Central European University
Department of Environmental Sciences and Policy
Academic year 2003/2004
Environmental Assessment & Management
Professor A. Cherp
EVALUATION OF THE QUALITY OF THE DRAFT EIS OF
THE SAKHALIN II ENERGY PROJECT
VOLUME II: PLATFORMS,
OFFSHORE PIPELINES AND LANDFALLS
Svetoslav Apostolov
Oana Boingeanu
Iordan Hristov
Milena Novakova
Zita Szecsenyi-Nagy
Anastasiya Timoshyna
Budapest - 2004
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List of contents
Introduction………………………………………………………………………………………………2
I. Existing Environment (Chapter 1) (OANA BOINGEANU)…………………………………………..4
II. Existing Environment (Chapter 1) (IORDAN HRISTOV)……………………………………………8
III. Project Description: Offshore Field Development (Chapter 2) (ANASTASIYA TIMOSHYNA)..…11
IV. Project Description: Offshore Field Development (Chapter 2) (ZITA SZECSENYI-NAGY)……….15
V. Impacts Assessment, Mitigation and Monitoring (Chapter 3) (SVETOSLAV APOSTOLOV)………19
VI. Impacts Assessment, Mitigation and Monitoring (Chapter 3) (MILENA NOVAKOVA)…………..23
Overall conclusions………………………………………………………………………………………28
Reference list…………………………………………………………………………………………….30
Annex 1 Collation sheet of the quality assessment
Introduction
As the part of the Environmental Assessment and Management Stream assignment our group
focused on a specific part of the draft EIS of the Sakhalin 2 Energy Project: Platforms, Offshore
Pipelines and Landfalls (Volume 2 of EIA).
The quality of the EIS was assessed using the instructions in Part B of the OP 55 members of
group reviewed the quality of the BTC Project EIS (Lee et all. 1999) guidance as well as other literature
sources available. The team divided the chapters to be analyzed and met several times to discuss the
progress. Everyone reported on the progress and based on the final discussions the individual evaluation
agreed on common mark for the relevant review area and all relevant review categories, with a general
understanding of the other chapters of EIA, relevant for the task. Emphasis during the evaluation process
has been done on the question raised up during the December 18 Briefing held by the Sakhalin Energy
Investment Company (US DoT 2003)
The Lee-Colley Environmental Statement Review Package is one of the methods developed for
evaluating an EIS. In the basis of an evaluation there is the hierarchical structure of an assessment, which
allows to come from the simplest and smallest details of an EIS to the more complex and broad. The
Volume, to give the best possible evaluation, has been divided between 6 members of the group, each
performing individual tasks and coming up with own conclusions and recommendations that can be found
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in the respective parts of the paper. Next chapters with given tasks were divided between the next
students.

Oana Boingeanu assessed the physical conditions in the area that may be affected during the project
development;

Iordan Hristov evaluated the described baseline conditions of the existing living environment around
the Sakhalin project area, focusing on three main questions: the comprehensiveness of the description
of each element of the environment; relationship of that particular element with the others; data
explaining what will happen in the ecosystem if an accident occurs;

Anastasiya Timoshyna focused on the platform development description: details of the construction
phase, operational activities, possible wastes and emissions produced during the whole cycle of
platform existence. Comments considering the Communication of results are also provided in the
chapter;

Zita Szecsenyi-Nagy provided the assessment of the Subsea infrastructure development,
concentrating on the impact of gas and oil offshore pipelines. The other field of assessment was the
alternatives of the specific details of project implementation, including the site, technological process
to be implemented, production specification;

Svetoslav Apostolov evaluated the significance of potential impacts associated with project
implementation specifically associated with the offshore platforms and pipelines, temporary
infrastructure and associated activities. Specific focus is given to the impacts on seabed
sediments/hydrodynamics, water quality, benthic habitats, plants and animals, fish and shellfish,
seabirds, sea mammals, fishing activity and navigation, ambient air quality, and landscape and visual
resources;

Milena Novakova evaluated the impact and mitigation measures towards the next elements of the
environment and types of activities: fishing activities and hunting, shipping and navigation, air
quality, landscape and visual resources. Also an abandonment and decommissioning, emergency
events, cumulative impacts, transboundary impacts, monitoring and management are evaluated.
Results of the assessment are to be found in the conclusions and the body text of the respective parts of
paper, partially in the general conclusion of the evaluation and the Collation sheet, presented in the
Appendix 1. Collation Sheet contains the aggregated grades that were obtained after the discussion
process between the members of the group. This evaluation argues that the draft EIS should not be
accepted.
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I. Existing Environment (Chapter 1) (OANA BOINGEANU)
1. Methodology
The quality of the EIA was assessed mainly using the Lee-Colley package (Lee et all. 1999)
guidance. The team divided the chapters to be analyzed and met several times to discuss the progress.
Everyone reported on the progress and based on the final discussions the individual assessment is done
for the chapter analyzed and the relevant review topics, with a general understanding of the other chapters
of EIA, relevant for the task.
As we were in charge of only a small part of the complex EIA we became aware of the
inconvenient of not being very familiar with the whole complex process analyzed. This is just a specific
of this context otherwise it should not be an obstacle in the quality assessment. Questions that were
specifically raised under this chapter might be answered in some other parts of the EIA, and this would
improve the quality of the EIS, but it would have been appropriate to be found in this part in order to
increase to make the process more efficient.
2. Quality assessment
Chapter 1 –Existing Environment describes the study area and the current environmental
conditions, which might be affected by the proposed platforms and pipeline developments. This chapter
was divided between two members and the marks were given on a common agreement.
The specific components I addressed include:

