I consider the entire escape from the Genesis wave to the explosion and formation of the planet to be an action sequence, and an 8 minute long one at that. Kirk has a knife fight with david in the cave. Terrel shoots someone and then himself. There are dead bodies and earworms everywhere - which is admittedly more horror but is still in the same, or possibly lower, visceral neighborhood. And the film starts by ¡Killing the entire bridge crew! That sets the tone of the movie. You're the only person I've ever spoken to that has made the claim that TWOK is not an action movie. So I kind of find this discussion a little odd and possibly facetious.
I wasn't saying that it's a slow and boring movie by any stretch, just that it has this reputation as one of the more "pure action" Trek movies, and I think that if you compared it to just about any other Trek movie except for TMP and TVH, you'd find it's not that different from them in terms of action. I don't think it's in the same league as far as action as FC or Star Trek XI, though.
But if you're annoyed by this discussion, I'll just leave it at that.