Water pumping was completely terminated on 14 April 2018 at the uncontrolled Ukrainian Yuny Kommunar mine where an experimental nuclear explosion was performed in 1979.
The facility was transferred from dry to wet temporary shutdown without the consent of the IAEA and SNRIU. The consequences are unpredictable; Ukraine will formally bear responsibility for them. However, this is only one example.
The decision to flood the Yuny Kommunar mine (Yunkom) was taken by the so-called Ministry of Coal and Energy of the self-proclaimed Donetsk People’s Republic (DPR). According to it, “flooding the mine horizons 500 m above the nuclear explosion site is the most functional technical solution for environmental safety in the central region of Donbas”.
Having reported on a positive impact of mine flooding on Donbas ecology, the authorities of the self-proclaimed “republic” refer only to the conclusions of several Russian institutions, while forgetting about the conclusions of the state nuclear and radiation safety review of Ukraine: water pumping termination can lead to transfer to the surface of artificial radionuclides, which can be contained in the Cleavage facility (the so-called glass chamber, which was formed after the nuclear explosion), namely strontium-137, cesium-90 and plutonium-239.
Self-proclaimed safety of central Donbas
0.3-kiloton nuclear charge was set off at the 903-meter underground operations horizon of the Yunkom coalmine for degassing of coal layers and testing of a regional methane release control tool in 1979. A glass chamber with a radius of about 10 m around which a rock compaction zone with a radius of 20-25 m was formed as a result of the explosion.
An integrated commission involving representatives of the Ministry of Ecology and Natural Resources of Ukraine really acknowledged in 2006 that the nuclear explosion did not lead to radiation contamination of the mine, its adjacent territories and the environment. However, the commission recommended maintaining the Cleavage facility in a dry unflooded state in order to ensure Donbas radiation and environmental safety.
Before start of the military operations in Donbas, the mine water was pumped out of 936, 826 and 476-meter horizons to the surface into mine basin, from where the water flowed to the sedimentation pool and further to the river of Bulavin. The mode of such water pumping provided minimum impact on the environment due to absence of leaching processes of radionuclides from the vitrified mass. Water supplied to the surface did not contact directly with the Cleavage facility.
After actual mine flooding, it is too early to confirm facility safety and completely exclude possible groundwater and surface water contamination. This requires additional surveys and studies by experienced experts, in particular the SNRIU and the IAEA. However, Ukraine does not have today access neither to Yunkom, nor to complete documentation on the facility and many other radiation sources that remained on the illegally annexed territory of the ARC and the occupied territories in the East of Ukraine.
Let me remind you that radiation source is a device containing radioactive substance that generates or can generate radiation under certain conditions. The high-level radiation sources are used in industry, e.g., for detection of micro cracks in metal-concrete or metal structures, in medicine for treatment of oncological diseases and their diagnosis (X-ray equipment). The radiation sources are also used for military purposes, in particular, for production of weapons of mass destruction. They are not hazardous, if full control is provided. However, radiation sources in the hands of uncontrolled separatists can pose a threat to the public and the environment. They can also become a raw material base for nuclear terrorism.
Ukraine — IAEA
Ukraine promptly informed the IAEA of the loss of control over radiation facilities in the ARC and the occupied East of the country.
Representatives of the national nuclear regulator submitted a specific report to the IAEA on 26 March 2014 to inform them that the control over nuclear materials and facilities in Crimea has been lost due to the occupation by the Russian Federation.
On 8 April 2015, the SNRIU submitted a similar report to the IAEA on the loss of regulatory control over nuclear materials and facilities on the temporarily uncontrolled territory in Donetsk and Luhansk oblasts.
The information submitted by the SNRIU was taken into account. However, … In accordance with the resolution of the UN General Assembly No. 68/262, which recognized the sovereignty and territorial integrity of Ukraine, the IAEA continues to adhere to the position on the application of safeguards to all nuclear facilities and materials in our country in accordance with the Agreement between Ukraine and the IAEA.
In other words, Ukraine is liable to the IAEA even for nuclear facilities located on the illegally annexed territory of the ARC and the occupied territories of Donetsk and Luhansk oblasts! Despite the lack of access to such facilities…
“11784 radionuclide radiation sources were located on the territory of Ukraine as of 2014. 296 of them were located on the territory of the Autonomous Republic of Crimea before its illegal annexation by the Russian Federation.
73 economic entities that used 1,292 sealed radionuclide radiation sources were found to be on the territory of separate districts in Donetsk and Luhansk oblasts (ORDLO) as a result of military aggression of the Russian Federation and military operations in the East of Ukraine in the absence of state regulatory control of nuclear and radiation safety. Namely, as of September 2014, 914 radionuclide radiation sources were in the occupied region in Donetsk oblast and 278 radionuclide radiation sources were on the territory of uncontrolled regions in Luhansk oblast…”, the SNRIU reported.
