Policies
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. Contractors and suppliers are obligated by
their contracts with NCOC to adhere to our Health,
Safety and Environmental policies in all aspects of
their work with us.
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;
and continually re-checking the risks and improving
the measures to address them.
Programmes
Important environmental compliance and
protection programmes include Environmental
Impact Assessments, baseline studies and
monitoring, and environmental sensitivity
mapping.
Availability
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,
media articles and company brochures.
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 Kazhydromet (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 air quality monitoring stations (AQMS)
in Atyrau region.
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: environmental surveys and
monitoring of air, water, soil, and biodiversity;
UPDATE ON GREEN SHELTER BELTS
“Green Shelter Belt” is a project approved by the Atyrau Oblast Department for Natural Resources and
Nature Use Regulation to plant trees and shrubs around the Bolashak plant as emission-absorbing
buffers.
Experience shows that few trees survive conventional “open” planting in the highly s aline soil and
scarce groundwater around the plant. So in the fir st phase of the project between Samal Camp and the
plant, 4,000 trees were planted in 2018 in 19 modules, each c onsisting of six 180-meter PVC-insulated
trenches filled with imported soil. Each module has its o wn drip irrigation system, which delivers
recycled
wastewater directly to the roots. Seedlings with closed root system were supplied by local tree
nurseries:
common ash, Siberian pea-tree, large-leaved elm, and Caspian willow. Tree survival performance has now
reached about 70%.
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.
Environmental Support Team
Environmental specialists are embedded with
the Operations departments onshore, offshore,
and at Bautino Marine Suppor t Base to verify
and consult on compliance with environmental
laws and regulations. The Teams conduct
daily inspections (announced, as well as
unannounced), do “toolbox talks,” and help with
the environmental aspects of managing process
changes, incident response, emission permits,
monitoring, and reporting.
5.2. 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 programmes
Four marine environmental surveys (one at each
season of the year) and two onshore surveys
are carried out each year. 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 200 such environmental and wildlife
surveys have been conducted since the star t of
the Project.
In view of the environmental sensitivity of the North
Caspian Sea and Ural River delta, the North Caspian
Project was allowed to proceed in 1993 as a result of
a government decision, based on special ecological
requirements developed by a group of Kazakhstan
scientists and experts. The decision established new
protected areas along the coast, and recommended
seasonal restrictions on operations that NCOC
follows in order to allow for migration, feeding and
breeding patterns of commercial fish species, birds,
and seals. The protected areas have been expanded
over the years: in 2012, as a result of a publicprivate
initiative with NCOC shareholder Eni, the
Ak Zhaiyk State Nature Reserve was designated a
UNESCO Man & Biosphere Reserve.
Hunting and fishing is prohibited at all NCOC
facilities, with exception of scientific fish catches
during Company environmental survey activities.
NCOC has developed special Biodiversity Action
Plans for all stages of engineering and construction
in both onshore and offshore environments. Some
programmes are described below for key indicator
species. (More detailed information may be found
this year in the new NCOC brochure “Environmental
Surveys and Initiatives.”)
Caspian Seal
As we have done every year since 2005,
NCOC conducted a seal sur vey in 2018, using
Kazakhstani experts with oversight by scientific
institutes. The 2018 seal sur vey began on
January 26 and lasted till March 8. At various
times eleven seal monitoring volunteers from
NCOC were on board of ice-breaking vessels,
helping the seal experts to cover the route
between Bautino Base and the Kashagan field
area on the icebreakers Mangystau-3 and
Tulpar.
In addition to gathering scientific data, onboard
observers help the ship captains avoid
seals, in compliance with the mitigation
recommendations
developed at the star t of
the project by marine mammal exper ts. This is
complemented with helicopter reconnaissance
flights over seal accumulation areas. The
reconnaissance results are reported directly
to the icebreaker, where captains and seal
observers select the safest navigation route to
protect the animals. Thermal imaging cameras
have been mounted in recent years on all icebreakers
used by NCOC. These cameras enable
observers to “see” seals day or night, in blizzar d
or fog, at a distance hundreds of meters from the
vessel, which allows detouring around the seal
nursery areas in advance.
