Perhaps the most
significant potential environmental threat from Sakhalin offshore oil
and gas development is that of a major oil spill from one of the
transport tankers. It is well established that the greatest risk for
catastrophic oil spills is that of transportation via tanker. Given
that VLCCs with 2 million barrel capacity will be calling at the
offshore terminal and then sailing south along the island, the
potential for a loss of an entire cargo needs to be considered. At
projected production levels of 90,000 barrels/day, they expect one
tanker transit every 5 - 6 days, or about 36 each operating season. In
the EIA, Sakhalin Energy suggests that "the potential of a transport
tanker release is classified as unlikely," and goes into little
additional detail regarding risk from these shipping operations. They
simply say that the transport tankers are not their responsibility. For
such a serious threat as a catastrophic tanker spill along the east
coast of Sakhalin or further south off Hokkaido, this is an entirely
unacceptable assessment.
There are any number of scenarios for
catastrophic oil spills from tankers off Sakhalin, including grounding
or collisions caused by power or steering loss, navigational error,
hull failure, fire/explosion, etc. Shuttle tankers can be blown off the
FSO while loading, an incoming tanker can collide with a fully loaded
FSO, a fully loaded tanker can lose power or steerage in an easterly
gale and be blown onto shore at Sakhalin, a tanker can collide with a
fishing vessel, a tanker can ground due to navigational errors, and so
forth. All such scenarios need to be carefully examined and planned for
in order to minimize the risk of occurring.
Although SEIC
presents the image that they have conducted "risk analyses," they
clearly haven't addressed all potential problems. It is clear that a
thorough risk assessment should be conducted that, at a minimum, would
(1) identify, evaluate, and rank the risks of oil transportation off
Sakhalin and Hokkaido, (2) identify, evaluate, and rank potential risk
reduction measures for the tankers, (3) develop a risk management plan
for oil transport off Sakhalin and Hokkaido. The three principal
components of the oil transport system that should be carefully
evaluated regarding spill risk are the vessels, vessel
traffic/shoreside monitoring, and the crews.
Vessels: In order to adequately evaluate
and manage the risk of these operations, it will be necessary to fully
characterize the fleet that will be used to haul oil from the Vitiaz'
terminal: name of vessels, age, hull design, classification society,
owner and operator, previous owners, insurer, status of class reports,
flag and changes in flag, complete casualty history, pollution history,
company vetting policies and maintenance schedules, major repairs
completed, history of any and all deficiencies and violations found by
classification society or flag state or port state, history of
detentions and/or refusals to enter port in vessel's history, etc. SEIC
has now developed a vetting procedure by which they intend to screen
the quality of vessels that may load at the terminal, and they have
established arrival inspection procedures. These procedures need to be
thoroughly evaluated by independent analysts, and the inspections
should be a matter as well for Russian maritime authorities. The
company suggests that they will have the "right to reject vessels on
arrival which contravene their established Port Procedures and/or
Vessel Conditions." The "right to reject" is not the same as "the
obligation to reject." One wonders how rigorously these standards would
be enforced if, for instance, the Okha is full, and no other tankers
are available to load except those of lower quality that might not be
accepted otherwise. Faced the choice of either stopping production from
Molikpaq, or accepting a sub-standard vessel, what will the company
choose absent governmental oversight and intervention?
Regarding vessel
construction standards, while both the United States and subsequently
the International Maritime Organization (IMO) have now mandated the
phase-in of double-hulled oil tankers over the next couple of decades,
this still leaves Sakhalin and Japan exposed to unnecessary risk in the
interim. Double hulls provide a significant degree of reduction in risk
of oil spills in the event of grounding or collisions of loaded
tankers. For instance, Conoco Oil Company, which went ahead and built
all double-hulled tankers far in advance of the U.S. and IMO
requirement , has had two potentially serious incidents recently,
neither of which resulted in an oil spill because the vessels were
double-hulled. In 1996 the "Randgrid," a double-hulled Conoco tanker
with 1 million barrels of oil onboard, grounded on a rock reef in
France and spilled no oil. And in 1997, a barge flotilla slammed into
the "Guardian," another double-hulled Conoco tanker with 550,000
barrels of oil onboard in Louisiana, and although a 120 m gash was torn
in its hull, again not one drop of oil spilled. A statement by Conoco
said "in both incidents, the ships' outer hulls absorbed the brunt of
the impact and, although penetrated and heavily damaged, protected the
inner hulls and prevented any loss of cargo."
The government of Japan has requested the IMO
to accelerate its phase-in schedule for double-hulled tankers ,which
began in 1994 for any new build, and extends to 2024 for pre-existing
tankers. It is recommended here that the Japanese government move
ahead unilaterally, outside the IMO process, to legally require all oil
shipped in territorial waters of Japan to be hauled only in
double-hulled vessels as of 2005. Similarly, the Russian government
should insist that only double-hulled tankers be used to transport oil
from the Sakhalin project. The double hull spacing should be sufficient
- the National Research Council in the U.S. recommends that inter-hull
spacing be at least the beam width of the vessel divided by 15, or 2
meters, whichever is greater. Further, these tankers should be fitted
with twin engines, twin rudders, and bow thrusters. This is the sort of
tanker now being built by ARCO in the U.S., called the "Millennium
Class Tanker.
