Sakhalin Environment Watch Letter to the Sakhalin Administration In translation from the Russian By Pacific Environment staff 26 April 2007 Russian original follows translation. Letter No. 68 April 24, 2007 To the Chair of the Natural Resources and Nature Protection Committee of Sakhalin Oblast D.V. Goncharenko Dear Dmitrii Vladimirovich! Our organization continues to carry out public environmental monitoring of the Sakhalin II Project. Furthermore, we are constantly receiving information from local residents, fishermen, representatives of Native Peoples on the ecological aspects of project construction. After generalizing all the information accumulated during the period of January - April 2007, we came to the conclusion that in spite of the significant efforts in the second half of 2006 by governmental entities and the public towards minimization of harm to the environment and reductions in the ecological risks of Sakhalin II, the entire complex of ecological problems remains, and in some aspects they became still worse. A brief description of these problems consists of the following: 1. The situation in the region of the on-shore pipeline route through waterways. In the winter-spring period of 2007 we inspected a number of the sections of pipeline in the Dolinsk and Makarov regions and revealed a whole series of violations. First of all, the prevention of water flow in the riverbeds of small rivers in the section 422.9 – 358.5 km. In the accompanying photographs (appendix 1) one can see clearly that in a whole series of rivers water is accumulated in the form of ice mounds upstream of the bridge crossings in the area of the pipeline route. It is obvious that many bridges during winter 2006 - 2007 acted as dams, which prevent the water from flowing in the riverbeds. This is confirmed by that fact that upstream from the bridge there are enormous ice mounds, and downstream there are no such ice mounds. Even during August - September of 2006 the inspections by the Rosprirodnadzor revealed numerous violations of water systems on the waterways of the Dolinsk and Makarov regions along the pipeline route. In the order given out by the Sakhalin Regional office of Rosprirodnadzor to Sakhalin Energy on Sept. 18, 2006, the company was ordered to reestablish the disrupted water systems, complete the construction of bridges and other structures around water in accordance with the technical and economic assessment of the construction project (points 6 and 7 of the administrative order). Sakhalin Energy and its contractors did not carry out this order, as a result of which on many waterways in the winter the water flow was seriously reduced, while in some places the water flow was stopped completely. In winter conditions this is fatal for anything living in these rivers, including Salmonidae roe. A list of such places with the indication of their location on the pipeline route is in the accompanying photographic material. The inspection of the same sections of rivers, carry out during March and the beginning of April 2007, showed that the water, accumulated for the winter in the ice mounds upstream from the bridges on the pipeline route, actively erodes the embankments of the bridges and culverts, carrying significant masses of mud into the beds of rivers downstream. This pollution is completely unforeseen in either the environmental impact evaluation or the Plan of Nature-Conservation Measures. This situation was noticed on Pipeline Kilometer (PK) 407.3 – on the left inflow of the Ssora River (the river bed was covered with a layer of clay sediments about 60 m downstream from the pipeline crossing); PK 402.5 – on the Rudnaya
River (water flows above the bridge, eroding the embankment); PK 401.9 – on the left inflow of the Vostochnaya River (the river bed approximately 100 m downstream was covered with mud); PK 399, PK 398.2 – on the Biya River, and on a number of others. 2. Construction of the on-shore pipelines across active seismic faults. Until recently Sakhalin Energy continued to plan and to build the pipeline underground, trenching passages through 19 active seismic faults. The Construction Norms and Regulations 2.05.06-85 on "main pipelines" (Moscow 1997) establish the required standard: "in the sections of the pipeline which intersect with active seismic faults it is necessary to use above-ground construction" (p. 5.37). However, Sakhalin Energy could obtain the agreement of the Russian Federal Gosstroy - State Committee for Construction - to the building of the pipeline through the seismic faults using the underground (trench) method within the framework of the affirmed special technical specifications of design, despite the fact that even the state ecological examination technical and economic assessment (State Environment Expert Review) done on the construction in 2003 pointed out the explicit danger of this solution. However, then, in the