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Cases / Oil, gas and coal operations · Kazakhstan · 2007–2026

Tengizchevroil sulphur storage claims and emission fines (Kazakhstan)

Nature's voice · report
Sulphur from Tengiz crude was stored on me in open-air blocks; the Atyrau regional environment protection department said in 2007 that 2.8 million tonnes were stored there in 2003–2006 without official permission.
Did nature suffer? Yes. Harm is on record. Disputed
Recorded
  • Kursiv reported in November 2007 that about 8.5 million tonnes of sulphur lay openly on me, exposed to rain and wind. Kursiv
  • My land was named as polluted in the Zhylyoi District Court ruling of 27 July 2023; no quantities were given. Informburo
  • Between the third quarter of 2023 and the second quarter of 2024 my air received 49.3 tonnes of pollutants above permitted norms from the Tengiz field, 4.9 tonnes of them without a permit, according to an inspection by the specialised environmental prosecutor's office. Tengrinews
What the record lacks: 6 none on record · 1 not disclosed · 1 not measured · 5 disputed · 2 unclear See the gaps
Accounts of the harm differ
Whether the stored sulphur was handled safely
  • Company or project Tengizchevroil: It operated and managed its sulphur storage in an environmentally safe manner (October 2007). Oil & Gas Journal
  • Government and regulators Environment Protection Minister: The company is causing colossal damage to the environment and all people in Kazakhstan's western region by its actions (2007). Oil & Gas Journal
Emissions and land pollution found in 2023
  • Courts Zhylyoi District Court: Imposed fines totalling KZT 2.8 billion under articles 328 and 337 of the Code of Administrative Offences for unauthorised emissions, exceeding permissible emission standards and land pollution. Informburo
  • Company or project Tengizchevroil: The emissions were not caused by exceedances or environmental incidents; impact in 2021 corresponded to limits set by the authorities. Bizmedia.kz

Kazakh authorities pursued Tengizchevroil over open-air sulphur storage at the Tengiz field in 2007–2009 and over air emissions above permitted limits between 2011 and 2026. A damage claim of KZT 74.4 billion in 2007 was cut to KZT 37 billion by a regional economic court; administrative fines of KZT 2.8 billion (2023), KZT 639.6 million (2025) and KZT 53.7 million (2026) followed.

KZT 74.4bnDamage claim for open-air sulphur storage, July 2007
Cut to KZT 37bn by the Atyrau regional economic court in October 2007; Tengizchevroil appealed. Oil & Gas Journal gave the claim as US$609 million.

Status As of April 2026: the Zhylyoi District Court fined TCO KZT 53.7 million for excess emissions; the appeal outcome of the 2007 sulphur-storage damages is not on record.

What?
Kazakh authorities claimed damages and imposed fines on Tengizchevroil for open-air sulphur storage at the Tengiz field (2003–2006, claimed in 2007) and for air emissions above permitted limits, unauthorised emissions and land pollution (2011–2026). Oil & Gas Journal
Where?
Tengiz field, Zhylyoi district, Atyrau region, Kazakhstan, on the north-east Caspian coast. Oil & Gas Journal
When?
Claim July 2007; reduction October 2007; prosecutor's statement May 2009; payment announced September 2011; fines July 2023, July 2025 and April 2026. Oil & Gas Journal
Who?
Gained
  • Kazakh state budget — Fines and payments: KZT 1.7 billion in 2011, an administrative fine of over KZT 37 billion under collection in 2009, and KZT 2.8 billion, KZT 639.6 million and KZT 53.7 million in fines in 2023, 2025 and 2026 Caravan
  • Tengizchevroil and its owners (Chevron 50%, ExxonMobil Kazakhstan Ventures 25%, KazMunayGas 20%, LukArco 5%) — Sulphur sales of 1.5 million tonnes in 2006 to buyers including China, Russia and Uzbekistan Kursiv
Lost
  • Tengizchevroil — Fines and payments listed above; the company contested the 2007 claim Oil & Gas Journal
Harmed
  • Land and air around the Tengiz field — Sulphur stored in open-air blocks (2.8 million tonnes without permission in 2003–2006, per the Atyrau department); 49.3 tonnes of pollutants above norms in 2023–2024 Tengrinews
Why?
The Atyrau regional environment protection department said the sulphur was stored without official permission; TCO said it held annual permits for the volumes and that no alternative disposal method existed for the stored volume. The 2023–2026 fines concerned emissions above permitted limits. Kursiv
How?
A civil damages claim by the regional environment department in 2007, an administrative fine opened by the environmental prosecutor, and court fines on notices from the specialised environmental prosecutor in 2023–2026. Informburo
6 of 6 questions answered from the record

What happened

The record, in order.

