[] TL: RUSSIAN NUKE WASTE DUMPING SO: Greenpeace International (GP) DT: November 8, 1993 Keywords: nuclear power weapons waste disposal ussr russia ocean dumping oceans conventions gp greenpeace / GREENPEACE: THE NEED FOR FURTHER ACTIONS CONCERNING THE DUMPING OF RADIOACTIVE WASTE BY THE SOVIET UNION AND THE RUSSIAN FEDERATION (GP) Submitted by Greenpeace International to the 16th Consultative Meeting of the London Convention 8-12 November 1993 At the IMO, London Introduction (1) Dumping of radioactive wastes at sea by the Soviet Union and the Russian Federation has attracted considerable international attention as details have progressively come to light since 1991. Greenpeace welcomes the resulting increased availability of official information on these dumping activities and the recent signs that access to dumping sites tor scientific missions may be improving. However being informed of the true extent of this dumping and its potential impacts are only two aspects of the problems created by these dumping programmes. This document therefore focuses mainly on other issues of great importance for Contracting Parties which we believe need further actions. In particular we wish to draw the attention of Contracting Parties again to the question of retrieval and other remedial measures which might be undertaken, and the question of whether dumping will continue to be carried out by the Russian Federation. Information Provision and Risk Assessment (2) A document submitted by Greenpeace International to the 4th Meeting of IGPRAD [1], drew the attention of Contracting Parties to persistent but unconfirmed reports of Soviet dumping of radioactive wastes at sea from the 1960s to 1986. The subject was referred to the 14th Consultative Meeting of Contracting Parties to the London Convention, where a commitment was made by the delegation of the USSR to investigate the situation and submit the relevant information to the 15th Consultative Meeting [2]. No such document was presented by the Russian Federation to the 15th Consultative Meeting of Contracting Parties. However Greenpeace International was able to submit at that Meeting a detailed inventory of wastes dumped in the Barents and Kara Seas [31. (3) The 15th Consultative Meeting discussed the Soviet Union and Russian Federation radioactive waste dumping at considerable length and in addition to reiterating its requests for information concerning the alleged dumping and making requests concerning access to dumping sites for investigations, the Meeting also requested, inter alia [4]: the Russian Federation to undertake studies including site surveys in international co-operation if it transpires that dumping of radioactive matter has also occurred in other marine areas besides the Barents Sea and Kara Sea; the International Atomic Energy Agency to continue its participation in relevant investigations and its assessment of the associated risks to human health and the marine environment and to report their findings as soon as possible and no later than at the Sixteenth Consultative Meeting; the International Atomic Energy Agency and the Russian Federation to indicate scientific and technical measures to reduce, as much as possible, any significant risk including remedial actions such as capping, retrieval and storage on land; [and] all Contracting Parties to consider provision upon request of relevant and adequate assistance to the Russian Federation, Norway and the International Atomic Energy Agency for the planned survey and for possible remedial activities to reduce the risks. (4) It was not until June 1993 that the Russian Federation presented the report prepared by the Governmental Commission on Matters Related to Radioactive Waste Disposal at Sea. An unofficial English translation was also made available and, for example, was circulated to the 6th Meeting of IGPRAD [5]. This document substantially confirmed earlier reports and revealed hitherto unreported dumping, for example, in the Seas of Japan and Okhotsk. Some additional details are still clearly needed however, for example better estimates of activity for the dumped reactors, detailed radionuclide composition of dumped materials, and the nature of packaging materials used, and their present condition. (5) The International Atomic Energy Agency (IAEA) has initiated the International Arctic Seas Assessment Project (IASAP) to assess the risks to human health and the environment associated with the radioactive wastes dumped in the Kara and Barents Seas, and to advise on possible remedial actions for these wastes. This project was launched at the meeting on Assessment of Actual and Potential Consequences of Dumping of Radioactive Waste into Arctic Seas which was held in Oslo during February 1993. The IASAP is set to be completed during 1996. (6) It should be noted that, despite the request from the 15th Consultative Meeting of the London Convention, the IAEA has not complied with the request to initiate investigations which would address the impacts of Soviet and Russian dumping beyond the Arctic area, namely that which has been conducted in the Seas of Okhotsk and Japan. Nor is it planned to complete the assessment of the dumping in the Arctic region within the time-frame requested by the Contracting Parties to the London Convention. Finally, while the IASAP is open to experts from all IAEA Member States, NGOs such as Greenpeace have not been permitted to participate in this project thus far. This regrettable situation mirrors the earlier years of IGPRAD's work and should be speedily corrected. Retrieval and Other Remedial Actions (7) As is made clear by the requests from the 15th Consultative Meeting of the London Convention, the interests of Contracting Parties must go beyond the provision of data about the dumping activities and related risk assessments and include consideration of remedial measures to be undertaken. While the IASAP program me does address retrieval and other remedial measures, this work is to be the subject of only one of the four IASAP working groups which is also to consider impact assessments (the other three working groups focusing on the source terms, existing environ,mental concentrations and transfer mechanisms and models), and the first meeting of technical experts on remedial measures is set to take place only in Spring 1994 [6]. It must be questioned, therefore, whether retrieval and other remedial measures are being given sufficient priority in the programmes that have been established already. (8) In Greenpeace's view, consideration of retrieval and other remedial measures must be put to the forefront of any program me relating to the Soviet and