WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12Th Meeting

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC Review of Sakhalin Energy’s Oil Spill Response Arrangements 2012, Parts 1 and 2 Summary of findings from site visits to Sakhalin Island, May and July 2012

Brian Dicks, WGWAP Panel Member

Introduction I made two visits to Sakhalin Island in 2012, the first from 19th to 29th May and the second from 14th to 25th July. The main purposes of the visits were for me to attend two oil spill exercises (a Tier 3 Oil Spill Response (OSR) exercise for the Nogliki Oil Production Facility and a shoreline OSR exercise at the Piltun Lagoon mouth), participate in and contribute to two OSR Workshops organised by Sakhalin Energy and continue the process of updating the Panel’s knowledge of Sakhalin Energy’s oil spill preparedness and response. OSR equipment stockpiles at Sovetskoye Pipeline Management Depot (PMD), Nogliki PMD and the Prigorodnoye LNG Terminal Marine Base were inspected, as were oiled wildlife response facilities at Prigorodnoye. Detailed reports of the two visits follow this summary (Attachment 1 and Attachment 2).

The May visit was conducted jointly with Lenders’ representatives Frank Marcinkowski (PCCI) and Chris Halliwell (Environ). The July visit was conducted jointly with George Franklin (Shell International) and Victoria Broje (Shell Houston). Both visits were concluded by discussion meetings with SEIC.

My main findings were as follows:

Tier 3 Exercise, Nogliki OPF The exercise was based on a terrorist attack at the Nogliki Oil Production Facility (OPF) and involved the breaching of a condensate storage tank and spillage of about 20 cubic metres of condensate inside the site and injuries to on-site personnel. The exercise was classed as Tier 3 because a terrorist attack would involve both local authorities at Nogliki OPF (Police and EMERCOM), and EMERCOM in the central command post in Yuzhno.

The exercise was very well organised and run. Two command centres were established in SEIC’s offices, one dealing directly the Nogliki PMD responders and addressing response issues, the other dealing with internal communications (mainly related to the personnel injuries) and with external communications to EMERCOM and the press. Response equipment was deployed rapidly, professionally and efficiently at Nogliki and operations at the two command centres were also professional and efficient.

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC

A few areas were identified by Lenders’ representatives and me where improvements might be made for future exercises: • All of the response personnel appeared to be aware of the details of the drill in advance, which undoubtedly contributed to its very smooth running. The main criticism of this approach is that it fails to throw in the unexpected challenges which real spills pose. Personnel and response arrangements are better tested and personnel learn and benefit more if advance knowledge is kept to the minimum and an exercise command team is in place which releases information as the drill progresses and has the ability to change conditions in order to challenge the responders. • EMERCOM was represented at the Yuzhno command centre but took no active part in directing or advising on the response, which made it impossible to assess this team’s spill response knowledge or the role it would assume in a real spill. Active participation by EMERCOM in a future Tier 3 exercise would clarify its role and intentions. In the brief post-drill analysis, EMERCOM’s representatives indicated that they were happy with the overall conduct of the drill. • Two safety issues related to handling of the spilled condensate were identified and need to be addressed. One concerned foam-blanketing by the fire department and the other the use of vaccum trucks for transport of recovered oily waste. • The responders at Nogliki PMD and in the Yuzhno command centre failed to realise that spilled condensate may have escaped off-site through drainage channels, which should at least have been checked by off-site inspections. • The exercise was terminated without considering final disposal of recovered oily waste, which often proves to be a bottleneck in real spills. Temporary storage had been handled well during the response and it would have been beneficial for those involved to spend some time at least considering and/or developing final disposal options.

Shoreline OSR Exercise at Piltun Lagoon, 17th-19th July 2012 This exercise was a repeat of an exercise conducted in September 2011. It was conducted with the aim of overcoming practical problems experienced in the earlier drill. Overall, the exercise was a success. Logistics were good and the potentially fragile access tracks to the site withstood the extra traffic.

The exercise demonstrated the feasibility of recovering some floating oil and of carrying out shoreline clean-up in this remote area at the Piltun lagoon entrance, but also confirmed that in a real incident it would be unlikely to be feasible to prevent oil penetration to the lagoon

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC due to the tidal currents. Opportunities missed by this exercise were to test the feasibility of deflection booming and to test the arrangements for waste disposal, e.g. by the deployment of trucks to the site to take away recovered oily wastes for final disposal. Both should be included in a future shoreline exercise, not necessarily at Piltun. This means that the status of recommendation WGWAP-11/011 can be changed to ‘Closed, implemented satisfactorily’.

Status of OSR stockpiles and preparedness The OSR equipment stockpiles at Sovetskoye PMD, Nogliki PMD and the Progorodnoye marine base are in good order with all the equipment stored and maintained in good condition. The operational personnel are well trained and versed in using and deploying the resources. The stockpiles have an excellent range of specialist equipment and there are sufficient personnel and vehicles to deal with relatively small incidents and to start response for a large spill. However, in a large spill, for which clean-up is often a prolonged affair, it is likely that Sakhalin Energy will need to obtain and manage considerable additional manpower and non-specialist resources such as trucks, diggers and support boats. It would be beneficial for such manpower and support equipment to be identified in advance and mobilisation tested in a Tier 3 exercise.

Aerial application of dispersants has potential for rapid response to a spill threatening the Piltun area shorelines. Sakhalin Energy has a sharing agreement with ENL, which holds three heli-spray units in its northern stockpiles. This arrangement has not been tested and it would be useful to conduct an exercise to confirm that it works within a reasonable time frame.