The observer teams were accompanied by
inspectors from the Atyrau Oblast Department
of Ecology and the Oblast Territorial Forestry and
Wildlife Inspectorate.
Fish
Catch assessment surveys are regularly performed in
offshore project areas in spring, summer and autumn.
Tissue samples from sedentary indicator fish species
(goby) are randomly tested for hydrocarbons and
heavy metals.
Sturgeon is the most valuable fish in the Caspian
Sea. It is now endangered, with Caspian states
agreeing in 2014 to prohibit commercial fishing
in order to restore the populations. The Operator
supported the commissioning of a sturgeon
hatchery on the Ural River delta in 1998, at the very
beginning of our project, and has continued to fund
studies and contribute to hatchery upgrade projects
over the years. In 2018, NCOC financed capital
improvements for water supply to the Ural-Atyrau
Sturgeon Hatchery, and sponsored their specialists
to attend IV Scientific Conference on sturgeon
population protection and reproduction held in
Kazan, Russia.
Also in 2018, NCOC completed a three-year offset
programme of the fish damage compensation
measures to release more than 700,000 “fry” ( juvenile
fish), with the aim of contributing to the sturgeon
population.
ADDITIONAL MEASURES TO PROTECT BIRDS
NCOC has been experimenting with “bio-acoustic” bird repellant devices at one of its evaporation ponds
near
Bolashak plant. The devices broadcast the cries of raptor species and distress calls from migrating
waterfowl, and
were judged effective at scaring away birds that might settle on the natural-looking pond surface. In
2019, the
devices will be tested at the offshore islands, to avoid instances of bird collisions with the steel
structures.
2018 Bird Surveys
Every year, over 280 species of birds migrate along
flyways from Eurasia and Siberia to Africa and India,
with long stopovers for shelter and rest in the reedy
wetlands of the North Caspian.
The Operator has conducted annual and regular
seasonal bird studies since 2000: two annual surveys
during the regular seasonal migrations (in spring and
autumn), a survey of nesting colonies in near-shore
areas during mating season in summer, over-winter
monitoring of aquatic and semi-aquatic birds, and
observations around onshore and offshore facilities,
and during summer nesting period.
The surveys cover a vast area from the Volga River
delta in the west to the Emba River delta in the east,
from Atyrau in the north to Aktau in the south.
The surveyor groups include NCOC ecologists and
lead ornithology experts of Kazakhstan, and inspectors
from the Atyrau Oblast Department of Ecology and the
Oblast Territorial Forestry and Wildlife Inspectorate
In 2018, the population density of birds during
autumn migrations remained high. In fact, 544,000
birds were counted during the survey in October, more
than ever before. At 91,000, the population of one
key indicator species, the mute swan, was the highest
recorded since 2000. The spatial distribution of birds is
changing, with Komsomolets Bay in the east practically
dry due to declining sea levels, and attracting fewer
flamingo and mute swans. The same may be said of
the Emba delta and the area between the Volga and
Ural River deltas. This led to higher concentrations of
birds observed in the warm, shallow waters around the
Seal Islands, where protective cover abounds.
CASPIAN SEA LEVELS
The shallow northeast portion of the Caspian Sea is well-known for its variability. The average depth
here is only
about 3 m, so even relatively minor changes can make a big difference to safety of navigation. And since
NCOC
relies on vessels to supply the offshore islands and to evacuate personnel in the event of emergency,
the water
depth has a direct impact on our ability to continue to safely produce oil.
NCOC has a specialized ice and hydrometeorology department that constantly monitors the level of the
Caspian
using the equipment of our own hydrometeorological stations, and conducts research to model and predict
the
potential for sea level fluctuations.
This analysis shows that average sea level in the northeast Caspian has been declining steadily since
2005, and is
now more than a meter less than it was a decade ago. Significant inflows of fresh water from the Volga
are being
offset to some extent by increased evaporation and less-than-average precipitation.
The average sea level around Kashagan was slightly shallower than the average value for the Caspian due
to the
wind effect on shallow seas in this area, which can periodically “pile up” the water in the downwind
direction.
One of the largest ever such wind effects was observed in November 2018, when the sea level around
Kashagan
dropped 75 cm below its average value (see satellite image from 13 November).
