The progress of the liquidation and the actions of Norilsk Nickel are now closely monitored by the environmental community not only of our country, but of the whole world.

WWF-Russia actively contributes to the elimination of emergency oil spills in our priority regions. Estimates by leading experts clearly show that the accident at HPP-3 occurred due to serious mismanagement in the corporate governance system of MMC Norilsk Nickel in terms of assessing environmental risks and ensuring environmental safety.

We believe that in this situation, the company’s management and you personally must take full responsibility for the environmental disaster that has occurred and immediately provide a full range of emergency measures to eliminate damage and prevent similar situations in the future at the expense of Norilsk Nickel.

First of all, we expect a maximally open position and informing both about the causes and consequences of the accident, and about the measures taken. In the first days after the accident, we observed an attempt to hide what had happened. WWF-Russia experts, having received information about the scale of the accident from social networks, had to intervene and inform the Marine Rescue Service.

Such secrecy, as well as the provision of false information is unacceptable. Any delay in responding to a spill leads to significantly greater damage and complicates the management of the consequences. We suggest that you develop corporate regulations to inform all interested parties about incidents that have occurred.

We are sure that the company should learn other lessons from this accident:

1. In the event of a leak, the necessary safety measure for tank farms - a walling that can hold the maximum amount of oil contained in the tank - has not fulfilled its functions. It means that its suitability was not checked and its technical condition was not monitored.

We ask you to submit to the public the results of the investigation of this accident and preventive measures in the future within 30 days, the period established by law.

2. During the emergency oil spill response, significant faults in the company’s oil spill prevention and response plan (OSR plan) became visible. In particular, many of the tools necessary for localization and collection on water were missing, there were no pre-made solutions for storing of the collected oil products, etc.

Please immediately provide the public with an effective OSR plan for critical analysis and preparation of recommendations for its processing. The new OSR plan must also be made publicly available.

3. Despite the fact that the first, most urgent stage of clean-up from water surface is about to finish, the accident area needs close attention, professional and public monitoring after the completion of work.

We ask you to inform the public about the measures taken for:

- ensuring safe storage and preventing re-leaks of already collected oil products, which are now stored on the banks of the Ambarnaya river;

- complete post-treatment of the shores of polluted rivers and lakes, as well as of the soil;

- ensuring safe transportation of collected oil products, without any chance of their entry into the environment.

4. The accident area should become not only a territory of consequences rectification, but also area of restoration of disturbed ecosystems affected by accidental pollution and numerous cases of discharge of pollutants in the past. All expenses under the restoration program should covered by the Norilsk Nickel company.

Please inform the public within 30 days of development plans and the possibilities of discussing the monitoring program and its implementation.

5. A comprehensive hydrochemical and hydrobiological monitoring is required on the territory from the accident site and downstream to the Kara Sea for an objective assessment of environmental damage, with the involvement of leading specialists of the country. Particular attention should be paid to the state of the Taimyr population of wild reindeer and commercial fish species, which form the basis of the traditional way of life of the indigenous peoples of the North.

We expect from the Nornickel company initiatives and allocation of funds for organizing monitoring and publication of research results in the public domain.

6. Taking into account the impossibility to completely eliminate the risks of oil spills in the region at the moment and the lack of a solution to eliminate them in the extreme climatic conditions of the North, WWF-Russia proposes to include the task to completely stop the use of oil fuels for energy and transport (heavy vehicles and ships) and shift to liquefied natural gas (LNG) in the medium-term business strategy of the company.

Shift away from the use of petroleum fuels is a real opportunity to reduce pollutant emissions and completely eliminate the risks of accidental oil spills. The environmental and economic efficiency of liquefied natural gas (LNG) for the Russian Arctic has already been proven. Moreover, there are already companies in Russian business that have included the use of LNG in their business strategies.

We look forward to your and Norilsk Nickel’s careful consideration of our proposals, your open response, detailed information on measures taken, as well as active actions to eliminate the consequences and prevent future accidents.

We hope that the lessons of the Taimyr disaster initiate systemic changes in the environmental policy of Norilsk Nickel.

Your sincerely,

Dmitry Groshkov

Director, WWF-Russia

Photo: (c) Marine rescue service of Russian Federation

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Open letter to Vladimir Potanin, President of Nornickel