Soil & subsurface water protection and site restoration

Soil and subsurface water contamination is critical issue in the oil & gas industry. As non-renewable resources that play various roles ranging from natural functions to socio-economic and cultural ones, soils and subsurface water need to be protected and managed in a sustainable way to preserve their functions as well as to be restored in case of degradation to a level of functionality consistent with intended uses. The hydrocarbon and petrochemical operations of MOL Group companies and its legal predecessors have caused pollution to the soil and groundwater at several locations over the past decades, and management of these sites falls under the scope of our environmental liabilities.

Overall Goal

The main goals of the soil and subsurface water protection activities of MOL Group are to protect human health and the environment, to prevent the spread of contamination, to enable redevelopment, and to limit liabilities.

Experience gained over the past decades has fully confirmed that prevention is critical, thus our priority is to ensure permanent monitoring of the environment in addition to continuously modernizing and controlling our equipment. This outstanding focus can enable us to obtain in–time information on any eventual emergency or pollution events caused by third parties, and helps to quickly and efficiently minimize damages arising from such events.

Though remediation and recultivation action is the clearly the first priority, it is also very important that the causes of events are appropriately analysed, and the results of such analysis are fed back into the technical and administrative processes of the control / audit systems.

Legal environment

There is no harmonized policy yet in terms of contaminated land at the European level. Countries developed different approaches to tackle contamination issues taking into account their industrial footprint, general regulatory framework, economical context. In order to overcome this, a Soil Thematic Strategy (including a proposal for a Soil Framework Directive) has been adopted by the European Commission with the objective to provide a comprehensive common framework, but to date the Council has not yet reached a common position.

Due to this fact, in MOL Group’s operations, there are countries where the contaminated land issue is not covered, no national legislation covering contaminated land issues and some general principle may be included in environment laws, such as the polluter pays principle. In other countries, where MOL Group is active, a specific contaminated land regulation is in place, with mature remediation market, and extensive techniques experiences. MOL Group expects that the relevant practices will be gradually adopted into the national laws, in accordance with the European Union integration efforts. According to the objectives determined in the 7th Environment Action Programme (2014), MOL Group is fully committed to a risk-based approach according to which the necessity for remediation and/or for risk reduction activity is based on a site-specific risk assessment that takes into account the future use of the site, the nature of pollutants and the dispersal and exposure potential of the substances involved. It is widely recognized that this approach is the most resource-effective way to manage soil and groundwater impacts.

MOL Group reviewed its HSE Management system in 2017 in order to develop good practice, to summarize commonly accepted principles, approaches and methodologies. The risk-based management framework is used to address the actual or potential adverse impact(s) of a contaminant present in the soil and/or groundwater on human health and the environment by evaluating the linkage between release of a chemical from a source; the transport or exposure pathway; and the exposure to, and uptake of, the chemical contaminants by the receptor. The risk assessment methodology follows a staged approach, designed to ensure that key elements are addressed in succession and only as needed. The three main stages are the site Characterisation & Assessment, Corrective Action Feasibility & Design and the Corrective Action Implementation & Aftercare.

Knowledge and experience sharing, following industry and group guides and best practices are most critical management techniques in order to implement an efficient remediation program on group level.

Remediation of demages inherited from past operations

Management of damages inherited from past operations is significantly more difficult than the remediation of new events. MOL Group has sites which have been in industrial use for more than 100 years. As the task is huge and complex, we have a Group-level program for coordinating and harmonizing remediation activities. The parent company laid down the foundations for this program and takes great care to ensure that the remediation of liabilities of new member companies can also be implemented within the same framework and according to a pre-defined timeline, as a key part of our business culture. This is how similar remediation programs have been implemented and closed, or are successfully in process in Slovakia and Hungary in the territory of refineries, petrochemical facilities, logistic depots and service stations. We wish to use the same or similar guidelines in MOL Group Italy and with INA, the Croatian petroleum giant.

All remedial work is carried out in accordance with the applicable current standards and regulations, and in co-operation with local authorities and communities.

The group-level soil and subsurface protection activities consist environmental assessments, investigations of known or suspected contaminations, designing of remediation solutions, active clean-up works and monitoring efforts. In the case of active remediation, the typical remedy is ‘pump & treat’ for contaminated subsurface water, and in-situ, ex-situ extractive and the bioremediation technologies for contaminated soil.

In 2017 the annual cost of soil and groundwater protection activities was HUF 2261 million (USD 8.3 million), which is 82% of planned expenditure. The most significant remediation activities were implemented in Logistics and Refining business sectors. Provision for Environmental Expenditure is made for the estimated cost of the remediation of past environmental damages, primarily soil and groundwater contamination, and the disposal of hazardous wastes in Hungary, Croatia, Slovakia and Italy.

In Hungary the ‘Necklace project’, the remediation hydraulic system at the Tisza site started its test run in 2017. The second protective line implementation is ongoing.

In Croatia INA finished its Contaminated Land Management strategy development. INA continued the preparation for the redevelopment of closed Mlaka site last year.

At the Slovak operational sites in 2017, the construction phase of the “Little Danube” project was started. The goal is to install monitoring equipment in order to improve leak-detection capabilities.

Environmental due diligence

In case of merger and acquisition, it is critical to understand the potential liability for the soil and groundwater status. In the due diligence approach environmental due diligence is a significant work stream, which shall be performed in order to avoid the unexpected risk coming from past contamination.

Site restoration

At international upstream operational sites, the supervision of site restoration project in Oman completed last year.

Research project for innovative technology

The scope of our innovation research project fits the international trend that remediation operations are encompassed by ideas about sustainability. Our participation in international professional organizations can enable us to follow the said efforts, and, when evaluating any remediation options, to consider future economic, environmental and social benefits based on a standardized system.