" As the entire
world tanker fleet of approximately 3,000 vessels will have to be
replaced over the coming two decades or so, one wonders if this might
be considered as an economic development opportunity for the Russian
Far East. If Russia could develop a state-of-the-art shipbuilding
capability, with the highest standards anywhere in the world, it could
conceivably capture a portion of this enormous economic potential,
which will run into the several hundred billion dollar range. It must
be stressed that contracts for these new vessels should go to shipyards
with the highest possible quality standards.
Short of requiring all shuttle tankers to be
double-hulled at the outset - which clearly is the best safety
precaution - the Russian government should push for a more aggressive
phase-in of the new vessels and phase-out of the old, single-hulled
vessels. If this is the option chosen, then there are several interim
structural and operational measures that should be mandatory for all
single-hulled vessels. Restrictions against carrying oil in wing tanks
will provide additional protection in the event of an accident
(particularly collisions), and hydrostatic balanced loading, whereby
the cargo holds are not filled all the way so that in the event of a
hull rupture the inward pressure of seawater is greater than the
outward pressure of oil, would greatly reduce oil outflow in grounding
situations. Industry representatives have stated that the costs of
implementing both hydrostatic balanced loading and the use of empty
wing tanks would only be about two cents per gallon of cargo hauled.
Another interim possibility is to fit single-hulled cargo holds with a
horizontal mid-deck, essentially resulting in a hydrostatically
balanced load. Extensive testing has confirmed the validity of the
mid-deck design. Such minimum interim measures should be mandatory
until the entire Sakhalin fleet is double-hulled, with redundant engine
and steering systems.
Another concern is
that, if VLCCs with a loaded draft in excess of 20 meters will be
accepted at the Vitiaz' terminal, which is in only 30 meters of water,
might heavy swells lead to a dangerous situation where a fully loaded,
single-hulled VLCC could actually bottom-out in wave troughs while
moored alongside the Okha? Ten meters of clearance in large sea swells
does not give much room for comfort.
Regarding the pre-loading vessel inspections at
the FSO, it is important to understand just how thorough such
inspections will be - will they include the tanker's inert gas system
operability, the oily water separator, fire fighting systems, cargo
pump emergency shut- down systems, tank level alarms, combustible gas
detectors, steering gear systems and failure alarms, back up steering
gear operability, emergency generator operability, vent pipes, pumproom
shutdowns and explosion proofing, navigation equipment, engine room
systems, and so forth?
Vessel
Traffic/Shoreside Monitoring: Another concern is the vessel traffic
situation off Sakhalin and Hokkaido. As the EIA for the project states
that northeast Sakhalin has fog about 1/2 of summer days when these
tankers will be navigating the area, the vessel traffic situation needs
to be thoroughly analyzed and routing agreements should be established.
These agreements could include at a minimum a traffic lane with a north
- south traffic separation scheme that is located as far from shore as
possible. This assessment should also identify what shoreside
monitoring system would enhance the safety of navigation both off
Sakhalin and off Japan - a vessel traffic service (VTS), an automated
dependent surveillance system (ADSS), vessel transponders and shoreside
tracking, and/or tug escorts in hazardous seaways. Additional
navigation aids should be considered along the entire route of the
transit tankers.
Of critical concern, and again not addressed at
all to date by the company or apparently by the government, is how to
render assistance to disabled tankers. A plan should be developed that
would identify and evaluate existing tugs and emergency towing and
salvage capabilities both in Russia and Japan, and include an
assessment of various alternative equipment and deployments that would
improve the safety of the system. Protocols should be clearly
established whereby tanker masters are required to immediately notify
Russian and/or Japanese authorities of any loss of power or steerage,
so as to avoid potentially disastrous delays in dispatching rescue tugs
to the scene. Emergency tow packages similar to those employed in
Prince William Sound, Alaska should be required on all transport
tankers and the FSO, and the salvage assets of Sakhalin and Hokkaido
should be assessed.
Also,
communication protocols should be established whereby loaded tankers
are required to report positions along their transit route to both
Russian and Japanese government authorities.
Crew: Finally, because over 80% of
maritime disasters are caused by human error, it is incumbent upon the
governments to insist on the highest possible crew standards for the
shuttle tankers and the FSO. The IMO Standards for Training,
Certification, and Watchkeeping (STCW) Convention of 1984 provides just
the bare minimum, and Russia and Japan should insist on higher crew
standards. In general, the quality of seafarers has eroded over the
past few decades. Crew complements are now about 1/2 of what they were
just 20 years ago, which causes increased fatigue, additional stress,
reduced on-board training and maintenance time, decreased morale, and
less ability to respond to emergencies. Also, many ship owners are now
relying on manning agencies to supply crew, who generally supply the
least expensive, least experienced, multinational crews that often have
trouble simply communicating with one another in a common language.
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