A general overview of
potential environmental impacts of offshore oil and gas development off
Sakhalin is useful in order to understand the full scope of effects on
the environment. The Environmental Protection section of the EIA for
the Sakhalin II Project contains an overview of some potential impacts
off Sakhalin. The environmental impacts can be either those chronic
impacts expected from normal operations, or those acute impacts from
serious accidents.
In general,
Sakhalin Energy suggests that direct environmental impacts associated
with project implementation include withdrawal of oil, gas, and
condensate; introduction of chemicals, noise and vibration; solid and
liquid sanitary and production waste; and habitat effects. Pollution
introduced into surrounding waters will come mostly from drilling
wastes, which include spent mud and cuttings, cementing waste, produced
fluids, process water, drainage wastewater, etc.
Impacts from the construction &
installation phase of the project can include increased water
column turbidity from dredging; disturbance of sea bed areas in
preparing platform foundation; avoidance of the area by marine
wildlife, including fish and marine mammals, arising from construction
noise, vibration and the presence of erected facilities; exclusion of
commercial fishing and shipping operations from the immediate area; air
emissions associated with vessel and construction equipment; wastewater
discharges; habitat alteration; and accidents and upset conditions such
as fuel spills and vessel collisions.
Impacts from the drilling
& production phase - include discharges from the Molikpaq, the
Floating Storage & Offloading (FSO) Unit and vessels including
crude oil, discharge of 5,000 barrels/day (675 tons) of drilling fluids
and produced water; operation and maintenance activities such as pipe
cleaning and equipment washing; drilling activities such as shipment of
drilling mud constituents, mud preparation, cuttings handling, etc.;
air emissions from Molikpaq, the FSO, and vessels; and marine habitat
loss due to placement of the pipeline and Molikpaq, and from noise,
vibration and physical presence of structures offshore; and accidental
spills from Molikpaq and the subsea pipelines, operational accidents,
and vessel collisions.
The largest intentional discharges are expected
to be the large volume discharge of produced water and drilling fluids
and cuttings. Produced water consists primarily of relatively warm
water (60 degrees F) from the oil reservoir, containing dissolved and
dispersed oils, high salt concentrations, heavy metals, and no oxygen.
The project is expected to discharge the 5,000 barrels/day of
wastewater at a depth of 5 meters, which SEIC states should be
sufficiently diluted within the 500 meter mixing zone around the
platform to meet Russian water quality standards - 29 mg/L oil with a
daily maximum of 42 mg/L. It should be pointed out, however, that these
levels are toxic to a number of marine organisms. And, as the industry
is fond of pointing out, many marine organisms are actually attracted
to offshore rigs, thus putting them inside the mixing zone within which
they are exposed to much higher, toxic levels of various pollutants.
That SEIC will be monitoring the sediment throughout the project is
good, but a realistic picture of ecosystem effects would require the
monitoring of toxicant levels in marine organisms as well.
Of greater concern
is disposal of drilling fluids and cuttings. The drilling muds are
chemically complex, formulated fluids circulated into the bore hole to
control temperatures and pressures, to cool and lubricate the drill
bit, and to remove drill cuttings from the bore hole. The cuttings are
small fragments of subsurface rock that break and are incorporated into
the drilling mud. The muds consist of various chemicals, including
weighting agents (barites), gelling and deflocculating agents
(bentonite clays), deflocculants and filtration control agents, pH and
ion-control substances, bactericides, corrosion inhibitors, lubricants,
and defoaming agents.
Of the four disposal methods possible -
overboard marine discharge, shore disposal, injection, disposal in
Molikpaq's core - SEIC has chosen the easiest, cheapest, and
unfortunately the most environmentally damaging method - overboard
marine discharge. They state that overboard discharge will result in
"limited, short-term environmental impact in the immediate vicinity of
the platform...due to physical smothering and short-term oxygen
demand." They assert that "there is not a suitable receiving formation
into which Molikpaq's wastes could be injected." This assertion should
be independently verified.