Oily waste management and its final disposal are an important component of spill response and can prove to be a bottleneck in a sustained clean-up. SEIC has a general overview of handling and disposing of such wastes (solid wastes to Smyrnyck and oily liquids to Prigorodnoye or private contractors), but details are not specified in the OSRPs and these arrangements have not been tested. These issues need to be addressed and arrangements tested in a drill.

OSR workshops Both workshops were well organised and run by Sakhalin Energy and were well attended by about 40 staff in total. Presentations were made by Sakhalin Energy management plus, for the first workshop, invited speakers from Gazprom, Ecoshelf and Ecospace (SEIC contractors), a Russian dispersant research specialist, Lenders’ representatives and

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC WGWAP, and for the second workshop by invited speakers from Shell International, Shell Houston and WGWAP. The second day of the first workshop included a training exercise, involving participants in a mini-drill based upon a spill from a tanker at the Aniva Bay LNG terminal. This proved particularly beneficial as it tested participants’ knowledge and ‘common sense’ as there had been no pre-warning of the exercise content and conditions were changed to challenge participants as the drill developed. This is an excellent learning approach and could and should be more widely applied to oil spill exercises. Overall the workshops were well received and were actively participated in by the SEIC team.

Discussion meetings with SEIC These provided the opportunity to review the findings of the visits and any outstanding issues from Panel discussions. They included the status of the OSRPs and the ice response manual, regulatory requirements for dispersant application, in-situ burning, response in ice and waste management. Some of the main issues on these topics have already been covered above, but additional items are as follows: • The OSRPs are currently being revised for re-submission to the regulators. They may be condensed somewhat to minimise repetition and will contain more realistic ‘worst case’ scenarios but are not expected to contain any changes to the company’s approach to spill clean-up. • SEIC is trying to work with the regulators to get pre-approval for dispersant use, thereby avoiding potential delays which would come from current requirements for a NEBA process with the regulators. • The latest draft of the Oil in Ice Manual has been commented on by Dicks and Lenders’ representatives. Both noted that the manual was greatly improved compared with earlier versions but that it could be further improved by being better tailored to SEIC-specific operations and the Sakhalin environment. It was reported that Shell had developed a new state-of-the-art response plan for ice operations in the Chukchi Sea, to the north of the Bering Strait, and that it would be useful for SEIC to obtain a copy for review. • In-situ burning is being pushed as an effective and more widely applicable tool post- Macondo, but at present SEIC is not planning any changes to the approach set out in the OSRPs.

Brian Dicks, 1st August 2012

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC ATTACHMENT 1

Review of Sakhalin Energy’s Oil Spill Response Arrangements 2012 Part 1 Report of Site Visit to Sakhalin Island, 19th – 29th May 2012

Brian Dicks, WGWAP Panel Member

INTRODUCTION A visit was made to Sakhalin Island by WGWAP Panel Member Dicks between 19th and 29th May 2012. The main purpose of the visit was to attend a Tier 3 Oil Spill Response (OSR) exercise followed by a two day OSR Workshop. In order to continue the process of updating the Panel’s knowledge of oil spill preparedness and response, an OSR equipment stockpile at Sovetskoye Pipeline Management Depot (PMD) was also inspected, as were oiled wildlife response facilities at the Prigorodnoye LNG Terminal in Aniva Bay. The visit was concluded by discussion meetings with SEIC regarding the Tier 3 exercise and workshop and a preparatory meeting to finalise arrangements for Dicks’ attendance at the proposed repeat OSR shoreline exercise at the Piltun Lagoon mouth in July 2012. All the on-site activities were conducted jointly with representatives of the lenders, Frank Marcinkowski from PCCI and Chris Halliwell from Environ. Prior to the visit a list of visit objectives and issues to be discussed had been prepared.

Tier 3 Exercise, conducted 23rd May 2012 The exercise was based on a terrorist attack at the Nogliki Oil Production Facility (OPF) at the northern end of the pipelines which take the produced gas and oil to the Prigorodnoye LNG Terminal. The exercise was classed as Tier 3 because a terrorist attack would involve both local authorities (Police and EMERCOM) at Nogliki OPF, and EMERCOM in the central command post in Yuzhno.

The drill was based upon a vehicle penetrating the outer fence, riding over a tank bund and crashing into and breaching a condensate storage tank. The attack resulted in multiple human injuries and although the tank bund contained most of the condensate spilled from the breach, about 20 cubic metres overtopped the bund and spilled on to roads and into rain water drainage channels. Condensate is light and highly volatile and therefore posed fire and explosion risks as well as the risk of off-site contamination through the rain water drainage systems which discharge outside the site boundary into river systems in adjacent forest.

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC

Halliwell attended on site at Nogliki, whilst Dicks and Marcinkowski were present in the control centres in Sakhalin Energy’s offices in Yuzhno. The main focus for Lenders’ representatives was to assess the effectiveness of the command and control of the exercise (in line with OSRPs) and how the organisation, conduct and outcomes of the drill compared to applicable standards. It should be noted that Lenders’ representatives do not advise Sakhalin Energy, but have the role of assessing performance against applicable standards/international good practice and identifying areas of non-compliance, which are then discussed with Sakhalin Energy and reported back to Lenders. The Panel’s role is of course advisory. Dicks’ primary focus was on the effectiveness of the command and control of response (in line with OSRPs) and how Sakhalin Energy interacted with Russian authorities. As the drill was based upon a relatively small condensate spill from tankage, with very little likelihood of oil reaching the marine environment, there were no specific whale issues to address.