Tengiz crude is sour, and the sulphur separated from it is stored in open-air blocks at the field. In July 2007 the Atyrau regional environment protection department claimed KZT 74.4 billion from Tengizchevroil LLP (TCO), saying the company had stored 2.8 million tonnes of bulk sulphur from 2003 to 2006 without official permission. In November 2007 Kursiv reported about 8.5 million tonnes of sulphur stored openly, exposed to rain and wind, and said company specialists had told it that no alternative disposal method existed for that volume. In 2002 reporting, sulphur had been said to accumulate at about 4,500 tonnes a day (per DPA).

In October 2007 the Atyrau regional economic court cut the claim to KZT 37 billion, scheduled to be levied on 29 October; TCO said it would appeal, and Kursiv reported on 8 November 2007 that the ruling was not yet in force because TCO had used its right of appeal. In April 2008 TCO said it would challenge a fine reported as US$307 million. In May 2009 the Atyrau environmental prosecutor said an administrative fine of “over 37 billion tenge” for sulphur stored without permits in 2006 had stood after appeal and was being collected; Caravan described this as separate from the earlier court-ordered damages for the same storage.

On 23 September 2011 the Prosecutor General's Office announced that TCO had paid KZT 1.7 billion for unauthorised gas flaring; the source excerpt does not state the flaring period. On 27 July 2023 the Zhylyoi District Court imposed fines totalling KZT 2.8 billion for unauthorised emissions, exceeding permissible emission standards and land pollution under articles 328 and 337 of the Code of Administrative Offences. TCO said the penalty was connected with limited time to provide data on environmental impact and that the emissions were not caused by exceedances or environmental incidents.

In July 2025 a court fined TCO KZT 639.6 million for 49.3 tonnes of pollutants emitted above permitted norms between the third quarter of 2023 and the second quarter of 2024, of which 4.9 tonnes were emitted without a permit; the case was opened by a decree of the specialised environmental prosecutor's office and the decision entered into legal force. On 20 April 2026 the Zhylyoi District Court found TCO administratively liable and fined it KZT 53.7 million for excess emissions.

TCO's owners were reported in 2007 and 2025 as Chevron (50%), ExxonMobil Kazakhstan Ventures (25%), KazMunayGas (20%) and LukArco/Lukoil (5%). TCO sold 1.5 million tonnes of sulphur in 2006 and reported sulphur sales up 28% as of 30 June 2007, with buyers including China, Russia and Uzbekistan.

  1. 2002Supreme Court upholds an earlier sulphur penalty of US$72 million; in 2002 the ministry classed stored sulphur as industrial waste and TCO argued it was a raw material (reported 29 Mar)
  2. 2007Atyrau regional environment protection department claims KZT 74.4bn for sulphur storage (Jul); Atyrau regional economic court cuts it to KZT 37bn, TCO appeals (Oct)
  3. 2008TCO says it will challenge a fine reported as US$307 million (Apr)
  4. 2009Atyrau environmental prosecutor says an administrative fine of over KZT 37bn for 2006 storage stands after appeal and is being collected (May)
  5. 2011Prosecutor General's Office announces TCO paid KZT 1.7bn for unauthorised gas flaring (23 Sep)
  6. 2023Zhylyoi District Court fines TCO KZT 2.8bn in total for emissions and land pollution (27 Jul)
  7. 2025Court fines TCO KZT 639.6m for excess emissions; decision in legal force (Jul)
  8. 2026Zhylyoi District Court fines TCO KZT 53.7m for excess emissions (20 Apr)

What was said

Claims, in the words of those who made them.

