Experimental dismantlement of experimental reactors
Reactor Units 1 and 2 of Novovoronezh NPP, a plant located 42 kilometres south of the town of Voronezh, were the first reactors built in the Soviet VVER series of pressurised water reactors that could be called experimental prototype reactors. The Soviet Union started developing this model in the late 1950s based on shell-type reactors used on nuclear submarines. The reactors VVER-210 and VVER-365 were launched at Novovoronezh in 1964 and 1969, respectively.
Reactor Unit 1 was shut down when its design-basis twenty-year operational term expired in 1984. The first instinct of the nuclear industry was to modernise the reactor, instead of shutting it down, but the tragedy that occurred at Ukraine’s Chernobyl in April 1986 made it clear that its further operation was unsafe. It was officially taken offline in 1988.
The second reactor was shut down in 1990 – even before its engineered operational lifespan ran out – following a decree by what was then the Ministry of Atomic Energy of the USSR, which cited “major non-conformance of design specifications to current safety requirements, as well as the economic inadvisability of [the reactor’s] modernisation.”
Works to render the old units safe for future decommissioning were started as soon as the reactors were taken down. But it was not until over twenty years later that today’s successor to the Soviet atomic energy ministry, the Russian State Nuclear Corporation Rosatom, decided to develop the actual decommissioning project.
The public information department of the Russian NPP operator company, Concern Rosenergoatom, referred to the Novovoronezh decommissioning plans in a November 2010 statement as a “pilot project of the nuclear branch” – something that would indicate that further decommissioning projects for Russia’s VVER reactors would likely follow the same procedure that has been worked out for Novovoronezh.
The statement was a report by Rosenergoatom’s press service on a public hearing held in the plant’s home town of Novovoronezh to present a preliminary version of an environmental impact assessment (EIA) report on future decommissioning works. The company also set a December deadline to file remarks or suggestions regarding the EIA document.
The project “provides for step-by-step disassembly and liquidation of equipment, systems, constructions and building structures, disposal of all radioactive waste as well as [reclamation] of the NPP unit for further use,” the statement said, adding that this was what is called a “brownfield” scenario for the “first Russian project for decommissioning of an NPP with VVER-type reactors.”
But a “pilot project” would also mean that, as Russia has no experience decommissioning VVER-type reactors, the endeavour is, in essence, a potentially dangerous experiment.
No money for decommissioning?
Sources at Novovoronezh NPP told Bellona that in the past twenty years that the two old reactors stayed offline, awaiting decommissioning, certain vigorous, if chaotic, activities were in progress at the units absent of any decommissioning project: What parts of equipment or components remained uncontaminated by the many years of operation were being pulled apart and mysteriously lost track of. Indeed, copper wiring, power generators, and any other electrical equipment can easily be dismantled and sold for profit. The same, however, cannot be said about the radioactively contaminated parts of an old reactor unit – the reactor itself, the pipes of the primary coolant circuit, or steam generators.
There is no verifying this information. As per the current condition of the two shut-down reactors, the EIA report does not provide any data on that.
It looks therefore, judging by the information from Bellona’s sources, as if that stage of dismantlement that could prove profitable has already been taken care by someone. Someone has made a bargain on what could be taken away and sold for some sort of profit. There is no information on which and how many parts have been sold and at what price.
Likewise, it is unclear where the money went – one would hope it was Rosatom’s special decommissioning fund. After all, the expensive preliminary works to render the reactors’ radioactive parts safe for dismantlement and decommissioning will, as per the project, be carried out with money from that fund.
“As regards the funding, there is a decommissioning fund that was accumulated in the course of many years. This money was locked in accounts held by [Rosatom’s] Concern Rosenergoatom. The start of this project of reactor decommissioning, its approval by the Russian [Chief State Expert Evaluation Department], the ecological impact assessment, and a license by [the Russian federal industry oversight agency] Rostekhnadzor will prompt the unfreezing of this funding and the launch of decommissioning works,” Valery Novak, Rosenergoatom’s head for design and engineering branch, said in a recent news report.
But Rosenergoatom’s environmental impact report on the decommissioning project says quite the opposite: Rosatom is not ready to finance all decommissioning works at the site.
“At present, the limit set for deductions to the Reserve Fund for financing decommissioning costs is too low to allow for the creation of a sufficient accruable part in the reserve, or to provide enough funding to fully carry out works required to prepare, transport, and dispose of [spent nuclear fuel] after its temporary on-site storage at [the nuclear power plant].”
