NCOC is committed to developing a world-class project
that is designed and operated in a manner protective of
the unique, sensitive environment of the North Caspian
Sea. We conduct our operations responsibly and in full
compliance with the laws of the Republic of Kazakhstan,
and in line with accepted international regulations,
standards, and best practices.
NCOC has a policy of zero discharge into the Caspian Sea;
NCOC has a “No Routine Flaring” policy;
Our approach is one of risk management. Conceptually,
that means identifying and understanding the risks
of any action and its potential impacts; taking steps
to minimize that risk or mitigate its impacts down to
acceptable levels; monitoring performance and the
effectiveness of mitigation measures, and continually
re-checking the risks and improving the measures to
See NCOC’s General Business Policy on Health, Safety, Security & Environment - d
CASPIAN DAY 2016
NCOC regularly marks Caspian Day (12
August) as a way to honor this unique inland
sea and those who study and protect its flora
On August 10, NCOC environmental engineer
Sergey Ukhov briefed local environmental
NGOs in Atyrau on NCOC’s programs for
sampling the physical and chemical properties
of sea water and bottom sediments, hydrogeological
surveys, and other long-term
environmental baseline monitoring programs
that NCOC has carried out annually since the
start of the project. (This follows a tradition
from Caspian Day in 2015, when NCOC
presented a new book entitled “Environmental
Monitoring of the North-East Caspian Sea during
Development of Oil Fields” e summarizing results
of environmental monitoring.
And on August 7-13, NCOC jointly with
Eco Mangistau (NGO) organized the Third
Environmental Summer School in Aktau.
Thirty-four students from Mangystau and
Atyrau Oblasts – potential future ecologists
(pictured) – took master classes and handson
lessons from Russian and Kazakhstani
specialists on topics such as diving, sample
collection, Caspian seal population surveys,
and much more. (see photo)
Environmental Impact Assessments.
NCOC updated the Environmental Impact Assessment (EIA)
covering its Phase 1 project in 2016, in accordance with official
requirements, and obtained a positive conclusion from the
government’s environmental review panel. The studies developed for
the North Caspian project engaged Kazakhstan environmental expert
consultants, and have been presented to the local communities for
Baseline Studies and Monitoring.
An essential technique of environmental protection is to understand
initial conditions prior to project activity (the “baseline”), and then
to monitor these conditions on an on-going basis as the project
progresses to completion. NCOC has conducted hundreds such
studies in all areas of our activity, with involvement of external experts
and institutions. Specific studies are mentioned in appropriate sections
NCOC shares the conclusions of its environmental monitoring in many
forms: peer-reviewed academic publications, reports, public hearings,
EIAs, presentations at public and industry forums, the NCOC website,
and media articles.
NCOC provides the environmental monitoring data it collects directly to
the government agencies responsible for environmental protection, per
terms of the North Caspian PSA. These agencies ensure that the public
is appropriately informed. For example, the Department of Ecological
Monitoring of RGP Kazgidromet (RoK Ministry of Energy) publishes
monthly, quarterly and annual reports on the state of the environment
that include an appendix of analyzed data from NCOC industrial air
quality monitoring stations at Bolashak and surrounding areas.
Link to Kazgidromet 2016 Report - f
Environmental Sensitivity Mapping.
These interactive GIS (Geographic Information System) maps of
landscapes, ecosystems, protected areas and habitats collate the
data from many years of continuous environmental monitoring, and
help define the most environmentally important areas around our
operations for planning of oil spill response planning, biodiversity
preservation, future development, and more. The maps are regularly
Environmental Protection Plans.
NCOC’s environmental protection activities are guided by an
Environmental Protection Plan that is approved annually by state
environmental regulatory agencies. The type of projects included in
the annual EPP include: environmental surveys and monitoring of air,
water, soil, and biodiversity; solid and liquid waste management; oil
spill response; green spaces; and environmental education. Reports on
implementation of the EPP are submitted to the government quarterly.
6.2 Biodiversity of the Caspian Ecosystem
The Caspian Sea as an ecosystem has a high percentage of rare and
endemic species found nowhere else. Protection and preservation of
this area’s unique biodiversity is a top sustainability objective.
Policy, plans and programs.
In 2016 extensive data was collected during four marine environmental
surveys (one at each season of the year) and two onshore surveys.