5.3. DISCHARGES TO WATER
NCOC uses lined evaporation ponds as the
safest available method for managing treated
industrial water. (See the Case Study on
Evaporation Ponds.) Treated wastewater from
industrial processes and domestic sewage
is discharged through filtration screens into
these ponds, and the water is removed by
evaporation.
The total quantity of hydrocarbons discharged with
treated domestic wastewater and industrial water
into evaporation ponds in 2018 was equal to 15.95
tonnes.
NCOC obtained all permits in 2018 for
discharge of treated water to evaporation
ponds in accordance with RoK environmental
requirements, with one exception discussed in the
Case Study.
As noted in the section on Fresh Water, NCOC
intends to build an additional wastewater processing
facility at Bolashak in 2019 that will maximize our
capacity for recycling water from technical and
industrial processes.
5.4. NON-GHG AIR EMISSIONS
The primary air emission sources at NCOC’s facilities are
the flare unit, gas turbines, boilers and diesel generators.
The flare unit is a part of any oil and gas
production facility and functions as a so-called
“relief valve” of the plant. A small ignition flame
burns at all times, to ensure ready combustion.
The flare unit height is designed t o maximize
dispersion of combustion products in the air.
Power is supplied to onshore and offshore
facilities by gas turbines running on associat ed gas
produced from the field. The turbines are equipped
with special burners designed to reduce nitrogen
oxide emissions. Boilers produce steam, heat water
and provide space heating for buildings. Boilers
run on fuel gas but diesel fuel can also be used.
Diesel generators are used only for stand-by pow er
generation.
In 2018, NCOC non-GHG air emissions from all
operations were 21% of permitted volumes, and
totaled:
-
943 tonnes of volatile organic compounds (VOCs),
-
27,949 tonnes of dioxides of sulfur (SO2)
-
2550
tonnes of oxides of nitrogen
(NOx excluding N2O,
which is reported under GHG Air Emissions).
Compared to 2017, VOCs and NOx emissions were
about the same, in the context of a 60% increase in
oil production. SO2 emissions were down sharply due
to a forty percent decrease in flaring volumes over
the reporting period.
Air monitoring is an important part of NCOC’s overall
industrial environmental monitoring programme.
There are several components, including:
Under-Plume Monitoring
Periodically, under-plume monitoring is conducted,
using a specialized vehicle with air sampling and
meteorological instruments to drive under the flare
flame and collect samples identifying the emissions.
Monitoring at Emission Sources
Maximum permissible emission (MPE) rates that
NCOC is required to comply with are calculated
for each emission source. Measurements of actual
emissions from a source are made instrumentally.
For example, the exhaust stacks at lar ge emission
sources are equipped with special sampling
ports that allow inser ting a gas sampling probe
and pitot tube on a periodic basis to take
measurements of nitrogen oxides, sulfur dioxide,
carbon monoxide, gas flow velocity, pressure and
temperature.
Air Quality Monitoring Stations
20 air quality monitoring stations in Atyrau oblast
operate 24/7 to measure the ambient atmospheric
levels of various compounds and collect weather
data.
H2S OVERLIMIT CASES IN 2018 20-MIN AVERAGED DATA
Note 1: This diagram shows only H2S. In addition, NCOC air quality monitoring stations
register CO,
SO2, NO and NO2 levels. Note that SOx
and NOx are possible combustion products from the flaring of sour gas. If H2S were to arise, it
is almost
always from a leak.
Note 2:
“Maximum Permissible Concentration” set by the Kazakhstan government is a conservative standard, 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, carrying crude oil.
4 stations are located on the perimeter of the
7-km 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 Kazhydromet monitors
this air quality data and publishes monthly and
annual summary bulletins on its website. On-line
access to the data is also provided to the Atyrau
Oblast Department of Natural Resources and Nature Use Regulation.
Hydrogen Sulfide
Hydrogen sulfide (H2S) is another non-GHG air
emission. It is flammable and highly toxic, and has
a strong, unpleasant odor. 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 during sour crude
oil processing and transportation.