Problems with the EIA report
There is as yet little clarity as to the size of Rosatom’s decommissioning fund or sources from which funding is entered on its accounts, or how this funding will be spent. Experts estimate the costs of works required to decommission a nuclear power plant as ranging between half a billion and a billion euros, or more, per each reactor unit. Such assessments appear, for instance, in a 2006 study done by Professor Stephen Thomas of the British University of Greenwich.
Professor Thomas says decommissioning works fall into three principal stages. Stage 1, lasting the first several months after a shutdown, involves removal of spent nuclear fuel (about one sixth of total costs); Stage 2 takes up to 40 years and envisions dismantlement of uncontaminated and slightly contaminated reactor parts (about a third of total costs); and Stage 3, which takes between nine and 135 years, focuses on removing the core and requires half of all decommissioning costs. This extended period also includes the long time it takes until radioactivity levels of certain isotopes, like caesium or strontium, subside to safe enough levels.
Works that have allegedly already been performed at the closed reactors of Novovoronezh NPP are probably closer now to Stage 2, though there is no confirmation of the current progress. The official environmental impact document offers no assessment at all of the total time frame envisioned for the entire decommissioning process, nor for any of its stages.
In fact, environmentalists are already voicing strong criticism of the official EIA statement, saying it is both incomplete and misleading.
A number of NGOs – the environmental group Ecodefense!, GROZA, and the Interregional Human Rights Group Voronezh/Chernozemye – have written a critical letter to the organisers of the public hearing in Novovoronezh, posing a range of serious questions with regard to the EIA report.
“The document lacks certain very important information which is essential for an environmental impact assessment,” says the letter that the environmentalists handed over to Novovoronezh city administration last month. “The EIA report is incomplete […] and cannot be accepted in its current version, since it could mislead both those responsible for decision-making and the population.”
The absence of any concrete time frames is one of the issues the environmentalists raised with Rosenergoatom’s Novovoronezh EIA statement.
“The document does not specify the duration of any of the decommissioning stages, nor the amount of radioactive waste that will be generated at each decommissioning stage,” the letter said.
The problem is that absent of any concrete time frames, it is impossible to assess the risks of various projects or works undertaken as part of the decommissioning process or the impact they might have on the environment.
What about the waste?
Rosenergoatom’s environmental impact statement says: “At each of the decommissioning stages (‘Preparation for monitored storage,’ ‘Monitored storage,’ ‘Disposal of the [nuclear power] unit as a source of radiation hazard’) harmful substances may come into existence, both radioactive and non-radioactive. Generation of radioactive substances occurs during works involving dismantlement, fragmentation, and disposal of contaminated equipment and structures; when decontaminating premises and equipment; and during reprocessing of [radioactive waste].
But the report omits the most important information that has to do with radioactive waste – the actual amounts of waste expected to be generated in the decommissioning process.
“The document offers no quantitative assessment or qualitative analysis of radioactive waste that will be produced during decommissioning works on Power Units 1 and 2 of Novovoronezh NPP,” environmentalists said in their letter to the organisers of the November public hearing in Novovoronezh. “There are no data on the amounts, radioactivity levels, or isotope composition of anticipated radioactive waste. Without these data, it is impossible to assess the impact of decommissioning works on the environment.”
In particular, the letter said, the report has no information on the contaminated equipment and pipelines to be dismantled during decommissioning.
“For this kind of radioactive waste, this is [supposed to be] quite a considerable amount – we’re talking both about the reactor vessel, and the equipment inside the reactor, and the components of the primary loop,” the letter continued.
Strangely enough, the report is indeed silent on the amounts of waste expected to be produced during decommissioning. The EIA statement’s authors do mention the amounts of waste they expect to be generated on a yearly basis – but they say nothing about how many years this or that type of works is going to take.
The report says, for instance:
“The plasma-based [radioactive waste] reprocessing complex is expected to produce on the order of 142 cubic metres of liquid [radioactive waste] in stillage residue per year.” But nothing is said on the total amount of liquid waste expected from the entire decommissioning process.