Overall, the exercise was very well organised and run. Two separate control centres were set up in Yuzhno by Sakhalin Energy, both on different floors in the same building, which allowed both telephone and face to face contact between the two teams. An Emergency Control Team (ECT) was in command of response, led by Alexander Gutkin, and a Corporate Response Team (CRT), led by Sergey Litvinov, was in control of internal and external communications. Both were manned by Sakhalin Energy’s spill management staff who were mainly Russian.

The exercise started at 11:00 with notification of the incident to Gutkin, who called together his ECT team, which took about ten minutes. Initial details of the injuries and the initial assessment and containment response at Nogliki were received by telephone. Notifications were immediately made locally to EMERCOM (although EMERCOM representatives were already in the ECT, an exercise artificiality to keep the time spent on the exercise minimal) and to the CRT, which assembled promptly.

At Nogliki OPF the on-scene commander made an initial inspection of the incident and the injured personnel were assessed. After about 25 minutes the spill area was deemed safe to enter and the injured were moved away for medical treatment and the responders laid a foam blanket on the spillage. Clean-up crews arrived with equipment about 55 minutes after the spill and deployed containment and recovery resources along with portable temporary waste storage tanks. Containment focussed on blocking drainage channels and deploying

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC booms within the ditches, after which skimmers were deployed to recover the spilled condensate into the temporary storage tanks. An additional difficulty for the responders resulted from the death of one of the injured personnel, which initiated additional investigations and notification procedures for dependants.

Details of the on-site response reached the ECT by telephone and email and these were considered and feedback was made to the Nogliki team. ECT kept good records of the incoming information and briefed the CRT regularly. Overall communications were excellent. There was little to fault with the performance of either of the Yuzhno teams, although it would have been beneficial to have more control over ‘internal’ discussions and briefings by isolating key ECT personnel from telephones etc. for their discussions. All the key support activities for Nogliki OPF were performed well, ECT staff both knew and performed their roles well and the activities were well prioritised in relation to safety, environment, property and the company’s reputation. Overall, the response at Nogliki OPF also appeared to have been very professional with good communications both locally and to the ECT in Yuzhno. Response equipment was deployed rapidly and all functioned well. These views were subsequently confirmed by Halliwell who had been on site.

The main issues which were identified by Dicks and Lenders’ representatives regarding the response and some potential improvements which could be made and used in future exercises were as follows:

1. The exercise was well planned and tested many of the response plan requirements by including issues related to safety, personnel, communications as well as clean up challenges for responders. However, all of the personnel in the ECT and CRT appeared to be aware of most of the details of the drill in advance, which undoubtedly contributed to its very smooth running. Halliwell confirmed that this was also the case at Nogliki. Whilst this approach might ‘tick all the boxes’ for the Russian regulators and help to keep relationships between them and the company on an even keel, the main criticism of this approach is that it fails to throw in the unexpected challenges which real spills pose. The vagaries of weather, the physical environment in which people are working and human error are the norm in most spills. In my view it would have been better for the response personnel to know little or nothing of the details of the drill in advance and they would then respond using their knowledge of the OSRPs and their individual roles. This really enhances the learning process, shows up any gaps in procedures and is much more like the real thing. A simple way of achieving this would be to have an exercise command team which releases information as the drill

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC progresses and has the ability to change conditions in order to challenge the responders. This approach was adopted during a mini-exercise in the OSR Workshop (see later) and elicited a positive response from those involved. I am aware that within the Russian system it could be problematic for Sakhalin Energy to admit/accept that things could/can go wrong in a spill, and that this might result in unwillingness to highlight this in a drill. Even if Sakhalin Energy is of the view that this problem cannot be addressed in advance because of the way the regulators work, the issue is an important one and will have to be faced during the real thing.

2. I was concerned at the minimal contribution made to the exercise by the EMERCOM representatives in the ECT. I was aware of only one comment made by them, which related to writing up information on display boards slightly more clearly. They took no active part in directing or advising on the response. Consequently it proved impossible for me to assess their spill response knowledge or the role they would assume in a real spill. It is understandable that they might well have been happy with what was going on in the ECT and at Nogliki OPF because everything ran so smoothly, but their lack of initiative to at least join in is worrying. In the brief post-drill analysis, EMERCOM indicated that they were happy with the overall conduct of the drill.

3. Overall, the response, equipment deployment, communications and general conduct of the drill were well done at the Nogliki OPF, but two important concerns were noted, one related to safety and the other to the behaviour of the spillage. At the start of the incident the initial assessment identified the problem and located the casualties and within 25 minutes or so (I don’t have an exact time on this) deemed the area safe for medics and clean-up crews to start their work. A foam blanket was laid on the spillage and once the clean-up crews arrived (after about 55 minutes) drainage channels in the area were plugged. Condensate recovery started with small skimmers deployed into the drainage channels and recovered oil was pumped into portable temporary storage tanks. A foam blanket is a temporary measure, and unfortunately it was not renewed on the spilled condensate and neither were the open temporary storage tanks foam-blanketed. An additional risk arose from using a vacuum truck which was deployed to empty the recovered condensate from the temporary storage tanks. The waste was sucked out of the storage tanks using the truck’s built-in vacuum pump. However, these pumps get very hot in use and can pose a serious fire/explosion hazard with volatile products like condensate. It would have been fine to transfer the condensate into the truck using a regular pump and this should be addressed in future incidents. The other issue relates to the behaviour of the spill, which immediately entered and flowed along rain water

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC drainage channels as soon as the spill occurred. I estimate that these channels were plugged about 55 minutes to an hour after the tank breach, during which time condensate would have been able to flow freely through them. These channels drain off-site into local creeks, making it possible or even likely that at least some of the spillage would have escaped from the site and into the local environment. The responders reported that everything had been contained on site, which could have been the case, but my main criticism is that there was no procedure in place to check the exit points of the drainage channels or the local creeks in the nearby forest for pollution. This would be essential in a real spill.

