March 3, 2022

Is Russia Committing an Environmental War Crime in Donbas?

A miner of the Kholodnaya Balka coal mine in the Donetsk region.
A miner of the Kholodnaya Balka coal mine in the Donetsk region.

Eight years of hybrid war focused on Ukraine’s Donbas region have made it very difficult to understand the conditions in which that part of Ukraine have lived since its de facto removal from Ukrainian national jurisdiction in 2014.

The multi-pronged Russian invasion that began on 24 February 2022 will only further distract attention from a problem that has been growing since 2014: the deterioration of infrastructure and the risks it poses to environmental safety in this highly industrialised region. The unpalatable fact is that these risks have now become critical, with attendant dangers not only for local inhabitants but adjacent Ukrainian localities and districts. Even if, by some miracle, Russia withdraws its forces from Ukraine tomorrow, including the Donbas itself, these environmental dangers will demand urgent attention from central Ukrainian authorities and the international community.

Evidence now suggests that Russia, together with its proxies in Donetsk and Luhansk, might have committed an environmental war crime in 2018, with unfolding consequences. The root of the problem lies in the flooding of the region’s Soviet era coal mines, one of which was a site for a nuclear explosion in 1979 that has polluted the groundwater with radiation.

Areas of Concern and Approaching Risks

As seen on the map below, the majority of these mines are located in the area occupied by so-called “People’s Republics” since 2014. According to recent data, there are 220 coal mines in the region, out of which 38 have been flooded while under the control of the Russian proxies.

Figure 1: Map of critical infrastructure in the Donbas region. Source: the official webpage of “The Donbas Environment Information System” run by the Ukrainian government and OSCE.


According to experts on the ground, uncontrolled flooding has led to a number of problems. Flooded mines are causing floods on the surface, earthquakes, explosive and toxic gas leakages, infrastructure damage, deteriorating soil quality and finally, surface and groundwater pollution.

Pollution of groundwater and surface water is of particular concern because many of these mines are full of hazardous chemicals and, in some cases, radioactive residues that dissolve in the water and leach into groundwater and rivers.

The situation in the mines began to deteriorate after 2014 when Russia launched its war in Ukraine, but the situation has become particularly critical since 2016, when separatists from the so-called “People’s Republic’s” decided to stop pumping water out of several mines, apparently for cost-saving reasons. The most critical of these were the “Rodina”, “Pervomaiska” and “Holubivska” mines, which contain toxic chemicals and are directly linked through hydrological underground connections to mines like “Zolote”, “Karbonit”, “Raduha” and “Hirska” on the other side of the front line.


Figure 2: “Waterflow from the ‘Holubivska’ to the ‘Hirska’ mine”. Source: Ministry of Reintegration of Temporarily Occupied Territories of Ukraine.


Figure 3: Flooding schema of the “Pervomaiskvuhillia” and neighbouring mines. Source: Ministry of Reintegration of Temporarily Occupied Territories of Ukraine.


As predicted by OSCE experts, the flooding of these mines resulted in a massive, uncontrolled influx of mine water into the hydrologically connected Zolote mine, which had to install emergency pumps to prevent the worst-case scenario in which the toxic mine water would have flooded approximately 6,000 hectares of land and made it impossible for some 80,000 people to remain in the cities of Kirovsk, Pervomaisk, Zolote, Hirske and Karbonitis.

However, since the Zolote mine was unable to cope with such an influx of water, it consequently discharged the water directly into the Komyshuvakha river, which is why the physical-chemical composition of the river’s water is significantly above normal now, according to Truth Hounds samples taken in April 2021. This is especially dangerous because water from smaller regional rivers such as Komyshuvakha ends up in the Seversky Donets reservoir, from which, according to the OSCE, 70% of Donetsk and 30% of Luhansk inhabitants receive their drinking water. According to the latest studies undertaken by hydrogeologist Evgeny Yakovlev from the National Academy of Sciences of Ukraine, “ninety percent of the water sampled outside the centralised supply system is not drinkable”. Furthermore, according to Serhii Ivaniuta, a chief consultant at the National Institute for Strategic Studies, the “pollution of reservoirs in the temporarily occupied territories of Donetsk and Luhansk regions poses an urgent threat to 300,000 inhabitants of the region”.

