TAG Oil (NZ) Ltd Company - Groundwater Monitoring Programme Compliance Report 2011- 2012, Taranaki Regional Council, Stratford. 8 Taranaki Regional Council, November 24, 2011, Hydrogeologic Risk Assessment of Hydraulic Fracturing for Gas Recovery in the Taranaki Region. The report started with a disclaimer: The hydraulic fracturing and geologic information in this report has largely been supplied by oil and gas companies in the region and is believed to be accurate and reliable. However, no liability is accepted for any opinions expressed or for any errors or omissions in the information supplied. The report concluded: Considering the depths involved (of both hydraulic fracturing operations and freshwater aquifers), the limited scale of hydraulic fracturing currently occurring, the integrity of the well casing, the integrity of the natural reservoir geologic seals, and the nature of the multiple natural geological seals between the petroleum hydrocarbon reservoir and any freshwater aquifer, there is no evidence that hydraulic fracturing operations for gas production conducted in the Taranaki Region between 2000 and mid-2011 have involved any substantial adverse impact on groundwater quality. Assuming hydraulic fracturing operations are properly designed and conducted in the future, there is little potential for any in the future. The situation with regard to historical hydraulic fracturing operations is summarized in Figures 10 and 11, which generally show large thicknesses of low permeability natural materials between past hydraulic fracturing activities and freshwater aquifers. Although it is not possible to eliminate all risk, the risk that properly conducted hydraulic fracturing operations could adversely affect freshwater aquifers in the Region is considered very low. 9 Wright, November 28, 2012, P44. 10 Ibid, P73. 11 The term “tight gas sands” refers to low permeability sandstone reservoirs that produce primarily dry natural gas. A tight gas reservoir is one that cannot be produced at economic flow rates or recover economic volumes

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker of gas unless the well is stimulated by a large hydraulic fracture treatment and/or produced using horizontal wellbores. Holditch, S. A, 2006, SPE paper 103356, “Tight Gas Sands”, Journal of Petroleum Technology: http://emd.aapg.org/technical_areas/tightGas.cfm 12 Ibid Wright, P43: “In tight sands and shale, the distance between where the fracking occurs and aquifers is typically large – anywhere between a thousand to several thousand metres. However, the Manutahi-A1 and B1 wells in Taranaki were fracked only 260 metres below the overlying aquifer.” Data from Taranaki Regional Council, 2011, Shell Todd Oil Services Limited Maui and Kapuni production stations monitoring programmes, annual report 2010–2011, Taranaki Regional Council Technical Report 2011-74. 13 Pers. comm, July 16, 2013: Contacted by the writer to provide a source for the 600 number, Lustgarten was unable to recall where he got it from. 14 Climate Justice Taranaki, August 15, 2012, Hazardous Chemicals in Fracking Taranaki V3: http://climatejusticetaranaki.files.wordpress.com/2011/04/hazardous-chemicals-in-fracking-taranaki-v3.pdf 15 Knudson, Tom, July 9, 2013, “Fracking in California’s oil frontier”, The Sacramento Bee, Sacramento, California: The oil industry responded to his and other concerns in 2011 by setting up a website, www.fracfocus.org , where some companies have listed chemical details. The listings are voluntary. 16 Taranaki Regional Council, February 17, 2012, Hydrogeologic Risk Assessment of Hydraulic Fracturing for Gas Recovery in the Taranaki Region, P5. 17 Ibid, TRC TAG Oil report, P4. 18 Ibid Wright, P76. 19 One is now ready for release. Fred McLay, pers comm, February, 2014. 