4. The exercise lasted about two hours and was then concluded. I believe it would have been beneficial for at least some of the players to continue working on the last stage of clean-up, which is final disposal of the recovered wastes, which often proves to be a bottleneck in real spills. Temporary storage had been handled well and it would have been beneficial for those involved to spend some time at least considering and/or developing final disposal options. Given that there are no waste disposal facilities available close to Nogliki OPF, wastes would have had to be transported elsewhere (e.g. to Smyrnyck or to Aniva Bay where disposal sites are available) and this would require sorting out the necessary logistics – an opportunity missed which could beneficially be included in future exercises.

OSR Workshop Report The OSR Workshop was held 24th and 25th May at the Pacific Plaza Hotel and was well attended with more than 40 attendees plus 4 translators. Most of the participants were members of the ECT and CRT. The outline programme was as follows: Introductory talks were given on SEIC’s oil spill response by Peter Norman (acting CEO for SEIC) and Richard Evans, and by Kozlov Alexeyvich for Gazprom. These speakers were followed by Lenders’ representatives and Dicks, who provided background on their respective roles and lenders’ and WGWAP interactions with the company. Bill Stillings (Ecoshelf) and P. Stadnik (CREO) provided overviews of their response activities on behalf of SEIC (Ecoshelf and CREO are SEIC’s OSR contractors). Semanov of CNIIMF made an interesting presentation on dispersants in the Russian context and Sergey Litvinov overviewed SEIC’s company approach to spill response and training. Exxon Neftgas were included in the programme to introduce their OSR capabilities, but unfortunately on the day their representative was ill and no substitute was available. The penultimate session of the workshop was a training exercise, involving participants in a mini-drill based upon a spill from a tanker at the Aniva

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC Bay LNG terminal. The final session was an interesting discussion on SEIC’s approach to spill response and actions, schedules and future objectives.

Overall the workshop was well organised and there was positive interaction between attendees and speakers. The second day of the workshop proved to be the most appreciated by participants (even though there were fewer present than on the first day). Discussion sessions related to real incidents (e.g. the CRISTOFORO COLOMBO spill on Sakhalin about two years ago) highlighted the real difficulties of dealing with the spill and the public outrage that accompanies it. The mini-drill was particularly beneficial as it tested participants’ knowledge and ‘common sense’ as there had been no pre-warning of the exercise content. The players were divided into teams and had to think on their feet to determine a response. Ecoshelf had planned the drill, and we were able to change conditions as the scenario developed, thus challenging the participants to amend their response to meet the changing conditions. This is an excellent learning approach and could and should be more widely applied to oil spill exercises.

During the presentations and the mini-drill it was clear that the participants’ knowledge of oil spills, spill behaviour and likely impacts and the challenges that clean up presents was relatively limited. It would be beneficial for them to receive additional training on these subjects.

The final discussion involved a much smaller group of mainly SEIC managers and covered the following topics: Revision of OSRPs, dispersant use, in-situ burning, spill response in ice conditions, the ice response manual, waste management ‘worst case’ scenarios for use within the plans.

SEIC noted that the OSRPs were currently under revision for re-submission to the regulators by the end of the year. The final form of the plans is not yet decided, but may well follow the same format as previously, but with the current six asset plans perhaps being consolidated into three plans to reduce duplication (and thus approval times). They also indicated that they would submit their Corporate Plan, which had not previously been required by the regulators. SEIC also indicated that the revised plans would contain more realistic ‘worst case’ scenarios than are required by the regulators, which is technically a better approach and one which I fully support.

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC Dispersant use was of particular interest to the company. At present, dispersant use requires a Net Environmental Benefit Analysis (NEBA) to be carried out and submitted to the regulators for formal permission. This would clearly lead to delays which could mean that the window for dispersant use would be missed. However, the management team stated that they would conduct the NEBA themselves and then apply dispersant (in line with OSRPs and Panel advice with respect to whale interests) in parallel with requesting formal permission, and sort out any disputes or issues with the authorities after the event. I support this approach. The revised OSRPs will have additional material on dispersant use and the company intends to use this and other discussion forums to try to gain some kind of pre- approval for dispersant use, which is a step in the right direction. I suggested that the company might consider discussing with the regulators an approach similar to that used in the UK where pre-approval is given for limited use of dispersants (small volumes) to get the response started. Formal approval is then required should larger volumes be needed.

A brief discussion of the new Oil in Ice Manual followed. Both PCCI and I had reviewed the manual and commented back to the company. We were in broad agreement that the manual contained a lot of useful guidance material but that it could be improved by being better tailored to SEIC-specific operations and the Sakhalin environment. PCCI noted that they believed that Shell have developed a new state-of-the-art response plan for their operations in the Chukchi Sea, to the north of the Bering Strait, and that it would be useful for SEIC to obtain a copy if that was possible.

The issue of temporary storage and transport of recovered oily wastes had come up on several occasions during the workshop and in the various reviews conducted by PCCI and the Panel of SEIC’s plans. In the case of recovered oil/water mixtures, SEIC already aim to minimise waste volumes by separating and decanting recovered water back into the booms from which oil was being recovered. Temporary storage for small volumes of liquid waste (up to about 100 tonnes per vessel) is available on the Smit operated vessels which work routinely around the production platforms. For large volumes of liquid waste, the company has shuttle tankers which would be diverted to this task. SEIC are currently investigating local availability of dumb barges which could be hired during a spill and they have also identified a storage tank near Prigorodnoye which could be available for emergency use but its availability is not yet confirmed. These latter items need to be followed up.

