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T-PVS (2001) 70 MEDASSET: Conservation Priority for the Green Turtle (Chelonia mydas) in Turkey (2001). 1 Marine Turtle Conservation in the Mediterranean CONSERVATION PRIORITIES FOR THE GREEN TURTLE (Chelonia mydas) IN TURKEY Report for the 21 st Meeting of the Standing Committee of the Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention) Report prepared by MEDASSET The Mediterranean Association to Save the Sea Turtles Text prepared by Keith Corbett September, 2001

T-PVS(2001)70: Conservation of the Green Turtle Chelonia mydas in Turkey

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T-PVS (2001) 70

MEDASSET: Conservation Priority for the Green Turtle (Chelonia mydas) in Turkey (2001).

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Marine Turtle Conservation in the Mediterranean

CONSERVATION PRIORITIES FOR THE GREEN TURTLE (Chelonia mydas) IN TURKEY

Report for the 21st Meeting of the Standing Committee of the Convention on the Conservation of European Wildlife and Natural Habitats (Bern Convention)

Report prepared by MEDASSET

The Mediterranean Association to Save the Sea Turtles Text prepared by Keith Corbett

September, 2001

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CONSERVATION PRIORITIES FOR THE GREEN TURTLE (Chelonia mydas) IN TURKEY INTRODUCTION This paper summarises and prioritises the main points from last years MEDASSET submission to the 20th Standing Committee - T-PVS (2000) 56, and further updates the situation from the results of contracted field assessments in 2001. It is clear that the overall situation has continued to deteriorate, not least via the serious pollution incidents from Kazanli's beach edge Soda-Chrome factory, but also crucially from the lack of any progress in Turkey's implementation of Bern Recommendations 7 & 8 (1987), 12 (1988), 24 (1991), or 66 (1998). 2001 ASSESSMENT MEDASSET again funded Marine Turtle experts to re-examine the 2001 situation of the 3 key Turkish nesting sites for this critically endangered species; ie. those 3 Green Turtle sites correctly identified by WWF's 1988 research, and duly accepted by the Turkish government for necessary conservation measures. These are KAZANLI, AKYATAN, & SAMANDAG - see Figs. 1 & 2. Being aware of the serious exploitation and erosion of the beach of KAZANLI 'III', Turkey's most important single nesting site for this species, our research was extended to examine whether known site fidelity might somehow have been disrupted and nesting transferred to previously less favoured beaches to the north or south. 1. Accordingly, 36.5 Kms of potential beaches were assessed in late June on 12 surrounding sites to each side of Kazanli; Kizkalesi; Limonlu; Ayas; Erdemli (3); Cesmeli; Davultepe (2); & Tarsus (3). Perhaps predictably, only one beach was found to have Green Turtle significance (14 nests) but not in the same order of magnitude as that effectively lost from the damaged Kazanli III. This was the private Ministry of Forestry beach of Davultepe East (3 Kms), securely fenced and essentially free from public disturbance. It had apparently been overlooked during WWF's 1988 survey. Its Marine Turtle use was unknown to that Ministry but was initially well received. One other beach merits a mention for other than Green Turtle use, that of Erdemli's 300m beach owned privately by the Middle East Technical University. 9 Caretta caretta nests were found here during the sample survey period, but far more important was its increasing population of Trionyx triunguis. Not only was the beach relatively undisturbed, but previous illegal fishing offshore had now been largely returned to the 2 mile legal limit, thanks to the efforts of NGO conservationists and co-operation from local fishermen and coast guards. The lesson is clearly here for the learning! The lack of any significant Marine Turtle use of the majority (10) of the remaining beaches can be explained by the usual incidence of noted human use and abuse of beach and dune, combined with degrees of urban development of the adjacent hinterland. Returning to the update on the 3 main nesting areas : Despite their long known importance and the national obligations under both the Bern and Barcelona Conventions, no protective designations have been afforded to most if not all of the Kazanli beaches. This is completely unacceptable. Turkey's paper T-PVS (2000) 73 states that in 1999 "a section of the shore has been declared as a Natural SIT"; we have been unable to find out which and cannot understand why any one section alone would have been considered?