20 Harvey, Helen, November 28, 2012, “Study of fracking finds lax control”, Taranaki Daily News, Edition 1, P1, New Plymouth. 21 Harvey, Helen, November 29, 2012, “Council gives assurances on fracking”, Taranaki Daily News, Edition 1, P2, New Plymouth. 22 Dyer, Gwynne, January 11, 2013, “Forget shale gas as a miracle fuel option”, Marlborough Express/Stuff. Edition 1, P20, Blenheim. 23 Chamberlain, September 19, 2012, P15. 24 Or 1930s – sources vary. 25 A diagram that appears in the Taranaki Area Petroleum Geological Summary, 2013 Block Offer. 26 Haskell T R and J A Palmer, 1984, Lands and Survey Department, Wellington, An Outline of Geology in Taranaki, P20. 27 Natural-gas condensate is a low-density mixture of hydrocarbon liquids that are present as gaseous components in the raw natural gas produced from many natural gas fields. Wikipedia, accessed July 23, 2013. 28 Wikipedia, June 21, 2013: An aquifer is an underground layer of water-bearing permeable rock or unconsolidated materials (gravel, sand, or silt) from which groundwater can be extracted using a water well. 29 Taranaki Regional Council, February, 2009, State of the Environment Report 2009, P124: Groundwater is aged by analysing the quantities of tritium, chlorofluorocarbons and sulphur fluoride, and comparing them with the quantities that would have been in the rainfall when it first entered the groundwater system. 30 Shell Todd Oil Services Limited, January, 2012, “Executive summary”, Application to Taranaki Regional Council for Four Discharge Consents and Assessment of Environmental Effects, Hydraulic Fracture Stimulation at Four Existing Wellsites within the Kapuni Field, Pv. 31 Wikipedia, July 25, 2013: Seawater has a salinity of roughly 35,000ppm. 32 TRC, 2009, State of the Environment Report 2009, P122: The estimate in 2008 was about 15% of water abstracted on the ring plain for farming and household use was coming from groundwater, amounting to about 8000 cubic metres a day. 33 The 2008 total was 44,000 cubic metres a day, twice that recorded in 2003 (but still only enough water to fill about 18 Olympic swimming pools each day). Biggest growth came from oil exploration (up from 2% to 18%), town water supplies (12% to 27%) and meat/by-products processing (6% to 10%). Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker

34 A TRC report on groundwater quality covering the period 1994 to 2007 found, against expectations, no sign of overall degradation from the use of nitrogen and phosphate fertilisers. These have probably not yet had time to get down to the deep aquifers, but would show up in the shallow ones. However, problems with raised nitrate levels have been found in a few wells, mainly in South Taranaki. According to the executive summary of a report entitled State of the Environment Monitoring 2002-2007, Nitrates in shallow groundwater in Taranaki: …the number of wells where levels of nitrates consistently (as determined by the median concentration) exceeded the nitrate drinking water criterion [Maximum Acceptable Value (Ministry of Health, 2005)] of 11.3 mg/l was seven (up to 30 was found in one well). Some 90.5% of the 550 samples analysed were below the guideline. The mean concentration for all samples was 4.51 mg/l which has again remained below the drinking water guideline. The analysis has shown that the number of sites with decreases in the concentration of nitrates in groundwater noticeably outnumbered those showing increases in nitrate concentrations, by 2:1. Consequently, it can be said that at the regional scale, there is evidence to show that shallow groundwater quality in the Taranaki region is improving in regard to nitrates concentrations…The South Taranaki sub-region still appears as the one with highest levels of nitrates in shallow groundwaters and the region where there is a pattern of some wells presenting consistently breaches of the MAV for drinking water. 