Climate and meteorology

Hydrography and oceanography

Seabed morphology and sedimentology

Coastal morphology and land use

Marine geology and seismic stability:
The baseline survey is meant to describe in detail the physical conditions in the area that may be
affected. Its purpose is to create the basis of comparison between the conditions that exist before the
project is done and the conditions after the impacts. Environmental components facing the strongest
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negative impacts should be identified and labeled accordingly to be studied more accurately as key
components.
According to the Lee-Colley criteria for reviewing the different categories the following gaps
were identified:
1.4
Environment description: The area and location of the environment likely to be
affected by the development proposals should be described – D
-
There is only a General Location map in the beginning of the chapter which can not be considered
suitable for a good understanding of the environment expected to be affected by the development of the
project.
A detailed map with all the physical features (relief, hydrography, altitudes) should be
included;
-
The environment is presented broad enough but there is no comprehensive integration of the
components so that the functionality of the overall system can be easily understood. The geo-physical
system is the support of all the activities and their consequences therefore it should be well understood
in the overall complex context. The coastal system is in general considered a sensitive eco-system but
there is not enough attention given to this aspect in order to present a real image of the environment to
be affected. More information should be given about the way the component elements interact. A
geomorphologic map, to include the localization (possible occurrence) and nature of the geomorphic
processes likely to develop, could be used in analysing potential geomorphic hazards. It could correlate
various types of geomorphic risk on the shore with relief steps and the hydrometeorological factors
liable to exists in these areas. The same type of integrated analysis on coupling factors should be done
for the oceanographyc system.
1.5
Baseline conditions: A description of the affected environment as it is currently, and as
it could be expected to develop if the project were not to proceed, should be presented. C
-
Components of the affected environments are identified and described but given the complexity
of the project more observations would be needed to answer at least the next questions:
1. What are the main changes in the coastal configuration, the erosion and redistribution of sediment that
can be anticipated so that the disturbance caused by the construction associated with the landfalls of the
outfall and oil pipelines can be anticipated;
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2. Are currents strong enough to mobilize sediments and cause considerable change to the shoreline’s
configuration over a short period of time, as a result of only natural processes, including sea level rise and
near shore currents?
The associate methods to obtain such observations should be used and mentioned in the report.
-
There is no information about the ground types in Sakhalin nearshore environment as a very
important component of this particularly sensitive environment, which can be considered a significant
omission;
-
There is uncertainty in the case of tsunami and earthquakes occurrence, faults and gas anomalies
presence and potential intersection with the drilling wells but it is not well indicated and therefore it is
doubtful if it was properly taken into consideration in impact prediction.
-
The region is considered seismically unstable region with regular earthquakes but there is not
enough information about this hazard. Different sources assign different orders of potential magnitude;
there is not a lot of emphasis on the fact that this is a highly seismic area in a dynamic environment;
-
Relevant maps (land altitude and water depth, geologic hazards, ground types near shore) are
missing and the ones used can not be clearly read and interpreted; Aerial photos could give a more accurate
picture of the dynamic processes which are shaping the area;
-
Indicators are used to asses the quality of the water and air but standards are not mentioned all
the time (no thresholds for nutrients presence); no observations on what their variations could be (between
samples or stations, or surveys, with water depth etc.);
-
No particular favorability for the two locations of platforms is explained in order to exclude
other sites and justify minimised impacts on the near shore environment. No scientific base is given to
present and reject alternatives. There is no figure about the estimated hydrocarbons deposits, which will be
exploited in the area.
-
No information about the impact of the Phase I on the existing environment; are the current
conditions just the result of the existing natural and economic conditions or are already altered by the first
phase? This is important further in estimating cumulative impacts.
-
There is no clear identification of key components and key hazards (erosion, seisms, volcanic
activity); no ierahization of physical features and processes that have different sensitivities ( ex: highly
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mobile sediments - disturbance of highly mobile sediments will lead to increased water turbidity as well as
increased sedimentation as the sediment settles)
-
Faults and gas anomalies are considered the only geo hazards but no risk assesment is done;
-
No land use plans or maps are shown or mentioned to be used to provide information about the
utilization of the coastland. This could provide information about the locations of important elements of
exiting natural and antropic environment and where the new elements would fit in.
The main deficiencies in the communication of results are:
-
Presentation of data is not well sustained by relevant maps which are necessary in the
description of the physical environment;
-
Statements are often made without enough scientific explanatory data and no methodology to
explain the results;
-
The importance of some existing natural factors is minimized (seismicity).
Conclusions
There is not enough information, data and data interpretation about the existing environmental
physical conditions. Parts are well attempted but must, as a whole be considered just unsatisfactory
because of omissions or inadequacies, such as:
-
no suitable relevant maps
-
no information about soils;
-
no analysis of coupling meteorological and oceanographic conditions with the
other elements of this complex environment;
-
no risk assessment for cyclones and seismic activity ;
-
no emphasis on the most vulnerable components.
The accuracy of the impact predictions is therefore doubtful, as there is not complete assessment
of the environmental conditions. No key elements are identified nor labeled so that further key impacts
can be analyzed. Imprecision and lack of detail of the statements about environmental components lead to
the necessity to make assumptions leading to further inaccuracies.
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II. Existing Environment (Chapter 1) (IORDAN HRISTOV)
Introduction
This chapter reviews the described baseline conditions of the existing living environment around
the Sakhalin project area. The description is part of chapter 1 in volume 2, from the EIS for the Sakhalin 2
Energy Project. The revision will cover three major aspects. The first one will look at the
comprehensiveness of the description of each element of the environment i.e. What is there? The other
aspect, will look at the relationship of that particular element with the others i.e. Why it is there?, and
furthermore, will be checked data explaining what will happen in the ecosystem if an accident occurs.
Reviewing these aspects is a base for the future estimation of risks and impact assessment of the project
on the environment and is considered for the “essence of ecological impact assessment” (Treweek 1999).
The components of the existing environment that will be reviewed are marine invertebrates and fish
communities, marine mammals, seabirds, and the human environment. This revision will argue that the
description of the baseline conditions of the existing biological environment that is done in chapter 1 of
volume 2 from the EIS is not done thoroughly. As a result, comprehensive EIS and precise prediction of
impacts cannot be done because of the existing gaps.
Throughout the whole part of chapter 1 in volume 2, which describes the living environment was
not found the role of particular group of organisms in the environment. A description of the way the
ecosystem works is necessary i.e. How does a particular element relate to the others? What amount of
biomass or phytoplankton does a representative from a community need and has? What are the products
that one organism produces and is used by other organisms. This information will help us describe the
functions of each element of the existing ecosystem. Without knowing how an ecosystem functions one is
not able to predict the reaction of the ecosystem if an element belonging to that ecosystem is affected.
Besides the “internal” ecosystem relationship, information was also not found for the “external”
relationships. When a number is given, it is not explained whether it is high or low. The number is not
related to similar environmental conditions. Besides the Gray Whale, there is a lack of information for the
percentage of the local number of organisms in relation to the population size on a larger scale. This
information would help us estimate how important is the particular population and what might be the
possible results on a larger scale if an accident occur - whether an accident will lead to the extinction of
the species from the Earth or will harm the local population.
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It could not be found information for the viability of the populations. Information was not found
about the minimum number of individuals from particular species that could guarantee that the population
would not become extinct if an accident occurs. To prove the viability of the species populations, data
should be given for the numbers and distribution of reproductive individuals and insure the long term
existence of the organisms in the area (USDA 1982). Although there is a figure for reproductive Gray
Whales, it is not said the birth rate, which will tell us how many whales annually can be calved and how
viable is the population in long terms. Having in mind the long period needed for whales to reach a sexual
maturity – 5 to 11 years (ACS 2004), the long period of nursing the calves – 7 to 8 months (ACS 2004),
and the low birth rate - one calve per two years or more (ACS 2004), it should be explained the sensitivity
of the species to disturbance. If a precise prediction of the viability of the population is not made, even a
small-scale impact might cause the extinction of the local population and further degradation of the
ecosystem can occur.
There is an overall scarce of visual materials representing the abundance, distribution, species
composition, densities of populations, and movements. As a result one will not be able to predict the
impact of the platforms and the pipelines connecting the platforms with the shore.
1. Gaps in describing the Marine invertebrates (plankton species, benthic communities and fish
communities):
1.1 plankton.
-
There is a wide use of scientific terms and information, which are not explained. For
example, it is not explained the meaning of primary production of the plankton.
1.2 fish communities
-
The conservation status of fish species is not given, so one cannot assess the value of the
fish species and the outcomes if an accident occur.
-
There is no justification of the time when the survey of the pink salmon migration was
done. Thus the results from the survey might be biased and the impact assessment will be lowered.
-
When describing the fish communities, is mentioned that a survey of the salmon migration
routes was done (p.1-34) and pipeline routes were proposed. However, further in the text is said that
this same survey is “not considered for representative” (p.1-34). If results from a survey are not
considered for representative, how can be assessed the impact of the proposed platform sites and
pipeline routes?
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3. Gaps in describing the Marine mammals (whales, dolphins, seals, sea lions):
-
There is a contradiction in the part describing the distribution of the gray whale (p.1-53). It
is said that the whales do not form dense aggregation during the feeding period when they scatter
along the coast. However, the coast length is said to be 90 km (p.1-53). If the estimated number of
whales is 100 individuals that means that for every km of sea coast there will be more than one whale.
Having in mind the large size of the whale – 13 to 14m (ACS 2004) and the mentioned amount of
food it needs – 400 to 1200 kg/day, this distribution can be considered for dense. In addition, fig 1.9
shows high density of observations of gray whales, although it is not clear what does every dot from
the map mean - whether it is a single observation or it corresponds to certain number of whales.
-
In the briefing notes is mentioned a possible displacement of the gray whale populations
from the Piltun Lagoon to the Chayvo bay, which is situated to the south from the first place. Another
statement in the briefing notes says that it was not identified any displacement of the whale
populations, which contradicts the first statement. On the base of this statement, the impact
predictions are done, which can be considered for biased conclusions.
4. Gaps in describing the Seabirds:
The part describing the birds has lack of information concerning the density of the bird
populations, the availability of food resources for them and the viability of the populations.
5. Gaps in describing the Human environment:
-
It is not given the amount of fish caught per year;
-
It is not justified the conclusion that collection and cultivation of algae in the area will be