These covered wildlife and plant life, bottom organisms, soil and
air quality, in order to better understand species distribution and
population dynamics of Caspian biota. Over 100 such environmental
and wildlife surveys have been conducted since the start of the project.
NCOC has developed special Biodiversity Action Plans for at all
stages of engineering and construction in both onshore and offshore
environments. Some programs are described in more detail below for
key indicator species.
The population of the Caspian Seal has been declining over the
previous century, due to various natural and anthropogenic/technical
(i.e. man-made) reasons. These include diseases, reproductive
difficulties, changes in the food chain, and changes in ice formations
as well as hunting, fouling in nets, and ship strikes. In 2008 the
IUCN changed the status of the Caspian Seal from ‘vulnerable’ to
‘endangered’ and placed it on the Red List of Threatened Species.
WHAT HAVE SEAL
SURVEYS TOLD US?
The surveys have shown that the birth rate
and location of breeding sites vary greatly
from year to year, mostly due to changes in ice
conditions and sea level, with no obvious trend
over the study period.
See NCOC Biodiversity brochure and
CISS studies for more detailed data on seal
population, distribution of pups, recorded seal
Observer reports indicate that icebreakers
rarely if ever strike seals. To put this in
perspective, CISS studies estimate that fishing
by-catch and poaching result in the death
of 1000s to 10,000s of seals each year, while
licensed hunters harvest an additional 10s to
1000s of seals.
Some conclusions are restricted by lack of
survey access to Russian sector of the Caspian.
However, whilst this may limit the scope of
scientific surveys, it does not hamper our
ability to monitor seals in Kazakhstan waters
and mitigate impacts from our shipping. In
case of need, NCOC has potential access to
satellite data, and is in touch with Russian
researchers to compare and contrast results.
The North Caspian project has taken the initiative
to launch and fund early scientific studies that
have made lasting contributions to our knowledge
of the Caspian seal, and to designing strategies for
The 2016 seal survey began on January 23 with two
days of instruction at Bautino Base for vessels’ captains
and crews on mitigation measures based on scientific
recommendations and global best practice in protection
of marine mammals. For the next five to six weeks,
seal observers accompanied the five icebreakers
coursing between Bautino Base and the Kashagan
field, mapping the haul-out sites along the navigation
routes, counting and classifying seals, and observing
their behavior during the breeding season. Observer
teams, accompanied by inspectors from the Atyrau
Oblast Department of Ecology and the Oblast Territorial
Inspectorate of Wildlife and Hunting, surveyed survey
seal concentrations by helicopter near the icebreaker
NCOC has fielded independent international and
national seal experts to monitor and study seals
every year since 2005, resulting in safer routes for
the icebreakers, contributing to preserving the seal
population in the North Caspian, and learning more
about them as a species. These experts are now mostly
experienced Kazakhstanis, with oversight by scientific
institutes in Kazakhstan and Russia.
NCOC’s Kazakhstani ecologists and wildlife specialists
attended a conference in Astrakhan, Russia in
November 2016 devoted to research and conservation
of the Caspian seal, and another in Krasnodar, Russia in
June devoted to sturgeon conservation.
All species of Caspian Sea sturgeon are now classified as ‘endangered’
by the IUCN. The native population has been impacted by overfishing
and illegal fishing, as well as damming of rivers, agricultural run-off and
In addition to studies and voluntary financial contributions in
previous years for a variety of upgrade projects, NCOC is making a
sizable contribution to fish hatcheries on the Ural River as part of its
compensation obligations to add over 700 thousand sturgeon fingerlings
to the population in coming years. On July 20, the State Ural-Atyrau
Sturgeon Hatchery in Kurilkino village released about 235 thousand
fingerlings into the Ural river, the first annual release quantity as part of
Jointly with the Association for the Conservation of Biodiversity of
Kazakhstan (ACBK), NCOC is continuing a program, launched in 2014,
to tag and monitor a small population of saiga (saiga tatarica, dwarf
antelope). Three animals were caught and affixed with telemetric collars
this year during the October 2-13 expedition in Atyrau and Mangystau
Oblasts, which allows specialists to follow their daily activities in real
time using GPS tracking. Saiga were included in the IUCN Red List of
Threatened Species in 1996 and declared critically endangered in 2002.
Enthusiasts like ACBK have in recent years rallied to help the animal,
supporting initiatives such as the 2000-hectare protected area in Issatay
District that shelters a herd of about 100 animals.
Record Number of Migrating Birds in Fall 2016.