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2. KAZANLI - west to east (see Fig.3) BEACH IV - Immediately in front of the Soda-Chrome factory, its beach is visibly heavily polluted, apparently from direct factory discharges. The unscreened factory lights continue to cause widespread photo-pollution. Only part of the comparatively recent harbour wall/unloading jetty has been removed and its presence is inhibiting any natural ability to restore the adjacent key nesting beach of Kazanli III since scoured away. Following MEDASSET's illustrative report in 2000 of "White" turtles just offshore of the factory, two serious and successive Chromium related pollution incidents occurred in 2001. Relevant details can be read in Appendix 1, but it should be noted that it has been left entirely to NGO negotiation with the factory to try to persuade them to facilitate an independent investigation - at the time of writing (September 2001) no agreement has yet been reached. In the aftermath many marine turtles of 3 species and of various age classes were recovered dead; tissue analysis revealed some "lethal" amounts of tissue contamination by Chromium compounds. Others of the casualties may have been related to "accidental captures" by fishing, possibly trawling although some of these turtles also had large hooks in them. This cause does however conflict with the reported though recent cessation of fishing within 2 miles offshore? BEACH III - The plastic waste from horticulture and continuing agriculture have destroyed the upper beach and sand dunes (see Plates 1 & 2). The lower beach has been all but washed away by scouring (see Plate 3), while the blocking of on-shore accretion by the adjacent factory jetty prevents all possibility for recovery. This was the single densest nesting beach for the Green Turtle in Turkey with 216 nests in 1994 on its modest 0.5 Km extent. 111 nests were still laid in 1999 but in such marginal locations as to mostly guarantee their failure. Only 3 nests were found so far this June, again in an unsuitable area and with one of them having already been predated. We must assume that more, perhaps many more, nests will be attempted on the remnants of their ancestral beach this year, but with the certainty of minimal hatching success. Confirmatory data should soon be available since Italian experts have been contracted by the Government and RACSPA to further research the Kazanli nesting situation - it seems that it is always easier to facilitate research than to implement conservation measures? Unfortunately, this group is unable or unwilling to yet exchange or disseminate their data. BEACH II - Kazanli's Mayor has successfully closed the coast road; removed photo-polluting street lights; signs now give advice on nest protection; and it seems that the two mile exclusion zone for fishing is now being enforced. This has all been dependant on the personal goodwill and co-operation of a local politician. As welcome as this is, it may only prove to be of short duration given the absence of any national government input. Unfortunately, these recent improvements have been undermined by the effects of Chromium pollution, so evidenced here that swimmers reported skin ulcerations. Only one nest was found in June. BEACH I - This is the longest (2.2 Kms) of the Kazanli beaches and is relatively underused and regularly patrolled. It is also furthest from the pollution source. 46 Green turtle nests were already found in June and this may partly represent some local migration away from the wreckage of nesting beach III. 3. AKYATAN Marine Turtle conservation has still not been included within the management plan for this designated Natural SIT, either for its nesting beach or the offshore feeding area. Potentially this 22 Km beach should support the highest Green Turtle recruitment left in the Mediterranean, but this cannot be realised in the face of the continuing high and unsustainable levels of nest and hatchling predation. An initial peak of 735 nests were reported in 1998, then rising to an unsurpassed high of "1500" in 2000.

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However, methodologies are unclear and it is not known how much extrapolation might be involved, or indeed whether Loggerhead nests have been included? Whatever, nest losses alone are now running at levels exceeding 75%. The enormous fishing pressures, based at Karatas but extending (legally and illegally) to the Green's feeding and presumed maturation areas off Akyatan, and into their overwintering haven in Yumurtalik ("Turtle") Bay, are not being addressed in Ankara. Likewise, the reported problems (T-PVS (2000) 56) of plastic and chemical waste pollution, and of the adverse effects of an increasing local tourism, both continue to be ignored by the authorities. 4. SAMANDAG (see Fig.4) The many problems here were again detailed in our last year's paper : sand winning, dune loss, consequent erosion; local holiday building in sensitive locations and with associated photo-pollution; the Treasury Ministry's four storey Hotel; and the plastic waste obstructions to hatchlings etc (see Plate 4). None of these pressures have been tackled and our 2001 visits confirmed that some have worsened. The dumping of dead animals (and the associated scavenger predation on nests) has now been exacerbated by the Municipality discharging raw sewage straight onto nesting areas (see Plate 5). The reported cessation of sand winning, and the stated interest by the Mayor in turtle conservation, have scarcely been reflected by ongoing (albeit illegal) sand winning, including that directly for use by the Municipality! A noted hostility towards Turtles was now manifest by two co-incidentally recorded acts; one of the deliberate killing of a Green by a car, the other by its stoning to death during its attempted returning from nesting to the sea. This third Turkish nesting site remains without any protective designation and without even attempted remedial measures for the abuses outlined above. It is only too evident that Turkey has not applied one iota of conservation effort towards this important beach and its endangered Turtles since its official recognition in 1988. CONCLUSIONS It is tempting to say "address as recommended in T-PVS (2000) 56, but now more urgent", but the worsening situations at Kazanli and Samandag surely require a more strategic approach for this species in Turkey? If it is not considered too late for individual actions, some priority actions can be deduced, and these proposals have the full support of SEH & the IUCN's SSC Group for European Herpetofauna:- KAZANLI • Protect the beaches and offshore areas by immediate and national designation. • Ensure no possible pollution from/by the Soda-Chrome factory. • Remove the jetty and horticultural waste, and restore beach III. AKYATAN • Reduce/prevent nest predation; action as an immediate management target of the

