Chief among these concerns voiced in the report is the storage of spent nuclear fuel (SNF) extracted from the decommissioned vessel at Zvyozdochka shipyard, and that the current outdoor storage methods for intermediate level radioactive waste are unsatisfactory. The report was written at Norways behest by the UKs Enviros Consulting group to review the previous two dismantlement projects, which began in June of 2003.
At issue in the Enviros report are the environmental impact assessments (EIAs) that had been performed by the Nerpa and Zvyozdochka shipyards on the dismantlement work and their neglect of how to handle the spent fuel that would be unloaded from the submarines.
This should be especially poignant for Norwegian authorities, who have championed rigorous EIAs for nuclear dismantlement projects in numerous international forums—particularly through the Contact Expert Group (CEG) of the International Atomic Energy Agency (IAEA).
The risk analyses performed by the shipyards were too limited because they did not include what would become of the fuel, said Nils Bøhmer, Bellonas Russian Programme Director.
The technical aspects of dismantlement, such as cutting up the vessel, are easy to deal with—the focus of such studies should be on finding safe storage for the spent nuclear fuel, which is the most environmentally dangerous aspect of submarine dismantlement, and that was not done in this case.
Foreign Ministry reportedly had doubts
Sources close to the submarine dismantlement project within the Norwegian Foreign Ministry expressed doubts about the results of the project, NRK television reported on its website. But according to the same report by NRK, both independent experts and the Foreign Ministry officially stated that the dismantlement projects had been carried out in a satisfactory manner by both Russian shipyards.
Responsible parties at the Norwegian Ministry of Foreign Affairs were unavailable to comment to Bellona Web either by telephone or via emailed requests for reaction to the Enviros report, and whether its findings would influence how Norway handles its third submarine dismantlement project in Russias Northern Fleet.
Ingar Amundsen, a senior advisor at the Norwegian Radiation Protection Authority (NRPA)—which co-commissioned the Enviros report with the Norwegian Foreign Ministry—said that the Enviros report, which included site visits by Enviros staff, did not find any insurmountable obstacles to obtaining information, but that some elements of the project required more information.
We are dealing with those lacks of information now and they will be taken into consideration in future projects," he said in a telephone interview with Bellona Web.
He said that the NRPA was engaged in intensive dialogue with the Nerpa shipyard—where the next Norwegian sponsored submarine will be dismantled—in order that NRPA officials have greater access to where the submarines spent fuel will be unloaded.
This is a requirement, in fact, said Amundsen. He said that a thorough environmental impact study analyzing the environmental risks posed by the fuel and its subsequent planned transportation to Russias Mayak spent fuel reprocessing facility in the Southern Urals will be conducted before dismantlement of the submarine begins.
Nothing will happen before these questions are answered, he said.The Enviros reports findings
A proper EIA, as envisioned by Norways delegation during a CEG meeting held early in 2003 in Murmansk, would have detailed each element of dismantlement, from moving decommissioned vessels to dismantlement ports to the storage disposition of SNF.
But neither of the two Victor II class submarines EIAs took further storage of intermediate waste into acccount beyond leaving it essentially in the open. Higher level wastes, according to information furnished to Enviros, is stored in dedicated buildings. But, notes Enviros, there are questions about the robustness of and security of these buildings and about their capacity to continue to accommodate future arisings of the unloading of future high level waste, the report read.
Conditions are even more precarious for intermediate level waste, especially at the Zvyozdochka shipyard in Severodvinsk in the Arkangelsk region.
Exposed to the elements, it is likely some drums of intermediate activity nuclear waste will begin to leak (if they have not done so already) and some activity will be released into the environment via drains, soil or by direct washing into the sea, the Enviros report read.
Apart from the current practice being poor housekeeping, minor incidents of this nature could easily be blown out of proportion so as to reflect very poorly on the overall running of the shipyard.
The other Norwegian sponsored dismantlement effort was carried out at the Nerpa shipyard on the Kola Peninsula in the Murmansk Region. Nerpa, according to Enviros, is to ship its reactor section accompanied by two adjacent pontoons to Sayda Bay. Though Enviros acknowledged that the management of Sayda Bay was beyond the scope of its report, it nonetheless said this method was also likely to be unsatisfactory as anything other than a short term arrangement.
Though the report concluded that, from information available, Norways dismantlement projects had been undertaken in compliance with applicable regulations, it noted that full documentation had been—even a year after the dismantlement procedures had been completed—hard to access.
In fact, the Enviros report indicates that its auditors received no information at all or information that was sketchy at best on 11 of the 12 key points governing the dismantlement of the submarines. What little information was furnished came from the Norwegian Ministry of Foreign Affairs.
The twelve key points for which Enviros requested information regarded:
*Transport of the submarines to the shipyards for docking, for which Enviros received no information.
*Preparatory work before de-fuelling for which Enviros received incomplete information from Nerpa.
*Removal of SNF, radioactive waste and other waste materials, including an assessment of possible accidents, for which Enviros received no documentation from Zvyozdochka.
*Loading of SNF into transport cask, information about which was furnished by neither shipyard.
*Removal of bow and stern sections, on which Enviros received data from Zvyozdochka only after the operations had occurred. Nerpa sent information both before and after. But both shipyards have yet to furnish any information on the environmental impact of these operations.
*Enviros received information on preparations of the storage hulls from Nerpa, including an assessment of materials released into the air during welding and painting operations. Zvyozdochka has supplied no such information.
*Information on transport of SNF for long term storage/disposal from Nerpa has indicated that SNF flasks have left the shipyard, but nothing more.
*Zvyozdochka supplied detailed information about on sight storage and packing of low and intermediate waste. Nerpa also supplied some information in this regard, but neither yard supplied risk assessments of the storage. No information at all was supplied about the planned storage of Nerpas waste at Sayda Bay in reactor compartments.
*Neither shipyard supplied any detailed information about the recycling of salvageable materials.
*Nerpa has given no information, namely risk assessments, associated with towing the hulls and pontoons to Sayda Bay.
*Both Nerpa and Zvyozdochka gave complete information regarding the packaging and storing of chemically hazardous substances.