The only area in
the U.S. where the oil industry is allowed to discharge drilling muds
and cuttings into the marine environment is in Cook Inlet, Alaska,
where some of the strongest tidal flushing in the world is found (10
meter tides). Just this month however, environmental groups filed a
lawsuit seeking to close the marine discharge option in Cook Inlet
based on concerns of toxic contamination. A recent study by the U.S.
Environmental Protection Agency found cadmium, which is one of the
heavy metals found in drilling muds and cuttings, in several marine
invertebrates used for subsistence foods.
While drilling muds from the Molikpaq will be
reused to some extent, normal drilling operations are expected to
intermittently discharge into the marine environment from 80 - 160
cubic meters of drilling muds/hr., in 1 - 2 hour periods. Ultimately,
about half (2,000 cubic meters) of all the drilling mud and all (5,300
cubic meters) of the drill cuttings from the project will be discharged
into the sea. SEIC states that this will cause turbidity from sediment
load suspension and increased heavy metal pollution from weighting
agents and clays. Heavy metals known to be elevated by drilling mud
disposal include mercury, lead, zinc, cadmium, arsenic, and chromium,
many of which are known to bio-accumulate to toxic levels in the food
chain. Also, there is evidently little consideration given to the
potential introduction of exotic marine species from shuttle tankers
deballasting before loading at the FSO.
The company
suggests that most of the operational impacts discussed would be
short-lived, very localized and thus of little environmental
consequence. This is doubtful and should be confirmed or refuted in
independent analysis. Furthermore, Sakhalin Energy has not conducted a
cumulative impact assessment, which is required in the United States.
Federal law in the U.S. requires that environmental impact analyses for
Outer Continental Shelf oil development include all "Past, present, and
reasonably foreseeable future actions or activities." This is to
include not only past, present, and potential future oil and gas
activities in the area, but also all "non-OCS" activities. Non-OCS
activities include such things as dredging and marine disposal of
dredge wastes, municipal wastes, radioactive wastes, obsolete
munitions, industrial and municipal wastes; coastal and community
development which alter coastal hydrology, reduce wetlands, logging of
coastal forests; commercial fisheries; other non-energy mineral
development; and other transportation of oil and gas through the
region. Such an analysis for Sakhalin and the Sea of Okhotsk should be
conducted to get a complete, synoptic picture of how impacts of the oil
and gas projects will add to other overall ecosystem impacts. The
impacts of the Sakhalin-II project cannot be adequately assessed in
isolation from the other offshore oil and gas projects (Sakhalin I -
VI), and other human activities in and around the Sea of Okhotsk. SEIC
representatives stated publicly (at the SRC Symposium) their agreement
with the need for a cumulative impact assessment in the region.
Of far greater
concern than the chronic, operational impacts of the project as
discussed above is the real threat of a catastrophic accident -
structural failure; blowouts; and process system "upsets" such as fires
and explosions. History shows that catastrophic failure of complex
human-machine systems can result from relatively small system
anomalies. Structural failure of the Molikpaq, the offshore pipeline,
the FSO or the Single Anchor Leg Mooring (SALM) buoy could be caused by
seismic events, extreme seas, sea ice, corrosion, steel failure, etc.
Well blowouts can occur as a result of overpressurization, and could
release significant quantities of oil into the marine environment, as
could explosions/fires in the system. While the company suggests that
several design criteria will be incorporated into the system to prevent
such catastrophic failures, they give little specificity regarding such
criteria. For instance, they suggest that hazard analyses "will be
conducted" and other criteria "will be developed," but do not further
elucidate the details of such important components as the emergency
shutdown system, the design criteria for the emergency depressurization
system, the criteria for the fire suppression system on Molikpaq and
the FSO, the structural integrity of Molikpaq, etc. Such emergency
systems should be examined independently, and the company must strive
to satisfy government and people of Sakhalin that the most stringent
safeguards have been incorporated. These are all very real threats, and
should be of great concern in Russia and downstream in Japan.
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