A Scientist Listed 12 Comments On The Report Regarding The Radioactive Waste Repository In Belarus
- 4.07.2026, 14:46
Have the authorities published a simulation analysis?
Belarusian government agencies have published preliminary project documentation and environmental impact assessment materials for the radioactive waste disposal site. The document, approximately 300 pages long, is presented in the form of scanned images.
Radiation chemist Sergei Besarab, known for his criticism of design flaws at the BelNPP and the National Radioactive Waste Disposal Site, analyzed the material and formulated at least 12 comments on the report’s content.
According to the first comment, at the site in Khoyniki, Gomel Region, the specific activity of pine and birch branches was recorded at approximately 600 Bq/kg for cesium-137 and 200 Bq/kg for strontium-90. At the same time, the authors of the document classify logging waste as non-hazardous, and the recommended course of action is to transfer the timber to third-party organizations for further use.
Transferring contaminated timber to third-party commercial organizations poses the risk of it appearing on the market in the form of firewood, pellets, or lumber. As a result, the radionuclides bound in the wood become mobile and will sooner or later accumulate in the human body.
The second point notes that during the decontamination of equipment and containers, chemicals are used—Trilon B, citric acid, EDTA—that are capable of binding plutonium, americium, and uranium ions into soluble compounds. According to Besarab, this may increase the mobility of these elements in the soil when the effluents seep into the ground.
In fact, the use of complexing agents renders the clay barrier (arguably the main “containment mechanism” for radionuclide leaks from storage facilities) completely useless and accelerates the penetration of plutonium and uranium into aquifers by a factor of hundreds.
The third observation concerns the discrepancy between the facility’s name and its actual purpose: despite the definition of a “near-surface disposal site,” the master plan includes modules buried up to 5.5 meters deep, a site for spent nuclear fuel reprocessing waste, and a complex with evaporation and incineration facilities.
This is an example of a deliberate substitution of terms, where people are being “sold” what is in fact a nuclear-chemical industrial complex under the guise of “just a landfill.” This is done to simplify the regulatory review process, lower the environmental hazard classification, and minimize the sanitary protection zone around the facility.
The fourth point states that the long-term safety calculations were performed by the Russian organizations JSC “TVEL” and JSC “CPTI,” while the Belarusian institutes—OIYAEI-Sosny, TsNIIKIVR, and “Belnipienergoprom”—participated only in surveying work, without conducting independent calculations.
According to IAEA protocols, this situation is referred to as a direct conflict of interest. The legal provision establishes that there will be a complete absence of independent Belarusian verification of the calculations during the construction of the facility.
The fifth observation concerns the design-basis accident calculation—the crash of a 400-metric-ton aircraft with 70 metric tons of jet fuel igniting above the disposal cells. According to the report, the annual dose for the population at a distance of 100 meters will be 0.71 mSv, which is below the standard of 1 mSv per year.
Besarab points out that the methodology does not account for the possible destruction of ventilation filters during a fire of such intensity. A simulated fire resulting in the destruction of the ventilation system would generate a radioactive cloud with enormous radiation doses, requiring the immediate evacuation of people; therefore, the emission figures are underestimated by 4–6 orders of magnitude.
The sixth point provides data on the time it takes for contamination to be transported via groundwater: for the site in Mstislavl to the Chernaya Natopa River—5.8–6 years; for the site in Ostrovets to the Gozovka River—14.5 years. All remarks about the “reliability of clay” in one paragraph are completely undermined by mutually exclusive arguments about “sand lenses that allow water to pass through at a rate of 19 cubic meters per day” in another paragraph.
The seventh comment concerns the combination of different categories of waste in a single project, including the temporary storage of high-level waste from fuel reprocessing. At the same time, according to Besarab, the document does not contain a decision regarding their subsequent final disposal.
According to all international standards (IAEA basic regulations SSR-5 and GSG-1), the disposal of high-level waste in near-surface repositories is prohibited; it is permitted only in deep mines.
Paragraph 8 notes that the design life of the protective containers is set at 300 years, and that of concrete structures is 100 years, whereas some of the isotopes on the inventory list, including iodine-129, have half-lives of up to 15.7 million years. Moreover, both I-129 and Tc-99 are present in the waste in the form of anions, which neither clay nor concrete can retain; as soon as the stainless steel of the container cracked, everything leaked into the rivers.
The ninth observation concerns the methodology for hydrodynamic calculations, which, according to Besarab, is based on climate norms from the last century without taking into account modern climate change. This fails to account for the current realities of global climate change and the series of extreme weather events that have been increasingly hitting Belarus in recent years.
The tenth point points out the absence in the report of a section on the radiolysis of water in waste matrices—a process capable of leading to the accumulation of hydrogen inside the containers. The accumulated hydrogen will cause the container shells to rupture explosively.
The tenth point notes the absence in the report of a section on the radiolysis of water in waste matrices—a process that can lead to the accumulation of hydrogen inside the containers. The accumulated hydrogen will cause the container shells to rupture explosively.
The eleventh comment concerns the public consultation procedure: according to the Telegram channel “Gomelski Flagshtok,” cited by Besarab, the hearings were held behind closed doors, exclusively for administrative staff.
The closed format of the public hearings renders the EIA legally null and void (invalidates it) before international UN bodies, in accordance with, for example, Article 6 of the ESPOO Convention and the Aarhus Convention (from which Belarus withdrew in 2022).
The twelfth comment concerns the site selection procedure. According to IAEA recommendations, the selection process should include a stage of identifying a preferred and an alternative site. In our case, it is proposed that the Council of Ministers make a decision from among three options without prior professional screening.
In other words, the expert organizations that compiled the report are shifting the criminal and environmental liability for a future catastrophic decision onto the Council of Ministers.
Overall, Sergei Besarab characterized the report as a simulation analysis.
As a reminder, the project concerns a radioactive waste disposal site, for which sites in Khoyniki, Mstislavl, and Ostrovets, among others, are being considered.
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