35 Lustgarten, Abrahm, 2011, “Hydrofracked? One man’s mystery leads to a backlash against natural gas drilling”, ProPublica, US. 36 Taranaki Regional Council, 2007, Shell Todd Oil Services Limited, Deep Well Injection Monitoring Programme Triennial Report - 2003-2006, P20: It is noted that from 1973 to 1984, a total of 900,000 m3 of produced water was discharged via well KW-1 at the Kapuni production station under water right 130. The discharge was into a freshwater aquifer in the Matemateaonga Formation at a depth of 502 to 538 m. The Taranaki Catchment Commission subsequently became aware of this situation, and in 1981 when water right 130 was renewed, required a new disposal well to be found (KW-2), and the discharge via KW-1 to cease. Periodic discharges of produced water via KW-1 for emergency purposes occurred until 1990. Water right 130 expired on 1 June 1991. No adverse environmental effects have been reported. 37 Taranaki Regional Council, 2010, Shell Todd Oil Services Limited Deep Well Injection Monitoring Programme, Triennial Report - 2006-2009, P8. 38 http://www.toddenergy.co.nz/about/history/ June 22, 2013: The McKee field was first developed in 1979, when the Petroleum Corporation of New Zealand (Exploration) Ltd put down McKee 1, the first of numerous wells, some of which would later be used for deep well injection. The field is now owned by New Zealand company Todd Energy, whose website history section notes: As a result of exploration together with acquisitions and joint venture partnerships - Todd Energy now holds interests in producing fields that account for some 80% of New Zealand’s annual hydrocarbon production. Todd Energy's share of Kapuni increased from 25% to 50% and it also holds 100% of McKee – New Zealand's largest producing onshore oil field as well as the adjacent Mangahewa gas condensate field. 39 Lock, R, June, 1983, Petroleum Corporation of New Zealand (Exploration) Ltd, Wellington, Geological Appraisal of Waikiekie Formation Sandstones for Waste Water Disposal at the McKee Oil Field. 40 Taranaki Catchment Commission and Regional Water Board, September, 1983, Report of the committee hearing an application for water rights for the McKee development by Petrocorp Limited, P11. 41 http://nzic.org.nz/ChemProcesses/energy/7D.pdf , 2013: This was built by Shell BP and Todd to handle contaminated ballast seawater coming in empty tankers sent to Port Taranaki to collect increasing quantities of condensate, oil, synthetic petrol and other hydrocarbons products being produced by the Kapuni, Maui and McKee fields and by the proposed Synfuels Motunui plant. In November, 1981, the commission was told the need for de-ballasting was expected to increase 16-fold. According to the NZ Institute of Chemistry, ballast water contains small quantities of oil from ship storage tanks. The de-ballast facility separates the oil from the water, and then discharges the water into the nearby Hongihongi Stream. The facility consists of a de-ballast water storage tank, a small recovered oil storage tank, and an API separator and dissolved air flotation unit. 42 1983 TCC hearing report, P14. 43 Water analysis of produced water from the McKee 2A/4 well showed cations (positive ions) ranging from a high content of sodium, to lower traces of potassium, calcium, iron, and magnesium, to hints of lead, manganese, barium, aluminium, boron, ammonium and mercury. The anions (negative ions) were mainly chloride and bicarbonate, with traces of sulphate, carbonate, hydroxide and phosphate. 44 Most deep well injection in the region has taken place since 1990. Prior to that, it was mostly done at Kapuni and amounted to about a million cubic metres.

