Bellona’s Position Paper:

A number of these countries have given money under the aegis of the Northern Dimension Environmental Partnership programme, or NDEP, particularly those in Europe. Others have donated under commitments set by the Group of Eight industrialised nations.

The very nature of these projects is hazardous because they deal with nuclear and radioactive materials, and they present a very real danger for the environment and human health, despite their other benefits. It is therefore required that these projects and the issues surrounding them be subjected to several rigorous stages of oversight.

Certainly not the least of these issues is the efficiency of money spent on these projects, and the installation of cost-effectiveness controls to ensure that money sent is allotted to those projects for which it is meant to be spent.

Finally co-ordination of projects put forward by donor states, as well as all of their efforts as a whole, is of vital importance.

1. Transparency and co-ordination
Transparency on nuclear remediation projects through various nuclear safety programmes with Russia—from the research and development stages and throughout implementation—is critical. The opinion of independent experts and organisations must be solicited for each project the programme undertakes. After all, the projects that will—and already are—underway pose health risks to human beings. Because of this, all information on each project should be open to the public.

Project transparency is also vital for co-ordination. The benefits of this are endless: One country working on a similar project that another has already embarked on can benefit from the expertise. Likewise, a country with expertise in a certain area can offer its assistance on a project already begun by another country. Overall, transparency in projects will furnish participating nations with a general picture of what others are doing and how.

Transparency also works in favour of avoiding the misuse of funding. Project transparency would render impossible, for instance Russia’s request funding from two different countries for the completion of one project. Likewise, authorities in Moscow will be fully apprised of the cost, materials and dangers involved in each project.

One example where transparency was completely disregarded was an agreement signed between Russia and Italy, where Italy would be giving Russia € 360m for submarine dismantlement. But the language of the bilateral agreement, penned by the Russian Ministry of Atomic Affairs, or Minatom, was determined to keep the specifications of information as far under wraps as possible.

The agreement “does not imply the exchange of information considered a state secret to Russia with Italy,” the agreement begins. The agreement goes on to state that all information exchanged between both sides is to remain “confidential” and that “the sides will maximally restrict the circle of people having access to information that qualifies as confidential or sensitive.”

Strictly speaking, the MNEPR agreement, for example, contains no prohibition on such seemingly opaque agreements. As stated in MNEPR Article 6, Paragraph 2:

“The Russian Party shall ensure the prompt issuance of, inter alia, licenses, permits, approvals and the prompt customs clearances necessary for the efficient implementation of projects. The Russian Party shall ensure the provision of data and information necessary for the implementation of specific projects within the framework of this Agreement.[…] Should such access be restricted according to the provisions of the legislation of the Russian Federation, mutually acceptable procedures shall be developed in the Implementing Agreements. The Implementing Agreements shall also define the procedures for, and the scope of, the information to be transferred.”

There are broader examples: Minatom is a historically secretive organisation whose true name was not adopted until after the 1986 Chernobyl disaster—prior to which is was known as MINSREDMASH, or the Ministry of Medium-Level Machine Building. Minatom therefore has to be “encouraged” to be open.

That being the case, however, MNEPR does not exactly discourage such dense agreements either. But, as described above, the more financial, technical and informational transparency there is available on each project, the more effectively will donor countries and Russia will be able to solve these nuclear threats in effective manner.

2. Independent environmental and feasibility evaluations

The disaster of the K-159 submarine showed, in grisly detail, that donor nations cannot simply give money to Russia without examining each step of the nuclear dismantlement procedure. Though the K-159 was not a western-funded operation, it included many elements that western-funded operations do. Most notably, the submarine was being towed from Gremikha Naval Base, to dismantlement when it sank. Two Victor II class submarines, for whose dismantlement Norway paid €20m, were being towed in the same manner this summer. Bellona, in 2002, warned the Russian government that towing was extremely unsafe. Had it been one of Norway’s Victor’s, instead of the K-159 that when down, the responsibility would lie with Oslo and the safety evaluation it never performed.

A similar case is the liquid radioactive waste, or LRW, treatment facility at Atomflot, the enterprise that services the Murmansk Shipping Company’s nuclear icebreakers. In this case, the LRW facility was meant to be operational by 2000. It has also been plagued by cost overruns in excess of $2m and still is not operation. According to expert opinion, it never will be operation because the project will have to be started from scratch. A thorough and preliminary evaluation of the project would have saved millions of dollars and years of time before the project even began.

A much stricter policy of audits is direly needed. At present, western money is received, spent and controlled by one state agency: Minatom. In order to assure the effective use of this funding, however, these three elements must be split up and taken out from under the roof of one agency.

Minatom, for instance, should only implement nuclear remediation projects. Control of project safety should be handed over to Gosatomnadzor, or GAN, Russia’s nuclear regulatory agency, and other nuclear regulatory bodies. The actual spending of the money should be handled by the Russian General Accounting Office. And all these agencies should be submitting reports, which the donor countries should have access to.

There have been numerous occasions when Minatom has been shown to have misspent western funding, spent it with western partners, or diverted western funding into projects that have nothing to do with what that western funding was allocated for. Such cases help sustain and develop the dilapidated arsenal such money is meant to dismantle.

For their part, western donors should take a more aggressive stance with Minatom, not bow to its demands, and take a long, hard look at the feasibility and reason of the involved projects.

3. Conclusion
It is Bellona’s assertion that the signatories to the MNEPR agreement have established an unprecedented common framework for radiation safety and security issues in Russia—both for the sake of liability and tax exemption purposes.

The transparency on nuclear remediation projects through various nuclear safety programmes with Russia—from the research and development stages and throughout implementation—is critical and should become a common policy.
There is a need for environmental risk evaluation of each nuclear safety and radioactive waste project such that the money is spent "safely" and the implementation of the projects does not lead to accidents.

A more strict policy of controls is needed. The functions of regulatory and audit should be taken from Minatom and given to independent state bodies. There must be European Parliament, US congressional, Russia State Duma, and European nation parliaments’ involvement as to which specific projects receive funding. Furthermore, both Russian and International NGOs should be able to participate in these oversight programmes.

There is still a critical lack of the proper co-ordination of the nuclear remediation projects underway in Russia and an absence of a general “master plan” that would pinpoint priorities.

There are several structures that fill the void of this co-ordination. As the Evian G-8 summit showed, these organisations boil down to NDEP co-ordination structures, MNEPR co-ordination structures, bilateral and trilateral committees and finally the International Atomic Energy Agency’s consulting body, the Control Expert Group, or CEG.

It is Bellona’s suggest that such an oversight structure should be drawn from each of the above listed group, maintaining both a wide enough scope of members so that opinions are balanced, but familiar enough with the safety, health and security issues at stake to approve the right nuclear remediation plans.