The State Nuclear Regulatory Inspectorate has no authority to present a detailed information at DT.UA request on potentially hazardous facilities that have been found on the uncontrolled territories of Ukraine because this information was made classified since January 2017 according to the resolution of the Cabinet of Ministers of Ukraine. SNRIU also does not have any access to these facilities; it receives only brief notifications from the responsible organizations. These notifications are with time fragmentary and less frequent, they do not even give any idea of the management of these hazardous facilities on the uncontrolled territory of Ukraine in ORDLO. However, even the intentions of the Ministry of Coal and Energy of the self-proclaimed “republic” to terminate water pumping completely and transfer the Yunkom mine with radiation facility into a state of “wet” temporary shutdown is of unbiased concern to experts. However, we are talking about only one facility…
Ukraine has lost control over the research reactor DR-100 of the Sevastopol National University of Nuclear Energy and Industry and the facilities of Donetsk SISP of UkrDo Radon. The infrastructure of the latter was damaged during military operations in the city of Donetsk.
Two more storage facilities on the territory of Donetsk, namely Vuhleizotop and Donetsk metallurgical plant storing about 500 sealed radionuclide radiation sources remained uncontrolled. The territory of the temporarily shut down radioactive waste storage facility of the Donetsk state chemical plant came under fire in 2014.
The fate of Donetsk Coal Energy Company and Luhanskvuhillia with more than 100 radiation sources of potential hazard category III is also unknown.
“There are “Grad” multiple launch rocket systems, but nevertheless you want to send people there?!”
The SNRIU stated in response to DT.UA request: “As a result of the military aggression by the Russian Federation in ORDLO and illegal annexation of the territory of the Autonomous Republic of Crimea, the State Nuclear Regulatory Inspectorate of Ukraine has temporarily lost regulatory control over radwaste management on these territories since 2014”.
According to the information provided by SNRIU press secretary Taras Kozulko to DT.UA, the authority applied in 2014 to the Security Service of Ukraine (SSU) with a request to provide an opportunity for inspectors to perform measurements near the radiation sources on the territory of the illegally annexed Crimea. According to him, the SSU answer was that they could not ensure safety of SNRIU inspectors.
According to T. Kozulko, a similar answer to the question on conducting inspections on ORDLO territory and at the facilities recovered by Ukraine was received in 2016, in particular, Luhansk international airport and Lugansk Aircraft Repair Plant: “There are “Grad” multiple launch rocket systems, but you want to send people there to check, if the radiation sources are damaged?”
The Cabinet adopted the resolution “On Approving the List of Settlements where the State Authorities Temporarily do not Exercise their Powers, and the List of Settlements Located on the Confrontation Line” in September 2014. However, the fate of people was left behind the Cabinet’s formulations. Three inspectors of the Southeast State Inspectorate for Nuclear and Radiation Safety who were three defenseless women in that situation were seized by separatists and thrown into a basement. They held them until volunteers, and especially U.S. representatives intervened. They ensured resettlement of these inspectors with their families to the city of Zaporizhzhya.
Nuclear status of non-nuclear state
Ukraine gained the non-nuclear status after the adoption of the law on joining the Treaty on the Non-Proliferation of Nuclear Weapons in 1994. A condition for the entry into force of this decision was to provide our country with guarantees of security and territorial integrity, which was implemented by the provisions of the Budapest Memorandum. Russia, Great Britain and the United States of America signed this Memorandum. Following to this law, Ukraine eliminated all nuclear weapons from its territory.
However, it is possible that the invaders have returned nuclear weapons to Ukraine after Crimea annexation in early 2016. According to People’s Deputy of Ukraine Mustafa Dzhemilev, six nuclear warheads are located on the territory of the peninsula.
“First of all, this is a gross violation of the Budapest Memorandum because Crimea is the legally the territory of Ukraine. Ukraine, having a non-nuclear status, became a nuclear state again. I appealed to the Ministry of Foreign Affairs of Ukraine, talked with many deputies saying that we need the assistance of the IAEA. Because this is a threat not only for Ukraine, but for the entire Black Sea region”, the leader of the Crimean Tatar people commented on the situation.
To the best of DT.UA knowledge, the information on deploying nuclear warheads in Crimea was not confirmed by official sources. However, the same sources inform that the former Soviet nuclear weapons storage facility in Feodosiya that was destroyed in the 90’s underwent a large-scale restoration and guards were deployed there.
The international community has recognized violation of the Budapest Memorandum with respect to Ukraine. This was stated by UN Secretary General, Ban Ki-Moon, in his speech at the Nuclear Security Summit held in The Hague on 24 March 2014. He noted that security safeguards were an important condition for Ukraine to join the Non-Proliferation Treaty (NPT), but their reliability was seriously undermined. The UN Secretary General pointed out that this would have negative consequences for both regional safety and the entire non-proliferation regime.
The International Court of Justice in The Hague will decide how much and in what way will Russia pay for violating the state sovereignty and borders of Ukraine.