NCOC started its annual fall-migration bird survey on September 12
with two days of monitoring on the artificial islands EPC 2 and EPC 4,
followed by a helicopter survey of the Caspian coastal area run during
four days between September 15 and October 24. The surveyors
group included NCOC and contractor ecologists and ornithologists,
and inspectors from the Atyrau Oblast Department of Ecology and the
Oblast Territorial Inspectorate of Wildlife and Hunting.
The group counted over a million birds – a record high over the past
ten years of surveys – including some of the most beautiful species
such as Flamingo (55,000), Mute Swan (133,000), Great White and
Dalmatian Pelican (6,000) and Red-crested Pochard (150,000).
Some of the largest flyways in the Eastern hemisphere pass through the
North Caspian region. Coastal shallow water habitats and wetlands in
the Ural River delta island systems are breeding and moulting grounds
and long-term stopovers for the migrating birds. The Ak Zhaiyk State
Nature Reserve in this area was designated a Wetland of International
Importance under the UN Ramsar Convention in April 2009 and, as
a result of a public-private initiative with NCOC shareholder Eni, a
UNESCO Man & Biosphere Reserve in 2012.
The fall migration survey is one of four seasonal waterfowl and shore
bird surveys that NCOC conducts every year: over-wintering, summer
nesting, and fall-spring migrations.
6.3 Discharges to Water
NCOC discharges all treated wastewater from
industrial processes and domestic sewage through
filtration screens into lined evaporation ponds,
with no discharge into surface waters, including
the Caspian Sea.
The total quantity of hydrocarbons discharged with
treated sewage and process water into evaporation
ponds in 2016 was 0.23 tonnes.
NCOC uses lined evaporation ponds as the safest
available method for managing treated process water,
and is continuing to assess the possibility of subsurface
injection, if suitable geological formations can be found.
Wastewater from industrial processes at the Bolashak
plant arises mainly from:
• H2S conversion into elementary sulfur. This water may
contain sulfur and other residual components. It is
treated in a sour gas stripping column to remove
(by up to 400 times) most of the volatile components
(e.g. H2S, mercaptans).
• Produced water, i.e., water that has been separated
from produced oil. This water may contain residual
hydrocarbons. It is treated with demulsifiers,
hydrocyclone separation, flotation and skimmers that
reduce oil content by ~40 times.
In 2016, NCOC obtained all permits for discharge
of treated process water to evaporation ponds in
accordance with RoK environmental requirements.
6.4 Non-GHG Air Emissions
In 2016, NCOC air emissions from all operations were 56%
of permitted volumes, and totaled:
637 metric tons of volatile organic compounds (VOCs)
56,408 metric tons of oxides of sulfur (SOX),
1430 metric tons of oxides of nitrogen (NOX excluding N2O), and
Compared to 2015, emissions were up in 2016 due increased gas flaring
and power production after the restart of production in the fourth quarter.
Twenty air quality monitoring stations in Atyrau oblast
operate 24/7 to measure the atmospheric levels of
various compounds and collect weather data.
Four stations are located on the perimeter of the setback
area (“sanitary protection zone”) for the Bolashak plant;
7 more are located in surrounding areas, including
Dossor and Makat; and 9 are in Atyrau city proper.
The government meteorological agency (Kazgidromet)
monitors this air quality data and publishes monthly and
annual summaries (including NCOC’s data for CO, SO2,
H2S, NO and NO2) on its website. The 2016 summary
report may be found here
Kazgidromet 2016 Report (in Russian) - f
A FLARE IS
A SAFETY DEVICE.
Flaring is a normal part of start-up and
commissioning activities. As a plant reaches
steady-state production, flaring occurs less
If you see a flare, it means safety
systems are operating as designed,
to handle temporary changes in flow
Volumes of gas flared are calculated and
reported to RoK.
SOX and NOX (reported in 6.4, above) are
possible combustion products from the
flaring of sour gas. If H2S were to arise, it is
almost always from a leak.
Case Study – Bolashak Emissions Safety
With the restart of production in the fourth quarter of 2016, local
residents and media have inquired about the air quality and safety
aspects of emissions from the Bolashak plant, in particular gas flaring.
The primary guarantor of the plant’s safety is the 7 km buffer (Sanitary
Protection Zone or SPZ) around Bolashak, sufficient to protect nearby
residents from any long-term health effects from air emissions and
providing a conservatively high margin of safety even for unplanned
events. Confidence in this conclusion rests upon careful design, studies
and computer models, government review and approvals, and finally,
recent operating experience that confirms the models.