protected area. • Remove the offshore fishing pressure here, and during winters at Yumurtalik.

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SAMANDAG • Protect the beach by national designation, including an immediate 4 Km sanctuary

covering each side of the Asi river mouth. • Remove all shoreline plastics before and during the nesting season. • Ban strictly all sand winning. The detailed paper to last year's Standing Committee from the Turkish government referred to many Marine Turtle matters but had solved almost none, and certainly none for the 3 Green Turtle areas. A National, Scientific, and Local Committee structure was outlined but seeing this year's continuing problems it would appear that that route is not appropriate for the urgent actions now needed. The results of earlier researches were liberally quoted, but again can in no way be viewed as any reason for their prolonged inaction on the conservation front. Has the Turkish government progressed the Secretariat's request for enforced protection of sites as required in Rec.66 (1998); or have they taken up the offer of necessary assistance? Both matters are minuted in the T-PVS proceedings. Most importantly, will they be able to report on any practical measures taken to further the Green Turtle conservation priorities? As an involved and concerned NGO, MEDASSET can only conclude that : Turkey has known for a long time of the conservation measures needed for this species and its habitat(s). The Mediterranean Green Turtle population has little biological time left; in contrast to immediate conservation measures, further refining research is neither needed nor justified. The Bern Convention is overseeing an extinction scenario of a large and long-lived and "strictly protected" vertebrate much more acute even than that facing the large carnivores. Further inaction would be inexcusable. Turkey must now be urged to take immediate remedial measures. REFERENCES Environmental situation and Technical Reports presented by MEDASSET to the Standing Committees of the Bern Convention on the Conservation of European Wildlife and Natural Habitats at the Council of Europe, published under T-PVS References: T-PVS (99) 74: F. Demirayak, commissioned by MEDASSET: Specific Site, Status of the Green Turtle (Chelonia mydas) on the Turkish Mediterranean Coast, 26 pages. T-PVS (2000) 56 : MEDASSET : Habitat Assessment of the Remaining Significant Nesting Areas for the Green Turtle (Chelonia mydas) on the Turkish Coast : Kazanli, Akyatan and Samandag, 13 pages.

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Fig.1

Fig.2

Fig.3

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Fig.4

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Plate 1 - Kazanli III, looking east, showing loss of upper beach and dunes to horticulture

Plate 2 - Kazanli III, looking east, showing loss of beach to marine scouring

Plate 3 - Kazanli III, looking west, showing utilisation and loss of nesting beach

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Plate 4 - Samandag, uncleared plastic waste representing a serious barrier

to hatchlings on route to the sea, also carcass of scavenged livestock.

Plate 5 - Samandag, overview of plastic waste problem, together with freshly dumped body of domestic animal. Note also the unnatural flat profile of the beach which is due to many years of sand-winning.

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APPENDIX 1. "AN ECOLOGICAL DISASTER IN KAZANLI".