On social media, locals are already complaining that the water from the tap is strangely coloured, tastes like bleach and causes stomach aches and cramps. In addition, mainstream media have reported a number of landslides and subsidence and gas explosions in the basements of residential buildings, as the water accumulating in the mines weakens the soil and pushes flammable methane to the surface.

According to OSCE environmental expert Dmitry Averin, soil sedimentation can already be seen in Donetsk-Makiivka-Khartsyzsk, Toretsk-Horlovka-Yenakievo (close to Yunkom mine), Shakhtersk-Snezhne-Khrustalny and Dolzhansk, Sorokino and Zolote-Kadiyevka-Alch localities.

Most worrying, however, is the Yunkom mine (Klivazh Facility), in which a nuclear explosion was carried out in 1979. The express purpose of the explosion was to release poisonous and highly flammable methane from the ground in order to discharge the extant gas leakages from the soil. The blast, however, was a complete failure because the gas leaks continued. Moreover, the area around the radioactive ball, sealed by a glass shell that formed after the explosion, started to fill with water, so pumps had to be installed to avoid an environmental catastrophe. In 2018, however, the pumping was gradually stopped, and now the mine is flooded.

Experts interviewed by the BBC in September 2021 predicted that radioactive pollution would rise to the surface of the mine 8-12 years after the flooding and, in an additional 3 to 10 years, reach the Kalmius river and Seversky Donets reservoir. Furthermore, according to this prediction, the pollution could reach groundwater within as early as three years. Worryingly, however, according to unofficial measurements made in July 2020 by independent experts, “the total concentration of radionuclides in the aquifers of the surrounding area, within a distance of 5 km from the object” already succeeds dangerous levels for health with water measurements showing radionuclide level to be between 2060-3502 becquerels per kg. This figure cannot be officially confirmed because international organisations have been denied access to the site. Nevertheless, if it is true, it means that the radionuclides have already reached the surrounding waters, making them undrinkable and dangerous for the living organism. By comparison, when Sweden was measuring cesium-137 in the wild boars after the Chernobyl accident, the sales limit for meat was set at 1500 becquerels per kg while the Swedish Food Agency advised against eating the meat at all.

If officially confirmed, such damage to the environment constitutes a war crime under the Rome Statute art. 8 chp. 2 cls IV and is punishable under the ENMOD Convention.

In addition, under Article 91, “Responsibility 20”, point 3661 of the Additional Protocol to the Geneva Convention, a party that violates the above-mentioned conventions or their protocols and causes environmental damage must reimburse the beneficiary for the costs incurred if the damage is established. Moreover, as this situation involves nuclear pollution, Russia cannot pull its “green men did it” card either because, according to point 3661, it is “possible that a Party to the conflict could be liable to pay compensation even in a case where no particular violation of the rules of the Conventions and the Protocol, or of another rule of the law of armed conflict, can be imputed to it.”

Current Situation

According to Doctor of Technical Sciences, hydrogeologist Evgeny Yakovlev, at present, irreversible changes have already taken place, and the degree of further deterioration of the environment now depends on how long such conditions last. Yakovlev warns that “the longer the wait, the more lands will be very heavily flooded and the opportunities for agricultural activities will be minimised due to the high level of soil salination. According to Yakovlev’s estimates the quality of surface and groundwater will continue to degrade as well. And this will make it impossible to use it for drinking.”

