The Norwegian Environmental Protection Association (NMF) demands that the covering and lifting of cargo must be deleted as environmental measures for U-864. Lifting is the only solution that must be investigated by the Expert Committee for U-864.
Facts: It is not allowed to establish a mixed and toxic "sea dump", covered with pure pulp. Such practice is a direct violation of the EEA Agreement's legal acts. Politicians must be aware that Norway is formally and materially obliged to implement in Norwegian law regulations that are included in the EEA Agreement's annexes, in the same way as directives. I recommend the Prime Minister and the Minister of Transport to familiarize themselves with the following:
- 2017/852 (Mercury Ordinance).
- 1999/31/EC (Landfill Directive).
- 2008/98/EC (Waste Directive).
- 2000/60/EC (Water Directive).
"Mercury Regulation 2017/852/EC". Article 13 allows the short-term storage of liquid mercury above ground level (not under water) in strictly regulated premises, until solidification (solid form) of the mercury has been carried out. The mercury can then be stored in solid form for a long time, but here too there are very strict requirements for storage on land.
"Landfill Directive 1999/31/EC". Article 5 does not allow liquid waste or explosives to be stored in a landfill. Circular economy is of central importance.
"Waste Directive 1998/98/EC". The directive regulates the type of waste landfill, sets requirements for the prevention of pollution to the environment, circular economy and controlled closure of landfills. Mixed waste is prohibited, and it is not permitted to cover unclean masses with clean masses. "Water Directive 2000/60/EC". The authorities' measures and/or permits can only result in an improved state of water quality, and not worsen it.
Conclusion:
Covering is deleted as an environmental measure for U-864
350,000 tonnes of man-made mercury are circulating in the air, water and soil. 67 tonnes in U-864 can be taken out of this accounting, and out of the global cycle. Covering the wreck is considered an illegal landfill for mercury in seawater.
Lifting cargo is deleted as an environmental measure for U-864
Removing the mercury bottles from the cargo keel at a depth of 150 meters is expensive, time-consuming and risky in terms of leaching of mercury into the marine environment. There is also a lot of other dangerous material in the wreck, including ammunition and torpedoes which also contain mercury. There is also hydraulic oil, compressed air cylinders and probably uranium oxide in the cargo. There may also be more mercury stored inside the submarine. Elevation of mercury from the cargo keel is thus not relevant as an environmental measure for U-864.
Raising the hull and clean-up is the only option as an environmental measure in the short and long term for U-864
Lifting of wrecks with protection against leakage, locating and digging up loose mercury bottles.
Excavate contaminated seabed (hotspots). The cargo keel on U-864 is in better condition than the one tested for rusting by DNV-GL on U-534. U-864 lies at an oxygen-poor depth (150 m), compared to U-534 (67 m) and the keel is buried in mud. This means that the keel is as good as new, and there is very little risk of raising the hull parts.
Investigate and order lifting
The Norwegian Environmental Protection Association (NMF) demands that the government-appointed expert committee for U-864 should only consider what comes to the table on the basis of tenders for lifting. It is not the committee's job to choose a method. The tenderer with the best concept gets the assignment, and the expert committee can quality-assure the lifting for the least possible contamination and minimization of leakage during a lifting operation.The report to the expert committee should result in a requirement specification for lifting, so that the process does not drag on for years.
NMF proposes a paid tender competition, where the 5 best get a sum, for example NOK 500,000.
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