course of creating a working design, Sakhalin Energy changed this solution on four passages through the active seismic faults, and at present agrees to create working designs for aboveground passages. Information about this was contained in the Plan of Nature-Conservation Measures for the Elimination of the Violations Revealed by the Rosprirodnadzor (Environment Action Plan). This plan is accessible on the official Web site of Sakhalin Energy. It is our deep belief that this positive solution and the experience gained by the company must be applied also to the remaining 15 sections where the pipeline crosses active seismic faults, i.e. the company needs to design aboveground passages, as required by the Construction Norms and Regulations. According to our data, thus far not one passage through the seismic faults has yet been built; therefore there still is time to substantially increase safety of the pipeline through the construction of the aboveground passages through all active seismic faults. 3. Building on-shore pipelines in areas prone to landslide, flood and erosion danger. In the order give by the Sakhalin regional office of Rosprirodnadzor dated September 18, 2006, there were the direct requirements for the company to develop individual design solutions for the passage of the pipeline route through the areas that are prone to mudslides, landslides, and erosion in the Dolinsk and Makarov districts. It also ordered the company not to begin construction before these solutions were approved (items 1, 2, 5 of the order). According to our data, these solutions have not yet been approved, but nevertheless construction in the mentioned sections goes full speed at present and continued during the entire winter. This is the crudest violation, which places the integrity of the pipeline under threat and which threatens massive oil spills in the future. Our inspections of the pipeline route showed that the Sakhalin Energy contractors still have not begun construction of the sediment conduit (the facility which prevents damage from mudflow) in the Pulka River headwaters, despite the fact that this was directly indicated in the order of Sept. 18, 2006 (item 17). The bridge built across the Pulka River in no way satisfies the order’s and safety standards’ requirements regarding the sediment conduits. The coming summer season threatens sedimentation of the Pulka River, but comprehensive measures haven’t yet begun to be taken to minimize the risk of this dangerous phenomenon in this section. In the order of Sept. 18, 2006, (item 8) was the requirement to immediately remove temporary soil storage sites located in the sections at risk for landslides, and to recultivate the earth where it was disturbed. However, in many landslide-prone areas, such soil storage sites (disposal tips) remain, even now. Moreover, you can see in the accompanying photographs (appendix 2) the landslide processes already evident.
During July 2006 three complete sets of the materials, which give the basis of the selection of the sections of forest stock, by total area 29.2 hectares, for the additional areas for disposal tips along the boundaries of the oil and gas pipeline route in the Makarov region were rejected by the State Environmental Expert review (a decision affirmed by the orders of the Rosprirodnadzor Numbers 210, 211 and 212 of July 11, 2006). Nevertheless, work in these sections was carried out, and waste soil was dumped and remains in large part still there. This is the crudest violation of nature-conservation legislation, in particular the Federal Law "on the environmental assessment," which directly forbids activity that has been rejected by the state impact assessment. The plan for soil storage was rejected first of all because of the high danger of landslides with soil storage in the mountainous terrain of the Makarov region, and because they directly and irrefutably prove the high environmental danger of construction in these sections. 4. Problem of the reassessment of damage to fish resources. From the beginning of 2006 the community of Sakhalin has been raising the problem of the need for the reassessment of damage to fish resources done in the course of the Sakhalin II construction. This issue even caused public protests, such as, for instance, the picketing of the LNG plant construction site in January 2006. The validity of the demands of the island’s population was at that time supported by Governor Ivan Malakhov, who personally met with the picketers. Exceeding the original calculations of the damage (at the design stage ) was confirmed as due to significant departures during construction from the design materials, by which were calculated the damages initially. Examples of this are the nonsimultaneous installation of the oil and gas pipelines through spawning rivers, the pollution of spawning rivers with suspended solids along considerably larger stretches of