Since 2017, the Russian-controlled management of the Sevastopol National University of Nuclear Energy and Industry repeatedly stated its intention to start up DR-100 research reactor seized by Moscow after the peninsula annexation. In 2014, all the property of the Crimean State Inspectorate for Nuclear and Radiation Safety was also passed into possession of the Russian Federation, but the communication with its employees and management lasted until September 2015. Since then, Ukraine cannot implement the state regulation of nuclear and radiation safety on the territory of Crimea.
The research reactor has been used for scientific purposes since 1967 for training of officers for the Navy and experts in the nuclear industry field. It was shut down due to the need to extend reactor life after its design life expiration in 2012.
In addition, the companies and hospitals that used devices and protective containers with depleted uranium at the time of the annexation are located on the territory of the ARC. Another six establishments used in their activity high-level radiation sources of the highest category I.
The state and fate of these establishments is unknown, because neither the university nor the enterprises and medical institutions report to the official Kyiv. However, the occupational government of the peninsula is not ashamed to send annually to the state institutions of the non-occupied Ukraine the invitations to participate in the so-called international scientific-practical conference on nuclear energy arranged by the Russians in Laspi, Sevastopol three years in a row…
The nuclear industry of Ukraine also suffered in the sense that after the annexation of the peninsula it lost a powerful training base for its specialists, namely the Sevastopol National University of Nuclear Energy and Industry. A question arose this year on renewing its activities in the city of Slavutych, but starting from nothing in a new place will be not easy.
ORDLO nuclear facilities or “scorched earth” tactics
The greatest risk in view of potential hazard are category I radiation sources with activity over 1000 Curie. Eight entities are responsible for their management, as well as SSE Donetsk SISP of UkrDo Radon.
The radiation safety situation of the entities using radiation sources on the uncontrolled territories has significantly worsened in 2015-2016. Illicit trafficking detector with build–in radiation source 133Ba at Izvarino checkpoint was destroyed. Radioisotope ice detector RIO-3A with built-in radiation source with radionuclide Sr-90 + Y-90 was burned in a plane in Donetsk airport. 15 radiation sources with Sr-90 + Y-90 radionuclide in RIO-3 installed in airplanes stored in separate premises of the Luhansk international airport and Luhansk Aircraft Repair Plant were destroyed.
As of October 2014, according to the State Agency of Ukraine on Exclusion Zone Management (SAEZ), the infrastructure of SSE Donetsk SISP was damaged as a result of military operations on the territory of Donetsk. According to a resolution of the Cabinet of Ministers of Ukraine, SAEZ issued a special order to relocate Donetsk SISP from the city of Donetsk to Dnipro to Dnipropetrovsk SISP site.
Unfortunately, the law enforcement bodies and the Ministry of Defense did not succeed in arranging safe transfer of the enterprise under the conditions of military operations. Therefore, the activities of Donetsk SISP were suspended in early 2015 until the end of the military operations. Radioactive waste was left in a temporary hangar storage facility in two containers. As of today, the service sector of the enterprise was transferred to SSE Dnipropetrovsk SISP.
Resulting from careful monitoring of the number of days since the beginning of the war, during which the military operations were conducted directly near several nuclear facilities on ORDLO territory, the figures are impressive (see Fig.). How can you not agree with the statement on the “scorched earth’ tactics used by the occupation forces?
Any activity related to nuclear and radiation facilities in Ukraine carried out by representatives of other countries or even by unlawful armed groups is illegal and poses a hazard for both the facilities and the public.
Moreover, it can be qualified as international nuclear terrorism. It also should be noted that neither the so-called DPR nor the so-called LPR have any legal or institutional rights to activities related to the management of radioactive waste or radioactive sources. Finally, there are no specialized institutions on ORDLO territory that could bear responsibility for them.
As mentioned above, the Ukrainian nuclear regulator does not have currently access to potentially hazardous facilities in the annexed Crimea and on the occupied territories of Donetsk and Luhansk oblasts. Who controls them and how, for what purpose are they used? There are many questions to be answered.
Let us summarize: the IAEA considers Ukraine to be an integral state that continues bearing responsibility for all nuclear facilities on its territory. The Ukrainian Foreign Ministry supports this position. The position of the Ministry of Foreign Affairs can be understood ass well since the loss of Ukraine’s authority over nuclear facilities on its territory will mean automatic delegation of this authority to the aggressor country.
Partly delegation of authority over certain facilities on the occupied territories to occupants will mean approaching the recognition of their jurisdiction on these territories.
There is also a human factor in addition to the political one. Nuclear facilities and radiation sources on the temporarily uncontrolled territories in Ukraine can be used to make a dirty bomb, contaminate drinking water, and devastate the environment primarily in Donbas. The occupation authorities can have irresponsible attitude towards such facilities, and this can have negative consequences for the public and environment on the territory both controlled and uncontrolled by the official Kyiv.
We should not be indifferent. Constant radiation control is required at the checkpoints on the boundary line and on the occupied territories. We have to provide Ukrainian experts with access to the high-risk facilities in ORDLO and Crimea to check their condition. After all, the State primarily means people, and citizens of Ukraine should not suffer from illegal and unlawful acts of the invaders.