on a small scale;
-
It is concluded that tourism activity in the area is absent because the area is swampy and
marshy (p.1-69). However, birdwatching tourists choose such areas for tourism destinations because
of the variety of birds in such areas.
Conclusion
The major gaps in the description of the existing living environment are lack of information for
the viability of the populations, the way the ecosystem functions and role of each group of organisms in
the ecosystem. Without this information, the precise impact from the project cannot be assessed and the
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relevance of the conclusions can be questioned. The existing gaps are a prerequisite for biased
conclusions when predicting the impact. On the base of the identified gaps, the Environmental Impact
Statement cannot be accepted before these gaps are fulfilled.
III. Project Description: Offshore Field Development (Chapter 2) (ANASTASIYA
TIMOSHYNA)
Introduction
This chapter provides an assessment of the part 1 Platforms of the Chapter 2, Volume 2 SEIC
Environmental Impact Statement Project Description: Offshore Field Development. The offshore
development project includes two parts: Platforms and Subsea infrastructure. The part assessed by the
author was the platform development description. The methodology of estimation the quality of the
Environmental Impact Statement included the analysis according to the Lee-Colley Quality Assessment
Package (Lee & Colley 1999). Besides, the analysis of available literature sources, as well as electronic
sources available. Author analyzed the material provided in the EIS according to the criteria of the
Quality Review Package starting from the sub-categories and then accumulating the mark in the hierarchy
of categories. It should be taken into an account, however, that the general grading of categories 1.1, 1.2,
1.3 and the subcategories in the mentioned categories might differ from those, given below because the
second part of the Chapter 2 (Subsea Infrastructure) has been evaluated by the other member of the group
and later the grades were aggregated in order to receive the overall assessment mark.
Chapter analyzed provides information on the construction, commissioning, operation of
platforms Piltun-Astokskoye-B (PA-B) and Lunskoye (LUN-A) Platforms. The Chapter includes
explanation of the technological processes to be done during the operation stages, terms of completing the
stages of work, wastes and emissions to be produced as the by-products of the activities. The author’s
comments according to the assessment of the Chapter quality are developed in further sub-chapters.
1. Description of the development evaluation
1.1.1 Purposes and objectives of the development are explained, though no explanation
according to the choice of object placement is given in the given chapter of the Volume 2. Referencing to
the Volume 1 and thus recognizing the EIS in a full size grading might differ. Though in a case
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1.1.2 design and size of project facilities are described; in the introductory part of the volume the
general map of Sakhalin Island with the projected sites for these concrete activities is shown, the structure
and layout of the facilities is shown on a graph (though here the detailed indications of the part of
facilities would have been useful) B (improve the graph/map with more technical details and
explanations)
1.1.3 The project is not an upgrade development, but the building of new facilities (PA-B and
LUN-A platforms), thus there is no indication of the physical presence of a facility within the receiving
environment. However, according the up-to-date information available through the SEIC web-site (SEIC
2004), even before January 2004, the preparation works are being done on the site. This information, to
our opinion should have been mentioned, as it would indicate the possible impact on the environment.
Besides, the question (2.4.) was upraised in the US Department of Treasury Environmental Questions list
(US DOT 2003) among others to be addressed at 18 December 2003 Briefing, which also indicates its
importance. However the answer was not given during the Briefing itself (Briefing Notes 2003) nor they
are highlighted in other chapters of the EIS.
1.1.5 The only information given about the nature and quantities of raw materials for the
construction of platforms is the fact that ‘platforms will be manufactured outside of Sakhalin, probably in
the Russian Far East or Southeast Asia’ (EIS, Vol.2, Ch.2, 2.2.3), also the numbers of material to be used
for strengthening the ‘legs’ of platform are given, however without mentioning the possible sources of
raw materials.
2. Site description assessment
1.2.1 The land area taken up by the development site is defined, however, there is lack of a clear
map, showing the site placing (the clarity of maps is a general comment for improvement along all the
assessment period)
1.2.2 Uses are described, as for the platform construction only the sea zone is used. Otherwise,
there is an indication of the spatial relation of the fishing zones, which can be defined as the certain land
use type, to the projected exclusion zone of 500 m around the platform (the effect of this is discussed
while assessing the impact prediction and mitigation measures - Chapter 3, Volume 2)
1.2.4 The approximate number of workers during the construction phase is estimated, though for
the operational phase ‘number of personnel are not yet known as these will be determined by the
contractor’ (Vol.2, Ch.2, p. 17).
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1.2.5 Support logistics is described; for the products to be transported from the platforms to the
onshore facilities, it is assumed that the offshore pipelines are to be used (however, it is not clearly
mentioned in the text of the EIS)
3. Wastes description evaluation
1.3
Types of waste matter are described, though showing no comparison with the limit
values/maximum or average concentrations allowed. Types of wastes and emissions are counted
independently for different processes to occur during the Phase 2 Sakhalin project: construction, testing
and commissioning, drilling and operation decommissioning. No routes by which the wastes will
eventually be disposed of to the environment as well as no answer of the environment towards those
intrusions are mentioned. As for the methods by which the quantities of residuals and wastes were
obtained, the only thing mentioned is the reference to the TEO-C Volume 2A&2B, Book 8, Appendix E1.
No method on how the data have been received is provided.
The valuable gap in the EIS is the graphical representation of the data obtained. SO, on page 13,
there is table given Table 2.2. Waste Generation on the Offshore Platforms. However, there is no
possibility to read any of those data provided either in the electronic form or the printed out version.
Though this comment might be considered in the part, which assesses the presentation of information, the
author is considering it to be also an essential point here, as soon as we were not able to analyze the
quality of data having no opportunity to read them.
The essential remark according the assessment of the Project description chapter of the
Volume 2 is the fact that there is an Engineering for safety (p. 6) part, which gives the superficial
overview as well as the analysis of models that have been assessed for each of the platforms. Amount of
simulation activities is quite impressive (approximately 300 thousand scenarios for each platform), the
figures given for estimation the individual risk of fatality per year are not informative enough. Thus, for
example the highest individual risk of fatality per year is 2.9 E-4 for the PA-B platform. There is an
explanation given for the limits, though in a form, which if difficult to understand. It seems to be
doubtful, that this kind of information will it be clear for the personnel, people who are interested in the
threat to their health and life from the activities performed. Besides, it is only mentioned, that ‘platforms
are acceptably safe according to international standards’ (p.8) with no reference to the standards
themselves.
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4. Communication of results assessment
The comments below are given only to the points, which were considered by the authors as
unsatisfactory (and thus given D or less grade).
While assessing we again faced that to make an objective evaluation authors have to take into an
account Volume 1 of the EIS. So, for example grading the quality of introduction, when considering the
EIS as a whole, it gives a good background to the EIS, however introduction to the Volume 2 lacks being
concise and enough broad to deliver the aims of the given project part.
Chapter of the Volume 2 lack the summaries outlining the main findings of each phase of the
investigation, though providing the introductory information about the object of the given chapter. In
several places there are not full references to the literature used, however, in the separate chapter of the
Volume there is a full reference list to the sources.
The information, presented in the EIS is not in all cases comprehensive to the non-specialist.
Tables, graphs are in many cases not readable, not allowing important information to be brought to the
reader.
As for the category 4.3 Emphasis (Lee & Colley 1999), generally the information provided in the
EIS was considered as satisfactory with omissions and/or inadequacies. However, while checking the
other sources of information available via the Internet, the author identified, that to some significant
threats not enough attention has been given in the EIS. Thus, in February 2004 US Congressmen has been
questioning the financing of Sakhalin-2 Project (which is done by the Ex-Im Bank, USA). The
explanation is given in the report.
‘the pipeline will cross 24 earthquake faults in one of the most seismically active areas of
the world and over hundreds of wild salmon spawning streams, the on-going threat of the project
to the endangered gray whale populations and pollution associated with the construction and
discharge from the largest liquid natural gas power plant in the world’ (Sakhalin Independent
2004)
Albeit this information, there is lack of attention and emphasis brought to lighten up the threat to
the projected facilities because of seismic situation in the region. The author considered this omission
serious as they threat to both the human health and the fragile marine environment of the sited place.
Conclusions
General comment: the assessment of the selected part of an EIS is having the limited character,
though it allows concentrating on numerous details. To give the high quality assessment still requires at
the minimum superficial knowledge of other project volumes and in some case analysis of those. For
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example, to assess point 3.1. of the Lee-Colley quality review package (Alternatives evaluation) for the
volume 2 of the SEIC EIA, we addressed to the Volume 1, where all the alternatives are discussed and the
supporting explanation to the choice of them is given. Otherwise, for point 3.1.2, there was need to
evaluate the description of alternative processes, designs and operating conditions, which required
necessary knowledge about the chosen object of the project development (in this case: platforms, offshore
pipelines and landfalls).
Similarly, when grading part 4.1: Layout, if taking only the excerpt, which is Volume 2, one may
not find the relevant and enough informative introduction, however, the general introduction, which is the
Volume 1 itself, gives enough amount of comprehensive information.
Part I of Chapter 2 Volume 2 Sakhalin-2 EIS can be assessed as generally satisfactory with minor
omissions/inadequacies.
Chapter,
concerning
waste
management
and
generally
amount
of
wastes/emissions produced is to be developed further. The description of methods by which the data were
obtained is to be included with the not-obscure language description of possible threats to human health.
Explanation of kinds of raw materials for the construction process is to be provided in order to evaluate
the possible impact to the environment through the life cycle of the product.
IV. Project Description: Offshore Field Development (Chapter 2) (ZITA SZECSENYI-NAGY)
Subsea Infrastructure
Inroduction
This chapter evaluates the quality of the EIS of the Sakhalin II Project with a special focus on the
Volume II, Chapter 2, which describes the offshore field development, the installation, commissioning
and operation of the sub sea infrastructure, offshore pipelines and landfalls. The review package
developed by Lee & Colley (1999) was applied to assess the quality of the environmental statement. The
review findings are listed on the Collation sheet (Appendix 1.). Strengths and weaknesses of the offshore
field development description are set down hereinafter.
Various alternative development options for the export routes of oil and gas were considered
(Volume 1 Chapter 5) and the shortest technically and environmentally acceptable pipeline configuration
(concerning to ice, faulting, constructability and access issues) was chosen. In case of the PiltunAstokhskoye platforms separate gas and oil offshore pipelines were designed, while in case of the
Lunskoye platform two multiphase pipelines were chosen in order to avoid increased environmental
footprint and cost. Landfalls were planned on the basis of environmental offshore and onshore surveys in
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order to optimise dredging volumes and to avoid nature reserves and near shore lagoons. Alternatives of
the offshore pipeline construction methods for landfalls were evaluated on the basis of the pathway of the
environmental impact, the potential receptor, the technical feasibility and their costs. Pre-trenching was
chosen, due to the possibility to install several pipelines and cables in the same trench. However this
method results in the highest volumes of excavated materials, which should be disposed.
1. Evaluation of the quality of the offshore field development description

