TL:Dumping of radioactive wastes SO: Greenpeace International (GP) DT: November 18, 1991 Keywords: nuclear power waste ocean dumping greenpeace statements conferences london uk europe gp risks / Oral Statement to IGPRAD IV by Greenpeace International London at the IMO 18 November 1991 On behalf of Greenpeace, I would like to express our appreciation for the opportunity provided to us, to make a presentation at the beginning of your Meeting. As all of you are aware, we take the work of the LDC very seriously, and we have a particular interest in the issue of radioactive wastes, and - therefore - in the work of IGPRAD. For this reason, we find it regrettable that International Non- Governmental Organisations (INGOS) are not allowed to take an active part in the work of your Panel, aside from the opportunity given to us since last year to submit documents, and make an oral presentation at the beginning of your meetings. We have distributed two documents for your meeting, which I would like to briefly introduce. We are sorry for the late submission of these documents, which is in part due to the fact that one of them contains information that was unknown until only a few days ago. Comparative Assessment: The first document prepared by Greenpeace is "A Review of the IAEA Approach to Comparative Assessments of the Impact of the Dumping at Sea and Land-Based Disposal of Low-Level Radioactive Wastes". We chose this subject as an important area in which IGPRAD has yet to provide the assessments requested in 1985 pursuant to Resolution LDC 21(9). In 1987, IGPRAD recommended that the IAEA should "evaluate the comparative assessments of the disposal on land and dumping at sea options for the management of low level radioactive wastes submitted by Contracting Parties", and - in response - the IAEA produced in 1990 IAEA Tecdoc-562, entitled "Low Level Radioactive Waste Disposal: An Evaluation of Reports Comparing ocean and Land Based Disposal Options". From this document, some significant conclusions can be drawn: (1) one of the most fundamental conclusions to be drawn from the IAEA review of comparative assessment relates to the fact there were only five studies worldwide, which Contracting Parties considered suitable for submission, on the issue relating to radioactive waste dumping in the ocean vs. land based options, and that not one of these has been used for decisions in site-specific circumstances. It is generally accepted within the risk assessment and decision-making communities, that detailed quantified analysis of radiological impact are of limited usefulness, that the crucial issue cannot be quantified, and cannot be addressed by scientific methodology. The IAEA review does not ignore the issue of non quantifiable factors; it refers to them particularly with regard to the issue of weighting of impact, but does not underline their crucial importance. (2) At the end of the day, these factors can be reduced to the difference in radiological terms between exposing large numbers of people worldwide to smaller doses via marine food chains, and relatively much smaller numbers of people to higher doses (ignoring the potential for accidents in both cases), perhaps with significant risk of harm, in the localized areas for containment of the wastes. In quantifiable radiological terms (ie. the collective dose in person-sieverts), the radiation damage may be equal, although it is likely the ocean option will entail larger collective doses. The difference between the two doses cannot be described scientifically. It can only be evaluated in social and political terms. It is, in other words, a matter of values. (3) For example, the two exposed populations will differ: In the ocean option, the exposed people will be of all ages and both sexes. They will largely have derived no economic benefit from the nuclear programme. They will not have had access to the decision-making procedures. Indeed, they are likely to be ignorant of the risk, or to have - quite understandably and legitimately - exacerbated fears and aversion responses to the contamination, with the resulting potentially real economic and environmental consequences. And they will have no means of reducing the risk, other than by restricting their activities, and most likely, forms of cultural expressions and sustainment such as fishing. The other exposed population, on the contrary, is likely to contain a high proportion of professional male radiation workers, with economic benefit obvious. They will also be better informed of the risk, and able to take action to limit it, and will have better access to the relevant decision-making concerned with the trade off of risks and benefit. (4) In the most detailed of the comparative assessments (that done by the UK), these two differences were reduced to one single unit of radiological damage by the operation of "weighting factors" in the analysis. For example, the ocean route doses were increased by a factor of ten, to take account of the political factors outlined above. But there is of course no basis in science for such a factor. Ten was chosen arbitrarily; it could just as easily be 100, 1000, or 1,000,000, depending upon how the difference is valued. Thus, the "scientific model", quite simply disguises the value judgement, and actually leaves them in the hands of the assessment experts, rather than the political decision-makers. (5) It is clear to us that comparative assessment can aid in identifying the differences between options, but are of limited value in quantifying such differences - in particular with respect to radiological units. At the end of the day (or - rather - at the end of a decade of controversy), the matter will depend upon social, political and cultural values relating to perceived benefit and risk. It is already abundantly clear to us that the majority of the world population, and probably also their governments, have already made those decisions in favor of land-based options, and that there is no more significant information to be derived from future studies that can affect those decisions. This is in part why, as many of you must be