Meanwhile, the so-called “People’s Republics” of Donetsk (DPR) and Luhansk (LPR) authorities together with Russia have been hiding the issue from public attention. In April 2018, The Ministry of Coal and Energy of the DPR, relying on the conclusions of Russian experts from the St. Petersburg Institute “Shakhtoproekt”, the federal “Gidrospetsgeologiya” and JSC “VNIMPI proekthnologiya” from Moscow, stated that it did not see any danger arising from mine flooding. In an interview in Deutsche Welle on 21 December 2021, a representative of the DPR stated in a similar fashion that “environmental degradation in the DPR, unlike the difficult environmental situation in modern Ukraine, is not taking place”. Nevertheless, according to the head of the Ukrainian delegation to the Trilateral Contact Group (TCG), Leonid Kravchuk, the Russian Federation was not willing to allow an OSCE eco-mission to visit the Temporarily Occupied Territories of Ukraine (TOTU) to observe the situation either.

According to a member of the Working Group on Economic Rehabilitation in the framework of the TCG interviewed for this article, who wished to remain anonymous due to the sensitivity of the issue, the ecological risks stemming from flooded coal mines in the Donbas region have been discussed for several years now. In summer 2021, TCG finally managed to establish an expert group with participation from Kyiv, Moscow, Donetsk and Lugansk, to consider potential measures to reduce risks. However, their observation area is limited to the vicinity of the Line of Contact (LoC). This limitation was imposed because the separatists did not want an inspection of the Yunkom mine, which is not located close to the LoC. Furthermore, as the Yunkom mine is considered to be a nuclear facility, the OSCE experts commissioned by the TCG would not be able to carry out the necessary inspections there anyway, as such inspection falls exclusively within the International Atomic Energy Agency’s (IAEA) remit.

According to Ukraine’s Defence Minister Alexey Reznikov, Ukraine has been calling for an IAEA observation mission for a long time, but Russia, which is de facto controlling the so-called “People’s Republics”, did not allow this to happen until December 2021 when IAEA-inspectors were able – at the IAEA’s request – to visit two facilities, one in Lugansk and one in Donetsk, through mediation work of the TCG. However, this visit did not lead to any change, as according to an interviewed member of the TCG, the experts were only taken to the two sites that the IAEA had visited regularly up to 2015. One of the sites visited was an oncological clinic in Luhansk and the second a metallurgical institute in Donetsk. One does not have to be a nuclear expert to understand that the pollution risks stemming from these facilities are not considerable.

Therefore, the issue is still germane, and the international community, led by the IAEA, should take this issue seriously, insofar as Russia and the titular Donetsk/Luhansk authorities clearly do not want to address it. The fact that Russia officially claims “responsibility for the lives of compatriots” living in TOTU, but in reality allows potentially catastrophic pollution to spread, is certainly something that people in Donbas and in Russia should hear about.

Possible Solutions

In the midst of today’s much wider war in Ukraine, there is little that can be done at present besides supporting Ukraine in every possible way. However, it should be kept in mind that the environmental situation is rapidly deteriorating for the local population on a daily basis, and it is quite possible that if nothing is done in the near future, the area will become partially or entirely uninhabitable. Furthermore, if the pollution reaches local rivers and lakes, it is only a matter of time before nuclear decay also contaminates other regions.

If the dangers posed by the latest Russian invasion can be contained or reversed, it might be possible — and, vitally important — to get IAEA experts on the scene. The formalities are secondary.

Thereafter, according to Dr Evgeny Yakovlev, it will be essential to ensure that an artesian water system is installed, a course also recommended by the EU Water Framework Directive. This would be the most sustainable way to supply pollution-free water. According to Yakovlev, there are currently two million cubic meters of artesian waters in the Donetsk region and four million in Luhansk, which means that already 50% of these reserves could provide the local population with safe drinking water for the near future. At the same time, the local population needs to be prepared for the likelihood of further deterioration in the form of landslides, floods and damage to infrastructure. In Dr Yakovlev’s view, this deterioration is inevitable.

Thirdly, according to the head of the energy department of the Ecodia Centre for Environmental Initiatives, Konstantin Krinitsky, some solutions to this problem could include purification of the water to make it safe for technical needs or for thermal power generation.

Regardless of the possible solutions, however, none of them is doable as long as Russia is waging war in Ukraine. For now, obviously the challenges of the current war must and will take precedence.


Views expressed in ICDS publications are those of the author(s).