M E D A S S E T P R E S S R E L E A S E

02.04.01

AN ECOLOGICAL DISASTER IN KAZANLI, TURKEY! No. 2. Preliminary Analysis Results Now Available

Dumped chemicals pose further threat to critically endangered

Mediterranean green sea turtles. On 6th March 2001, workers at the soda-chrome factory bulldozed the land bridge separating effluent basins of the factory from the sea, discharging the contents into the Mediterranean. The entire sea in front of the factory turned red, and remained so for the following days. The company involved is Soda Sanayi A.S., whose facilities include Oxyvit, a joint venture of the Sisecam Group with the Italian Cromital SPA. Products produced in the facility include Sodium and Chromium compounds. The contaminated sample from the sea in front of Kazanli had a chromium concentration above 5.4 mg/l, 13,500 times higher than the natural occurrence in seawater, and 2.7 times higher than German limits for wastewater! Chromates are estimated to be stable for 50 years in alkaline conditions, and reach the groundwater, even through tenacious soils. Chromium exists in various forms, of which Chromium (VI) is by far the most poisonous, causing skin ulceration, allergies and cancer. Oxidation reduces chromium (VI) to chromium (III), which forms complexes with DNA and is mutagenous. The chemical effluent has a high content of highly poisonous, carcinogenic chromium (VI) compounds, and is stored until oxidation has taken place. According to local reports, these hazardous chemical substances are released into the sea on a regular basis. It is logical to conclude that the factory has no alternative treatment for this highly toxic chromium effluent. This practise is against international laws for the sea, in particular the Barcelona Convention for the Protection of the Mediterranean Sea against Pollution. The Government of Turkey must take immediate steps to stop this violation. In view of the high toxicity MEDASSET (The Mediterranean Association to Save the Sea Turtles) has great fears regarding the long-term effects on the local over-wintering, visiting and nesting populations of green turtles. We sincerely hope that the relevant authorities are closely monitoring local fish catches, the seawater for bathing, and the ground water used for drinking. Please do all you can to help us gain maximum publicity for this ecological disaster. The full analytical report prepared by UMWELTBÜRO WOLF, together with some photographs and the previous press release, is available in .pdf format from : - <http://tofino.ex.ac.uk/euroturtle/medas/pdf/KazanliNo2.pdf> For further information, please contact: <[email protected]>.

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M E D A S S E T P R E S S R E L E A S E

29.06.01

AN ECOLOGICAL DISASTER IN KAZANLI, TURKEY! No. 4.

Endangered sea turtles �Disaster of the Decade�! It has taken some time, since MEDASSET�s original disclosure on 20th March 2001, of the Chromium waste dumped into the sea at Kazanli by the Soda Chrome factory, and its devastating effects on the Mediterranean green turtle population, and the entire marine and littoral ecosystem. At last the Turkish media have taken the matter up, forcing the government to address the sensitive issue, which besides its environmental aspects concerns the wellbeing of the 5,000 local inhabitants who work at the factory. So far 23 dead green turtles and 6 dead loggerheads have been washed ashore. Numbers washed out to sea or still floating along the shoreline can only be guessed at. It seems clear however that a major part of this important breeding and over-wintering population has now been decimated. Green turtles are the most endangered of the indigenous sea turtle species, with estimates of a total Mediterranean population down to few hundred. Kazanli was one of only three remaining major green turtle nesting beaches in Turkey. - Popular Turkish newspaper Hurriyet carried a major front page report with a photograph,

that can be found in Turkish on their Internet site at: www.hurriyet.com.tr/hur/turk/01/06/21/turkiye/02tur.htm

- Filiz Demirayak, MEDASSET�s sea turtle researcher in Turkey appeared on primetime Turkish TV, with live links to the Soda Chrome factory general manager, and the under secretary at the Ministry of the Environment to discuss the situation. She made some very strong points.

- Italian sea turtle researcher Monica Aureggi, who is coincidentally at Kazanli doing a green turtle assessment for the Turkish Ministry of the Environment and RAC/SPA(UNEP/MAP) has written to MEDASSET that �NOT A DAY GOES BY WITHOUT FINDING ANOTHER DEAD TURTLE WASHED UP ON THE BEACH�.

- At a recent meeting, which our Scientific Advisor and researcher Dr. Max Kasparek had at the Turkish Ministry of the Environment, it became evident that further toxic substances have been released into the sea - substances which had not been screened for in the assessment made for MEDASSET by "Umweltburo Wolf". The situation therefore seems to be much worse even than described in their report.