Overall the SEIC management team revealed a good understanding of the main issues and difficulties that a spill poses.

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC

Visit to Sovetskoye PMD, 22nd May 2012 In line with previous visits to SEIC’s spill equipment stockpiles, the Sovetskoye equipment is a comprehensive stockpile and is well maintained. All the resources are well stored and are readily accessible. There is a regular maintenance schedule for equipment with pumps, motors, hydraulics etc. and everything appeared to be in good order. Some of the equipment is packaged in plywood containers for transport to a work site and some of these appeared rather flimsy and would be unlikely to stand up to repeated use. It was suggested to the operators that they could be strengthened with metal corners and metal strapping to make them more robust. The operational staff appeared well trained and familiar with all of the resources and their workings.

Fig. 1. OSR equipment at Sovetskoye (May 2012).

One criticism I have was that some of the staff appeared over-confident that they could handle any likely incident related to a pipeline spill and that any response could be handled entirely with the PMD resources with no need to source any outside assistance, e.g. additional trucks or manpower, which in my view would certainly be necessary in a larger incident or where large volumes of oily waste might be generated. This was discussed with SEIC management who agreed to address it with the relevant personnel.

After inspecting the equipment stockpile, a nearby beach was visited where clean-up might be needed. The beach was of firm sand with relatively good access, but the upper shore was piled fairly deeply with seaweed and sea grass, plus timber and other flotsam and jetsam. This would clearly be an issue for clean up as even a small spillage would be likely to generate large volumes of recovered oily waste. This is a widespread problem on Sakhalin,

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC and is an issue which I flagged with the SEIC management teams in our various discussions.

Oiled Wildlife – visit to Progorodnoye facilities 26th May 2012 The visit was led by Peter van der Wolf, who is one of SEIC’s wildlife advisors, and we were accompanied by Alexander Brikov a senior HSE specialist with SEIC’s LNG Terminal’s HSE team.

Oiled wildlife response facilities were first visited during my site visit in 2009, at which time I reported them to be well organised and in line with international good practice, and they have been improved since then. All of the response equipment is now in proper dedicated storage and the stockpile contains tents, heating machines, tanks, cages and cleaning facilities suitable for 1,000 birds. One item is still awaited to complete the facilities and make them fully operational - hot water supply hoses are being sourced and are expected to be in place by the end of August 2012, at which time the whole bird cleaning system will be finished and ready. At present, more than 40 bird rescue and cleaning staff have been trained and a total of eight state vets are available and trained for dealing with the birds. During my previous visit I suggested that SEIC might consider adding resources suitable for handling oiled seals, but this has not been pursued by the company.

Following the site visit, we met with three of the state vets who assist with bird cleaning and with training of the response staff - Igor Ivanovitsh Antipenko (Deputy-Head of the Oblastnoye Veterinary Service for Yuzhno-Sakhalinsk), Ivan Victorovitsh Rimar (lead vet at Yuzhno-Sakhalinsk Zoo) and Wasili Petrovitsh Pastushenko (vet at Yuzhno-Sakhalinsk Zoo). We discussed the Panel’s interest in obtaining or having access to samples taken from whale carcasses. From what they said, they seem to have a pretty free hand to do things/take samples etc. on the beach at the carcass, but there are no state directives over what should be done or what samples might be taken. Their main purpose on site is to determine cause of death, rather than to take samples to augment research. All three expressed an interest in obtaining further details and in being trained in what should/could be done during a necropsy and they asked for information and advice on necropsy kits. I agreed to put this to the Panel for follow up.

Brian Dicks, 10th July 2012.

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC ATTACHMENT 2

Review of Sakhalin Energy’s Oil Spill Response Arrangements 2012 Part 2 Report of Site Visit to Sakhalin Island, 14th – 25th July 2012

Brian Dicks, WGWAP Panel Member

INTRODUCTION A second visit this year was made to Sakhalin Island by WGWAP Panel Member Dicks between 14th and 25th July 2012. The main purpose was to attend a shoreline OSR exercise at the Piltun Lagoon mouth 17th-19th July 2012. The process of updating the Panel’s understanding of Sakhalin Energy’s oil spill preparedness and response was continued by visiting equipment stockpiles at Nogliki Pipeline Management Depot (PMD) and the Marine Base of the Prigorodnoye LNG terminal in Aniva Bay. Dicks also gave two presentations to an OSR training workshop for Sakhalin Energy response staff on 20th July 2012. In addition to Dicks, this event involved invited speakers from Shell and Sakhalin Energy.

Shoreline OSR Exercise at Piltun Lagoon, 17th-19th July 2012 Panellists will recall that as reported at WGWAP 11, an oil spill exercise was conducted at the mouth of Piltun lagoon in September 2011, in compliance with recommendation WGWAP-7/019. The intended deployment of resources in September 2011 is shown in Fig. 1.

Fig. 1 Intended boom deployment Sept 2011 exercise.

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC Sakhalin Energy provided an Ecoshelf report on that drill for consideration at the EMTF meeting in November 2011. Ecoshelf’s reports are factual and frank and contain practical recommendations for improvements where problems are encountered. The drill revealed problems with vehicle access to the site (due to the poor quality of roads combined with rain), deployment of oil recovery booms in the lagoon mouth (which is very difficult due to strong tidal currents and inadequate power of the boats’ engines) and support for personnel in the field.