aware, Greenpeace International has expressed the view that the LDC should be amended in line with the current political and social realities, with a view to banning the dumping of radioactive wastes at sea, as well as other environmentally and socially detrimental disposal practices (ocean incineration and the dumping of other kinds of industrial wastes). In this regard, we have listened closely to the views and concerns of LDC Contracting Parties and other States around the world in making this recommendation. Our views follow the lead taken by the growing number of States who believe that the LDC must be amended to ban, once and for all, these kinds of outdated practices. As one important example, the South Pacific Forum Communique of 30 July 1991 is indicative of such State concerns. The Heads of Government who signed that Communique were right on target in saying, among other things (and I quote): "Concern was expressed about the potential for the region to become a dumping ground for toxic and hazardous waste and chemicals and radioactive materials. In this regard, the Forum commended the (LDC) for its recent progressive stance on ocean dumping, and in particular for its 1990 decision to phase out industrial waste dumping at sea. The Forum expressed support for Forum Island Country members who were seeking to codify these advances by amendment of the LDC. The Forum noted its desire to culminate this procedure at the Fifteenth Consultative Meeting of the LDC in 1992 coincident with the UNCED Conference." In addition to Greenpeace's basic support for the views expressed by the South Pacific Forum as to the need for amending the LDC, we also strongly agree with their view that such amendments should be adopted in 1992, linking the LDC with the Rio Earth Summit decisions taken earlier in the year. As we all know, 1992 also is the 20th anniversary of the adoption of the LDC, yet another reason for taking such momentous action at that time. IGPRAD should - we feel - work toward this end. Such an outcome would be - indeed - a tremendous success for IGPRAD and the LDC, for all the governments involved, and for the Secretariat. Alleged Soviet Dumping: As many of you must be aware, in recent weeks, the world press has repeatedly reported information indicating that radioactive wastes were dumped at sea - perhaps until very recently - in the Soviet Union. Because such information contrasts significantly with the data provided by the government of the USSR to the LDC and the IAEA, and because it affects the credibility of the LDC, as well as the credibility of the IAEA's inventory of radioactive wastes entering the marine environment, we have collected at least some of these reports in a document called "Ocean Dumping of Radioactive Wastes in the USSR". This document speaks for itself, and we shall look forward to hearing the views of the delegation of the Soviet Union at the 14th Consultative Meeting of the LDC, next week. According to coinciding reports from various sources, radioactive wastes from civil and military origins (including the damaged reactor with its fuel from the ice-breaker "Lenin" in the 1960s) were dumped at sea for many years in the Kara and Barents Seas. Amongst the possible actions required in this instance, we would like to underline the following: (1) a clear and detailed explanation by the Soviet Union of its past and present radioactive waste disposal activities, including a full inventory of wastes dumped at sea - if they are not in a position to accurately deny the numerous coinciding reports on sea dumping; (2) an undertaking by the Soviet Union that - from now on - sea dumping will cease; (3) the presentation of the purpose, and the release of the findings, of the scientific expedition announced by the Russian government on November 1st 1991, to investigate around the archipelago of Novaya Zemlya, one of the alleged dump sites. The findings of this expedition apparently planned for the month of December should be submitted to the LDC, and their sponsor should consider associating the LDC or another independent body to its preparation and conduct; (4) When feasible, the IAEA inventory should be modified and updated accordingly. Everyone is aware of the very special political and social circumstances presently in the Soviet Union. As a result, the LDC should offer all required assistance to the Soviet Union. The Komsomolets Submarine: On a more positive note, our paper also addresses the plans apparently underway by a Soviet-Dutch Consortium, to lift up the Komsomolets nuclear submarine lost in the Barents Sea with nuclear weapons on 7 April, 1989. Greenpeace has already expressed in the past that - twenty years after its foundation - the LDC should seek to facilitate and encourage the retrieval of wastes dumped or lost at sea, rather than continuing to provide a mechanism to facilitate the continuation of dumping activities. In this regard, we see the plans to lift up the Komsomolets nuclear submarine in the Barents Sea as a potentially very significant development, and we would like to invite the USSR and other Contracting Parties to the LDC which are involved, to share those plans with the LDC, including safety aspects of this operation, and the planned final disposal site for this nuclear waste. Many other nuclear-powered vessels and nuclear weapons (from the US and the UK, as well as the USSR) lay on the seabed in various parts of the world, and if the Soviet Union with a Dutch firm have found the technology to retrieve them, LDC Contracting Parties should encourage its use everywhere. Conclusion: As stated in our opening remarks, we take the work of IGPRAD very seriously, and we would like to wish you all a very successful and productive meeting. There is a strong case for banning radioactive waste dumping at sea, and the time has come to move on more forcefully. A ban on radioactive waste dumping at sea should be viewed as a remarkable achievement by all those who have participated in the work of IGPRAD over the years. A failure to agree on such a ban, on the contrary, would constitute a missed historic opportunity.