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45 Shyba, G, 2008, “Water management in Alberta’s oilfields – issues and opportunities”, quoted in Zemansky, Gil, February, 2013, Review of regulation of deep well injection under the Resource Management Act, GNS Science, Wellington. 46 Taranaki Regional Council, 2007, Shell Todd Oil Services Limited, Deep Well Injection Monitoring Programme Triennial Report - 2003-2006, P33: Consent 1336 sets no limits on injection pressure, however, the data for KW-2 (Appendix II) suggest that hydro-fracturing (fraccing) of the injection zone has occurred. Fraccing has been inferred from the data where an increase in injection rate and volume coincides with a marked pressure drop (eg. 12, 14, 16, 20 July; 18 August; 4, 15, 17 October; and 7, 26 November 2003). Provided the seals in the disposal well and injection zone remain secure, intra-zonal hydro-fracturing to accept waste does not warrant concern (section 1.3.3). 47 Transfield Worley Ltd, New Plymouth, February, 2003, Moturoa oil field investigation: Stage 1 Report, P7: The current legislation covering abandonment is The Health and Safety in Employment (Petroleum Exploration and Extraction) Regulations 1999. Regulation 2 defines the term abandonment as meaning to seal a well to render it permanently inoperative. In recent times isolation practice has been to require the isolation of perforated permeable intervals by cement plugs over the perforated intervals and some 30m either side above and below the interval. These guidelines are generally applied specifically across hydrocarbon bearing intervals but are relevant for isolating all permeable intervals from cross flowing via a well bore and this is also commonplace in modern abandonment’s. Practices early last century (1900’s) and in the latter part of the 1800’s were not prescribed and were highly variable. In general most of the early, and relatively shallow wells, experienced major hole stability problems and it is believed that these would have been/were abandoned with a combination of well bore cavings combined with whatever fill lay readily at hand, including material removed from the well while drilling, nearby rock and debris, and even tree trunks and organic debris are known to have been used. 48 Shell Todd Oil Services triennial report, 2003-2006: On pages 14 to 21, 14 instances are noted of Petrocorp, FCET and STOS failing to provide data, with the former two not reporting anything at all. 49 Zemansky, Gil, February, 2013, Review of regulation of deep well injection under the Resource Management Act, GNS Science Consultancy report 2012/200, for TRC. 50 The TRC’s original guidelines on DWI were based on those used in Alberta, Canada. 51 Zemansky, 2013, P22. 52 Sherburn, Steven and Rosemary Quinn, February, 2012, GNS Science Consultancy Report 2012/5, Lower Hutt, “Executive Summary”, An Assessment of the Effects of Hydraulic Fracturing on Seismicity in the Taranaki Region. 53 Ellsworth, William L, July 12, 2013, “Injection-Induced Earthquakes”, Science, Vol. 341 no. 6142. Abstract: Human-induced earthquakes have become an important topic of political and scientific discussion, owing to the concern that these events may be responsible for widespread damage and an overall increase in seismicity…In particular, earthquakes caused by injection have become a focal point, as new drilling and well- completion technologies enable the extraction of oil and gas from previously unproductive formations…Micro- earthquakes (that is, those with magnitudes below 2) are routinely produced as part of the hydraulic fracturing (or “fracking”) process used to stimulate the production of oil, but the process as currently practiced appears to pose a low risk of inducing destructive earthquakes. More than 100,000 wells have been subjected to fracking in recent years, and the largest induced earthquake was magnitude 3.6, which is too small to pose a serious risk. Yet, wastewater disposal by injection into deep wells poses a higher risk, because this practice can induce larger earthquakes. For example, several of the largest earthquakes in the U.S. midcontinent in 2011 and 2012 may have been triggered by nearby disposal wells. The largest of these was a magnitude 5.6 event in central Oklahoma that destroyed 14 homes and injured two people. The mechanism responsible for inducing these events appears to be the well-understood process of weakening a pre-existing fault by elevating the fluid pressure. However, only a small fraction of the more than 30,000 wastewater disposal wells appears to be problematic—typically those that dispose of very large volumes of water and/or communicate pressure perturbations directly into basement faults. 54 Walsh, Bryan, July 12, 2013, Time, Science and Space, “Deep Disposal Wells from Oil and Gas Drilling Linked to Earthquakes”: http://science.time.com/2013/07/12/deep-disposal-wells-from-oil-and-gas-drilling- linked-to-earthquakes/#ixzz2YzeV0Yxw 55 Aguwa, Aloysius A, 2007, Universe, Lincoln, New England, US, Waste Management in the Oil Industry, P156.