I provided comments on the Ecoshelf report to Sakhalin Energy and to the Panel members of the EMTF in advance of WGWAP 11. As a result, it was recommended at WGWAP 11 (WGWAP-11/011) that lessons learned from the 2011 Piltun drill should be taken into account and that a repeat drill should take place as scheduled for 2012 with attendance by Dicks. A revised and more realistic deployment plan was assembled which included boats better able to cope with the conditions and the deployment of three recovery systems, oriented around the currents which would be encountered on the day of the drill (see Fig. 2). The ideas of boom towing in the bay and sorbent deployment on the inner bay shoreline opposite the lagoon entrance were rightly abandoned.

Fig. 2. Planned boom deployments, 18th July 2012.

On the day of the exercise the team of observers, of which I was a member, totalled six. Peter van der Wolf (SEIC’s oiled wildlife specialist, who also oversees the whale observer camp in which we stayed for the drill and is an experienced field worker) led the team in this remote location. George Franklin (ex-mariner for Shell International), Victoria Broje (Shell Houston, who is the company’s new oil spill specialist who contributed to EMTF 1 last November), two Sakhalin Energy staff (Anton Shivaev, one of SEIC’s HSE team, and Pavel

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC Truskov, an ice research scientist who has specialist knowledge of the Piltun area and has been involved in offshore platform design to resist ice) and I completed the group. We mobilised to the whale observer camp during the afternoon and evening of 17th July.

On the same day all the Sakhalin Energy resources for the exercise were mobilised to the site. For the first time in the series of drills booms were delivered by sea, using one of the passenger ferries that transport personnel to the offshore platforms. Sea conditions were calm and this allowed the booms to reach the deployment site in about three hours, which could also be achieved in a spill in good weather conditions. All other resources (boats, skimmers, pumps, personnel and logistical support for the camp) were brought in by road that day which took about six hours. This proved to be slower and more difficult than expected near the Nogliki PMD due to heavy rain, but weather conditions were better at Piltun and all resources reached site and camp was established (Figs 3 and 4), ready for the exercise on the following day.

Fig. 3. Resources on site. Fig. 4. Camp established.

On the day of the drill (Wednesday 18th July) high tide was at about 06:00 and the diurnal tidal cycle meant that an ebb current was flowing out of the lagoon mouth throughout the day until late afternoon. The boom and skimmer deployments were thus configured in a way that would cope with the ebbing tide (the reverse of those shown in Fig. 2) rather than try to defend the area on an incoming tide. With an incoming tide it would have been straightforward to reverse the deployments to those planned, and the operators clearly understood that this would have to be done in response to tidal changes in a real incident.

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC Equipment deployment began at 08:00 on 18th July and by 09:00 all three planned deployments were in place, each comprising one or more lengths of boom, a skimmer, a pump and two temporary storage tanks (Fastanks) – see Figs. 5 - 8.

Figs. 5 – 8. Boom, skimmer and temporary storage tank deployment. Note that the water compartment of the shore-seal boom was not filled (not a problem for the drill) because this usually introduces beach sand and makes later cleaning time consuming and costly.

When the booms were deployed the tidal current was weak (about 1 kt) and all of the booms were clearly functional as marine foam (which behaves similarly to oil on the water) was being caught by the boom and was being deflected inshore to the skimmers. During the morning the tidal current steadily increased and after about two hours it was clear that the booms would no longer be able to hold oil, although oil would likely still be deflected in towards the skimmers. This failure is shown by the turbulence on the down-current side of the boom (Fig. 9).

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC

Current

Turbulence

Fig. 9. Current causing boom failure at peak tidal flow.

This would likely limit effective oil recovery to about four to five hours around the slack tide at high and low water in each 12 hour tidal cycle. The operators were well aware of this limitation and understood that complete defence of the lagoon would not be a realistic expectation, but that at least partial oil recovery would be possible. Overall I was impressed by the deployments and they would clearly have been effective at recovering some oil.

During the late afternoon and evening of 18th July the resources were all recovered and re- loaded into the trucks, ready for return to Nogliki PMD the following morning. Overall, the exercise was very well organised and run and I had no concerns about the conduct of the exercise or maintenance of the camp. A few minor equipment omissions were noted by the operators (e.g. missing lengths of small-bore hose for decanting temporary storage tanks) and these were recorded so that checklists could be updated for future operations. I also noted that toilet facilities had been overlooked for the camp, but I was assured that this would not happen again.

Van der Wolf and I inspected the area inside the lagoon mouth by boat to assess the potential for equipment deployment further into the lagoon and near the lighthouse, in line with Dicks’s comments on the Ecoshelf Piltun exercise report of Sept. 2011. As well as suggesting a repeat exercise, I had suggested evaluating the possibility of deploying shoreline recovery booms further into the lagoon, and looking at potential deflection booming on the outer sides of the two sand spits to deflect oil migrating north or south past the lagoon entrance.

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC

Fig. 10. Piltun lagoon entrance – areas marked in red are not suitable for deployment of oil recovery booms/skimmers or for deflection booming, due to shallow waters and wave action. The position shown in green may be suitable for deployment of a deflection boom.