Physical characteristics, diameter and length of the planned offshore pipelines, power and fibre optic
cables are well presented by Table 2.6. and 2.7. The location of the planned activities is given in
satisfactory details. Several maps, figures and tables are given in the Environmental Statement. A useful
overview (Figure 1.2 in Volume 1 Introduction) visualises the appearance of the Sakhalin II Project. On
the other hand some figures are not appropriate because of their bad resolution, like in case of the graph
about the depths and widths of the trenches on Figure 2.4 and 2.5.

Conflicting information is given about the Piltun landfall’s onshore manifold. In the second paragraph
of the 2.3.1 part (page 23.) it is said: “The four export pipelines will be tied into two 20’ (51 cm) diameter
pipelines at the onshore manifold”. Whilst at the Piltun landfall description (page 32.) it is written: “the
four oil and gas pipelines will be tied in via offshore manifold to one 20’ (51 cm) onshore gas pipeline
and one 14’ (36 cm) onshore oil pipeline”. The Figure 1.2., overview of the Sakhalin II Project in Volume
1 Introduction supports the first description.

Offshore pipelines detailed design is currently under way in the SAIPEM offices in Fano as part of the
offshore pipelines EPC contract. The environmental parameters, which were considered during the design
of the pipelines, are not presented in details. It is not known whether stability analyses have been
conducted using those parameters in order to ensure that the pipelines are suitable for the environmental
conditions. It is stated that concrete coated steel pipelines are protected against corrosion with a bitumenenamel coating and cathode protection, but no alternative coating techniques are evaluated – like
polypropylene, polyethylene-coating and anode protection (Azeri, Chirag and deep water Gunashli Full
Field Development Phase I Project). Sources of the methods, which were applied during the offshore
pipeline planning process, are not given and it is not clear, which standards were used during the
engineering phase. However among the legislation and project standards (Volume 1 Chapter 2) some
instructions, procedures and standards can be found in connection with pipeline engineering. (a)
Procedure for construction of underwater cable and pipelines in internal sea waters and in
territorial waters of the Russian Federation. Resolution No.68 of 26.01.2000 by the RF
- 16 -
Government, (b) 1973/1978 International Convention for the Prevention of Pollution from Ships
(MARPOL 73/78), (c) 1974 International Convention for the Safety of Life at Sea (SOLAS), (d) 1975
International Oil Pollution Prevention (IOPP) Certificate. Oil Company International Marine Forum
(OCIMF) Guidelines, (e) Environmental, Health and Safety Guidelines: Oil and Gas Development, (f)
World Bank Pollution Prevention and Abatement Handbook.