Studies and Permits
The Environmental Impact Assessment for the project was updated
in 2016. It received a favorable conclusion from the government’s
environmental expertise review, and shows that air emissions should
remain within permitted concentrations at and beyond the perimeter
of the 7-km Sanitary Protection Zone around the Bolashak plant,
regardless of wind and weather assumptions.
Link to 2013 Kazakh National Medical University
study on Bolashak plant air emissions g
Similarly, a 2013 screening study by the Kazakh National Medical
University concluded that emissions from Bolashak plant do not pose
a health risk to nearby residents, nor those in Atyrau city, as the risk
of long-term negative effects is significantly lower than established
Furthermore, NCOC studied a scenario that is impossible in reality, but
used as a theoretical “worst case”: an H2S leak from full-bore rupture
of a sour gas pipeline. The computer model shows that people just
outside the 7-km radius may detect a smell for a time but will experience
no long-term health effects at such low levels. The smell will dissipate
NCOC also studied SO2 emissions from intense sour gas flaring at
maximum rate. We found SO2 does not exceed allowed design levels
beyond the 7-km perimeter.
Air Quality Monitoring Stations
Flaring occurred at Bolashak to deal with flow problems during start-up
on September 11 – October 20, 2013. Even under these extraordinary
circumstances, air monitoring at 7-km SPZ boundaries and nearby
villages (see Section 6.4) shows average H2S and SO2 emissions remained
far below allowed levels. The data has been published by KazGidroMet.
During the 2016 re-start and associated sour gas flaring, the average
H2S and SO2 levels likewise remained far below allowed levels. In fact,
ongoing monitoring shows consistently that higher-level short-term H2S
peaks remain far more likely in Atyrau from other routine sources not
associated with NCOC flaring than those measured near Bolashak.
H2S Peaks in October-December 2016
Hydrogen sulfide – H2S – is the air
emission compound that concerns many.
It is flammable, and highly toxic. It may be
generated anywhere that sulfur-containing
organic materials decompose in the absence
of oxygen, so is emitted naturally in marsh
gases and volcanoes (sometimes in large
quantities). It is produced also at tanneries
and pulp/paper mills, and during sour crude
oil processing and transportation.
H2S has a characteristic odor (some say
like “rotten eggs”) that can be smelled at
concentrations thousands of times less than
levels at which physical effects begin to take
place (watery eyes and nose). Even these
effects go away after a few breaths of fresh
air; H2S does not accumulate and is rapidly
passed out of the body. At ten times higher
concentration, however, the sense of smell
may be deadened and eye damage can
occur; ten times more than that are very
dangerous levels. For safety reasons, NCOC
specialists who work in immediate proximity
to wellheads, flash gas compressors and
other equipment receive special training
and personal detectors; they put on masks
and breathing apparatus where such
high concentrations are possible as an
The risk drops off quickly the further
from these locations; so do the potential
concentrations. “Maximum Permissible
Concentration” set by the Kazakhstan
government is a conservative standard,
similar to the World Health Organization’s
guidelines for short-term H2S ambient air
exposure for the public at which about half
the population may detect the smell (i.e.,
about 6 parts per billion). These levels, tens
of thousands of times less than immediately
harmful levels, are so small that electronic
instruments sometimes have trouble
accurately detecting them. False “peaks” are
common, as are short-term peaks from, for
example, a passing train.
6.5 Oil Spills to the Environment
In 2016, there were 0 hydrocarbon spills greater than 1 barrel reaching the
environment from NCOC operations (total volume: 0 barrels of oil-equivalent
NCOC places first priority on prevention of oil spills. Secondly, no matter how
confident we are of their prevention, NCOC remains always prepared to respond
quickly and fully to incidents were they to occur.
By far the best defense against oil spills is to prevent them from occurring
in the first place.
Link to 2010 Oil Spill Response brochure (English). - h
Oil spills are prevented by identifying spill risks at all project phases, from design,
to construction and operation, and ensuring that the highest safety standards are
continuously applied to mitigate those risks. Approaches include:
• Addressing the human factor. Clear procedures and work practices are established,
and monitoring and maintenance rules enforced through frequent training.