NCOC specialists who work in immediate proximity
to wellheads, flash gas compressors and other
equipment receive special training and personal
detectors. They wear masks and breathing
apparatus as a precaution in areas where high H2S
concentrations are possible as an
occupational
hazard. The risk drops off quickly the further from
these locations; so do the potential concentrations.
NCOC can state with confidence that the Bolashak
plant is safe for the public. The primary guarantor of
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, multiyear
studies and computer models, government
review and approvals, and finally, recent operating
experience that confirms the models (see figure). As
in years past, on-going monitoring in 2018 shows
consistently that short-term H2S peaks (from 1 to 20
minutes in duration) remain far more likely in Atyrau
than near Bolashak. The competent government
agency for air monitoring RSE Kazhydromet
confirmed there were no cases of high– (VZ) or
extremely-high pollution (EVZ) registered around
Bolashak in 2018. See the report “Informational
Bulletin on the Condition of the Environment of the
Republic of Kazakhstan, 2018” (www.kazhydromet.
kz), in which the data from all twenty NCOC air
monitoring stations is published in summary form.
Case study
WASTEWATER AND LINED
EVAPORATION PONDS
Wastewater
There are three types of wastewater streams generated at North Caspian Project facilities: domestic
(including
sewage), stormwater, and industrial wastewater from technical processes and production activities.
Domestic wastewater from D-Island and Living Quarter Barges offshore is treated in a special compact
system
that combines biological treatment with membrane filtration, resulting in water clean enough to re-use
for
many purposes. Despite higher costs, this wastewater is collected in dedicated tanks and transported by
barge
to onshore facilities in Mangystau Oblast for disposal, in line with NCOC’s “Zero Discharge Policy” into
the
Caspian Sea.
Industrial wastewater from D-Island is also transported to shore, where it is treated to remove oils and
suspended solids. An additional onshore treatment step, installed in 2017, dissolves air into the
wastewater and
skims off the contaminants as they attach to finely dispersed air bubbles rising to the top, thus
removing up
to 99.9% of oil products and 97% of suspended solids. The treated wastewater is then discharged into
lined,
isolated evaporation ponds at the Koshanai Waste Management Facility near Bautino Base.
Wastewater is handled in largely the same way onshore at the Bolashak plant. Domestic wastewater
generated at
the camps and onshore facilities is biologically treated and used for dust suppression and irrigation in
summer,
and any excess is disposed in evaporation ponds within the Sanitary Protection Zone.
Some wastewater has been brought up from the subsurface with the crude oil (produced water), or has come
in contact with the oil during processing, and contains residual hydrocarbons. It is treated with
demulsifiers,
hydrocyclone separation, flotation skimmers, filters and a sour water stripper operating in batch mode,
reducing
oil content by a factor of 35-36 prior to the wastewater being sent to the evaporation ponds.
A large volume of wastewater is generated from technical processes. Treatments used here include the
Sour
Water Stripper, which uses low pressure steam to remove hydrogen sulfide and other residual components
from
the water used in processes to “sweeten” produced liquids. Additional technical wastewater processing
capacity
came online in 2017 that allows the water to be recycled (returned for re-use in the processes) rather
than
being discharged as waste. Recycling has allowed us to reduce by up to 50% the amount of water needed to
be
withdrawn from the Astrakhan-Mangyshlak pipeline for plant needs.
Evaporation Ponds
The treated wastewater streams are then sent to the artificial evaporation ponds at Bolashak. There are
nine
such ponds in a 3x3 grid, each section roughly 250 by 500 m in size and 3 m deep. The ponds are
completely
isolated from surface waters, with sloping concrete banks and lined on the bottom with multiple layers
of an
impermeable geo-textile membrane to prevent groundwater contact through seepage.
Once discharged, the wastewater is evaporated by solar energy, leaving behind solids/salts in sludge
form and
returning clean water to the water cycle as vapor. Compared to underground injection, which removes the
water from the water cycle, the evaporation pond is an economic, low-carbon solution suitable for hot
and
dry regions where solar irradiation is high. (Underground injection is also a best practice disposal
method,
however, no underground aquifers have been found in the vicinity of Bolashak suitable for wastewater
discharge.)