“operated and managed its sulfur storage in an environmentally safe manner”

Tengizchevroil, as reported by Oil & Gas Journal · October 2007 · Oil & Gas Journal

“We categorically disagree with the original demands of the ecologists”

Tengizchevroil head of government and public relations, as reported by Kursiv (translated) · November 2007 · translated from Russian · Kursiv

“is causing colossal damage to the environment and all people in Kazakhstan's western region by its actions”

Nurlan Iskakov, Environment Protection Minister, on the company, as reported by Oil & Gas Journal · 2007 · Oil & Gas Journal

“Questions are not solved just by handing in fines.”

Where accounts differ

Each party's account, side by side, with its source. The record does not settle these points; it shows them.

Whether the stored sulphur was handled safely
Company or project
Tengizchevroil

It operated and managed its sulphur storage in an environmentally safe manner (October 2007).

Oil & Gas Journal
Government and regulators
Environment Protection Minister

The company is causing colossal damage to the environment and all people in Kazakhstan's western region by its actions (2007).

Oil & Gas Journal
Whether stored sulphur is waste or a product
Government and regulators
Environment ministry (2002)

Classed stored sulphur as industrial waste.

RFE/RL
Company or project
Tengizchevroil (2002)

Argued that sulphur is a raw material or product.

RFE/RL
Courts
Supreme Court (2002)

Disagreed with TCO and upheld the sulphur penalty of that year.

RFE/RL
Size of the 2007 sulphur-storage claim
Press and investigations
Oil & Gas Journal, 15 October 2007

Gave the fine as US$609 million.

Oil & Gas Journal
Press and investigations
Oil & Gas Journal, 18 October 2007

Reported the department's claim of KZT 74.4 billion cut to KZT 37 billion by the Atyrau regional economic court.

Oil & Gas Journal
Press and investigations
Oil & Gas Journal, 18 April 2008

Reported TCO's plan to challenge a fine of US$307 million.

Oil & Gas Journal
Emissions and land pollution found in 2023
Courts
Zhylyoi District Court

Imposed fines totalling KZT 2.8 billion under articles 328 and 337 of the Code of Administrative Offences for unauthorised emissions, exceeding permissible emission standards and land pollution.

Informburo
Company or project
Tengizchevroil

The emissions were not caused by exceedances or environmental incidents; impact in 2021 corresponded to limits set by the authorities.

Bizmedia.kz
Response to the 2025 and 2026 emission fines
Courts
Court (2025) and Zhylyoi District Court (2026)

Fined TCO KZT 639.6 million and KZT 53.7 million for excess emissions.

Tengrinews
Company or project
Tengizchevroil

No public response on record.

How it looked

What was shown, beside what was recorded.

Shown

  • The ministry grants an annual permit for a set volume of stored sulphur, and the company held permits for the disputed volumes.
    Tengizchevroil, as reported by Kursiv, November 2007 · Kursiv
  • The court ruling was a major achievement in enforcing environmental compliance.
    Prosecutor General's Office, 2007 (paraphrased by Kursiv) · Kursiv
  • A “project on storing and utilizing sulfur” offered to President Nazarbayev.
    Chevron chief executive, April 2008, as reported by Oil & Gas Journal · Oil & Gas Journal
  • The 2023 penalty was “connected with limited time to provide data on environmental impact”; the emissions “were not caused by exceedances or environmental incidents”.
    Tengizchevroil, August 2023 (reported speech, translated) · Bizmedia.kz