- Grant Darrie, Chairman of the Health, Safety and Environmental Committee of the International Chromium industry Development Association, that encourages its members to adopt best practice standards, has written to us, �Your reports indicate that the company in question carries out at least some of its activities to unacceptable and irresponsible standards, which, if verified do indeed deserve to be dealt with severely�.

The full analytical report commissioned by MEDASSET, and prepared by UMWELTBÜRO WOLF, together with some photographs and the previous press releases, is available in .pdf format from: - <http://tofino.ex.ac.uk/euroturtle/medas/pdf/KazanliNo3.pdf> For further information, please contact: <[email protected]>.

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BBC Wildlife Magazine, UK (September 2001, Vol. 19 � No. 9).

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ARTICLE TO BE PUBLISHED IN BBC WILDLIFE MAGAZINE (OCTOBER 2001 ISSUE).

ON JULY 12TH IT HAPPENED AGAIN! There has been another discharge of chrome waste into the sea from the Sisecam Kromsan Sanayi chrome processing plant at Kazanli (Turkey). The discharge has occurred onto a key green turtle nesting beach in the middle of the nesting season. In response to this, the factory declared that it was unsure if there had been a second incident or not! The factory continue to deposit 1.5 million tonnes of highly toxic waste substances next to the sea, which gives great cause for concern to the local people and the environment. In the 12 days following this recent accident, 10 sea turtles have been washed ashore dead, which has received considerable coverage in the Turkish press. After the first incident (6/03/01), an initial autopsy was carried out on one of the 23 dead turtles (6 loggerheads, 16 green turtles and 1 Trionyx) and revealed lethal levels of chromium compounds present in lung tissue. It is feared that the recent deaths may be due to this same cause. Following an International campaign by MEDASSET (who also commissioned an initial analysis of contamination), heavy pressures from the Turkish press and harsh criticism by the International Chrome Industry, the Companies top management has been persuaded to finance an independent assessment of the environmental impact of the accident on the local environment. The assessment will be carried out by an international company specializing in toxic EIA (Environmental impact). The assessment has the full support of the DHKD (Society for the Protection of Nature), a Turkish NGO who have been commissioned to initiate this assessment: MEDASSET has been helping to locate a suitable international company. ---------------------------------------------------------------------------------------- Mediterranean Association to Save the Sea Turtles - MEDASSET 24, Park Towers, 2 Brick Street, London. W1J 7DD - UK Fax: 0030 10 3613572 E-mail: [email protected] E-mail: [email protected] URL: http://www.euroturtle.org/medasset ----------------------------------------------------------------------------------------

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APPENDIX 2: Report by Prof. Dr. Jaeger of Umweltbüro Wolf

UMWELTBÜRO WOLF Kazanli Environmental Pollution

Kazanlı Environmental Pollution in March 2001 Report on the chemical analysis of samples

Preliminary results of a rapid assessment

Report prepared by

UMWELTBÜRO WOLF

March 2001

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Umweltbüro Wolf Kazanli Environmental Pollution

1. Introduction Environmental pollution According to information given by the Mayor of the Municipality of Kazanlõ, Mr. Kenan Yõldõrõm, on 6th March, 2001: Workers at the soda-chrome factory bulldozed the land bridge which separated waste retention basins on the premises of the factory from the sea, and discharged the contents of the basins into the Mediterranean Sea. The entire sea in front of the factory subsequently turned red, and remained so for the following days. 2. Background to the Soda-Chrome factory The factory from which the chemical effluent has been dumped into the sea is Soda Sanayi A.Ş., an industrial facility that was built by Şişecam at Kazanlõ near Mersin between 1975 and 1984. A wide range of products are produced in the facility, including the following: • sodium bicarbonate (soda) • refined sodium bicarbonate • sodium silicate • chromic acid • basic chromium sulphate (Tankrom® SB, Tankrom® OB) • chrome syntan The factory facilities of the soda-chrome factory also include the facilities of Oxyvit, a joint venture of the Şişecam Group with the Italian Cromital SPA. The products include: • Menadione dimethylpyrimidinol bisulphite a • Menadione sodium bisulphite 2.1 The toxicity of products In the website (www.sisecam.com.tr) of the Soda Sanayi A.Ş. factory the following information is given for safety precautions while handling some of the products, for example: • Sodium Bichromate: It will irritate the skin and respiratory tract and is a severe irritant to

the eyes. It is toxic if swallowed. Do not breathe dust. After contact with skin wash immediately with plenty of water.

