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Depleted uranium exports to Russia are not a ”resource” – they are radioactive waste

Our conclusion is that this form of TENORM (technically enhanced naturally occurring radioactive material) should be considered in principle as a waste material, for which full transparency should be assured over its complete chain of management,

DU Exports to Russia – A case of lack of transparency and research Nuclear Transparency Watch By Jan Haverkamp (Greenpeace, WISE) December 21,

From 1996, the uranium enrichment facilities URENCO Almelo (Netherlands) and URENCO Gronau (Germany) regularly sent shipments of depleted uranium (DU) in the form of UF6 (uranium hexafluoride) to TENEX, later TVEL, in Russia, where this was stored in the open air in Seversk in the Krasnoyarsk region. Protests in Europe then halted these transports in 2009. TVEL is since 2007 a subsidiary of the Russian nuclear giant Rosatom. URENCO carries out enrichment for nuclear fuel production from natural uranium to low-enriched uranium for clients all over the world and has facilities in the Netherlands, Germany and the UK.

In 2019 and 2020, these transports were resumed from the enrichment facility of URENCO Gronau and URENCO UK in Capenhurst.

URENCO Almelo currently has a permit for export, but does not use it. Its DU is sent to France for conversion into stable U3O8 (depleted tri-uranium-octo-oxide or uranium oxide), which is returned to the Netherlands and handed over to the waste management organisation COVRA for interim storage in the VOG facility, awaiting final disposal after 2100.

The claim is that the DU is sent to TENEX, later TVEL, for re-enrichment to natural level and reuse of the resulting double depleted uranium (DDU). Rosatom furthermore claims[2] that DDU and DU are used industrially and that the UF6 also delivers fluorine for reuse purposes. It furthermore, describes in detail how it wants to convert its UF6 stockpile into uranium oxide for waste treatment before 2057.

Our conclusion is that this form of TENORM (technically enhanced naturally occurring radioactive material) should be considered in principle as a waste material, for which full transparency should be assured over its complete chain of management, also when a limited amount of the material may be used as resource. Research on optimization of the management pathways should be part of European research programmes like EURAD.

Our central observations are:

  • The involved DU is in Russia not a resource in the sense of sustainable recycling – that is, it is not 100%, nor for a majority of it, recycled and reused.
  • The ownership structure of this export of DU to Russia hides this fact. Rosatom / TVEL has taken ownership of the material after export and with that, the material is out of sight of URENCO, its hosting EU Member State (MS) Germany, and of Euratom. It is today impossible for Euratom, Germany or URENCO to confirm whether the material is indeed reused in any form or not.
  • Resulting radioactive waste from any management operation should be returned to the country of origin (as happens in the case of reprocessing of spent nuclear fuel). This does not happen in this case.
  • Material that is not reused or recycled within a reasonable timeframe constitutes waste and has to be treated as such from the start. It falls under radioactive waste as defined in 2011/70/Euratom and the treatment of DU – whether within or outside the Union – should be considered as waste management.
  • This implies that there should be a clear description of incurred streams of all treatment pathways in line with 2011/70/Euratom – and decisions on these treatment pathways should all be based on 2011/70/Euratom and complete knowledge of these pathways, irrespective of whether this treatment takes place within the Union or outside.
  • Law and transparencyThere is no transparency about the pathways of management of the DU exported by URENCO to Russia. There are claims of reuse on the Russian side,[3] but there are no clear descriptions of streams and involved amounts.

The Euratom radioactive waste directive defines radioactive waste as: “radioactive material in gaseous, liquid or solid form for which no further use is foreseen or considered by the Member State or by a legal or natural person whose decision is accepted by the Member State, and which is regulated as radioactive waste by a competent regulatory authority under the legislative and regulatory framework of the Member State;” (art. 3(7) 2011/70/EURATOM).

Article 4(2) of the directive states: “Where radioactive waste or spent fuel is shipped for processing or reprocessing to a Member State or a third country, the ultimate responsibility for the safe and responsible disposal of those materials, including any waste as a by-product, shall remain with the Member State or third country from which the radioactive material was shipped”.

