561 



In agreeing to PS-82, Goskomgidromet assumed that the Navy was planning to commission 

 RW handling facilities by 1986, and it scheduled a review of the Regulations for 1986-1987 in ac- 

 cordance with the recommendations of the IAEA and London Convention [2, 3, 4]. However, no 

 RW handling facilities had been built, and the Navy was forced to continue dumping RW at sea. 

 In 1985, Goskomgidromet refused to agree to the Navy's proposed disposal areas in the northern 

 seas, some of which were on the eastern coast of the Novaya Zemlya archipelago. In view of the 

 continued dumping of RW at sea, Goskomgidromet withdrew its consent to PS-82 effective De- 

 cember 1, 1987. From then on, approvals to dump RW at sea were issued by Navy Headquarters. 



In February 1992, the Commander-in-Chief of the Navy submitted a request to the Govern- 

 ment of the Russian Federation for a temporary extension of the Navy's existing procedures for 

 dumping RW at sea. In accordance with Instruction No. A-2-61 1 of the Government of the Rus- 

 sian Federation, the Russian State Nuclear Power Supervisory Administration (Gosatomnadzor) 

 reviewed the request and recommended that the Navy obtain an opinion from scientific institu- 

 tions and interested ministries. According to the opinions of the Russian Ministry of Nature, Min- 

 istry of Foreign Affairs, and the Scientific Commission for Radiation Protection, decisions on 

 matters of RW disposal at sea should be guided by international standards, which eflFectively 

 meant prohibiting dumping at sea. 



In violation of the requirements of the London Convention and the USSR Council of Minis- 

 ters resolution [18], Goskomgidromet did not furnish information on RW disposal at sea to the 

 IMO and IAEA. Moreover, in its answers to the London Convention's questionnaire in 1989, it 

 declared that "the USSR has not dumped, is not dumping, and does not plan to dump radioactive 

 waste at sea" [6]. 



It is especially important to dwell on the normative documents relating to the disposal of 

 high-level RW. Such dumpings are completely prohibited by the London Convention and existing 

 national regulations, but the USSR made them from 1965 onward under ad hoc decisions of the 

 USSR State Committee for Shipbuilding, the USSR State Committee for the Use of Atomic En- 

 ergy, and the Navy on individual projects developed earlier by scientific research institutes (in 

 particular, the Russian Ministry of Atomic Energy's Scientific Research and Engineering Institute 

 of Power Technology). 



Beginning in 1987, the dumping of RW at sea by the USSR was doubly unlawful; 



• first, normative documents approved by the USSR contained requirements for dis- 

 posal of RW at sea that did not conform to the requirements of international stan- 

 dards recognized by the USSR; 



• second, even these normative documents approved by the USSR were violated (RW 

 was dumped without coordination with environmental bodies and without appro- 



^Figure 4. Location of Major Radioactive Waste Sources and Disposal Areas in Northern Seas [14]. 

 Northern Fleet Bases: / — ^Neipichya Bay; 2 — Andreyev, Bolshaya Lopatka and Malaya Lopatka Bays; 

 3 — Olenya and Sayda Bays; 4 — Ara Day; 5 — Pala Bay; 6 — Yokanga. Holding and Recycling Sites for 

 Decommissioned Nuclear-Powered Naval Vessels and Ships: 4 — Polyamy; 6 — Yokanga; 7 — Murmansk 

 (Nuclear Fleet Radio Regiment); 8 — Severodvinsk (water area of Zvezdochka Shipyard, North Production 

 Association). Temporary Storage Sites for Spent Nuclear Fuel: / — Andreyev Bay; 6 — Yokanga; 7 — Mother 

 ships Imandra, Lepse, and Loita\ 2 — Navy tender for refiieling reactors of NS's. Shipyards: 8 — Severodvinsk 

 (Northern Machinery Enterprise Production Association, North Production Association); 4 — Polyamy (Naval 

 shipyard); 4 — Vyuzhny (Nerpa Shipyard). Not shown on map: Saint Petersburg (Baltic Yard Production 

 Association, Admiralty Production Association), Nizhniy Novgorod (Krasnoye Sonnovo Production 

 Association). /, V: LRW dumping sites. /, (7// (boxed): SRW disposal areas. 



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