• Chromic Acid: It is a strong oxidizing agent both as a solid and in solution. Contact with the skin is potentially harmful as it may cause skin ulceration. Contact with eyes, clothing and inhalation of the dust should be avoided. In the case of contact, wash with water; for eyes, irrigate with copious quantities of water, seek immediate medical attention.

• Tankrom (chromium sulphate): Harmful effect on skin and eyes. After contact with skin wash immediately with water. Avoid breathing the dust.

3. The water analytics Two water and two mud samples where taken from Kazanli on 13.3.2001 and sent to Germany to be analysed by �Institut Prof. Dr. Jaeger�, one of Germany�s renowned laboratories for environmental analysis. The institute is accredited according to EN 45001. The chemical analyses were done according to internationally recognised standards: DIN EN ISO 11885 (E22), DIN 38405 � D24, and DIN 38414 � S2. In the first step, the samples were screened for chromium. Further analyses are being processed.

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Umweltbüro Wolf Kazanli Environmental Pollution

3. 1 Water and mud analytics and their condition The four samples - two water and two mud samples: sample 1 water sample (liquid), yellow colour, taken from a channel before

entering the basin and the sea sample 2 water sample (liquid), reddish colour, taken from the sea in front

of the soda-chrome factory sample 3 mud sample, black colour sample 4 mud (loam), greenish inclusions 3.2 Analysis and results chromium (total) chromium(VI): chromate sample 1 (water) 1,430 mg/l 1,310 mg/l sample 2 (water) 5.4 mg/l <0.05 mg/l sample 3 (mud) 11,700 mg/kg <0.05 mg/kg sample 4 (mud) 9,200 mg/kg 152 mg/kg The water samples from the factory which have bean taken from the water run-off into the Mediterranean Sea gives us the following situation, both the highly toxic chromium(VI) content and the total chromium amount was determined in the water samples. The highly toxic chromium(VI) was found in significant concentrations both in effluents to the sewage retention basin, and in mud around the basins. Sample one is with 1,310 mg/l, extremely high in chromium (VI) chromate. In contrast to chromium(VI), the total chromium amount is very high in all samples that where taken at the water run-off (by the factory) into the Mediterranean Sea from Kazanli. It was highest in the effluents to the waste retention basins, but still was 5.4 mg/l chromium in the sea in front of the factory. The latter value exceeds even the upper limit that is allowed e.g. in Germany for waste water. The chromium amount of the sea is 2.7 times higher than what is allowed in Germany for waste water. The high concentration of chromium is particularly noteworthy in the mud along the sea shore: concentrations of up to 11,700 mg/kg exceed by far what is acceptable in western countries even for sewage sludge. Chromium also occurs naturally in sea water, the concentration there is 0.0002�0.0006 mg/l, Sample No. 2 which was taken from the sea in front of Kazanli after the contaminant water was released in to the sea, had a concentration of chromium from 5.4 mg/l which is 13,500 times higher than the natural concentration that occurs in the sea water. This sea water is hazardous with these substances. Table. Concentration of various chemical elements in sample no. 2 (sea water). element concentration in mg/l aluminium 40 barium <0.05 beryllium <0.5 boron 6.0 cadmium <0.05 calcium 180 cobalt <0.5

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Umweltbüro Wolf Kazanli Environmental Pollution

copper <0.5 iron 10 lead <0.05 magnesium 1,400 manganese 0.1 nickel <0.5 silicium 38.0 strontium 9.0 titanium 0.8 vanadium 14.0 zinc <0.5 zircon <0.5

4. Environmental standards Many countries and organisations allow chromium only to an upper limit of concentration. The following tables give examples of thresholds for chromium in some countries. 4.1 Water Chromium sector country/organisation upper limit drinking water Germany 0.050 mg/l World Health Organisation 0.050 mg/l ground water Netherlands 1.000 mg/l waste water Germany 2.000 mg/l

4.2 Soil Chromium sector country/organisation upper limit soil (general) Switzerland 75 mg/kg sewage sludge Germany 1200 mg/kg Switzerland 1000 mg/kg European Union 20�40 mg/kg compost Germany 100 mg/kg Switzerland 150 mg/kg