Offshore pipeline routes should be determined more precisely, especially at shore/platform
approaches and tie-in points, during the detailed engineering phase. It follows that EIA will have to be
accomplished continuously, in parallel with development process in order to assess further
potential impacts, since shore/platform approaches and tie-in points are the most probable to have
major impact in case of an unwanted event.

The tasks to be accomplished during the installation, testing and pre-commissioning of the offshore
pipelines are listed and discussed in details. During the installation phase it would be useful to place
exclusion buoys around the laybarge installation area to facilitate the safe passage of construction vessels
and to avoid disturbances by other vessels. The equipment for dredging and trenching are described,
though there is no information given about the source of the vessels and the requirements, which they
fulfil. The extension of the area of the pipeline trenches and the required volume of backfilling rock are
also estimated. However there is no description about the method, which were used to determine volume
of the backfilling material and no information is given on the amounts of the needed sand and gravel. The
potential quarry sites are not yet identified, which means that it is not possible to estimate the ecological
footprint and the environmental impacts of the whole project at this stage. (Quarries might have huge
impact on the environment, due to soil erosion, habitat loss and habitat fragmentation). The maximum
width of trench required for construction works should be confirmed during the detailed engineering
phase as well as the temporary exclusion zone. Specific methods for dredging, trenching and disposing
the dredged materials should be determined during the detailed engineering phase.

Some technical details about hydrotesting are omitted. Information about the applied hydrostatically
pressure during testing in comparison with the normal operating pressure and the “minimum hold period”
are missing (Azeri, Chirag and deep water Gunashli Full Field Development Phase I Project). The rate of
the injection (litres/min) and the amount of the additives, which are injected into the hydrotest water (like
biocides, corrosion inhibitors, detoxifier for the biocides and dyes), should be given. These chemical
compounds will be discharged at the pipeline landfall to the sea or on the platform site and can be toxic
for the environment, therefore they might present an environmental impact.
- 17 -

In case of the installation phase the SO2, NOx, CO, CO2, PM10 emissions are estimated by
SOFRESID (No 5025-Y-90-04-A-7002-00-Rev01). CH4 emissions are not indicated. There is no data
about the atmospheric emission during the commissioning and operational phase.

Generated wastes are estimated and described in the Position Paper Waste Management during the
Sakhalin II Phase 2 Project May 2003. It is stated that an extensive review of the Russian and
international legislation was undertaken and over 200 documents were examined in order to determine an
appropriate waste management strategy. However no adequate, detailed information is given about the
quantity and quality of the potentially generated wastewater and solid waste during the offshore pipeline
installation, commissioning and operational phase. The Technical and Economic Substantiation for
Construction (TEO-C) is cited as a basis for the waste management planning.

Vessels should be equipped with certified sewage systems capable of treating wastewater to an
acceptable level according to national (Federal Law “On Industrial and Domestic Wastes” of 24.06.1998.)
and international requirements, or vessels should collect wastes and transport them to shore for disposal.
Solid wastes should be classified by toxicity (hazardous or non-hazardous) and by material (combustible
paper, wood or non-combustible scrap metal) and handled separately.

Number of workers during construction is roughly estimated but there is no exact number given for
the operation of the pipelines.

Measures are taken to manage emergency events and to ensure a safer operation of the system. A
power supply is installed for emergency systems and for critical utilities in case of power cuts or
blackouts. A Supervisory Control and Data Acquisition system is provided at the main control centre. A
leak detection system and emergency shutdown valves are installed.

