Environmental management approaches

Environmental management system

To manage environmental impacts KPO is certified to use the Integrated HSE management system cetrified to comply with international standards ISO 14001:2015, ISO 45001:2018 and ISO 50001:2018, as well as HSE Policy dedicated for continious improvement.

In 2022, KPO successfully passed ISO 14001 Audit, confirming compliance with the standard’s requirements. The key environmental commitments of the Company’s HSE Policy include the following significant objectves:

• prevention of the environmental pollution,
• reduction of GHG emissions,
• conservation of biodiversity and ecosystems,
• conservation of natural resources,
• continuous improvement of environmental performance.

As part of maintaining an effective environmental management system and in order to comply with the requirements of the new Environmental Code, an Implementation Plan for the requirements of Environmental Code of the Republic of Qazaqstan has been developed and internal documentation in the field of environmental protection has been revised.

In accordance with Environmental Code, KPO, as the Field Operator, is responsible for emissions from the Karachaganak project. Since the second half of 2021, data has been collected and analysed to set up the system for emissions accounting from contractors operating in the Karachaganak field.

According to the RoQ Environmental Code, KPO has an obligation to implement the best available techniques (BAT). In 2023, it is planned to conduct a comprehensive technical audit for compliance with BAT. 

Environmental aspects management system

In 2020 KPO has developed and introduced the environmental aspects management system EnvAR, which is a convenient and effective management tool.

Environmental Aspects Register of the Company’s divisions are annually reviewed and updated considering changes in the current situation. Based on the Company’s divisions registers, the Consolidated register of the most significant environmental aspects is developed, to apply additional activities/control measures to reduce risks and improve the environmental condition. In 2022, the EnvAR system was supplemented with functionality that allows you to automatically track the implementation of additional activities. The Consolidated Register of KPO Significant Environmental Aspects in 2022 included the following aspects:

1. Pollutant emissions into the atmosphere and greenhouse gases,
2. Waste generation and management,
3. Detection of unauthorized waste disposal,
4. Domestic wastewater treatment and discharge,
5. Industrial wastewater generation and disposal,
6. Spills,
7. Water resources consumption.

Environmental compliance

KPO conducts its business in accordance with the environmental legislation of the Republic of Qazaqstan (RoQ). KPO annually requests and obtains an Environmental Impact Permit (EEP) from the RoQ Ministry of Environmental Protection. This permit sets the limits for contaminants emissions, discharges and limits for accumulation and burial of wastes.

In 2022, KPO did not exceed the general emission, waste accumulation and disposal limits set in the Permits. In 2022, three civil claims in the field of environmental protection were filed in relation to the events of 2020–2021 for a total amount of 26.2 million tenge. Based on court decisions in three civil environmental claims, KPO paid 14.1 million tenge, partially winning two claims and reducing the amount with a difference of 12.1 million tenge. It should be noted that during 2022 the Company was not held administratively liable, and no administrative fines were imposed.

Implementation of the new Environmental Code’s requirements

In 2022, as part of the efforts over the new Environmental Code by the Company’s employees, critical production issues were resolved on the legislative level, such as:

• Obtaining environmental impact permit for KOGCF facilities for 2023;
• Obtaining environmental permit for Atyrau Terminal facility for 2023–2030;
• Activities related to the Plan of implementation of the requirements of the new RoQ Environmental Code for 2023;
• Legislative work in the field of environmental protection and subsoil use. Analysis of the provisions of more than 40 new RoQ by-laws in the field of environmental protection;
• Participation in development of the new environmental requirements and submission of comments and proposals for average 90 regulatory and by-law RoQ acts in environment protection by KPO specialists as members of the working groups under the Ministry of Environmental Protection, Geology and Natural Resources of RoQ and Association “KAZENERGY”;
• Resolving a number of issues on revising environmental requirements for business within the framework of the “Regulation from a clean sheet”, as part of the working group on energy, ecology and the oil and gas industry of the Council of Foreign Investors under the President of the RoQ:
  • with the Ministry of Energy of the RoQ – questions on classifying technologically inevitable gas flaring as V9¹¹;
  • with the Committee on Water Resources of the Ministry of Natural Resources of the RoQ – amendments and additions to the new by-law acts in the field of the use and protection of the water fund, water supply and disposal;
  • with members of the Mazhilis Parliament of the RoQ – amendments to Administrative Code of the RoQ to increase the number of fines for gas flaring and strengthening the role of the public within the framework of the Environmental Code of the RoQ.