4. 3 Background information: chromium Chromium exists in five different forms, from chromium(II) to chromium(VI). Chromium(VI) is by far the most poisonous form, and is 100 to 1000 times more poisonous than chromium(III). Chromium(VI) causes skin ulceration, allergies and cancer. Through oxidation processes, chromium(VI) is reduced in the human body to chromium(III), but the body may nevertheless be harmed by the oxidation process. Chromium(III) cannot pass cell membranes, but forms complexes with DNA and is thus mutagenous. As regards environmental behaviour, chromium(III) compounds can be said to have a high degree of stability in contrast to chromium(VI) compounds. Refuse containing chromium should generally be critically viewed in particular on account on its behaviour in the geological substrate on waste tips and on the bottom grounds. Chromates are estimated to be stable for 50 years in an alkaline milieu even through tenacious soils to reach the groundwater. The incineration of sludges containing chromium(III) should therefore be avoided on account of possible chromate (chromium(VI) formation.

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Umweltbüro Wolf Kazanli Environmental Pollution

4.4 Barcelona Convention Chromium is listed in Appendix II of the Protocol against Pollution from Land-based Sources in the Mediterranean Sea under the Barcelona Convention (Convention for the Protection of the Mediterranean Sea against Pollution). Pollution caused by the substances and sources listed in this appendix is severely restricted. The Government of Turkey is party to the Barcelona Convention and signed the relevant Protocol (publication in no. 19404 of the Official Newspaper, Resmi Gazete, on 18.3.1987). The discharge of chromium by the soda-chrome factory at Kazanli is thus a flagrant violation of the Barcelona Convention and must be prosecuted by the Government of Turkey according to international law. 5. Evaluation and Conclusions The soda-chrome factory at Kazanlõ/Mersin produces chemical effluent with a high content on highly poisonous, carcinogenic chromium(VI) compounds. This sewage is stored in sewage retention basins close to the sea, apparently until an oxidation process has taken place, and until the highly toxic chromium(VI) compounds are reduced to chromium(III) compounds which are less toxic, but still mutagenous. These hazardous water substances (chemical substances) were released into the sea on 6 March, 2001. According to reports by local people, this happens on a more or less regular basis. An overall assessment needs to be undertaken immediately in order to find out the full extent of the water pollution in the Mediterranean sea at Kazanli, in particular on: • substances discharged into the sea other than chromium • how often does the factory discharge chromium into the sea • the overall contamination of the sea water and the sea ground with chromium and other

substances also from previous discharges of chemicals waste water Also some more questions should be answered: Does the factory have a waste water purification program? What is the (annual, monthly) waste water amount and waste water type? What kind of waste water purification measurements are undertaken by the factory to purify waste water? Who has the waste water control? What kind of waste water drainage exists at the factory? Is there a waste water management? Is there a waste water monitoring system? Who gets the results of the waste water analysis? Who is responsible for control and supervision? Are there any waste water administrative regulations? Immediate steps are recommended:

There should be no more fishing in a proposed radius of 25 km around the water run-off from the factory until the full scope of the water pollution has been cleared There should be a complete survey of the pollution caused by chemicals released from the soda-chrome factory in the area around the factory. The survey should in particular include the sea, the sea bottom and the ground water from which the Municipality of Kazanlı gets its drinking water. The impact of the pollution on marine organisms should be studied, including the impact on the threatened green turtles, Chelonia mydas, for which Kazanlı is one of the few nesting and wintering sites in the Mediterranean.

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Umweltbüro Wolf Kazanli Environmental Pollution

From the information available it seems that the soda-chromium factory has for the highly toxic chromium sewage no other treatment system than to store chromium(VI) in sewage retention basins until the chromium is reduced to chromium(III), and is then released into the sea. The discharge of high amounts of chromium into the sea, which apparently takes place regularly, is against international laws for the sea, in particular against the Barcelona Convention (Convention for the Protection of the Mediterranean Sea against Pollution). The Government of Turkey has to take immediate steps to stop this violation of the Convention. The plot where the soda-chrome factory is situated was found to be heavily contaminated with chromium. The contaminated mud (soil) apparently has to be treated as hazardous waste. The waste management board should take immediate steps towards a safe disposal of the toxic soil and waste water. Precautionary measures should immediately be taken.