Recorded

  • Claim of KZT 74.4 billion by the Atyrau regional environment protection department (July 2007), cut to KZT 37 billion by the Atyrau regional economic court (October 2007); TCO appealed.
    Oil & Gas Journal
  • An administrative fine of over KZT 37 billion for sulphur stored without permits in 2006 was upheld on appeal and was being collected, according to the Atyrau environmental prosecutor (May 2009).
    Caravan
  • KZT 1.7 billion paid for unauthorised gas flaring, announced by the Prosecutor General's Office on 23 September 2011.
    MEES
  • Fines totalling KZT 2.8 billion (Zhylyoi District Court, 27 July 2023); KZT 639.6 million (2025, in legal force); KZT 53.7 million (Zhylyoi District Court, 20 April 2026).
    Bizmedia.kz
  • Company-reported spending in 2007: US$63 million on “sulphur projects” in 2002–2005, US$1.2 billion on environmental measures over the previous eight years, and US$60 million invested in 2006 in flaking, granulation and packaging equipment.
    Kursiv
  • The Tax Code sets a payment rate of 3.77 MRP per tonne for open-air placement of sulphur on “sulphur maps” (article 576 para 7, as amended by Law No. 402-VI of 2 January 2021).
    Republic of Kazakhstan (legal database reproduction)
  • Emission payment rates per tonne from stationary sources (Tax Code article 576 para 2, in force from 1 January 2022): sulphur oxides 20 MRP, nitrogen oxides 20 MRP, hydrogen sulphide 124 MRP, methane 0.02 MRP; halved rates applied until 1 January 2025; flaring within an integrated environmental permit carries a coefficient of 0.
    Republic of Kazakhstan (legal database reproduction)

Who gained

Money that reached nature, beside money that stayed elsewhere.

Reached nature or the ground

Not published
Remediation or restoration funded by the claims and fines—
None on record.

Gained elsewhere

Not totalled
Administrative fine for open-air sulphur storage in 2006 (collection under way, May 2009)37bn
Window: 2009
Whether this is the same proceeding as the October 2007 court reduction to KZT 37 billion is unclear.
Paid for unauthorised gas flaring1.7bn
Window: 2011
Administrative fines, Zhylyoi District Court2.8bn
Window: 2023
Court fine for excess emissions (decision in legal force)640m
Window: 2025
Bizmedia reported in April 2026 that TCO had paid it the previous summer.
Administrative fine for excess emissions54m
Window: 2026
Company-reported spending on sulphur projects 2002–2005—
US$63 million (company figure, 2007).
Company-reported spending on environmental measures over eight years to 2007—
US$1.2 billion (company figure).
Currency: KZT · Window: 2007–2026 (mixed — see each line). Figures cover different periods and are not compared as a ratio. * Estimate built from cited figures.

Responses on record

  • Tengizchevroil (October 2007): Operated and managed its sulphur storage in an environmentally safe manner. · Oil & Gas Journal
  • Tengizchevroil (November 2007): Disagreed categorically with the original demands of the ecologists; the industry ministry grants an annual permit for a set volume of stored sulphur and TCO held permits for the disputed volumes. · Kursiv
  • Tengizchevroil (August 2023): The 2023 penalty was connected with limited time to provide data on environmental impact; the emissions were not caused by exceedances or environmental incidents, and 2021 impact corresponded to limits set by the authorities. · Bizmedia.kz

In court and with insurers

Every proceeding and every insurer decision on record.

Lawsuits and rulings

  1. 2007–2007Outcome not on recordKZT 37bn after court reduction from KZT 74.4bn; appealed
    Atyrau regional environment protection department v. TCO (sulphur storage damages)
    Atyrau regional (specialised interdistrict) economic court · Civil · Atyrau regional environment protection department → Tengizchevroil LLP

    Claim of KZT 74.4 billion filed in July 2007 for sulphur stored without permission in 2003–2006; cut to KZT 37 billion in October 2007; TCO appealed and Kursiv reported on 8 November 2007 that the ruling was not yet in force. The final outcome is not on record. Kursiv

  2. 2009Claimant wonKZT 37bn over; fine upheld on appeal, being collected (May 2009)
    Administrative proceeding over sulphur stored in the open in 2006
    Court not named; opened by the Atyrau environmental prosecutor's office · Administrative · Atyrau environmental prosecutor's office → Tengizchevroil LLP

    The prosecutor said in May 2009 that an administrative fine of over KZT 37 billion for open-air storage of sulphur without permits in 2006 had stood after appeal and was being forcibly collected into state revenue. Caravan

  3. 2023–2023Claimant wonKZT 2.8bn fines in total
    Atyrau Region Department of Ecology v. TCO (emissions and land pollution)
    Zhylyoi District Court · Administrative · Atyrau Region Department of Ecology (on a notice from the specialised environmental prosecutor) → Tengizchevroil LLP

    On 27 July 2023 the court imposed fines totalling KZT 2.8 billion under articles 328 and 337 of the Code of Administrative Offences for unauthorised emissions, exceeding permissible emission standards and land pollution. Informburo