Environmental Public Hearings 

As per the requirements of the new Environmental Code dated January 2, 2021, public hearings in the process of carrying out the state environmental review are mandatory, and are carried out in accordance with the rules for holding public hearings. Thus, all project documentation for construction and (or) operation of facilities of categories I and II (which include KPO facilities) and other project documents stipulated by Environmental Code for obtaining environmental permits are sent for examination and submitted to public hearings. All this takes place in the process of obtaining an environmental permit.

In 2022, the Company held nine public hearings on project documentation for construction and (or) operation of Category I and II facilities and other project documents required to obtain environmental permits.

Information about the planned public hearings was brought to the attention of representatives of interested state authorities and public through announcements on the Unified Environmental Portal, in a periodical print publication (newspaper), TV channel and on bulletin boards of local executive authorities of administrative-territorial units.

All projects submitted for discussion at public hearings in 2022 were approved by the interested state authorities and the public. The results of public hearings are reflected in the protocols of public hearings. A package of documents submitted for public hearings, as well as the results of the discussion, are available at the Unified Environmental Portal.

Suppliers’ environmental assessment

According to the Environmental Code of the Republic of Qazaqstan (dated January 2, 2021 No. 400-VI RoQ Law), the Karachaganak field is the facility that has a significant negative impact on the environment (category I), and the condensate pipeline export facilities KPC-Bolshoi Chagan-Atyrau are classified as facilities that have a moderate negative impact on the environment (category II). KPO, as the operator of Category I and II facilities, receives an Environmental Impact Permit, and contractors engaged to perform certain works and (or) provide certain services on the territory of KPO facilities during its construction, reconstruction or operation are required to comply with the conditions of such an environmental permit.

During 2021, the Company carried out a large-scale work to account for emissions generated during the performance of services by contractors for inclusion in the KPO environmental impact permit. The Company also revised a number of work processes for environmental control of contractors whose emissions are included in the general environmental impact permit.

Further, in 2022, the Company organized a system that makes it possible to identify and control environmental aspects that arise when contractors provide services on the territory of KPO facilities. Control also covers waste management plans and registers environmental aspects. In this regard, KPO has sets up an objective to train and improve environmental awareness and qualification of contractors. Thus, during 2022, KPO carried out active work to raise the awareness of contractor employees during regular meetings with responsible personnel, visits, as well as familiarizing with KPO requirements at quarterly and annual Contractor HSE forums.

Since the beginning of 2022, the system was established for monthly reporting by contractors of data on fuel consumption by stationary emissions sources, on waste accumulation, as well as on water consumption and disposal.

In order to communicate KPO requirements to the contractors, an e-guide on environmental reporting and compliance has been released. The guide demonstrates eight sequential steps from the beginning of collecting information for the Environmental Permit to the submission of regular reporting, as well as actions to be taken in case the set limits are exceeded. It should be noted that this guide and its applications can be downloaded from any electronic media via QR. Expanded requirements for contractors were reflected in Schedule D, updated in May 2022, to Company contracts on HSE requirements. These include requirements for training under the current Environmental Code of the Republic of Qazaqstan, for maintaining of environmental aspects register, compliance with the conditions of environmental permits, for waste management, discharges and emissions, environmental fines, etc. Thus, KPO has the opportunity to evaluate new contractors for environmental criteria.

Since the beginning of 2022, the system was established for monthly reporting by contractors of data on fuel consumption by stationary emissions sources, on waste accumulation, as well as on water consumption and disposal.

All incoming information on emissions and waste accumulation since 2022 is carefully analysed as part of the KPO Environmental Permit compliance procedure, which has been updated to reflect the new requirements. Information on contractors is being compiled into a database, which will form the basis for an electronic reporting and environmental performance monitoring system.

Environmental protective measures plan 2022

To achieve the set goals in environmental protection, KPO annually develops an Environmental Protective Measures Plans (hereinafter referred as EPMP). The Plan’s measures focus on ensuring the environmental safety, improving environmental protection methods and technologies, ensuring rational use of nature and maintaining compliance with the ISO 14001 and ISO 50001 international standards.

In 2022, KPO operated the business on the basis of the environmental permits issued. The EPMPs were developed and approved for each of the Permits obtained.

Tab. 25. KPO Environmental Protective Measures Plans for 2022 and Emissions Permits issued

In 2022, the total actual costs of the environmental measures implemented at Karachaganak Field amounted to KZT 2.3 bln and that is 113 %.

The 2021 KPO EPMP implementation by sections is shown in Table 26.

Tab. 26. Environmental Protective Measures Plan implementation in 2022, %

The environmental effect from the implementation of environmental protection measures is presented in Table 27.