Russian dumping. This is consistent with the fact that, as recognised in the rep on of the Russian Federation to the London Convention [5], the Soviet and Russian radioactive waste dumping operations breached technical and scientific criteria contained in the lAEA's "Definition and Recommendations" [7]. It is also in line with the emphasis placed on intervention measures by the 15th Consultative Meeting, with Contracting Parties requesting: The International Atomic Energy Agency and the Russian Federation to indicate scientific and technical measures to reduce, as much as possible, any significant risk including remedial actions such as capping, retrieval and storage on land. [4]. (9) Clearly, retrieval of the dumped wastes offers the greatest potential for averting risk to the marine environment from eventual release and dispersion of radionuclides. Therefore, in Greenpeace's view, retrieval should be the preferred option and ultimate goal of all remedial activities in this context. Illustrative of just one of the scientific and technical problems inherent to the sea disposal option, however, it is also clear that in some cases retrieval might entail unacceptable risks to the marine environment, to workers, or to both. In such cases, and as an interim solution only, other remedial measures such as capping may be the most appropriate management option. (10) However it retrieval and other remedial measures are to be deployed in a timely manner, it will be necessary to shift the focus of the efforts currently in progress away from largely theoretical modelling and risk assessment to more directly utilisable research. Urgent information is needed on the current condition of the waste packages both in order to establish priorities tor intervention and to allow opportunity tor the development of intervention techniques. A detailed and systematic program me of retrieval and other remedial measures will need to be elaborated and implemented, and an appropriate starting point tor such considerations would be the provision of the reports from the IAEA and the Russian Federation on matters requested by the 15th Consultative Meeting [4]. (11) Although a significant proportion of the Soviet dumping was conducted prior to the entry into force of the London Convention, it is recognised also in the report presented by the Russian Federation to the London Convention, that the Soviet Union and the Russian Federation have violated the provisions of the Convention [5]. The importance of maintaining the credibility of the London Convention as an instrument of marine environmental protection means that intervention to redress breaches of the Convention's provisions must be required of Contracting Parties. In the case of the Soviet and Russian dumping of radioactive wastes, this should clearly involve retrieval as a first option. Future Dumping Activities (12) There have been conflicting statements by Russian officials about whether sea dumping of radioactive wastes by the Russian Federation will continue. On the one hand, statements to the 15th Consultative Meeting by the Russian Federation indicated that no dumping was taking place and that all regulations and recommendations of the London Convention, including the moratorium, were now adhered to by the Russian Federation [8]. This would rule out any dumping unless the moratorium is lifted, and in any case, in line with the IAEA Definitions and Recommendations this would, tor example, permanently rule out any dumping of any radioactive waste in the Arctic Seas. (13) On the other hand, at the International Conference on Environmental Radioactivity in the Arctic and Antarctic held in Kirkenes in August 1993, Russian representatives stated that there would be a need to continue with some sea-dumping of liquid wastes for several years. In addition, the recent Russian Federation Government Decree on radioactive waste and dumping at sea [91 implies that a final decision is still awaited on whether to forbid all solid radioactive waste dumping at sea, and requires temporary rules tor liquid wastes be developed within three months of the Decree's promulgation. (14) It is therefore important that the Russian Federation unambiguously clarifies its intentions concerning possible future sea disposal of radioactive wastes at the 16th Consultative Meeting of the Contracting Parties to the London Convention. Recommendations (15) This paper identifies a number of issues which Greenpeace strongly encourages Contracting Parties to address during the 16th Consultative Meeting Of the London Convention. In particular we recommend that: 1. The Contracting Parties encourage the IAEA, in conjunction with the Governments of Japan and the Russian Federation, to establish a project similar to the IASAP to address Soviet Union and Russian Federation dumping of radioactive wastes in the Seas of Okhotsk and Japan; 2. The Contracting Parties encourage the IAEA to allow NGOs immediate and unrestricted access to and participation in the meetings, working groups and documentation of the IASAP; 3. The Contracting Parties recall the primary importance of work relating to retrieval and other remedial measures and reiterate their request to the IAEA and the Russian Federation to report as soon as possible to the London Convention on scientific and technical measures to reduce, as much as possible, any significant risk including remedial actions such as capping, retrieval and storage on land; 4. The Contracting Parties request clarification from the Russian Federation of its intentions concerning possible future sea disposal of radioactive wastes, and call upon the Russian Federation to abide by its commitment to adhere to all regulations and recommendations of the London Convention, including the moratorium on the dumping of radioactive wastes. References 1. "Ocean Dumping in the USSR", LDC/IGPRAD 4/lNF.5, Greenpeace International, 1991. 2. see par a. 11.43 in the Report of the 14th Consultative Meeting, LDC 14/16, 1991. 3. "Necessary Correction to IAEA's Inventory of Radioactive Wastes in the Marine Environment: Soviet-Russian Dumping Activities", Greenpeace International, LDC 15/lNF.18, 1992. 4. Document LC 15/16, par a. 11.33, December 1992. 5. "Facts and Problems Related to Radioactive Waste Disposal in Seas Adjacent to the Territory of the Russian Federation", LC/IGPRAD 6/lNF.4,1993. 6. IAEA, IASAP Progress Report no. 1, July 1993 7. IAEA, "Definition and Recommendations for the Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter, 1972", Safety Series No. 78, 1986. 8. Document LC 15/16, par a. 11.29, December 1992. 9. Russian Federation Government Decree No. 710, 23rd July 1993.