  4. 2025Claimant wonKZT 639.6m fine; decision in legal force
    Specialised environmental prosecutor's office v. TCO (excess emissions, 2023–2024)
    Court not named · Administrative · Specialised environmental prosecutor's office → Tengizchevroil LLP

    A court fined TCO KZT 639.6 million for 49.3 tonnes of pollutants emitted above permitted norms between the third quarter of 2023 and the second quarter of 2024, of which 4.9 tonnes were emitted without a permit; the case was opened by a decree of the prosecutor's office. Tengrinews

  5. 2026Claimant wonKZT 53.7m fine
    Department of Ecology v. TCO (excess emissions)
    Zhylyoi District Court · Administrative · Atyrau Region Department of Ecology → Tengizchevroil LLP

    The ruling of 20 April 2026 found TCO administratively liable for excess emissions and fined it KZT 53.7 million. Orda.kz

Insurers

No insurer decision on record.

What nature saw

Outcomes measured on the ground, and nature's note.

Nature's report opens this page. Below: further outcomes measured on the ground.

Sulphur stored without permission
2.8 million t
2003–2006, according to the Atyrau regional environment protection department
Emissions above norms
49.3 t
Third quarter 2023 to second quarter 2024; 4.9 t emitted without a permit
Damage claim, 2007
KZT 74.4bn → 37bn
Cut by the regional economic court; appealed
Fines 2023–2026
KZT 2.8bn, 639.6m, 53.7m
Zhylyoi District Court and a court in 2025

What we don't know

Undisclosed, unproven, untried: recorded as data.
Court ruling existsNo independent ecological evaluation

Nature

  • Disputed Whether the stored sulphur was handled safely
  • Disputed Emissions and land pollution found in 2023

Money

  • None on record Remediation or restoration funded by the claims and fines — None on record.
  • None on record Company-reported spending on sulphur projects 2002–2005 — US$63 million (company figure, 2007).
  • None on record Company-reported spending on environmental measures over eight years to 2007 — US$1.2 billion (company figure).

Court

  • Unclear Atyrau regional environment protection department v. TCO (sulphur storage damages): outcome not on record.

Accounts

  • Disputed Whether stored sulphur is waste or a product
  • Disputed Size of the 2007 sulphur-storage claim
  • Disputed Response to the 2025 and 2026 emission fines
  • None on record Tengizchevroil: No public response on record.

Record

  • None on record None on record: the final appeal outcome and the payment of the KZT 37 billion damages ordered by the Atyrau regional economic court in October 2007.
  • Unclear Unclear: whether the administrative fine of over KZT 37 billion described by the Atyrau environmental prosecutor in May 2009 and the October 2007 court reduction to KZT 37 billion are one proceeding or two; Caravan describes them as two.
  • Not measured Not measured: sulphur dust, soil or groundwater around the Tengiz sulphur blocks; no measured data accompany the 2023, 2025 and 2026 fines.
  • Not disclosed Not disclosed: the period of the gas flaring covered by the KZT 1.7 billion paid in 2011.
  • None on record None on record: insurance cover or insurance payments for any of the claims or fines.

Did the harm stop?

None on record; emission fines were imposed again in July 2023, July 2025 and April 2026.

Who paid?

TCO, through fines of KZT 2.8 billion (2023), KZT 639.6 million (2025) and KZT 53.7 million (2026) and KZT 1.7 billion paid in 2011; the payment status of the 2007 damages is not on record. Use of the money for nature is not on record.

Sources

Voices on record: — Company or project✓ Government and regulators— Courts✓ Press and investigations— Communities and civil society— Researchers

Government and regulators

  1. Law No. 402-VI of 2 January 2021 amending the Tax Code (via zakon.uchet.kz, in Russian)
    Republic of Kazakhstan (legal database reproduction) · 2021-01-02

Press and investigations

Connected cases

Related matters, and cases linked to this one through the same organisations, with the role each played in both.
Terms used on this page

Science and environment

Groundwater
Water held underground in soil and rock, drawn through wells.

Law and courts

Arbitration
A private dispute process in which an appointed arbitrator, instead of a court, decides the case.
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