Article 4(4) of the directive explains in more detail: “Radioactive waste shall be disposed of in the Member State in which it was generated, unless at the time of shipment an agreement, taking into account the criteria established by the Commission in accordance with Article 16(2) of Directive 2006/117/Euratom, has entered into force between the Member State concerned and another Member State or a third country to use a disposal facility in one of them.

Prior to a shipment to a third country, the exporting Member State shall inform the Commission of the content of any such agreement and take reasonable measures to be assured that:

(a) the country of destination has concluded an agreement with the Community covering spent fuel and radioactive waste management or is a party to the Joint Convention on the Safety of Spent Fuel Management and on the Safety of Radioactive Waste Management (‘the Joint Convention’);

(b) the country of destination has radioactive waste management and disposal programmes with objectives representing a high level of safety equivalent to those established by this Directive; and

(c) the disposal facility in the country of destination is authorised for the radioactive waste to be shipped, is operating prior to the shipment, and is managed in accordance with the requirements set down in the radioactive waste management and disposal programme of that country of destination.”

Furthermore, the Euratom directive obliges in art. 10 transparency concerning radioactive waste.

In Russian law, the definition of radioactive waste is “materials and substances not subject to further use, and equipment, articles (including spent ionizing radiation sources), in which the content of radionuclides exceeds the levels established in accordance with the criteria defined by the Government of the Russian Federation” (clause 8, article 3).[4] This is a much more shady definition, whereby the issue of responsibilities for waste material and waste as by-product are not defined. It may therefore well be that where there is responsibility for exported DU for the state of origin under 2011/70/Euratom, there is none under Russian law.

Transfer of ownership and responsibility

In the current set-up, ownership of this TENORM is transferred from URENCO to TVEL / Rosatom. Nevertheless, 2011/70/EURATOM stipulates that “the ultimate responsibility for the safe and responsible disposal of those materials, including any waste as a by-product, shall remain with the Member State or third country from which the radioactive material was shipped”. Logically, because URENCO Gronau does not reuse this material, for URENCO Gronau and Germany, this depleted uranium in the form of UF6 is a waste material for which it has ultimate responsibility – also when others claim (but not prove in the form of accountable and accounted for pathways) use as resource. After all, ‘ultimate responsibility’ when the material is (partially) not reused in any way but ends de facto as waste, can never be shed. This has several consequences:

The transfer of ownership does not release the Member State from which the material was shipped (e.g., Germany) from its ultimate responsibility for the depleted uranium and waste as by-product when it is not actually reused;……………………………………………….

URENCO DU is waste

The production of TENORM waste in the EU delivers still poorly researched long-term issues. The fact that part of this TENORM is transferred outside of the EU only further complicates the situation, but should in essence not change the ‘ultimate responsibility’ of Euratom Member States (2011/70/EURATOM art. 4(2)) for proper handling and disposal of this radioactive material that appears as waste from industrial processes within the European Union. Especially the longevity and toxicity of the material (with a half-life of uranium-238 of 4.5 billion years) urges for research into proper disposal of this material, when it de facto will not be further used.

This is especially relevant for the exported depleted uranium from URENCO to Russia. There is currently no transparency about whether any fraction of this material is actually de facto reused, what happens with the remaining fraction in case it is reused, and which proper handling and deposition methods must be found and optimised. Also, when this material has to be considered as waste (as we argue), or certain fractions of it, repatriation of resulting wastes after processing needs to be taken into account, as well as handling methods that should be in place. 

Given the fact that this DU will in Russia either be demobilised as uranium oxide before 2057 and stored for an unspecified multi-generational time, or for a tiny fraction reused under the production of radioactive wastes as by-product, we argue that the status of this from the EU to Russia exported DU should by default be that of waste

December 24, 2021 - Posted by | depleted uranium, Russia, wastes

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