Gazprom Neft Shelf refuses to report publicly the full text of the Plan, ignoring the recommendations of the Arctic Council. That means substantial parts of the information is unavailable, including the amount of financial security a company is obligated to prepare for dealing with oil spills and how it will be provided. It means that number of gaps and failures could be bigger.
1. The company has no detailed action plan for the case of spill of 1,500-5,000 tonnes of oil, while national legislation requires that company should cover emergencies up to 5000 tonnes. According to the document, an oil spill up to 10,000 tonnes of oil is possible in the area (in the case of a tanker accident).
2. The equipment the company prepared is insufficient for timely and effective response to a major oil spill.
The document states that the company has 800 meters of inflatable oil-spill sea booms on site and 400 meters more in Varandey village on the cost.
At the same time in order to even keep a 10,000 tonnes oil spill localized the company says they would need over 1,700 meters of booms at least.
Gazprom lists only 300 meters of coastal protection booms amongst its equipment, while an accident could affect many kilometers of the coastline.
The amount of tools for recovering oil from the coast by hand is insufficient too. The plan provides 15 shovels, 15 buckets, 3 axes and a sledge-hammer to clean dozens of kilometers of polluted shore. Cleaning is supposed to be done by 15 people (given the number of suits outlined in the same document).
3. The documents does not consider extreme weather conditions that could affect timing and equipment efficiency.
The OSRP Summary lacks description of worst-case storm conditions as well as information about the number of unfavorable days a year in terms of storm conditions, making it impossible to assess the possibilities and limits of using supply vessels (eg: boom-laying boats), helicopters, boom efficiency estimates and so on.
In conditions of storm and darkness, the transportation of additional equipment from Varandey both by sea and helicopters would be impossible. Multifunctional icebreaking supply vessels would not operate efficiently in a heavy storm either.
4. The company overestimates the effectiveness of oil spill sea inflatable booms.
According to the Plan, to mitigate a spill of 1,500 tonnes of oil, 1,200 meters of inflatable booms should be deployed by boom-laying boats. Collecting 1,500 tonnes of oil takes 16.6 hours.
But the record of oil accidents on sea proves that in most cases inflatable booms have been impossible to deploy or ineffective because of rough sea and strong currents. (1)
5. The OSRP gives preference to mechanical clean-up methods that have proven to be ineffective in the open sea. Efficiency ratio of skimmers is estimated at 100%. But previous accidents show that mechanical clean-up guarantees collection of only several % of spilled oil. In the case of Deepwater Horizon accident, only 3% of spilled oil was collected mechanically from the sea surface.
6. Incorrect evaluation of the effectiveness of cleanup techniques in ice-covered waters.
The company estimates effectiveness of cleanup techniques in ice conditions as close to 100%. To date, the only example of a real oil spill response operation in icy conditions is after the grounding of the vessel Godafoss off the coast of Norway and Sweden in February 2011. Less than 50% of spilled oil was collected in that case.
According to the National Energy Board (NEB) in the conditions of the Beaufort Sea, during the period from November until May, clean-up efforts would be impossible in case of the ice presence (2).
7. Ineffective evaluation and environmental impact assessment of in-situ oil burning.
One of the methods to mitigate an under-ice oil spill, proposed in the OSRP, is in-situ oil burning.
But crude oil is very difficult to ignite after it starts mixing with water. Besides, burning will cause high emission of soot, which will be deposited on the Arctic's icy surfaces, increasing the melting rate of snow and ice.
8. No evaluation of the harsh environments the personnel might be working in.
It is an extremely important point that Gazprom Neft Shelfs’s OSRP lacks assessment of the extreme conditions the employees might face during an oil spill response - such as working in the open and ice-covered waters in the polar night and Arctic winter. The Labour Code imposes clear restrictions on work performed in darkness, at low temperatures, etc.
Full version of the Greenpeace Russia Analysis
Greenpeace research: Gaps in the oil spill prevention and response plan for the operational area of the Prirazlomnaya offshore ice-resistant stationary platform of Gazprom Neft Shelf
Summary of the oil spill response plan published by Gazprom Neft Shelf
 «Обзор и анализ чрезвычайных ситуаций (разливы нефтепродуктов и других опасных загрязняющих веществ) в пределах морских, прибрежных и приморских особо охраняемых природных территорий и опыта ликвидации их последствий». А.Ю. Григорьев. М. 2011. http://mpa-russia.ru/obzor_i_analiz/