• Include early-warning and protective containment measures at the design stage, such
as the impermeable geotextile membranes and runoff collection systems used on
artificial islands offshore to prevent any hydrocarbons from reaching the Caspian Sea
• Continuous reassessment of spill risks at all locations by trained specialists, and
mitigation measures if risks are found. For example, OSR specialists are engaged when
NCOC monitors its offshore wellheads on a yearly basis using divers.
We employ a wide range of innovative technologies,
such as remote aerial observation with the use of GPSGIS
handheld units and other remote sensing methods
to monitor, map and detect oil spills as well as define
oil film thickness in both open water and ice conditions.
Computer-generated models of oil spill trajectories help
responders understand where an oil spill might spread,
depending on weather and sea conditions, and are a
fundamental part of oil spill response planning.
In combination with environmental sensitivity mapping
(see pg. 18), this helps set priorities in response planning
in order to preserve important habitat and minimize
impact on the environment. In September 2016, NCOC
conducted a ten-day survey of reed beds and special
training on their protection in the event of an oil spill.
NCOC is conducting research on spill response
techniques and tools with potential application to the
• NCOC has conducted joint research with the
Kazakhstan Institute of Oil and Gas on use of
• NCOC is currently conducting research on the
operational capabilities and related conditions for use
of in-situ burning.
• NCOC is participating in joint work to support RoK
Authorities in formalizing the related procedures and
regulatory framework needed to use these oil spill
response methods in case of incident.
OIL SPILL PREPAREDNESS REGIONAL
OSPRI, the “Oil Spill Preparedness Regional Initiative (Caspian
Sea – Black Sea – Central Eurasia)”, was established in 2003 by a
group of oil companies to promote sustainable oil spill response
capability in this region. These companies are BP, Chevron,
ENI, ExxonMobil, INPEX, Shell and Total – the latter five are
major investors in the North Caspian project. NCOC’s Crisis and
Emergency Response Manager, Gani Zharikessov (pictured), is a
deputy chair of OSPRI.
OSPRI provides the means of alignment and focus for the
involved companies to share their knowledge and resources,
giving consistent support to governments in developing oil spill
preparedness in the region. OSPRI is not an oil spill response
organization or company with resources on standby, and has no
vested interests in particular services or approaches.
The business plan is grouped into five core themes of support
- National planning
- Regional planning
- Equipment and infrastructure
- Cooperative agreements
- Training and exercising
IPIECA (www.ipieca.org) is the umbrella organization under
which OSPRI functions. IPIECA has a joint programme with the
International Maritime Organization (IMO) –
a specialized UN agency – called the Global Initiative (GI), which
promotes improved oil spill contingency planning around the
world. OSPRI is fully integrated and coordinated with the GI and
represents the main mechanism to achieve the GI’s objectives in
OSPRI also works with a wide range of other international
organizations, including International Financial Institutions, donor
agencies, UN agencies (e.g. UNEP and UNDP), the IOPC Fund,
International Tanker Owners Pollution Federation (ITOPF),
Oil Spill Response Limited and other commercial oil spill service
providers, the European Union, and the Organization for
Security and Cooperation in Europe (OSCE).
OSPRI’s regional focus assists its members to integrate and
address risks associated with their production and transportation.
This recognizes that an incident which may be geographically
distance from a business unit’s production or oil handling
operations may cause widespread and serious disruption, for
example if export routes are disrupted.
OSPRI’s 2016 report is available here. - i
NCOC maintains a comprehensive Oil Spill Response Plan that is regularly drilled,
including joint exercises with responsible government agencies. The Oil Spill Response
plan has detailed sections for incidents along the pipeline, with environmental
sensitivities identified and specific response guidelines established for each pipeline.
NCOC has a dedicated Oil Spill Response group, staffed by about a hundred fullytrained,
full-time responders, maintenance personnel, and vessel crew for a dozen
shallow draft vessels and several oil recovery barges. Tens of kilometers of oil boom,
absorbent material, floating and collapsible tanks, containers, and other equipment
have been specially procured for operating in the unique environment of the North
Caspian Sea, and are warehoused at marine support bases in Bautino and Damba (the
latter operated for NCOC under contract to KMG Systems and Services).
In 2016, NCOC conducted more than a hundred major and minor exercises at all
locations, involving training for nearly nine hundred NCOC staff and contractors.
Total quantity of waste classified as hazardous by the RoK and disposed from NCOC
operations in 2016 was 12,090 tonnes. This number includes some wastes classified as
green under Basel Convention rules, such as office equipment, wood and food waste,
spent air filters, etc.