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56 Taranaki Regional Council, Stratford, Chamberlain, B G, June 16, 2011, Document 908057, Response to Catherine Delahunty MP for Official Information Act Request – Hydraulic Fracturing. 57 Ministry for the Environment, Guidelines for Assessing and Managing Petroleum Hydrocarbon Contaminated Sites in New Zealand, Module 7 - Site Management: MfE describes the method as “an inexpensive option for remediating soils with petrol, diesel and waste oil, but requires a large area of land. Petrol is easily degraded and takes less time to achieve clean-up levels than diesel and waste oil…Leachate from the spraying process and stormwater run-off are collected in a sump and reapplied over the soil”: http://www.mfe.govt.nz/publications/hazardous/oil-guide-jun99/module-7.pdf 58 Harvey, Helen, March 19, 2013, “Tararua exploration waste heading for Taranaki”, Taranaki Daily News/Stuff, New Plymouth: http://www.stuff.co.nz/taranaki-daily-news/news/8441503/Tararua-exploration- waste-heading-for-Taranaki 59 Climate Justice Taranaki, May 14, 2013, “BTW breach toxic waste consents”: http://climatejusticetaranaki.wordpress.com/2013/05/14/btw-breach-toxic-waste-consents/ 60 Taranaki Regional Council, February, 2007, Shell Todd Oil Services and Todd Taranaki Limited Mix-Bury- Cover and Land Treatment Monitoring Programme - Biennial Report, 2004-2006. 61 Taranaki Regional Council, April, 2008, Todd Taranaki Ltd, Todd Exploration Ltd, Shell Todd Oil Services Ltd and Shell Exploration NZ Ltd Mix-Bury-Cover and Land-farm Monitoring Programme Annual Report – Annual Report 2006-2007. 62 Taranaki Regional Council, July, 2006, Greymouth Petroleum Acquisition Company Limited – Hawera Land-farm Monitoring Programme Annual Report 2005-2006. 63 Taranaki Regional Council, June, 2013, Greymouth Petroleum Hawera Land-farm Monitoring Programme Annual Report 2011-2012. 64 Taranaki Regional Council, undated, Guidelines for the control of disposal of drilling wastes onto and into land: http://www.trc.govt.nz/assets/Publications/information-sheets-and-newsletters/resource-consent- information-sheets/drilling+waste.pdf 65 Taranaki Regional Council, February, 2010, Boyd Land-farm Monitoring Programme Annual Report 2008- 2009. 66 Taranaki Regional Council, March, 2011, C Boyd - Drilling Waste Disposal Monitoring Programmes Annual Report 2009-2010. 67 Taranaki Regional Council, March, 2011, C Boyd - Drilling Waste Disposal Monitoring Programmes Annual Report 2010-2011. 68 Ewing, Isobel, May 15, 2013, “Two breaches by drill waste firm”, Taranaki Daily News/Stuff: http://www.stuff.co.nz/taranaki-daily-news/news/8672815/Two-breaches-by-drill-waste-firm 69 Ewing, Isobel, June 17, 2013, “How they turn oil into milk”, Taranaki Daily News/Stuff: http://www.stuff.co.nz/business/farming/dairy/8805421/How-they-turn-oil-into-milk 70 Ewing, Isobel, June 20, 2013, “Fonterra to halt future land-farm collections”, P1, Taranaki Daily News/Stuff. 71 “Concerns about mixed messages answered by Fonterra”, July 4, 2013, RadioNZ National. 72 Proffitt, Graeme, June, 2013, Review Of Petroleum Waste Land Farming, for Taranaki Regional Council. 73 P13, Ibid. 74 Wikipedia, Dec 17, 2013: TPH - Total petroleum hydrocarbon (TPH) is a term used for any mixture of hydrocarbons that are found in crude oil: http://en.wikipedia.org/wiki/Total_petroleum_hydrocarbon 75 Ministry for the Environment, April, 2012, National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health. 76 Edmeades, Doug, September, 2013, The Taranaki Landfarms: are they “Fit for Purpose”, P14, report Commissioned by Taranaki Regional Council. 77 “Nine to Noon” interview by Kathryn Ryan, December 17, 2013, Radio New Zealand, Wellington. 78 Taranaki Regional Council, May, 2011, Origin Energy NZ Ltd, Rimu Pipeline Leak, October 2010: Cause, Remediation and Learning Points.