Or: “The amount of [liquid radioactive waste] to be drained from the hot cell into the special-purpose sewage system of Reactor Unit 1 does not exceed 20 cubic metres per year, to a combined radioactivity of 18.5 * 1010 becquerels (5 curies).” Yet, again, nothing is said about the total amount of liquid waste that will be generated from decommissioning the units.
Another example: “The amount of [solid radioactive waste] to be generated is assessed at an average of 65 cubic metres per year. The data on solid radioactive waste comprise: flammable materials (58 percent), metals (8 percent), plastics (6 percent), buildings’ brickwork (6 percent), and other materials (22 percent)…” but there is no assessment of the overall amount of solid radioactive waste that will result from the entire decommissioning process.
Calculations show that if decommissioning works last a total of around 50 years, as suggested in Thomas’ study, the overall amount of liquid and solid radioactive waste will reach 8,150 cubic metres and 3,250 cubic metres, respectively.
Since hardly any experience has been accumulated globally with decommissioning nuclear power reactors, comparisons are hard to come by, but one could be made with the data contained in the decommissioning plans developed by Lithuania in 2005 for its Soviet-built Ignalina NPP, which was shut down for good on December 31, 2009. The reactors at Ignalina are much more powerful and belong to a completely different design series, but the expected amounts of resulting waste should be of a similar scale.
The Lithuanians anticipate producing some 5,900 cubic metres of high-level radioactive waste and around 130,000 cubic metres of solid medium- and low-level radioactive waste during the decommissioning of Ignalina’s two RBMK reactors. Lithuania’s 5,900 cubic metres of high-level radioactive waste are quite on par with the figure of 3,250 cubic metres for solid radioactive waste expected at Novovoronezh. But nothing resembling the 130,000 cubic metres estimated by the Lithuanians for solid medium- and low-level waste is found in the EIA report for Novovoronezh decommissioning. Have the experts behind the Novovoronezh report completely forgotten about medium- and low-level radioactive waste? But this waste will be generated whether or not Rosenergoatom wants it to. What will happen to it? How will it be handled?
Waste storage and related problems
The resulting radioactive waste needs to be stored somewhere, and that makes for yet another separate headache.
At one point in the environmental impact report, its authors do mention one substantive assessment: 20,000 containers. But the language provides no clarity as to what kind of containers are meant or how much waste they can contain. Twenty thousand containers – does that make 10,000 cubic metres? The report offers no answers on that account.
“According to the assessments made, the overall amount of radioactive waste generated during the decommissioning will total around 20,000 [unrecoverable protective containers].” Yet, no substantiation is provided for that assessment, nor any data that will place the resulting waste into appropriate types of classes. Furthermore, the report mentions at one point that the site is furnished with a place suitable for temporary storage, but it can only accommodate 10,000 containers. There is no information as to how the remaining 10,000 containers will be stored once they are filled.
“The document has no description provided for the conditions in which the radioactive waste expected to be generated during decommissioning works on Reactor Units 1 and 2 of Novovoronezh NPP will be transported and stored,” Ecodefense!, GROZA, and the Human Rights Group Voronezh/Chernozemye said in their letter. “There is a roster and descriptions of [solid radioactive waste storage facilities], but no information on how long they have been in operation, nor any factual data on how filled they are to date, nor about how much and which types of waste resulting from the decommissioning will be sent to which storage facilities or for how long.”
Likewise, the report provides no scenarios for potential accidents or incidents that may take place during transportation or storage – such as damage sustained by the waste or a storage facility or the risks of atmospheric precipitation coming into contact with the waste – and makes no assessment of environmental damage that can occur as a result.
Current problems and Rostekhnadzor’s assessments
As it happens, Novovoronezh NPP is already dealing with a number of pressing issues it is experiencing with storage of solid and radioactive waste accumulated on site.
Even Rostekhnadzor – an agency that rarely takes a critical stand when it comes to practices observed in the nuclear industry – has been forced to take notice of violations of radioactive waste storage guidelines that inspectors discovered at Novovoronezh. These concern the management of treated waste – or waste that has been duly processed in preparation for transportation, storage, reprocessing, or disposal – and non-treated waste.
“In breach of [2002 Sanitary Rules for Management of Radioactive Waste], non-treated [solid and liquid radioactive] waste from Units 1 and 2 of Novovoronezh NPP is being held in storage beyond design-basis time frames; in breach of [2002 Sanitary Rules for Management of Radioactive Waste], treated radioactive waste is being stored at the NPP in barrels with service periods under 50 years,” Rostekhnadzor said in its yearly report for 2009.