The wastewater may contain some volatile fractions – i.e., contaminants including trace methanol that
will
evaporate from the pond surface as vapor – but according to studies called atmospheric dispersion
modelling, it
is known that these are well within allowable limits at the boundary of the Sanitary Protection Zone.
Methanol
Methyl alcohol (methanol or “wood alcohol”) is one of these volatile fractions. It is added to the oil
offshore to
prevent hydrate plugs in the pipeline, and is removed again during subsequent treatment, thus appearing
in
process wastewater.
Like ethyl alcohol, methanol is highly soluble in water so that little is lost to evaporation. Sunlight
and natural
biodegradation breaks down methanol vapor into carbon dioxide and water over a few days. Methanol is
a naturally-occurring organic compound; trace amounts are found in the breath of normal, healthy human
individuals. Studies show low toxicity to mammals from inhalation, therefore air emissions from ponds
are
thought to pose negligible risk to humans or the local environment. There are no airborne methanol
standards
in most OECD12 countries.
Regulation of Evaporation Ponds
Evaporation ponds are recognized as a best practice in wastewater disposal, especially in hot and dry
climates.
In Russia and OECD countries they are subject to technical and engineering standards for their
construction and
operation but there are no effluent standards for discharges13.
In Kazakhstan, discharge into isolated man-made industrial ponds requires the same permit, monitoring
and
effluent standards that might be required for discharge into a natural water body used for recreation,
fisheries
and drinking water. Methanol limits in particular are set very high (3 milligrams per liter), exceeding
the capacity
of most equipment currently in use for removing it from industrial wastewater. NCOC is working toward
compliance with this standard, but it will be costly and the environmental benefits of the additional
investment
are not clear.
Ministry of Energy’s Reform of Environmental Regulation in Kazakhstan
Kazakhstan also differs in the breadth and complexity of its system of environmental tax payments for
emissions,
discharges and waste. These are applied to dozens of pollutants here, compared to a few “priority”
pollutants
(e.g., greenhouse gases) in some OECD countries.
In Kazakhstan, exceeding an emission standard, or emitting one of these dozens of regulated pollutants
other than as described in a per mit, triggers automatic civil penalties assessed as a multiple o f the
tax
rate. In the OECD civil penalties addr ess the polluter’s behavior, rather than a recoup of lost taxes.
Fines
and penalties are infrequent in OECD-member countries, assessed only in cases wher e the polluter has
failed to cooperate with authorities, or has clearly av oided using best available techniques for
preventing
pollution.
Exceeding a permit limit can also trigger a claim for monetary compensation to the State for damage to
the
environment. The liability for this environmental damage is established simply due to the permit
violation,
without need to provide evidence of actual physical harm to the environment. The amount of monetary
damages that the violator must pay is assessed from a formula calculation, unconnected to a field-based
assessment of restoration costs (typically because there is no actual damage to remediate).
Again, this differs sharply from OECD practices, where the “Polluter Pays” principle means the polluter,
not the
State, is responsible for cleaning up the damage and restoring the environment in the event of a major,
localized
pollutant release. The clean-up must happen. If the polluter does not or cannot, the State may perform
the
clean-up and charge it back to the polluter. This applies to water and soil, but rarely to air emissions
in which
clean-up is not possible, or the damage is not localized because the atmosphere itself disperses and
neutralizes
the pollutant. In any event, in Kazakhstan these monetary damages are simply collected and deposited
into
the State budget; there are no requirements that it be spent on restoration of the harm that
non-permitted or
above-limit emissions have allegedly caused.
The sharp difference in approach has led the OECD to remark that Kazakhstan appears to be “focused on
calculating and collecting monetary compensation for the state (essentially serving as a revenue-raising
penalty)
rather than on preventing and correcting the damage, reducing emissions over time and incentivising the
use of
BATs [Best Available Technology]14.”
In 2018, the Ministry of Energy announced that it would undertake a reform of the Environmental Code to
address these and other issues. NCOC has been an active participant in the public discussion, believing
reforms
are needed to better align with international practice and to facilitate foreign investment while
remaining
protective of the environment.