Tab. 27. Environmental impact from the implementation of measures to reduce emissions and wastes in 2022

Environmental monitoring

KPO implements a number of environmental programmes, which cover all areas of its production activities. One of the key programmes is a Production Environmental Control (PEC) Programme developed in line with the RoQ Environmental Code requirements to meet the following objectives:

• obtaining reliable data about the Company’s emissions and impact of production activities on the environment;
• rapid and proactive response to emergencies;
• minimizing the impact on the environment and human health;
• communication with stakeholders (local communities, state regulatory authorities, partner companies) about the environmental activities of the Company and risks for population health.

As part of the PEC Programme, the environmental emissions such as air emissions, wastewater discharge, waste treatment, accumulation and disposal, and the quality of environmental components such as air, surface and ground water, and soil are monitored.

The PEC monitoring of the quality of soils, surface and ground water in 2022 has demonstrated that concentrations of target substances were on a par with those observed in previous years. No negative impact on environment from KOGCF operations was identified. Also, KPO regularly monitors the production environmental control over the environmental condition at the field waste disposal facilities.

Also, KPO regularly monitors the production environmental control over the environmental condition at the field waste disposal facilities. In 2022, as a result of monitoring of ground water and soil at the Eco Centre’s Solid Industrial Waste Burial Landfill and the Temporary Liquid Drilling Waste Storage Site, as well as in checks 35A and 35B, no direct negative impact on the environmental protection components is revealed. Quantitative control over the movement of waste is carried out in order to consider the volume of burial, as well as the volumes and time of waste accumulation.

Air quality is monitored by ways of collecting and testing the samples. The job is performed by an accredited laboratory, as well as 18 stationary automatic EMSs. Air quality is assessed based on the sanitary and hygienic limits, i.e. maximum permissible concentrations (MPC). To identify the level of air pollution, the recorded concentrations of monitored components are compared with MPC and quantified in fractions.

In 2022, more than 100 thousand samples were taken by the laboratory during the process, about 115 thousand laboratory sample analyses and about 28 thousand measurements were carried out.

The Company pays special attention to protection of atmospheric air in the Field area, at the SPZ boundaries and in settlements adjacent to Karachaganak field.

Sanitary protection zone

New estimated sanitary protection zone (SPZ) has been set up on the territory of the KOGCF since January 1, 2018. In 2021, KPO successfully completed the relocation of environmental air monitoring stations. The relocation of these stations was scheduled due to the change of Sanitary Protection Zone to ensure correct performance of the continuous air monitoring and to comply with the RoQ legal requirements. Plot map of the Karachaganak field with SPZ marked, as of end 2022 is available on the KPO website in the section Sustainable Development/Environmental Protection/Sanitary Protection Zone.

In 2022, KPO continued the implementation of the project “Organization and improvement of the estimated KOGCF sanitary protection zone” – stage 3 – “The first stage of planting the KOGCF SPZ and for extending of SPZ boundaries”. The aim of the project is to take care of existing forest stands and plant new trees, as well as to install information signs on the SPZ boundaries. In order to protect historical and cultural heritage sites from potential negative impact, the project also provides for the installation of appropriate signs at the boundaries of the protected heritage sites. Earlier, in 2019, KPO organized the large-scale archaeological research on this topic (see the details in the KPO Sustainability Report 2019, pp. 85-88).

So, in 2022, surveys, field work, monitoring of existing forest plantations and project documentation were completed. Based on the results of the work performed, decisions were made on the reconstruction of previously planted plantations around the settlements of Uspenovka, Karakemer, Zhanatalap, Karashyganak, forest belts within the SPZ, the creation of new forest belts within the SPZ boundaries, the staking out of the SPZ boundaries, the installation of information signs and the boundaries of protected zones of historical and cultural heritage objects, the technology of their creation is determined, the costs for the implementation of the planned activities are calculated.

Total area of ​​plots planned for green construction for the entire project period will be 249.1 hectares including 151.9 hectares area to ​​create new forest belts, 97.2 hectares is the area of ​​reconstruction work on existing plantations.

Total implementation period for the entire project includes the period from spring 2023 until 2028:

• 2022 – surveys, field work, development of project documentation,
• 2023 – drawing SPZ boundaries,
• 2024 – installation of information signs on SPZ boundaries and protected historical sites,
• 2023–2026 – renovation of forest belts,
• 2025–2028 – planting of new forest belts.