Inside the lagoon to the south of the entrance, there is a narrow deep channel flanked by shallow and gently sloping sand flats, which makes shoreline access by boat very difficult and rules out effective boom deployment. The same difficulty was found northwards on the inner (western) side of the lagoon, up to the lighthouse. Access by track is also difficult along this sector. These areas, marked in red in Fig. 10, are therefore not amenable to either defensive booming or recovery of floating oil. If they become oiled, sorbent boom deployment for oil recovery should be feasible and manual cleaning by boat access at high water should be possible. The inner side of the northern spit is accessible by boat at most tidal states and boom deployment to recover floating oil would be feasible there, as tested successfully during this exercise. Access to the northern sand spit by road involves considerable distances and time, and is probably not realistic, so Sakhalin Energy’s focus, should these areas become oiled, would have to be on boat or helicopter access.

The potential for deflection booming to help protect the lagoon entrance was also considered. On the northern sand spit shallow water, breaking waves (even in calm conditions) and the need for long lengths of boom to make an effective deflection array would in my view make deflection booming unrealistic (area marked in red, Fig. 10). However, deflection booming on the tip of the southern spit (green line Fig. 10) may be feasible and could be tested in a future OSR exercise in this area or in a drill at a similar lagoon entrance.

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC On departure from the site, Vvan der Wolf and I checked the condition of the access tracks along the south Piltun spit. Van der Wolf is very familiar with these tracks as he has travelled them for several months a year for the last five years.

Fig. 11. Access tracks through sand dunes at Piltun towards the end of the exercise. He reported that overall the tracks have been stable over the five year period, but of course have only a low normal usage of one or two 4WD vehicles a day. The exercise resulted in up to about 10 4WD journeys a day for the three day period (17th – 19th July) plus the influx of four Urals carrying equipment and personnel plus trailers with boats. In spite of the extra traffic Van der Wolf confirmed that in his opinion the tracks had not deteriorated as a result of the drill (Fig 11). During a real incident it is possible that even greater traffic would result in track damage, so it would be necessary to consider means of stabilising fragile sections, e.g. by protective deployment of metal tracking or strips of heavy-duty geotextile. Van der Wolf has confirmed that the dune grasses are readily transplantable to re-stabilise damaged areas, so there is potential for post-spill restoration of damage, once clean-up is complete.

Panellists may also recall concerns over environmental disturbance which might be caused by an exercise in this remote location. During the exercise Steller’s sea eagles were seen close to the deployment sites and four to five hundred spotted seals were present on nearby sand bar haul-outs in the mouth of the lagoon (within 400 – 500 metres of the deployments). Neither showed any obvious signs of being perturbed by our presence and seals approached as close as within 10 metres of booms and vessels, presumably from curiosity. We also saw reasonable numbers of sea birds (terns, gulls and waders) during the exercise and the terns were feeding within the lagoon entrance close to where the equipment was deployed. Van der Wolf, who has considerable experience of these animals and the site, was in agreement with me that this drill seemed to be causing no undue disturbance to wildlife. However, this might not be the case during bird or seal breeding seasons, or during a more prolonged shoreline clean-up after a spill.

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC

An opportunity that was missed by this exercise is to test the arrangements for waste disposal, e.g. by the deployment of vacuum trucks to the site to take away recovered oily wastes for final disposal. In a real incident it is likely that effective removal of recovered oil would require ten or more vacuum trucks, with the potential to damage the access tracks. This issue had not been discussed in advance of the exercise although boom deployment strategies had. It is something which should be included in a future drill, not necessarily at Piltun, but associated with any future shoreline exercise. Further considerations regarding waste management and final disposal are noted below.

Overall, the exercise was a success. It has demonstrated that recovery of some oil is feasible, as is some level of shoreline clean-up, at the Piltun lagoon entrance, but also that in a real incident it would be unlikely to be feasible to prevent oil penetration to the lagoon. The best potential for preventing lagoon oiling would be effective at-sea response from vessels, possibly assisted by the application of dispersant by helicopter.

Visits to Nogliki PMD OSR stockpile, 17th July 2012 and Prigorodnoye Marine Base OSR stockpile 21st July 2012 In line with previous visits to SEIC’s spill equipment stockpiles and the earlier visit in May this year to Sovetskoye PMD stockpile, the OSR stockpiles at Nogliki PMD and Prigorodnoye were inspected. Both are comprehensive stockpiles and appear to be well maintained.

All the resources are well stored and readily accessible for transport to a clean-up site. There is a regular maintenance schedule for equipment with pumps, motors, hydraulics etc. (most are inspected and tested monthly) and everything appeared to be in good order.

Some of the equipment is packaged in wooden and plywood containers for transport to a work site. The wooden containers appear well constructed and are strengthened with metal strapping on corners, but some of the plywood units appeared rather flimsy and would be unlikely to stand up to repeated use loading, transport over rough roads and unloading. It was suggested to the operators that they could be strengthened with metal corners and metal strapping to make them more robust.

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC The operational staff appeared well trained and familiar with all of the resources and their workings. Numbers of trained operators and responders are also being maintained. 42 were reported as currently available for response (28 Sakhalin Energy, 4 Ecospace and 10 Ecoshelf). About 20 of these individuals were mobilised for the OSR exercise at Piltun.

Fig. 12. OSR equipment at Nogliki PMD (top two photos) and Prigorodnoye Marine Base (bottom two photos).

A further 70 local people have also been given OSR training by Sakhalin Energy, but this programme is being terminated because of the unreliability of these personnel on call-out. This means that additional response personnel would have to be found from private contractors and through Emercom/Oblast, but no formal arrangements are in place.