NCOC FINED FOR EVAPORATION PONDS IN 2018
NCOC voluntarily notified the regulator in March 2018 that along with discharges of treated wastewater
into
PLWDA pond via outlet point st ated in the Maximum Permissible Discharge (MPD) Project, separate treated
wastewater discharges into the same pond were performed through the outlet points which had not been
envisaged in the MPD project. The decision was made t o segregate off-spec streams in one of PLWDA pond
section in order to minimize risks of environmental impacts to ornithofauna. The design of the PLWDA
pond
prevents migration of the treated wastewater into soil and aquifer.
As a result there was no net environmental impact. However, NCOC has
been allegedly accused that such
actions resulted indirect (momentary) damage to the environment.
5.5. OIL SPILLS TO THE ENVIRONMENT
Performance
In 2018, there were 0 hydrocarbon spills greater
than 1 barrel reaching the environment from NCOC
operations (total volume: 0 barrels of oil-equivalent
hydrocarbons).
Approach
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.
2018 Actions
-
Prevention.
By far the best defense against
oil spills is to prevent them from occurring
in the first place, identifying spill risks and
ensuring that the highest safety standards are
continuously applied to mitigate those risks.
-
Technology.
We employ a wide range
of innovative technologies to assist in
responding to oil spills, and are actively
engaged in research on new and more
effective methods.
-
Response Training.
NCOC has a dedicated
Oil Spill Response group, with about a
hundred fully-trained staff, and equipment
suitable for the harsh environment of the
North Caspian Sea stored at marine support
bases in Bautino and Damba. NCOC has a
comprehensive Oil Spill Response Plan that
is regularly drilled. In 2018, in addition to
on-going minor exercises at all locations,
NCOC also conducted two “Tier 3” exercises,
simulating a major oil spill.
TENIZ-2018, an international integrated
exercise of Caspian states conducted under the
Astrakhan Emergency Cooperation Agreement,
took place on 2-3 August 2018. Task forces,
made up of representatives from responsible
government agencies and oil companies from the
various countries, worked together to fight the
(simulated) oil spill. The exercise was followed
by a demonstration of NCOC’s oil spill response
equipment at Bautino Base.
This was followed on 14 and 18-20 September by
a Regional Tier 3 spill exercise code-named “Altyn
Qyran.” The exercise involved over a hundred NCOC
personnel and contractors, and six representatives
from related national and local government
agencies. In the event of a major spill, NCOC would
call in additional support from OSRL (an oil spill
FIELD TRIAL ON OIL SPILL PREPAREDNESS
As a follow-up to the finalizing of the Arctic JIP research project last year
(www.arcticresponsetechnology.org), NCOC in 2018 implemented a project
to investigate the feasibility of using herders in combinations with controlled
in-situ burning (ISB).
Herders contain surfactants and are applied to the water surface adjacent
to an oil slick. Once applied, the surfactants spread to ultimately form a
monomolecular layer that significantly reduces the surface tension of the water.
The reduced water surface tension reverses the oil spreading tendency and a thin
slick can rapidly re-thicken. The surfactants do not need a boundary to “push”
against and can therefore function in both open water and broken ice.
The scientific data and technical report from the field trial will be shared
with the international oil spill community, and used in Kazakhstan to further
strengthen NCOC’s oil spill response capabilities, and inform development of a
national regulatory framework.
NET ENVIRONMENTAL BENEFIT ANALYSIS (NEBA)
NEBA is a structured approach that may be used by oil spill experts,
government regulators and the public to plan oil spill preparedness
measures and response scenarios. Each type of oil spill response measure
(in-situ burning, dispersants, mechanical recovery, etc.) has its own
benefits, drawbacks and limitations, and depends further on factors such
as water and weather conditions. There is no “best” technique for all
situations. The NEBA process compares the environmental benefits of
various response techniques with a “no intervention” strategy.