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79 Taranaki Regional Council, July 8, 2009, Taranaki Regional Council Marine Oil Spill Tier 2 Response – AWE/Prosafe FPSO Spill – Okato Beaches, October 2007. 80 Wikipedia, July 23, 2013: The Deepwater Horizon oil spill was an oil spill in the Gulf of Mexico on the BP- operated Macondo Prospect, considered the largest accidental marine oil spill in the history of the petroleum industry…Following the explosion and sinking of the Deepwater Horizon oil rig, which claimed 11 lives, a sea- floor oil gusher flowed for 87 days, until it was capped on 15 July 2010. The total discharge is estimated at 4.9 million barrels (210 million US gal; 780,000 m3)…Three years after the spill, tar balls could still be found on the Mississippi coast. In July 2013, the discovery of a 40,000 pound tar mat near East Grand Terre, Louisiana prompted the closure of waters to commercial fishing…Numerous investigations explored the causes of the explosion and record-setting spill. Notably, the US government's September 2011 report pointed to defective cement on the well, faulting mostly BP, but also rig operator Transocean and contractor Halliburton. 81 Maetzig, Rob, May 2, 2011, “Taranaki set for deep sea drilling”, Taranaki Daily News/Stuff, New Plymouth. Rilkoff, Matt, September 29, 2012, “Drilling in the deep blue sea”, Taranaki Daily News/Stuff, New Plymouth. 82 Maetzig, June 7, 2013, “Drilling blowout emergency plan aired”, Taranaki Daily News/Stuff, New Plymouth. 83 Greenpeace, oil spill map, 2013, http://oilspillmap.org.nz/ 84 “Report confirms oil spill likely to reach beaches”, December 13, 2013, Radionz.co.nz, Wellington: http://www.radionz.co.nz/news/national/230840/report-confirms-oil-spill-likely-to-reach-beaches 85 Ewing, Isobel, February 4, 2014, “Seabed mining impact queried”, Taranaki Daily News/Stuff: A key point of concern was sediment plume resulting from extraction of sand and its effect on marine ecology and water colour and clarity. The council said the lack of light could have flow-on effects for recreational and commercial fisheries by preventing growth of the likes of phytoplankton, which formed the base of the marine food web. It also said TTR showed a lack of consideration of the long-term (up to 20 years) effects of the sediment plume, as its studies focused mainly on dredging operations lasting just one year. The impact on marine mammals was also downplayed in TTR's application on the basis that blue whales and orca were rarely sighted in Taranaki waters, the council said. 86 Chamberlain, Basil, September 19, 2012, Oil and Gas Industry Impacts - A Taranaki Perspective, address by the TRC chief executive to the New Zealand Petroleum Summit 2012, Wellington. 87 Ibid, P18. 88 Taranaki Regional Council, August, 2007, Mangati Stream Catchment Monitoring Programme Annual Report, 2005-2006, P1. 89 Conditions included: After allowing for a mixing zone of 20 metres downstream, a discharge could not cause conspicuous oil or grease films, scums or foams, or floatable or suspended materials; noticeable change in the colour or visual clarity of the water; objectionable smell; significant adverse effects on aquatic life; or make the water unusable for farm animals. The pH level had to stay within 6 and 9, oil and grease could not exceed 15 grammes per cubic metre, and suspended solids 100g/m3. Companies had to provide a contingency plan for dealing with accidents. Dates were set for reviewing the consents within a few years. For chemical surveys, the council did general sampling at up to 34 points along the stream, or tested for particular contaminants from a discharge, or set up 24-hour testing that sampled the water every 15 minutes. 90 Less than 60 is a “very poor” score for stream health measured by the presence of macro-invertebrate life, and 60 to 79 is “poor”. See Chapter 2 for a full explanation 91 Mangati 2005-2006 report, P43. 92 Taranaki Regional Council, June, 2013, Mangati Catchment Joint Monitoring Programme Annual Report 2011-2012. 93 Ibid. 94 Ibid, P179. 95 Ibid, P181. 96 The US-owned company, one of the country’s major sources of agricultural chemicals, responds to historical allegations about illegal dumping and dioxin poisoning on its web page: June 30, 2013. 97 Taranaki Catchment Commission, Minutes, August 24, 1983, from a meeting of the Permits and Planning Committee.