One change in resources has occurred at Nogliki. A heli-spray system which was in the Nogliki PMD stockpile in 2009 has been sent back to the contractor who had supplied it. In its place, Sakhalin Energy now has a sharing agreement with ENL, who hold three heli-spray units in their northern stockpiles. However, this arrangement has not been tested and it would be valuable to test that it functions effectively, for example in an exercise. Rapid

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC deployment of dispersant spraying equipment to a spill at the platforms, which could quickly be brought to shore by an onshore wind, is in my view a potentially effective component of clean-up efforts to protect near-nshore whale feeding habitat.

Overall the OSR equipment stockpiles at Sovetskoye, Nogliki and the Progorodnoye marine base are in good order with all the equipment stored and maintained in good condition. The operational personnel are well trained and versed in using and deploying the resources.

OSR Training workshop for Sakhalin Energy response staff, 20th July 2012 About 20 of SEIC’s response staff attended the OSR workshop, including senior managers Litvinov, Gutkin and Pak. There were some familiar faces from the May workshop. Overall the workshop seemed to be well received and was interactive with numerous questions asked after presentations and in breaks.

The programme included: Welcome and Introduction – Sakhalin Energy; Review of Shell’s global research programmes post-Macondo OSR planning, Shell initiatives and global oil industry initiatives – George Franklin, Shell International; Review of oil spill response techniques post-Macondo with emphasis on response in ice conditions – Victoria Broje, Shell Houston; Practical examples of spill response from past incidents and review of Piltun OSR exercise and OSR stockpiles – Brian Dicks, WGWAP; Review of winter ice conditions in the offshore oil fields around PA-A and PA-B – Pavel Truskov, Sakhalin Energy.

Franklin reviewed various industry-wide spill response programmes and technical and research ‘sharing’ initiatives and programmes, many of which have been triggered by the Macondo blow-out and some of which were not particularly relevant to Sakhalin Energy. This kind of initiative often follows a major oil disaster, such as past ones like the TORREY CANYON tanker spill (1968), the Ekofisk Bravo blow-out (1977), the AMOCO CADIZ tanker spill (1978), the EXXON VALDEZ tanker spill (1989) and the ERIKA (1999) and PRESTIGE (2002) tanker spills of heavy fuel oil. The merits of post-Macondo changes to spill planning, blow-out response and general oil spill response remain to be seen.

Broje gave a very wide ranging review of oil spill response techniques and impacts, which was well received. My first presentation was complementary to Broje’s and addressed the realities of oil spill response, focussing on selected oil spill examples which had relevance to SEIC’s oil type and its likely behaviour in the marine environment. I also highlighted specific issues such as access difficulties in remote areas, use of dispersants and what can be

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC achieved with them, and in particular waste disposal as a likely headache/bottleneck in spills, which I identified as a priority for further attention and as a subject for exercises by the company.

Overall the SEIC management team revealed a good understanding of the main issues and difficulties that a spill poses and the workshop was well organised and well run.

Final discussion meeting at Sakhalin Energy, 23rd July 2012 I met with Evans, Vladimirov and Shivaev. We discussed the Piltun shoreline exercise, my visit findings regarding the OSR stockpiles, dispersant use and policy, additional manpower and resources for a larger spill and the wider problems of oily waste management. We also briefly re-considered in-situ burning, spill response in ice conditions and the ice response manual. These latter points were covered in the report of my May visit and there was nothing new to add.

Sakhalin Energy expressed uncertainty about the Panel’s position on dispersant use but I believe that this has been fairly clearly stated in a recommendation in the WGWAP-3 report as follows:

Use of dispersants - The Panel recommends that SEIC should maintain its policy of no dispersant use in or near the Piltun feeding area at any time. Under certain circumstances it may be prudent to use dispersant in or near the offshore feeding area, although the Panel anticipates these conditions will be rare and any use of dispersant will require great caution. The Panel recommends that dispersant should not be used when WGWs are present in the offshore feeding area [WGWAP 3/017].

Sakhalin Energy fully agreed with this approach and incorporated it into revisions to their OSRPs. The subject of dispersant use has arisen from time to time in later Panel meetings and the Panel position has remained unchanged, with the focus on keeping dispersant application away from gray whales and their feeding grounds. My experience is that dispersant application can be a valuable technique if applied in line with the regulations in most countries where their use is permitted (including Russia), namely in waters deeper than 20 metres, which ensures ample dilution for the dispersed oil. The properties of Vityaz crude make it amenable to chemical dispersion and the use of dispersant has the potential to treat large volumes of spilled oil quite quickly, especially if applied from the air.

WESTERN GRAY WHALE ADVISORY PANEL WGWAP 12/4 12th Meeting 5-7 November 2012 PUBLIC My two main concerns which I think have real potential for causing difficulties in responding to a larger spill relate to the sourcing of additional manpower, vehicles and equipment as needed and to oily waste management/final disposal.

Additional manpower and mechanical equipment: The existing SEIC OSR stockpiles have an excellent range of specialist equipment and there are sufficient personnel and vehicles to deal with smaller incidents and to start response for a larger spill. My concern is that in a larger spill, for which clean-up is often a prolonged affair, it will be necessary for the company to obtain and manage considerable numbers of additional manpower and non- specialist resources such as trucks, diggers and support boats. Whilst Sakhalin Energy recognises the concern, no arrangements appear to be in place for mobilisation of such resources. I believe it is important that such resources be identified pre-spill and arrangements should be in place and have been tested in a Tier 3 exercise.

Waste disposal: Although the SEIC managers have general ideas about how oily wastes might be handled and where they might be disposed of (solid wastes to Smyrnyck and oily liquids to Prigorodnoye or private contractor), no details are specified in the OSRPs and these arrangements have never been tested. I think it important that they be in place pre- spill and should be tested.

Brian Dicks, 1st August 2012.