river beds in comparison with calculated data, the absence of the calculation of damage from the building of bridges on the pipeline route, the nonobservance of prohibition of building of pipeline crossings across salmon rivers during spawning season, the significant exceeding of the area of the sea bottom that was covered by the layer of sediments with the discharge of soil in Aniva Bay, etc. Our organization repeatedly brought this problem to the attention of the Sakhalin Administration (letter № 06 from January 31, 2006, letter № 78 from September 4, 2006), and also to the President of Russia, the Minister of Natural Resources, the Authorized Representative of the President in the Far-Eastern Federal Region, and the deputies of the Regional Duma. In spite of the agreement of all public bodies in the fact that the damage to fish reserves must be recalculated, as far as we know, practically nothing in this sphere, until now, has been done (in contrast to the damage to forest stock and to soil caused by pipeline construction, damage which at least was partially calculated in the course of the autumn Rosprirodnadzor inspection). Besides the problems connected with Sakhalin II construction, we are extremely concerned by the situation arising in recent years with the response to oil spills related to Sakhalin I and Sakhalin II. According to the information, given to us by the Federal Emergency and Disaster Relief Ministry (Emercom) for the Sakhalin region (appendix 3), during the years 2005 - 2006 in the territory of Sakhalin more than 200 oil spills have been identified. Mostly they have come from operators of shelf projects and their contractors. At the same time, we have numerous evidence from local residents, fishermen, representatives of Native Peoples, and also workers at these same oil companies about the fact that far from all the facts about oil spills are made available by oil-industry workers to public agencies. Especially this is typical for sea structures (water areas around off-shore oil platforms, and near the structures of the LNG plant and oil terminal in Prigorodnoye). Frequently these oil spills are connected with transportation and fuel transfer.
Even during June 2006 we appealed to Sakhalin Energy with the request to grant information about the transport and bunkering of fuel for the sites under construction, the permits issued by public agencies for this activity, the oil spill response plans for these operations, licenses to the deliveries of fuel for the offshore and on-shore sites (appendix 4); however, so we did not receive an answer. Also Sakhalin Energy and Exxon Oil and Gas Ltd. answered by means of a refusal to our request to share the oil spill response plan for all the sites of Sakhalin II and Sakhalin I. This lack of transparency in regards to the most important question of environmental safety causes enormous fears and it attests to the fact that the risk in this region is extremely high, and standards are low. In connection with all that is outlined above, on behalf of the members of our organization I am appealing to you with the request to check the facts presented, and also, if necessary to take meaningful actions towards the operators of shelf projects Sakhalin I and Sakhalin II to minimize environmental risks, increase environmental safety and bring the construction activities on industrial sites and oil and gas extraction into compliance with the requirements of Russian Law. I also ask you to verify the availability and the legal adherence of permits that have been given out to the oil companies, in particular with regards to the crossings of active seismic faults. For our part, our organization is ready to render assistance in conducting inspections and the collection of missing information of any kind, and also in any other feasible possible way. I ask that you reply to this appeal. Our address: 693007, Yuzhno Sakhalinsk, Kommunisticheskii pr. 27A, k. 310. Tel. 74-75-19, Fax 74-75-18. With deep respect, Chairman of the Board of the Organization ________________ Lisitsyn D.V. Appendices: 1. A selection of the photographs which illustrate the problem of the disturbance of the hydrological regime of a number of water flows along the Sakhalin II pipeline route and as a consequence the formation of ice mounds which block river drainage. 2. A selection of photographs which illustrate the problem of the placement of construction waste (disposal tips) in areas prone to landslides, outside the limits of the right-of-way of the Sakhalin II pipeline route. 3. Information from the Federal Emergency and Disaster Relief Ministry for the Sakhalin Region about the facts regarding oil spills in the territory of Sakhalin in 2005 - 2006. 4. Letter addressed to the management of Sakhalin Energy about the sharing of information regarding the issue of oil spills during the transport and the bunkering of fuel for Sakhalin II.