Decommissioning phase still needs to be designed in details. It is not the part of the Sakhalin II
project and it will be accomplished by the Russian Federation after the expiration of the SEIC licence
period.
Conclusion
The purpose of the offshore pipeline field development project is well defined, the construction, testing,
commissioning and operational phase are described in details. However there is no plan for the
decommissioning phase, which will be accomplished by the Russian Federation after the expiration of the
licence period of the SEIC. Sources of the data and the methods, which were applied during the offshore
pipeline planning process, are not referred and it is not clear which standards were used during the
engineering phase. Some details will be planned during the further engineering phase, which means that
- 18 -
EIA will have to be accomplished continuously, in parallel with development process in order to assess
further potential impacts. In the description of the development parts are well attempted but as a whole it
is considered just unsatisfactory. The site description part of the environmental statement can be
considered just satisfactory despite some omissions. Types and quantities of wastes and proposed disposal
routes are mostly inadequate or information and data sources are missing. However parts are well
attempted and this part is considered just satiosfactory.
V. Impacts Assessment, Mitigation and Monitoring (Chapter 3) (SVETOSLAV
APOSTOLOV)
Introduction
This chapter identifies and evaluates the significance of potential impacts associated with project
implementation specifically associated with the offshore platforms and pipelines, temporary infrastructure
and associated activities. The chapter is structured such that possible impacts are discussed for each
environmental resource or receptor.
An Issues Scoping Matrix was used to identify the possible impacts on the following resources/
receptors:
• seabed sediments/hydrodynamics;
• water quality;
• benthic habitats, plants and animals;
• fish and shellfish;
• seabirds;
• sea mammals;
• fishing activity and navigation;
• ambient air quality; and
• landscape and visual resources.
Consultations with the general public, stakeholders and experts are also said to have been applied
during the identification and signification process (see also Volume 1, Chapter 4).
- 19 -
1. The quality of the chapter will be reviewed hereunder based on the review package developed by
Lee and colleagues [1]
Detailed comments on the report
Detailed comments by sections, sections 3.3 through 3.8:
1.
Section 3.3: no impact description and magnitude prediction provided at all for this part.
Offshore dumping of sediments is said to be outside of the scope of this EIA, which is not correct – since
this activity is envisaged, sites have to be suggested and the possible negative effects should be described
and assessed as well. Misleading use of measuring units is observed – although in the list of abbreviations
a Nautical Mile is abbreviated as “NM”, in the text it is used as “nm”, which, according to the
international system for measuring units (SI) [2], is the abbreviation for a “nanometre”. No notice is taken
of the disposed dredged material in terms of disturbance of the sediments and hydrodynamics. Changes in
prevailing currents are not quantified – they are simply described as “localized” but no clear basis for that
judgement is provided. Since no description and magnitude of impacts are provided, it is not clear on
what basis the impact significance was determined as minor. No comment on the effectiveness of the
suggested mitigation measures is made.
2.
Section 3.4: no notice is taken of possible leaks from pipes. Impacts are not quantified (no
magnitude is provided) – two typical examples are the statement that “heated water will rapidly lose
thermal energy to the surrounding water column, reducing the plume temperature,” and that “Dilution and
dispersion will rapidly reduce the concentration [of discharges from service water systems and sewage
treatments] to below levels harmful to marine organisms.” However, neither the necessary volumes of
water nor the time needed for the processes are estimated – it is not clear how the capacity of the sea was
assessed so that no impacts were predicted in these cases. Same approach is followed till the end of this
section – see comments on hydrotesting of pipes, sanitary effluent, and scour protection measures. Some
modeling studies are mentioned but no description or references are provided, and their choice is not
justified. The report leaves the impression, that the seabed around the platform sites and the pipeline
routes is not studied for contaminants, as it is “not considered to contain high levels of contaminants”.
The effects of rain washing of contaminated deck areas are not commented on. The hazardous drilling
fluids are estimated to reach a distance of 250 m from the discharge source, however, no justification of
the assessment is made, and no impacts on water chemistry/quality are described. No indirect effects of
these on living organisms (through deteriorated water quality) are described. It is not clear at all on what
basis the judgement of the impacts’ significance is made since most of the impacts are not described in
details, and none of them is quantified.
- 20 -
3.
Section 3.5: no description and quantification of impacts in terms of magnitude and time-
span is provided. Benthic communities are claimed to be accustomed to sediment disturbance and
increased turbidity, however, no comparison between natural disturbance and that caused by construction
activities is provided to show that the anthropogenic disturbance would not exceed the natural, to which
the organisms are accustomed. The discharged cuttings and drilling fluids are expected to “be dispersed
further in currents”. However, the speed of dispersal is not specified, and no comment on the direction
and speed of the currents are provided to prove that these hazardous substances will not reach the habitat
of some important/protected benthic species. No comment is made on the possible effect of platforms’
shading part of the bottom. No comment on the effectiveness of the suggested mitigation measures is
made.
4.
Section 3.6: the disturbance of vessels and platform operation (e.g. vibrations, noise,
wastewater, toxic and heated water discharge, etc.) is not discussed in the impacts resulting from
commissioning and operation, though it is included as a significant disturbance for plankton and fish. No
comment on the effectiveness of the suggested mitigation measures is made.
5.
Section 3.7: the disturbance is not quantified, and might be considered even not described
properly, as it does not provide any information regarding its effect on bird populations. The mitigation
measures envisaged to reduce the potential impacts during construction do not avoid completely
disturbing areas of importance for birds. No comment on the effectiveness of the suggested mitigation
measures is made.
6.
Section 3.8: the possible adverse effect of cables on whales is not commented at all. There
is data suggesting that for some reason whales tend to become entangled in different types of cables laid
under water [3, 4, 5], and some sources suggest that telecommunication cables can negatively affect the
long-distance communication of whales [5].
2. Conclusions
1.
No description of the identification methods and no rationale for using them are provided.
2.
For most of the resources/receptors no impact description and magnitude prediction are
3.
Where the impact significance is predicted, it is not clear on basis of what that judgement
made.
is made.
4.
Mitigation measures have been suggested only for some of the activities. No justification
of the effectiveness of the suggested mitigation measures is provided.
- 21 -
5.
No maps were used to visualize the possible impact location and magnitude. In parts 3.6
and 3.8 a model, or at least a map, of the sea currents and the distribution of fish stocks and whales,
should have been used to visualize the migration and possible effects of discharges on the whales’
populations, and especially on the Gray Whale’s population, which is very close to the island.
6.
For the commented sections, no monitoring programme is proposed.
7.
No external data sources acknowledged in this part.
8.
The EIA looks quite biased as important impacts are not discussed or even not mentioned
(or nor reason for their omission is provided).
3. General comments on certain other aspects of the EIA Report
1.
Major weakness of the report is that it has not cared to gather enough data to properly
assess the possible impacts of the Project. For example, in Volume 7, Chapter 2, the EIA clearly states
that nothing is known on the Western Gray Whale ecology – no population numbers or dynamics, no
migration routes, only one summering and feeding place known – and no information on the wintering
places. It is not clear on basis of what in Volume 2, Chapter 3 the significance of the impacts on the Gray
Whales is estimated as moderate.
2.
Some of the suggested mitigation measures would pose a major threat to the environment
rather than compensate for negative impacts of the project – as is the case with the example of “in-kind
compensation” in part 3.4.2 of Volume 1, Chapter 3 (p. 3.9) and the sowing of rapidly growing grasses in
part 2.2.6 of Volume 7 (p. 2-6):
a)
The planting of new woodland (which will most probably result in a monoculture
plantation) elsewhere would in no way compensate for the lost biodiversity of a mature, fully developed
forest in the project region, with its extremely high variety of species and, hence, with its complex
interspecies interactions and trophic chains.
b)
The sowing of rapidly growing grasses will most probably result in a complete change in
species composition, as these grasses (not explicitly mentioned in the Report but most probably nonindigenous species, as otherwise they would have become the dominant vegetation long ago) will become
invasive and will supplant the native species.
3.
In Volume 1, Chapter 3 of the EIA, the Project declares commitment to the
implementation of certain mitigation measures, together with those measures that would be expected as
part of good international practice. Therefore, it is the significance of the residual impacts that is
described, i.e. those that remain after such intrinsic mitigation. The residual impacts are described in
- 22 -
terms of their significance (following the significance criteria and EIA process described in Volume 1,
Chapter 3). However, no concrete measures or terms are identified at that point, and no reference is
provided as to what is to be considered “good international practice” in terms of mitigation. Therefore no
lessening of negative impacts could be expected in future in these two cases.
4.
Local
In Volume 7, Chapter 2, the EIA states that within the Project funds will be provided to
Authorities
for
upgrading
public
facilities.
However,
no
impact
identification/
magnification/signification of these activities are provided doe to “lack of detailed design information”.
In part 2.2.1 it is implied that the Project will not undertake any responsibility for possible adverse
environmental impacts of the upgrading projects. It is not clear from the report generally who will be
responsible for any possible negative impacts: it does not state who shall carry out the EIA of these
upgrading projects, who will implement mitigation measures, who will monitor their implementation, etc.
Further down, in part 2.2.2, the increased effect of poaching resulting from the improved transport