As part of a project to introduce NEBA in Kazakhstan, workshops were
organized in April 2018 by NCOC, jointly with the Kazmunaigas National
Institute of Drilling and Production Technology, Shell, and OSPRI (Oil Spill
Preparedness Regional Initiative), under the umbrella of the Ministry of
Energy. The workshops had the following objectives:
-
As part of a project to introduce NEBA in Kazakhstan, workshops were
organized in April 2018 by NCOC, jointly with the Kazmunaigas National
Institute of Drilling and Production Technology, Shell, and OSPRI (Oil Spill
Preparedness Regional Initiative), under the umbrella of the Ministry of
Energy. The workshops had the following objectives:
-
Sharing a new NEBA methodology, called Spill Impact Mitigation
Assessment (SIMA); and
-
Decision-making on the basis of NEBA in practice within the RoK
regulatory framework
One finding of the NEBA approach is that every effort possible must
be used to treat oil while it is offshore to prevent it from reaching
shallow, reedy and sensitive shorelines where protection and response
efforts are unlikely to significantly mitigate the environmental impact.
This aligns with lessons learned from previous oil spill recovery
events around the world. In order to treat the oil while it’s on the
water surface and as close to the source as possible, responders,
governments and the public need t o be aligned, so that time is not lost
on decision-making in an actual ev ent.
response cooperative located in Southampton,
UK) and its shareholder parent companies. Two
persons from OSRL and (for the first time) over 40
staff from Shell and ExxonMobil took part in the
simulation this year. During this exercise NCOC
Incident Management Team and Crisis Management
Team members drilled the Incident Command
System and crisis management techniques at a
simulated Incident Command Post at the NCOC
Atyrau Training Centre, including online software
tools to order and track resources and a “Common
Operating Picture” to provide everyone in the
exercise a simulated real time image of the current
situation. The exercise provided great experience
and highly valuable feedback that will be used
continuously improve the Crisis and Emergency
Preparedness and Response Process.
5.6. WASTE
Total quantity of waste generated by the Company
in 2018 was 10,976 tonnes, including 5731 tonnes
of waste with hazardous properties classified as
hazardous and 5245 tonnes classified as nonhazardous
according to the RoK Environmental Code.
The volume of waste generated in 2018 vs 2017 has
dropped by 58% due to completion of construction
works at the Company’s onshore and offshore
facilities.
Policies and Programmes
The key objective of NCOC’s Waste
Management System is to reduce or fully
eliminate waste generation at the source or the
process through proper planning of Company
operations.
Waste management is performed throughout
the life cycle of the waste starting from its
generation to final disposal. Waste segregation
is an important step in the process, so that
hazardous and non-hazardous wastes are not
mixed.
Since the RoK Environmental Code now permits it,
food and medical wastes (considered hazardous)
are incinerated offshore. The ash after incineration is
transferred to onshore facilities.
To improve compliance with the newly-introduced
Extended Producer Responsibility provisions in the
RoK Environmental Code, the onshore industrial
waste storage site is being upgraded with additional
waste segregation, and waste tracking processes
have been established. The waste subject to
EPR provisions will be transferred to specialized
organizations for further processing and recycling.
See Section 9.2 “Employee Engagement in the
Community” for more information about recycling
at NCOC offices and Samal camp as part of “Green
Office” initiatives.
5.7. ONSHORE AND OFFSHORE
SURVEYS
NCOC implements comprehensive environmental
monitoring programmes to collect offshore data,
analyze the chemical composition of seawater and
bottom sediments, and to study fish, benthos and
plankton populations. Since 1994 the project has
conducted more than forty offshore monitoring surveys
in roughly 900 different locations. Data collected during
the regular seasonal surveys covers weather conditions,
water quality, bottom sediments quality and biological
data (micro-organisms, phytoplankton, zooplankton,
fish). Starting in 2013, we added air quality, birds, and
additional Caspian seal studies.
NCOC published a 40-page brochure in 2018 entitled
“Environmental Surveys and Initiatives,” providing
more detail on the company’s environmental
impact monitoring, biodiversity surveys, air quality,
wastewater treatment, waste management, and
public environmental initiatives. See www.ncoc.kz.
5.8. DECOMMISSIONING AND
REMEDIATION
Decommissioning is governed by the
North Caspian Sea
PSA, including detailed
planning and funding at the appropriate time.
Decommissioning and remediation is planned
and executed in the same manner as any other
engineering project, with each programme
needing an environmental impact assessment
to determine the preferred option to apply to a
particular facility.