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker

98 Wikipedia, June 30, 2013: A phenoxy herbicide is any member of a family of chemicals related to the growth hormoneindoleacetic acid (IAA). When sprayed on broad-leaf plants they induce rapid, uncontrolled growth, eventually killing them… First introduced in 1946, these herbicides were in widespread use in agriculture by the middle of the 1950s. The best known phenoxy herbicides are MCPA,[1] 2,4- dichlorophenoxyacetic acid (2,4-D) and 2,4,5-trichlorophenoxyacetic acid (2,4,5-T). 2,4,5-T was later found to be inherently contaminated with the dioxin 2,3,7,8-tetrachlorodibenzo-para-dioxin (TCDD), and has since been banned in most countries. 2,4-D may also contain dioxin impurities, depending on the production method. 99 Taranaki Regional Council, August, 2001, Investigation of alleged agrichemical waste disposal sites in New Plymouth, Technical Report 2001-42, report by GPR (Ground Penetrating Radar) Geotechnical Services, Auckland, for Taranaki Regional Council, P34: In conclusion the results of the Council's Stage Two investigation indicate: There is no evidence that any disposal of agrichemical wastes at sites (other than those already known as disposal sites) has led to environmental contamination. In particular, no contamination was found at or near any residential property. At the known sites, this investigation has confirmed what was already known or expected to be the situation, in respect of the presence and levels of some agrichemical contaminants. There is no evidence of environmental risk at any site, or in the marine environment in the vicinity of those sites that were on the coast. No new drum dumpsites have been found. The Council at this point has no evidence that any further action is required at any of the sites investigated. 100 In 2009, a children’s playground in nearby Marfell was found to have the remnants of chemical waste drums under it, but after comprehensive testing and investigation, contamination was not considered by the TRC to be an issue. NZ Herald, June 18, 2009, “Toxins removed from Taranaki park”. 101 Taranaki Regional Council, November, 2012, Dow AgroSciences (NZ) Ltd Monitoring Programme, Annual Report - 2011-2012, PP14-15. 102 Ibid, P21. 103 Ballance Agri-Nutrients Ltd was established in 2001 after an amalgamation of several fertiliser entities, including BOP Fertiliser, which bought the Kapuni plant in 1992. 104 Taranaki Catchment Commission, May 6, 1982, Minutes, from a meeting of the Arbitration Committee. 105 Taranaki Catchment Commission, December 8, 1982, Minutes, from a meeting of the Executive Committee. 106 Taranaki Catchment Commission, January 1, 1983, Minutes, from a meeting of the Water Committee. 107 Taranaki Catchment Commission, May 25, 1983, Minutes, from a meeting of the Water Committee. 108 Taranaki Regional Council, June, 2013, “Executive Summary”, Ballance Agri-Nutrients (Kapuni) Ltd Monitoring Programme, Biennial Report - 2010-2012. 109 Ibid, P30. 110 Ibid, PP51-52: The results of bio-monitoring in the Kapuni Stream indicate that there is no significant impact in the stream as a result of plant operations. In relation to discharges to land, the high levels of nitrate in shallow groundwater are partly due to the heavy effluent application that occurred early in the life of the plant. Current application rates are considerably lower. However, nitrate concentrations in the soil profile underneath the irrigation areas remain elevated. Two concentrated ammonia plumes due to historical leaks from the effluent storage basin and from the urea plant are managed with pump and treatment systems. The contaminated groundwater is pumped back through the plant and waste treatment systems. Both plumes currently do not extend beyond the Ballance site and are monitored. They posed no short term threat to freshwater ecosystems.

Ch 8, Clearing the Water – Industry, Sept 15, 2014 – By Jim Tucker