infrastructure is not taken into consideration. It is not clearly stated who will enforce the poaching control
measures described in the SEIC No Fishing, Gathering, Hunting Policy, as well as who will control these
during operation of the facilities. In the section on Quarries it is stated that “peat and soft soils” will be
excavated and disposed. Peatlands are wetlands, and these habitats are often protected by legislation.
Even if this is not the case, wetlands shelter many endangered and endemic species. It is not clear how the
envisaged extraction of approx. 6 Mm3 of peat will affect these. No description is provided as to what
“soft soils” is to mean – and if it is humus, special care has to be taken of the soil, and no any sign is
provided that measures to use the soil properly will be enforced.
5.
Risk associated with fires on platforms is not estimated.
6.
In Table 2.3 of Volume 7, Chapter 2, it is not clear on what basis the significance of the
impact on “the fauna species, being endangered, are considered to be of high value” is estimated as
moderate.
VI. Impacts Assessment, Mitigation and Monitoring (Chapter 3) (MILENA
NOVAKOVA)
Introduction
The objective of the quality control of the EIA documentation is to find out the sufficiency
regarding the content and the scope of the assessment process, as well as to note the extent to which the
- 23 -
concerned parties have been involved. The Lee-Colley Environmental Statement Review Package is one
of the methods developed for evaluating an EIS. The hierarchical organization of the assessment criteria
in the package suggests reviewing, which starts from simple tasks and procedures and then progressively
applies more complex and broader criteria.
Based on the guidelines set in the Lee-Colley Package (Lee et al 1999) the author of the current
paper provides a quality evaluation of the draft EIS of the Sakhalin 2 Energy Project, Platforms, Offshore
Pipelines and Landfalls (Volume 2), Impact Assessment, Mitigation and Monitoring (Chapter 3). The
assessment is focused on the:
-
fishing activities and hunting;
-
shipping and navigation;
-
air quality;
-
landscape and visual resources;
-
abandonment and decommissioning;
-
emergency events;
-
cumulative impacts;
-
transboundary impacts;
-
monitoring and management.
The aim of the paper is to identify the main insufficiencies in the proposed EIS related to the
issues mentioned above and using the Lee-Colley Package methodology to make recommendations for
their overcoming. The assessment of the pointed out activities and environmental resources is done in
accordance with the specific requirements for reviewing set up in the List of Review Topics and
concerning the identification and evaluation of the key impacts and the mitigation measures.
1. Identification and evaluation of the key impacts
The definition of the impacts should be done in a broad way so that as many as possible potential
effects on the environment to be identified as deviation from the baseline conditions (Lee et al. 1999). For
the thorough identification of the impacts possible deviations resulting from accidents should also be
considered. The sources of the impacts and the potential impacts on such occasions are described in the
part “Emergency events” (Volume 2, Chapter 31). Regarding the findings that the pipeline landfall areas
for the offshore platforms are located on the Sakhalin’s northeastern coast, which is characterized by a
All further references within this paper in the format “Chapter ____, Volume ____” relate to Sakhalin Energy Investment
Company. 2003. Environmental Impact Assessment.
1
- 24 -
rich ornithofauna, including species registered as endangered and that the phytoplankton community in
the Piltun-Astokhskoye area is the most abundant and largest in terms of biomass in this part of the island
(See Volume 2, Chapter 1), it is of crucial importance the exhaustiveness of the potential impact
prediction. During the reviewing process the following omissions were identified:
-
lack of information and analysis for the potential impacts on the phytoplankton community
because of spillages of oil, chemicals or other materials into the sea (the latter are defined
as possible risks of accidents);
-
it is not considered that the negative impact on the seabirds and shorebirds might have
different extent in the different seasons because large number of the birds are migratory
species. From this point of view, a prediction of the possible negative impact on the
species should be done in order to provide a clear evidence for the level of deviation from
the baseline conditions;
-
as a possible emergency event is perceived only the spillage. No analysis of the adverse
impacts is provided in case of other accident events (a fire for instance). The Sakhalin
Energy Environmental Briefing Notes from December 18, 2003, based on questions on
behalf of the United States Department of Treasury, also does not bring this issue to the
attention;
-
according to the Sakhalin Energy Investment Company (SEIC) no transboundary impacts
are predicted. There is lack of information for the consequences of oil spills during sea-ice
season when the latter could have transboundary impacts (See Volume 7, Chapter 2).
The conclusion drawn, from the comments made above, is that important omissions are available
and they are related to consideration of adverse impacts which might occur due to accidents. Their
prediction is of paramount importance as permanent damages could be caused to the environment.
There is no clear evidence in Chapter 3, Volume 2 about the prediction of the impact magnitude
(for instance air quality, cumulative impacts). It is of importance for the thorough evaluation of the
residual impacts (George 2000; Cherp 2003).
Considerable diversion from the applied review quality guidelines is identified in the part
“Landscape and Visual Resources”. SEIC provides information only about the sources of the potential
impacts and no analysis of the effects which the construction would have on the environment. The applied
quantitative and qualitative EIA methods for the significance measurement are not motivated.
The remark regarding the inadequacy when defining a category of significance is applicable for
all of the points discussed in Chapter 3, Volume 2. Assessing the significance should be done in
- 25 -
accordance with the sources of quality standards together with the rationale, assumptions and value
judgments (Lee et al. 1999). Such an approach allows not only a thorough overview of the assessed
subject but it provides a motivation for the assigned category of significance (“no” impact, minor,
moderate, major significance) (See Volume 1, Chapter 3).
2.
Mitigation measures
The scope and the effectiveness of the proposed mitigation measures by SEIC, also show some
weak points with respect to the review guidelines. The identified insufficiencies are different for the
different resources/receptors.
In a number of cases the proposed mitigation measures are mixed with precautionary steps to
avoid accidents and public participation activities (fishing activities and hunting, shipping and
navigation). The proposed consultations with interested parties and all relevant procedures for their
identification and access to information are one of the main requirements for defining the key impacts.
The aim of the mitigation measures is to decrease the adverse effects during the development of the
project. The following hierarchy of design of mitigation measures suggests a couple of alternative means
(George 2000):
avoid  replace  reduce  restore  compensate
The consultations with the public or the social impact assessment could be used as instruments for
addressing any of the above mitigation approaches (George 2000).
It is not clear to what extent the suggested mitigation methods for the air quality, landscape and
visual resources will be effective when implemented. The mitigation measures for the abandonment and
decommissioning phase are proposed to be the same as those, which are applied during the construction
phase of the project, but there is no justification of their effectiveness for this period. Moreover, the
expected date of decommissioning is 2045, when probably there are likely to be developed more
advanced methods for mitigation. In such a light the developer of the project should point out that the
mitigation measures during this last stage will be in accordance with any higher standards and improved
technologies. This would explicitly demonstrate the commitment to mitigation, which at the present
moment is not distinctly presented in Chapter 3, Volume 2.
The mitigation measures for the cumulative impacts are declared to be designed in a way to
eliminate or to reduce the negative impacts. No particulate mitigation measures are illustrated within the
section, which weakens the claim above. This is a serious omission of the EIS because the sources of the
impacts have a complex and different character and a deep analysis should be done.
- 26 -
The monitoring arrangements, which are going to be used to check the environmental impacts
resulting from the implementation of the project, are mentioned briefly. As far as the environmental
monitoring measures are going to be developed in the future it is not clear to what extent they will
correspond with the predictions within the Statement.
Conclusion
The review process of the EIS shows that in some points it complies with minimum requirements
set up in the Environmental Statement Review Package. The identified gaps are important because they
refer to sub-category areas and their inadequacy reflects to the further stages of the statement and its
thorough completeness and quality. These omissions, where the lack of impact identification could lead to
adverse damages of the environment, are considered to be of crucial importance. The suggested range of
mitigation measures to ensure that the potential impacts of the project would be reduced is not
exhaustively motivated and does not prove the investor’s commitment to them.
- 27 -
Overall conclusions
The Group has evaluated the activities connected with Platforms, Pipelines and Landfalls
development. The activities include construction and operation of two platforms: Piltun-Astokhskoye – B
platform and Lunskoye Platform and offshore pipelines that connect the platforms with onshore facilities.
The quality review process of Volume 2 (Platforms, pipelines and landfalls) of the Environmental Impact
Statement of the Sakhalin 2 Energy Project has shown that there are generally significant omissions and
inadequacies, thus the part can not be considered as satisfactory. However, it is important to note here that
the authors’ general comment concerning the assessment process is to evaluate the EIS as a whole
document, not the excerpted part. The reasoning is because other Volumes contain the information, which
are essential for the EIS, though some parts of it were omitted during the assessment in order to give a
detailed evaluation of Volume 2.
The Statement has been graded with E mark, that is ‘Not satisfactory, significant omissions or
inadequacies’ (Lee et al. 1999), which means there are omissions, which can lead to adverse damage to
the environment or the human health that have not been taken into account. To see the detailed evaluation
please find the Appendix 1 Collation sheet of the quality review.
Full and unabridged comments concerning each part of the respective EIS Volume can be found in
the chapters of the paper. However, the assessment group produced the next general conclusions after the
quality review process.