Rosenergoatom’s environmental impact report for Novovoronezh decommissioning says: “Metal containers with evaporate concentrate will be moved for storage to the 10,000-container temporary storage site located on [Novovoronezh NPP’s] industrial premises.” However, no time frames are determined for how long the containers – or, to be precise, half of them – will stay in storage there. The project thus seems to prepare the plant for certain failure, pushing it for repeat violations with regard to storage of waste in unsuitable conditions.
Just as it made no provisions for possible accident scenarios involving storage of waste off site, the EIA report makes no mention of environmental risks emerging from potential accidents or incidents affecting the 10,000 containers with radioactive waste at the on-site storage facility.
Accidents and incidents – underrating the danger
One of the more serious issues that environmentalists point to with regard to Rosenergoatom’s Novovoronezh decommissioning EIA report is what they refer to as an inaccurate analysis of possible accident risks.
“The document contains no quantitative or qualitative assessment of radioactive discharges that may occur during an accident. The claim that existing safety standards will not be breached under any accident scenarios is unsubstantiated,” the open letter by Ecodefense!, GROZA, and Voronezh/Chernozemye said. “There is no basis not to consider emergency situations or accidents associated with a possible failure of the gas scrubber system. It is evident that such an accident may lead to a release into the surrounding environment of radionuclides with a combined activity exceeding accepted norms.”
The environmentalists are concerned that the relevant section in the report does not examine any possibility at all of accidents or abnormal functioning of the equipment or erroneous actions on the part of the personnel. Accordingly, they reiterate, it provides no accident scenarios for emergency situations involving damage, contact with atmospheric precipitation, or leaks, nor any assessments of resulting environmental harm.
This, in turn, creates a skewed view of potential damage to population health.
“Calculations of population exposure doses have not been done for situations involving disruptions to normal operational conditions during accidents and incidents,” the letter continued.
Again, no analysis is provided for how malfunctioning equipment or personnel’s errors may lead to increased exposure of the population residing nearby, even though, according to the environmentalists, the section on non-radioactive discharges does consider a scenario involving destruction of the plasma-based reprocessing complex as a result of external impact, while another section, on potential accidents at the site, deals with accident scenarios leading to potential discharges of radioactive dust and gases into the atmosphere.
“It is obvious that destruction of the plasma-based radioactive waste reprocessing facility occurring as a result of external impact or for other reasons may lead to significant discharges of radionuclides into the surrounding environment,” the letter said.
The EIA report gets approved – but questions linger
Though serious issues remain unresolved with the future decommissioning project, Rosenergoatom reported the environmental impact assessment a done deal.
Rosenergoatom said in its November press release that over 350 people took part in the hearing in Novovoronezh, including representatives of the operator company as well as specialists from scientific institutions and Rostekhnadzor.
“ It was particularly noted that the qualitative and quantitative characteristics of the forecast state of the environment and living conditions make it possible to evaluate the impact of decommissioning of [the] power units […] as environmentally safe,” the report said. “The [hearing’s] participants took a favourable view of the EIA preliminary materials. The [hearing has] been declared valid.”
A news report by the Russian news agency REGNUM said the project was discussed at an extended meeting of the Novovoronezh City Public Council and received broad public support.
“We fear absolutely nothing from living next to the NPP, it makes us happy, even, that there is a nuclear power plant nearby,” the agency quoted one of the hearing’s participants, Yelena Pavlenko, as saying. Pavlenko heads the regional branch of the all-Russian Children’s Ecological Movement “Zelyonaya Planeta” (Green Planet), the report said.
But the city public council’s support or the children’s ecological movement’s enthusiasm notwithstanding, nuclear officials will still have to find answers to environmentalists’ questions about the expected amounts of radioactive waste or possible risks of accidents.
“The nuclear industry must create a ‘greenfield’ at the site where the reactors [are now standing], whatever that costs,” Ecodefense! co-chairman Vladimir Slivyak told Bellona, referring to a concept which – compared to that of a “brownfield” – implies complete remediation of land formerly used for industrial purposes in order to return it to natural state.
The question now is whether, armed with the environmental impact assessment report that is criticised so heavily for containing so many crucial gaps, Rosatom will even be successful in building a “brownfield” there in the first place.