Total quantity of waste classified as non-hazardous by the RoK and disposed from NCOC
operations in 2016 was 11,115 tonnes.
In line with our “Zero Discharge” policy in the Caspian, all waste materials from
offshore facilities are brought to shore for treatment and recycling or disposal, including
cuttings (mixed soil, rock and lubricant fluids brought to the surface as a by-product of
drilling). The solid waste is disposed by a specialized and licensed company, selected by
competitive tender, with demonstrated capability to process and dispose of the project’s
solid waste in line with our sustainability requirements.
6.7 Onshore and Offshore Surveys
NCOC implements comprehensive environmental monitoring programs to collect
offshore data and analyze the chemical composition of seawater and bottom sediments,
and to study fish, benthos and plankton populations. Since 1994 the project has
conducted about forty offshore monitoring surveys in roughly 900 different locations.
Data collected during the twice-annual surveys covers weather conditions, water quality
(salinity, nutrients, metals, etc.), bottom sediments quality (metals, total hydrocarbons,
etc.), and biological data (micro-organisms, phytoplankton, zooplankton, fish). Starting in
2013, we added air quality, birds, and additional Caspian seal studies.
NCOC conducts onshore monitoring surveys to analyze soil and groundwater quality
in Atyrau and Mangystau regions. In 2016 the project conducted ten such surveys with
thousands of laboratory-analyzed samples. The Caspian onshore area has a long history
of oil production, so the scope of onshore surveys takes into account historic activities
and data as well as current activities of nearby oil and gas developments. The soil
surveys since 2005 show a general improvement in terms of heavy metals and organics.
Groundwater surveys from 2005 to 2010 show it to be unfit for industrial or other use,
mostly due to high salinity.
6.8 Decommissioning and Remediation
Decommissioning is governed by the North Caspian Sea PSA, including detailed
planning and funding at the appropriate time. Decommissioning is planned and
executed in the same manner as any other engineering project, with each program
needing an environmental impact assessment to determine the preferred option to
apply to a particular facility.
Case Study – Sulfur Management
Processing sour gas and managing sulfur safely and
effectively is of crucial importance to the Project.
The project design calls for up to 80% of the sulfur to
be returned to the reservoir via the sour gas re-injection
systems. The remaining 20% will remain as elemental
sulfur, generated as a by-product at the Bolashak
onshore process facility.
An average of around 1.1 million tonnes per year of
elemental sulfur will be produced during the life of the
project (3,800 tonnes of sulfur per day).
Sulfur is a commodity with market value and growing
demand, and the project’s shareholders intend to sell
all that is produced. International market opportunities
are in China and the western Mediterranean as a raw
material for agricultural fertilizers. NCOC has also
worked with Kazakhstan and foreign institutes to study
prospective applications for sulfur in construction and
road-building, and as a fertilizer component for the
highly saline soils found in Kazakhstan.
Sulfur will be exported to these markets by rail through
a dedicated loading facility at Eskene West. Up to
4 million tonnes of sulfur may be stored on a temporary
basis. At the end of 2016 about 125,000 tonnes of sulfur
were in storage, pending completion, commissioning
and start-up of the rail loading facility in 2017.
NCOC is exploring economic
development options for future
Phases that, in combination with
reinjection, would reduce by up
to 90% the volumes of additional
associated sour gas to be processed.
This could almost completely
eliminate production of additional
sulfur as a by-product from these
Pure elemental sulfur is odorless and non-toxic, and
non-reactive with water or air. However, it does need to
be handled properly to reduce generation of airborne
The sulfur byproduct produced by the Project is in liquid
form. For its temporary storage, the sulfur is poured into
large (100m x 300m) solid blocks at a rate of about
7 mm per day. Once a block reaches a certain height it
is covered with a weighted polymer sheet. This prevents
the sulfur from coming in contact with wind or water.
When the time comes to transport, the blocks are remelted
and the liquid sulfur formed into tiny solid pellets
(pastilles). Blocks are not crushed, which is one measure
for preventing loose sulfur or sulfur dust.
The storage area is lined and provided with drainage to
prevent seepage into groundwater, and fully equipped
with fire- and gas-detectors along its perimeter.
A special facility cleans the rail cars within 24 hours and,
after filling with sulfur pastilles, covers them prior to