There is not enough information, data and data interpretation about the existing environmental
physical conditions. Lack of the next elements make the accuracy of impact prediction doubtful:
suitable relevant maps, information about soils, analysis of coupling meteorological and
oceanographic conditions with the other elements of this environment, risk assessment for cyclones
and seismic activity, no emphasis on the most vulnerable components.

There is a lack of information for the viability of the populations, the way the ecosystem functions
and role of each group of organisms in the ecosystem. Without this information, the precise impact
from the project cannot be assessed and the relevance of the conclusions can be questioned. The
existing gaps are a prerequisite for biased conclusions when predicting the impact. On the base of the
identified gaps, the Environmental Impact Statement cannot be accepted before these gaps are
fulfilled.

The Chapter, concerning waste management and generally amount of wastes/emissions produced
during the construction and operational phases of the platforms development is to be developed
further. The description of methods by which the data were obtained is to be included with the not- 28 -
obscure language description of possible threats to human health. Explanation of kinds of raw
materials for the construction process is to be provided in order to evaluate the possible impact to the
environment through the life cycle of the product.

The purpose of the offshore pipeline field development project is well defined, the construction,
testing, commissioning and operational phase are described in details. However there is no plan for
the decommissioning phase. Sources of data and the methods, which were applied during the offshore
pipeline planning process, are not referred and it is not clear which standards were used during the
engineering phase. Some details will be planned during the further engineering phase, which means
that EIA will have to be accomplished continuously, in parallel with development process in order to
assess further potential impacts.

For the Impact Prediction and Mitigation Measures part the next omissions and inadequacies were
notices, which does not allow to grade the part as the satisfactory: no description of the identification
methods and no rationale for using them are provided, for most of the resources/receptors no impact
description and magnitude prediction are made, where the impact significance is predicted, it is not
clear on basis of what that judgement is made, mitigation measures have been suggested only for
some of the activities. No justification of the effectiveness of the suggested mitigation measures is
provided, no maps were used to visualize the possible impact location and magnitude, no monitoring
program is proposed, no external data sources acknowledged in this part. The EIA looks quite biased
as important impacts are not discussed or even not mentioned (or nor reason for their omission is
provided).

The review process of the EIS shows that in some points it complies with minimum requirements set
up in the Environmental Statement Review Package. The identified gaps are important because they
refer to sub-category areas and their inadequacy reflects to the further stages of the statement and its
thorough completeness and quality. These omissions, where the lack of impact identification could
lead to adverse damages of the environment, are considered to be of crucial importance. The
suggested range of mitigation measures to ensure that the potential impacts of the project would be
reduced is not exhaustively motivated and does not prove the investor’s commitment to them.
- 29 -
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Cherp, A. 2003. Environmental Assessment and Management. Department of Environmental
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Sakhalin Energy Investment Company 2003 Sakhalin Energy Environmental Briefing Notes
Duplicated
SEIC News Release 2004 Tseremoniya pervoy svarki trub [The Ceremony of firstpipe welding].
URL: http://sakhalinenergy.ru/news/nws_releases_20040123.pdf [Consulted 15 February 2004]
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Sperm whales. [on-line] URL: http://www.whalewatch.co.nz/sperm.htm (page last visited on
13.02.04).
Systeme
Internationale
(SI)
Units
and
Prefixes.
[on-line].
URL:
http://www.google.com/url?sa=U&start=1&q=http://www.cofc.edu/~chem/deavor/221/si_units.html&e=
7415 (page last visited on 13.02.04).
United States Department of Treasury 2003 Sakhalin 2 Phase 2 USG Environmental Questions
Duplicated
US congressmen question Sakhalin-2 financing The Sakhalin Independent URL:
http://sakhalinindependent.com/IMAGES/oilandgas/seic_financing_questioned.htm [Consulted 14
February 2004]
USDA Forest. 1982. Service Planning Rule to the National Forest Management Act. [on-line].
URL: http://www.fs.fed.us/emc/nfma/index1.html [consulted febr. 12th 2003].
Treweek, J. 1999. Ecological impact assessment. Oxford: Blackwell Science Ltd.
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Appendix 1. COLLATION SHEET
1.
ASSESSMENT SYMBOLS: Use the following symbols when completing the Collation Sheet below.
Symbol
Explanation
A
Relevant tasks well performed, no important tasks left incomplete.
B
Generally satisfactory and complete, only minor omissions and inadequacies.
C
Can be considered just satisfactory despite omissions and/or inadequacies.
D
Parts are well attempted but must, as a whole, be considered just
unsatisfactory because of omissions or inadequacies.
E
Not satisfactory, significant omissions or inadequacies.
F
Very unsatisfactory, important task(s) poorly done or not attempted.
NA
2.
Not applicable. The Review Topic is not applicable or it is irrelevant in the
context of this Statement.
COLLATION SHEET
Overall assessment E
1
D
2
F
3
F
4
C
1.1
1.1.1
1.1.2
1.1.3
1.1.4
1.1.5
C
C
B
N/A
A
D
2.1
2.1.1
2.1.2
2.1.3
2.1.4
F
F
F
D
F
3.1
3.1.1
3.1.2
3.1.3
N/A
N/A
N/A
N/A
4.1
4.1.1
4.1.2
4.1.3
4.1.4
C
B
B
D
C
1.2
1.2.1
1.2.2
1.2.3
1.2.4
1.2.5
C
B
A
A
C
D
2.2
2.2.1
2.2.2
E
E
E
3.2
3.2.1
3.2.2
3.2.3
F
E
N/A
F
4.2
4.2.1
4.2.2
4.2.3
C
D
A
A
1.3
1.3.1
1.3.2
1.3.3
D
D
D
D
2.3
2.3.1
2.3.2
2.3.3
E
E
E
E
3.3
3.3.1
3.3.2
F
F
F
4.3
4.3.1
4.3.2
C
C
B
1.4
1.4.1
1.4.2
D
D
D
2.4
2.4.1
2.4.2
2.4.3
F
F
F
F
4.4
4.4.1
4.4.2
C
B
C
1.5
1.5.1
1.5.2
1.5.3
E
F
C
D
2.5
2.5.1
2.5.2
2.5.3
N/A
N/A
N/A
N/A
Minimum Requirements
Were minimum requirements met, taking into account whether or not the following Review Sub-categories were all performed
satisfactorily, i.e. assessed A, B, or C?
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(a)
1.1.2, 1.2.1 yes
(b)
1.1.4, 1.1.5, 1.2.1, 1.2.2, 1.2.4, 1.3.2, 1.4.1, 1.4.2, 1.5.1, 1.5.3, 2.4.1 no
(c)
2.1.1, 2.1.2, 2.5.1, 2.5.2 no
(d)
3.2.1, 3.3.1 no
(e)
4.4.1, 4.4.2 yes
YES
NO
Broad Compliance
Were minimum requirements met, AND Review Areas 1, 2, 3 and 4 all performed satisfactorily, i.e. assessed A, B or C?
YES
NO
Overall Quality
Assign an assessment symbol (A, B, C, D, E or F) to the Statement as a whole and summarize, in one or two paragraphs, the
key factors which have determined your overall assessment.
To identify the key factors, which have determined the overall assessment, please see the Overall
conclusions of the paper.
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