There will be no any capital facilities construction in the process of project implementation. The work is expected to be carried out by a contractor. Plot map “Main design solutions for arrangement and improvement of KOGCF SPZ for the period 2023–2028” is available on the KPO website in the section Sustainable Development/Environmental Protection/Sanitary Protection Zone. Consolidated plot plans for placement of SPZ facilities and landscaping were agreed by interested parties, business organizations and agricultural producers.

Air Monitoring by automatic Environmental Monitoring Stations

18 stationary automatic environmental monitoring stations are installed along the perimeter of the KOGCF and SPZ (EMSs 001 – 018) and integrated into a single automatic environmental monitoring system.

Four out of 18 EMSs are located at the field and within the SPZ. The stations 005 – 018 were relocated to new spots in accordance with the Project for EMS relocation to the boundary of the new estimated SPZ, which was completed in December 2021. As of end 2021, there are 13 EMSs located at the estimated SPZ boundary: 006 – 018; the EMS 005 was relocated to a site near Aksai.

Annual average concentrations of the monitored components recorded by EMSs in 2022 at the KOGCF SPZ boundary are shown in Table 28. The column “Actual annual average concentration” shows the minimum and maximum annual average concentrations of the monitored components recorded by each EMS.

All the EMSs take measurements of the four main pollutants (H₂S, SO₂, NO₂, CO) on a continuous basis, 24/7.

According to the data received from EMSs in 2022, the actual daily, monthly, quarterly and annual average concentrations of the monitored components did not exceed the established sanitary and hygienic limits. However, on June 13 and 14, 2022, EMS-017 registered two cases of a 20-minute exceedance of the maximum permitted concentration of hydrogen sulphide and on September 27, one case was registered by EMS-007. Pursuant to the requirement of the RoQ Environmental Code (Sub-item 8 Item 2 Article 184), the Company sent a notification regarding the exceedance recorded at EMS-017 and EMS-007 to the WQO Environmental Department.

Tab. 28. Annual average concentrations of the monitored components recorded by EMS in 2022

It should be noted that no connection was found between the exceedance shown in Table 30 and the KPO field facilities operations. The review of the KPO field operations, considering the meteorological parameters at the time of the MPC one-time exceedance, has shown that all production facilities were in normal operation with no flaring events, no equipment failures or emergencies recorded. No direct H₂S sources revealed among KPO facilities. At the moment of MPC exceedance recorded by EMS-007 KPO facilities were fully stopped for turnaround.

Tab. 29. One-time MPC exceedances recorded by EMS in 2022

No gas odour complaints from the local communities adjacent to the KOGCF were raised on the date the MPC exceedances were recorded.

Air quality data from all 18 KPO automatic EMSs are transmitted online to the West Qazaqstan Oblast Environmental Department via the Ecomonitor portal.

Atmospheric air monitoring in the villages adjacent to the Karachaganak Field

There are stationary air monitoring posts in six settlements located along the perimeter of the field – Zharsuat, Zhanatalap, Dimitrovo, Karachaganak, Priuralnoye, Uspenovka, and in Aksai town. The air sampling is carried out four (4) times a day (at 1, 7, 13 and 19 hours according to the State Standard) by the permanent personnel of the contracting laboratory, who reside in the specified villages. Approximately 52,000 air samples were collected and analyzed at the stationary posts in 2022.

Air samples are chemically tested in the laboratory in Aksai for the content of five main components in accordance with the State Standard and ruling documents: hydrogen sulphide (H₂S), sulphur dioxide (SO₂), nitrogen dioxide (NO₂), carbon oxide/monoxide (CO), and methyl mercaptan (СH₃SH). In addition, every 10 days the air is monitored for the concentration of volatile organic components: benzene (C₆H₆), toluene (C₇H₈), xylene (C₈H₁₀).

Monthly results of air monitoring are published in local print media and distributed to the villages for posting on the information boards, as well as published on the KPO web-site on a monthly basis. If any gas odour complaint is raised by someone of the community, an unscheduled air sampling is performed at the stationary posts.

In 2022, no MPC exceedances were recorded for the daily average concentrations of the monitored air components in the villages.

In 2022, seven complaints with respect to gas odour were raised by the village communities adjacent to the Karachaganak Field. The unscheduled air sampling was carried out in the villages, the analysis results of which indicated that the concentrations of the monitored components did not exceed the established MPC one-time. Each complaint from an initiator with respect to gas odour was addressed.

The annual average concentrations of the monitored air components in the seven villages in 2022 are shown in Table 30. The column “Actual annual average concentration” shows the minimum and maximum annual average concentrations of the monitored components. Criterion for assessing air quality in settlements is MPC daily average.

Tab. 30. Annual average concentrations of the monitored air components in the villages adjacent to the KOGCF in 2022